Applied Materials Inc v. Uri Cohen

1. Case Identification

• Case #: IPR2018-00731
• Patent #: 7,199,052
• Filed: March 6, 2018
• Petitioner(s): Applied Materials, Inc.
• Patent Owner(s): Dr. Uri Cohen
• Challenged Claims: 12, 19, 21, 23-25, 28, 35, 38, 39, 41-44, 48-52, 55, and 59-64

2. Patent Overview

• Title: Multiple Seed Layers for Metallic Interconnects
• Brief Description: The ’052 patent discloses methods for making metallic interconnects on semiconductor substrates. The methods involve depositing two distinct seed layers to facilitate the void-free electrochemical filling of high-aspect-ratio openings, such as vias and trenches, with copper.

3. Grounds for Unpatentability

Ground 1: Claims 12, 19, 21, 24, 25, 28, 35, 38, 39, 42-44, 48, 49, 51, 52, 55, and 59-64 are anticipated under 35 U.S.C. § 102 by [Liu](https://ai-lab.exparte.com/case/ptab/IPR2018-00731/doc/1005).

• Prior Art Relied Upon: Liu (Patent 6,037,258).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Liu disclosed every element of the challenged claims. Liu described a method for fabricating copper interconnects by depositing a first copper seed layer using a Physical Vapor Deposition (PVD) technique, which provided continuous coverage of the sidewalls and bottom of a damascene opening. Liu then disclosed depositing a second copper seed layer, also via a PVD technique, over the first. The combined thickness of Liu’s two seed layers (1000-2400Å) was argued to inherently provide a low electrical resistance path for subsequent uniform electroplating, as recited in the claims. Finally, Liu taught completely filling the opening by electroplating a thick copper layer over the seed layers. Petitioner asserted that Liu’s disclosed thickness ranges for the two seed layers (500-1200Å each) inherently disclosed embodiments where the first layer is thicker than the second, anticipating claims with that specific limitation.

Ground 2: Claims 19, 21, 23-25, 35, 38, 39, 41-44, and 48-52 are obvious over Liu.

• Prior Art Relied Upon: Liu (Patent 6,037,258).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground served as an alternative to anticipation. Petitioner argued that even if Liu did not explicitly disclose an embodiment where the first seed layer is thicker than the second, it would have been obvious to a Person of Ordinary Skill in the Art (POSITA) to implement such a configuration.
  • Motivation to Combine (for §103 grounds): Petitioner contended that since Liu taught a thickness range (500-1200Å) for both seed layers, a POSITA would have found it obvious to explore the finite and predictable options within these disclosed ranges. Making one layer thicker than the other was presented as a simple design choice to optimize the process, with no technical obstacles preventing such a configuration. The motivation was to pursue known, predictable solutions to achieve a desired seed layer structure.
  • Expectation of Success: A POSITA would have had a high expectation of success because varying the relative thicknesses of the layers was a routine process optimization using known PVD techniques.

Ground 3: Claims 59-64 are obvious over Liu in view of [Gopalraja](https://ai-lab.exparte.com/case/ptab/IPR2018-00731/doc/1006).

• Prior Art Relied Upon: Liu (Patent 6,037,258) and Gopalraja (Patent 6,042,700).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that the combination of Liu and Gopalraja rendered claims 59-64 obvious. Liu taught the foundational two-step PVD seed layer process. The key limitation at issue in claim 59 was the requirement that the deposition of the second seed layer uses a "second set of deposition parameters" that includes "at least one deposition parameter which is different than in the first set." To the extent Liu’s disclosure of an intervening cooling step (changing the temperature parameter) was insufficient, Petitioner argued Gopalraja explicitly taught this element. Gopalraja disclosed a two-step PVD process for improving deposition uniformity by intentionally varying deposition parameters, such as DC power, between the steps.
  • Motivation to Combine: A POSITA would combine these references because both addressed the same field of improving PVD-deposited thin films for semiconductor manufacturing. Liu’s goal of achieving a smooth, continuous seed layer aligned with Gopalraja’s goal of improving film uniformity and sidewall coverage. A POSITA seeking to improve the radial uniformity of Liu’s seed layers—a known problem in the art—would have been motivated to incorporate Gopalraja’s technique of using different deposition parameters for the two PVD steps.
  • Expectation of Success: The combination was a simple substitution of a known technique (Gopalraja's varied-parameter sputtering) into a known process (Liu's two-step deposition) to achieve a predictable improvement in film uniformity.

4. Key Claim Construction Positions

• "Seed Layer": Petitioner contended that most terms should be given their plain and ordinary meaning. However, should the Board require a construction for "seed layer," Petitioner proposed it should be understood as "an electrically conductive layer that facilitates growth of a conductive material." This construction was argued to be consistent with the understanding of a POSITA at the time of the invention and necessary to properly interpret the scope of the prior art’s teachings against the claims.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) was not warranted. While the ’052 patent was involved in co-pending district court litigation and other IPR petitions had been filed, this petition challenged a different set of claims and presented different grounds. Petitioner asserted that the filing was not abusive under the General Plastics factors, as the Patent Owner had not yet filed a preliminary response in the earlier petitions and the Board had not yet made an institution decision. Therefore, denying institution would not serve the interests of efficiency and would run contrary to the public interest in canceling invalid patent claims.

6. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 12, 19, 21, 23-25, 28, 35, 38, 39, 41-44, 48-52, 55, and 59-64 of the ’052 patent as unpatentable.