Applied Materials Inc v. Ocean Semiconductor LLC

1. Case Identification

• Case #: IPR2021-01348
• Patent #: Patent 6,836,691
• Filed: August 3, 2021
• Petitioner(s): Applied Materials, Inc.
• Patent Owner(s): Ocean Semiconductor LLC
• Challenged Claims: 1-19

2. Patent Overview

• Title: System for Collecting and Filtering Metrology Data in Manufacturing
• Brief Description: The ’691 patent discloses methods and systems for improving semiconductor manufacturing processes by using metrology data more effectively. The invention involves collecting metrology data, generating associated context data which includes a "collection purpose," filtering the metrology data based on this purpose, and then conducting a process control activity using the filtered data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Funk and Stoddard - Claims 1-19 are obvious over Funk in view of Stoddard and the background knowledge of a POSA.

• Prior Art Relied Upon: Funk (Patent 7,123,980) and Stoddard (Patent 6,587,744).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of Funk and Stoddard disclosed every limitation of the challenged claims. Funk taught a modular and flexible Advanced Process Control (APC) system for monitoring and controlling semiconductor manufacturing. This system utilized context-specific "plans"—such as data collection, judgment, and intervention plans—that were executed based on the current process context (e.g., tool ID, wafer ID, recipe step). Stoddard taught a run-to-run controller that specifically used metrology data from workpieces to adjust process parameters and recipes.
  • Petitioner contended that the key limitation—filtering metrology data based on "collection purpose data"—was rendered obvious by this combination. In Funk's modular system, each plan has an inherent purpose and is associated with an ID. A POSITA would have understood that a "data collection plan" for establishing a "'good tool state' baseline" serves the purpose of "process control sampling," while a "judgment/intervention plan" for responding to alarms serves the purpose of "fault detection." Petitioner argued these plan IDs and their inherent purposes constitute the claimed "collection purpose data." Filtering data using these plan IDs to isolate data for a specific task—like process control or fault analysis—would have been an obvious implementation.
  • For dependent claims, Petitioner asserted that the combined system would inherently perform the recited functions. For example, identifying a fault condition (claims 4, 13) would be achieved by using Stoddard’s metrology data to detect out-of-limit values within Funk’s existing fault-handling framework. Similarly, updating a control model (claims 6, 15) was disclosed by Funk’s method of comparing subsequent data against a baseline of "good tool state" data, which itself constitutes a control model.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine these references to achieve the well-known goal of improving yield and cost-effectiveness in semiconductor manufacturing. Funk provided a ready-made, modular APC framework that was particularly suited for integrating the known metrology-based process control techniques taught by Stoddard. The combination represented a predictable use of prior art elements according to their established functions to achieve a more robust process control system.
  • Expectation of Success: Petitioner asserted a high expectation of success. Funk’s APC system already included a relational database and a modular framework for analyzing data. Integrating Stoddard's established metrology data analysis techniques was a straightforward modification, especially since APC systems using metrology data from engineering databases were common at the time. The modularity of Funk's "plan" system was designed for such additions, ensuring predictable results.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under either 35 U.S.C. §325(d) or 35 U.S.C. §314(a) (pursuant to the Fintiv factors) would be inappropriate.
• §325(d) Arguments: Petitioner contended that this ground was not the "same or substantially the same" as arguments previously presented to the USPTO. The primary references, Funk and Stoddard, were not before the Examiner during the original prosecution. The Examiner's allowance of the claims over a different reference (Barna) was based on the Applicant's argument that Barna did not teach filtering based on collection purpose. Petitioner asserted that its proposed combination directly addresses and renders obvious this specific limitation, highlighting a material difference from the prosecution record.
• §314(a) (Fintiv) Arguments: Petitioner argued that the Fintiv factors strongly favored institution. As a non-party to any parallel district court litigations involving the ’691 patent, the IPR proceeding represented Petitioner's only available forum to challenge the patent's validity. Petitioner asserted that Factors 3 (minimal investment in the early-stage litigations), 4 (no overlap, as invalidity contentions had not yet been served), 5 (Petitioner not a party to any parallel case), and 6 (strong merits of the petition) all weighed in favor of institution. Factors 1 and 2 (motions to stay and trial date proximity) were argued to be neutral due to the lack of any stay motions and the inherent uncertainty of trial schedules in the various parallel cases.

5. Relief Requested

• Petitioner requests the institution of an inter partes review and the cancellation of claims 1-19 of Patent 6,836,691 as unpatentable.