DCT

0:00-cv-04558

Plasma Physics Corp v. Mitsubishi Electric Corp

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:00-cv-04558, E.D.N.Y., 09/04/2001
  • Venue Allegations: Venue is asserted based on allegations that the defendants transact business in New York, contract to supply goods within the state, commit tortious acts causing injury in New York, and derive substantial revenue from commerce in the district. The U.S.-based defendants are also alleged to have a registered agent for service of process in New York.
  • Core Dispute: Plaintiffs allege that Defendants’ semiconductor wafer and flat panel display products, which are made by certain manufacturing processes, infringe four U.S. patents directed to methods for forming semiconducting materials and the resulting device structures.
  • Technical Context: The technology relates to semiconductor manufacturing, specifically the use of gaseous glow-discharge processes to deposit thin films of materials like amorphous silicon, a foundational technique for producing solar cells and flat panel displays.
  • Key Procedural History: This Amended Complaint, filed September 4, 2001, explicitly relates back for all substantive purposes to a prior case (CV-99-8593) filed on December 28, 1999. This earlier effective filing date is significant for the calculation of past damages.

Case Timeline

Date Event
1977-12-05 Priority Date for '897, '784, '634, and '648 Patents
1980-10-07 U.S. Patent 4,226,897 Issues
1995-11-28 U.S. Patent 5,470,784 Issues
1996-08-06 U.S. Patent 5,543,634 Issues
1999-12-28 Original Complaint Filing Date (via relation back)
2001-06-12 U.S. Patent 6,245,648 Issues
2001-09-04 Amended Complaint Filing Date

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

U.S. Patent No. 4,226,897 - "Method of Forming Semiconducting Materials and Barriers"

  • Patent Identification: U.S. Patent 4226897, titled "Method of Forming Semiconducting Materials and Barriers," issued October 7, 1980 ('897 Patent, cover; Compl. ¶7).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies shortcomings in prior art glow-discharge methods for creating amorphous silicon (a-Si) films, including the production of high-resistivity films unsuitable for many semiconductor applications and difficulties in creating uniform coatings over large, commercially viable areas ('897 Patent, col. 1:41-68).
  • The Patented Solution: The invention describes a method for forming semiconductor films using a glow-discharge process where a "spatially non-uniform electric field" is used to create a "weak field region" over the substrate ('897 Patent, Abstract). By controlling the gas pressure, the glow-discharge is maintained primarily in this weak field region, which is said to result in a more uniform deposition over a large area. The patent also discloses treating the resulting film with activated nitrogen species to form an improved barrier layer for semiconductor devices like solar cells ('897 Patent, col. 4:1-9; Fig. 1).
  • Technical Importance: The described process sought to improve the commercial feasibility of amorphous silicon devices by enabling the production of large-area, uniform semiconductor films with controlled electrical properties ('897 Patent, col. 2:11-24).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" without specification (Compl. ¶11). Independent claim 2 is representative of the core method:

  • The method of producing a film on the surface of a substrate in an evacuated enclosure, which includes the steps of:
  • introducing a gaseous material at sub-atmospheric pressure in the region of said surface,
  • applying to said surface a spatially non-uniform electric field having a weak field region extending over a portion of said surface,
  • and controlling said pressure to maintain a glow-discharge in said weak field region adjacent said portion of said surface,
  • to produce a substantially uniform film on said portion of said surface.

U.S. Patent No. 5,470,784 - "Method of Forming Semiconducting Materials and Barriers Using A Multiple Chamber Arrangement"

  • Patent Identification: U.S. Patent 5470784, titled "Method of Forming Semiconducting Materials and Barriers Using A Multiple Chamber Arrangement," issued November 28, 1995 (’784 Patent, cover; Compl. ¶8).

The Invention Explained

  • Problem Addressed: Fabricating multi-layer semiconductor devices in a single chamber can lead to cross-contamination, where residual gases from one deposition step (e.g., doping) adversely affect the purity and quality of subsequent layers (e.g., an intrinsic layer), thereby degrading overall device performance (’784 Patent, col. 7:8-12).
  • The Patented Solution: The invention discloses an in-line, multi-chamber manufacturing system where a substrate is transported sequentially through separate, isolated deposition chambers ('784 Patent, Fig. 4). Each chamber is dedicated to a specific process step, and "restricting means" (such as airlocks or differential pumping) between chambers prevent cross-contamination. This arrangement allows for the continuous and controlled fabrication of complex, high-purity, multi-layer semiconductor structures (’784 Patent, Abstract; col. 7:15-32).
  • Technical Importance: The multi-chamber approach facilitates high-throughput, automated manufacturing of semiconductor devices while mitigating the quality control problems associated with single-chamber batch processing (’784 Patent, col. 7:15-20).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" without specification (Compl. ¶11). Independent claim 1 is representative of the multi-chamber process:

  • A process for glow discharge deposition in an apparatus comprising a first deposition chamber, a second deposition chamber, restricting means, and transporting means.
  • The steps include disposing a substrate in the first chamber and depositing a first layer via a first glow discharge.
  • The substrate is then transported through the restricting means to the second chamber, while the interiors of the chambers are shielded from the external atmosphere.
  • In the second chamber, a second layer is deposited on the first layer via a second glow discharge.

U.S. Patent No. 5,543,634 - "Method of Forming Semiconductor Materials and Barriers"

  • Patent Identification: U.S. Patent 5543634, "Method of Forming Semiconductor Materials and Barriers," issued August 6, 1996 (Compl. ¶9).
  • Technology Synopsis: This patent claims the resulting semiconductor device, rather than the process. The claims are directed to a device comprising a body of hydrogenated amorphous silicon and an enhanced barrier layer, which itself includes a glow-discharge fabricated hydrogenated nitride of silicon and a metal oxide. This composite barrier is intended to improve device performance (’634 Patent, Abstract; col. 9:11-21).
  • Asserted Claims: The complaint asserts "one or more claims" of the patent (Compl. ¶11).
  • Accused Features: The complaint accuses "flat panel display cells and/or modules and/or products made therefrom" of infringing the ’634 patent (Compl. ¶5, 11).

U.S. Patent No. 6,245,648 - "Method of Forming Semiconducting Materials and Barriers"

  • Patent Identification: U.S. Patent 6245648, "Method of Forming Semiconducting Materials and Barriers," issued June 12, 2001 (Compl. ¶10).
  • Technology Synopsis: This patent claims a method for fabricating semiconductor devices using a multi-chamber system where a substrate is moved between isolated, evacuable enclosures. The claims focus on the sequence of steps, including introducing different gaseous materials into different chambers to deposit distinct films, thereby enabling the manufacture of complex structures while preventing cross-contamination (’648 Patent, Abstract; col. 9:1-29).
  • Asserted Claims: The complaint asserts "one or more claims" of the patent (Compl. ¶¶ 14, 15).
  • Accused Features: The complaint alleges that processes used to make "semiconductor wafer products" and "flat panel displays, cells and/or modules" infringe the ’648 patent (Compl. ¶¶ 14, 15).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities in broad categories as "semiconductor wafer products" and "flat panel display cells and/or modules and/or products made therefrom" that are manufactured, used, sold, or imported by the Defendants (Compl. ¶¶ 5, 11, 14, 15). No specific product models are named.

Functionality and Market Context

  • The complaint does not provide any specific technical details regarding the functionality, operation, or market context of the accused Mitsubishi products. The infringement allegations are based on the processes allegedly used to manufacture the products rather than their end-use functionality (Compl. ¶¶ 11, 14).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides no specific mapping of accused product features to claim limitations. The following charts are based on the general allegation that Defendants' manufacturing processes for semiconductor wafers and flat panel displays incorporate the claimed steps (Compl. ¶¶ 11, 14, 15). The "Alleged Infringing Functionality" column reflects the complaint's conclusory allegation, which lacks specific factual support.

'897 Patent Infringement Allegations

Claim Element (from Independent Claim 2) Alleged Infringing Functionality Complaint Citation Patent Citation
introducing a gaseous material at sub-atmospheric pressure in the region of said surface The complaint alleges that Defendants' processes for making the accused products utilize a gaseous material at sub-atmospheric pressure. ¶11 col. 3:20-28
applying to said surface a spatially non-uniform electric field having a weak field region extending over a portion of said surface The complaint alleges that Defendants' processes apply a spatially non-uniform electric field with a weak field region to the substrate surface. ¶11 col. 3:48-53
and controlling said pressure to maintain a glow-discharge in said weak field region adjacent said portion of said surface The complaint alleges that Defendants' processes control pressure to sustain a glow-discharge in the specified weak field region. ¶11 col. 3:41-47
to produce a substantially uniform film on said portion of said surface. The complaint alleges that this process results in the formation of a substantially uniform film on the substrate. ¶11 col. 2:65-3:2

'784 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A process for glow discharge deposition in an apparatus comprising, a first deposition chamber... a second deposition chamber... restricting means... The complaint alleges that Defendants' manufacturing apparatus contains at least two distinct, isolated deposition chambers. ¶11 col. 7:15-32
transporting said substrate on which said first layer is deposited from said first deposition chamber to said second deposition chamber through said restricting means, while each interior of said deposition chambers is shielded from an external atmosphere The complaint alleges that Defendants' processes move substrates between these isolated chambers while maintaining vacuum integrity. ¶11 col. 7:25-32
introducing said second gaseous material in said second deposition chamber and applying a second electric field... to generate a second glow discharge, whereby a second layer is deposited on said first layer. The complaint alleges that a second, different layer is deposited on the substrate in the second chamber. ¶11 col. 7:15-20

Identified Points of Contention

  • Factual Dispute: The central dispute will be factual, as the complaint offers no evidence that Defendants' manufacturing processes for semiconductor wafers and flat panel displays actually practice the methods claimed in the patents-in-suit. The viability of the infringement claims will depend on evidence obtained through discovery.
  • Scope Questions: The case may raise questions about the scope of key claim terms. For the '897 patent, this includes the definition of a "weak field region" and whether Defendants' processes create such a specific field configuration. For the '784 patent, a key question will be the scope of "restricting means" and whether the level of isolation in Defendants' manufacturing lines meets that claimed limitation.

V. Key Claim Terms for Construction

The complaint's lack of detail precludes a definitive analysis of which terms will be disputed. However, based on the technology, certain terms are central to the scope of the claims.

Term from the '897 Patent: "spatially non-uniform electric field having a weak field region"

  • The Term: "spatially non-uniform electric field having a weak field region"
  • Context and Importance: This phrase is the technological core of claim 2 of the '897 patent. Infringement hinges on whether an accused process generates an electric field meeting this description. Practitioners may focus on this term because it is not a standard industry term and its meaning will likely be defined by the patent's specification.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims define the term functionally by its purpose—to maintain a glow discharge adjacent to the substrate to produce a uniform film. Language such as "The discharge then occurs in the weaker region of the electric-field E" suggests the concept is not limited to a single structure (col. 3:48-49).
    • Evidence for a Narrower Interpretation: The specification heavily links the creation of this field to the specific concave electrode (4) and cylindrical pin (80) embodiments shown in Figures 1 and 3. The abstract states, "Electrodes having concave and cylindrical configurations are used to produce a spacially varying electric field," potentially limiting the term to fields created by such structures.

Term from the '784 Patent: "restricting means"

  • The Term: "restricting means"
  • Context and Importance: This term is critical for defining the required degree of isolation between chambers in the claimed multi-chamber process. The infringement analysis for the '784 patent will depend on whether the mechanisms used in Defendants' production lines meet the definition of this means-plus-function limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: As a means-plus-function term, its scope could be construed to cover any structure that performs the function of "restricting the flow of at least one of said gaseous materials," so long as it corresponds to a structure disclosed in the specification or its equivalent.
    • Evidence for a Narrower Interpretation: A party may argue the term is limited to the specific structures disclosed in the specification for performing the restricting function. The description of Figure 4 points to a combination of physical separation and differential pumping as the structure: "Pressures in ports 65, 66 are adjusted to be below that in compartments 62, 63, 64 to insure that the exhaust gases G do not flow into adjacent compartments" ('784 Patent, col. 7:8-12).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement of infringement for all four patents, although it provides no specific factual basis for the knowledge and intent required for such a claim (Compl. ¶¶ 5, 11, 14, 15). For the process patents ('897, '784, and '648), the complaint also alleges infringement under 35 U.S.C. § 271(g) based on the importation, sale, or use of products made abroad by the patented processes (Compl. ¶¶ 11, 14, 15).
  • Willful Infringement: Willful and deliberate infringement is alleged for the '897, '784, and '634 patents (Compl. ¶13). The complaint asserts this is based on "notice of infringement" having been given to Defendants (Compl. ¶12). No allegation of willfulness is made regarding the '648 patent, which issued less than three months before the amended complaint was filed.

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

  • A primary issue in this case will be one of factual proof: Given the conclusory nature of the complaint, the case will turn on whether discovery yields evidence that Defendants' specific, proprietary manufacturing processes for semiconductor wafers and flat panel displays actually practice the steps recited in the asserted method claims.
  • A second core issue will be one of claim construction: The resolution of the dispute may depend on the court's interpretation of key technical terms. A central question will be whether the scope of foundational terms like "weak field region" ('897 patent) and "restricting means" ('784 patent) is limited to the specific embodiments shown in the patents or can be construed more broadly to cover other functionally similar industrial processes.