Appeal No. 2006-1360
Application No. 09/427,675
At the bottom of page 8 of the brief, appellants also argue that Jacquinot is directed to a
method of chemical mechanical polishing using an acid aqueous suspension of colloidal silica
containing individualized colloidal silica particles not linked together by siloxane bonds, and
water as the suspension medium. Appellants also argue that Jacquinot is directed to the chemical
mechanical polishing specifically of silicon dioxide layers, and makes no mention of polishing
silicon nitride. Brief, page 9.
At the top of page 10 of the brief, appellants then argue that Grover teaches a chemical
mechanical polishing having a unique chemistry that is especially suitable for chemical
mechanical planarization where a high silicon dioxide removal rate and a low silicon nitride
removal rate are required on the same substrate. Appellants argue that it is the unique chemistry
of Grover that achieves the objective of Grover of a greater than five to one oxide to nitride
selectivity. Brief, page 10. Appellants argue that to accomplish the objectives of Grover, Grover
teaches a method for using a chemical mechanical polishing composition comprising carboxylic
acid, a salt, and a soluble cerium silicon compound in an aqueous solution having a pH above 3.
Brief, page 10. On page 11 of the Brief, appellants state that in Grover, the unique chemistry
clearly is the composition of carboxylic acid and a soluble silicon compound that provide the
selective polishing capability.
Appellants acknowledge that Grover teaches the use of surfactants at column 6, lines 37
through 64, from among a variety of optional additives. Appellants state that Grover teaches that
the function of the optional surfactant is (1) improve stability of the polishing slurry, i.e.,
against settling, flocculation and decomposition of the oxidizing agent, and refers to column 6,
lines 37 through 39 of Grover, or (2) improve stabilization of the slurry, and refers to column 6,
lines 49 through 54 of Grover, or (2) improve the within-wafer-nonuniformity (WIMNU) of the
wafers. Brief, pages 11-12. Appellants argue that not one of the 34 specific examples of Grover
shows the use of a surfactant in the slurry.
On page 2 of the reply brief, appellants emphasize that Grover teaches that it is the
unique chemistry which provides improved selectivity in Grover. Appellants argue that contrary
to the examiner’s argument in the middle paragraph on page 3 of the examiner’s answer, Grover
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