PTAB

IPR2014-00521

Intel Corp v. Zond LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus for Generating a Strongly-Ionized Plasma
  • Brief Description: The ’716 patent discloses a method and apparatus for generating plasma for applications like sputtering. The invention aims to reduce electrical arcing by first creating a "weakly-ionized plasma" and then applying a high-power electrical pulse to transform it into a "strongly-ionized plasma" for processing.

3. Grounds for Unpatentability

Ground 1: Claims 12 and 13 are obvious over Mozgrin in view of Lantsman.

  • Prior Art Relied Upon: Mozgrin (a 1995 article titled "High-Current Low-Pressure Quasi-Stationary Discharge in a Magnetic Field") and Lantsman (Patent 6,190,512).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the academic paper Mozgrin anticipates all limitations of independent claim 1, from which challenged claims 12 and 13 depend. Mozgrin describes a process for generating plasma that avoids arcing by operating in specific regimes. Petitioner equated Mozgrin’s initial "pre-ionization stage" (Region 1), which creates a plasma with a density of 10⁹–10¹¹ cm⁻³, to the claimed "weakly-ionized plasma." Subsequently, applying a high-voltage pulse transitions the plasma to a "high-current magnetron discharge" (Region 2) with a density exceeding 2x10¹³ cm⁻³, which Petitioner mapped to the claimed "strongly-ionized plasma." Mozgrin explicitly teaches that this pre-ionization step reduces the probability of the discharge transferring to an undesirable arc mode. The limitations of dependent claims 12 and 13, which recite a gas line for supplying feed gas and enabling additional power absorption, are not explicitly in Mozgrin. Petitioner contended these features are taught by Lantsman, which discloses supplying feed gas throughout the entirety of a plasma process to maintain a desired pressure.
    • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Mozgrin and Lantsman because both address the same field of plasma sputtering and share the common goal of avoiding arcing. Both references describe systems using two power supplies (one for pre-ionization/pre-ignition and one for deposition). A POSITA reading Mozgrin’s foundational teachings would look to a practical patent like Lantsman for well-known implementation details, such as managing gas flow, to create a stable and efficient sputtering system.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success, as combining Lantsman’s conventional gas flow control with Mozgrin’s plasma generation method involves applying known techniques to a known system to achieve a predictable result—maintaining stable pressure during processing.

Ground 2: Claims 12 and 13 are obvious over Wang in view of Lantsman.

  • Prior Art Relied Upon: Wang (Patent 6,413,382) and Lantsman (Patent 6,190,512).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Wang anticipates independent claim 1. Wang discloses a pulsed magnetron sputtering apparatus that uses two power levels to mitigate arcing. A constant, low background power (PB) maintains a low-density plasma between pulses, which Petitioner equated to the "weakly-ionized plasma." This pre-existing plasma "substantially eliminat[es] the probability" of arcing that typically occurs during plasma ignition. High-power pulses (PP) are then applied to this plasma to increase its density and perform sputtering, which Petitioner mapped to the "strongly-ionized plasma." As in Ground 1, Petitioner relied on Lantsman to supply the limitations of claims 12 and 13, arguing Lantsman’s disclosure of continuous gas flow during both pre-ionization and deposition phases would be an obvious addition to Wang’s system.
    • Motivation to Combine (for §103 grounds): The motivation to combine Wang and Lantsman is strong, as both patents are directed to plasma sputtering systems, use a two-stage power application (a lower power pre-ignition/maintenance stage and a higher power deposition stage), and are explicitly concerned with avoiding arcing. A POSITA seeking to implement Wang’s power scheme would naturally incorporate the standard practice of continuous gas exchange taught by Lantsman to maintain stable chamber pressure, a fundamental requirement for industrial sputtering.
    • Expectation of Success (for §103 grounds): The combination would have been expected to succeed because it amounts to integrating a standard, necessary process component (continuous gas flow from Lantsman) into the sputtering system of Wang. Each element would perform its known function predictably.

4. Key Claim Construction Positions

  • "weakly-ionized plasma" / "strongly-ionized plasma": Petitioner argued that these terms are not terms of art with a special meaning and should be construed based on their function and the patent’s description. The petition proposed that the terms simply denote relative plasma densities. Therefore, "weakly-ionized plasma" should be construed as "a lower density plasma," and "strongly-ionized plasma" should be construed as "a higher density plasma." This construction is central to the argument, as it allows Petitioner to map the prior art’s descriptions of low-density "pre-ionization" or "background" plasmas and subsequent high-density "deposition" plasmas directly onto the claim language.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and cancellation of claims 12 and 13 of the ’716 patent as unpatentable under 35 U.S.C. §103.