PTAB

IPR2025-00256

Lam Research Corp v. Inpria Corp

Key Events

Petition

petition

Title: System for Forming Organotin Oxide Hydroxide Layer
Brief Description: The ’048 patent describes a system for forming an organotin oxide hydroxide layer on a substrate via vapor deposition. These layers are intended for use as radiation-sensitive materials (photoresists) for high-resolution lithography, particularly with extreme ultraviolet (EUV) exposure.

Prior Art Relied Upon: Meyers (Application # 2017/0102612) and Weidman (Patent 8,536,068).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Meyers, which is from the same patent family as the ’048 patent, discloses the chemical methods and compositions for forming the organotin photoresist layers but lacks specific structural details for the required deposition apparatus. Weidman allegedly supplies these missing details by disclosing a conventional chemical vapor deposition (CVD) apparatus suitable for depositing metal-based photoresist layers. Petitioner contended that Weidman’s apparatus discloses the claimed deposition chamber, substrate holder, and various inlets and conduits (gas channels, outlets, flow controllers) that correspond to the "structure" limitations of claim 1.
- Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA), seeking to implement the method disclosed in Meyers, would combine its teachings with a known, commercially relevant apparatus for vapor deposition like that described in Weidman.
- Expectation of Success: A POSITA would have a reasonable expectation of success because Weidman describes a versatile apparatus for depositing metal-based films, including those from tin precursors, making it a suitable choice for performing the specific methods taught by Meyers.

Prior Art Relied Upon: Berney (WO 2020263750).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Berney, a reference that is only available as prior art if the ’048 patent is not entitled to its earliest priority date, discloses every element of the challenged claims. Berney allegedly teaches a dry deposition apparatus for generating EUV-sensitive photoresist layers, including a processing chamber isolated from the atmosphere, a substrate support, and a showerhead with multiple inlets. Petitioner argued Berney’s disclosure of using organometallic precursors (including tin compounds with alkyl groups and dialkylamino/alkoxy ligands) and counter-reactants (like water) meets the chemical composition limitations of claim 1. Berney’s system of valves, manifolds, and vaporizers allegedly provides the claimed "structures" for delivering precursor vapors.
- Key Aspects: This ground’s viability hinges on Petitioner’s argument that the ’048 patent’s effective filing date is January 20, 2021, due to the alleged addition of new matter during prosecution, which would make the December 30, 2020 publication of Berney valid prior art under 35 U.S.C. §102(a)(2).

Prior Art Relied Upon: Berney (WO 2020263750) and Molloy (a 2008 journal article titled "Precursors for the formation of tin(IV) oxide and related materials").
Core Argument for this Ground:
- Prior Art Mapping: This ground builds upon the disclosures of Berney as argued in Ground 2. Claims 6 and 7 add limitations requiring a third precursor vapor comprising a composition of formula MLv (claim 6) and specifically SnL4 (claim 7). Petitioner argued that while Berney teaches using multiple organometallic precursors, Molloy provides specific teachings of inorganic tin compounds, such as SnMe4, as a "precursor of choice" for CVD processes.
- Motivation to Combine: A POSITA would combine Molloy's teachings with Berney’s system because Berney suggests benefits from using multiple precursors, and Molloy teaches specific tin compounds known to produce films with desirable properties (e.g., high deposition rates, good resistivity).
- Expectation of Success: A POSITA would expect success in using Molloy's precursors in Berney's apparatus because both relate to analogous vapor deposition of tin-based films, and Molloy confirms that SnMe4 is a suitable precursor for such methods.

Petitioner argued that several terms in the independent claims are means-plus-function (MPF) terms under 35 U.S.C. §112(6) because they use the generic term "structure" or "configuration" without reciting sufficiently definite structure for performing the claimed function.
Key terms identified as MPF include "structure configured to deliver flow," "configuration providing for selection of the pressure and/or the temperature," and "one or more vapor inputting structures."
The proposed corresponding structure depends on whether Figure 16 of the ’048 patent is considered. Petitioner contended that if Figure 16 is improper new matter, the specification only supports a generic "conduit" or a "class of structures for delivering flow."

Petitioner’s central technical contention was that the ’048 patent is not entitled to its claimed priority date. It was argued that during prosecution, the Patent Owner improperly added new matter—specifically, a new Figure 16 and related text—to the specification to provide structural support for the MPF limitations that the Examiner had found lacking.
Because this alleged new matter was first introduced on January 20, 2021, Petitioner contended this is the earliest effective filing date for the challenged claims. This date is critical as it renders the Berney reference, published on December 30, 2020, prior art to the ’048 patent.

Petitioner argued against discretionary denial under 35 U.S.C. §325(d), stating that the petition presents new prior art (Berney, Weidman, Molloy) and arguments that were not before the Examiner during prosecution.
Petitioner also argued against discretionary denial under Fintiv, asserting that the parallel district court litigation is in its early stages, with fact discovery not closing until February 2025 and a trial date more than a year away. Petitioner further noted that the IPR is more comprehensive than the district court invalidity contentions.

Petitioner requested institution of an inter partes review and cancellation of claims 1-20 of the ’048 patent as unpatentable.