Applied Materials Inc v. Demaray LLC

1. Case Identification

• Patent #: 7,544,276
• Filed: October 23, 2020
• Petitioner(s): Applied Materials, Inc.
• Patent Owner(s): Demaray LLC
• Challenged Claims: 1-13

2. Patent Overview

• Title: Sputtering Reactor Apparatus for Depositing Oxide and Oxynitride Films
• Brief Description: The ’276 patent discloses a sputtering reactor apparatus for depositing films, such as oxide and oxynitride, on a substrate. The system utilizes a pulsed DC power supply coupled to a sputtering target, an RF bias power supply coupled to the substrate, and a narrow band rejection filter to prevent RF interference from affecting the pulsed DC power supply.

3. Grounds for Unpatentability

Ground I: Claims 1-3 and 6-8 are obvious over Licata in view of Kelly and Collins.

• Prior Art Relied Upon: Licata (Patent 6,132,564), Kelly (a 2000 article on reactive pulsed magnetron sputtering), and Collins (Patent 6,077,384).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Licata taught the foundational elements of a sputtering reactor, including a chamber, a target powered by a pulsed DC supply, a substrate holder powered by an RF bias supply, and an "RF filter" between the DC supply and the target. However, Licata did not explicitly disclose a bipolar pulsed DC supply or a narrow band rejection filter. Petitioner asserted that Kelly taught using a bipolar pulsed DC supply that provides alternating negative and positive voltages to a target. This technique was used to deposit dielectric films (e.g., alumina) by effectively discharging "poisoned" regions on the target, reducing arcing and stabilizing the process. Petitioner further asserted that Collins taught the use of isolation filters, specifically including band-rejection filters, in plasma systems with multiple RF power sources. Collins' filter was designed to prevent RF energy from a substrate bias supply from interfering with the primary RF power supply, thereby protecting the power supply and preserving its waveform.
  • Motivation to Combine: A POSITA would combine Kelly’s bipolar pulsing technique with Licata's reactor to improve the deposition of insulating films—a capability disclosed by Licata—by mitigating the known problem of target poisoning and arcing. The combination would be a predictable application of a known solution to a known problem. A POSITA would then replace Licata’s generic "RF filter" with the narrow band-rejection filter from Collins. This would be an obvious design choice to protect the sensitive waveform of the pulsed DC power supply from interference from the RF substrate bias, a known issue in dual-frequency plasma systems. This modification would ensure deposition quality while preventing damage to the power supply.
  • Expectation of Success: A POSITA would have a reasonable expectation of success, as the combination involved applying known solutions (bipolar pulsing, band-rejection filters) to a conventional sputtering reactor to achieve the predictable results of improved film quality, reduced arcing, and effective power supply isolation.

Ground II: Claims 4 and 5 are obvious over Licata in view of Kelly, Collins, and Aokura.

• Prior Art Relied Upon: Licata (Patent 6,132,564), Kelly (a 2000 article), Collins (Patent 6,077,384), and Aokura (Japanese Patent Publication No. JPH10102247A).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon Ground I to address dependent claims 4 and 5, which required a magnet that scans across the target and extends beyond it. Petitioner argued Aokura taught a magnetron sputtering apparatus with a magnet designed to scan across a rectangular target. Aokura’s magnet explicitly extended beyond the target’s edges to ensure the entire target volume was eroded uniformly.
  • Motivation to Combine: A POSITA would be motivated to incorporate the magnet scanning technique from Aokura into the Licata-Kelly-Collins system. This modification would predictably improve the uniformity of target erosion and maximize the target's usable life, which are well-understood goals in the field of sputtering.

Ground III: Claims 9 and 10 are obvious over Licata in view of Kelly, Collins, and Dogheche.

• Prior Art Relied Upon: Licata (Patent 6,132,564), Kelly (a 2000 article), Collins (Patent 6,077,384), and Dogheche (a 1999 article on aluminum nitride films).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added Dogheche to the primary combination to address claim 9 (using a ceramic target) and claim 10 (using a temperature controller for the substrate). Petitioner asserted that Dogheche taught reactive sputtering using a ceramic (AlN) target. Dogheche also taught that maintaining the substrate at a constant, optimal temperature (e.g., 400 °C) was important for depositing high-quality films.
  • Motivation to Combine: A POSITA would be motivated to use a ceramic target as taught by Dogheche to expand the capabilities of the combined system, allowing it to deposit a wider variety of useful films. Furthermore, a POSITA would incorporate Dogheche’s teaching of substrate temperature control as a known method to improve the quality and consistency of the deposited films, a standard practice in semiconductor manufacturing.

Ground IV: Claims 11-13 are obvious over Licata in view of Kelly, Collins, and Doessel.

• Prior Art Relied Upon: Licata (Patent 6,132,564), Kelly (a 2000 article), Collins (Patent 6,077,384), and Doessel (Patent 5,527,605).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground introduced Doessel to address claims 11-13, which required an alloyed target containing specific elements. Petitioner argued that Doessel taught sputtering from an alloyed target, including alloys containing rare-earth metals (terbium, dysprosium) and other elements like silicon and aluminum.
  • Motivation to Combine: A POSITA would be motivated to use an alloyed target as taught by Doessel to further enhance the versatility of the Licata-Kelly-Collins system. This would allow the deposition of films with different properties, such as the magnetooptic layers with high corrosion resistance described in Doessel, which was a known application for alloyed targets.

4. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §325(d), contending the petition raised new arguments not considered during prosecution. The primary references Licata and Collins were never before the Examiner, and while Kelly was cited in an Information Disclosure Statement (IDS), it was never substantively applied against the claims or discussed by the Examiner.
• Petitioner also argued against discretionary denial under Fintiv, asserting that the parallel district court litigations were in their infancy with no firm trial dates set. Petitioner contended that there was minimal investment by the parties and the court, that a stay pending IPR was likely, and that the invalidity grounds presented in the petition were not the same as those in the litigation.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-13 of the ’276 patent as unpatentable under 35 U.S.C. §103.