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IPR2014-00470

Intel Corp v. Zond LLC

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1. Case Identification

2. Patent Overview

  • Title: Sputtering Using a Single Power Supply
  • Brief Description: The ’421 patent discloses methods and apparatus for plasma sputtering that use a single voltage pulse from a power supply. The pulse is shaped to first generate a low-density, "weakly-ionized" plasma and subsequently use that plasma to create a high-density, "strongly-ionized" plasma for sputtering, all while avoiding electrical arcing.

3. Grounds for Unpatentability

Ground 1: Claims 9 and 35 are obvious over Mozgrin in view of Kudryavtsev

  • Prior Art Relied Upon: Mozgrin (a 1995 journal article on plasma discharge) and Kudryavtsev (a 1983 journal article on plasma ionization relaxation).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mozgrin teaches all limitations of the independent claims from which claims 9 and 35 depend. Mozgrin describes a sputtering source that applies a voltage pulse to create a low-density "pre-ionization" plasma (the claimed "weakly-ionized plasma") and then transitions to a high-density "high-current magnetron discharge" (the claimed "strongly-ionized plasma"). Mozgrin explicitly teaches that this process can be performed without transiting to an arc discharge. The limitations added by dependent claims 9 and 35, related to the generation of excited atoms and their subsequent ionization by secondary electrons, are taught by the combination with Kudryavtsev. Kudryavtsev explains the physics of how applying a voltage pulse to a plasma creates excited atoms and leads to a two-stage ionization process (a slow stage followed by a fast "explosive" stage), which is dominated by the ionization of these excited atoms.
    • Motivation to Combine: A POSITA would combine these references because Mozgrin expressly states that in designing its experimental unit, it "took into account the dependences which had been obtained in [Kudryavtsev]." A POSITA reading Mozgrin would therefore be directly motivated to consult Kudryavtsev to better understand the underlying ionization physics and optimize the sputtering process by leveraging Kudryavtsev’s teachings on achieving rapid, multi-step ionization.
    • Expectation of Success: A POSITA would have a reasonable expectation of success, as combining Kudryavtsev’s fundamental principles on plasma ionization with Mozgrin's experimental sputtering apparatus is a predictable application of known science to improve a known process.

Ground 2: Claims 9, 21, and 35 are obvious over Wang in view of Kudryavtsev

  • Prior Art Relied Upon: Wang (Patent 6,413,382) and Kudryavtsev.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Wang, which describes a commercial pulsed sputtering device, anticipates the independent claims. Wang teaches using a low-level background power to maintain a continuous, low-density plasma (weakly-ionized) and then applying high-power pulses to generate a high-density plasma (strongly-ionized) for sputtering. Wang also explicitly teaches that this method avoids arcing after an initial, one-time plasma ignition. For the dependent claims, Petitioner again relied on Kudryavtsev to teach the generation of excited atoms in the weakly-ionized plasma and their subsequent ionization to create the strongly-ionized plasma. Wang’s disclosed power levels for the background and peak pulse fall within the ranges disclosed in the ’421 patent.
    • Motivation to Combine: Because Wang applies voltage pulses that suddenly generate an electric field in a weakly ionized gas, a POSITA would have been motivated to consult a fundamental text like Kudryavtsev. Kudryavtsev's teachings are directly characteristic of the phenomena in Wang's device, and a POSITA would seek to use Kudryavtsev's principles to better understand and optimize the ionization efficiency and sputtering rate in Wang's system.
    • Expectation of Success: Applying the known ionization physics from Kudryavtsev to the commercial sputtering system of Wang would predictably result in an enhanced understanding and optimization of the process.

Ground 3: Claim 21 is obvious over the combination of Mozgrin, Lantsman, and Kudryavtsev

  • Prior Art Relied Upon: Mozgrin, Lantsman (Patent 6,190,512), and Kudryavtsev.

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground builds on the combination of Mozgrin and Kudryavtsev from Ground 1. The additional reference, Lantsman, was introduced to teach limitations of independent claim 17 (from which claim 21 depends) not explicitly found in Mozgrin, specifically a "substrate support that is positioned adjacent to the sputtering target" and a "bias voltage source" coupled to that support. Lantsman explicitly discloses these features in the context of a plasma sputtering system. The final limitation of claim 21, regarding the excitation of atoms and ionization by secondary electrons, is taught by the combination with Kudryavtsev, as argued in prior grounds.
    • Motivation to Combine: A POSITA would be motivated to combine Mozgrin and Lantsman because both relate to the same field of plasma sputtering and address the common problem of avoiding arcing. To build a complete, practical sputtering device based on Mozgrin’s plasma generation teachings, a POSITA would have naturally looked to conventional components, such as the substrate support and bias supply taught by Lantsman, to hold a workpiece and control deposition.
    • Expectation of Success: Combining these known elements from the same technical field for their intended and well-understood functions would yield the predictable result of a functional sputtering system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including the Mozgrin Thesis (a more detailed version of the Mozgrin article) to provide further evidence for features like voltage pulse rise times, and combinations of Wang with the Mozgrin Thesis.

4. Key Claim Construction Positions

  • Petitioner proposed constructions for two key, related terms that are not explicitly defined in the patent:
    • "weakly-ionized plasma": Petitioner argued this term should be construed as "a lower density plasma."
    • "strongly-ionized plasma": Petitioner argued this term should be construed as "a higher density plasma."
  • These constructions are central to the invalidity arguments, as they allow Petitioner to map prior art that discloses generating plasmas of different densities (e.g., a "pre-ionization" plasma followed by a "high-current" plasma) directly onto the claim limitations.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 9, 14, 21, 26, 35, and 37 of the ’421 patent as unpatentable under 35 U.S.C. §103.