Case IPR2013-00362
`Patent Owner’s Motion to Exclude Evidence
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`DOCKET NO: 418599US
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________
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`CARL ZEISS SMT GMBH
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`Petitioner
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`v.
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`NIKON CORPORATION
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`Patent Owner
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`__________
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`Case IPR2013-00362
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`Patent 7,348,575
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`__________
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`PATENT OWNER’S CONDITIONAL MOTION TO EXCLUDE
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`EVIDENCE
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`PURSUANT TO 37 C.F.R. § 42.64(C)
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`i
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`Patent Owner’s Motion to Exclude Evidence
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`DOCKET NO: 418599US
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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________
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`CARL ZEISS SMT GMBH
`
`Petitioner
`
`v.
`
`NIKON CORPORATION
`
`Patent Owner
`
`__________
`
`Case IPR2013-00362
`
`Patent 7,348,575
`
`__________
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`PATENT OWNER’S CONDITIONAL MOTION TO EXCLUDE
`
`EVIDENCE
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`PURSUANT TO 37 C.F.R. § 42.64(C)
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`i
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`Case IPR2013-00362
`Patent Owner’s Motion to Exclude Evidence
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`TABLE OF CONTENTS
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`I.
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`II.
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` Page
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`Statement of the Precise Relief Requested .................................................. 1
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`Statement of Material Facts .......................................................................... 1
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`III. Relevant Law .................................................................................................. 2
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`IV. Statement of the Reasons for Relief Requested .......................................... 3
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`A. Exhibit 1036 (“Supplemental Declaration of Richard Juergens”) Is
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`Irrelevant ...................................................................................................... 3
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`B. Exhibits 1038-1049, Each Described as a “Code V Sequence” in ZEISS
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`1036, Are Irrelevant .................................................................................... 8
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`ii
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`Case IPR2013-00362
`Patent Owner’s Motion to Exclude Evidence
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`TABLE OF AUTHORITIES
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`Cases
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`Page
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`Abbott Labs. v. Alra Labs., Inc.,
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`1997 U.S. Dist. LEXIS 16611 (N.D. Ill. Oct. 20, 1997) ....................... 4, 8
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`Ariad Pharms., Inc. v. Eli Lilly & Co.,
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`
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`598 F.3d 1336 (Fed. Cir. 2010) ................................................................. 4
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`Genentech, Inc. v. Trs. of the Univ. of Pa.,
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`
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`871 F. Supp. 2d 963 (N.D. Cal. 2010) ................................................... 4, 8
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`Lorraine v. Markel Am. Ins. Co.,
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`241 F.R.D. 534 (D. Md. 2007) .................................................................. 6
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`Rules
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`37 C.F.R. § 42.62 ................................................................................................. 2
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`37 C.F.R. § 42.64(c) ............................................................................................. 1
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`Federal Rule of Evidence 104 .............................................................................. 3
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`Federal Rule of Evidence 401 ...................................................................... 3, 6, 9
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`Federal Rule of Evidence 402 ...................................................................... 3, 6, 9
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`Federal Rule of Evidence 403 ...................................................................... 3, 6, 9
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`iii
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`I.
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`Statement of the Precise Relief Requested
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`Pursuant to 37 C.F.R. § 42.64(c), Patent Owner Nikon conditionally moves
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`to exclude Exhibits 1036 and 1038-1049, including a supplemental declaration and
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`accompanying computer-assisted lens designs, submitted in support of Petitioner’s
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`Reply (Doc. No. 22). If Patent Owner’s Exhibits 2036-2039 remain in the
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`evidentiary record for consideration of the merits of this trial, then Patent Owner
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`will withdraw this motion because Exhibits 2036-2039 demonstrate that Exhibits
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`1036 and 1038-1049 support Patent Owner’s contention that the prior art does not
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`enable or render obvious the claimed invention.1 If Patent Owner’s Exhibits 2036-
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`2039 are excluded or otherwise do not remain part of the evidentiary record, then
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`Patent Owner submits this conditional motion to exclude Petitioner’s Exhibits
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`1036 and 1038-1049.
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`II.
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`Statement of Material Facts
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`On May 28, 2014, Petitioner Zeiss filed its Reply to Patent Owner’s
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`Response (Doc. No. 22) along with several corresponding exhibits, including
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`Exhibits 1036 and 1038-1049 that purportedly show how one of ordinary skill in
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`the art could utilize the latest version of CODE V computer software to modify a
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`prior art lens system to arrive at the claimed invention. Patent Owner timely
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`1 Patent Owner anticipates that Petitioner will file a motion to exclude Exhibits
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`2036-2039, based on a prior telephone conference with the panel. (Ex. 2042.)
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`1
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`served objections to evidence on June 4, 2014. (Ex. 2041.) Subsequently, Patent
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`Owner cross-examined Petitioner’s expert, Mr. Juergens. (Ex. 2040.) The cross-
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`examination shows that the computer-assisted lens designs described in Exhibits
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`1036 and 1038-1049 are inoperable, specifically because those lens designs fail to
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`properly form an image that is focused. (Ex. 2040, 110:12 – 111:21, 115:2 –
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`117:14, 123:22 – 125:19 ). Additionally, some of the lens designs are inoperable
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`because they suffer from beam separation problems.2 (Ex. 2040, 117:15 – 120:1).
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`Accordingly, Exhibits 1036 and 1038-1049 are irrelevant to Petitioner’s
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`positions on obviousness and enablement, but are nonetheless conditionally
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`relevant to Patent Owner’s position that the challenged claims are not obvious and
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`that the prior art is not enabling, in view of Mr. Juergens’ cross-examination
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`testimony and related Exhibits 2036-2039.
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`III. Relevant Law
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`The Federal Rules of Evidence (“FRE”) apply to the current proceedings.
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`37 C.F.R. § 42.62.
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`2 Patent Owner has submitted observations on Mr. Juergens’ deposition testimony
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`that reveal in further detail the severity of the problems with his computer-assisted
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`lens designs.
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`2
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`FRE 104(b) addresses conditional relevance, i.e., relevance that depends
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`upon a fact: “When the relevance of evidence depends on whether a fact exists,
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`proof must be introduced sufficient to support a finding that the fact does exist.”
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`FRE 401 defines relevant evidence as evidence that “has any tendency to
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`make a fact more or less probable than it would be without the evidence” and “the
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`fact is of consequence in determining the action.” Under FRE 402, irrelevant
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`evidence is inadmissible. FRE 403 states that even relevant evidence may be
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`excluded where its probative value is substantially outweighed by a danger of
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`unfair prejudice, confusing the issues, wasting time, or needlessly presenting
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`cumulative evidence.
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`IV. Statement of the Reasons for Relief Requested
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`A. Exhibit 1036 (“Supplemental Declaration of Richard Juergens”)
`Is Irrelevant
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`Mr. Juergens’ supplemental declaration (Ex. 1036) describes his attempt to
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`recreate steps that a person of ordinary skill in the art would have undertaken to
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`modify the Terasawa reference with the assistance of the optimization function in
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`Synopsys Inc.’s CODE V software. (See, e.g., Ex. 1036 ¶¶5, 14). Mr. Juergens
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`relies on the “design experiments” described in his supplemental declaration to
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`support the opinions expressed in his original declaration (Exhibit 1016).
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`However, as admitted by Mr. Juergens, his design experiments were not performed
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`using the version of CODE V available to one of ordinary skill in the art in 2003,
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`rather they were performed using the current version, version 10.6, released in
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`2013. (See Ex. 1036 ¶17; Ex. 2035).
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`Evidence of what a person of ordinary skill in the art knew must arise at the
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`time of the filing date. Genentech, Inc. v. Trs. of the Univ. of Pa., 871 F. Supp. 2d
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`963, 981 (N.D. Cal. 2010) (citing Ariad Pharms., Inc. v. Eli Lilly & Co., 598 F.3d
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`1336, 1355 (Fed. Cir. 2010)). Mr. Juergens’ use of the current 2013 version of
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`software to show what optimization software was available nearly ten years prior,
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`is inappropriate. Petitioner should not be allowed to conveniently assert arguments
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`as to what would have been known at the time of the invention in 2003 by relying
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`on 2013 software and technology. See, e.g., Abbott Labs. v. Alra Labs., Inc., 1997
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`U.S. Dist. LEXIS 16611, at *16 (N.D. Ill. Oct. 20, 1997) (finding that a party could
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`not avoid an adverse ruling “by relying on tests not known to the art at the time of
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`application for the patent or that were not generally used at the time.”).
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`In an attempt to compensate for using the current software version, Mr.
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`Juergens asserts that he “was careful to use only those functions and features of the
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`program that were available in the 2003 version,” which Mr. Juergens admits is no
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`longer available. (Ex. 1036 ¶ 17.) But, neither Petitioner, nor Mr. Juergens
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`provide any independent evidence showing this to be true or the methods by which
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`it was accomplished, nor do they provide any evidence as to how Mr. Juergens can
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`be sure which functionalities and features were available at the time without
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`reference to the 2003 version of the software.
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`Regardless, even if Mr. Juergens were to successfully disable all relevant
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`functionalities of the 2013 version of the software not available in 2003, neither
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`Mr. Juergens, nor Petitioner provide any evidence (nor could they) that the 2013
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`software’s program source code for optimizing a lens design did not change over
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`the last ten years. In fact, in advertisements for Synopsys’ CODE V, versions 9.8,
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`10.1, 10.2, 10.3, 10.4, 10.5, and 10.6, describe the addition of numerous new,
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`enhanced, and/or improved optimization features and capabilities, design tools,
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`mathematical formulations, charting capabilities, macro functions, methods of
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`calculation, algorithms, tolerancing features, and analysis functions. (See Exs.
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`2029-2035, describing changes in various CODE V versions between 2007 and
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`2013.) Undoubtedly CODE V has been updated many times through new version
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`releases, online updates, etc. in the ten years since the immersion techniques
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`described in the 575 Patent. Undoubtedly, Mr. Juergens cannot be sure that the
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`addition of these (and potentially many other) features between 2003 and 2013 did
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`not impact his results. As such, neither Mr. Juergens nor Petitioner has or can
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`demonstrate that the results of Mr. Juergens’ “design experiments” (described in
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`his Exhibit 1036, paragraphs 14-48) are results that one of ordinary skill could
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`have obtained prior to the May 6, 2003 priority date of the 575 patent.
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`5
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`Mr. Juergens has not reliably shown how one of skill in the art could have
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`used the 2003 version of CODE V. The software function and features of his
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`computer program are those of 2013, not 2003. Without any evidence explaining
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`the lens design optimization routines used by the 2003 version, or the
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`improvements made to subsequent versions (see, e.g., Exs. 2029-2035), the
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`underlying information regarding the code is unreliable. Moreover, improvements
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`to computer hardware capabilities may have also led an unreliable simulation of
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`the 2003 functionality, to the execution of processor instructions not available in
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`2003, and to enhanced performance and output – even assuming that Mr. Juergens
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`made a perfect assessment of which functions were available/unavailable. In this
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`situation, district courts have declined to admit such “evidence.” See Lorraine v.
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`Markel Am. Ins. Co., 241 F.R.D. 534 at 560-562.
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`At most Mr. Juergens has provided us with the software output one might
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`obtain presently using the latest version of CODE V, replete with numerous new,
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`enhanced, and/or improved features – evidence that is entirely irrelevant to the
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`question of what would have been known and accessible to one of ordinary skill in
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`the art prior to May 6, 2003. (See Fed. R. Evid. 401-402).
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`Even if the Board were to determine that this evidence is somehow relevant
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`in the slightest, which it is not, its probative value is substantially outweighed by
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`the danger of prejudice and confusion in relying upon it. (See Fed. R. Evid. 403).
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`6
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`This is highlighted by the recent deposition of Mr. Juergens (Ex. 2040). There,
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`Mr. Juergens was presented with the plots in Patent Owner’s Exhibits 2036-2039,
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`showing how his computer-assisted lens designs affects light originating from all
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`of the field points in the field width, as opposed to only the two field points that
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`Mr. Juergens had selected. From his testimony, it is clear that Mr. Juergens
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`understood the plots to show the RMS wavefront error performance and distortion
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`versus field position corresponding to the respective exhibits. (Ex. 2040, 74:12 -
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`75:13, 108:14 - 109:12, 113:21 – 115:1, 123:1-16). Mr. Juergens’ own plots only
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`show that his computer-assisted lens designs are able to focus two field points of
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`light without interference, while completely ignoring all other field points within
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`the field width. Because Mr. Juergens plotted only two field points of light
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`favorable to Petitioner’s position, his results do not represent the effect of the lens
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`designs on the entire field width. The effect of the lens design on the entire field
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`width contradicts Petitioner’s characterizations of the two points that Mr. Juergens
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`plotted, and demonstrates that the prior art did not enable the claimed invention.
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`Thus, even if Exhibit 1036 had any probative value, such value is far outweighed
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`by the prejudicial and confusing effect of Exhibit 1036, unless Patent Owner’s
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`Exhibits 2036-2039 are also permitted into the record.
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`Accordingly, Exhibit 1036 has no probative value and no relevance to any
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`issues raised by the parties, unless Nikon’s Exhibits 2036 – 2039 are also included
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`in the record.
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`B.
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`Exhibits 1038-1049, Each Described as a “Code V Sequence” in
`ZEISS 1036, Are Irrelevant
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`Each of Exhibits 1038-1049 purport to contain programming input/output,
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`what Mr. Juergens refers to as “the Code V Sequence” for his experiments using
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`the latest 2013 Version 10.6. (See Ex. 1036 ¶¶15-17, 22, 24, 26, 30, 32, 34, 36, 38,
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`40, 44, 46). Again, without the 2003 version of CODE V, and without evidence of
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`the programming changes made to CODE V over the last ten years, such
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`documents are not relevant to the knowledge of one of ordinary skill in 2003. See
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`Genentech, 871 F. Supp. 2d at 981; Abbott Labs., 1997 U.S. Dist. LEXIS 16611, at
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`*16. Rather, like the declaration that references them, these documents are
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`irrelevant and prejudicial unless viewed in the context of Nikon Exhibits 2036-
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`2039, which plot the results for the entire beam field, not just the two points that
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`Mr. Juergens plotted.
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`Thus, for the same reasons outlined with respect to Exhibit 1036 in Section
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`A above, such Exhibits 1038-1049 do not represent computer-assisted results that
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`one of ordinary skill in the art would have had access to at the time of the
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`invention. Neither Mr. Juergens nor Petitioner has or can show that the code
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`sequences in Exhibits 1038-1049 are sequences that one of skill in the art would
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`8
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`have used/obtained prior to May 6, 2003 or as a reliable simulation of such. (See
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`Lorraine, 241 F.R.D. at 560). Thus, the evidence presented in these exhibits is
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`entirely irrelevant to the question of what would have been known and accessible
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`to one of ordinary skill in the art prior to May 6, 2003. (See Fed. R. Evid. 401-
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`402). Further, even if the Board were to determine that this evidence is somehow
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`relevant, which it is not, its probative value would certainly be substantially
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`outweighed by a danger of unfair prejudice, confusing the issues, and wasting time,
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`unless viewed in the context of Nikon’s Exhibits 2036-2039. (See Fed. R. Evid.
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`403).
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`Accordingly, Exhibits 1038-1049 have no probative value and no relevance
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`to any issues raised by the parties, unless Nikon’s Exhibits 2036 – 2039 are also
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`included in the record.
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`V. Conclusion
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`For the foregoing reasons, Patent Owner’s Conditional Motion to Exclude
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`Evidence should be granted unless Patent Owner’s Exhibits 2036-2039 remain in
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`the record and are considered on the merits.
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`Dated: July 11, 2014
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`Respectfully submitted,
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`/John S. Kern/
`John S. Kern (Reg. No. 42,719)
`Attorney for Patent Owner
` Nikon Corporation
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`Case IPR2013-00362
`Patent Owner’s Motion to Exclude Evidence
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`Exhibit
`2001
`2002
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`2003
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`2004
`2005
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`2006
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`2007
`2008
`2009
`2010
`2011
`2012
`2013
`2014
`2015
`2016
`2017
`2018
`2019
`2020
`2021
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`2022
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`2023
`2024
`2025
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`EXHIBIT APPENDIX
`
`
`Description
`Equation from the 2/12/14 Juergens Deposition
`Moore, “Cramming More Components onto Integrated Circuits,”
`PROCEEDINGS OF THE IEEE, VOL. 86, NO. 1, JANUARY 1998
`(reprinted from Gordon E. Moore, “Cramming More Components
`onto Integrated Circuits,” Electronics, pp. 114–117, April 19, 1965)
`International Technology Roadmap for Semiconductors, 2003 Edition,
`Lithography
`U.S. Patent No. 5,488,229
`Feldmann et al., “Catadioptric Projection Lenses for Immersion
`Lithography,” Proc. Of SPIE Vol. 5962, 59620Y, 2005.
`Ohmura et al., “Catadioptric lens development for DUV and VUV
`projection optics,” Optical Microlithography XVI, Anthony Yen,
`editor, Proceedings of SPIE Vol. 5040, June 25, 2003.
`U.S. Patent No. 4,812,028
`U.S. Patent No. 4,747,678
`U.S. Patent No. 5,668,673
`U.S. Patent No. 5,808,805
`U.S. Patent No. 5,691,802
`U.S. Patent No. 5,861,997
`U.S. Patent No. 5,815,310
`U.S. Patent No. 7,079,314
`U.S. Patent No. 6,636,350
`WO2001/59502
`U.S. Patent No. 7,301,605
`U.S. Patent No. 7,030,965
`U.S. Patent Publication No. US2003/197922A
`U.S. Patent No. 7,385,756
`Deposition Transcript of Richard C. Juergens dated February 12, 2014
`for IPR2013-00362
`Deposition Transcript of Richard C. Juergens dated February 13, 2014
`for IPR2013-00363
`U.S. Patent No. 5,788,229
`Expert Declaration of Dr. Jose M. Sasian
`Curriculum Vitae of Dr. Jose M. Sasian
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`Case IPR2013-00362
`Patent Owner’s Motion to Exclude Evidence
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`2026
`2027
`2028
`2029
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`2030
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`2031
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`2032
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`2033
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`2034
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`2035
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`2036
`2037
`2038
`2039
`2040
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`2041
`2042
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`Certified Translation of WO2001/59502 (Ex. 2016)
`U.S. Patent No. 4,293,186
`U.S. Patent No. 5,298,939
`Article entitled “CODE V 9.8 delivers improved optical system
`modeling and optimization,” obtained at
`http://www.ledsmagazine.com/ugc/2007/09/code-v-9-8-delivers-
`improved-... on June 20, 2014
`Article entitled “Code V 10.1. Optical Design Software – Synopsys,
`Inc., Optical Solutions Group,” obtained at
`http://www.photonics.com/Product.aspx?PRID=38981 on June 20,
`2014
`Article entitled “Optical Research Associates’ CODE V 10.2 Delivers
`– Designed to Enhance Ease of Use,” obtained at
`http://www.deskeng.com/de/optical-research-associates-code-v-10-2-
`deliver... on June 20, 2014
`Article entitled “Synopsys’ CODE V Enhances Aspheric Lens System
`Design,” obtained at
`http://in.reuters.com/article/2011/03/15/idUS149326+15-Mar-
`2011+PRN20... on June 20, 2014
`Article entitled “Synopsys CODE V Version 10.4 Optical Design and
`Analysis Software,” obtained at http://edablog.com/2011/09/29/ora/
`on June 20, 2014
`Article entitled “Synopsys Releases Version 10.5 of CODE V Optical
`Design Software,” obtained at
`http://edablog.com/tag/ora/?d96a349c52fc4f68eea46a47ccb3d360 on
`June 20, 2014
`Article entitled “Code V 10.6 – Synopsys Optical Solutions,” obtained
`at http://optics.synopsys.com/codev/codev-whatsnew.html on June 20,
`2014
`Plots of Terasawa Example 2 in Table 2, Fig. 5
`Plots of Lens Design in Exhibit 1042
`Plots of Lens Design in Exhibit 1047
`Plots of Lens Design in Exhibit 1049
` Deposition Transcript of Richard C. Juergens dated July 2, 2014
`for IPR2013-00362
`Patent Owner’s Objection to Evidence served June 4, 2014
`Transcript of Telephonic Conference Call with the Board
`conducted on July 7, 2014
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`Case IPR2013-00362
`Patent Owner’s Motion to Exclude Evidence
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing PATENT OWNER’S
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`CONDITIONAL MOTION TO EXCLUDE EVIDENCE was served via email
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`(IPR24984-0056IP1@fr.com) on July 11, 2014 in its entirety, to the following:
`
`Marc M. Wefers
`Chris C. Bowley
`Lawrence K. Kolodney
`Kurt L. Glitzenstein
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth St.
`Minneapolis, MN 55402
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`/John S. Kern/
`John S. Kern (Reg. No. 42,719)
`Attorney for Patent Owner
` Nikon Corporation
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`
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`Date: July 11, 2014
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