Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`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. 6,587,744 (“Stoddard”). To the extent that Stoddard is found not to anticipate one or
`more of the claims of the ’691 Patent, those claims are obvious in view of Stoddard, 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 Stoddard
`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 Stoddard alone or in combination with other prior art
`renders the ’691 Patent invalid.
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`1[p]
`
`A method, comprising:
`
`152515573.1
`
`Defendant does not concede that the preamble is limiting. To the extent
`it is limiting, see, e.g.:
`
`Stoddard at Abstract: “A automated run-to-run controller for controlling
`manufacturing processes comprises set of processing tools, a set of
`metrology tools for taking metrology measurements from the processing
`tools, and a supervising station for managing and controlling the
`processing tools. The supervising station comprises an interface for
`receiving metrology data from the metrology tools and a number of
`variable parameter tables, one for each of the processing tools,
`collectively associated with a manufacturing process recipe. The
`supervising station also includes one or more internal models which
`relate received metrology data to one or more variables for a processing
`tool, and which can modify variables stored in the variable parameter
`table to control the process tools using feedback and/or feed-forward
`control algorithms. Feed-forward control algorithms may, in certain
`embodiments, be used to adjust process targets for closed loop feedback
`
`- 1 -
`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`1[a]
`
`collecting metrology data related to the
`processing of workpieces in a plurality of
`tools;
`
`control. The supervising station may have a user interface by which
`different feedback or feed-forward model formats (single or multi-
`variate) may be interactively selected based upon experimental or
`predicted behavior of the system, and may also permit users to utilize
`their own models for run-to-run control.”
`
`Stoddard at 1:15-19: “The field of the present invention pertains to
`microelectronic circuit fabrication and, more particularly, to methods
`and apparatus for controlling microelectronic circuit fabrication
`processes.”
`
`See 1[a], 1[b], 1[c], and 1[d].
`
`See, e.g.:
`
`Stoddard at 2:19-35: “In one embodiment, an advanced run-to-run
`controller for controlling manufacturing processes comprises set of
`processing tools, a set of metrology tools for taking metrology
`measurements from the processing tools, and a supervising station for
`managing and controlling the processing tools. The supervising station
`comprises an interface for receiving metrology data from the metrology
`tools and a number of variable parameter tables, one for each of the
`processing tools, collectively associated with a manufacturing process
`recipe. The supervising station also includes one or more internal
`models which relate received metrology data to one or more variables
`for a processing tool, and which can modify variables stored in the
`variable parameter table to control the process tools using feedback
`
`152515573.1
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`IPR2021-01348
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`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`and/or feed-forward control algorithms. Feed-forward control algorithms
`may, in certain embodiments, be used to adjust process targets for closed
`loop feedback control.”
`
`Stoddard at 5:16-6:67: “Further details will now be set forth concerning
`metrology acquisition, storage and maintenance, after which will be
`described further details concerning run-to-run control using the
`metrology data.
`
`The acquisition of metrology data (i.e., process measurements) can be
`difficult for a variety of reasons. For example, the particular metrology
`measurement unit may not have external communication. In such
`instances, manual entry of the process results must be undertaken.
`Manual entry, however, is tedious, highly susceptible to data entry
`errors, and not the preferred manner of obtaining metrology information
`in the system. Another obstacle with implementing such a system is the
`acquisition of the process measurements in a timely manner. It may be
`anywhere from an hour to several days before the results from the latest
`run are obtained or are otherwise made available to the ESW. Since each
`fabrication facility stores and analyzes the process results in a different
`way, it can be quite challenging to provide a standard interface to
`acquire this information without writing special code for each customer.
`The software architecture illustrated in FIG. 2 is designed to overcome
`or mitigate the above obstacles. A description of each of the functional
`modules, as they relate to metrology acquisition, storage, and
`maintenance, follows below.
`
`152515573.1
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`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`With reference to FIG. 2, a Metrology Broker 70 is used to manage all
`of the metrology acquisition requests provided by an ARRC Controller
`75. Each metrology acquisition request from the ARRC Controller 75 is
`associated with a metrology map defining the method of acquiring the
`metrology results. Once the metrology information is acquired, it is
`stored in a Metrology Database 85 along with the Date, Time, Tool,
`MiniSpec, Lot ID and Run Number. The requesting ARRC Controller
`75 will also be notified of the acquisition of the metrology results when
`it occurs.
`
`The metrology map is the vehicle that allows the user to define the
`method of acquiring the process measurements as well as the format in
`which they are presented. The user can define the number of wafers and
`sites (process measurement locations) and define more specific names
`for the metrology points.
`
`Various automated methods of obtaining process measurement results
`may be used and defined in the metrology map. With reference to FIG.
`2, the automated methods include, for example, the following:
`
`GEM Interface 90—A standardized GEM interface may be provided to
`transfer the process measurements into a high performance database and
`to provide the measurements to the ARRC system. This method
`generally requires that the users at the fabrication facility write custom
`code to interface their process measurement database to a supervisory
`workstation, such as an ESW.
`
`152515573.1
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`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`CIM Framework (CORBA Interface) 95—This interface is provided for
`customers with process measurement tools or a SPC database that is
`compliant with Sematech's APC Framework. For the CIM Framework
`95, the ESW 30 subscribes to a CORBA object to automatically obtain
`the process measurements as they are measured.
`
`ESW Metrology Tool Interface 100—This interface is provided for
`users at fabrication facilities who wish to connect an ESW directly to the
`metrology tool for the purpose of run-to-run control.
`
`SMC Result—This interface allows linkage to a Statistical Machine
`Control application which provides automated fault detection using the
`equipment real-time measurements. Calculations from this application
`may generally be provided to the ARRC system as measurements from
`real-time sensors.
`
`In addition to the foregoing automatic metrological acquisition methods,
`the ARRC system may also employ a Manual Metrology Entry interface
`105. Here, a user interface is provided to manually enter the process
`measurements of the metrology tool for fabrication facilities that do not
`have a centralized SPC database or that have process measurement tools
`without external communication capabilities. Although not generally the
`most efficient manner of acquiring metrology data, this functionality is
`especially useful for users who wish to validate the functionality of the
`ARRC system without committing resources to code a GEM or CORBA
`compliant interface to establish a link with the metrology tools or SPC
`database.
`
`152515573.1
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`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Preferably, the Manual Metrology Entry interface 105 allows the user to
`select an open metrology request and then enter new data, preferably in
`a Unix® environment. The user interface window preferably contains a
`scrollable list of open metrology requests and displays the following
`information about each request: date, time, tool, lot ID, and recipe name.
`Because there may be a multitude of open metrology requests, the
`following three fields may be used to narrow the search: tool, recipe
`name and lot ID. Any name or portion of a name followed by an asterisk
`can be entered to automatically filter the available selections. After all
`metrology values have been entered for a particular request, the ARRC
`Controller 75 will be notified of the acquisition of the data and can
`process the data accordingly.
`
`Metrology Database 85 is preferably in the form of a proprietary, flat
`file database, although other database structures (e.g., relational
`databases) may be used instead. The Metrology Database 85 is used to
`store and maintain the process measurement results. These values are
`generally not stored in the standard database of the ESW 30 since often
`it is necessary to store measurement information on the order of ten
`times longer than the real-time process data stored in the standard ESW
`database. An abundance of process measurements should preferably be
`made available for statistical analysis of the process and for allowing
`robust modeling of the process. Separate database clean up and
`maintenance operations may also be provided for the Metrology
`Database 85.
`
`152515573.1
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Each ESW 30 may comprise an equipment supervisory workstation of
`the type such as available from SEMY Engineering, Inc., of Phoenix,
`Ariz. Integrating run-to-run functionality in such a workstation may
`require the addition of several hooks to the existing ESW software.
`Implementation is preferably achieved by associating run-to-run control
`methods 110 to values defined in the VPT. This association process
`allows the user to define adjustable variables in the recipe for each
`individual tool.”
`
`Stoddard at 7:33-37: “Data Collection—this mode is used to acquire
`only the process measurement data which is required for a feed-forward
`process where the upstream process tool is connected to an ESW and
`does not have a feedback controller defined.”
`
`Stoddard at 7:50-65: “As previously indicated, a number of means are
`available for the acquisition of metrology data and the generation of
`metrology maps. By way of example, automated methods of obtaining
`process measurement results include use of a standardized GEM
`Interface 90, a CIM Framework (CORBA) Interface 95, or an ESW
`Metrology Tool Interface 100. Also, the ARRC system may also employ
`a Manual Metrology Entry interface 105. The information from these
`metrology acquisition techniques is supplied to a set of metrology maps
`205, which, as noted, are the vehicles which allow the user to define the
`method of acquiring the process measurements, as well as the format in
`which they are presented. Using the metrology maps 205, the user can,
`for example, define the number of wafers and sites (process
`
`152515573.1
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`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`measurement locations) and define more specific names for the
`metrology points.”
`
`Stoddard at 3:13-20: “One embodiment of a processing platform
`architecture that may be used to implement the disclosed ARRC system
`is set forth in FIG. 1A. In the illustrated embodiment, the platform
`architecture, shown generally at 20, is comprised of a Fabrication
`Supervisor Workstation (FSW) 25, one or more Equipment Supervisor
`Workstations (ESW) 30, one or more processing tools 35, and one or
`more metrology tools 40. The metrology tools 40 may either be in-situ
`or ex-situ in nature.”
`
`Stoddard at 3:30-30: “An equipment tool set is shown generally at 45 of
`FIG. 1A. The equipment tool set 45 includes one or more processing
`tools 35 that are connected for bilateral communication with a common
`ESW 30. Processing tools 35 are generally of the same type. For
`example, all of the processing tools 35 may be furnaces. However, it
`will be recognized that processing tools 35 may include different tool
`types which be grouped based upon the type of processes that are to be
`executed upon the workpieces to fabricate the end products.”
`
`Stoddard at 11:50-12:34: “FIG. 8 is a process flow diagram illustrating
`the run-to-run control process of FIGS. 6A and 6B from an alternative
`perspective. In the run-to-run process 800 depicted in FIG. 8, both feed-
`forward and feedback control may be utilized to control the operation of
`a process tool (designated Process Tool B in FIG. 8). In a first step 801
`in the run-to-run process 800, a first process tool (designated Process
`Tool A) performs processing according to the process variables
`- 8 -
`
`152515573.1
`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`downloaded to the tool from the Variable Parameter Table (VPT)
`associated with the particular recipe. In a next step 802, a first metrology
`tool (designated Metrology Tool A) measures the appropriate output of
`Process Tool A, depending upon its nature. The measurements from
`Metrology Tool A are collected in step 803, according, for example, to
`any of the metrology acquisition methods previously described with
`reference to FIGS. 6A and 6B. In a next step 804, the process control
`points (i.e., target) for the upcoming feed-forward and/or feedback run-
`to-run algorithms are set, based upon the information stored in the
`metrology maps. In the following step 805, the selected feed-forward
`control algorithm is applied by the ESW 30, resulting in feed-forward
`control model outputs. These outputs are used to adjust the process
`targets, in step 806, for the upcoming feedback control algorithm. In one
`aspect, the feed-forward control algorithm provides the capability of
`generating a “variable” process target for a process controlled by a
`closed-loop feedback control loop.
`
`Once the process targets have been adjusted based on the outputs of the
`feed-forward control algorithm, the feedback control algorithm of the
`run-to-run controller may be applied in step 807. In a next step 808, the
`process variables or parameters for the recipe are adjusted in the variable
`parameter table (VPT), and the updated variables or parameters are
`downloaded to Process Tool B. In step 809, Process Tool B performs its
`assigned task(s) utilizing the variables or parameters associated with the
`process recipe. In a next step 809, a second metrology tool (designated
`Metrology Tool B) is used to measure the appropriate output of
`Metrology Tool B, depending upon its nature. The metrology data from
`
`152515573.1
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`
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`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Metrology Tool B is acquired in a next step 811, according, for example,
`to any of the metrology acquisition methods previously described herein.
`Based upon the acquired metrology data, the process control points for
`the feedback control algorithm are adjusted in step 812. The closed-loop
`feedback control process then returns to step 807, wherein the feedback
`control algorithm is applied again. The feedback control algorithm
`continues to control the process target(s) for Process Tool B in a closed-
`loop fashion, but periodically the process target(s) may be adjusted
`based upon the measured output(s) of Process Tool A, and the feed-
`forward control algorithm depicted in step 805 of FIG. 8.”
`
`Stoddard at claim 1: “1. A run-to-run control system for controlling
`manufacturing processes, comprising:
`
`a plurality of processing tools;
`
`a plurality of metrology tools for monitoring operation of said
`processing tools each metrology tool adapted to obtain metrology data
`from a corresponding processing tool;”
`
`Stoddard at claim 38-43: “38. A method of controlling a manufacturing
`process, comprising the steps of:
`
`(a) obtaining metrology data from a first metrology tool with respect to a
`first processing tool;
`
`(b) applying said metrology data to a first model structure relating said
`metrology data to a target set-point for a second processing tool and
`
`152515573.1
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`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`using a second model structure to control operation of the second
`processing tool in a feed-back control loop;
`
`(c) modifying one or more variables in a variable parameter table for
`said second processing tool in response to application of the first model
`structure to the received metrology data;
`
`(d) downloading said one or more modified variables to said second
`processing tool;
`
`(e) operating said second processing tool in accordance with said
`downloaded variables.
`
`39. The method of claim 38, wherein steps (a) through (e) are repeated
`to effectuate run-to-run control of the manufacturing process.
`
`40. The method of claim 39, further comprising the steps of:
`
`obtaining metrology data from a second metrology tool with respect to
`said second processing tool;
`
`applying said metrology data from said second metrology tool to a
`second model structure relating said metrology data from said second
`metrology tool to said target set-point for said second processing tool;
`and
`
`modifying one or more variables in said variable parameter table for said
`second processing tool.
`
`152515573.1
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`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`41. The method of claim 40, wherein said step of applying said
`metrology data from said second metrology tool to said second model
`structure comprises the step of applying said metrology data from said
`second metrology tool to a feedback model.
`
`42. The method of claim 40, further comprising the step of selecting, via
`a user interface, a model formats from among a plurality of model
`formats from which said second model structure is generated.
`
`43. The method of claim 42, wherein said plurality of model formats
`comprise a linear model format, a quadratic model format and a cubic
`model format.”
`
`See also 2:19-25, 4:15-22.
`
`152515573.1
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`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`Stoddard at Fig. 1A:
`
`
`
`
`152515573.1
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`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`Stoddard at Fig. 1B:
`
`
`
`
`152515573.1
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`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`Stoddard at Fig. 2:
`
`
`
`
`152515573.1
`
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`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Stoddard at Fig. 5:
`
`
`
`
`152515573.1
`
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`
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`

`

`ELEMENT
`NO.
`
`1[b]
`
`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`generating context data for the metrology
`data, the context data including collection
`purpose data;
`
`See, e.g.:
`
`Stoddard at 5:40-50: “With reference to FIG. 2, a Metrology Broker 70
`is used to manage all of the metrology acquisition requests provided by
`an ARRC Controller 75. Each metrology acquisition request from the
`ARRC Controller 75 is associated with a metrology map defining the
`method of acquiring the metrology results. Once the metrology
`information is acquired, it is stored in a Metrology Database 85 along
`with the Date, Time, Tool, MiniSpec, Lot ID and Run Number. The
`requesting ARRC Controller 75 will also be notified of the acquisition
`of the metrology results when it occurs.”
`
`Stoddard at 2:19-35: “In one embodiment, an advanced run-to-run
`controller for controlling manufacturing processes comprises set of
`processing tools, a set of metrology tools for taking metrology
`measurements from the processing tools, and a supervising station for
`managing and controlling the processing tools. The supervising station
`comprises an interface for receiving metrology data from the metrology
`tools and a number of variable parameter tables, one for each of the
`processing tools, collectively associated with a manufacturing process
`recipe. The supervising station also includes one or more internal
`models which relate received metrology data to one or more variables
`for a processing tool, and which can modify variables stored in the
`variable parameter table to control the process tools using feedback
`and/or feed-forward control algorithms. Feed-forward control algorithms
`may, in certain embodiments, be used to adjust process targets for closed
`loop feedback control.”
`
`152515573.1
`
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`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Stoddard at 3:53-65: “the ESW 30 includes a Variable Parameter Table
`(VPT) associated with each of the processing tools 35, as illustrated, for
`example, in FIG. 5. The VPT 37 includes the parameters that are used in
`the execution of a processing recipe by a given processing tool. The
`parameters of the VPT 37 are based on the particular characteristics of
`the associated tool 35 and, as such, will frequently differ between the
`tools of the same type. In general, each fabrication process is comprised
`of one or more recipes (one recipe per process step), and each recipe will
`involve one or more processing tools 35, each processing tool 35 having
`a VPT 37 for all of the process recipes.”
`
`Stoddard at 11:50-12:34: “FIG. 8 is a process flow diagram illustrating
`the run-to-run control process of FIGS. 6A and 6B from an alternative
`perspective. In the run-to-run process 800 depicted in FIG. 8, both feed-
`forward and feedback control may be utilized to control the operation of
`a process tool (designated Process Tool B in FIG. 8). In a first step 801
`in the run-to-run process 800, a first process tool (designated Process
`Tool A) performs processing according to the process variables
`downloaded to the tool from the Variable Parameter Table (VPT)
`associated with the particular recipe. In a next step 802, a first metrology
`tool (designated Metrology Tool A) measures the appropriate output of
`Process Tool A, depending upon its nature. The measurements from
`Metrology Tool A are collected in step 803, according, for example, to
`any of the metrology acquisition methods previously described with
`reference to FIGS. 6A and 6B. In a next step 804, the process control
`points (i.e., target) for the upcoming feed-forward and/or feedback run-
`to-run algorithms are set, based upon the information stored in the
`
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`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`metrology maps. In the following step 805, the selected feed-forward
`control algorithm is applied by the ESW 30, resulting in feed-forward
`control model outputs. These outputs are used to adjust the process
`targets, in step 806, for the upcoming feedback control algorithm. In one
`aspect, the feed-forward control algorithm provides the capability of
`generating a “variable” process target for a process controlled by a
`closed-loop feedback control loop.
`
`Once the process targets have been adjusted based on the outputs of the
`feed-forward control algorithm, the feedback control algorithm of the
`run-to-run controller may be applied in step 807. In a next step 808, the
`process variables or parameters for the recipe are adjusted in the variable
`parameter table (VPT), and the updated variables or parameters are
`downloaded to Process Tool B. In step 809, Process Tool B performs its
`assigned task(s) utilizing the variables or parameters associated with the
`process recipe. In a next step 809, a second metrology tool (designated
`Metrology Tool B) is used to measure the appropriate output of
`Metrology Tool B, depending upon its nature. The metrology data from
`Metrology Tool B is acquired in a next step 811, according, for example,
`to any of the metrology acquisition methods previously described herein.
`Based upon the acquired metrology data, the process control points for
`the feedback control algorithm are adjusted in step 812. The closed-loop
`feedback control process then returns to step 807, wherein the feedback
`control algorithm is applied again. The feedback control algorithm
`continues to control the process target(s) for Process Tool B in a closed-
`loop fashion, but periodically the process target(s) may be adjusted
`
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`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`based upon the measured output(s) of Process Tool A, and the feed-
`forward control algorithm depicted in step 805 of FIG. 8.”
`
`Stoddard at 5:40-50: “With reference to FIG. 2, a Metrology Broker 70
`is used to manage all of the metrology acquisition requests provided by
`an ARRC Controller 75. Each metrology acquisition request from the
`ARRC Controller 75 is associated with a metrology map defining the
`method of acquiring the metrology results. Once the metrology
`information is acquired, it is stored in a Metrology Database 85 along
`with the Date, Time, Tool, MiniSpec, Lot ID and Run Number. The
`requesting ARRC Controller 75 will also be notified of the acquisition
`of the metrology results when it occurs.”
`
`Stoddard at claim 1: “1. A run-to-run control system for controlling
`manufacturing processes, comprising:
`
`***
`
`a plurality of variable parameter tables, one for each of said processing
`tools, stored in said memory, said variable parameter tables collectively
`associated with a manufacturing process or recipe, each variable
`parameter table being downloaded to a respective processing tool prior
`to operation of the respective processing tool;”
`
`Stoddard at claim 38-43: “38. A method of controlling a manufacturing
`process, comprising the steps of:
`
`152515573.1
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`- 20 -
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`(a) obtaining metrology data from a first metrology tool with respect to a
`first processing tool;
`
`(b) applying said metrology data to a first model structure relating said
`metrology data to a target set-point for a second processing tool and
`using a second model structure to control operation of the second
`processing tool in a feed-back control loop;
`
`(c) modifying one or more variables in a variable parameter table for
`said second processing tool in response to application of the first model
`structure to the received metrology data;
`
`(d) downloading said one or more modified variables to said second
`processing tool;
`
`(e) operating said second processing tool in accordance with said
`downloaded variables.
`
`39. The method of claim 38, wherein steps (a) through (e) are repeated
`to effectuate run-to-run control of the manufacturing process.
`
`40. The method of claim 39, further comprising the steps of:
`
`obtaining metrology data from a second metrology tool with respect to
`said second processing tool;
`
`applying said metrology data from said second metrology tool to a
`second model structure relating said metrology data from said second
`
`152515573.1
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`- 21 -
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`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`metrology tool to said target set-point for said second processing tool;
`and
`
`modifying one or more variables in said variable parameter table for said
`second processing tool.
`
`41. The method of claim 40, wherein said step of applying said
`metrology data from said second metrology tool to said second model
`structure comprises the step of applying said metrology data from said
`second metrology tool to a feedback model.
`
`42. The method of claim 40, further comprising the step of selecting, via
`a user interface, a model formats from among a plurality of model
`formats from which said second model structure is generated.
`
`43. The method of claim 42, wherein said plurality of model formats
`comprise a linear model format, a quadratic model format and a cubic
`model format.”
`
`See also Stoddard at 5:40-50, 9:66-10:8, 10:48-51.
`
`152515573.1
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`- 22 -
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`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Stoddard at Fig. 3:
`
`
`
`
`152515573.1
`
`- 23 -
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Stoddard at Fig. 6A:
`
`
`152515573.1
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`- 24 -
`
`
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Stoddard at Fig. 7:
`
`
`
`
`152515573.1
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`- 25 -
`
`IPR2021-01348
`Ocean Semiconductor Exhibit 2027
`
`

`

`Exhibit G-09 to Defendant’s Invalidity Contentions:
`Comparison of U.S. Patent No. 6,836,691 and Stoddard
`
`ELEMENT
`NO.
`
`’691 CLAIM ELEMENT
`
`STODDARD
`
`Stoddard at Fig. 8:
`
`
`1[c]
`
`filtering the metrology data based on the
`collection purpose data; and
`
`
`
`See, e.g.:
`
`Stoddard at 2:19-35: “In one embodiment, an