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 OPPOSITION
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`TO PETITIONER’S MOTION TO EXCLUDE EVIDENCE
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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
`
`Petitioner
`
`v.
`
`NIKON CORPORATION
`
`Patent Owner
`
`__________
`
`Case IPR2013-00362
`
`Patent 7,348,575
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`__________
`
`PATENT OWNER’S OPPOSITION
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`TO PETITIONER’S MOTION TO EXCLUDE EVIDENCE
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`Case IPR2013-00362
`Patent Owner’s Opposition to Petitioner’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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`Introduction ..................................................................................................... 1
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`Counterstatement of Material Facts ................................................................. 2
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`III. Relevant Law ................................................................................................... 4
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`IV. Argument ......................................................................................................... 4
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`A. Mr. Juergens and Dr. Sasian Each Authenticated Exhibits
`2036-2039 .............................................................................................. 4
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`B.
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`C.
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`Exhibits 2036-2039 Are Not Hearsay, and Even if They
`Were, They Fall within the Hearsay Exception .................................... 8
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`Irrespective of Hearsay, Exhibits 2036-2039 May Still Be
`Relied Upon for the Limited Purpose of Demonstrating
`that Petitioner’s Exhibits 1036 and 1038-1049 Have No
`Probative Value ................................................................................... 11
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`V.
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`Conclusion ................................................................................................... 13
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`ii
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`TABLE OF AUTHORITIES
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`Page
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`Cases
`Innovention Toys, LLC v. MGA Entm't, Inc.,
`2012 U.S. Dist. LEXIS 158194, at * 6-7 (E.D. La. Nov. 4, 2012) ........ 12
`
`Shu-hui Chen v. Herve Bouchard,
`2002 Pat. App. LEXIS 201 (BPAI Aug. 2, 2002) ..................................... 9
`
`
`Rules
`37 C.F.R. § 42.62 ................................................................................................. 3
`37 C.F.R. § 42.64 ................................................................................................. 7
`Federal Rule of Evidence 801 .............................................................................. 8
`Federal Rule of Evidence 807 .............................................................................. 9
`Federal Rule of Evidence 901 .............................................................................. 5
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`iii
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`Case IPR2013-00362
`Patent Owner’s Opposition to Petitioner’s Motion to Exclude Evidence
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`INTRODUCTION
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`I.
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`Petitioner’s Motion to Exclude Evidence ignores the fact that Patent
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`Owner’s Exhibits 2036-2039 simply include additional results of the lens design
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`that Petitioner and its declarant, Mr. Juergens, omitted from the reply brief and
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`accompanying exhibits. Significantly, Petitioner does not dispute that Mr.
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`Juergens’ Supplemental Declaration merely shows how his lens designs affect light
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`originating from only two field points out of the entire field width. Nor does
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`Petitioner appear to dispute that Mr. Juergens’ lens designs fail to properly form a
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`usable image – a result that Patent Owner’s Exhibits 2036-2039 confirm by
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`showing how the lens designs affect all light originating from the entire field
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`width.
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`Petitioner provides no credible basis for excluding the evidence, testimony,
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`or observations that it finds objectionable. Mr. Juergens and Patent Owner’s
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`expert, Dr. Sasian, have each authenticated Exhibits 2036-2039. Furthermore,
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`there is no hearsay issue here because the results in Exhibits 2036-2039 are simply
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`the output of Mr. Juergen’s lens design. Similar to the way an algebraic function
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`operates on inputs to generate outputs, the effect of the lens design on different
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`field points is immutable. The lens design will always have the same effect on the
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`same light originating from the same field point.
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`1
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`Petitioner has been afforded ample opportunity to verify the effect of Mr.
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`Juergens’ lens designs on light originating from all of the field points in the field
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`width. Thus, Petitioner has not been prejudiced by its inability to take further
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`depositions – Petitioner could have simply checked the effect of Mr. Juergens’ lens
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`designs on the entire field width instead of studiously omitting them from its reply
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`brief and accompanying exhibits.
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`Accordingly, Petitioner’s Motion to Exclude should be denied.
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`II.
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` COUNTERSTATEMENT 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 for the first time how
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`Petitioner’s expert, Mr. Juergens, utilized optical design software to modify a prior
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`art lens system to generate a lens system that falls within the scope of the claims
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`under review. Subsequently, Patent Owner cross-examined Mr. Juergens to
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`demonstrate that his computer-assisted lens designs described in Exhibits 1036 and
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`1038-1049 are inoperable, specifically because those lens designs fail to properly
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`form an image that is focused. (Ex. 2040, 110:12 – 111:21, 115:2 – 117:14,
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`123:22 – 125:19 ). Moreover, Mr. Juergens’ cross-examination testimony
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`demonstrated that some of the lens designs are inoperable because they suffer from
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`beam separation problems.1 (Ex. 2040, 117:15 – 120:1).
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`As evidenced by Exhibits 1036 and 1038-1049, Mr. Juergens curiously only
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`plotted two field points for his computer-assisted lens designs. The output
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`provided for those two field points suggests that the lens designs are usable in a
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`projection optical system to form an effective image. (Paper 22 at pages 12-13.)
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`Patent Owner’s Exhibits 2036-2039, on the other hand, plot the entire field width
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`of Mr. Juergens’ lens system, not just the two points that he selected. The output
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`for the complete field points demonstrate without question that Mr. Juergens’
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`computer-assisted lens designs fail to properly form an image that is focused (Ex.
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`2040, 110:12 – 111:21, 115:2 – 117:14, 123:22 – 125:19 ) and, in some cases, are
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`also inoperable because they fail to properly separate the beam paths. (Ex. 2040,
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`118:20-120:13.)
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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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`1 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 freshly-minted
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`computer-assisted lens designs submitted for the first time with Petitioner’s Reply.
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`3
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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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`IV. ARGUMENT
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`A. Mr. Juergens and Dr. Sasian Each Authenticated Exhibits 2036-
`2039
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`Mr. Juergens has over twenty-five years of experience working with optical
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`design software, first as an Assistant Director of Marketing for Optical Research
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`Associates from 1988-1999 and then as a consultant for Cimarron Optical
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`Consulting, starting in 1999. As a consultant, he has performed comparisons of
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`optical design software and conducted lens design and analysis using optical
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`design software. (Ex. 1028, 1-2.) Mr. Juergen’s curriculum vitae touts the
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`following:
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`Mr. Juergens is an expert user of the CODE V optical design software,
`which is used by many optical designers world-wide, such as those at
`Zeiss in Germany and Nikon in Japan (both places of which he has
`visited and given seminars and technical support). He worked 11
`years at Optical Research Associates, the suppliers of CODE V, and
`went around the world giving seminars, lectures, and technical
`support on how to use CODE V effectively for design and analysis of
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`all kinds of optical systems, including lithographic systems. (Ex.
`1028, 1.)
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`Mr. Juergens also testified as to his familiarity with how optical design software is
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`commonly used to design lens systems and determine RMS wavefront error for a
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`lens design at specified field points. Accordingly, Mr. Juergens is amply qualified
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`to recognize the output of optical design software.
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`With respect to the specific output shown in Exhibits 2036-2039 for the
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`Terasawa lens design and the lens designs that Mr. Juergens generated for his
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`supplemental declaration, Mr. Juergens has sufficient knowledge of those designs
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`to authenticate the output resulting from those same designs in Exhibits 2036-
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`2039. See FRE 901(a). In particular, Mr. Juergens executed his supplemental
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`declaration on May 27, 2014, in which he describes in detail his analysis of the
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`very lens designs described by Exhibits 2036-2039. (See, e.g., Ex. 1036 ¶¶ 15, 22,
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`30, 40, 49.) A little over a month after he submitted his supplemental declaration,
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`Mr. Juergens testified on cross-examination that Exhibits 2036-2039 are what they
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`claim to be, i.e., additional plots for the field points in the field width of the very
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`designs that Mr. Juergens analyzed in his supplemental declaration. (Ex. 2040,
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`74:12 -75:13, 108:14 - 109:12, 113:21 – 116:1, 116:17-117:6, 123:1-21.)
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`Representative samples of that testimony are as follows:
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`Q. Do you understand the plot shown in Figure 1?
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`A. Yes.
`Q. On Page 2 would you likewise agree that it is a plot of distortion
`based on the Table 2 in Terasawa?
`MR. WEFERS: Objection, foundation. Objection, scope.
`A. Yes. (Ex. 2040, 75:2-10, emphasis added.)
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`Q. So this exhibit is a plot of the RMS wavefront error corresponding
`to your example number two in -- or as set forth in your Exhibit
`1042. Do you recognize the plot shown on Page 1?
`A. I recognize what it is.
`Q. Could you please explain what you believe it to be?
`A. It's a plot of RMS wavefront error versus field height.
`Q. So -- scratch that. Does it surprise you that your design
`corresponding to Experiment Number II corresponding to the
`CODE V lens layout from Exhibit 1042 produces a plot as shown
`in Figure 1?
`MR. WEFERS: Objection, foundation.
`A. No. (Ex. 2040, 109:2-19, emphasis added.)
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`Q. So, again, what in your opinion is shown on Page 1 of this exhibit?
`A. It shows RMS wavefront error versus field.
`Q. So would you agree that this is the RMS wavefront error
`corresponding to the CODE V lens layout for the exhibit marked
`1049 of your Supplemental Declaration?
`A. I can accept that. (Ex. 2040, 123:14-21.)
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`6
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`Accordingly, Mr. Juergens was able to authenticate Exhibits 2036-2039 as plots
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`resulting from his own lens designs.
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`Independently, Patent Owner’s expert, Dr. Sasian, executed a second
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`declaration (Ex. 1054) that authenticates Exhibits 2036-2039 as plots resulting
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`from the lens designs that Mr. Juergens generated for his supplemental declaration.
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`Petitioner appears to concede that Dr. Sasian’s second declaration is sufficient to
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`authenticate Exhibits 2036-2039, but complains that the declaration is not timely,
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`citing to 37 C.F.R. 42.64(a).
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`A waiver of Rule 42.64 is warranted in this situation because Petitioner is
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`not in any way prejudiced by receiving Dr. Sasian’s second declaration after the
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`deposition, and because Patent Owner will suffer an easily-avoidable injustice if
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`the record includes plots for all field points in the field width of Mr. Juergens’
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`designs rather than the two field points that suggest that the prior art is enabling.
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`Had Patent Owner presented Dr. Sasian’s second declaration to counsel for
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`Petitioner during Mr. Juergens’ cross-examination, nothing about the deposition
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`would have changed. Dr. Sasian’s second declaration merely shows that he was
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`the person responsible for “plugging in” Mr. Juergens’ lens designs into computer
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`software that could plot points in the field width of Mr. Juergens’ designs. Even if
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`Petitioner were afforded the opportunity to cross-examine Dr. Sasian on his second
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`declaration, there is nothing that Petitioner could obtain from such testimony other
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`than that Dr. Sasian performed data entry to load Mr. Juergens’ designs into
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`software that plotted additional points in the field width of Mr. Juergens’ designs.
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`Exhibits 2036-2039 include the parameters of Mr. Juergens’ lens designs,
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`which Petitioner could have checked for accuracy during the deposition or
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`subsequently. Further, Petitioner could have checked the accuracy of Exhibits
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`2036-2039 by simply plotting additional points in the field width of Mr. Juergens’
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`designs.
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`Due to the unique situation that Petitioner has created by submitting with its
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`Reply new lens designs and plots for two field points that allegedly show that the
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`prior art enabled the scope of the claims under review, Patent Owner was denied an
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`opportunity to have its own expert replicate and opine on the relevance of Mr.
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`Juergens’ optical modeling process. Waiver of Rule 42.64 is justified here because
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`a gross injustice will occur if Patent Owner’s plots for all field points in the field
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`width are not allowed into the record to show that Mr. Juergens’ lens designs are
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`inoperable to form an effective image, as claimed in the 575 patent.
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`B.
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`Exhibits 2036-2039 Are Not Hearsay, and Even if They Were,
`They Fall within the Hearsay Exception
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`As an initial matter Exhibits 2036-2039 are not hearsay. They are not
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`statements by Dr. Sasian. Nor do they fall under the definition of a “statement”
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`under FRE 801(a) because they are not written assertions. They are simply the
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`plots that Mr. Juergens’ lens designs generate for the entire field width instead of
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`8
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`the two points that Mr. Juergens plotted. Similar to the way an algebraic function
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`operates on an input “x” to generate a plot of “y,” the effect of a lens design on
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`different field points is immutable.
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`If there were a practical way to express Mr. Juergens’ lens designs
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`mathematically, Patent Owner could have asked Mr. Juergens to plot additional
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`field points at his deposition. Instead, computer software is required to plot the
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`field points for a complex lens system. It does not matter who enters the data or
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`runs the optical modeling software – the software will always output the same plot
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`for each field point for the same lens design. Exhibits 2036-2039 reflect the
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`complete results of Mr. Juergen’s lens designs, which Petitioner, not Patent Owner,
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`has introduced into the record. Accordingly, Exhibits 2036-2039 are not hearsay.
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`In its motion to exclude (at 9), Petitioner relies on the Board’s decision in
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`Shu-hui Chen v. Herve Bouchard, Patent Interference No. 103,672, 2002 Pat. App.
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`LEXIS 201 (BPAI Aug. 2, 2002). While Patent Owner agrees that the Board in
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`Shu-hui Chen determined that certain scientific data was inadmissible hearsay, the
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`facts from that case are easily distinguished from the instant matter. First, unlike
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`here, there was a serious authenticity dispute regarding who actually created the
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`laboratory notebooks and scientific data relating thereto in Shu-hui Chen. As noted
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`above, there is no dispute that the subject data here is generated from Mr.
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`Juergens’ lens designs. Second, and most importantly, the Shu-hui Chen case did
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`not involve a situation caused by a party like Petitioner here who attempted to
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`improperly smuggle evidence into the proceeding by way of a reply brief.
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`Additionally, Exhibits 2036-2039 fall within the residual exception to
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`hearsay, FRE 807. First, Exhibits 2036-2039 do not fall within another hearsay
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`exception but they have the equivalent circumstantial guarantee of trustworthiness
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`as other hearsay exceptions. Specifically the exhibits are plots that Mr. Juergens’
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`lens design mathematically generated. The accuracy of the plots can be easily
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`confirmed by Petitioner.
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`Second, Exhibits 2036-2039 are offered as evidence of a material fact, i.e.,
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`that Mr. Juergens’ lens designs are inoperable to form an effective image.
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`Third, Exhibits 2036-2039 are more probative on the point for which they
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`are offered than any other evidence that Patent Owner can obtain through
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`reasonable efforts. Specifically, Patent Owner filed its response long before Mr.
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`Juergens' lens designs were submitted, and the schedule for this proceeding does
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`not permit Patent Owner a chance to submit a declaration of an expert to provide
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`opinions and analysis pertaining to Mr. Juergens’ lens designs.
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`Fourth, admitting Exhibits 2036-2039 best serves the purposes of the FRE
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`and the interests of justice. In Petitioner’s Exhibits 1036 and 1038-1049, Mr.
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`Juergens only plotted two field points out of the entire field width for his
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`computer-assisted lens designs. Exhibits 2036-2039 contain plots for all the points
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`Case IPR2013-00362
`Patent Owner’s Opposition to Petitioner’s Motion to Exclude Evidence
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`in the field width, and thus, provide the “rest of the story.” In particular, Exhibits
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`2036-2039 are necessary to correct the false impression that Petitioner’s Exhibits
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`1036 and 1038-1049 give with respect to the usefulness of Mr. Juergens’ lens
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`designs and whether the prior art enabled the claimed invention. Without the
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`addition of Exhibits 2036-2039 and the related cross-examination testimony of Mr.
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`Juergens, there is no evidence to rebut Petitioner’s and Mr. Juergens’ erroneous
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`conclusions that computer modeling software successfully modified the prior art to
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`generate an immersed lens design. Petitioner’s Reply (Paper No. 22) at pages 12-
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`13 is indicative of this problem:
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`Mr. Juergens showed that a POSITA could have used CODE V to
`redesign the optical prescription for FIG. 5 in Terasawa by adding an
`immersion fluid between the last lens surface and the wafer to
`increase DOF, adjusting the thicknesses and curvatures of certain
`lenses, and re-optimizing the aspheric coefficients of the system to
`obtain an imaging performance as good as, or better than, the
`original dry design. (ZEISS 1036, ¶¶ 15-31, 43-47, emphasis added.)
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`Patent Owner’s Exhibits 2036-2039 clearly disprove sweeping statements such as
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`those made above. It is plainly within the interests of justice to admit into the
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`record the other plots generated by the same lens designs.
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`C.
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`Irrespective of Hearsay, Exhibits 2036-2039 May Still Be Relied
`Upon for the Limited Purpose of Demonstrating that Petitioner’s
`Exhibits 1036 and 1038-1049 Have No Probative Value
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`Patent Owner’s Opposition to Petitioner’s Motion to Exclude Evidence
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`Lastly, even if the Board is inclined to exclude Exhibits 2036-2039, they
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`should at least be admitted for the limited purpose of demonstrating that
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`Petitioner’s Exhibits 1036 and 1038-1049 are incomplete and thus should be given
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`little weight (if any). Specifically, Petitioner’s Exhibits 1036 and 1038-1049 plot
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`only two field points out of the entire field width. Patent Owner’s Exhibits 2036-
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`2039 demonstrate that the plots of only two field points is not probative of whether
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`the prior art enables the claims under review.
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`If admitted for this limited purpose, Exhibits 2036-2039 could not constitute
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`hearsay because they are not offered for the truth of the matter asserted.
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`Innovention Toys, LLC v. MGA Entm't, Inc., 2012 U.S. Dist. LEXIS 158194, at *
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`6-7 (E.D. La. Nov. 4, 2012) (holding that certain letters were not hearsay because
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`they were not offered to prove the truth of the matters asserted in those letters, but
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`instead to show the accused infringer’s state of mind). In this case, Exhibits 2036-
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`2039 would not be offered to prove that the prior art is not enabling, but rather to
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`show that Petitioner’s Exhibits 1036 and 1038-1049 paint an incomplete and
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`misleading picture.
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`Patent Owner’s Opposition to Petitioner’s Motion to Exclude Evidence
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`V. CONCLUSION
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`For the foregoing reasons, the Board should deny Petitioner’s Motion to
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`Exclude Evidence.
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`Dated: July 14, 2014
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`Respectfully submitted,
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`____
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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 Opposition to Petitioner’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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`OPPOSITION TO PETITIONER’S MOTION TO EXCLUDE EVIDENCE was
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`served via email (IPR24984-0056IP1@fr.com) on July 14, 2014 in its entirety, to
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`the following:
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`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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`____
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`/John S. Kern/
`John S. Kern (Reg. No. 42,719)
`Attorney for Patent Owner
` Nikon Corporation
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`Date: July 14, 2014
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