PTAB

IPR2019-00045

Avant Technology Inc v. Anza Technology Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Dissipative Ceramic Bonding Tool
  • Brief Description: The ’864 patent relates to bonding tools, such as capillary tips used in microelectronics assembly, that are formed from a dissipative ceramic material. This material is designed to prevent damaging electrostatic discharge (ESD) to sensitive electronic components during the wire bonding process.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 1-2, 4, 7, and 28 are anticipated by Shunji under 35 U.S.C. §102.

  • Prior Art Relied Upon: Shunji (WO 98/49121).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shunji disclosed every element of the challenged claims. Shunji taught a bonding tool for producing electronic devices made from a "destaticizing" material, specifically a partially stabilized zirconia ceramic with conductivity-imparting agents. This material was disclosed as having a surface resistivity of 10^5 to 10^9 Ohm-cm, which fell within the range of 5x10^4 to 10^12 ohms required by the ’864 patent. Petitioner contended that Shunji explicitly taught that this material allows static electricity to be "released gradually," thereby meeting the limitations related to providing a smooth, non-damaging current flow.

Ground 2: Obviousness over Shunji and Admitted Prior Art - Claims 1-2, 4, 7, and 28 are obvious over Shunji in view of Applicant Admitted Prior Art (AAPA).

  • Prior Art Relied Upon: Shunji (WO 98/49121) and AAPA Bonding Tips (disclosed in Figs. 1-4, 5A-5B, and 6A-6B of the ’864 patent).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Shunji taught the use of a dissipative ceramic material (zirconia with conductive oxides) in a bonding tool to solve the known problem of ESD. The AAPA, taken from the ’864 patent itself, disclosed the conventional structure of wire bonding tips, which the patent owner admitted were typically made of alumina (Al2O3). The combination of Shunji’s dissipative material with the conventional tip structure of the AAPA allegedly rendered the claims obvious.
    • Motivation to Combine: Petitioner provided multiple motivations for a Person of Ordinary Skill in the Art (POSITA) to combine the references. A POSITA would combine the known dissipative material from Shunji with the known tool structure from the AAPA to solve the well-documented problem of ESD in semiconductor manufacturing. Key rationales included: (1) combining known elements that would perform as expected; (2) improving the performance of a base material (the AAPA alumina tip) with a known addition (Shunji's dissipative agents); and (3) it would have been "obvious to try" applying Shunji's finite, predictable solution to the known ESD problem associated with standard bonding tips.
    • Expectation of Success: A POSITA would have had a high expectation of success because applying a known material property (dissipation) to a standard mechanical structure to solve a known electrical problem was a predictable and straightforward design choice.

Ground 3: Obviousness over Popp and Admitted Prior Art - Claims 1-2, 4, 7, and 28 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: Petitioner argued that Popp taught the use of dissipative materials for tools and surfaces used to handle ESD-sensitive components. Popp explicitly disclosed a wear-resistant ceramic with a surface resistivity between 10^5 and 10^12 ohms—the exact range claimed in the ’864 patent. Popp further taught that this material, which could be doped aluminum oxide, prevents damaging current discharge. Combining Popp's teachings on dissipative handling tools with the specific bonding tip structures shown in the AAPA would result in the claimed invention.
    • Motivation to Combine: The motivation was again based on solving the known ESD problem. A POSITA, aware of the need to prevent ESD during wire bonding (the application of the AAPA tips), would have looked to analogous arts, such as tools for handling sensitive components described in Popp. Applying Popp's specific teachings on dissipative ceramic materials to the AAPA bonding tips was presented as a common-sense solution to improve the safety and reliability of the bonding process.
    • Expectation of Success: A POSITA would have reasonably expected that incorporating the dissipative ceramic taught by Popp into the structure of an AAPA bonding tip would predictably prevent ESD damage, as Popp demonstrated the material's effectiveness for that very purpose.

4. Key Claim Construction Positions

  • "smooth current" and "current high enough to avoid a build up of charge": Petitioner argued these terms were not adequately disclosed in the ’864 patent specification. To address this alleged indefiniteness for the purpose of the invalidity analysis, Petitioner proposed constructions based on the underlying technical goal. It defined "smooth current" as "current that flows at a constant rate" and "current high enough..." as "current of a sufficient magnitude to prevent static charge build up." These constructions were critical to mapping the prior art, which described gradual charge dissipation rather than using these exact phrases.
  • "dissipative material": Petitioner construed this term broadly as a "material that conducts electricity and allows current flow," consistent with its function described in the patent and the properties disclosed in the prior art references.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 4, 7, and 28 of Patent 6,651,864 as unpatentable.