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Enthone v. Moses Lake Industries

Enthone v. Moses Lake Industries

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01054-TJM-RFT: Enthone Inc. v. Moses Lake Industries, Inc. Filed in U.S. District Court for the Northern District of New York, the Hon. Thomas J. McAvoy presiding. See http://news.priorsmart.com/-l8ZW for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01054-TJM-RFT: Enthone Inc. v. Moses Lake Industries, Inc. Filed in U.S. District Court for the Northern District of New York, the Hon. Thomas J. McAvoy presiding. See http://news.priorsmart.com/-l8ZW for more info.

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Published by: PriorSmart on Aug 28, 2013
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09/18/2013

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1IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ENTHONE INC.,Plaintiff,v.MOSES LAKE INDUSTRIES, INC.,Defendant.Case No.
JURY TRIAL DEMANDEDCOMPLAINT
Plaintiff Enthone Inc. (“Enthone”), for its Complaint against Defendant Moses LakeIndustries, Inc. (“MLI”)alleges as follows:
Parties
1.Enthone is a corporation organized under the laws of the State of Delaware and maintains a principal place of business at 350 Frontage Road, West Haven, Connecticut 06516.2.Upon information and belief, MLIis a Washington corporation with a principal place of business located in Moses Lake, Washington.
Jurisdiction and Venue
3.This is an action for patent infringement under 35 U.S.C. § 271. The Court hassubject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a).4.The Court has personal jurisdiction over Defendant MLIin that it has transacted  business, contracted to supply goods or services,and/or committed tortious acts within the Stateof New York out of which this action arises. N.Y. C.P.L.R. § 302.
1:13-CV-1054 [TJM/RFT]
 
25.Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b) and (c)and §1400(b), in that a substantial part of the events giving rise to the claim occurred here, and DefendantMLIissubject to personal jurisdiction here.
Patent-In-Suit
6.On December 4,2007, the United States Patent and Trademark Office duly anlegally issued U.S. Patent No. 7,303,992(“the ‘992patent”), entitled “Copper Electrodepositionin Microelectronics.” A copy of the ‘992patent is attached as Exhibit A.7.Enthoneowns the ‘992patent and holds all rights to sue for past, present, anfuture infringement of the ‘992patent.8.On October 19, 2010, the United States Patent and Trademark Office duly and legally issued U.S. Patent No. 7,815,786 (“the ‘786 patent”), entitled “Copper Electrodepositionin Microelectronics.” A copy of the ‘786patent is attached as Exhibit B.9.Enthone owns the ‘786 patent and holds all rights to sue for past, present, and future infringement of the ‘786 patent.
Facts
10.Among other products, Enthonemanufacturesand sellschemicalsused in theelectrolytic platingofcopper onto semiconductor substrates in the field of microelectronicsmanufacturing.11.One conventional semiconductor manufacturing process is the copper damascene process.Specifically, this processbegins by etching a combination of trenches and vias (knownas interconnect features)into the substrate’s dielectric material. Next, a barrier layer is laid over the dielectric to prevent diffusion of the subsequently applied copper layer into the substrate’s junctions, followed by deposition of a copper layer to provide electrical conductivity for a
 
3sequential electrochemical process. After the copper layer has been deposited, excess copper isremoved from the facial plane of the dielectric by chemical-mechanical polishing, leaving copper in only the etched interconnect features of the dielectric.12.Copper can be deposited by electrolytic platingto fill the interconnect featuresonsubstrates.13.Some electrolytic copper platingsystems rely on “superfilling” or “bottom-upgrowth” to deposit copperintothe interconnect features.14.Superfilling involves filling a feature from the bottom up, rather than at an equalrate on allofits surfaces, to avoid seams and pinchingoff that can result in voiding.15.As electronics have decreased in size, the smaller device sizesand increased circuit density require decreasing the dimensions of interconnect features.16.Inventors at Enthone discovered thatcertainsuppressor agents comprising polyether groupsbonded to a nitrogen-containing speciesachieve superior fill speedsand  polarization.17.The discoveriesof Enthone’s inventors, includingelectrolytic copper platingcompositionswithsuppressoragents havingpolyether groupsbonded to a nitrogen-containingspeciesandrelated electroplating methods,are disclosed and claimed in the ‘992 and ‘786 patents.18.MLI is a competitor of Enthone. MLIsellsspecialty chemicalsand solutions tomicroelectronics manufacturers for use inthe electrolytic plating of copper onto semiconductor substrates.19.On information and belief, MLI has made, used, sold, oroffered for salecompositionsfor electrolytic copper plating solutions, which—when prepared according to

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