PTAB

IPR2019-00042

Avant Technology Inc v. Anza Technology Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dissipative Ceramic Bonding Tip
  • Brief Description: The ’479 patent describes bonding tool tips, used in microelectronics assembly, that are constructed from a dissipative ceramic material. This construction is intended to safely dissipate electrostatic discharge (ESD) to prevent damage to sensitive electronic components during the wire bonding process.

3. Grounds for Unpatentability

Ground 1: Anticipation over Shunji - Claims 1, 2, 19, 23, 37, 38, and 46-51 are anticipated under 35 U.S.C. §102 by Shunji.

  • Prior Art Relied Upon: Shunji (WO 98/49121).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shunji discloses every limitation of the challenged claims. Shunji teaches a “destaticizing member” for use in a bonding tool, made from a semiconductive zirconia sinter with a specified surface resistivity (e.g., 10⁶ to 10⁹ Ω·cm). Petitioner contended this material is a “dissipative material” and that its resistivity falls within the scope of the claimed resistance range (1x10⁵ to 1x10¹² ohms). The tool is described for use in electronics fabrication, meeting the limitation for connecting leads on integrated circuit bonding pads, and its properties are inherently suited to prevent damaging ESD while avoiding shorts.

Ground 2: Obviousness over Shunji and Admitted Prior Art - Claims 1, 2, 19, 23, 37, 38, and 46-51 are obvious over Shunji in view of Applicant Admitted Prior Art (AAPA).

  • Prior Art Relied Upon: Shunji (WO 98/49121) and AAPA Bonding Tips (figures from the ’479 patent designated as prior art during prosecution of a related patent).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that, at a minimum, it would have been obvious to combine Shunji’s teachings with the known bonding tip structures disclosed in the AAPA. The AAPA shows the conventional form of wire bonding tips made of alumina (Al₂O₃), which the patent owner admitted are “electrically dissipative.” Shunji teaches adding a “conductivity imparting agent” (e.g., doped zirconium oxide) to a ceramic to create a “destaticized” tool with a specific resistivity range to solve the known problem of ESD.
    • Motivation to Combine: Petitioner provided several rationales for why a person of ordinary skill in the art (POSITA) would combine the references. A POSITA would have been motivated to apply Shunji’s advanced dissipative material to the conventional AAPA tip structure to improve its performance and create a more reliable tool for preventing ESD damage, a well-known problem in the field. This combination represented the use of known elements (Shunji’s material, AAPA’s tip structure) for their known purposes, leading to a predictable result. The combination was also presented as an "obvious to try" solution, as dissipative materials were one of a finite number of predictable approaches to solving the ESD problem.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. Applying a material expressly designed for ESD protection (Shunji) to a standard tool used in ESD-sensitive applications (AAPA) would be expected to yield a bonding tip with the desired protective properties.

Ground 3: Obviousness over Popp and Admitted Prior Art - Claims 1, 2, 19, 23, 37, 38, and 46-51 are obvious over Popp in view of AAPA.

  • Prior Art Relied Upon: Popp (DE 3743630) and AAPA Bonding Tips.
  • Core Argument for this Ground:
    • Prior Art Mapping: Popp was presented as teaching tools for handling electrostatically sensitive components made from a static dissipative material having a surface resistivity between 10⁵ and 10¹² ohms—the exact range recited in several challenged claims. Popp further suggested that this material could be wear-resistant ceramic, such as aluminum oxide doped with zirconium oxide. Petitioner argued that a POSITA would have found it obvious to apply the specific dissipative material and resistivity range taught by Popp to the conventional bonding tip structures shown in the AAPA.
    • Motivation to Combine: The motivation was similar to that for the Shunji combination. A POSITA seeking to solve the known ESD problem in wire bonding would look to analogous arts, such as the general handling of sensitive components taught by Popp. Popp provided an explicit recipe and performance specification (the 10⁵ to 10¹² ohm range) for a dissipative tool. Applying this established solution to the specific application of a wire bonding tip (AAPA) was argued to be a simple and predictable design choice to improve the tool's safety and effectiveness.
    • Expectation of Success: A POSITA would have a high expectation of success, as Popp explicitly discloses how to create a dissipative ceramic tool with the precise resistivity range claimed in the ’479 patent for the exact purpose of preventing ESD damage to electronic components.

4. Key Claim Construction Positions

  • Petitioner argued for specific constructions to resolve alleged indefiniteness and provide context for its invalidity arguments.
  • "a device": For claim 46, which uses the term twice, Petitioner proposed a dual construction. The first instance of "a device" should be construed as "an electrically dissipative wire bonding tool tip," while the second instance should be construed as the "semiconductor integrated circuit chip" being bonded. This construction was deemed necessary to make sense of the claim, which otherwise appeared to refer to two different subjects with the same term.
  • "dissipative material": Proposed construction was a "material that conducts electricity and allows current flow," consistent with its function of preventing static charge build-up.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 19, 23, 37, 38, and 46-51 of the ’479 patent as unpatentable.