PTAB
IPR2019-00783
Samsung Electronics Co Ltd v. ProMOS Technologies Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2019-00783
- Patent #: 6,099,386
- Filed: March 5, 2019
- Petitioner(s): Samsung Electronics Co., Ltd.
- Patent Owner(s): ProMOS Technologies, Inc.
- Challenged Claims: 1-3, 5
2. Patent Overview
- Title: Control Device for Maintaining a CMP Machine in a Wet Mode
- Brief Description: The ’386 patent discloses a control device for a chemical mechanical polishing (CMP) machine designed to prevent process degradation from dried residual liquid. The system uses a sensor to detect the opening and closing of a slurry sprinkler and a control unit to measure the duration the sprinkler is closed, automatically sprinkling liquid onto the polishing pad if a predetermined time is exceeded to maintain a wet mode.
3. Grounds for Unpatentability
Ground 1: Claims 1 and 5 are obvious over Miyaji in view of Shimomura
- Prior Art Relied Upon: Miyaji (Japanese Patent Publication JP H10-235550) and Shimomura (Japanese Patent Publication JP H10-141403).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Miyaji disclosed a CMP apparatus that addresses the problem of polishing pads drying out when the machine is idle. Miyaji's system includes a control unit that measures the time since polishing stopped (by sensing the cessation of platen rotation) and, after a predetermined interval, discharges water onto the pad to keep it wet. While Miyaji taught the core system, it did not disclose a dedicated sensor for directly monitoring the slurry sprinkler’s valve. Petitioner asserted that Shimomura remedied this deficiency by teaching a substrate processing device with sensors that directly detect the open/closed state of a fluid supply valve. The signals from Shimomura’s sensors are sent to a control unit to precisely manage fluid supply. Petitioner contended that combining Shimomura’s direct valve sensor with Miyaji’s CMP control system would render all limitations of independent claim 1 obvious. For dependent claim 5, which specifies the sprinkled liquid is slurry, Petitioner argued Miyaji met this by disclosing the use of a "polishing agent."
- Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Shimomura's sensor with Miyaji’s system to improve its accuracy and reliability. Miyaji’s method of inferring sprinkler downtime from platen rotation is indirect and cannot detect a valve malfunction while the platen is rotating. A POSITA would recognize the benefit of incorporating Shimomura's dedicated valve sensor to more accurately measure the period of inactivity, thereby better achieving Miyaji’s stated goal of preventing pad drying. This combination would also provide the additional advantages taught by Shimomura, such as lower cost compared to flowrate sensors and more precise control over the chemical supply.
- Expectation of Success: Petitioner contended a POSITA would have had a high expectation of success. The combination involved applying a known sensor technique from Shimomura to a similar fluid control problem in Miyaji's CMP system to achieve the predictable benefits of improved accuracy and direct monitoring.
Ground 2: Claims 2 and 3 are obvious over Miyaji, Shimomura, and Perlov
- Prior Art Relied Upon: Miyaji, Shimomura, and Perlov (EP0774323A2).
- Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the combination of Miyaji and Shimomura from Ground 1 and added Perlov to address the limitations of claims 2 and 3. Claim 2 requires the liquid sprinkled from the sprinkler to be "deionized water for rinsing the polishing pad and the carrier head." The base combination (Miyaji) taught using "water" to rinse the polishing pad. Petitioner argued that Perlov taught the remaining elements, as it explicitly disclosed rinsing a carrier head with deionized water in a CMP apparatus to remove debris and reduce contamination. Claim 3, which depends on claim 2, recites that the control unit sprinkles the deionized water, a function Petitioner asserted was inherent in the combined teachings.
- Motivation to Combine: Petitioner asserted a POSITA would be motivated to incorporate Perlov’s teachings into the Miyaji/Shimomura apparatus to provide a more comprehensive cleaning solution. Both Miyaji and Perlov recognized the adverse effects of dried slurry on CMP components. Since Perlov taught the benefit of rinsing the carrier head to reduce contamination, a POSITA would find it obvious to modify Miyaji’s system to rinse both the pad and the carrier head. Furthermore, Petitioner argued that using deionized water for cleaning was a well-known and preferred industry practice for CMP processes, making its substitution for regular water a simple and obvious design choice to improve cleaning efficacy.
- Expectation of Success: Petitioner argued the proposed modification was a predictable solution. Extending Miyaji's rinsing function to the carrier head and using deionized water as taught by Perlov were straightforward adaptations within the common knowledge and skill of a POSITA to improve overall machine cleanliness and performance.
4. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-3 and 5 of the ’386 patent as unpatentable.
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