Lam Research Corp v. Inpria Corp

1. Case Identification

• Case #: IPR2025-00309
• Patent #: 11,537,048
• Filed: December 13, 2024
• Petitioner(s): Lam Research Corp.
• Patent Owner(s): Inpria Corp.
• Challenged Claims: 1-20

2. Patent Overview

• Title: Vapor Deposition System for Organotin Compositions
• Brief Description: The ’048 patent discloses systems and methods for depositing organotin oxide hydroxide films used in high-resolution lithography. The technology is directed at forming low-dose photoresist patterns for applications such as extreme ultraviolet (EUV) lithography.

3. Grounds for Unpatentability

Ground 1: Obviousness over Dhas and Cardineau - Claims 1-6 and 8-20 are obvious over Dhas in view of Cardineau.

• Prior Art Relied Upon: Dhas (Patent 9,328,416) and Cardineau (a 2014 journal article titled "Photolithographic properties of tin-oxo clusters using extreme ultraviolet light").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued Dhas taught a vapor deposition apparatus with nearly all the structural elements of claim 1, including a deposition chamber isolated from the atmosphere, a substrate holder, inlets for reactants, and the use of inert carrier gases. Dhas also disclosed operating temperatures and pressures that overlap or are proximate to those claimed. However, Dhas did not explicitly teach the specific organotin composition (RSnX3) recited in the claims. Cardineau, a named inventor on the ’048 patent, remedied this deficiency by disclosing the use of organotin trichlorides (e.g., butyltin trichloride), which fall within the claimed formula, as superior photoresists for EUV lithography due to tin's high EUV absorbance.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Dhas's deposition system with Cardineau's chemistry to improve lithographic performance. As EUV lithography became more prominent, a POSA would seek to apply superior photoresist materials, like those in Cardineau, to known, reliable deposition systems, like the one in Dhas, to achieve the improved sensitivity and lower shot noise described by Cardineau. The references were considered analogous, as both related to forming photoresists.
  • Expectation of Success: A POSA would have a reasonable expectation of success. Dhas taught depositing organometallics using water as a co-reactant, and Cardineau taught that its organotin precursors react with components of water (via hydrolysis) to form the desired tin clusters. This compatibility would lead a POSA to expect that Cardineau’s precursors would successfully form a photoresist film in Dhas's apparatus.

Ground 2: Obviousness over Weidman and Cardineau - Claims 1-5 and 8-20 are obvious over Weidman in view of Cardineau.

• Prior Art Relied Upon: Weidman (Patent 8,536,068) and Cardineau (2014 journal article).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that Weidman disclosed an atomic layer deposition (ALD) apparatus for forming photoresist films that taught the key structural features of the challenged claims. This included a deposition chamber, precursor inlets, and the use of inert carrier gases like argon. Weidman taught using volatile metal-containing compounds, including tin precursors, and water as a co-reactant. Cardineau supplied the specific teaching of the claimed RSnX3 organotin compounds for high-performance EUV photoresists.
  • Motivation to Combine: A POSA would be motivated to use Cardineau's high-performance EUV precursors in Weidman's ALD apparatus to achieve a more reliable coating. Weidman explicitly taught that "dry" deposition techniques like ALD provide superior atomic layer control compared to spin-coating (the method disclosed in Cardineau). Therefore, a POSA would combine the references to gain the benefits of both: Cardineau's advanced resist chemistry and Weidman’s more precise and reliable deposition method.
  • Expectation of Success: A POSA would reasonably expect success because Weidman taught using water as a reactant, and Cardineau taught that its organotin precursors are hydrolysable to form tin clusters. This fundamental chemical compatibility indicated that Cardineau's precursors would function as intended within Weidman's ALD system to form the desired photoresist layer.

• Additional Grounds: Petitioner asserted additional obviousness challenges by adding Molloy (a 2008 journal article on tin oxide precursors) to the Dhas/Cardineau and Weidman/Cardineau combinations. Molloy was primarily used to teach that using a third precursor vapor comprising SnL4 (for claim 7) or other MLv compounds (for claim 6) was a known and obvious choice for chemical vapor deposition (CVD) processes.

4. Key Claim Construction Positions

• Petitioner argued that several "structure" and "configuration" terms in claims 1, 10, and 12 were means-plus-function (MPF) limitations under 35 U.S.C. §112(6) that lacked corresponding structural support in the original specification.
• For the IPR, Petitioner proposed constructions based on Patent Owner's positions in parallel district court litigation, which identified the corresponding structure in Figure 16 of the patent (e.g., construing "structure configured to deliver flow" as a "conduit").
• Alternatively, Petitioner argued that if Figure 16 constitutes new matter, the corresponding structure should be interpreted more broadly as a "class of structures" known to a POSA for performing the claimed function (e.g., a conduit and an interconnected vessel).

5. Key Technical Contentions (Beyond Claim Construction)

• A central contention was that Figure 16 and its accompanying description were improperly added during prosecution to overcome rejections. Petitioner asserted this addition constituted new matter in violation of 35 U.S.C. §132.
• This argument was foundational, as it impacted the patent's effective priority date and the structural basis for the MPF claim terms. Petitioner argued that without the allegedly new matter, the claims lacked adequate written description support.

6. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under §325(d), stating that the petition presented new prior art and arguments not previously considered by the USPTO during prosecution.
• Petitioner also contended that discretionary denial under Fintiv was inappropriate. It argued the factors favored institution because the parallel district court trial was scheduled more than a year away, claim construction had not yet occurred, and the invalidity case presented in the IPR was more extensive than the one in the district court.

7. Relief Requested

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