Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
`
`----------------------:
` :
`CARL ZEIS SMT GMBH :
` :
` Petitioner :
` : Case IPR2013-00362
` v. :
` : Patent 7,348,575
`NIKON CORPORATION :
` :
` Patent Owner :
` :
`----------------------:
`
` CROSS-EXAMINATION BY DEPOSITION
` OF RICHARD C. JUERGENS
`
` WEDNESDAY, FEBRUARY 12, 2014
` 9:10 AM
`
` FISH & RICHARDSON
` One Marina Park Drive
` Boston, Massachusetts 02210
`
` Sandra A. Deschaine, CSR, RPR, CLR, CRA
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 1
`
`
`Juergens, Richard C. 02-12-2014
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
`
`----------------------:
` :
`CARL ZEIS SMT GMBH :
` :
` Petitioner :
` : Case IPR2013-00362
` v. :
` : Patent 7,348,575
`NIKON CORPORATION :
` :
` Patent Owner :
` :
`----------------------:
`
` CROSS-EXAMINATION BY DEPOSITION
` OF RICHARD C. JUERGENS
`
` WEDNESDAY, FEBRUARY 12, 2014
` 9:10 AM
`
` FISH & RICHARDSON
` One Marina Park Drive
` Boston, Massachusetts 02210
`
` Sandra A. Deschaine, CSR, RPR, CLR, CRA
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 1
`
`
`
`2
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 A P P E A R A N C E S
`2
`ON BEHALF OF NIKON CORPORATION:
`3 OBLON, SPIVAK, MCCLELLAND, MAIER &
`NEUSTADT, L.L.P.:
`
` John Kern, Esquire
`6 Robert Mattson, Esquire
`7 1940 Duke Street
`8 Alexandria, Virginia 22314 U.S.A.
`9 T. 703.412.3000 F. 703.413.2200
`10 jkern@oblon.com
`11 rmattson@oblon.com
`12
`13 ON BEHALF OF CARL ZEISS SMT GMBH:
`FISH & RICHARDSON, P.C.
`14
`15 Kurt Glitzenstein, Esquire
`16 Marc Wefers, Ph.D., Esquire
`17 One Marina Park Drive
`18 Boston, Massachusetts 02210
`19 T. 617.542.5070 F. 617.542.8906
`20 glitzenstein@fr.com
`21 wefers@fr.com
`22
`23
`24
`
`4 5
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 2
`
`
`
`3
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 I N D E X
`2 WITNESSES: PAGE
`3 Richard C. Juergens
`4 By Mr. Zern 4/275
`5 By Mr. Glitzenstein 265
`
`6 7
`
` E X H I B I T S
`8 EXHIBITS: DESCRIPTION PAGE
`9 Exhibit 2001 International
` Technology Roadmap for
`10 Semiconductors, 2003 69
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 3
`
`
`
`4
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 RICHARD C. JUERGENS, Deponent,
`2 having first been satisfactorily identified
`3 by the production of his Arizona driver's
`4 license and duly sworn by the Notary Public,
`5 was examined and testified as follows:
`
`6 7
`
` MR. GLITZENSTEIN: Kurt
`8 Glitzenstein of Fish & Richardson. I
`9 represent Carl Zeiss.
`10 MR. WEFERS: Marc Wefers of Fish &
`11 Richardson. I also represent Carl
`12 Zeiss.
`13 MR. KERN: John Kern of Oblon
`14 Spivak. I represent Nikon
`15 Corporation.
`16 MR. MATTSON: Robert Mattson of
`17 Oblon Spivak, also representing Nikon
`18 Corporation.
`19 CROSS-EXAMINATION
`20 BY MR. KERN:
`21 Q. Good morning, Mr. Juergens.
`22 A. Good morning.
`23 Q. Do you know why you're here today?
`24 A. Yes.
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 4
`
`
`
`5
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 Q. Are you an expert witness for Carl
`2 Zeiss in IPR matter IPR2013-00362?
`3 A. I am.
`4 Q. And that is involving U.S. Patent
`5 Number 7,348,575?
`6 A. That's correct.
`7 Q. I want to let you know, before we
`8 get into the general questions, that if at
`9 any point during our deposition, if you don't
`10 understand a question or a question isn't
`11 clear, please feel free to ask me to repeat
`12 the question or rephrase the question.
`13 Is that clear?
`14 A. Yes.
`15 Q. I'm going to start off with some
`16 general questions.
`17 In the context of
`18 microilithography, what does it mean to be a
`19 dioptric projection optical system?
`20 A. "Dioptric" means that the
`21 projection system consists entirely of
`22 transmitting elements or lenses and does not
`23 contain any powered mirrors.
`24 Q. But could it retain or include
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 5
`
`
`
`6
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 mirrors?
`2 A. It can include flat fold mirrors.
`3 Q. And what does it mean, again, in
`4 the context of microlithography, to be a
`5 catoptric projection optical system?
`6 A. Catoptric projection system is one
`7 that contains only reflecting optical
`8 elements and does not retain any powered
`9 transmitting elements.
`10 Q. But it could contain transmitting
`11 elements?
`12 A. It can contain windows or filters.
`13 Q. And finally, what does it mean to
`14 be a catadioptric projection optical system?
`15 A. That would be a system that
`16 contains both power reflective systems, and
`17 elements, and lenses, the combination of the
`18 two.
`19 Q. And how long have catadioptric
`20 systems been around?
`21 A. Hundred of years. A long time. I
`22 don't know about projection catadioptric
`23 systems, but cat systems have been around for
`24 a long time.
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 6
`
`
`
`7
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 Q. Do you have a sense for how long
`2 catadioptric systems have been around in the
`3 context of microlithography?
`4 A. No.
`5 Q. Do you have a sense of how long
`6 catadioptric systems using in-line structures
`7 have been in use?
`8 A. Almost from the very start of
`9 lithography the systems were in line. It's
`10 only been recently that they had nonin-line
`11 systems.
`12 Q. So there are two types of
`13 catadioptric systems, one in line and one not
`14 in line; is that accurate?
`15 A. Most -- no. My question (sic) was
`16 answering that most lithography systems were
`17 in line, not necessarily catop -- was your
`18 question relating to catadioptric projection
`19 systems?
`20 Q. Right. The general question was
`21 how long have catadioptric systems been in
`22 use that are in line?
`23 A. That are in line. I do not know
`24 the exact history, so I can't say when they
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 7
`
`
`
`8
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 first were starting to be used.
`2 Q. Okay. Fair enough.
`3 So in the context of
`4 microlithography, what is immersion
`5 technology?
`6 A. Immersion technology is technology
`7 where you introduce a fluid between the last
`8 optical element in the system and the wafer
`9 where the image is being formed, and that
`10 liquid is being used for several purposes but
`11 mainly to increase the numerical aperture.
`12 Q. And for how long has immersion
`13 technology been used in photolithography?
`14 A. Probably -- I don't know exactly,
`15 but I would say probably a little over a
`16 decade.
`17 Q. And prior to May 6, 2003, are you
`18 aware of any catadioptric projection optical
`19 systems that operated using immersion
`20 technology?
`21 A. I'm not aware specifically of
`22 systems that used immersion technology prior
`23 to 2003, but I would not be surprised if
`24 there were some.
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 8
`
`
`
`9
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 Q. Why, in your opinion, would the
`2 use of immersion technology prior to 2003 not
`3 have been widespread?
`4 MR. GLITZENSTEIN: Object to form.
`5 BY MR. KERN:
`6 Q. Please answer the question.
`7 A. I would say it's probably because
`8 up until that time the demands on
`9 microlithography did not require the
`10 precision, the fine structure that was needed
`11 that is provided by immersion, and
`12 so that's -- I think that's the answer.
`13 Q. So there wasn't a desire in the
`14 industry to increase the resolution of a
`15 projection optical system prior to 2003?
`16 A. There always is a desire to
`17 improve resolution, resolving power. It
`18 wasn't -- it got to the point where it needed
`19 the step of immersion until probably past --
`20 in year 2000 or so.
`21 Q. You differentiated between
`22 resolving power and resolution.
`23 Is there a difference?
`24 A. It's just a question in terms of
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 9
`
`
`
`10
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 trying to define a smaller item as being
`2 better or improved. So saying improving the
`3 resolution, do mean enlarging it, making it
`4 larger, making it smaller? You say improving
`5 the -- or resolving power, that, I think, is
`6 a clearer term.
`7 Q. So just for clarity, for resolving
`8 power, do you mean the ability of a
`9 photolithog -- or microlithography projection
`10 lens to define a particular size on a wafer,
`11 a line on a wafer?
`12 MR. GLITZENSTEIN: Object to the
`13 form.
`14 THE WITNESS: Yes.
`15 BY MR. KERN:
`16 Q. So, to your knowledge, when was
`17 the first dioptric projection optical system
`18 that utilized immersion technology
`19 manufactured?
`20 A. I could not say when the first one
`21 exactly used immersion.
`22 Q. Do you have a sense of maybe when
`23 they were designed?
`24 MR. GLITZENSTEIN: Objection to
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 10
`
`
`
`11
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 form.
`2 BY MR. KERN:
`3 Q. Let me rephrase it. Do you have
`4 a -- scratch that.
`5 Are you aware of when dioptric
`6 projection optical systems using immersion
`7 technology were first designed?
`8 A. I could not give you an exact
`9 date.
`10 Q. Do you know when dioptric
`11 projection optical systems using immersion
`12 technology were first commercially available?
`13 A. Again, I could not tell you the
`14 exact date. It is in 2005, more than likely,
`15 but I cannot give you the exact date.
`16 Q. Do you have any idea, or do you
`17 know who -- scratch that.
`18 Do you know who would have made
`19 such a device?
`20 A. There's many companies that are
`21 making microlithography equipment; so I can
`22 not tell you which one made the first one.
`23 Q. Do you know if Zeiss manufacturers
`24 a dioptric projection optical system
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 11
`
`
`
`12
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 utilizing immersion technology?
`2 A. I do not know that specifically,
`3 no. I would not be surprised if they did.
`4 Q. And why is that?
`5 A. Because Zeiss makes cutting-edge
`6 microlithography equipment and immersion
`7 technology certainly is cutting edge.
`8 Q. Is dioptric projection optical
`9 system a cutting-edge technology?
`10 A. Dioptric is not, no. It's just
`11 been used for decades.
`12 Q. Is the use then -- scratch that.
`13 Is the use of dioptric projection
`14 optical systems with immersion technology a
`15 cutting-edge technology?
`16 A. Within this century, it probably
`17 has been, within the 2000s.
`18 Q. Do you know the resolution of such
`19 systems?
`20 A. It's in the 30 to 50 micron
`21 region.
`22 Q. Do you know the numerical aperture
`23 of such systems?
`24 A. It ranges from -- the highest
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 12
`
`
`
`13
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 numerical aperture is probably in -- ranges
`2 from 1., say, 25 and 1.35, in that region
`3 there.
`4 Q. Do you know if the dioptric
`5 projection optical systems that utilize
`6 immersion technology are in line?
`7 A. Most of them, yes, are in line.
`8 Q. Do you know if the dioptric
`9 projection optical systems utilizing
`10 immersion technology are off-access
`11 illumination?
`12 A. Dioptric systems usually are not
`13 off access. There's no need for them to be
`14 off access.
`15 Q. Are there dioptric systems that
`16 are off access?
`17 A. There could be.
`18 Q. So, to your knowledge, when was
`19 the first catadioptric projection optical
`20 system that utilized immersion technology
`21 design?
`22 A. I could not give you an exact date
`23 on that.
`24 Q. Do you know when the first, or
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 13
`
`
`
`14
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 generally speaking, catadioptric projection
`2 optical systems using immersion technology
`3 became commercially available?
`4 A. I cannot give you an exact date on
`5 that.
`6 Q. Are catadioptric projection
`7 optical systems that utilize immersion
`8 technology commercially available today?
`9 A. I believe they are, yes.
`10 Q. Do you know who manufacturers such
`11 a device?
`12 A. I do not know specifically. I
`13 would guess that probably both Zeiss and
`14 Nikon probably do, but I'm not familiar with
`15 this product line entirely; so I can't tell
`16 you exactly.
`17 Q. Are you aware of any of the models
`18 out there available in the market?
`19 A. No.
`20 Q. Are you aware whether any of the
`21 catadioptric projection optical systems
`22 utilizing immersion technology also utilized
`23 off-access illumination?
`24 A. I would -- I believe that almost
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 14
`
`
`
`15
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 entirely that they do, yes.
`2 Q. And why is that?
`3 A. If you're catadioptric and you are
`4 not using off-access technology, then you
`5 have a -- you have to put in extra shields to
`6 prevent stray light issues, and so it's
`7 easier just to do that with an off-access
`8 illumination and off-access imagining.
`9 Q. And are those shields -- is there
`10 a specific name for those shields in the
`11 system itself?
`12 A. Different people use different
`13 names. "Shields" is a commonly used term.
`14 Q. Is an aperture stop a shield?
`15 A. No.
`16 Q. Does the use of sheets in
`17 photolithography cause obscurations in light
`18 incident on wafer?
`19 MR. GLITZENSTEIN: Object, form.
`20 MR. KERN: Scratch that.
`21 BY MR. KERN:
`22 Q. Does the use of shields in
`23 catadioptric projection optical systems
`24 result in loss of light incident on a wafer?
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 15
`
`
`
`16
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 MR. GLITZENSTEIN: Object, form.
`2 THE WITNESS: Yes.
`3 BY MR. KERN:
`4 Q. How so?
`5 A. Well, by the very nature of being
`6 a shield means that it's blocking some of the
`7 light that's getting to the image plate.
`8 Q. And that's generally, in the
`9 industry, not desirable?
`10 MR. GLITZENSTEIN: Objection to
`11 form and foundation.
`12 MR. KERN: Scratch that.
`13 BY MR. KERN:
`14 Q. Is it your opinion that
`15 obscuration in a catadioptric system is
`16 desirable?
`17 A. It is not desirable.
`18 Q. And why?
`19 A. Because -- for two reasons. One
`20 is that obscurations, by their nature,
`21 obscure, so they cut out light; so you lose
`22 throughput, is one reason.
`23 And the second reason is that they
`24 have an impact on the shape of the image, on
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 16
`
`
`
`17
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 the point spread function of the image.
`2 Q. What would one of ordinary skill
`3 in the art, at the time of filing the '575
`4 Patent, understand vignetting to mean?
`5 A. Vignetting is blocking of light
`6 that is not on access by some mechanical
`7 aperture somewhere in the system.
`8 Q. Could that mechanical aperture be
`9 a shield?
`10 A. Yes.
`11 Q. And is vignetting something an
`12 optical designer tries to avoid?
`13 MR. GLITZENSTEIN: Objection to
`14 form, foundation.
`15 BY MR. KERN:
`16 Q. Please answer.
`17 A. In general -- that's a very
`18 general question. In general, you try to
`19 avoid vignetting, but there are times when
`20 vignetting is useful.
`21 Q. When the '575 Patent was filed,
`22 what type of system was Zeiss selling?
`23 MR. GLITZENSTEIN: Objection to
`24 form, foundation.
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 17
`
`
`
`18
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 THE WITNESS: I do not know the
`2 answer to that question.
`3 BY MR. KERN:
`4 Q. Do you know whether Zeiss sells
`5 microlithography systems?
`6 A. I do know that they sell them,
`7 yes.
`8 Q. Do you have any idea of what type
`9 of systems they sell?
`10 A. I have -- I'm not familiar with
`11 their product line in particular, no.
`12 Q. Would it surprise you if they sold
`13 dioptric projection optical systems?
`14 MR. GLITZENSTEIN: Objection to
`15 form.
`16 THE WITNESS: No.
`17 BY MR. KERN:
`18 Q. Would it surprise you if they sold
`19 catadioptric projection optical systems?
`20 MR. GLITZENSTEIN: Objection to
`21 form.
`22 THE WITNESS: No.
`23 BY MR. KERN:
`24 Q. Would it surprise you to learn
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 18
`
`
`
`19
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 that Zeiss sold catadioptric projection
`2 optical systems using immersion technology?
`3 MR. GLITZENSTEIN: Objection to
`4 form.
`5 THE WITNESS: No.
`6 Q. So to your knowledge, does Zeiss
`7 manufacture a dioptric projection optical
`8 system that operates using immersion
`9 technology?
`10 MR. GLITZENSTEIN: Objection,
`11 foundation.
`12 THE WITNESS: To my knowledge,
`13 I -- I do not know the answer to that
`14 question.
`15 BY MR. KERN:
`16 Q. Are you aware if Zeiss has any
`17 patents assigned to Zeiss directed to
`18 dioptric projection optical systems using
`19 immersion technology?
`20 A. No.
`21 Could you repeat that again,
`22 please?
`23 Q. Sure. Are you aware of any
`24 patents assigned to Zeiss that are directed
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 19
`
`
`
`20
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 to dioptric projection optical systems using
`2 immersion technology?
`3 A. I'm not aware of a specific
`4 patent.
`5 Q. Are you aware of any patents
`6 assigned to Zeiss directed to catadioptric
`7 projection optical systems using immersion
`8 technology?
`9 A. Yes.
`10 Q. Do you know whether those patents
`11 have issued?
`12 A. No.
`13 Q. To your knowledge, does Zeiss
`14 manufacture a catadioptric projection optical
`15 system using immersion technology?
`16 MR. GLITZENSTEIN: Objection,
`17 form, and foundation.
`18 THE WITNESS: I believe that they
`19 do manufacture those, yes.
`20 BY MR. KERN:
`21 Q. And do you know when those systems
`22 would have been commercially available?
`23 A. I could not tell you an exact
`24 date.
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 20
`
`
`
`21
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 Q. Do you know when those systems
`2 were designed by Zeiss?
`3 A. No, I do not know that.
`4 Q. Do you know whether they were
`5 designed prior to 2003?
`6 A. I would say that they probably
`7 were.
`8 Q. Do you know whether Zeiss was
`9 aware of the '575 Patent at the time of
`10 designing those systems?
`11 A. No. I cannot speak for what Zeiss
`12 knows and does not know.
`13 Q. Did anybody tell you that Zeiss
`14 was aware of that patent at the time of
`15 designing the catadioptric systems?
`16 A. No.
`17 Q. So, Mr. Juergens, when dealing
`18 with immersion designs, what are the benefits
`19 provided by a catadioptric system over a
`20 dioptric system?
`21 A. The main benefit is that one of
`22 the driving concerns is to achieve what's
`23 called a flat field, and that is achieved by
`24 driving a number called the Petzval sum to
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 21
`
`
`
`22
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 zero. Petzval sum being the curvature of
`2 that -- of the imaged surface.
`3 And with all lenses in a dioptric
`4 system, it is difficult to drive the Petzval
`5 sum to zero, but a catadioptric system using
`6 mirrors makes it much easier to drive that
`7 Petzval sum to zero.
`8 Q. Could you explain what it means,
`9 then, to satisfy Petzval's condition?
`10 A. At the Petzval -- at the sum of --
`11 all the Petzval terms of each surface sums to
`12 zero.
`13 Q. What is a Petzval term?
`14 A. It's a mathematical equation that
`15 is related to the -- mainly to the radius of
`16 curvature and to the indices of refraction on
`17 either side of the surface.
`18 Q. So it's equal?
`19 A. It's a mathematical term that then
`20 sums to the final curvature.
`21 Q. So each lens or mirror in a system
`22 would have to be analyzed to determine --
`23 A. Actually, each surface.
`24 Q. Okay. Mr. Juergens, would you
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 22
`
`
`
`23
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 agree that a catadioptric system is generally
`2 more compact than a dioptric system?
`3 MR. GLITZENSTEIN: Objection to
`4 form.
`5 THE WITNESS: It can be.
`6 BY MR. KERN:
`7 Q. Why is that?
`8 MR. GLITZENSTEIN: Same objection.
`9 THE WITNESS: If you mean by
`10 "compact," if you mean shorter -- is
`11 that what you mean by "compact"?
`12 BY MR. KERN:
`13 Q. Shorter takes -- generally takes
`14 less space?
`15 MR. GLITZENSTEIN: Same objection.
`16 THE WITNESS: Okay. Well, the
`17 fact that a catoptric system that has
`18 light going back and forth means that
`19 you can use the space more effectively.
`20 BY MR. KERN:
`21 Q. And is that desirable in the field
`22 of microlithography, to have a more compact
`23 system?
`24 MR. GLITZENSTEIN: Objection,
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 23
`
`
`
`24
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 form.
`2 THE WITNESS: It's generally
`3 desirable in almost any kind of optical
`4 system, to make your system as compact
`5 as possible.
`6 BY MR. KERN:
`7 Q. What are some of the benefits of
`8 having a more compact system?
`9 A. Less weight, less structure, less
`10 impact of environmental effects.
`11 Q. Do catadioptric systems require
`12 less lenses than a dioptric system?
`13 MR. GLITZENSTEIN: Objection to
`14 form.
`15 THE WITNESS: Usually, yes.
`16 BY MR. KERN:
`17 Q. Because catadioptric (sic) systems
`18 require less lenses, are they less expensive
`19 than catadioptric (sic) systems?
`20 MR. GLITZENSTEIN: Objection to
`21 form.
`22 THE WITNESS: It's a very complex
`23 question, what the cost of the system
`24 is, based upon the cost of the
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 24
`
`
`
`25
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 materials, cost of the shape, surfaces;
`2 so you can't categorically say that one
`3 is cheaper than the other.
`4 BY MR. KERN:
`5 Q. Are there limits on the
`6 manufacturability of lenses?
`7 MR. GLITZENSTEIN: Objection,
`8 form.
`9 THE WITNESS: Could you clarify
`10 what you mean by "limits"?
`11 BY MR. KERN:
`12 Q. Do certain materials used in lens
`13 designs have limits as to the diameter of the
`14 lens you can manufacture?
`15 MR. GLITZENSTEIN: Same
`16 objection.
`17 THE WITNESS: There -- yes.
`18 BY MR. KERN:
`19 Q. Could you describe some of the
`20 limits?
`21 A. Some crystalline materials, such
`22 as calcium fluoride, are difficult to obtain
`23 in very large diameters; so you would try to
`24 minimize the size of those diameters. That's
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 25
`
`
`
`26
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 one example.
`2 Q. Is the diameter of a lens
`3 important in optical design?
`4 MR. GLITZENSTEIN: Objection,
`5 form.
`6 THE WITNESS: Only important in
`7 terms of the manufacturability and the
`8 mounting. It's not a driving part of
`9 consideration in the design itself, in
`10 the design process.
`11 BY MR. KERN:
`12 Q. Would an optical designer take
`13 into account the cost of a lens or
`14 manufacturing a lens when designing a system?
`15 MR. GLITZENSTEIN: Objection,
`16 form.
`17 THE WITNESS: Usually cost is
`18 important; they take that into account.
`19 BY MR. KERN:
`20 Q. So is it true that there are
`21 limits on the practical size of lenses when
`22 manufacturing a projection optical system?
`23 A. I wouldn't say there are limits.
`24 I would say that there are considerations to
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 26
`
`
`
`27
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 be made during the design process.
`2 Q. So phrased a little differently,
`3 would a designer take into account the cost
`4 of manufacturing a particular lens in their
`5 optical design when designing a projection
`6 lens?
`7 MR. GLITZENSTEIN: Objection to
`8 form.
`9 THE WITNESS: Yes.
`10 BY MR. KERN:
`11 Q. Are there any other reasons or --
`12 scratch that.
`13 Are there any other reasons that a
`14 catadioptric projection optical system is
`15 better, in your opinion, than a dioptric
`16 system?
`17 A. There are techniques you can use
`18 in a catadioptric system to reduce the
`19 chromatic aberration of a system.
`20 Q. And those are not present in a
`21 dioptric system?
`22 A. No.
`23 Q. How does a lens designer correct
`24 for chromatic aberration in a dioptric
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 27
`
`
`
`28
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 system?
`2 A. You have to use a combination of
`3 at least two different materials.
`4 Q. Could you explain further?
`5 A. Glasses are characterized by their
`6 dispersion, which is a measure of the change
`7 of refraction with wavelength; so a lens
`8 could have high dispersion or it can have low
`9 dispersion. And you correct chromatic
`10 aberration by combining, usually, a positive
`11 lens with low dispersion, with a negative
`12 lens of high dispersion.
`13 Q. I'd like to turn now,
`14 Mr. Juergens, to your expert report, and
`15 that's Exhibit 1016. Here's a copy of your
`16 report.
`17 MR. GLITZENSTEIN: This is for the
`18 witness?
`19 MR. KERN: Yes.
`20 BY MR. KERN:
`21 Q. Do you agree that in your expert
`22 report that you describe the level of
`23 ordinary skill in the art?
`24 A. Yes.
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 28
`
`
`
`29
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 Q. Have you ever been an expert for
`2 Zeiss before, in the past?
`3 A. Yes.
`4 Q. Are you currently an expert for
`5 Zeiss in any other matter?
`6 A. No.
`7 Q. Do you recall which matters you
`8 have been an expert for Zeiss in?
`9 A. It was a previous issue with the
`10 same patent.
`11 Q. With the same patent?
`12 A. I can't remember if -- I cannot
`13 tell you the exact patent number. I don't
`14 have it in front of me. It was a patent
`15 having to do with catoptric systems. I
`16 believe it was very similar to this patent,
`17 if not the same patent.
`18 Q. Would you agree if I told you that
`19 it was a child or continuation of the '575
`20 Patent we're discussing today?
`21 A. I would agree with that.
`22 Q. Do you understand what it means to
`23 be a continuation or a child of a parent
`24 application?
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 29
`
`
`
`30
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 A. I could guess the meaning by the
`2 words, but I cannot tell you exactly what
`3 that means legally.
`4 Q. Do you know whether you were an
`5 expert for Zeiss in an interference of U.S.
`6 Patent Number 7,309,870? This patent was
`7 issued to Mr. Yashuhiro Omura of Nikon.
`8 A. That sounds correct.
`9 Q. So in your Expert Declaration,
`10 Exhibit 1016, you have described the level of
`11 ordinary skill in the art.
`12 Is it the same as the level you
`13 had previously described during the '870
`14 interference?
`15 A. Yes, it is.
`16 Q. And you're certain of that?
`17 A. Yes.
`18 Q. I'd like you to turn to Paragraph
`19 22 on Page 8 of your expert report. If you
`20 could take a second to refresh your
`21 recollection of it.
`22 (Witness reviewing document.)
`23 A. Okay.
`24 Q. At Line 8 you describe "the field
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 30
`
`
`
`31
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 of optical design"; is that correct?
`2 A. Uh-huh.
`3 Q. What exactly is encompassed by
`4 "the field of optical design"?
`5 A. It means that the person has
`6 experience in actually designing optical
`7 systems.
`8 Q. And what type of optical systems?
`9 A. It could be any kind of optical
`10 systems. There's thousands of different
`11 kinds of optical systems.
`12 Q. Would binoculars be included in
`13 the field of optical design?
`14 A. Yes.
`15 Q. Telescopes?
`16 A. Yes.
`17 Q. Glasses?
`18 A. Technically, yes.
`19 Q. Microlithography?
`20 A. Certainly.
`21 Q. So in Paragraph 22 of your expert
`22 report, you're implying that a person of
`23 ordinary skill in the art would have
`24 experience in designing projection optical
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2014
`
`CARL ZEISS V. NIKON
`IPR2013-00363
`Ex. 2003, p. 31
`
`
`
`32
`
`Capital Reporting Company
`Juergens, Richard C. 02-12-2014
`
`1 systems for microlithography?
`2 A. I did not say that directly, no.
`3 Q. So they would have experience in
`4 the field of microlithography?
`5 A. They would have experience in --
`6 MR. GLITZENSTEIN: Objection,
`7 form.
`8 Proceed.
`9 THE WITNESS: Th
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
