`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE WESTERN DISTRICT OF TEXAS
`
`WACO DIVISION
`
`DEMARAY LLC,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD (A
`KOREAN COMPANY), SAMSUNG
`ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC., and
`SAMSUNG AUSTIN SEMICONDUCTOR,
`LLC
`
`Defendants.
`
`Case No. 6:20-CV-00636
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`JURY TRIAL DEMANDED
`
`PUBLIC VERSION
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`DEMARAY LLC’S AMENDED COMPLAINT
`FOR INFRINGEMENT OF U.S. PATENT NOS. 7,544,276 AND 7,381,657
`
`Plaintiff Demaray LLC (“Demaray”), by and through its undersigned counsel, pleads the
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`following against Samsung Electronics Co., LTD (a Korean Company) (“Samsung Electronics”),
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`Samsung Electronics America, Inc. (“Samsung Electronics America”), Samsung Semiconductor,
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`Inc. (“Samsung Semiconductor”), and Samsung Austin Semiconductor LLC (“Samsung Austin
`
`Semiconductor”) (collectively, “Samsung” or “Defendants”), and alleges as follows:
`
`THE PARTIES
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`1.
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`Dr. Richard Ernest Demaray, a named inventor on both of the patents at issue in
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`this case, has been working in and with the semiconductor industry for more than forty years.
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`Dr. Demaray began his training in chemical physics, studying ultraviolet photoconductivity of
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`materials. His doctoral work focused on cross-supersonic molecular and atomic beams with
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`which he demonstrated lossless conversion of molecular vibration to light in vacuum. During his
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`post-doctoral fellowship, he designed and built some of the first pulsed xcimer laser driven
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`tunable dye lasers for resonant multiphoton photoionization in the cooled beam. That work
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`became instrumental to understanding the photo-physics of the high lying states of small and
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`aromatic molecules.
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`2.
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`Much of Dr. Demaray’s work in industry has involved advances in thin film
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`technology. In the 1980s, he worked as a senior physicist at BOC Group on electron beam
`
`evaporation technology used to deposit thermal barrier coatings. His work on adherent electron
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`beam evaporation thermal barrier coatings revolutionized high-temperature jet engine
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`performance, efficiency and longevity. Dr. Demaray’s zirconia coatings are in worldwide
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`production today on military, commercial and power generation turbine hot section blades and
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`vanes. Later that decade and continuing into the early 1990s, Dr. Demaray worked at Varian
`
`Associates. He served as Varian’s R&D Director for thin film systems, and developed full-face
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`erosion and sputter physical vapor deposition technology now used extensively in semiconductor
`
`manufacturing worldwide. In the late 1990s, he helped form Applied Komatsu, where he served
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`as General Manager of the PVD division and developed wide-area magnetron sputter machines.
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`Thereafter, he managed several additional companies in the thin film space, including
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`Symmorphix Inc., where he served as Chief Technology Officer and Chairman of the Board.
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`3.
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`After serving in senior management roles at some of the more prominent
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`companies in the industry, he founded Demaray in order to focus on research, development, and
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`commercialization of new product applications based on technologies he had developed,
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`including technologies protected by the patents at issue in this case. Much of that work—which
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`remains ongoing—relates to the production of low-defect thin films for advanced electronic
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`devices. In the course of his work, Dr. Demaray discovered that his patented technology was
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`being used by Samsung, without authorization, to manufacture thin films in Samsung electronic
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`devices with which Samsung is generating many tens of billions of dollars per year.
`
`4.
`
`Demaray is a Delaware limited liability company duly organized and existing under
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`the laws of the State of Delaware. The address of the registered office of Demaray is 9 East
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`Loockerman Street, Suite 202, Dover, DE 19901. The name of Demaray’s registered agent at that
`
`address is Spiegel & Utrera, P.A.
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`5.
`
`Demaray is the assignee and owns all right, title, and interest to U.S. Patent Nos.
`
`7,544,276 (“the ’276 Patent”) and 7,381,657 (“the ’657 Patent”) (collectively, the “Asserted
`
`Patents”). A true and correct copy of the ’276 Patent is attached hereto as Exhibit 1. A true and
`
`correct copy of the ’657 Patent is attached hereto as Exhibit 2.
`
`6.
`
`On information and belief, Defendant Samsung Electronics America is a
`
`corporation duly organized and existing under the laws of the State of New York, having a regular
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`and established place of business in the Western District of Texas, including at 12100 Samsung
`
`Blvd, Austin, Texas 78754.1 Defendant Samsung Electronics America may be served with process
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`through its registered agent CT Corporation System, 1999 Bryan St., Ste. 900, Dallas, TX 75201-
`
`3136.
`
`7.
`
`On information and belief, Defendant Samsung Electronics is a company duly
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`organized and existing under the laws of the Republic of Korea with its principal offices at 129
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`Samsung-ro, Yeongtong-gu, Suwon-si, Gyeonggi-do, Republic of Korea. Further, upon
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`information and belief, Samsung Electronics directs and controls the actions of Samsung
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`1 https://www.samsung.com/semiconductor/about-us/location/manufacturing-centers/.
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`Electronics America such that it too maintains a regular and established place of business in the
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`Western District of Texas, including at 12100 Samsung Blvd, Austin, Texas 78754, and 2800
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`Wells Branch Pkwy, Austin, Texas 78728.
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`8.
`
`On information and belief, Defendant Samsung Semiconductor is a corporation
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`organized and existing under the laws of the State of California, and is located at 3655 North
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`First Street, San Jose, California 95134, and is believed to be a wholly-owned subsidiary of
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`Samsung Electronics America. Defendant Samsung Semiconductor may be served with process
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`through its registered agent National Registered Agents, Inc., 1999 Bryan St., Ste. 900, Dallas,
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`TX 75201-3136.
`
`9.
`
`On information and belief, Defendant Samsung Austin Semiconductor is a limited
`
`liability company organized and existing under the laws of the State of Delaware, and is located
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`at 12100 Samsung Boulevard, Austin, Texas 78754, and is believed to be a wholly owned
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`subsidiary of Samsung Semiconductor. Defendant Samsung Austin Semiconductor operates the
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`semiconductor fabrication plant known as the “S2-Line” in Austin, Texas, in which it uses
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`manufacturing processes for semiconductors pertinent to this Complaint. Defendant Samsung
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`Austin Semiconductor may be served with process through its registered agent CT Corporation
`
`System, 1999 Bryan St., Ste. 900, Dallas, TX 75201-3136.
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`JURISDICTION AND VENUE
`
`10.
`
`This is an action arising under the patent laws of the United States, 35 U.S.C. § 1
`
`et seq. Accordingly, this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`11.
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`Each Defendant is subject to this Court’s specific and general personal jurisdiction
`
`consistent with the principles of due process and/or the Texas Long Arm Statute.
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`12.
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`Personal jurisdiction exists generally over the Defendants because each Defendant
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`has sufficient minimum contacts with the forum as a result of business conducted within the State
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`of Texas and the Western District of Texas and/or has engaged in continuous and systematic
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`activities in the Western District of Texas, and Defendants Samsung Electronics America,
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`Samsung Semiconductor, and Samsung Austin Semiconductor are registered with the Secretary of
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`State to do business in the State of Texas. Personal jurisdiction also exists over each Defendants
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`because each, directly or through subsidiaries, makes, uses, sells, offers for sale, imports,
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`advertises, makes available, and/or markets products or processes within the State of Texas and
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`the Western District of Texas that infringe one or more claims of the Asserted Patents , as alleged
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`more particularly below.
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`13.
`
`Venue in this District is proper under 28 U.S.C. §§ 1400(b) and 1391(b) and (c)
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`because each Defendant is subject to personal jurisdiction in this District and has committed acts
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`of infringement in this District. Each Defendant, directly or through subsidiaries, makes, uses,
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`sells, and/or offers to sell infringing products or processes within this District, has a continuing
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`presence within the District, and has the requisite minimum contacts with the District such that
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`this venue is a fair and reasonable one. Upon information and belief, each Defendant, directly or
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`through subsidiaries, has transacted, and at the time of the filing of the Complaint, is continuing to
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`transact business within this District.
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`TECHNOLOGY BACKGROUND
`
`14.
`
`Semiconductor devices are generally manufactured using a series of process steps
`
`applied to a substrate. A particularly important portion of typical semiconductor manufacturing
`
`processes involves the deposition of thin films used to form structures in the final product. One
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`of the most practical and effective approaches to thin film deposition used to make modern
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`semiconductor devices, and which is often used a dozen or more times in manufacturing even a
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`single semiconductor product, is called “magnetron sputtering.”
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`15. Magnetron sputtering is a physical vapor deposition (“PVD”) technique. It can be
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`carried out in a reactor that applies power to a target, e.g., a metal such as tantalum (Ta) or
`
`titanium (Ti), to deposit a thin film onto a substrate, e.g., silicon.
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`16. Magnetron sputtering, as practiced in modern commercial operations, generally
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`involves the use of magnets behind the negative cathode in the reactor to create magnetic and
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`electrical fields superimposed on the metal target. See also, e.g., Ex. 1 at 8:38-60. An inert gas,
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`e.g., argon, can be introduced into the chamber to create a magnetically confined ionized plasma.
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`The plasma may be located near the surface of the metal target such that the positively charged
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`plasma ions collide with the negatively charged metal target material ejecting atoms from the metal
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`target, which then deposit on the substrate. See also, e.g., id. at 5:24-27.
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`17.
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`One form of magnetron sputtering is bias pulsed DC (“BPDC”) sputtering. As that
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`process is practiced in semiconductor industry today, a DC power supply that provides alternating
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`negative and positive voltages is generally applied to the metal target while an RF voltage is
`
`generally applied to the substrate. See also, e.g., id. at 2:45-3:7, 5:60-67.
`
`18.
`
`Reactive magnetron sputtering (“RMS”), as used currently for industrial scale
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`semiconductor fabrication, generally includes the addition of a reactive gas, e.g., nitrogen, as a
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`process gas while sputtering from a metal target. See also, e.g., id. at 8:61-67. As an example,
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`RMS using nitrogen gas can be used for depositing dielectric barrier layers of tantalum nitride
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`(TaN) or titanium nitride (TiN) for copper interconnects on silicon wafers for semiconductor
`
`devices. BPDC sputtering systems are now being used for RMS sputtering.
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`FIRST CLAIM
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`(Infringement of U.S. Patent No. 7,544,276)
`
`19.
`
`Demaray re-alleges and incorporates herein by reference Paragraphs 1-18 of its
`
`Complaint.
`
`20.
`
`The ’276 Patent, entitled “Biased pulse DC reactive sputtering of oxide films,” was
`
`duly and lawfully issued on June 9, 2009. Ex. 1.
`
`21.
`
`The ’276 Patent names Hongmei Zhang, Mukundan Narasimhan, Ravi B.
`
`Mullapudi, and Richard E. Demaray as co-inventors.
`
`22.
`
`The ’276 Patent has been in full force and effect since its issuance. Demaray owns
`
`by assignment the entire right, title, and interest in and to the ’276 Patent, including the right to
`
`seek damages for past, current, and future infringement thereof.
`
`23.
`
`The ’276 Patent relates generally to a configuration of a reactor for deposition of
`
`thin films “by pulsed DC… sputtering,” which, in certain implementations, uses “a pulsed DC
`
`power supply providing alternating negative and positive voltages to the target” and “a narrow
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`band-rejection filter” coupled between the pulsed DC power supply and a target area that receives
`
`a metal target to provide high quality deposition layers. See, e.g., Ex. 1 at 1:12-14.
`
`24.
`
`The ’276 Patent also describes, among other things, for example, “a substrate
`
`electrode coupled to an RF power supply. A substrate mounted on the substrate electrode is
`
`therefore supplied with a bias from the RF power supply.” Id. at 2:45-53.
`
`25.
`
`Demaray is informed and believes, and thereon alleges, that Samsung has infringed,
`
`and unless enjoined will continue to infringe, one or more claims of the ’276 Patent, in violation
`
`of 35 U.S.C. § 271, by, among other things, (1) making, using, offering to sell, and selling within
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`the United States, supplying or causing to be supplied in or from the United States, and/or
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`importing into the United States, without authority or license, semiconductor manufacturing
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`equipment including sputtering reactors configured as described in the claims of the ’276 Patent;
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`and/or (2) supplying or causing to be supplied in or from the United States (a) all or a substantial
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`portion of the components of semiconductor manufacturing equipment including sputtering
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`reactors configured as described in the claims of the ’276 Patent in such manner as to actively
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`induce the combination of such components outside of the United States in a manner that would
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`infringe the ’276 Patent if such combination occurred within the United States, and/or (b) a
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`component of semiconductor manufacturing equipment including sputtering reactors configured
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`as described in the claims of the ’276 Patent that is especially made or especially adapted for use
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`in the invention and not a staple article or commodity of commerce suitable for substantial
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`noninfringing use, where such component is uncombined in whole or in part, and Samsung knows
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`that such component is so made or adapted and intends that such component will be combined
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`outside of the United States in a manner that would infringe the ’276 patent if such combination
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`occurred within the United States.
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`26.
`
`For example, the accused products for the ’276 Patent embody every limitation of
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`claims of the ’276 Patent, literally or under the doctrine of equivalents, including as set forth in
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`the illustrative example below. The further descriptions below are preliminary examples and are
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`non-limiting.
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`[“1. A reactor according to the present invention, comprising:”]
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`27.
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`On information and belief, Samsung uses infringing reactors (“Samsung reactors”)
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`according to the claims of the ’276 Patent in the production of its semiconductor products at its
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`semiconductor fabrication plants and research facilities, including but not limited to premises
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`within the United States.
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`28.
`
`As an example, on information and belief, Samsung configures reactors, including,
`
`but not limited to reactors in the Endura product line from Applied Materials, Inc. (“Applied
`
`Materials”) for deposition of layers (including, e.g., metal nitride layers, such as, for instance, TaN
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`barrier layers and/or TiN hardmask layers and metal layers, such as Ti and Co) in its semiconductor
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`products. Samsung has identified Applied Materials as a supplier.2 On information and belief,
`
`these reactors can be modified with application-specific process kits to deposit specific materials.
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`The Endura product line includes reactors that can be configured for deposition of TaN layers (e.g.,
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`CuBS RFX PVD with the Encore II Ta(N) barrier chamber) and TiN layers, Ti layers, or Co layers
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`(e.g., Cirrus PVD chamber). A true and correct copy of a brochure for the Endura product line is
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`attached as Exhibit 3. A true and correct copy of an article from the Nanochip Technical Journal
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`regarding TaN deposition chambers is attached as Exhibit 4.3 A true and correct copy of a
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`presentation on the Cirrus TiN deposition chambers is attached as Exhibit 5.4 An example image
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`of an Endura CuBS RFX PVD is shown below:5
`
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`2 https://www.samsung.com/us/aboutsamsung/sustainability/supply-chain/supplier-list/.
`3 https://www.appliedmaterials.com/files/nanochip-
`journals/nanochiptechjournal_vol6_issue2.pdf#page=45.
`4
`http://www.appliedmaterials.com/files/pdf_documents/cirrus_htx_pvd_techncial_briefing.pdf.
`5 http://www.appliedmaterials.com/products/endura-cubs-rfx-pvd.
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`29.
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`As an example, on information and belief, Samsung has configured, or causes to
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`be configured, and uses and/or has used infringing Samsung reactors for TaN barrier layer
`
`deposition with its copper interconnects in the fabrication of its semiconductor products,
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`including but not limited to memory products. On information and belief, for example, Samsung
`
`has configured, or causes to be configured, and uses infringing Samsung reactors in the
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`fabrication of TaN barrier layers in its Samsung K4A8G085WC-BCRC 8 Gb DDR4 SDRAM
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`(“DDR4 SDRAM”). An inspection of a cross-section of the copper interconnects with metal
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`nitride barrier layers in Samsung’s DDR4 SDRAM indicates use of infringing Samsung reactors.
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`As a further example, on information and belief, Samsung has configured, or causes to be
`
`configured, and uses and/or has used infringing Samsung reactors
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`As an additional example, on information and belief, Samsung has configured, or causes to be
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`configured, and uses and/or has used infringing Samsung reactors
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`[“a target area for receiving a target;”]
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`30.
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`31.
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`The Samsung reactors comprise a target area for receiving a target.
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`For example, for Samung reactors, “[i]n PVD, the target is the source of the material
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`to be deposited. Atoms are ejected from the target as a result of the bombardment of energetic
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`particles.”6 In Samsung reactors for depositing TaN, tantalum is the source material (i.e., the metal
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`target). See Ex. 3 at 4 (Cu barrier reactor for TaN). In Samsung reactors for depositing Ti, titanium
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`is the source material (i.e., the metal target). In Samsung reactors for depositing Co, cobalt is the
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`source material (i.e., the metal target). The reactors include a target area (indicated as “target” in
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`the image below) for receiving the tantalum:
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`Ex. 4 at 42 (Fig. 1).
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`6 https://www.appliedmaterials.com/resources/glossary.
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`32.
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`An example of the target and target area in a reactor is shown below:
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`
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`[“a substrate area opposite the target area for receiving a substrate;”]
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`33.
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`The Samsung reactors comprise a substrate area opposite the target area for
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`receiving a substrate.
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`34.
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`For example, for Samsung reactors a substrate is “[t]he material upon which thin
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`films are manipulated. Silicon is most commonly used for semiconductors ….”7 The substrate in
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`a RMS reactor for deposition of a TaN barrier layer in Samsung’s DDR4 SDRAM, for instance,
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`is a silicon wafer. A substrate area is opposite the target area for receiving the silicon substrates
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`(indicated as “wafer”) as illustrated below:
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`7 https://www.appliedmaterials.com/resources/glossary.
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 13 of 30
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`See Ex. 4 at 42 (Fig. 1).
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`35.
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`The substrate area in a reactor is shown below:
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`
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`[“a pulsed DC power supply coupled to the target area, the pulsed DC power supply
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`providing alternating negative and positive voltages to the target;”]
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`36.
`
`On information and belief, Samsung configures, or causes to be configured, the
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`Samsung reactors such that they comprise a pulsed DC power supply coupled to the target area,
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`and the pulsed DC power supply provides alternating negative and positive voltages to the target.
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 14 of 30
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`37.
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`For example, on information and belief, in the Samsung reactors a power source is
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`coupled to the target area as illustrated below:
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`See Ex. 4 at 42 (Fig. 1).
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`
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`38.
`
`The presence of a DC power unit in a reactor for deposition (e.g., TaN when using
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`a tantalum target and a process gas that includes nitrogen) is illustrated below:
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`
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`See Ex. 5 at 9 (“DC” power supply in 1st generation iPVD products). The presence of a pulsed
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`DC power unit in a reactor configured for deposition (e.g., TaN, when using a tantalum target
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`and a process gas that includes nitrogen) is shown below:
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 15 of 30
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`[“an RF bias power supply coupled to the substrate;”]
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`39.
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`On information and belief, Samsung configures, or causes to be configured, the
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`Samsung reactors such that they comprise an RF bias power supply coupled to the substrate.
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`40.
`
`For example, a power supply is coupled to the substrate area to bias the substrate
`
`as illustrated below:
`
`See Ex. 4 at 42 (Fig. 1).
`
`
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`41.
`
`The presence of an RF bias power supply in a reactor for deposition (e.g., TaN,
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`when using a tantalum target and a process gas that includes nitrogen) is shown below:
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 16 of 30
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`[“and a narrow band-rejection filter that rejects at a frequency of the RF bias power
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`supply coupled between the pulsed DC power supply and the target area.”]
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`42.
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`On information and belief, Samsung configures, or causes to be configured, the
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`Samsung reactors such that they comprise a narrow band-rejection filter that rejects at a
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`frequency of the RF bias power supply coupled between the pulsed DC power supply and the
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`target area.
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`43.
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`On information and belief, a narrowband filter is coupled between the pulsed DC
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`power supply and the target area in a reactor for deposition of tantalum nitride (e.g., TaN, when
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`using a tantalum target and a process gas that includes nitrogen). On information and belief, a
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`narrowband filter is used in the Samsung reactors as configured to, for example, protect the
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`pulsed DC power supply from feedback from the RF bias power supply.
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 17 of 30
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`SECOND CLAIM
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`(Infringement of U.S. Patent No. 7,381,657)
`
`44.
`
`Demaray re-alleges and incorporates herein by reference Paragraphs 1-43 of its
`
`Complaint.
`
`45.
`
`The ’657 Patent, entitled “Biased pulse DC reactive sputtering of oxide films,” was
`
`duly and lawfully issued on June 3, 2008. Ex. 2.
`
`46.
`
`The ’657 Patent names Hongmei Zhang, Mukundan Narasimhan, Ravi B.
`
`Mullapudi, and Richard E. Demaray as co-inventors.
`
`47.
`
`The ’657 Patent has been in full force and effect since its issuance. Demaray owns
`
`by assignment the entire right, title, and interest in and to the ’657 Patent, including the right to
`
`seek damages for past, current, and future infringement thereof.
`
`48.
`
`The ’657 Patent generally relates to a method of depositing thin films “by pulsed
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`DC reactive sputtering.” Ex. 2 at 1:11-13.
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`49.
`
`The ’657 Patent describes, among other things, methods of using a “sputtering
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`reactor according to the present invention includes a pulsed DC power supply coupled through a
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`filter to a target and a substrate electrode coupled to an RF power supply. A substrate mounted on
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`the substrate electrode is therefore supplied with a bias from the RF power supply.” Id. at 2:45-
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`54.
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`50.
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`Demaray is informed and believes, and thereon alleges, that Samsung has infringed
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`and unless enjoined will continue to infringe one or more claims of the ’657 Patent, in violation of
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`35 U.S.C. § 271, by, among other things, using the claimed methods for reactive sputtering in an
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`infringing manner to produce semiconductor products, and/or making, offering to sell, and selling
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`within the United States, and/or importing into the United States, without authority or license,
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 18 of 30
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`semiconductor products produced using the claimed methods for reactive sputtering in an
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`infringing manner.
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`51.
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`For example, the accused products for the ’657 Patent are produced by a method
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`that embodies every limitation of claims of the ’657 Patent, literally or under the doctrine of
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`equivalents, including as set forth in the illustrative example below. The further descriptions
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`below are preliminary examples and are non-limiting.
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`[“A method of depositing a film on an insulating substrate, comprising:”]
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`52.
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`On information and belief, Samsung uses a method of depositing a film on an
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`insulating substrate according to the claims of the ’657 Patent in the production of semiconductor
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`products at its semiconductor fabrication plants and research facilities, including but not limited
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`to its premises within the United States.
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`53.
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`As an example, on information and belief, Samsung deposits layers (including, e.g.,
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`metal nitride layers such as, for instance, TaN barrier layers and/or TiN hardmask layers) on
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`insulating substrates (e.g., semiconductor wafers) for its memory products, including but not
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`limited to its DDR4 SDRAM.
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`[“providing a process gas between a conductive target and the substrate;”]
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`54.
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`On information and belief, Samsung fabricates semiconductor products using a
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`method comprising providing a process gas between a conductive target and the substrate.
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`As an example, on information and belief, for example, Samsung uses a RMS reactor in the
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`fabrication of TaN barrier layers in its DDR4 SDRAM. On information and belief, Samsung
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`uses a RMS reactor that it configures to use with nitrogen as a process gas. See also, e.g., Ex. 3
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`at 6. The constitution of the metal nitride barrier layers confirms the use of nitrogen as a process
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 19 of 30
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`gas. An inspection of a cross-section of the copper interconnects with metal nitride barrier layers
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`in Samsung’s DDR4 SDRAM indicates use of infringing Samsung RMS reactors.
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`55.
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`On information and belief, in RMS reactors as configured, a process gas including
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`nitrogen (e.g., N2 or NH3) is provided in the chamber between the tantalum target and the silicon
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`substrate to deposit a tantalum nitride (TaN) film on the substrate. For example, the presence of a
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`process chamber between a conductive target and the substrate (e.g., TaN, when using a tantalum
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`target and a process gas that includes nitrogen) is shown below:
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`
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`[“providing pulsed DC power to the target through a narrow band rejection filter such that
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`the target alternates between positive and negative voltages;”]
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`56.
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`On information and belief, Samsung fabricates semiconductor products using a
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`method comprising providing pulsed DC power to the target through a narrow band rejection filter
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`such that the target alternates between positive and negative voltages.
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 20 of 30
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`57.
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`As an example, as discussed above, on information and belief, Samsung uses a
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`RMS reactor in the fabrication of TaN barrier layers in its semiconductor products, including, for
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`example, Samsung’s DDR4 SDRAM. See also, e.g., Ex. 3 at 6. A power source is coupled to the
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`target as illustrated below:
`
`See Ex. 4 at 42 (Fig. 1).
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`
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`58.
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`The presence of a pulsed DC power unit in a reactor configured for RMS
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`deposition (e.g., when using a tantalum target and a process gas that includes nitrogen) is shown
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`DC Feedthrough
`To Target Area
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`Power Cable
`Delivering Power
`from a Pulsed DC
`Power Supply (not
`shown)
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`below:
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 21 of 30
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`59.
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`On information and belief, a narrowband filter is coupled between the pulsed DC
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`power supply and the target area in a reactor for deposition of, e.g., TaN, when using a tantalum
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`target and a process gas that includes nitrogen. On information and belief, a narrowband filter is
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`used in the Samsung reactors as configured to, for example, protect the pulsed DC power supply
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`from feedback from the RF bias power supply.
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`[“providing an RF bias at a frequency that corresponds to the narrow band rejection filter
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`to the substrate;”]
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`60.
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`On information and belief, Samsung fabricates semiconductor products using a
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`method comprising providing an RF bias at a frequency that corresponds to the narrow band
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`rejection filter to the substrate.
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`61.
`
`As an example, as discussed above, on information and belief, Samsung uses a
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`RMS reactor in the fabrication of TaN barrier layers in its semiconductor products, including, for
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`example, Samsung’s DDR4 SDRAM. See also, e.g., Ex. 3 at 6. A RF power supply is coupled to
`
`the substrate area to bias the substrate as illustrated below:
`
`See Ex. 4 at 42 (Fig. 1).
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`
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`62.
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`The presence of a RF bias power supply in a reactor configured for RMS
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`deposition (e.g., TaN, when using a tantalum target and a process gas that includes nitrogen) is
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`shown below :
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 22 of 30
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`[“providing a magnetic field to the target;”]
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`63.
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`On information and belief, Samsung fabricates semiconductor products using a
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`method comprising providing a magnetic field to the target.
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`64.
`
`As an example, as discussed above, on information and belief, Samsung uses a
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`RMS reactor in the fabrication of, e.g., TaN, when using a tantalum target and a process gas that
`
`includes nitrogen, barrier layers in its semiconductor products, including, for example, Samsung’s
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`DDR4 SDRAM. See also, e.g., Ex. 3 at 6. As configured in the Samsung RMS reactors, RMS
`
`involves the use of magnets to provide a magnetic field to the target.
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`65.
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`The presence of a magnetron in a reactor for deposition of tantalum nitride (when
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`using a tantalum target and a process gas that includes nitrogen) is illustrated below. See Ex. 5 at
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`9 (1st generation iPVD products):
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`Case 6:20-cv-00636-ADA Document 212 Filed 08/17/22 Page 23 of 30
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`[“and reconditioning the target;”]
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`
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`66.
`
`On information and belief, Samsung fabricates semiconductor products using a
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`method comprising reconditioning the target.
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`67.
`
`As an example, as discussed above, on information and belief, Samsung uses a
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`RMS reactor in the fabrication of TaN barrier layers in its semiconductor products, including, for
`
`example, Samsung’s DDR4 SDRAM. See also, e.g., Ex. 3 at 6. On information and belief, as
`
`configured in the Samsung reactors with nitrogen process gas, impurities, such as nitrides,
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`generated in the deposition process are removed from the tantalum target surface prior to the next
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`deposition by sputtering in the absence of the nitrogen process gas.
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`[“wherein reconditioning the target includes reactive sputtering in the metallic mode and
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`then reactive sputtering in the poison mode.”]
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`68.
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`On information and belief, Samsung fabricates semiconductor products using a
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`method in which the reconditioning of the target includes reactive sputtering in the metallic mode
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`and then reactive sputtering in the poison mode.
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`69.
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`As an example, as discussed