Applied Materials, Inc. v. Cohen, Uri

1. Case Identification

• Case #: IPR2018-00732
• Patent #: 7,282,445
• Filed: March 6, 2018
• Petitioner(s): Applied Materials, Inc.
• Patent Owner(s): Dr. Uri Cohen
• Challenged Claims: 3, 5, and 8-12

2. Patent Overview

• Title: Multiple Seed Layers for Metallic Interconnects
• Brief Description: The ’445 patent discloses a method for making metallic interconnects on a semiconductor substrate. The method involves depositing two or more seed layers in via openings to promote subsequent void-free filling via electroplating.

3. Grounds for Unpatentability

Ground 1: Claims 3, 5, and 8-12 are obvious over Liu.

• Prior Art Relied Upon: Liu (Patent 6,037,258).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Liu, by itself, renders the challenged claims obvious. Liu discloses a method to fabricate a copper interconnect structure by depositing a first copper seed layer (5a) and a second copper seed layer (5b) using a multi-step physical vapor deposition (PVD) process within a cluster tool. Petitioner asserted that both of Liu's seed layers are continuous, deposited via PVD, and meet the claimed thickness requirements (500-1200Å is greater than 50Å). The use of a cluster tool inherently suggests that the substrate is not exposed to air between deposition steps.
  • Motivation to Combine (for §103 grounds): While this is a single-reference ground, Petitioner argued that to the extent Liu does not explicitly teach using an automatic controller with specific recipes, a person of ordinary skill in the art (POSITA) would have found it obvious to implement such standard automation. The ’445 patent itself admits that using automatic controllers with recipes in cluster tools was well known.
  • Expectation of Success: A POSITA would have expected that applying standard, well-known automated process controls to Liu's disclosed PVD deposition process would predictably and successfully produce the described seed layers.

Ground 2: Claims 8-12 are obvious over Liu in view of Gopalraja.

• Prior Art Relied Upon: Liu (Patent 6,037,258) and Gopalraja (Patent 6,042,700).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was asserted to the extent Liu is found not to teach a key limitation of claim 8: using a second set of deposition parameters that includes at least one parameter different from the first set. Liu provides the fundamental two-layer PVD seed layer process. Gopalraja was introduced for its explicit teaching of a two-step PVD sputtering process where deposition parameters (specifically, DC power to the target) are intentionally varied between steps to improve deposition uniformity and sidewall coverage.
  • Motivation to Combine: Petitioner argued a POSITA would combine these references because they are in the same field and address complementary problems. Liu seeks a smooth seed layer topography, while Gopalraja teaches a method to improve uniformity and coverage, which contributes to smoothness and continuity. A POSITA seeking to improve the radial uniformity of Liu's PVD process—a known problem in the art—would have been motivated to incorporate Gopalraja's technique of varying deposition parameters between steps.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in applying Gopalraja's parameter-varying technique to Liu's process. The combination involves applying a known technique (varying PVD parameters) to a known process (Liu's multi-step PVD) to achieve a predictable result (improved seed layer uniformity and coverage).

Ground 3: Claims 3, 5, and 8-12 are obvious over Liu in view of Nguyen.

• Prior Art Relied Upon: Liu (Patent 6,037,258) and Nguyen (Patent 6,122,566).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was asserted to the extent Liu is found not to explicitly teach the "automatic controller" and "recipe information" limitations of the claims. Liu provides the multi-chamber, multi-step deposition process. Nguyen was introduced for its detailed disclosure of a method and apparatus for controlling a multi-chamber semiconductor wafer processing system (a cluster tool). Nguyen explicitly teaches using a controller (controller 70) that executes recipes containing deposition sequences, process parameters (e.g., for PVD), and timing parameters to automate wafer processing.
  • Motivation to Combine: Petitioner argued that a POSITA would have been motivated to combine the teachings because it was standard practice to use automated controllers with multi-chamber cluster tools like the one used in Liu. Nguyen provides a clear, off-the-shelf example of such a controller. A POSITA implementing Liu's process would naturally and obviously use a controller like Nguyen's to achieve the required process control, efficiency, and repeatability.
  • Expectation of Success: The combination was argued to be predictable. Integrating a standard process controller (Nguyen) with a specific deposition process (Liu) would predictably result in the automated and controlled formation of seed layers. This amounts to implementing a known process using a known tool for its intended purpose.

4. Key Claim Construction Positions

• "Seed Layer": Petitioner contended that should the Board require an express construction, the term "seed layer" should be interpreted as "an electrically conductive layer that facilitates growth of a conductive material." Petitioner argued this reflects the broadest reasonable interpretation that a POSITA would have understood at the time of the invention.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §314(a) and §325(d). It contended that the petition was not abusive under the General Plastics factors, as it was filed less than two months after related IPRs against the same patent, and before the Patent Owner had filed a preliminary response in those cases. Petitioner further argued that the grounds presented here were not the same or substantially the same as those in the related petitions, which challenged a different set of claims using different prior art references.

6. Relief Requested

• Petitioner requested that the Board institute an inter partes review and cancel claims 3, 5, and 8-12 of the ’445 patent as unpatentable under 35 U.S.C. §103.