PTAB

IPR2014-00497

Intel Corp v. Zond LLC

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1. Case Identification

2. Patent Overview

  • Title: Methods and Apparatus for Generating a Strongly-Ionized Plasma
  • Brief Description: The ’142 patent discloses methods and apparatus for generating plasma for applications such as industrial sputtering. The invention is directed to a two-step process that first generates a "weakly-ionized plasma" to reduce the probability of electrical arcing, and then applies an electrical pulse to increase the plasma’s density to form a "strongly-ionized plasma."

3. Grounds for Unpatentability

Ground 1: Claims 22-23, 25, 29-30, 33-36, 39 and 43 are obvious over Mozgrin in view of Kudryavtsev.

  • Prior Art Relied Upon: Mozgrin (a 1995 article, "High-Current Low-Pressure Quasi-Stationary Discharge in a Magnetic Field") and Kudryavtsev (a 1983 article, "Ionization relaxation in a plasma produced by a pulsed inert-gas discharge").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mozgrin discloses all elements of the claimed invention. Mozgrin describes a plasma discharge process with distinct operational regions, teaching that operating within specific parameters avoids electrical arcing. Petitioner mapped Mozgrin’s initial "pre-ionization stage" (Region 1) to the claimed "weakly-ionized plasma," asserting it serves the claimed purpose of reducing the probability of electrical breakdown. Petitioner then argued that applying a high-voltage pulse, as taught by Mozgrin, transitions this plasma to a high-density "high-current magnetron discharge" (Region 2) or "high-current diffuse discharge" (Region 3), which corresponds to the claimed "strongly-ionized plasma." Kudryavtsev was cited to provide the underlying physics, explaining how applying a voltage pulse to a weakly ionized gas generates excited atoms and leads to an "explosive increase" in plasma density via multi-step ionization.
    • Motivation to Combine: Petitioner contended that Mozgrin explicitly cites Kudryavtsev when discussing the design of its pulsed power supply unit. A person of ordinary skill in the art (POSITA), upon reading Mozgrin, would have been directly motivated to consult Kudryavtsev to better understand, predict, and optimize the ionization relaxation process in Mozgrin's system. This would be done to achieve the predictable result of increasing plasma density and thereby enhancing the sputtering rate.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying Kudryavtsev's fundamental teachings to Mozgrin’s experimental setup. The combination represented the application of known plasma physics principles to a described apparatus to achieve the predictable outcome of more efficient ionization.

Ground 2: Claims 22-23, 25, 29-30, 33-36, 39 and 43 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 teaches a pulsed magnetron sputtering device, discloses the claimed two-step plasma generation process. Wang uses a low "background power level" to maintain a continuous, low-density plasma between high-power pulses. Petitioner equated this low-density plasma to the claimed "weakly-ionized plasma," arguing it reduces arcing by eliminating the need for repeated, high-arcing-risk plasma ignition events. Wang then applies a high "peak power" pulse to this existing plasma to create a high-density plasma for "highly ionized sputtering." Petitioner mapped this high-density state to the claimed "strongly-ionized plasma." Kudryavtsev was again used to explain the underlying physics of how Wang’s high-power pulse would generate excited atoms and cause a rapid increase in plasma density.
    • Motivation to Combine: Petitioner argued a POSITA would combine Kudryavtsev with Wang to understand and optimize the effects of Wang’s high-power pulses. Because Wang’s system applies pulses that "suddenly generate an electric field," a POSITA would naturally look to a fundamental reference like Kudryavtsev, which explains ionization under such conditions. The motivation would be to predictably increase plasma density, thereby improving the sputtering rate and reducing the time required to reach the target density.
    • Expectation of Success: A POSITA would expect that the principles of multi-step ionization described in Kudryavtsev would be applicable to the pulsed system in Wang. The combination would have yielded the predictable result of an increased ionization rate and a more efficient transition to a high-density plasma state.

4. Key Claim Construction Positions

  • Petitioner argued that the key claim terms "weakly-ionized plasma" and "strongly-ionized plasma" lacked explicit definitions in the ’142 patent and should be given their broadest reasonable interpretation.
  • Petitioner proposed the construction for "weakly-ionized plasma" is "a lower density plasma" and for "strongly-ionized plasma" is "a higher density plasma." This relative definition was crucial to the obviousness arguments, allowing prior art that discloses any two-step, low-to-high density plasma transition to be mapped onto the claims. Petitioner supported this construction by pointing to the patent’s specification and the Patent Owner's own arguments in a related European patent prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 22, 23, 25, 29, 30, 33-36, 39, and 43 as unpatentable under 35 U.S.C. §103.