PTAB

IPR2014-00945

Intel Corp v. Zond LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: High-Density Plasma Source Using Excited Atoms
  • Brief Description: The ’652 patent discloses a two-stage plasma source for materials processing. The system uses an "excited atom source" to generate an initial plasma and excited atoms from a feed gas, which are then directed toward a cathode and anode assembly where a second power supply "super-ionizes" the initial plasma to create a high-density plasma.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mozgrin, Kudryavtsev, and Fahey - Claims 1-14, 16, and 17 are obvious over Mozgrin in view of Kudryavtsev and Fahey.

  • Prior Art Relied Upon: Mozgrin (a 1995 journal article on high-current plasma discharge), Kudryavtsev (a 1983 journal article on plasma ionization relaxation), and Fahey (a 1980 journal article on a high-flux metastable atom beam source).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mozgrin disclosed a high-density plasma source with a cathode, anode, and power supply capable of generating plasma densities orders of magnitude higher than required by the ’652 patent. Petitioner contended that Fahey disclosed an "excited atom source" with a structure substantially identical to the one depicted in the ’652 patent, which generates an initial plasma and excited atoms from a feed gas. The combination would involve positioning Fahey’s source to direct its beam of excited atoms and initial plasma proximate to the cathode assembly of Mozgrin’s device.
    • Motivation to Combine: A POSITA would combine these references because Mozgrin explicitly stated it considered Kudryavtsev’s teachings when designing its system. Kudryavtsev taught that multi-step ionization via excited atoms leads to an "explosive increase" in plasma density. This teaching would motivate a POSITA to incorporate a dedicated excited atom source, like that disclosed in Fahey, into Mozgrin’s system to predictably increase plasma density, thereby enhancing the performance of known processes like sputtering and etching.
    • Expectation of Success: The combination involved using known components (Fahey's source, Mozgrin's chamber) according to known principles (Kudryavtsev's multi-step ionization) to achieve the predictable result of increased plasma density.

Ground 2: Obviousness over Mozgrin, Kudryavtsev, Fahey, and Vratny - Claim 5 is obvious over the combination of Ground 1 in view of Vratny.

  • Prior Art Relied Upon: The combination from Ground 1, plus Vratny (Patent 3,461,054).
  • Core Argument for this Ground:
    • Prior Art Mapping: Claim 5 recites an RF power supply that generates an alternating electric field. Petitioner asserted that Vratny disclosed a cathodic sputtering system where an RF potential is superimposed on a DC bias to enhance deposition rates. Adding Vratny's RF power supply to the primary combination of Mozgrin, Kudryavtsev, and Fahey would satisfy the limitations of claim 5.
    • Motivation to Combine: A POSITA would be motivated to add Vratny's teaching to the primary combination for the express purpose of enhancing sputter deposition rates. This was a stated goal in both Vratny and Mozgrin, making the combination a predictable solution to a known problem.

Ground 3: Obviousness over Mozgrin, Kudryavtsev, Fahey, and Iwamura - Claims 1-14, 16, and 17 are obvious over the combination of Ground 1 in view of Iwamura.

  • Prior Art Relied Upon: The combination from Ground 1, plus Iwamura (Patent 5,753,886).

  • Core Argument for this Ground:

    • Prior Art Mapping: Iwamura was cited not for a specific component but for providing an overarching motivation for the claimed two-stage architecture.
    • Motivation to Combine: Petitioner argued that Iwamura expressly taught the desirability of a two-step plasma generation process: a "preexcitation unit" to generate excited gas species upstream, followed by a second unit that further energizes the gas. This teaching provided an independent and explicit reason for a POSITA to combine an excited atom source like Fahey with a high-power plasma generation stage like Mozgrin, reinforcing the rationale presented in Ground 1.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for specific dependent claims based on combinations including Lantsman (Patent 6,190,512) for constant power/voltage/current control modes and Wang (Patent 6,413,382) for a rotatable magnet assembly.

4. Key Claim Construction Positions

  • "super-ionizing the initial plasma": Petitioner argued this central claim term should be construed to mean "converting at least 75% of the neutral atoms in the initial plasma generated from a volume of feed gas to ions." This construction was derived from an explicit definition in the ’652 patent’s specification. It was critical to Petitioner's obviousness arguments, as it set a quantitative threshold that Petitioner argued was met by the prior art.

5. Key Technical Contentions (Beyond Claim Construction)

  • Implicit Disclosure of Super-Ionization in Mozgrin: A key technical contention was that Mozgrin, while not explicitly stating a percentage of ionization, inherently disclosed the conditions for achieving "super-ionization" as defined by the patent. Petitioner's expert used the ideal gas law to analyze the power, pressure, and ion density parameters reported in Mozgrin's "regime 3." The analysis concluded that the resulting gas temperature would have been sufficiently high (greater than 966 K) to cause more than 75% of the neutral argon atoms to be ionized, thereby meeting the "super-ionizing" limitation.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of the ’652 patent as unpatentable.