Mattson Technology, Inc. v. Applied Materials, Inc.

I. BACKGROUND

1 The following discussion of background facts is based on the allegations contained in the 2 first amended complaint (the “FAC” at Dkt. 45), the truth of which the Court accepts for purposes 3 of resolving the Motions. See Boquist v. Courtney, 32 F.4th 764, 772 (9th Cir. 2022). “Mattson 4 designs, manufactures[ and] markets” technology in the semiconductor industry. See FAC ¶ 10. 5 Between 2011 and 2012, it developed two “proprietary approaches” to the development of 6 “plasma processing equipment,” known as the “Green Path” and “Grey Path.” See id. ¶ 17. The 7 Green Path involves “the use of magnetic field concentrators in conjunction with a remote plasma 8 source” in connection with “increas[ing the] efficiency of plasma generation at the bottom of the 9 source and significantly increas[ing] the radial control near the substrate.” See id. ¶ 20. The Grey 10 Path, in turn, involves “adjust[ing] the position of [a] gas insert relative to [an] induction coil in [a] 11 plasma source . . . to provide control of the source efficiency for a plasma process.” See id. ¶ 21. 12 Mattson never disclosed these approaches in patent filings. See id. ¶¶ 25-30. It also…