PTAB

IPR2014-00843

Intel Corp v. Zond LLC

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1. Case Identification

2. Patent Overview

  • Title: High-Density Plasma Source Using Excited Atoms
  • Brief Description: The [’652](https://ai-lab.exparte.com/case/ptab/IPR Trial No. TBD/doc/1101) patent discloses a method for generating high-density plasma using a two-stage process. The method involves first generating an initial plasma containing excited atoms from a feed gas at a first location, transporting it, and then "super-ionizing" this initial plasma at a separate, second location to create the final high-density plasma.

3. Grounds for Unpatentability

Ground 1: Claims 18-30 and 33-34 are obvious over Mozgrin, Kudryavtsev, and Fahey.

  • Prior Art Relied Upon: [Mozgrin](https://ai-lab.exparte.com/case/ptab/IPR Trial No. TBD/doc/1103) (a 1995 Plasma Physics Report), [Kudryavtsev](https://ai-lab.exparte.com/case/ptab/IPR Trial No. TBD/doc/1106) (a 1983 Sov. Phys. Tech. Phys. article), and [Fahey](https://ai-lab.exparte.com/case/ptab/IPR Trial No. TBD/doc/1105) (a 1980 J. Phys. E article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of these references taught every element of the challenged claims. Mozgrin was asserted to disclose a high-power plasma source capable of generating the claimed "high-density plasma" (exceeding 10^13 cm⁻³) and achieving the "super-ionizing" step (over 75% ionization) in its high-current operating regimes. Fahey was argued to teach a structurally similar source for generating an "initial plasma" with excited atoms and a gas exchange system for "transporting" it.
    • Motivation to Combine: Kudryavtsev taught that multi-step ionization—using excited atoms as an intermediate step—could "explosively" increase plasma density. Because Mozgrin's work was in the same field and acknowledged these principles, a Person of Ordinary Skill in the Art (POSITA) would have been motivated to add an external source of excited atoms, like the one taught by Fahey, to a high-density plasma system like Mozgrin's to achieve the known goal of further increasing plasma density.
    • Expectation of Success: Combining the references would predictably result in higher plasma density. Fahey would supply the initial excited atoms for the first stage, and Mozgrin's system would provide the high-power energy for the second, "super-ionizing" stage, directly aligning with the multi-step ionization principles described by Kudryavtsev.

Ground 2: Claims 31 and 32 are obvious over Mozgrin, Kudryavtsev, Fahey, and Campbell.

  • Prior Art Relied Upon: Mozgrin (a 1995 Plasma Physics Report), Kudryavtsev (a 1983 Sov. Phys. Tech. Phys. article), Fahey (a 1980 J. Phys. E article), and [Campbell](https://ai-lab.exparte.com/case/ptab/IPR Trial No. TBD/doc/1114) (Patent 5,429,070).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address dependent claims 31 and 32, which recite injecting a process gas for electron impact dissociation and performing plasma-enhanced chemical vapor deposition (PECVD). Petitioner asserted that Campbell taught the conventional process of PECVD, which involves injecting a "chemical gas" (i.e., process gas) into a plasma to dissociate it and deposit a film onto a substrate.
    • Motivation to Combine: Campbell explicitly taught that for PECVD, "it is therefore of importance to make the plasma as dense as possible" to improve the rate of dissociation and deposition. A POSITA would thus have been motivated to apply Campbell's well-known PECVD process to the highly effective, high-density plasma source created by the combination of Mozgrin, Kudryavtsev, and Fahey to achieve a more efficient deposition process.
    • Expectation of Success: Applying the conventional technique of PECVD from Campbell to the high-density plasma source from the primary combination would have been a straightforward integration of known elements to achieve the predictable result of improved film deposition.

Ground 3: Claims 18-30 are obvious over Mozgrin and Iwamura.

  • Prior Art Relied Upon: Mozgrin (a 1995 Plasma Physics Report) and [Iwamura](https://ai-lab.exparte.com/case/ptab/IPR Trial No. TBD/doc/1108) (Patent 5,753,886).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued this combination also taught all limitations of the independent claim. Iwamura was asserted to teach the first stage of the claimed method by disclosing a plasma apparatus with a "pre-excitation unit" (using UV or microwave energy) to generate an initial plasma with excited atoms, which is then transported downstream for further processing. Mozgrin was again relied upon to teach the second, "super-ionizing" stage, where a high-power discharge creates a high-density plasma.
    • Motivation to Combine: Both Mozgrin and Iwamura expressly taught the desirability of pre-ionization or pre-excitation to create a more stable plasma and avoid electrical arcing, a common problem in high-power plasma systems. A POSITA would have been motivated to combine Iwamura's pre-excitation first stage with Mozgrin's high-power second stage to achieve the predictable dual benefits of higher plasma density and a more stable, arc-free operation.
    • Expectation of Success: The combination was presented as a predictable design choice, substituting Iwamura's disclosed pre-excitation source for the pre-ionization step in Mozgrin's system to realize the known advantages described in both references.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations of the core references, such as adding Iwamura to the combinations in Grounds 1 and 2, which relied on similar motivations to enhance plasma stability or apply the resulting high-density plasma to known processes.

4. Key Claim Construction Positions

  • "transporting the initial plasma and excited atoms proximate to a cathode assembly": Petitioner proposed this term be construed as “moving the initial plasma and excited atoms from where they were generated to a location near a cathode assembly.” This construction was argued to be consistent with the patent's description and was important for highlighting the physical separation between the initial generation stage and the subsequent "super-ionization" stage, a key feature Petitioner mapped to the prior art combinations.
  • "super-ionizing the initial plasma...": Based on the patent’s explicit definition, Petitioner proposed construing this term as “converting at least 75% of the neutral atoms in the initial plasma into ions near the cathode assembly.” This quantitative benchmark was critical to Petitioner's argument that Mozgrin's high-power operating regimes, supported by technical calculations, inherently met this limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 18-34 of the ’652 patent as unpatentable under 35 U.S.C. §103.