PTAB
IPR2018-00828
Avant Technology Inc v. Anza Technology Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2018-00828
- Patent #: 7,124,927
- Filed: March 25, 2018
- Petitioner(s): Avant Technology, Inc.
- Patent Owner(s): Anza Technology, Inc.
- Challenged Claims: 1-4 and 14-17
2. Patent Overview
- Title: Flip Chip Bonding Tool and Ball Placement Capillary
- Brief Description: The ’927 patent discloses a flip chip capillary bonding tool for microelectronics assembly. The core inventive concept is the use of an "electrically dissipative" material on the tool tip to prevent electrostatic discharge (ESD) from damaging semiconductor devices during the bonding process.
3. Grounds for Unpatentability
Ground 1: Obviousness over Onitsuka, Shunji, and Solder Ball Bumper - Claims 1-4 and 14-17 are obvious over Onitsuka, Shunji, and Solder Ball Bumper.
- Prior Art Relied Upon: Onitsuka (Patent 5,839,645), Shunji (WO 98/49121), and Solder Ball Bumper (a 1998 IEEE/CPMT Symposium publication).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Onitsuka disclosed a flip chip bonding tool used for thermal pressing of electronic components, and Solder Ball Bumper disclosed a solder ball capillary system for flip chip assembly. Together, these references taught the structural and functional aspects of the bonding tool and capillary system of the independent claims. Shunji was argued to teach a "destaticizing member" for use in bonding tools, made of a semiconductor material with a specific resistivity (e.g., 10^5 to 10^9 ohms cm) expressly for preventing ESD damage. Petitioner contended this directly taught the claimed "dissipative material" with a resistance "low enough" to prevent discharge but "high enough" to stop damaging current flow.
- Motivation to Combine: A POSITA would combine these references to solve the well-known and pervasive problem of ESD damage during semiconductor bonding. It would have been obvious to apply the known ESD solution from Shunji (using a dissipative material) to the known bonding tools and capillary systems disclosed in Onitsuka and Solder Ball Bumper.
- Expectation of Success: A POSITA would have a high expectation of success, as the combination involved applying a known solution to a known problem using conventional components, leading to the predictable result of reduced ESD damage.
Ground 2: Obviousness over Yamamoto, Shunji, and Solder Ball Bumper - Claims 1-4 and 14-17 are obvious over Yamamoto, Shunji, and Solder Ball Bumper.
- Prior Art Relied Upon: Yamamoto (WO 97/45867), Shunji (WO 98/49121), and Solder Ball Bumper (1998 IEEE/CPMT Symposium publication).
- Core Argument for this Ground:
- Prior Art Mapping: This ground presented an alternative to Onitsuka. Petitioner argued that Yamamoto disclosed a thermal bonding tool tip that used selective doping to achieve a moderately low resistivity to prevent sparking. This provided another basis for the bonding tool element. The teachings of Shunji (dissipative material for ESD prevention) and Solder Ball Bumper (capillary system) were mapped in the same manner as in Ground 1 to meet the remaining claim limitations.
- Motivation to Combine: The motivation remained the same as in Ground 1: solving the recognized problem of ESD in the field of microelectronic assembly. Both Yamamoto and Shunji explicitly addressed managing electrical properties of bonding tools to prevent unwanted electrical discharge.
- Expectation of Success: Success would be predictable, as Yamamoto and Shunji both provided known methods for controlling the electrical characteristics of bonding tools to prevent damage, which could be readily applied to the capillary system of Solder Ball Bumper.
Ground 4: Obviousness over Onitsuka, Shunji, and Azdasht - Claims 1-4 and 14-17 are obvious over Onitsuka, Shunji, and Azdasht.
Prior Art Relied Upon: Onitsuka (Patent 5,839,645), Shunji (WO 98/49121), and Azdasht (WO 1995/000279A1).
Core Argument for this Ground:
- Prior Art Mapping: This ground was similar to Ground 1 but substituted Azdasht for Solder Ball Bumper. Petitioner argued Azdasht disclosed a solder ball capillary system for making metal contacts in flip chip production that was functionally identical to the system in the ’927 patent. Petitioner emphasized that Azdasht, published years earlier, included diagrams nearly identical to the "new matter" Figure 3 added during the prosecution of the ’927 patent. Onitsuka provided the broader flip chip bonding tool context, and Shunji again provided the crucial teachings on using dissipative materials for ESD prevention.
- Motivation to Combine: The motivation was again to solve the known ESD problem by applying Shunji's dissipative material solution to the known bonding apparatus of Onitsuka, which incorporated the specific capillary system taught by Azdasht.
- Expectation of Success: A POSITA would have reasonably expected success in achieving a bonding tool with improved ESD protection by combining these known elements.
Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations based on Yamamoto and Solder Ball Bumper (Ground 3) and Yamamoto, Shunji, and Azdasht (Ground 5), which relied on similar arguments for combining known bonding tools with known ESD-prevention materials.
4. Key Claim Construction Positions
- "dissipative material": Petitioner argued this term should be construed simply as a material that conducts electricity and allows current flow.
- "resistance low enough to prevent discharge of a charge" / "high enough to stop all current flow": Petitioner proposed these functional limitations should be interpreted broadly based on their purpose, rather than being tied to a specific numeric range not recited in the claim. This construction supports finding the limitations met by prior art like Shunji, which discloses materials with a range of resistivities (e.g., 10^5 to 10^9 ohms cm) designed to achieve this exact functional balance.
5. Key Technical Contentions (Beyond Claim Construction)
- Petitioner's central technical contention was that the laser beam capillary tip shown in Figure 3 of the ’927 patent, which was added as "new matter" during prosecution in 2005, was not novel. Petitioner argued this exact technology and nearly identical diagrams were disclosed 8-12 years earlier in prior art references like Azdasht and the Solder Ball Bumper publication. This argument was intended to undermine the patentability of the claimed invention by showing the inventor did not invent key aspects of the disclosed technology.
6. Relief Requested
- Petitioner requested the institution of an inter partes review and the cancellation of claims 1-4 and 14-17 of the ’927 patent as unpatentable under 35 U.S.C. §103.
Analysis metadata