`Case 6:20-cv-00636—ADA Document 77-8 Filed 03/10/21 Page 1 of 74
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`EXHIBIT 19
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`EXHIBIT 19
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`Case 6:20-cv-00636-ADA Document 77-8 Filed 03/10/21 Page 2 of 74
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`APPLIED MATERIALS, INC.
`Petitioner,
`
`
`
`
`
`v.
`
`DEMARAY LLC
`Patent Owner.
`___________________
`
`Case IPR2021-00104
`Patent No. 7,381,657
`___________________
`
`
`
`DECLARATION OF DR. ALEXANDER GLEW IN SUPPORT OF PATENT
`OWNER’S PRELIMINARY RESPONSE
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`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
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`Demaray Ex. 2002-p.1
`Applied Materials v Demaray
`IPR2021-00104
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`Case 6:20-cv-00636-ADA Document 77-8 Filed 03/10/21 Page 3 of 74
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`Case IPR2021-00104
`Patent No. 7,381,657
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`TABLE OF CONTENTS
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`I.
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`II.
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`Qualification ................................................................................................. 1
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`Knowledge of a POSITA .............................................................................. 3
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`III. Technology Background ............................................................................... 5
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`A. Magnetron Sputtering System ............................................................ 5
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`1.
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`2.
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`3.
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`4.
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`Targeted Reaction On Substrates Instead Of Targets .............. 7
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`Controlled Flow Rate Of Reactive Gases .............................. 10
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`Arc Suppression ..................................................................... 11
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`Synergy of different techniques ............................................. 13
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`Reactor Systems ............................................................................... 14
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`The Importance Of Filter Type For The Claimed Reactor
`System .............................................................................................. 18
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`B.
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`C.
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`IV. Cited References ......................................................................................... 22
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`A.
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`B.
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`C.
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`Barber ............................................................................................... 22
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`Licata ................................................................................................ 28
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`Kelly ................................................................................................. 32
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`D. Hirose ............................................................................................... 34
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`E.
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`F.
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`Collins............................................................................................... 39
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`Other Filter References .................................................................... 39
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`1.
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`2.
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`3.
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`Ex. 1023 (“Miller”) ................................................................ 40
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`Exhibits 1009, 1011 & 1012 .................................................. 42
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`Ex. 1013 ................................................................................. 43
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`Case IPR2021-00104
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`Ex. 1057 (“Sill”) .................................................................... 44
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`Ex. 1058 (“Zennamo”) ........................................................... 46
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`Ex. 1016 (“Celestino”) ........................................................... 46
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`Ex. 1014 ................................................................................. 48
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`Ex. 1017 ................................................................................. 49
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`Ex. 1018 ................................................................................. 50
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`10. Ex. 1019 ................................................................................. 52
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`11. Ex. 1020 ................................................................................. 53
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`12. Ex. 1021 ................................................................................. 55
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`13. Exs. 1024, 1025, 1026, 1062 and 1067 .................................. 56
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`V.
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`The ’657 Patent ........................................................................................... 57
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`I.
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`Qualification
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`1. My name is Alexander D. Glew, Ph.D., P.E. My qualifications are
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`summarized below and are addressed more fully in my CV attached as EXHIBIT
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`A.
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`2.
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`For 33 years I have been involved with engineering practice. A large
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`portion of my work has involved semiconductor fabrication, including product
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`design, semiconductor device analysis, semiconductor equipment design and
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`analysis, thin film processing, equipment, characterization, and project
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`development. I was intimately involved in this field during the time of the patents
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`at issue in this case.
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`3.
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`I received my Bachelor of Science in Mechanical Engineering from
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`the University of California, Berkeley, in 1985; I received my Master of Science in
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`Mechanical Engineering from the University of California, Berkeley, in 1987; I
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`received my Master of Science in Materials Science and Engineering from
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`Stanford University in 1995.
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`4.
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`I received my Doctor of Philosophy in Materials Science and
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`Engineering from Stanford University in 2003. My dissertation involved plasma
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`CVD of diamond-like carbon, fluorinated diamond-like carbon, and low k
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`dielectrics.
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`5.
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`I began my career with Applied Materials, Inc., one of the leading
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`companies that supplies equipment for semiconductor manufacturer. My services
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`to Applied Materials included various engineering roles: product development,
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`project management, core technology, and supplier quality management. I
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`remained at Applied Materials for ten years.
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`6.
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`I hold six patents on technologies such as tungsten chemical vapor
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`deposition, and ultra-high purity and high-temperature valves, and thin film heater
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`and chuck design for processing chambers. I have authored or co-authored over
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`nine articles, presentations, and seminars on topics including semiconductor thin
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`film processing and diamond like carbon.
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`7.
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`I have been asked by Demaray LLC (“Patent Owner”) to explain the
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`technologies involved in U.S. Pat. Nos. 7,381,657 and 7,544,276 (collectively “the
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`Demaray Patents”), the technologies described in the cited references, the
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`knowledge of a person of ordinary skill in the art at the time of the invention, and
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`other pertinent facts and opinions regarding IPR2021-00103 through 106. For the
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`purpose of this declaration, I apply the same skill level as proposed in the Petition,
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`although I reserve the right to explain why this level is too high. I am being
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`compensated for my work on this case at a fixed, hourly rate, plus reimbursement
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`for expenses. My compensation does not depend on the outcome of this case or
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`any issue in it, and I have no interest in this proceeding.
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`II. Knowledge of a POSITA
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`8. My testimony below is from the perspective of a person of ordinary
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`skill in the art at the time of the invention. I apply Petitioner’s definition of such a
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`skilled artisan for the purpose of this declaration, but I reserve the right to offer an
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`alternative level later in the proceeding or in the Texas Litigations.
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`9.
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`I am familiar with the skill level and knowledge of the skilled artisan
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`as defined by Petitioner because of my 33 years of experience in the industry and
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`my interactions with such people.
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`10.
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`In general, these skilled artisans would know that, at the time of the
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`invention, plasma processing was a complex and unpredictable process (and it still
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`is today). They would know that filters were specifically designed for a given
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`reactor system and thus could not just be applied to a totally different reactor
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`system. For example, they would know that a filter coupled to an RF power supply
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`was (and still is generally) designed to work with an RF matching circuit sized for
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`the RF power supply and the connected reactor system to make sure the designed
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`impedance was maintained for the plasma system. They would recognize that an
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`RF matching circuit was designed to enable as much of the RF power supply
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`output as possible to flow from the RF power source to the reactor and to minimize
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`the amount of energy that would travel in the reverse direction from the reactor to
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`the RF power source. They would know that an RF filter was designed to
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`supplement the tuning offered by the RF matching circuit and they generally would
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`not work without such an RF matching circuit.
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`11. A skilled artisan would also know that an RF matching circuits would
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`not work with a DC power source including pulsed DC power source because an
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`RF matching circuit, functioning like a big capacitor coupled to an associated
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`power supply, required a change in voltage output from the power supply while a
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`DC power source generally outputted a constant voltage. They would know that,
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`even a pulsed DC power supply would output a voltage that was constant most of
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`the time and that the change in voltage potential was only designed to occur as the
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`polarity of the DC power supply was switched or when the DC power supply was
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`de-energized (or turned off). They would recognize this difference between DC
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`and AC/RF power supplies, that is, while an AC or RF power supply’s voltage
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`output would change constantly, a DC power supply’s voltage output was designed
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`to be constant in general. As a result, a skilled artisan would know that a filter
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`designed with an RF matching circuit would not have worked with a DC power
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`supply (including a pulsed DC power supply) that had no associated RF matching
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`circuit.
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`12. A skilled artisan would also not have viewed bipolar pulsed DC
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`power supplies as necessary or helpful if the surface of the sputtering target
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`remained conductive. This is because, as Petitioner’s own reference suggested, at
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`the time of the invention, it was thought that arcing was caused by charge
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`accumulation on an insulating target surface that could not be effectively
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`conducted away and the sudden discharge of those accumulated charges. Ex. 1036
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`at 3 (“When an insulating material forms on the surface of the sputtering target
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`during deposition, those insulating surfaces build up a charge and then discharge
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`during dc reactive sputtering, which results in arcing.”). As a result, a skilled
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`artisan would not view it necessary or beneficial to alternate the target surface from
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`positive to negative using a pulsed DC power supply if the target surface remained
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`conductive during deposition and arcing was not an issue.
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`13. Below I first provide some background in the relevant sputtering
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`technology and then discuss Petitioner’s references in detail.
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`III. Technology Background
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`A. Magnetron Sputtering System
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`14. Fabrication of integrated circuits involves formation of defined
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`features on a substrate, such as a silicon wafer. The formation of these defined
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`features often begins with deposition of thin films of the appropriate materials,
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`such as titanium, tungsten and titanium nitride as barrier or nucleation layers. Ex.
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`1012, 1:10-24. In modern manufacturing, thin film are often deposited by physical
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`vapor deposition (PVD), also referred to as sputtering.
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`15. Sputtering involves the production of a vapors, which then deposit by
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`physical means on the substrate. As the feature sizes on integrated circuit become
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`smaller and smaller, the industry has gravitated towards plasma-assisted sputtering.
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`16.
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`In a plasma-assisted sputtering, “ions in a plasma are attracted to the
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`target at sufficient energy….” Ex. 1012 at 1:10-16. The “target is bombarded with
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`ions, and the atoms of the target material are mechanically ejected from the target
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`and deposited onto a nearby substrate.” Ex. 1005, 2:1-5. An ion is a charged
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`particle. One can use electrical attraction of the ion toward an electrically charged
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`substrate to direct it in a more vertical trajectory toward the surface, which has
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`certain advantages.
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`17. Sputtering can also involve a reactive gas, which “is introduced into
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`the deposition chamber and reacts with the target material to produce a film [on the
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`target] that is sputtered onto the substrate….” Ex. 1005, 2:5-9. The freed material
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`is deposited onto the substrate either directly or upon further reaction with the
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`reactive gas. Id. This ejected processing involving reactive gases (such as
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`nitrogen or oxygen) is known as reactive sputtering. Reactive sputtering
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`traditionally suffered from low deposition rate, arcing due to forming of an
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`insulating film on the target and poorer film quality due to varying stoichiometry
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`over the course of the deposition. Ex. 1048 at 2.
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`18. Several techniques were developed to improve the deposition rate as
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`well as density and adhesion of film formed by reactive sputtering. Ex. 1036 at 1.
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`Some techniques help direct the reaction away from the target and toward the
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`substrate; some provide more precise control of the amount of reactive gases in the
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`reactor (e.g., control of partial pressure of reactive gases); and still others help
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`neutralize the charge build-up during deposition so as to reduce the incidence of
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`arcing (e.g., bipolar pulsed DC power to the target).
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`1.
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`Targeted Reaction On Substrates Instead Of Targets
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`19.
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`“Magnetron sputtering is a principal method of depositing. Magnets
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`have been coupled to targets to increase the directionality and deposition rates. In a
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`magnetron sputtering systems, a magnetron having opposed magnetic poles is
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`disposed at the back of the target “to generate a magnetic field close to and parallel
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`to the front face of the target.” Ex. 1012, 1:35-37. The “magnetically-enhanced
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`targets are used to confine the plasma discharge along a particular path and
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`enhance the flow of target material.” Ex. 1005, 2:27-29. The magnetic field
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`generated near the target surface “traps electrons, and, for charge neutrality in the
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`plasma, additional argon ions are attracted into the region adjacent to the
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`magnetron to form there a high-density plasma.” Ex. 1012 at 1:37-41. The higher
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`concentration of plasma increases the sputtering rate. Id.
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`20. Traditionally, “the strength of the inner and outer magnets is roughly
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`equal,” and “the magnetron is said to be balanced.” Ex. 1036 at 1-2. In a balanced
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`magnet, “most of the magnetic field lines will loop between the inner and out
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`magnets as is shown” below. Ex. 1036 at 1-2. In such a system, any electrons
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`escaping from the primary magnetic trap between the inner and outer magnets will
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`go to anode and be lost. Id. The primary magnetic trap “is responsible for the
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`formation of the dense plasma directly in front of the sputtering target and for the
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`higher deposition rate of the magnetron cathode compared to a diode cathode.”
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`Ex. 1036 at 1. But the location of the reaction also increases the likelihood of
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`forming an insulating film on the target, therefore leading to arcing and variance in
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`stoichiometry over the course of deposition.
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`21.
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`In contrast, in unbalanced magnetron, one set of the magnets—
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`typically the outer magnets—is made stronger than the other, and “some field lines
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`from the stronger magnets will radiate away from the magnetic surfaces as is
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`shown” below. Id.
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`22.
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`In an unbalanced magnetron system, “the escaping energetic electrons
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`are trapped by excess magnetic field lines, and the electron spiral along the field
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`lines” to “undergo ionizing collisions with gas atoms.” Ex. 1036 at 1. “A
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`secondary plasma is formed away from the target surface from these ionizing
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`collisions and this secondary plasma can be used for ion-assisted deposition of the
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`growing film.” Id. at 2. Current density on the substrate in an unbalanced
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`magnetron system is greater than in a comparable balanced magnetron system. Id.
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`23. One effect of the unbalanced magnetron system is to form secondary
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`plasma away from the target and to energize substrate surface to stimulate reaction
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`of the reactive gas directly on the substrate (as on the target). Strongly unbalanced
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`magnetron, however, may create non-uniformity near the substrate.
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`24. Several other techniques, such as thermally energizing the substrate,
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`biasing the substrate to form a plasma near the substrate, providing a secondary
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`plasma generation source for creating a plasma in the volume between the target
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`and substrate and for creating a magnetic field line that is directed towards the
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`substrate, also produce similar technical effects. These other techniques were
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`described, for example, in Licata. Ex. 1010, 10:23-31, 7:11-25.
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`2.
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`Controlled Flow Rate Of Reactive Gases
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`25. Better control of the deposited film’s stoichiometry as well as reaction
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`rates may be achieved by a more precise control of the flow rate of the reactive
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`gas. The goal is to control the amount of reactive gas in the reactor for a given
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`reactor system.
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`26. One technique, as described by Sproul, is via control of the partial
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`pressure of the reactive gas at a desired set point. Ex. 1036 at 2-3. According to
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`Sproul, when done correctly, TiN can be deposited as the same rate as Ti and it
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`becomes possible to “produce the same compound material” with the repeatable
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`stoichiometry “in every run.” Ex. 1036 at 3.
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`27. Barber also provides a method for controlling the amount of reactive
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`gas in a reactor. Barber’s method involves first determining a relationship between
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`the chamber total pressure and the flow rate of the reactive gas such as nitrogen
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`and oxygen with a preset flow rate of the inert gases such as argon. See Ex. 1005,
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`8:49-56; 9:29-36. A cross-over point is then determined, where the cross-over
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`point corresponds to the point at which the increase in total chamber pressure
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`becomes non-linear with the flow of the reactive gases. Id.; see also 6:34-50.
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`28. The reactive gases are then introduced into the reaction chamber at a
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`flow rate that is about 3 sccm above the cross-over point. Id., 8:59-64, 9:35-36.
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`Assuming ideal gas law applies, the partial pressure of the reactive gas is chamber
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`pressure × molar ratio of reactive gas, with the molar ratio of reactive gas being
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`(cid:3045)(cid:3032)(cid:3028)(cid:3030)(cid:3047)(cid:3036)(cid:3049)(cid:3032) (cid:3034)(cid:3028)(cid:3046) (cid:3033)(cid:3039)(cid:3042)(cid:3050) (cid:3045)(cid:3028)(cid:3047)(cid:3032)
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`(cid:3045)(cid:3032)(cid:3028)(cid:3030)(cid:3047)(cid:3036)(cid:3049)(cid:3032) (cid:3034)(cid:3028)(cid:3046) (cid:3033)(cid:3039)(cid:3042)(cid:3050) (cid:3045)(cid:3028)(cid:3047)(cid:3032)(cid:2878) (cid:3033)(cid:3039)(cid:3042)(cid:3050) (cid:3045)(cid:3028)(cid:3047)(cid:3032)
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`. Because for a given reactor system (e.g., at a
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`preset argon flow rate, like below), a given reactive gas flow rate produces a given
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`chamber pressure, setting the reactive gas flow rate to a fixed value effectively
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`fixes the partial pressure of the reactive gas as well. In other words, Barber
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`improves the deposition rate and film quality of the deposited insulating films
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`effective by controlling the partial pressure of the reactive gases.
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`3.
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`Arc Suppression
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`29. As mentioned before, one drawback associated with reactive
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`sputtering is the build-up of an insulating film such as nitrides, oxides, oxynitrides
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`on the target surface. Ex. 1048 at 1; Ex. 1036 at 2. The build-up of such an
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`insulating film makes the target’s surface also more insulating; and “those
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`insulating surfaces build up a charge and then discharge during dc reactive
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`sputtering, which results in arcing.” Ex. 1036 at 3. The burst of high energy
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`released in arcing can damage power supplies to target and eject particles, even
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`liquid drops, from the target, (id.), resulting in contamination and poor film quality.
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`30. Arcing occurs when the accumulated charge causes a breakthrough in
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`the insulating film on the target surface. Each dielectric material has a dielectric
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`breakdown strength characterized by voltage divided by distance. When a high
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`level of electrons are emitted from the breakthrough area, (i.e., when discharge
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`occurs), an arc appears. Arcing is an unpredictable process causing changing
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`impedance in the reactor’s electrical circuits.
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`31. RF power with alternating positive and negative voltages theoretically
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`can alleviate the problem associated with charge accumulation on the insulating
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`surface of the target. But because sputtering occurs only in the negative voltage
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`regime, essentially half of the power is wasted. Ex. 1036 at 3.
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`32. Bipolar pulsed DC power that alternates between negative and
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`positive potentials has thus been suggested to suppress arcing. Ex. 1036 at 4; Ex.
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`1048 at 2. In bipolar pulsed DC power systems, the electric potential formed
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`between the cathode and the anode in the chamber is reversed periodically to
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`prevent charge accumulating on the target insulating film. More specifically, the
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`positive portion of the applied voltage neutralizes accumulation of positive charge
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`on the surface of the target insulating film. The negative portion of the applied
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`voltage, if sufficient, causes ions from the accumulated layer to sputter off the
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`target material, removing ions and allowing them to accumulate on the substrate.
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`Ex. 1060 at 2:24-3:5.
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`4.
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`Synergy of different techniques
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`33. Magnetron sputtering is a complicated process. The effects of
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`modifying reactor designs and process parameters are often unpredictable. For
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`example, one paper stated that “[w]ithout [a] combination of pulsed dc power and
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`partial pressure control, it really was not possible to reactively sputter Al2O3 at
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`high deposition rates in a practical way.” Ex. 1036 at 5.
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`34. As another example, the inventors noticed that using a pulsed DC
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`power supply at the target may not by itself provide for the desired quality of
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`deposited film. Ex. 1001, 5:66-6:6, 10:3-4. By applying an RF bias to the
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`substrate during deposition, as discussed above, the directionality of the deposition
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`is enhanced and a simultaneous deposition and etching of the film on the substrate
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`help densify the films by eliminating columnar structures in the deposited film. Id.
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`B. Reactor Systems
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`35. There are different plasma-assisted deposition systems, some with a
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`magnetron and others without. Some apply an RF power to the target, others apply
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`continuous DC and yet others apply pulsed DC (unipolar or bipolar). Some apply
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`an RF bias to the substrate, some apply a DC bias and still others may rely on self-
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`bias. Some may include an RF coil to surround the reactor walls to generate a
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`plasma field between the target and the substrate, while others do not.
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`36. For example, Hirose involves a plasma processing apparatus for
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`etching that apply one higher frequency (e.g., 60 MHz) RF power 14 to the target
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`and apply another lower frequency (e.g., 2 MHz) RF bias 15 to the substrate. E.g.,
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`Ex. 1006 at 5:26-30, 5:40-43. Hirose’s reactor does not include a magnetron. As
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`with most RF power sources, matching circuits are coupled to the RF power
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`sources for impedance matching to maximize power transfer and minimize signal
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`reflection from the load. In Hirose, the filter 20 is tuned so that is slightly off
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`resonance with the RF power source 15. See Ex.1005, abstract, 5:58-62.
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`37.
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`[Intentionally left blank]
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`38. Licata is an example of a magnetron IPVD system that applies a DC
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`power to the target and an RF bias power to the substrate. An RF generator
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`coupled to a coil generates a plasma in volume 26 between the target and substrate
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`that assists the targeted bombardment of the substrate.
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`39. Licata’s system is similar to Smolanoff discussed in detail during the
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`prosecution of the parent ’356 patent (indeed Licata is an inventor on both patents).
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`Both systems provide a DC power to the target via an “RF FILTER” 22. Both
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`apply an RF bias power 27 via a matching network to the substrate holder. Both
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`include an RF generator 32 with a matching network that is inductively coupled
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`into the chamber to generate a secondary plasma that assists in in-flight ionization
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`of ejected particles and better directs the targeted flow of the ejected particles.
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`Neither reference, however, explains the type of filter 22 used.
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`40. Still other systems apply bipolar DC pulses to the target. This
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`includes, for example, Barber (Ex. 1005), Kelly (Exs. 1048, 1059), Belkind (Ex.
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`1008), Sproul (Ex. 1011), and Miller (Ex. 1060). Some systems applied an RF bias
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`to the substrate, some applied a DC bias and still others allowed the substrate to
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`develop a self-bias. None of these references, however, mention the use of a filter
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`coupled with the bipolar pulsed DC power sources. Id. This is not surprising as it
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`is possible to run a plasma processing chamber without any filters with the right
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`control of circuit elements and frequency. Parameters such as pressure,
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`temperature, gas density, gas and gas ratio all determine the gas’s electrical
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`impedance. Ex. 1060, 8:9-30. For example, pulse frequency affects plasma
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`conditions because positively charged gas ions are much heavier than electrons.
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`Thus, electrons move much faster than the positively charged gas ions. By
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`choosing the right combination of pulse frequency (how frequently positive
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`voltage is applied) and pulse width (which determines how long positive voltage is
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`applied), one can suppress arcing. Thus, in many circumstances, one can prevent
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`RF coupling into the DC power source and thus obviates the need for a filter to the
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`bipolar pulsed DC power source.
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`41.
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`It should be noted, however, given the complexity of the reactor
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`system and the unpredictable nature of the deposition process, a skilled artisan
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`would not treat components of the reactor systems as modular pieces. For
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`example, they would not expect that a filter designed for a reactor system applying
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`only RF powers to target and substrate would be suitable for a reactor system using
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`a DC power to the target and RF power to the substrate. The electrical design of
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`the filter depends very strongly on the frequencies involved. Whereas pulsed DC
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`voltage does change from positive to negative as does AC, RF is AC, the DC
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`change is sharp compared to AC, thus it actually turns out that the DC pulse
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`generates many harmonics and odd frequencies. It is important not to filter out
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`portions of the DC signal while trying to filter out the undesired AC. The pulsed
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`DC power is not a perfect square wave, and the filter must accommodate it.
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`C. The Importance Of Filter Type For The Claimed Reactor System
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`42. While none of references on prior bipolar pulsed DC systems
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`mentioned the use of a filter with the bipolar pulsed DC power source, the
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`inventors discovered that not only a filter is needed for a claimed reactor system
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`with a bipolar pulsed DC power to a target and an RF bias power to a substrate, but
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`it needs to be a specific type of filter, i.e., a claimed narrow band rejection filter
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`that operates (or rejects) at a frequency of the RF bias power to the substrate.
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`During the prosecution of the parent ’356 patent, the inventors repeatedly
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`explained the unexpected discovery of the importance of the type of filter for the
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`claimed reactor system:
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`Ex. 1052 at 1134.
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`43. The inventors also disputed the examiner’s view that selection of a
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`filter type is merely a design choice and the right filter would be expected to work
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`under the right frequency:
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`Ex. 1052 at 1456-57.
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`44. The examiner accepted the explanation and thereafter allowed claims
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`that recited a combination of a claimed filter and a claimed reactor system with
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`bipolar pulsed-DC power to the target and an RF bias on the substrate. Ex. 1052 at
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`1448-53 (pending claims), 1471 (notice of allowance).
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`45.
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`In the ’657 patent’s prosecution, the examiner similarly allowed the
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`claims after the inventors successfully traversed that examiner’s incorrect
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`impression that filter choice was merely “a design choice.” Ex. 1004 at 957, 978-
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