Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 1 of 21
`
`
`
`
`Exhibit 4
`
`
`
`
`
`
`
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 2 of 21
`
`PATENT
`Customer Number 22,852
`Attorney Docket No. 09140-0016-01000
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Prior Application Art Unit: 2823
`
`Prior Application Examiner: Michelle ESTRADA
`
`SIR: This is a request for filing a
`~ Continuation· D Continuation-in-Part D Divisional Application under 37 C.F.R. § l.53(b)
`of pending prior Application No. 10/101,863 filed March 16, 2002 of ZHANG et al. for BIASED
`PULSE DC REACTIVE SPUTTERING OF OXIDE FILMS
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`(cid:143)
`(cid:143)
`
`Enclosed is a complete copy of the prior application including the oath or
`Declaration and drawings, if any, as originally filed. I hereby verify that the
`attached papers are a true copy of prior Application No. 10/101,863 as originally
`filed on March 16, 2002, which is incorporated herein by reference.
`
`Enclosed is a substitute specification under 3 7 C.F .R. § 1.125. The undersigned
`hereby verifies that no new matter is added in this substitute specification.
`
`Enclosed is a Request for Non-Publication of Application and Certification Under
`35 U.S.C. § 122(b)(2)(B)(i).
`
`A Preliminary Amendment is enclosed.
`
`The filing fee is calculated on the basis of the claims existing in the prior
`application as amended in the Preliminary Amendment filed herewith.
`
`DEMINT00001543
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 3 of 21
`
`Page 2- of3
`
`Basic Application Filing Fee
`
`$790
`
`$
`
`790.00
`
`Number of
`Claims
`
`Total Claims
`
`-
`45
`2 -
`Independent Claims
`D Presentation of Multiple Dep. Claim(s)
`Subtotal
`
`Reduction by 1/2 if small entity
`
`TOT AL APPLICATION FILING FEE
`
`Basic
`
`20
`
`3
`
`Extra
`Claims
`25 X $18
`
`$
`
`450
`
`0 X $86
`
`+$290
`
`0
`
`0
`
`$
`-
`
`$
`
`1240
`
`1240
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`11.
`
`12.
`
`13.
`
`14.
`
`(cid:143)
`
`cg]
`
`(cid:143)
`
`(cid:143)
`
`·cgi
`
`(cid:143)
`
`cg]
`
`A check in the amount of $1280 to cover the filing fee of $1240 and Assignment
`recordation fee of $40 is enclosed.
`
`The Commissioner is hereby authorized to charge any additional fees which may
`be required including fees due under 3 7 C.F .R. § 1.16 and any other fees due
`under 37 C.F.R. § 1.17, or credit any overpayment during the pendency of this
`application to Deposit Account No. 06-0916.
`
`New acceptable drawings are enclosed.
`
`The prior application is assigned of record to: Symmorphix, Inc.
`
`Priority of Application No. [Text], filed on [Text] in [Country] is claimed under
`35 U.S.C. § 119. A certified copy
`D is enclosed or D is on file in the prior application.
`Small entity status is appropriate and applies to this application.
`
`The power of attorney in the prior application is to FINNEGAN, HENDERSON,
`FARABOW, GARRETT & DUNNER, L.L.P., Customer No. 22,852
`
`The power appears in the original declaration of the prior application.
`
`Since the power does not appear in the original declaration, a copy of the power in
`the prior application is enclosed.
`
`15.
`
`cg]
`
`Please address all correspondence to FINNEGAN, HENDERSON, F ARABOW,
`GARRETT and DUNNER, L.L.P., Customer Number 22,852.
`
`DEMINT00001544
`
`

`

`. .
`
`..
`
`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 4 of 21
`
`Page 3 of3
`
`16.
`
`Also enclosed is Information Disclosure Statement under 37 CFR l.97(b) together ·
`with Form PTO 1449.
`
`PETITION FOR EXTENSION. If any extension of time is necessary for the filing of this
`application, including any extension in parent Application No. 10/101,863, filed March 16, 2002,
`for the purpose of maintaining copendency between the parent application and this application,
`and such extension has not otherwise been requested, such an extension is hereby requested, and
`the Commissioner is authorized to charge necessary fees for such an extension to our Deposit
`Account No. 06-0916. A duplicate copy of this paper is enclosed for use in charging the deposit
`account.
`
`FINNEGAN, HENDERSON, F ARABOW,
`GARRETT & DUNNER, L.L.P.
`
`Dated: September 30, 2004
`
`By:44-~
`ary(E~s
`Reg. No. 41,008
`
`DEMINT00001545
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 5 of 21
`
`PATENT
`Customer Number 22,852
`Attorney Docket No. 09140-0016-01000
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Prior Application Art Unit: 2823
`
`Prior Application Examiner: Michelle ESTRADA
`
`SIR: This is a request for filing a
`~ Continuation· D Continuation-in-Part D Divisional Application under 37 C.F.R. § l.53(b)
`of pending prior Application No. 10/101,863 filed March 16, 2002 of ZHANG et al. for BIASED
`PULSE DC REACTIVE SPUTTERING OF OXIDE FILMS
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`(cid:143)
`(cid:143)
`
`Enclosed is a complete copy of the prior application including the oath or
`Declaration and drawings, if any, as originally filed. I hereby verify that the
`attached papers are a true copy of prior Application No. 10/101,863 as originally
`filed on March 16, 2002, which is incorporated herein by reference.
`
`Enclosed is a substitute specification under 3 7 C.F .R. § 1.125. The undersigned
`hereby verifies that no new matter is added in this substitute specification.
`
`Enclosed is a Request for Non-Publication of Application and Certification Under
`35 U.S.C. § 122(b)(2)(B)(i).
`
`A Preliminary Amendment is enclosed.
`
`The filing fee is calculated on the basis of the claims existing in the prior
`application as amended in the Preliminary Amendment filed herewith.
`
`DEMINT00001546
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 6 of 21
`
`Page 2- of3
`
`Basic Application Filing Fee
`
`$790
`
`$
`
`790.00
`
`Number of
`Claims
`
`Total Claims
`
`-
`45
`2 -
`Independent Claims
`D Presentation of Multiple Dep. Claim(s)
`Subtotal
`
`Reduction by 1/2 if small entity
`
`TOT AL APPLICATION FILING FEE
`
`Basic
`
`20
`
`3
`
`Extra
`Claims
`25 X $18
`
`$
`
`450
`
`0 X $86
`
`+$290
`
`0
`
`0
`
`$
`-
`
`$
`
`1240
`
`1240
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`11.
`
`12.
`
`13.
`
`14.
`
`(cid:143)
`
`cg]
`
`(cid:143)
`
`(cid:143)
`
`·cgi
`
`(cid:143)
`
`cg]
`
`A check in the amount of $1280 to cover the filing fee of $1240 and Assignment
`recordation fee of $40 is enclosed.
`
`The Commissioner is hereby authorized to charge any additional fees which may
`be required including fees due under 3 7 C.F .R. § 1.16 and any other fees due
`under 37 C.F.R. § 1.17, or credit any overpayment during the pendency of this
`application to Deposit Account No. 06-0916.
`
`New acceptable drawings are enclosed.
`
`The prior application is assigned of record to: Symmorphix, Inc.
`
`Priority of Application No. [Text], filed on [Text] in [Country] is claimed under
`35 U.S.C. § 119. A certified copy
`D is enclosed or D is on file in the prior application.
`Small entity status is appropriate and applies to this application.
`
`The power of attorney in the prior application is to FINNEGAN, HENDERSON,
`FARABOW, GARRETT & DUNNER, L.L.P., Customer No. 22,852
`
`The power appears in the original declaration of the prior application.
`
`Since the power does not appear in the original declaration, a copy of the power in
`the prior application is enclosed.
`
`15.
`
`cg]
`
`Please address all correspondence to FINNEGAN, HENDERSON, F ARABOW,
`GARRETT and DUNNER, L.L.P., Customer Number 22,852.
`
`DEMINT00001547
`
`

`

`. .
`
`..
`
`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 7 of 21
`
`Page 3 of3
`
`16.
`
`Also enclosed is Information Disclosure Statement under 37 CFR l.97(b) together ·
`with Form PTO 1449.
`
`PETITION FOR EXTENSION. If any extension of time is necessary for the filing of this
`application, including any extension in parent Application No. 10/101,863, filed March 16, 2002,
`for the purpose of maintaining copendency between the parent application and this application,
`and such extension has not otherwise been requested, such an extension is hereby requested, and
`the Commissioner is authorized to charge necessary fees for such an extension to our Deposit
`Account No. 06-0916. A duplicate copy of this paper is enclosed for use in charging the deposit
`account.
`
`FINNEGAN, HENDERSON, F ARABOW,
`GARRETT & DUNNER, L.L.P.
`
`Dated: September 30, 2004
`
`By:44-~
`ary(E~s
`Reg. No. 41,008
`
`DEMINT00001548
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 8 of 21
`
`PATE~
`Customer No. 22,85
`Attorney Docket No. 10655.0016-01
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`)
`)
`) Group Art Unit: 2823
`)
`) Examiner: Michelle ESTRADA
`)
`)
`)
`) Confirmation No.: 9873
`)
`
`In re Application of:
`
`Hongmei ZHANG et al.
`
`Application No.: 10/954,182
`
`Filed: October 1, 2004
`
`For: BIASED PULSE DC REACTIVE
`SPUTTERING OF OXIDE FILMS
`
`MAIL STOP AMENDMENT
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Sir:
`
`AMENDMENT AND RESPONSE TO OFFICE ACTION
`
`In reply to the Office Action mailed November 15, 2007, please amend the
`
`above-identified application as follows:
`
`Amendments to the Claims are reflected in the listing of claims in this paper beginning
`
`on page 2.
`
`Remarks/ Arguments follow the amendment sections of this paper beginning on page 7.
`
`Attachments to this amendment include: Copies of referenced articles by P.F. Cheng
`
`et al., J. Vac. Sci. Techol. B 13 2 (1995), pp. 203-208, and S. M. Rossnagel et al., Appl. Phys.
`
`Lett. 63 (1993), p. 24.
`
`DEMINT00002511
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 9 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`AMENDMENTS TO THE CLAIMS:
`
`This listing of claims will replace all prior versions and listings of claims in the
`
`application:
`
`Claims 1-40 (Canceled).
`
`Claim 41 (Previously presented): The method of claim 85 wherein the target is a metallic
`
`target and the process gas includes oxygen.
`
`Claim 42 (Previously presented): The method of claim 85 wherein the target is a metallic
`
`target and the process gas includes one or more of a set consisting of N2, NH3, CO, NO, CO2,
`
`halide containing gasses.
`
`Claim 43 (Previously presented): The method of claim 85 wherein the target is a ceramic
`
`target.
`
`Claim 44 (Canceled).
`
`Claim 45 (Previously presented): The method of claim 85 wherein the magnetic field is
`
`provided by a moving magnetron.
`
`Claim 46 (Previously presented) The method of claim 85 further including holding the
`
`temperature of the substrate substantially constant.
`
`DEMINT00002512
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 10 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`Claim 47 (Previously presented): The method of claim 85 wherein the process gas
`
`includes a mixture of Oxygen and Argon.
`
`Claim 48 (Previously presented): - --- method of claim 85 wherein the Oxygen flow is
`
`adjusted to adjust the index of refraction of the flm.
`
`Claim 49 (Previously presented): The method of claim 85 wherein the process gas
`
`further includes nitrogen.
`
`Claim 50 (Previously presented): The method of claim 85 wherein providing pulsed DC
`
`power to a target includes providing pulsed DC power to a target which has an area larger than
`
`that of the substrate.
`
`Claim 51 (Previously presented): The method of claim 85, further including uniformly
`
`sweeping the target with a magnetic field.
`
`Claim 52 (Previously presented): The method of claim 51 wherein uniformly sweeping
`
`the target with a magnetic field includes sweeping a magnet in one direction across the target
`
`where the magnet extends beyond the target in the opposite direction.
`
`Claim 53 (Previously presented): The method of claim 85 wherein the target is an
`
`alloyed target.
`
`-3-
`
`DEMINT00002513
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 11 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`Claim 54 (Previously presented): The method of claim 53 wherein the alloyed target
`
`includes one or more rare-earth ions.
`
`Claim 55 (Previously presented): The method of claim 53 wherein the alloyed target
`
`includes Si and Al.
`
`Claim 56 (Previously presented): The method of claim 53 wherein the alloyed target
`
`includes one or more elements taken from a set consisting of Si, Al, Er, Yb, Zn, Ga, Ge, P, As,
`
`Sn, Sb, Pb, Ag, Au, Ce, Pr, Nd, Pm, Sm, Eu, Gd, Tb, Dy Ho, Tm, and Lu.
`
`Claim 57 (Previously presented): The method of claim 53 wherein the alloyed target is a
`
`tiled target.
`
`Claim 58 (Previously presented): The method of claim 57 wherein each tile of the tiled
`
`target is formed by prealloy atomization and hot isostatic pressing of a powder.
`
`Claims 59-61 (Canceled).
`
`Claim 62 (Currently amended): A method of depositing a film on [[a]] an insulating
`
`substrate, comprising:
`
`providing a process gas between a conductive target and [[a]] the substrate;
`
`providing pulsed DC power to the target through a narrow band rejection filter such that
`
`the target alternates between positive and negative voltages;
`
`-4-
`
`DEMINT00002514
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 12 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`providing an RF bias at a frequency that corresponds to the narrow band rejection filter to
`
`the substrate;
`
`providing a magnetic field to the target; and
`
`reconditioning the target;
`
`wherein reconditioning the target includes reactive sputtering in the metallic mode and
`
`then reactive sputtering in the poison mode.
`
`Claims 63-84 (Canceled).
`
`Claim 85 (Currently amended): A method of depositing [[a]] an insulating film on a
`
`substrate, comprising:
`
`providing a process gas between a target and a substrate;
`
`providing pulsed DC power to the target through a narrow band rejection filter such that
`
`the voltage on the target alternates between positive and negative voltages;
`
`providing an RF bias that corresponds to the narrow band rejection filter to the substrate;
`
`providing a magnetic field to the target;--aHEI
`
`wherein [[a]] an oxide material is deposited on the substrate, and aH oxide the insulating
`
`film is formed by reactive sputtering in a mode between a metallic mode and a poison mode.
`
`Claims 86-87 (Canceled).
`
`-5-
`
`DEMINT00002515
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 13 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`Claim 88 (Currently amended): The method according to claim [[87]] 85, wherein the
`
`narrow band-rejection filter has a bandwidth of about 100 kHz.
`
`Claim 89 (Previously presented): The method according to claim [[87]] 85, wherein the
`
`RF frequency is about 2 MHz.
`
`Claims 90-109 (Canceled).
`
`-6-
`
`DEMINT00002516
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 14 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`REMARKS
`
`Claims 41-43, 45-58, 62, 85, and 87-89 are pending in the above-identified application.
`
`The Examiner has rejected claims 41-43, 45-58, 62, 85, and 87-89. In this amendment, claims
`
`62 and 85 have been amended as agreed during an Interview held on December 11, 2007. Claim
`
`87 has been cancelled.
`
`Examiner's Interview
`
`Applicants thank the Examiner for meeting with us on December 11, 2007 (the
`
`"Interview"). In attendance at the Interview were Examiner Michelle Estrada, Inventor R. Ernest
`
`Demaray, and Applicants' representative Gary J. Edwards. During the interview, all of the
`
`claims were discussed as well as the art that has been cited against the claims. Agreement with
`
`respect to the claims was reached. In this Amendment, the claims have been amended as
`
`discussed during the interview. The Examiner indicated in the Interview Summary that the
`
`proposed language for the claims "would overcome the rejection on record."
`
`The substance of the discussion with the Examiner with respect to the claims and the art
`
`is provided below.
`
`Claims 62 and 87-89
`
`Claim Rejections Under 35 U.S.C. § 103(a)
`
`Claims 62, and 87-89 are rejected under 35 U.S.C. § 103(a) as being unpatentable over
`
`U.S. Patent No. 6,117,279 to Smolanoff et al. ("Smolanoff') in view of U.S. Patent No.
`
`6,306,265 to Fu et al. ("Fu"). As discussed during the interview, Smolanoff teaches away from a
`
`system where the target voltage becomes positive, and therefore teaches away from "providing
`
`pulsed DC power to the target through a narrow band rejection filter such that the target
`
`DEMINT00002517
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 15 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`alternates between positive and negative voltages" and "providing an RF bias at a frequency that
`
`corresponds to the narrow band rejection filter to the substrate," as is recited in claims 62.
`
`Additionally, because Smolanoff teaches away from the elements of claim 62, there is no reason
`
`to combine Smolanoff with Fu as is suggested by the Examiner. However, even if they were
`
`combinable, the combination of Smolanoff and Fu does not teach or suggest the combination of
`
`"providing pulsed DC power to the target through a narrow band rejection filter such that the
`
`target alternates between positive and negative voltages" and "providing an RF bias at a
`
`frequency that corresponds to the narrow band rejection filter to the substrate," as is recited in
`
`claim 62.
`
`Smolanoff teaches a directed ion metal vapor source for deposition of conductive films.
`
`Although Smolanoff states that the DC source can be a pulsed DC source, Smolanoff also states
`
`that "[p ]ower from the steady or pulsed DC power supply 21 and/or RF generator 24 produces
`
`a negative potential on the target 16." (Smolanoff, col. 5, line 66, -col. 6, line 1) (emphasis
`
`added). In every disclosure of target voltage, Smolanoff teaches that the target voltage must be
`
`negative. (See, e.g. col. 5, lines 39-44 ("[t]he magnet structure 20 preferably includes magnets
`
`that produce a closed magnetic tunnel over the surface of the target 16 that traps electrons given
`
`off into the chamber 12 by the cathode assembly 17 when the cathode assembly 17 is electrically
`
`energized to a negative potential as is familiar to one skilled in the art"); col. 6, lines 9-12
`
`("[t]his main plasma in the region 23 becomes a source of positive ions of gas that are
`
`accelerated toward, and collide against, the negatively charged surface of the target 16,
`
`thereby ejecting particles of coating material from the target 16") (emphasis added)).
`
`Smolanoff never teaches that the target can be positive and, in accordance with the
`
`teachings of Smolanoff, the target voltage must always be negative. Therefore. Smolanoff
`
`DEMINT00002518
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 16 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`teaches away from "providing pulsed DC power to the target through a narrow band rejection
`
`filter such that the target alternates between positive and negative voltages" as is recited in claim
`
`62. Additionally, Smolanoff then teaches away from the combination "providing pulsed DC
`
`power to the target through a narrow band rejection filter such that the voltage on the target
`
`alternates between positive and negative voltages" and "providing an RF bias that corresponds to
`
`the narrow band rejection filter to the substrate," as is recited in claim 62.
`
`Even if Smolanoff could be combined with Fu as suggested, the combination would not
`
`teach or suggest the claimed invention. The Examiner stated that "Smolanoff et al. do not clearly
`
`disclose reconditioning the target; and wherein reconditioning the target includes reactive
`
`sputtering in the metallic mode and then reactive sputtering in the poison mode." (Office Action,
`
`page 2). Fu is relied upon to disclose "wherein conditioning the target includes sputtering with
`
`the target in a metallic mode to remove the surface of the target and sputtering with the target in
`
`a poisonous mode to prepare the surface (Col. 19, lines 35-40)." (Office Action, page 2).
`
`Fu teaches high density, magnetic field enhanced ionized metal vapor deposition of
`
`conducting films. (See Fu, abstract). Fu, however, teaches utilization of a DC power supply (Fu,
`
`col. 1, lines 30-32) in combination with an RF bias applied to the substrate (Fu, col. 2, lines 36-
`
`41). Therefore, Fu fails to teach the combination "providing pulsed DC power to the target
`
`through a narrow band rejection filter such that the voltage on the target alternates between
`
`positive and negative voltages" and "providing an RF bias that corresponds to the narrow band
`
`rejection filter to the substrate," as is recited in claim 62.
`
`Fu does teach operation in the poison mode and operation in the metallic mode as applied
`
`to TiN deposition, but does not teach "wherein an oxide material is deposited on the substrate,
`
`DEMINT00002519
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 17 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`and the insulating film is formed by reactive sputtering in a mode between a metallic mode and a
`
`poison mode," as is recited in claim 62. As stated by Fu,
`
`Reactive sputtering to produce TiN is known to operate in two
`modes, metallic mode and poison mode. Metallic mode produces a
`high-density, gold-colored film on the wafer. Poison mode, which
`is often associated with a high nitrogen flow, produces a
`purple/brown film which advantageously has low stress. However,
`the poison-mode film has many grain boundaries, and film defects
`severely reduce chip yield. Furthermore, the deposition rate in
`poison mode is typically only one-quarter of the rate in metallic
`mode. It is generally believed that in poison mode the nitrogen
`reacts with the target to form a TiN surface on the Ti target while
`in metallic mode the target surface remains clean and TiN forms
`only the wafer.
`
`(Fu, col. 19, lines 28-30). Fu teaches operation in either metallic mode or poison mode, and does
`
`not teach "wherein an oxide material is deposited on the substrate, and the insulating film is
`
`formed by reactive sputtering in a mode between a metallic mode and a poison mode," as is
`
`recited in claim 62.
`
`Therefore, claim 62 is allowable over the combination of Smolanoff and Fu. Similar to
`
`the discussion regarding claim 62, the combination of Smolanoff and Fu does not teach
`
`"providing pulsed DC power to the target through a narrow band rejection filter such that the
`
`voltage on the target alternates between positive and negative voltages" in combination with
`
`"providing an RF bias that corresponds to the narrow band rejection filter to the substrate," as is
`
`recited in claim 85. Further, Fu does not teach "wherein an oxide material is deposited on the
`
`substrate, and the insulating film is formed by reactive sputtering in a mode between a metallic
`
`mode and a poison mode," as is recited in claim 85. Claim 87 has been canceled. Claims 88-89
`
`depend from claim 85 and are therefore allowable for at least the same reasons as is claim 85.
`
`In addition, the Examiner initially indicated, with regard to the narrow band-rejection
`
`filter, that "[u]sing an specific type of filter is a matter of design choice depending on the quality
`
`-10-
`
`DEM I NT00002520
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 18 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`of product needed, and it is obvious that the filter is going to work at certain frequencies."
`
`(Office Action, page 3). However, as explained during the interview, that is not the case. The
`
`narrow band rejection filter allows the combination of pulsed-de power to the target (where the
`
`target voltage is oscillated between positive and negative voltages) and an RF bias on the
`
`substrate. A filter that blocks too many of the constituent frequencies of the pulsed DC
`
`waveform results in the target voltage not attaining a positive voltage. A filter that does not
`
`block the RF bias voltage can result in failure of the DC power supply. Smolanoff does not
`
`teach the "narrow band rejection filtering" recited in each of claims 62 and 85.
`
`Claims 41, 45, 47, 49, 51, 52, and 85
`
`Claims 41, 45, 47, 49, 51, 52, and 85 are rejected under 35 U.S.C. § 103(a) as being
`
`unpatentable over Smolanoff in view of Fu, as applied to claims 62, and 87-89, and in further
`
`view of reference titled "Enhancement of Aluminum Oxide Physical Vapor Deposition with a
`
`Secondary Plasma" to Li et al. ("Li"). As discussed above, claim 85 is allowable over the
`
`combination of Smolanoff and Fu. Li also fails to teach "providing pulsed DC power to the
`
`target through a narrow band rejection filter such that the voltage on the target alternates between
`
`positive and negative voltages" in combination with "providing an RF bias that corresponds to
`
`the narrow band rejection filter to the substrate," as is recited in claim 85.
`
`At best, Li teaches a pulsed DC source with a positive target voltage and a DC substrate
`
`bias. With regard to substrate bias, Li states that
`
`The angular distribution of the sputtered atoms is roughly a cosine
`distribution, and is further broadened by gas phase scattering,
`yielding insufficient bottom coverage and voids during filling of
`high aspect ratio features. This problem is solved by ionizing the
`metal flux and applying a bias on the substrate, accelerating
`
`-11-
`
`DEMINT00002521
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 19 of 21
`
`U.S. Application No. 10/954,18'.1
`Attorney Docket No. 10655.0016-0
`
`the metal ions through the plasma sheath near the substrate
`surface [14 and 15].
`
`(Li, pgs 162). There is no teaching of an RF bias to the substrate. Further, the referenced
`
`articles (P.F. Cheng et al., J. Vac. Sci. Techol. B 13 2 (1995), pp. 203-208, and S. M. Rossnagel
`
`et al., Appl. Phys. Lett. 63 (1993), p. 24) teach only a DC bias. (For the Examiner's convenience'
`
`copies of these articles are attached to this response). Therefore, as discussed with the Examiner,
`
`Li does not teach or suggest "providing pulsed DC power to the target through a narrow band
`
`rejection filter such that the voltage on the target alternates between positive and negative
`
`voltages" in combination with "providing an RF bias that corresponds to the narrow band
`
`rejection filter to the substrate," as is recited in claim 85.
`
`Therefore, at least for the reasons discussed above claim 85 is allowable over the
`
`combination of Smolanoff, Fu, and Li. Claims 41, 45, 47, 49, 51, and 52 depend from claim 85
`
`and are allowable over Smolanoff, Fu, and Li for at least the same reasons as is claim 85.
`
`Claims 42. 48. and 50
`
`Claims 42, 48, and 50 are rejected under 35 U.S.C. § 103(a) as being unpatentable over
`
`Smolanoff in view of Fu and Li, as applied to claims 41, 45, 47, 49, 51, 52, and 85, and in further
`
`view of U.S. Patent Publication No. 2004/0077161 to Chen et al. ("Chen").
`
`As discussed above, claim 85 is allowable over Smolanoff, Fu, and Li. Chen also does
`
`not teach "providing pulsed DC power to the target through a narrow band rejection filter such
`
`that the voltage on the target alternates between positive and negative voltages" in combination
`
`with "providing an RF bias that corresponds to the narrow band rejection filter to the substrate,"
`
`as is recited in claim 85.
`
`-12-
`
`DEM I NT00002522
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 20 of 21
`
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`Chen teaches "[a] method of layer formation on a substrate with high aspect ratio
`
`features." (Chen, par. 0008). As taught in Chen, "[t]he target power source 108 is used to infuse
`
`the one or more process gases with energy and may comprise a DC source, a radio frequency
`
`(RF) source, a DC-pulsed source, or a microwave source." Chen does not teach "providing
`
`pulsed DC power to the target through a narrow band rejection filter such that the voltage on the
`
`target alternates between positive and negative voltages," as is recited in claim 85. Chen further
`
`teaches that "the PVD chamber 36 may include a bias power source 124 for biasing the substrate
`
`120" and further that "[t]he bias power source 124 is typically an AC source having a frequency
`
`of, for example, about 400 kHz." (Chen, par. 0034). Because Chen does not teach "providing
`
`pulsed DC power," Chen does not teach or suggest "providing pulsed DC power to the target
`
`through a narrow band rejection filter such that the voltage on the target alternates between
`
`positive and negative voltages" in combination with "providing an RF bias that corresponds to
`
`the narrow band rejection filter to the substrate," as is recited in claim 85.
`
`Therefore, claim 85 is allowable over Smolanoff, Fu, Li and Chen. Claims 42, 48, and 50
`
`depend from claim 85 and are therefore allowable for at least the same reasons as is claim 85.
`
`Claims 43. and 53-58
`
`Claims 43, and 53-58 are rejected under 35 U.S.C. § 103(a) as being unpatentable over
`
`Smolanoff in view of Fu and Li, as applied to claims 41, 45, 47, 49, 51, 52, and 85, and in further
`
`view of U.S. Patent Publication No. 2003/0175142 to Milonopoulou et al. ("Milonopoulou").
`
`Milonopoulou was filed on the same day as was the present application, includes an
`
`overlap of inventorship with the present application (R. Ernest Demaray), is co-owned with the
`
`-13-
`
`DEM I NT00002523
`
`

`

`Case 6:20-cv-00636-ADA Document 48-7 Filed 02/16/21 Page 21 of 21
`U.S. Application No. 10/954,182
`Attorney Docket No. 10655.0016-01
`
`present application, and was incorporated by reference in the present application (Paragraph
`
`0048). Therefore, Milonopoulou can not be prior art to the present application.
`
`Claims 43 and 53-58 depend from claim 85 and are allowable over the cited art for at
`
`least the same reasons as is claim 85.
`
`Conclusion
`
`In view of the foregoing amendments and remarks, Applicants respectfully request timely
`
`allowance of the pending claims. If the Examiner has any questions about these Amendments or
`
`Remarks, the Examiner is invited to call Applicants' representative.
`
`Please grant any extensions of time required to enter this response and charge any
`
`additional required fees to our deposit account 06-0916.
`
`Dated: December 18, 2007
`
`Respectfully submitted,
`
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
`
`By: ~4-~
`PayfE~
`Reg. No. 41,008
`(650) 849-6622
`
`ptta-~e--- e· a~-r•~o; ~;~-fi-d a-tff- -J"9
`.
`'
`., J. a .
`i. e ho( B
`. F. C ng t
`2 (19 5) pp 203-208, and
`S. M. Rossnagel et al., Appl. Phys. Lett. 63 (1993), p. 24.
`
`-14-
`
`DEM I NT00002524
`
`