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)

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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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