DCT

0:05-cv-01396

August Technology Corp v. Camtek Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:05-cv-01396, D. Minn., 04/12/2006
  • Venue Allegations: Venue is alleged to be proper based on Defendant's importation, distribution, and purposeful sale and offers for sale of the accused products within the District of Minnesota.
  • Core Dispute: Plaintiffs allege that Defendant’s Falcon line of automated visual inspection systems infringes a patent related to automated semiconductor wafer defect inspection.
  • Technical Context: Automated optical inspection of semiconductor wafers is a critical process for ensuring quality and maximizing yield in the microelectronics manufacturing industry.
  • Key Procedural History: The complaint alleges that Plaintiff August Technology Corporation notified Defendant Camtek of the patent-in-suit and its potential infringement by the accused Falcon device on or about February 1, 2005, more than a year before filing the complaint.

Case Timeline

Date Event
1998-07-14 U.S. Patent No. 6,826,298 Priority Date
2004-11-30 U.S. Patent No. 6,826,298 Issued
2005-02-01 Pre-suit notice letter allegedly sent to Defendant Camtek
2006-04-12 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 6,826,298, "AUTOMATED WAFER DEFECT INSPECTION SYSTEM AND A PROCESS OF PERFORMING SUCH INSPECTION," issued November 30, 2004.

The Invention Explained

  • Problem Addressed: The patent's background section describes the "second optical inspection" stage in semiconductor manufacturing as having been "largely ignored" by automation and still reliant on manual inspection by human operators. This manual process is described as inaccurate and slow, struggling to keep pace with increasing circuit density and new manufacturing techniques like flip-chip interconnects (’298 Patent, col. 2:11-30).
  • The Patented Solution: The invention is an automated inspection system designed to replace this manual process. The system is first "trained" by optically viewing a plurality of "known good die" to create a statistical "good die model." Subsequently, unknown wafers are inspected by comparing their images to this model to identify defects. The system is described as being capable of inspecting wafers while they are in motion using strobed illumination to increase throughput (’298 Patent, col. 1:30-38; col. 8:8-19).
  • Technical Importance: The invention proposed an automated solution for a critical, yet previously manual and error-prone, stage of semiconductor quality control, addressing a bottleneck in manufacturing throughput and reliability (’298 Patent, col. 2:16-30).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" without specifying which ones (Compl., Prayer for Relief ¶B). The patent's independent claims, Claim 1 (a system) and Claim 3 (a method), are representative of the core invention.
  • Independent Claim 1 (System) includes:
    • A wafer test plate;
    • A visual inspection device for inputting images of known good wafers during a training phase and unknown wafers during an inspection phase;
    • An illumination system (including brightfield, darkfield, or darkfield laser options) where at least one illuminator "strobes to provide short pulses of light during movement of a wafer"; and
    • A microprocessor for "developing a model of good quality wafer" from the training images and "comparing unknown quality wafers to the model."
  • Independent Claim 3 (Method) includes:
    • "training a model as to parameters of a good wafer via optical viewing of multiple known good wafers";
    • Illuminating unknown wafers with an illumination system where at least one illuminator "flashes on and off during movement of a wafer"; and
    • "inspecting unknown quality wafers using the model."

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "automated wafer inspection systems including, but not to, its Falcon line of products" (Compl. ¶15).

Functionality and Market Context

The complaint describes the accused products as "automated visual inspection systems for the microelectronics industry" that have been imported into the United States and sold for inspecting semiconductor wafer defects (Compl. ¶¶4, 7). The complaint does not provide specific details on the technical operation or architecture of the Falcon systems.

IV. Analysis of Infringement Allegations

The complaint does not provide specific factual allegations mapping elements of the asserted claims to features of the accused Falcon products. It makes a general allegation that the Falcon line of products infringes one or more claims of the ’298 patent (Compl. ¶15). Consequently, a detailed claim chart analysis is not possible based on the provided document.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: The patented method requires creating a "good die model" based on a training set of multiple good die, which is then used as the basis for comparison. A central question for the court will be whether the accused Falcon system's method for identifying defects falls within the scope of "training a model" and "comparing" as required by the claims, or if it uses a fundamentally different technique (e.g., comparison to a single golden image or a pre-defined set of design rules).
    • Technical Questions: Independent claims 1 and 3 require inspection to occur "during movement" of the wafer, enabled by "strobes" or "flashes." A key factual question will be whether the accused Falcon systems perform inspection while the wafer is in continuous motion to capture images "on-the-fly." The complaint provides no information that would help determine if the accused systems operate in this manner or use a more traditional "stop-and-go" imaging process, which may not meet this claim limitation.

V. Key Claim Terms for Construction

  • The Term: "training a model"

    • Context and Importance: This term describes the foundational process of the invention, where the system learns what constitutes an acceptable wafer. The construction of this term will be critical in determining whether the accused system's calibration or learning process constitutes infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's objectives section states an aim is to provide a system that "develops a model of a good die and uses this model to inspect unknown quality die," which could be argued to encompass any process of learning from examples (’298 Patent, col. 3:21-24).
      • Evidence for a Narrower Interpretation: The detailed description discloses a specific statistical implementation where "a mean and a standard deviation of the gray-scale number for each pixel" is calculated from a training set of thirty good die. A party could argue the term should be limited to such a statistical-modeling approach (’298 Patent, col. 14:26-34).

  • The Term: "strobes to provide short pulses of light during movement of a wafer"

    • Context and Importance: This limitation appears to be a key point of novelty, distinguishing the invention's "on-the-fly" inspection capability from slower, conventional methods. Practitioners may focus on this term because infringement will hinge on whether the accused system inspects wafers while they are physically in motion.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The language could be interpreted to cover any illumination and capture that occurs while the wafer stage is not fully stationary, as long as a clear image is obtained.
      • Evidence for a Narrower Interpretation: The specification explicitly contrasts this method with a "stop and go procedure" and describes it in the context of "continuously moving the plate" (’298 Patent, col. 8:8-15). This could support a narrower construction requiring continuous, non-stop scanning, potentially excluding systems that use rapid start-stop movements.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant has induced and contributed to the infringement of the ’298 patent (Compl. ¶15). However, it does not plead specific facts to support these allegations beyond the general claim that Defendant manufactures, uses, and sells the accused systems.
  • Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. The complaint alleges that Defendant had "actual knowledge" of the ’298 patent and its "likely infringement" as of February 1, 2005, due to a notice letter sent by Plaintiff August Technology (Compl. ¶¶8, 17). The allegation of willfulness is predicated on Defendant's continued sale of the accused Falcon products after receiving this notice (Compl. ¶¶9, 18).

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

  • A core issue will be one of technical and definitional scope: does the accused Falcon system's method for identifying defects meet the claim requirement of "training a model" from a plurality of known "good die," or does it operate on a different technical principle that falls outside the patent's specific teachings?
  • A key evidentiary question will be one of operational function: does the accused Falcon system perform inspection "during movement" of the wafer using strobed illumination, as recited in the independent claims? The resolution of this factual dispute will likely depend on expert analysis of how the Falcon system physically operates to acquire images.