DCT

1:22-cv-01359

Inpria Corp v. Lam Research Corp

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-01359, D. Del., 12/13/2023
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in the state of Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s dry resist deposition process and associated products, used for extreme ultraviolet (EUV) semiconductor manufacturing, infringe eight patents related to metal oxide photoresist compositions and patterning methods.
  • Technical Context: The technology at issue involves advanced photoresist materials critical for EUV lithography, a key manufacturing process for producing next-generation semiconductors with increasingly small feature sizes.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patents-in-suit because they, or related parent applications, were cited during the prosecution of Defendant’s own U.S. and foreign patent applications, a fact that may be central to allegations of willful and indirect infringement.

Case Timeline

Date Event
2010-06-01 Priority Date for ’564 and ’312 Patents
2014-10-23 Priority Date for ’684 and ’153 Patents
2015-10-13 Priority Date for ’505, ’048, and ’081 Patents
2016-04-12 ’684 Patent Issued
2017-04-12 Priority Date for ’903 Patent
2017-11-21 ’564 Patent Issued
2020-02-26 Defendant Announces Accused Dry Resist Technology
2020-05-05 ’153 Patent Issued
2020-08-04 ’505 Patent Issued
2022-12-27 ’048 Patent Issued
2023-06-13 ’903 Patent Issued
2023-07-04 ’312 Patent Issued
2023-11-07 ’081 Patent Issued
2023-12-13 Amended Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,732,505 - "Organotin oxide hydroxide patterning compositions, precursors, and patterning"

The Invention Explained

  • Problem Addressed: The patent addresses the challenges of creating photoresist films from precursor solutions, particularly the constraints imposed by pre-hydrolyzing the chemical compounds before application, which can limit the choice of materials and solvents. (’505 Patent, col. 5:11-24).
  • The Patented Solution: The invention describes a method where organotin precursor compounds with easily hydrolysable ligands are deposited onto a substrate, often via a vapor phase, and then react with ambient water vapor (in situ) to form the desired organotin oxide hydroxide photoresist film. This process avoids the stability and solubility issues of pre-mixed solutions and enables a wider range of precursor chemistries. (’505 Patent, Abstract; col. 5:36-47).
  • Technical Importance: This in situ hydrolysis approach, particularly through vapor deposition, allows for the creation of uniform, high-purity photoresist films while simplifying the manufacturing process compared to traditional liquid-based, pre-mixed resist formulations. (’505 Patent, col. 6:8-18).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶50).
  • Essential elements of claim 1 include:
    • A method for forming a radiation patternable organometallic coating.
    • Depositing a tin composition having organic ligands and hydrolysable ligands.
    • The organic ligands comprise radiation sensitive Sn—C bonds.
    • The hydrolysable ligands comprise an alkoxide, an alkylamide, an azide, a dialkylamide, a siloxide, a silylamide, or similar groups.
    • The depositing is by a vapor-based deposition process.
  • The complaint expressly reserves the right to assert additional claims. (Compl. ¶51).

U.S. Patent No. 9,823,564 - "Patterned inorganic layers, radiation based patterning compositions and corresponding methods"

The Invention Explained

  • Problem Addressed: The patent background describes that aqueous solutions of metal suboxides, which can be used to form inorganic resists, are often unstable and prone to gelling or precipitation, making them difficult to use in manufacturing. (’564 Patent, col. 5:40-44).
  • The Patented Solution: The invention discloses a stabilized precursor solution that uses peroxide-based ligands. These ligands bind to metal suboxide cations to prevent premature condensation and instability. When the resulting film is exposed to radiation, the peroxide ligands break, allowing the material to condense and form a patternable inorganic layer. (’564 Patent, Abstract; col. 6:45-54).
  • Technical Importance: This use of peroxide-based ligands as radiation-sensitive stabilizers enabled the creation of stable, high-contrast inorganic photoresist solutions, overcoming a key technical barrier for their adoption in high-resolution lithography. (’564 Patent, col. 6:4-10).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶62).
  • Essential elements of claim 1 include:
    • A structure comprising a substrate and a coating material on its surface.
    • The coating material comprises metal ions with radiation sensitive ligands.
    • Exposure of the coating material to UV, EUV, and/or electron-beam radiation alters its chemical properties.
    • This alteration creates an exposed coating material with differential dissolution rates between exposed and un-exposed regions.
  • The complaint expressly reserves the right to assert additional claims. (Compl. ¶63).

U.S. Patent No. 9,310,684 - "Organometallic solution based high resolution patterning compositions"

  • Technology Synopsis: This patent relates to organometallic resist compositions, particularly those using organo-tin compounds. The technology focuses on the formulation of the precursor solution itself to achieve high-resolution patterning and stability. (’684 Patent, Abstract).
  • Asserted Claims: Independent claim 10. (Compl. ¶74).
  • Accused Features: The accused features are Defendant's dry resist products, alleged to be organometallic compositions used for patterning. (Compl. ¶¶18, 74).

U.S. Patent No. 10,642,153 - "Organometallic solution based high resolution patterning compositions and corresponding methods"

  • Technology Synopsis: This patent, related to the ’684 Patent, describes radiation resist compositions based on tin ions with specific branched alkyl ligands. The use of branched ligands, such as tert-butyl, is disclosed as a solution to improve patterning contrast and radiation sensitivity while maintaining solution stability. (’153 Patent, Abstract; col. 7:20-30).
  • Asserted Claims: Independent claim 18. (Compl. ¶86).
  • Accused Features: The accused features are Defendant's dry resist products, which are alleged to contain organo-tin compounds with alkyl ligands used for high-resolution patterning. (Compl. ¶¶18, 24, 86).

U.S. Patent No. 11,537,048 - "Organotin oxide hydroxide patterning compositions, precursors, and patterning"

  • Technology Synopsis: This patent, related to the ’505 Patent, describes methods and systems for forming organotin photoresists using vapor deposition. The invention involves introducing precursor vapors into a deposition chamber to react and form a coating on a substrate, providing a method for in situ resist formation. (’048 Patent, Abstract; Fig. 16).
  • Asserted Claims: Independent claim 1. (Compl. ¶98).
  • Accused Features: The accused instrumentality is Defendant's "dry deposition" process, which allegedly uses a vapor phase reaction to form an organotin photoresist film. (Compl. ¶¶18, 20, 98).

U.S. Patent No. 11,673,903 - "Monoalkyl tin compounds with low polyalkyl contamination, their compositions and methods"

  • Technology Synopsis: This patent addresses the problem of contamination in precursor materials. It discloses methods for synthesizing high-purity monoalkyl tin compounds with low levels of polyalkyl tin contaminants, which can improve the performance and consistency of the resulting photoresist films. (’903 Patent, Abstract).
  • Asserted Claims: Independent claim 1. (Compl. ¶110).
  • Accused Features: The complaint alleges that Defendant's dry resist products are, or are made from, monoalkyl tin compounds. (Compl. ¶¶18, 24, 110).

U.S. Patent No. 11,693,312 - "Radiation based patterning methods"

  • Technology Synopsis: This patent, related to the ’564 Patent, describes methods of patterning using stabilized inorganic precursor solutions containing metal suboxide cations and peroxide-based ligands. The technology focuses on the process of irradiating and developing these films to form high-resolution patterns. (’312 Patent, Abstract).
  • Asserted Claims: Independent claim 1. (Compl. ¶122).
  • Accused Features: Defendant's dry resist products are accused of being radiation-based patterning compositions that form patterned inorganic layers. (Compl. ¶¶18, 20, 122).

U.S. Patent No. 11,809,081 - "Organotin oxide hydroxide patterning compositions, precursors, and patterning"

  • Technology Synopsis: This patent, also related to the ’505 Patent, further covers methods of forming organotin coatings via vapor-based deposition. It claims methods involving the deposition of tin compositions with specific organic and hydrolysable ligands to form a patternable coating. (’081 Patent, Abstract).
  • Asserted Claims: Independent claim 1. (Compl. ¶134).
  • Accused Features: The accused method is Defendant's "dry deposition" process, alleged to be a vapor-based method for creating an organotin photoresist. (Compl. ¶¶18, 20, 134).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are Defendant's "dry resist" or "dry deposition" process products, including a product line named "Aether" (Compl. ¶¶18, 26).
  • Functionality and Market Context: The accused technology is a process for applying photoresist films for EUV lithography. The complaint alleges that, unlike traditional "spin-on" liquid resists, Defendant's process uses "reactive organometallic precursors in a vapor phase" to deposit a uniform film of "small metalorganic units" (Compl. ¶¶20, 21, 23). The complaint includes a diagram from Defendant's materials contrasting this "Dry" deposition process with the conventional "Wet" process (Compl. p. 5). The complaint also cites Defendant's patent filings, which allegedly describe a "photoresist film...deposited based on a gas phase reaction of an organotin precursor" (Compl. ¶25). Defendant is alleged to have projected a market for these products greater than $1 billion (Compl. ¶32).

IV. Analysis of Infringement Allegations

’505 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method for forming a radiation patternable organometallic coating... Defendant's accused products are part of a process for EUV patterning using organometallic materials. ¶¶18, 20 col. 2:40-42
depositing a tin composition having organic ligands and hydrolysable ligands... Defendant's process allegedly uses an "organotin precursor" such as "isopropyl(tris)(dimethylamino)tin," and its provisional filings depict an "organotin composition." ¶¶24, 25 col. 12:48-52
wherein the organic ligands comprise radiation sensitive Sn—C bonds... The complaint alleges Defendant's precursors are "organotin" materials, which inherently contain radiation-sensitive Tin-Carbon (Sn-C) bonds. ¶¶24, 25 col. 7:20-25
wherein the depositing is by a vapor-based deposition process. Defendant's technology is described as a "dry deposition" process that applies precursors in a "vapor phase." A diagram from Defendant's presentation explicitly depicts this "Dry deposit" step. ¶¶18, 20; p. 5 col. 1:21-27
  • Identified Points of Contention:
    • Scope Questions: A potential issue may be whether the final film created by Defendant's process meets the specific chemical definition of an "organotin oxide hydroxide composition" as contemplated by the patent's specification and claims.
    • Technical Questions: The complaint alleges the use of an "organotin precursor." A key question will be what evidence demonstrates that this precursor, when deposited via the accused vapor process, forms a coating with the specific structural and compositional elements required by the claim.

’564 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A structure comprising a substrate and a coating material... Defendant's process creates a photoresist film on a semiconductor wafer substrate. ¶¶20, 28 col. 5:9-11
wherein the coating material comprises metal ions with radiation sensitive ligands... Defendant's photoresist is described as being composed of "small metalorganic units" and "organotin" materials, where the organo-tin (Sn-C) bond acts as the radiation-sensitive ligand. ¶¶23, 24 col. 6:4-10
wherein exposure of the coating material to...EUV...radiation alters the chemical properties of the coating material... Defendant's public presentations allegedly state that "EUV exposure and subsequent bake steps induce crosslinking and densification." ¶20 col. 5:45-54
creating an exposed coating material with differential dissolution rates between exposed and un-exposed regions... The complaint alleges Defendant's presentations describe that after exposure, "unexposed areas remain hydrophobic and freely soluble in common organic solvents," creating a dissolution differential. ¶20 col. 5:11-18
  • Identified Points of Contention:
    • Scope Questions: The '564 Patent's specification extensively discusses peroxide-based ligands as the solution to the problem of resist instability. A central question for claim construction will be whether the term "radiation sensitive ligands" is broad enough to read on the organo-tin (Sn-C) bonds in Defendant's accused products, or if the claim scope is implicitly narrowed by the specification's focus on peroxide chemistry.
    • Technical Questions: Does the alteration in Defendant's film ("crosslinking and densification") constitute the same type of chemical property alteration described in the '564 Patent, which focuses on the breaking of peroxide ligands to enable condensation?

V. Key Claim Terms for Construction

The Term: "radiation sensitive ligands" (’564 Patent, Claim 1)

  • Context and Importance: This term is critical because the '564 Patent specification teaches the use of peroxide-based ligands to solve the technical problem of solution instability. The complaint accuses a process based on organo-tin precursors, where the tin-carbon bond is the ligand sensitive to radiation. The viability of the infringement claim against the '564 patent family may depend on whether this term is construed broadly to cover any radiation-labile bond or more narrowly to the class of stabilizing ligands disclosed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to peroxides, simply requiring "radiation sensitive ligands." The term "ligand" in chemistry broadly refers to an ion or molecule attached to a metal atom, which would include the organic group in an organo-tin compound. (’564 Patent, col. 6:4-10).
    • Evidence for a Narrower Interpretation: The patent's abstract and detailed description frame the invention around solving instability by using peroxide-based ligands. Parties may argue that the specification defines the invention as this specific solution, potentially limiting the scope of the claims to peroxide or chemically similar stabilizing ligands. (’564 Patent, Abstract; col. 5:45-54).

The Term: "vapor-based deposition process" (’505 Patent, Claim 1)

  • Context and Importance: This term defines the core method step. Practitioners may focus on this term because the infringement allegation hinges on classifying Defendant’s "dry resist" process as a "vapor-based deposition process." The complaint provides strong evidence for this, including Defendant’s own descriptions of using a "vapor phase." (Compl. ¶20).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification mentions that the precursor compositions can be applied via "in situ hydrolysis or vapor based deposition." This suggests the patent contemplates a variety of non-solution-based methods. (’505 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The detailed description discusses specific vapor deposition techniques like chemical vapor deposition (CVD) and atomic layer deposition (ALD). A dispute could arise if Defendant's process does not fall squarely within established definitions of these techniques, raising the question of whether the claim covers Defendant's specific "dry deposition" approach. (’505 Patent, col. 6:8-18).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement by Defendant encouraging and instructing customers and end users on how to use the accused dry resist products in an infringing manner through user guides, technical specifications, and training. (Compl. ¶34). The complaint further alleges inducement through collaborations with customers like SK hynix and precursor chemical suppliers like Entegris and Gelest to "accelerate dry resist adoption." (Compl. ¶¶36, 37, 44).
  • Willful Infringement: Willfulness is alleged based on Defendant’s pre-suit knowledge of the Inpria Patents. The complaint asserts that Defendant was aware of the patents-in-suit (or their parent applications) because they were cited by patent examiners during the prosecution of Defendant's own patent applications in the U.S. and abroad. (Compl. ¶30). The complaint further alleges Defendant has monitored developments in the field, including those by Inpria. (Compl. ¶31).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can the term "radiation sensitive ligands," as used in the ’564 patent family and taught in the context of peroxide-based stabilizers, be construed to cover the organo-tin (Sn-C) bonds in the accused dry resist technology, or does the patent's specification implicitly limit the claim's reach?
  • A second central question will be one of technical characterization: does the film created by Defendant's "dry deposition" of an "organotin precursor" result in the specific "organotin oxide hydroxide composition" required by the claims of the '505 patent family, and does the process itself meet all the limitations of the asserted method claims?
  • A key issue for damages and indirect infringement will be knowledge and intent: the complaint presents specific allegations that Defendant had pre-suit knowledge of the asserted patents from citations in its own patent prosecution files, which will be a focal point for establishing induced and willful infringement.