PTAB

IPR2014-00447

Intel Corp v. Zond LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Magnetically Enhanced Sputtering Source
  • Brief Description: The ’759 patent describes a two-stage sputtering technique for depositing thin films. The invention is directed to an ionization source that first generates a low-density, "weakly-ionized plasma" and then applies a specific high-voltage pulse to convert it into a high-density, "strongly-ionized plasma" using a multi-step ionization process, allegedly without forming an undesirable arc discharge.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mozgrin and Kudryavtsev - Claim 40 is obvious over Mozgrin in view of Kudryavtsev.

  • Prior Art Relied Upon: Mozgrin (a 1995 article titled "High-Current Low-Pressure Quasi-Stationary Discharge in a Magnetic Field: Experimental Research") and Kudryavtsev (a 1983 article titled "Ionization relaxation in a plasma produced by a pulsed inert-gas discharge").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mozgrin disclosed all limitations of claim 40. Mozgrin teaches a magnetically enhanced sputtering apparatus that uses a two-stage process: a "pre-ionization stage" (generating a weakly-ionized plasma) followed by the application of a high-voltage pulse to create a "high current magnetron discharge" (a strongly-ionized plasma) useful for sputtering. Petitioner asserted that Mozgrin explicitly teaches how to operate in arc-free regions by controlling discharge parameters, providing a "recipe for avoiding arcs." While Mozgrin discloses the result of a multi-step process, Kudryavtsev provides the underlying physics.
    • Motivation to Combine: A POSITA would combine these references because Mozgrin explicitly cites Kudryavtsev when discussing the design of its pulsed power supply unit. A POSITA reading Mozgrin would have been motivated to consult Kudryavtsev to better understand, predict, and optimize the ionization relaxation and multi-step ionization phenomena inherent in Mozgrin's pulsed system to increase plasma density and improve the sputtering rate.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Kudryavtsev provides fundamental, predictable principles of plasma physics directly applicable to the pulsed plasma system described in Mozgrin. Applying Kudryavtsev's teachings would predictably lead to an enhanced multi-step ionization process within Mozgrin's disclosed apparatus.

Ground 2: Obviousness over Wang and Kudryavtsev - Claim 40 is obvious over Wang in view of Kudryavtsev.

  • Prior Art Relied Upon: Wang (Patent 6,413,382) and Kudryavtsev (the same 1983 article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Wang, which describes a commercial-grade pulsed magnetron sputtering system, disclosed nearly all limitations of claim 40. Wang teaches using a low-level "background power" to maintain a continuous, low-density (weakly-ionized) plasma and applying high-power pulses to generate a high-density (strongly-ionized) plasma for "highly ionized sputtering." Wang explicitly teaches that this method reduces the initial arcing common in plasma ignition. The combination with Kudryavtsev was argued to supply the explicit scientific basis for the multi-step ionization that occurs within Wang’s system.
    • Motivation to Combine: A POSITA would combine these references because Wang’s use of high-power pulses to "suddenly generate an electric field" in a pre-existing plasma is precisely the scenario analyzed by Kudryavtsev. A POSITA seeking to optimize the sputtering rate and plasma density in Wang's system would be motivated to apply Kudryavtsev's teachings on achieving an "explosive increase" in electron density through multi-step ionization.
    • Expectation of Success: There would be a high expectation of success in applying Kudryavtsev's established plasma physics to Wang's practical sputtering device. Adjusting operating parameters in Wang's device (e.g., pulse length, pressure) according to Kudryavtsev's teachings would predictably result in an enhanced multi-step ionization process and increased plasma density, which was a known goal in the art.

4. Key Claim Construction Positions

Petitioner asserted that several claim terms required construction under the broadest reasonable interpretation standard.

  • "weakly-ionized plasma" / "strongly-ionized plasma": Petitioner proposed these terms should be construed relative to each other as "a lower density plasma" and "a higher density plasma," respectively. This construction was based on the specification's descriptions and exemplary density values provided in other claims of the ’759 patent.
  • "multi-step ionization process": Petitioner proposed this term means "an ionization process in which a statistically significant portion of the ions are produced by exciting ground state atoms or molecules and then ionizing the excited atoms or molecules." This was based on the patent's definition and arguments made by the Patent Owner during prosecution to distinguish over prior art that had insignificant levels of multi-step ionization.
  • Means-Plus-Function Terms: Petitioner identified the "means for ionizing," "means for generating a magnetic field," and "means for applying a voltage pulse" limitations as means-plus-function elements under §112. For each, Petitioner identified the claimed function and the corresponding structures disclosed in the ’759 patent specification, such as specific power supplies, magnet assemblies, and their physical arrangements.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 40 of the ’759 patent as unpatentable under 35 U.S.C. §103.