STC.UNM v. Intel Corporation
Filing
176
DECLARATION re 175 Response in Opposition to Motion,, of Brian L. Ferrall in Support of Intel's Opposition to STC's Motion to Strike and Dismiss Intel's Invalidity Affirmative Defense and Counterclaim by Intel Corporation (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K - part 1, # 12 Exhibit K - part 2, # 13 Exhibit L)(Atkinson, Clifford)
Exhibit 6
STC.UNM v. Intel
Invalidity Claim Chart Comparing '998 Patent to AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
The following asserted claims of STC.UNM’s U.S. Pat. No. 6,042,998 (“'998 patent”) are invalidated pursuant to 35 U.S.C. § 102 and/or § 103, alone or in combination
with other references, by any of Applicant Admitted Prior Art (AAPA), U.S. Patent No. 5,415,835 to Brueck et al. (“Brueck '835”), U.S. Patent No. 4,891,094 to Waldo
III (“Waldo '094”), David H. Ziger, et al., Generalized Approach Toward Modeling Resist Performance, ALCHE JOURNAL, Vol. 37, No. 12, Dec. 1991, at 1863-74
(“Ziger”), Peter S. Gwozdz, Positive Versus Negative: A Photoresist Analysis, SEMICONDUCTOR LITHOGRAPHY VI, SPIE Vol. 275, 1981 (“Gwozdz”), and/or David J.
Elliott, INTEGRATED CIRCUIT FABRICATION TECHNOLOGY, 2d ed., 1989, at 85-106 and 326 (“Elliott”). These preliminary invalidity contentions are based on
information currently known to Intel, and, as a result, apply interpretations apparently or potentially adopted by STC.UNM. Intel reserves the right to amend its
preliminary invalidity contentions in light of developments in the case such as production of discovery, identification of additional prior art, and issuance of an order
following any Claim Construction Hearing, as stated in the Scheduling Order (Dkt. 47, dated March 2, 2011).
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
6. A method for obtaining a pattern wherein the Fourier
transform of said pattern contains high spatial frequencies
by combining nonlinear functions of intensity of at least
two exposures combined with at least one nonlinear
processing step intermediate between the two exposures to
form three dimensional patterns comprising the steps of:
The phrase “the Fourier transform of said pattern contains high spatial frequencies” is an inherent
result of the nonlinear processing step.
coating a substrate with a first mask material and a first
photoresist layer;
See, e.g., AAPA in the '998 patent, C7:41 to C8:3:
exposing said first photoresist layer with a first exposure
developing said photoresist to form a first pattern in said
first photoresist layer, said first pattern containing spatial
frequencies greater than those in a two dimensional optical
intensity image imposed onto said photoresist layer in said
first exposure as a result of a nonlinear response of said
first photoresist layer; transferring said first pattern into
said first mask material, said first mask material
comprising at least one of SiO.sub.2, Si.sub.3 N.sub.4, a
metal, a polysilicon and a polymer;
In addition, AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott each discloses a nonlinear
processing step as explained below.
“The use of the nonlinear response of photoresist to substantially sharpen developed photoresist
patterns in the z-direction, through the thickness of the resist, has long been understood [see, for
example, Introduction to Microlithography, Second Edition, L. F. Thompson, C. G. Willson and M.
J. Bowden, eds. (Amer. Chem. Soc. Washington D.C., 1994, pp. 174-180)]. To aid in
understanding this process, many approaches exist for modeling the photoresist response. Industrystandard modeling codes, such as PROLITH™ and SAMPLE, typically take into account the many
subtle effects that are often necessary to accurately model the lithography process. However, for
the present purposes, a simpler model, first presented by R. Ziger and C. A. Mack [Generalized
Approach toward Modeling Resist Performance, AIChE Jour. 37, 1863-1874 (1991)], typically
provides a good approximation. This model describes the photoresist thickness, t(E), after the
photoresist develop step substantially resulting from a given optical exposure fluence (typically
normalized to a clearing fluence) E by the relationship: ##EQU1## where n is a parameter that
characterizes the contrast of the resist. For typical novolac-based photoresist commonly used for I-
Ex. 6: Page 1
EXHIBIT F
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
line wavelengths, n.about.5-10. FIG. 4 shows a plot of t(E) vs. E showing the strong nonlinearity
often associated with the photoresist process.”
See, e.g., AAPA in the '998 patent, fig.4:
See, e.g., Brueck '835, C5:62-65:
“Nonlinearities in the exposure, develop and etch processes result in a higher-order terms in a
Fourier series expansion at the same period and phase as the original image.”
Ex. 6: Page 2
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Waldo '094, fig.1:
See, e.g., Waldo '094, C2:47-C3:4:
“Both the contrast and sensitivity of photoresist can be measured in a well known manner by
exposing a given thickness of a photoresist layer to varying doses of radiation and then measuring
the thickness of photoresist remaining for each radiation dose after development. This information
is plotted to obtain a photoresist characteristic curve. Such a characteristic curve 11 is shown in
FIG. 1 wherein each point 10 thereon corresponds to a given radiation dose and the thickness of
photoresist remaining after development. The intercept of the curve 11 with the X axis gives the
minimum radiation dose needed to completely clear the given thickness of photoresist after the
development step. By repeating this process for the same photoresist and radiation source but using
different thickness layers of photoresist, the sensitivity and contrast characteristics of the particular
photoresist can be determined.
In accordance with the present invention, the slope of the invention of the curve 11 as it intercepts
the X or radiation dose axis is determined to find the contrast of the given layer thickness of
photoresist and is plotted against the photoresist thickness that is cleared by the intercept radiation
dose after development. Each point 12 of the curve 14 in FIG. 1 therefore corresponds to the slope
Ex. 6: Page 3
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
of the intercept of curve 11 of FIG. 1 with the X axis for different thickness layers of photoresist.”
See, e.g., Ziger, at 1868, fig.2:
See, e.g., Ziger, at 1868: “Figures 2a-2c shows PROLITH/2 simulations of a positive nonabsorbing
photoresist with varying surface inhibition effects.”
See, e.g., Gwozdz, at 157, figs.1 & 2:
Ex. 6: Page 4
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Gwozdz, at 158, fig.4:
Ex. 6: Page 5
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Elliott, at 87:
“[Resist contrast] is a measure of the resist response to an aerial image that has an intensity gradient
defined by the optical modulation transfer function of the optical imaging system.”
See, e.g., Elliott, at 87, fig.3.2:
Ex. 6: Page 6
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Elliott, at 327, fig.9.20:
Ex. 6: Page 7
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
coating said substrate with a second photoresist;
See, e.g., AAPA in the '998 patent, C7:41 to C8:3:
exposing said second photoresist with a second exposure
“The use of the nonlinear response of photoresist to substantially sharpen developed photoresist
patterns in the z-direction, through the thickness of the resist, has long been understood [see, for
Ex. 6: Page 8
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
developing said second photoresist layer to form a second
pattern in said second photoresist layer, said second pattern
containing spatial frequencies greater than those in a two
dimensional optical intensity image imposed onto said
photoresist layer in said second exposure as a result of a
nonlinear response of said second photoresist layer;
transferring said first pattern and said second pattern into
said substrate using a combined mask including parts of
said first mask layer and said second photoresist; removing
said first mask material and said second photoresist.
example, Introduction to Microlithography, Second Edition, L. F. Thompson, C. G. Willson and M.
J. Bowden, eds. (Amer. Chem. Soc. Washington D.C., 1994, pp. 174-180)]. To aid in
understanding this process, many approaches exist for modeling the photoresist response. Industrystandard modeling codes, such as PROLITH™ and SAMPLE, typically take into account the many
subtle effects that are often necessary to accurately model the lithography process. However, for
the present purposes, a simpler model, first presented by R. Ziger and C. A. Mack [Generalized
Approach toward Modeling Resist Performance, AIChE Jour. 37, 1863-1874 (1991)], typically
provides a good approximation. This model describes the photoresist thickness, t(E), after the
photoresist develop step substantially resulting from a given optical exposure fluence (typically
normalized to a clearing fluence) E by the relationship: ##EQU1## where n is a parameter that
characterizes the contrast of the resist. For typical novolac-based photoresist commonly used for Iline wavelengths, n.about.5-10. FIG. 4 shows a plot of t(E) vs. E showing the strong nonlinearity
often associated with the photoresist process.”
See, e.g., AAPA in the '998 patent, fig.4:
Ex. 6: Page 9
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Brueck '835, C5:62-65:
“Nonlinearities in the exposure, develop and etch processes result in a higher-order terms in a
Fourier series expansion at the same period and phase as the original image.”
See, e.g., Waldo '094, fig.1:
Ex. 6: Page 10
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Waldo '094, C2:47-C3:4:
“Both the contrast and sensitivity of photoresist can be measured in a well known manner by
exposing a given thickness of a photoresist layer to varying doses of radiation and then measuring
the thickness of photoresist remaining for each radiation dose after development. This information
is plotted to obtain a photoresist characteristic curve. Such a characteristic curve 11 is shown in
FIG. 1 wherein each point 10 thereon corresponds to a given radiation dose and the thickness of
photoresist remaining after development. The intercept of the curve 11 with the X axis gives the
minimum radiation dose needed to completely clear the given thickness of photoresist after the
development step. By repeating this process for the same photoresist and radiation source but using
different thickness layers of photoresist, the sensitivity and contrast characteristics of the particular
photoresist can be determined.
In accordance with the present invention, the slope of the invention of the curve 11 as it intercepts
the X or radiation dose axis is determined to find the contrast of the given layer thickness of
photoresist and is plotted against the photoresist thickness that is cleared by the intercept radiation
dose after development. Each point 12 of the curve 14 in FIG. 1 therefore corresponds to the slope
of the intercept of curve 11 of FIG. 1 with the X axis for different thickness layers of photoresist.”
See, e.g., Ziger, at 1868, fig.2:
Ex. 6: Page 11
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Ziger, at 1868: “Figures 2a-2c shows PROLITH/2 simulations of a positive nonabsorbing
photoresist with varying surface inhibition effects.”
See, e.g., Gwozdz, figs.1 & 2:
Ex. 6: Page 12
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Gwozdz, at 158; fig.4:
Ex. 6: Page 13
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Elliott, at 87:
“[Resist contrast] is a measure of the resist response to an aerial image that has an intensity gradient
defined by the optical modulation transfer function of the optical imaging system.”
See, e.g., Elliott, at 87, fig.3.2:
Ex. 6: Page 14
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
See, e.g., Elliott, at 327, fig.9.20:
Ex. 6: Page 15
Asserted Claims of '998 Patent
AAPA, Brueck '835, Waldo '094, Ziger, Gwozdz, and Elliott
20336-1313/LEGAL20531271.1
Ex. 6: Page 16
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