UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________
`
`CARL ZEISS SMT GMBH
`Petitioner
`
`v.
`
`NIKON CORPORATION
`Patent Owner
`
`__________
`
`Case IPR2013-00362
`
`Patent 7,348,575
`
`__________
`
`SECOND DECLARATION OF DR. JOSE SASIAN
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`1
`
`ZEISS 1054
`Ziess v. Nikon
`IPR2013-00362
`
`
`
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________
`
`CARL ZEISS SMT GMBH
`Petitioner
`
`v.
`
`NIKON CORPORATION
`Patent Owner
`
`__________
`
`Case IPR2013-00362
`
`Patent 7,348,575
`
`__________
`
`SECOND DECLARATION OF DR. JOSE SASIAN
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`1
`
`ZEISS 1054
`Ziess v. Nikon
`IPR2013-00362
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`
`
`1. My name is Jose Sasian. I have been retained by counsel for patent
`
`owner, Nikon Corporation (“Nikon”), in the above captioned matter.
`
`2.
`
`In my previous declaration dated March 6, 2014 (Ex. 2024), I
`
`provided my opinion as to the validity of U.S. Patent No. 7,348,575 (Ex. 1001).
`
`My background and qualifications are set forth in Section II of my March 6, 2014
`
`declaration which is incorporated herein by reference.
`
`3.
`
`I have personal knowledge of the facts set forth below. All statements
`
`made herein are, to the best of my knowledge, true.
`
`4.
`
`In preparing each of the exhibits described below, I used the
`
`professional lens design software Zemax 13 Release 2 SP1 Professional from
`
`Radiant–Zemax. I prepared the plots in Tucson, Arizona and in Kohala, Hawaii.
`
`I.
`
`Exhibit 2036 - “RMS Wavefront Error (157 nm waves)
`for Example 2 (Table 2, Fig. 5) in Terasawa”_________
`
`5.
`
`On May 31, 2014 and June 22, 2014, I plotted the RMS wavefront
`
`error and distortion for the projection optical system labeled as Example 2 and
`
`shown in Figure 5 of Terasawa (Ex. 1008). To prepare the plots, I used the lens
`
`specification data corresponding to Example 2 that is provided in Table 2 of
`
`Terasawa.
`
`
`
`2
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`Exhibit 2036 demonstrates plots of RMS performance versus field
`
`6.
`
`position (Ex. 2036 1)1 and distortion (Ex. 2036 2) based on the data in Table 2 of
`
`Terasawa. The exhibit also includes the lens prescription data corresponding to
`
`Table 2 that was used by the Zemax software.
`
`7.
`
`To prepare the plots, I replicated the data provided in Table 2 of
`
`Terasawa into a Zemax lens file. I then inputted the field of view and object
`
`numerical aperture as taught by Terasawa. Next, I produced the plots shown in
`
`Exhibit 2036 using standard plotting commands in Zemax.
`
`8.
`
`A true and accurate copy of the results of my analysis is shown in
`
`Nikon’s Exhibit 2036 (submitted herewith as Attachment A) entitled “RMS
`
`Wavefront Error (157 nm waves) for Example 2 (Table 2, Fig. 5) in Terasawa.”
`
`Because I am the author/creator of Exhibit 2036, I am familiar with the facts
`
`shown therein.
`
`II. Exhibit 2037 - “RMS Wavefront Error
`(157 nm waves) for Exhibit 1042”_____
`
`9.
`
`On May 31, 2014 and on June 22, 2014, I plotted the RMS wavefront
`
`error and distortion corresponding to Experiment II as described in Zeiss Exhibit
`
`1042.
`
`
`1 Unless indicated otherwise, citations are to original page or column number.
`
`
`
`3
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`10. Exhibit 2037 shows plots RMS wavefront error versus field position
`
`(Ex. 2037 1) and distortion (Ex. 2037 2) based on the CODE V lens layout from
`
`Exhibit 1042 corresponding to Experiment II of Mr. Juergens’ supplemental
`
`declaration. The exhibit also includes the lens prescription data corresponding to
`
`Exhibit 1042 that was input into the Zemax software.
`
`11. To prepare the plots, I replicated the lens data from Exhibit 1042 into
`
`a Zemax lens file. I then produced the plots shown in Exhibit 2037 using standard
`
`plotting commands in Zemax.
`
`12. From the RMS wavefront error plot, I immediately recognized that –
`
`for the two field points at 40 mm and 65 mm which were used by Mr. Juergens –
`
`the RMS wavefront error was the same as the results reported in the supplemental
`
`declaration of Mr. Richard Juergens (Ex. 1036). This served as a check that the
`
`data input was correct, otherwise I would not expect to obtain agreement for those
`
`two field points.
`
`13. A true and accurate copy of the results of my plots are shown in
`
`Nikon’s Exhibit 2037 (submitted herewith as Attachment B) entitled “RMS
`
`Wavefront Error (157 nm waves) for Exhibit 1042.” Because I am the
`
`author/creator of Exhibit 2037, I am familiar with the facts shown therein.
`
`
`
`4
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`III. Exhibit 2038 - “RMS Wavefront Error
`(157 nm waves) for Exhibit 1047”_____
`
`14. On May 31, 2014 and on June 22, 2014, I plotted the RMS wavefront
`
`error and distortion corresponding to Experiment III as described in Zeiss Exhibit
`
`1047.
`
`15. Exhibit 2038 shows plots of the RMS wavefront error versus field
`
`position (Ex. 2038 1), distortion (Ex. 2038 2), and a beam footprint (Ex. 2038 3)
`
`based on the CODE V lens layout corresponding to Experiment III from Exhibit
`
`1047. The exhibit also includes the lens prescription data corresponding to Exhibit
`
`1047 that was input into the Zemax software.
`
`16. To prepare the plots, I replicated the lens data from Exhibit 1047 into
`
`a Zemax lens file. I then produced the plots shown in Exhibit 2038 using standard
`
`plotting commands in Zemax.
`
`17. From the RMS wavefront error plot, I immediately recognized that –
`
`for two field points at 40 mm and 65 mm that were used by Mr. Juergens – the
`
`RMS wavefront error was the same with the results reported in the supplemental
`
`declaration of Mr. Richard Juergens (Ex. 1036). This served as a check that the
`
`data input was correct, otherwise I would not expect to obtain agreement for those
`
`two field points.
`
`
`
`5
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`18. To plot the beam footprint (Ex. 2038 3) corresponding to Mr.
`
`Juergens’ Experiment III, I created a multi-configuration file with the azimuths -
`
`45, -30, 0, 30, and 45 degrees, and then overlapped the Zemax beam footprints at
`
`the area used by the second mirror and the area used by the incoming beams at the
`
`same system plane. As shown in the plot of the beam footprint (Ex. 2038 3), it is
`
`my opinion that at least Experiment III suffers from a beam separation problem.
`
`19. A true and accurate copy of the results of my plots are shown in
`
`Nikon’s Exhibit 2038 (submitted herewith as Attachment C) entitled “RMS
`
`Wavefront Error (157 nm waves) for Exhibit 1047.” Because I am the
`
`author/creator of Exhibit 2038, I am familiar with the facts shown therein.
`
`IV. Exhibit 2039 - “RMS Wavefront Error
`(157 nm waves) for Exhibit 1049”_____
`
`20. On May 31, 2014 and on June 22, 2014, I plotted the RMS wavefront
`
`error and distortion corresponding to Experiment IV as described in Zeiss Exhibit
`
`1049.
`
`21. Exhibit 2039 shows plots of an RMS wavefront error versus field
`
`position (Ex. 2039 1) and distortion (Ex. 2039 2) based on the CODE V lens layout
`
`from Exhibit 1049. The exhibit also includes the lens prescription data in Exhibit
`
`1049 that corresponds to Experiment IV and that was input into the Zemax
`
`software.
`
`
`
`6
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`22. To prepare the plots, I copied the lens data from Exhibit 1049 into a
`
`Zemax lens file. Then I produced the plots shown in Exhibit 2039 using standard
`
`plotting commands in Zemax.
`
`23. From the RMS wavefront error plot, I immediately recognized that –
`
`for two field points at 40 mm and 65 mm that were used by Mr. Juergens – the
`
`RMS wavefront error was the same with the results reported in the supplemental
`
`declaration of Mr. Richard Juergens (Ex. 1036). This served as a check that the
`
`data input was correct, otherwise I would not expect to obtain agreement for those
`
`two field points.
`
`24.
`
` A true and accurate copy of the results of my analysis is shown in
`
`Nikon’s Exhibit 2039 (submitted herewith as Attachment D) entitled “RMS
`
`Wavefront Error (157 nm waves) for Exhibit 1049.” Because I am the
`
`author/creator of Exhibit 2039, I am familiar with the facts shown therein.
`
`V.
`
`Jurat
`
`25.
`
`I understand that intentionally I declare that all statements made
`
`herein of my own knowledge are true and that all statements made on information
`
`and belief are believed to be true; and further that these statements were made with
`
`the knowledge that willful false statements and the like so made are punishable by
`
`
`
`7
`
`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`fine or imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`
`
`Executed on July 8, 2014
`
`
`
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`
`
`
`
`
`
`
`
`/Jose Sasian, Ph.D./
`Jose Sasian, Ph.D.
`
`
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`8
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`
`
`Supplemental Declaration of Dr. Jose Sasian
`IPR2013-00362
`Patent 7,348,575
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that a copy of the foregoing SECOND
`
`DECLARATION OF DR. JOSE SASIAN was served by electronic mail
`
`(IPR24984-0056IP1@fr.com) on July 9, 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
`
`Respectfully Submitted,
`
`
`
`
`
`
`
`
`
`
`
`/John S. Kern/
`John S. Kern, Reg. No. 42,719
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`9
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