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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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`EXPERT DECLARATION OF RICHARD C. JUERGENS
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`Exhibit No. 1116
`Petition for IPR of US 7,348,575
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`ZEISS 1116
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 2 of 99
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`Expert Declaration of Richard C. Juergens
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`I, RICHARD C. JUERGENS, do hereby declare that:
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`I.
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`BACKGROUND
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`1.
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`2.
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`3.
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`1129.
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`I am an American citizen residing in Tucson, Arizona.
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`A copy of my curriculum vitae is submitted as Exhibit No. (“ZEISS”)
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`I am a Senior Engineering Fellow at Raytheon Missile Systems,
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`Tucson, Arizona, working in the Hardware Design Department. I am also
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`President of Cimarron Optical Consulting, Inc., in Tucson, Arizona.
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`4.
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`I have held the following positions: Assistant Director of Marketing at
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`Optical Research Associates (now the Optical Solutions Group of Synopsys, Inc.),
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`Pasadena CA, 1988-1999; Senior Scientist at Hughes Aircraft Company, El
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`Segundo CA, 1984-1988; Vice President of Engineering at FLIR Systems, Inc.,
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`Portland OR, 1982-1984; Section Supervisor, System Analysis and Requirements,
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`Ford Aerospace, Newport Beach CA, 1970-1982; and Member of the Technical
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`Staff at Rockwell International, Anaheim CA, 1966-1970.
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`5.
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`I received a B.A. in Physics from California State College at
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`Fullerton, Fullerton, CA, in 1967. I received an M.A. in Physics from University
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`of California, Irvine, Irvine, CA, in 1969.
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`6.
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`I have over 40 years of experience as an optical designer and optical
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`engineer. I have designed many different types of telescopes and optical systems,
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`including catoptric, dioptric, and catadioptric systems.
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`7.
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`Since the mid-1970s, I have been a member of the Optical Society of
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`Southern California. In 1980, I was President of the Optical Society of Southern
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`California. Since the mid-1970s, I have been a member of the Optical Society of
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`America. Since the mid-1970s, I have been a member of the SPIE, The
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`International Society for Optical Engineering, and have chaired several of their
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`conferences during this time.
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`8.
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`From time to time, I teach courses at Raytheon Missile Systems on
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`fundamentals of optical engineering, and give guest lectures at the College of
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`Optical Sciences of the University of Arizona on various aspects of optical
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`engineering and design.
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`9.
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`I have extensive experience using CODE V optical design software,
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`which is used by many optical designers worldwide. While employed by Optical
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`Research Associates, the suppliers of CODE V, I gave seminars, lectures, and
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`technical support on how to use CODE V effectively for design and analysis of all
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`kinds of optical systems, including lithographic systems. During this time I gave
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`seminars and technical support at Carl Zeiss in Germany and Nikon in Japan.
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`10.
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`I understand that Carl Zeiss SMT GmbH will file a petition
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`(hereinafter the “Petition”) for Inter Partes Review (“IPR”) of claims 55-67 (the
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`“Challenged Claims”) of the Omura Patent (U.S. Patent No. 7,348,575), to Nikon.
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`I have been retained by Carl Zeiss SMT GmbH and my specific tasks have been
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`given to me by their counsel, Fish & Richardson, P.C. I am being compensated for
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`my work in this matter at my customary consulting rate of $125 per hour.
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`II. MATERIALS CONSIDERED FOR THIS DECLARATION
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`11. My opinions in this declaration are based on my academic training,
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`experience, research, and review of the documents cited in this declaration,
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`including U.S. Patent No. 7,348,575 (“the Omura Patent”) (ZEISS 1101); A
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`Certified English Translation of Japanese Unexamined Patent Publication No. JP
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`2003-128154 (ZEISS 1107); U.S. Patent Application Publication No.
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`2005/0036213 (“Mann”) (ZEISS 1110); Certified English translation (“Omura
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`‘387”) (ZEISS 1112) of JP Patent Application Publication No. JP 2003-114387
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`(ZEISS 1111); European Patent Application EP 1336 887 A1 (“Takahashi”)
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`(ZEISS 1114), which is an English republication of PCT Patent Publication
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`WO 02/035273 (“Takahashi PCT”) (ZEISS 1113); S. Asai et al., “Resolution Limit
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`for Optical Lithography Using Polarized Light Illumination,” Jpn. J. Appl., Phys.
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`Vol., 32, pp. 5863-5866 (1993) (“Asai”) (ZEISS 1114); U.S. Patent No. 5,825,043
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`(“Suwa”) (ZEISS 1123); W. Ulrich et al., “The Development of Dioptric
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`Projection Lenses for DUV Lithography,” Proc. SPIE Vol. 4832, pp. 158-169
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`(2002) (“Ulrich”) (ZEISS 1118); and U.S. Patent No., 4,346,164 (“Tabarelli”)
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`(ZEISS 1125). In arriving at my conclusions, I have also run calculations on some
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`of the optical designs disclosed in Mann, Takahashi, and Omura ‘387 using the
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`optical design software CODE V. CODE V sequence data and sub-routines used
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`for these calculations are provided in Exhibits ZEISS 1130 and ZEISS 1131
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`accompany this declaration.
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`12.
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`I note that cites to specific portions in the documents are only
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`exemplary.
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`13.
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`I also refer herein to the Claim Charts set forth as sections V(C),
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`V(E), and V(G) in the Petition, which also summarize at least some of my
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`conclusions below.
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`III. APPLICABLE LEGAL STANDARDS
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`14. Although I am not an attorney, and will not offer opinions on the law,
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`I have been informed of several principles concerning the patentability of claims in
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`a patent or application, which I have employed in arriving at my conclusions in this
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`declaration.
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`15.
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`I understand that when it comes to interpreting the scope of a claim,
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`the claim’s terms should be given their broadest reasonable interpretation
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`consistent with the specification and the prosecution history of the application or
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`patent. If the specification provides a definition of a claim term, the claim term
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`should be interpreted based on the definition.
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`16.
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`I understand that a patent claim is only valid if it is novel. I have been
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`informed that a patent is not novel if every element of the claimed invention is
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`present in a single prior art reference. I further understand that if every element of
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`a patent claim is found in a single prior art reference, the claim is invalid as
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`anticipated.
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`17.
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`I also understand that a patent claim is not valid if it is obvious. I
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`understand that a patent claim is obvious if the subject matter would have been
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`obvious to a person of ordinary skill in the art (POSITA) at the time the alleged
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`invention was made. I understand that the analysis of obviousness requires an
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`analysis of three factors: (1) a determination of the scope and content of the prior
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`art, (2) the level of ordinary skill in the art, and (3) the differences between the
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`prior art and the asserted claims.
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`18.
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`I have been informed that claims directed to a combination of familiar
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`elements according to known methods are invalid as obvious when the
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`combination does no more than yield predictable results. I understand that a
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`specific teaching, suggestion or motivation to combine elements in the prior art to
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`achieve the claimed combination is one way to demonstrate obviousness, but it is
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`not required for obviousness. For example, I understand that a combination of
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`known elements may be obvious in light of the interrelated teachings of the prior
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`art, the effects of demands known to the design community or present in the
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`marketplace, the background knowledge possessed by a POSITA, and inferences
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`and creative steps that a POSITA would employ.
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`19. Accordingly, I understand that a combination of known elements may
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`be obvious when there is a design need or market pressure to solve a problem and
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`there are a finite number of identified, predictable solutions known to a POSITA,
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`such that the combination would have been obvious to try.
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`20. Finally, I understand that claims may be obvious in light of
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`combinations of prior art, even if the prior art does not address the same problem
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`as that identified in the asserted patent.
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`IV. LEVEL OF ORDINARY SKILL IN THE ART
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`21. The Omura Patent is in the general technological field of projection
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`optical systems. More specifically, the Omura Patent relates to catadioptric
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`projection optical systems for use in microlithography exposure systems.
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`22. The POSITA at the time of the alleged invention of the Omura Patent
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`(i.e., during the time period from approximately 2003 through 2004) would
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`typically have had two or more years of post-graduate level education or
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`equivalent experience, with emphasis and experience in the field of optical design.
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`For example, the person would have had post-graduate level education in an
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`academic discipline such as physics or optics and experience using optical design
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`software, such as Zemax (commercially available from Radiant Zemax, LLC of
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`Redmond, WA) or CODE V (commercially available from Synopsys, Inc., Optical
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`Solution Group of Pasadena, CA). The POSITA during this time period would
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`have been able to use optical design software to determine a variety of properties
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`about an optical system from a lens prescription (i.e., the data providing the optical
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`properties and relative position of each element) for that optical system. For
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`example, the person would have been able to determine basic properties such as
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`the focal length, and hence optical power, of a series of surfaces in the optical
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`system, or the location of an intermediate image.
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`23. At the time of the alleged invention of the Omura Patent, the POSITA
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`would also have been able to optimize and/or re-optimize the performance of an
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`optical system using the optical design software by changing one or more
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`properties of one or more elements in the optical system. Performance metrics that
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`the design software would have been able to optimize include, for example, the
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`root-mean-square (RMS) of the wavefront error averaged over the field-of-view,
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`and the properties that the design software could have been directed to change
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`would have included, for example, radii of curvature, element thicknesses and
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`spacings, and aspheric coefficients. Moreover, the POSITA would have been able
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`to run such optimizations subject to various constraints on the optical system,
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`including, for example, magnification ratio, overall length, and element diameters.
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`24.
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`In arriving at my conclusions, I have considered the issues from the
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`perspective of this POSITA during the time period from approximately 2003
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`through 2004.
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`V.
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`TECHNICAL BACKGROUND
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`25. The Omura Patent describes “catadioptric projection optical systems,”
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`particularly for use in projection exposure apparatus in the field of
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`photolithography. Projection exposure apparatus are complex pieces of machinery
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`used, for example, for producing semiconductor devices. Generally, a projection
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`exposure apparatus serve to project an image of a pattern of a reticle onto a
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`substrate, which is typically a wafer coated with a photoresist (also referred as a
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`“photosensitive substrate”). In this field, the terms “reticle” and “mask” are used
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`interchangeably. Further processing of the exposed coating, such as developing
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`the exposed coating and depositing material over the developed coating or etching
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`material beneath the developed coating, allows one to transfer the pattern to a layer
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`of material on the substrate beneath the photosensitive coating. Repeating this
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`process along with various deposition and etch steps allows one to build up the tiny
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`complex components forming integrated circuits. (ZEISS 1101, 1:29-30, 6:23,
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`56:33-45; ZEISS 1114, [0033]-[0035], [0051]-[0054], [0239], [0240]; ZEISS 1110,
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`[0002]-[0003], ZEISS 1112, [0001]-[0002], [0048], [0057]; ZEISS 1127, pp. 1-2,
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`37-40.)
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`26. A projection exposure apparatus generally includes a number of
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`components including an illumination optical system, a projection optical system
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`(also referred as a “projection objective”), and a substrate positioning system.
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`(ZEISS 1101, 17:13-25, 18:33-54; ZEISS 1112, [0049], [0052], [0054]; ZEISS
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`1127, p. 2.) As an example, FIG. 1 (reproduced below) of the Omura Patent shows
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`a projection exposure apparatus EX including an illumination optical system IL, a
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`projection optical system PL, and a wafer stage WST, which is a substrate
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`positioning system.
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`27.
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`In connection with Fig. 1, the Omura Patent states that:
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`In Fig. 1, the exposure apparatus EX includes “a reticle stage RST
`supporting a reticle R (mask), a wafer stage WST supporting a wafer
`W as a substrate, an illumination optical system IL for illuminating
`the reticle R supported by the reticle stage RST, with exposure light
`EL, a projection optical system PL for performing a projection
`exposure of an image of a pattern on the reticle R illuminated with the
`exposure light EL, onto the wafer W supported by the wafer stage
`WST. (ZEISS 1101, 17:13-21.)
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`28. During operation, the illumination optical system IL illuminates the
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`pattern of the reticle R provided at the object surface of the projection optical
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`system PL. The projection optical system PL operates by imaging the pattern of
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`the reticle R provided at the object surface (“object plane”) of the projection
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`optical system PL onto the wafer W positioned at the image surface (“image
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`plane”) of the projection optical system PL. Usually, the object and image surfaces
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`are planar surfaces, and thus the term “object surface” can be used interchangeably
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`with the term “object plane” and the term “image surface” can be used
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`interchangeably with the term “image plane.” (ZEISS 1101, 17:13-21, 21:56-64;
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`ZEISS 1127, p. 26.)
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`29. Typically, the illumination system IL illuminates a portion of the
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`reticle to define the “illumination field” or the “object field.” The image of the
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`object field formed by the light beam formed at the image surface is referred as the
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`“image field.” (ZEISS ZEISS 1127, p.8.)
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`30. The wafer stage WST is used to support and position the wafer W
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`relative to the image surface. (ZEISS 1101, 18:34-39; ZEISS 1114, [0049],
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`[0054].)
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`31.
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`In general, a projection optical system is a compound optical system
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`made up of multiple optical elements that may include multiple lenses and/or
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`multiple mirrors. An example of a projection optical system is shown in FIG. 9 of
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`the Omura Patent, which is reproduced below. FIG. 9 depicts the paths of light
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`rays emerging from the object field through the optical elements that comprise the
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`projection optical system onto the image field. The lines annotated as “light rays”
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`indicate how the light passes through the projection optical system. The white
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`solid objects such as L2, L3, etc., are lenses. As light rays transmit through the
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`lenses, the lenses can be described as “transmitting elements.” The black solid
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`objects M1-M4 are mirrors. As the light reflects from the mirrors, the mirrors can
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`be described as “reflecting elements.” (ZEISS 1101, 29:27-37:14, Fig. 9.)
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`32. Figures such as FIG. 9, which may be referred as a “ray diagram”, can
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`provide much information of the projection optical system to a POSITA. For
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`example, the ray diagrams illustrate the curvatures of the respective lenses and
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`mirrors, the positions of the elements, the positions of the object field, image field,
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`intermediate image fields (if any), pupils, aperture stop; and the optical path of the
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`rays through the system. To demonstrate this, I have annotated FIG. 9 as shown
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`below. Similar information can be derived in the various figures in Mann,
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`Takahashi, and Omura ‘387.
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`33.
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`In FIG. 9, the projection optical system operates by imaging a reticle
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`R1 provided in an object plane of the projection optical system onto an image
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`plane of the projection optical system. The object surface may be referred as a
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`“first surface” and the image surface may be referred as a “second surface.”
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`(ZEISS 1101, 21: 56-64.) Multiple rays emerging from each of multiple points on
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`the reticle are recombined at each of corresponding points on the wafer W. The
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`multiple points on the reticle correspond to points on the object field. Each of the
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`corresponding points on the wafer W corresponds to points on the image field.
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`34.
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`In general, a projection optical system can include none, one, or
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`multiple intermediate images formed at intermediate locations between the reticle
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`and the wafer along the ray path. The intermediate images are formed at positions
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`where multiple light rays emerging from each of multiple points on the reticle are
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`recombined at each corresponding points. (ZEISS 1101, 21:56-64; ZEISS 1114,
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`[0061], ZEISS 1112, [0022]-[0024].)
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`35. As an example, FIG. 9 in the Omura Patent has one intermediate
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`image Io as annotated in reproduced FIG. 9 above. Multiple light rays emerging
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`from each of multiple points on the intermediate image Io are recombined at each
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`corresponding points on the final image. (ZEISS 1101, 21:56-64.)
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`36. The catadioptric projection system in FIG. 9 forms the intermediate
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`image Io and the final image using “imaging optical systems,” which are identified
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`as first imaging optical system G1 and second imaging optical system G2. The
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`first imaging optical system G1 images the reticle R to the intermediate image Io
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`and the second imaging optical system G2 images the intermediate image Io to
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`form the final image on the wafer W. (ZEISS 1101, 21:56-64.) The Omura Patent
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`explains that forming the intermediate image achieves “the optical path separation
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`between the beam toward the first surface and the beam toward the second surface,
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`even in the case where the numerical apertures of the catadioptric projection
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`optical systems are increased.” (ZEISS 1101, 12:7-14.) Furthermore, according to
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`the Omura Patent, “the total length of the catadioptric projection optical system can
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`be decreased and the adjustment for satisfying the Petzval’s condition can be
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`readily performed” by having a third unit that has negative optical power. (ZEISS
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`1101, 12:14-18.)
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`37.
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`I also note that other examples in the Omura Patent show FIGS. 5, 7,
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`10 having one intermediate image and FIGS. 14-16 having two intermediate
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`images. For example, in FIG. 5, the intermediate image Io is formed in the
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`approximate location of lens L21.
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 17 of 99
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`38. Various figures in Mann, Takahashi, and ‘387 Omura show one or
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`more intermediate images. For example, in section VII.A, I reproduced FIG. 2 in
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`Mann, showing one intermediate image. In section VII.B, I reproduced FIG. 6 in
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`Takahashi, which shows two intermediate images. Imaging systems can be
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`identified by image forming optical systems G1, G2, and G3. I also note that an
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`imaging system may include multiple imaging systems. For example, the
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`combined image forming optical systems G1 and G2 can be considered as a single
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`imaging system. (ZEISS 1101, 39:46-54.) In section VII.C, I reproduced FIG. 3
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`in Omura ‘387, which shows two intermediate images.
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`39. Generally, an optical element included in a projection optical system
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`can be a transmissive optical element (e.g., lens) or a reflective optical element
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`(e.g., mirror). (ZEISS 1118, pp. 15-20.) For instance, the example shown in FIG.
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`9 of the Omura Patent includes seventeen lenses L2-L18 and four mirrors, M1-M4,
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`which are referred as “transmitting members” and “reflecting members” with
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`optical power, respectively. (ZEISS 1101, 22:52-56) Consistent with this, in FIG.
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`9, the light rays transmit through lenses L2-L18 and reflect from mirrors M1-M4.
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`40. The catadioptric projection optical system in FIG. 9 of the Omura
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`Patent includes several types of lenses. For example, lens L3 is a “biconvex lens”
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`because it has two convex surfaces. Each surface of lens L31 is convex because
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 18 of 99
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`each surface is curved outwards from the body of lens L3. As another example,
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`lens L7 is a “biconcave lens” because it has two concave surfaces, where each
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`surface is curved inwards from the body of lens L7. Lens 4 is a “meniscus lens”
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`because it has one convex surface and one concave surface. Lens 18 is a
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`planoconvex lens because the surface facing towards the reticle R1 is a convex
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`surface and the other surface facing towards the wafer W is a planar surface.
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`(ZEISS 1101, 22:3-51, Table 5.)
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`41.
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`In FIG. 9 in the Omura Patent, mirror M1 is a concave mirror because
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`its reflecting surface is curved inward. Mirror M2 is a concave mirror because its
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`reflecting surface is curved outward. (ZEISS 1101, 22:3-26, Table 5.)
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`42.
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`I also note that the lenses and mirrors in FIGS. 5, 7, 10, 14-16 in the
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`Omura Patent as well as those in the various figures in Mann, Takahashi, and
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`Omura ‘387 can be identified in a similar manner.
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`43. Optical elements that focus or defocus light (e.g., cause light rays to
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`converge or diverge) are considered to have “refractive power” (also referred to as
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`“power,” “refracting power,” or “optical power”). Such focusing or defocusing
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`elements include curved mirrors (e.g., convex or concave mirrors) and lenses and
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`will hereinafter be referred as “imaging elements” because they focus or defocus
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`light. In general, a mirror having a convex surface defocuses parallel incident light
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 19 of 99
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`and is considered to have “negative refractive power.” Conversely, a mirror
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`having a concave surface focuses parallel incident light and is considered to have
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`“positive refractive power.” (ZEISS 1117.)
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`44. A surface of a lens has positive or negative refractive power
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`depending on how the surface focuses or defocuses incident light. A convex
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`surface of a lens focuses parallel light incident into the convex surface and is
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`considered to have “positive refractive power.” A concave surface of a lens
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`defocuses parallel light incident into the concave surface and is considered to have
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`“negative refractive power.” If a surface of a lens is flat, then that surface has no
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`refractive power. (ZEISS 1117.)
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`45. Lenses often have a spherical lens surface shape which is defined by a
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`radius of curvature. Such a surface may be described as “spherical.” On the other
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`hand, a surface of a lens may be described as “aspheric,” meaning the surface is
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`not purely spherical but is described mathematically as a deformation to a base
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`sphere. Aspheric surfaces are used to provide additional aberration correction in
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`the optical design process. A lens containing such an aspheric surface may be
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`referred to as an “aspheric lens” or simply as an “asphere.” Whether an aspheric
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`surface has positive or negative refractive power is generally determined by
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`whether the base radius is convex or concave. (ZEISS 1101, 11:52-57, 21:40-55,
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 20 of 99
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`22:3-51; ZEISS 1114, [0065]-[0066], [0088]-[0090]; ZEISS 1110, [0018]; ZEISS
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`1112, [0033], [0034], [0041].)
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`46. The refractive power of a lens is determined by the combined
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`refractive power of its surfaces. For example, a biconvex lens has positive
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`refractive power because each the surfaces is a convex surface with positive
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`refractive power. A biconcave lens has negative refractive power because each the
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`surfaces is a concave surface with negative refractive power. The refractive power
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`of a meniscus lens is positive or negative depending on the curvature of each
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`surface and the thickness of the lens.
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`47. A meniscus lens may have a convex surface and a concave surface
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`with the same curvature. The lens, however, still generally has a slight positive
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`refractive power which is linearly proportional to the center thickness of the lens.
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`48. A concave mirror focuses parallel light incident into the concave
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`surface and is considered to have “positive refractive power.” A convex mirror
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`defocuses parallel light incident into the convex surface and is considered to have
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`“negative refractive power.” In FIG. 9 of the Omura Patent, concave mirrors M1
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`and M3 have positive refractive power, and convex mirrors M2 and M4 have
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`negative refractive power.
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`ZEISS 1116
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 21 of 99
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`49. A collection of optical elements as a whole can be considered to have
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`positive or negative refractive power depending on how the collection as a whole
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`focuses or defocuses parallel incident light. For example, lens unit G23 in FIG. 9
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`of the Omura Patent has positive refractive power because it includes positive
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`lenses L12-L18. (ZEISS 1101, 30: 48-60.) Consistent with this, in connection to
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`FIG. 9, the Omura Patent states: “[A] lens unit with a positive refractive power
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`G23.” (ZEISS 1101, 29:48-49.)
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`50. As another example, lens unit G11 in FIG. 9 of the Omura Patent
`
`includes a plane-parallel plate L1, a negative lens L2, a biconvex lens L3, and a
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`positive meniscus lens L4. (ZEISS 1101, 29:56-62.) The Omura Patent describes
`
`that lens unit G11 has a positive refractive power. (ZEISS 1101, 29:39-42.)
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`51. According to my explanation, in FIG. 9 in the Omura Patent, L1 is a
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`plane-parallel plate, lenses L3, L9, L11 are each a biconvex lens having positive
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`refractive power, and lens L7 is a biconcave lens having negative refractive power.
`
`Also, lenses L4, L8, L10, L12-L17 are each a meniscus lens having positive
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`refractive power, and lenses L2, L5, L6 are each a meniscus lens having negative
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`refractive power. Lens L217 is a planoconvex lens having positive refractive
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`power. Mirrors M1 and M3 are each concave mirrors having positive refractive
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`power, and mirrors M2 and M4 are each convex mirrors having negative refractive
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 22 of 99
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`power. As a reference, I annotated FIG. 9 using the symbol “+” and “–“ to indicate
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`that the corresponding imaging element has positive or negative refractive power,
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`respectively.
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`52.
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`I also note that a lens having positive refractive power is referred as a
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`“positive lens.” Conversely, a lens having negative refractive power is referred as
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`a “negative lens.” (ZEISS 1008, [0179].) (ZEISS 1017.)
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`53. The path which the light rays follow may be referred as the “optical
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`path” in the projection optical system. For example, the light rays depicted in FIG.
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`9 in the Omura Patent follow an optical path starting from the reticle R1, through
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`plane-parallel plate L1, lenses L2-L5, reflected from mirror M1, through lens L5,
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`reflected from mirrors M2-M4, and then through lenses L6-L18, in the listed order.
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`Accordingly, mirror M1 is between lens L5 and mirror M2 in the optical path.
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`Mirror M2 is between mirrors M1 and M3 in the optical path. (ZEISS 1101, 7:60-
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`8:27.)
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`54. So, even though mirror M2 is positioned “physically” between lens
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`L4 and lens L5, mirror M2 is positioned “optically” between lens L5 and mirror
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`M3. (ZEISS 1101, 7:60-8:27.)
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`55. Lens L5 is an example of a “double optical path” element in that the
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`light rays pass through this element twice, a first time as the rays pass from L4 to
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 23 of 99
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`M1 and a second time as the rays pass from M1 to M2 (ZEISS 1101, 8:6-10, 12:
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`37-42, 34:7-12.) Other figures (e.g., FIGS. 5, 7, 10, 15) in the Omura Patent
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`include a double pass lens.
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`56. Typically, each optical surface in a projection optical system
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`corresponds to a mathematical surface that is rotationally symmetric about an axis,
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`which defines the “optical axis” for the optical surface. In some cases, the optical
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`axis for all optical surfaces in the projection optical system are the same. Such
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`designs are sometimes referred to as “inline” designs. In the example shown in
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`FIG. 9 in the Omura Patent (and reproduced above), the projection optical system
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`includes optical elements that share a single optical axis AX. (ZEISS 1101, FIG.
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`9.)
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`57.
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`In the case of mirrors, the optical surface can correspond to a segment
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`of the mathematical surface. Other projection optical systems shown in FIGS. 5, 7,
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`10, 14-16 in the Omura Patent also have a single optical axis. (ZEISS 1120;
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`ZEISS 1101, 5:52-69, 16:3-17.)
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`58.
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`I also note that the various figures in Mann, Takahashi, and Omura
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`‘387show catadioptric projection optical systems having a single optical axis.
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`(ZEISS 1114, [0038]; ZEISS 1110, [0046]; ZEISS 1112, [0025].)
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`Expert Declaration of Richard C. Juergens
`Petition for IPR of US 7,348,575
`Page 24 of 99
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`59.
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`In some designs, the image is formed in a region which does not
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`include the single optical axis of t
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