PTAB

IPR2019-00042

Avant Technology, Inc. v. Anza Technology, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Dissipative Ceramic Bonding Tip
  • Brief Description: The ’479 patent describes bonding tips for microelectronics assembly, specifically wire bonding tips made from a dissipative ceramic material. The invention aims to prevent damage to sensitive electronic components from electrostatic discharge (ESD) by providing a tip with a controlled electrical resistance that safely dissipates static charge.

3. Grounds for Unpatentability

Ground 1: Anticipation by 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 teaches every element of the challenged claims. Shunji discloses a bonding tool for semiconductor fabrication that includes a "destaticizing member" made of a semiconductive zirconia sinter. This material is described as having a surface resistivity of 10⁶ to 10⁹ Ω·cm, which falls within the broader range of 10⁵ to 10¹² ohms claimed in the ’479 patent. Petitioner contended that this disclosure of a dissipative bonding tool for connecting leads on integrated circuits meets all limitations of the independent claims.

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.

  • Prior Art Relied Upon: Shunji (WO 98/49121) and Applicant Admitted Prior Art (AAPA) Bonding Tips (figures from the ’479 patent itself, which the patentee admitted were prior art).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the AAPA discloses the conventional structure of wire bonding tips made from alumina (Al₂O₃), which the patent itself admits were "typical" prior art. Shunji taught the benefit of using a dissipative material (doped zirconium oxide) for bonding tools to solve the known problem of ESD. Petitioner argued that all claim limitations are met by applying Shunji's teaching of a dissipative material to the conventional alumina bonding tips shown in the AAPA.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Shunji with the AAPA to solve the well-known and persistent problem of ESD damage during wire bonding. The motivation was to improve the performance of a conventional base material (AAPA alumina tips) with a known addition (Shunji’s dissipative material) to achieve a known goal (ESD protection). The combination was presented as a predictable application of a known technology to a known device.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success. The combination involved applying a known solution (a dissipative material) to a known problem (ESD on bonding tips). Petitioner argued this was a simple substitution of one known material for another to gain a predictable benefit, yielding nothing more than a predictable result.

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 Applicant Admitted Prior Art.

  • Prior Art Relied Upon: Popp (DE 3743630) and AAPA Bonding Tips.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Popp discloses tools for manipulating electrostatically sensitive components made from a static dissipative material. Popp specifically teaches using wear-resistant ceramics, such as aluminum oxide doped with zirconium oxide, to achieve a surface resistivity between 10⁵ and 10¹² ohms—the exact range claimed in the ’479 patent. This teaching, when applied to the conventional bonding tip structure of the AAPA, allegedly renders the claims obvious.
    • Motivation to Combine: The motivation was to solve the recognized ESD problem by applying the specific dissipative material compositions taught by Popp to the known bonding tip structures of the AAPA. Petitioner asserted that Popp and the AAPA are analogous art from the same technological field (handling sensitive electronic components), and a POSITA would look to references like Popp for solutions to ESD issues encountered with tools like the AAPA tips.
    • Expectation of Success: A POSITA would have reasonably expected success because Popp explicitly teaches using doped alumina to create a dissipative surface for handling sensitive components. Applying this known material to a different but analogous handling tool (a bonding tip) would be a predictable path to solving the ESD problem, especially since Popp’s disclosed resistivity range directly matches the claimed range.
    • Key Aspects: Petitioner framed this combination as an "obvious to try" scenario, arguing there was a recognized problem (ESD), a finite number of predictable solutions (using conductive, insulative, or dissipative materials), and Popp provided a clear path to the successful use of a dissipative material.

4. Key Claim Construction Positions

  • "dissipative material" / "electrically dissipative": Petitioner proposed construing these terms as a material that conducts electricity to allow current flow, having a resistance within the specified range of 10⁵ to 10¹² ohms. This construction was central to arguing that prior art materials met the claim limitations.
  • "a device": Petitioner argued that in claim 46, the term "a device" is used indefinitely to refer to two different subjects: first to the bonding tip itself and second to the semiconductor chip being bonded. Petitioner proposed constructions to resolve this ambiguity, interpreting the first instance as the bonding tip and the second as the chip, to enable a proper invalidity analysis.

5. Key Technical Contentions (Beyond Claim Construction)

  • Alumina as an Inherent Dissipative Material: A central contention was that the patent owner’s own admissions and technical literature (e.g., the CRC Handbook) demonstrate that standard prior art alumina (Al₂O₃) is itself "electrically dissipative" under certain conditions, with a resistivity that falls within the claimed range (e.g., 2x10⁶ to 10x10¹⁴ ohms). Petitioner argued that because the admitted prior art tips were made of alumina, the claimed invention was not novel or, at a minimum, was obvious, as it merely recited an inherent property of a known prior art material.

6. 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 Patent 6,354,479 as unpatentable.