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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Attorney Docket No. EGQ-005CP3
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`PATENT
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`APPLICANTS:
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`Smith, Donald et al.
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`CONFIRMATION NO.:
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`9849
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`APPLICATION NO.:
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`13/024,027
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`GROUP NO.:
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`2881
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`FILING DATE:
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`February 9, 2011
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`EXAMINER 2
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`McCormack, Jason
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`TITLE:
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`LASER—DRIVEN LIGHT SOURCE
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`Commissioner for Patents
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`P.O. Box 1450
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`Alexandria, VA 22313-1450
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`RESPONSE TO NON-FINAL OFFICE ACTION
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`This paper is submitted in response to the Non-Final Office Action mailed from the
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`Patent Office on July 10, 2012 (“Office Action”). Applicants hereby request a one—month
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`extension of time, extending the due date for response to Monday, November 12, 2012. The
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`Commissioner is hereby authorized to charge the fee for the extension of time to Attorney’s
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`Deposit Account No. 50-3081. In the event any additional fees are due, the Commissioner is
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`hereby authorized to charge them to Attorney’s Deposit Account No. 50-3081.
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`Applicant respectfully requests entry of this Response, in Which:
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`Applicants’ Remarks begin on page 2.
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`ASML 1119
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`

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`Response to Non—Fina1 Office Action
`Application No.: 13/024,027
`Page 2 of 12
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`REMARKS
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`Claims 1-55 are currently pending. Claims 1-8 are elected and presented for
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`consideration. Claims 9-55 were previously withdrawn from consideration in response to the
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`Restriction Requirement of April 26, 2012.
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`In view of the following remarks, Applicants respectfully request reconsideration and
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`withdrawal of all grounds of objection and rejection.
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`1. Re'ections under 35 U.S.C.
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`112
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`The Office Action objects to claim 1 under 35 U.S.C. § 112 as being indefinite for failing
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`to particularly point out and distinctly claim the subject matter which Applicants regard as the
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`invention. The Office Action states that the term “high” in the phrase “high brightness light
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`source” is a relative term which renders the claim indefinite. Applicants respectfully disagree.
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`Applicants submit that one of ordinary skill in the art would reasonably understand the
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`term “high” in the phrase “high brightness light source” in view of Applicants’ specification. For
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`example, paragraphs [0003] — [0005] of Applicants’ published application no. 2011/0181191
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`(the “Present Application”) state “xenon or mercury arc lamps” are examples of “high
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`brightness” light sources and that the present application improves upon these lamps in creating
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`“high brightness light sources.” See Present Application at W [0003] — [0005]. Moreover,
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`Applicants further submit that one of ordinary skill in the art would reasonably understand the
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`term “high” in the phrase “high brightness light source” by virtue of Applicants’ recited uses, for
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`example, the light sources can be “used for inspection, testing or measuring properties associated
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`with semiconductor wafers or materials used in the fabrication of wafers (e. g., reticles and
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`

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`Response to Non-Final Office Action
`Application No.: 13/024,027
`Page 3 of 12
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`photomasks).” See Present Application at 1] [0003]. The high brightness light sources of the
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`Present Application can also be used in, for example, absorption cells, ultra-violet light detectors,
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`diode array detectors, and fluorescence detectors. See Present Application at W [013 l]-[0l34];
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`Figures 35-38. The specific parameters of the light “(e.g., wavelength, power level, and
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`brightness)” vary depending upon the specific application. These application-dependent
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`parameters are known to those of skill in the art. Applicants also describe high brightness light
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`as “light in the ultraviolet range” and “light in the visible range” used in arc lamps with solid
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`material bulbs “. .
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`. capable of sustaining high pressures and temperatures.” See Present
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`Application at ‘W [001 l], [0089], [0l8l], [0l43], and [00148],
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`Applicants’ descriptions of the phrase “high brightness light” throughout the Present
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`Application provide context for one skilled in the art to be reasonably apprised on the scope of
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`the invention. Based on the Present Application, Applicants respectfully submit that the term
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`“high” in the phrase “high brightness light” is not indefinite. Accordingly, Applicants
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`respectfully request reconsideration and withdrawal of the objection to claim 1.
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`2. Rejections under 35 U.S.C. § 102
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`The Office Action rejects claims 1-8 under 35 U.S.C. § 102 as allegedly being anticipated
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`by U.S. Publication No. 2006/03 9435 to Cheymol (“Cheymol”) and separately rejects claims l-8
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`under 35 U.S.C. § 102 as allegedly being anticipated by U.S. Publication No. 2002/0080834 to
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`Kusunose (“Kusunose”). Of these, claim 1 is independent. For a rejection under 35 U.S.C. §l02
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`to be proper, each reference by itself must disclose each and every element in the claim.
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`

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`Response to Non—Final Office Action
`Application No.: 13/024,027
`Page 4 of 12
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`Applicants respectfully submit that neither Cheymol nor Kusunose disclose each and every
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`element of Applicants’ claims.
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`a. Re'ections under 35 U.S.C.
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`102 — Chevmol
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`Applicants respectfully submit that Cheymol does not disclose each and every element of
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`Applicants’ claims, at least because Cheymol fails to disclose each of the following elements of
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`Applicants’ independent claim 1:
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`(l)
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`(2)
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`“a chamber having a gas disposed therein .
`light,” and
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`.
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`. to produce a high brightness
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`an “ignition source for exciting the gas, the excited gas having at least one
`strong absorption line at an infrared wavelengt
`.”
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`Applicants’ invention features a “light source for generating a high brightness light.”
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`Present Application at 1] [OOO8]. The light source is started by making the “absorption of the
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`laser light by the gas within the chamber ... strong enough to provide sufficient energy to the gas
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`to form a dense plasma. Id. at ll [O232]. “However, during operation, the same absorption that
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`was used to start the [laser-driven light source] LDLS can be too strong to maintain the
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`brightness of the light.” ld. This can create an imbalance between the “absorption needed to
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`start a LDLS and the absorption needed to maintain or operate the LDLS.” Id.
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`To correct the imbalance, the light source of the present invention has a “laser [that] is
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`first tuned to a wavelength nearer the absorption line and then tuned to another wavelength
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`further away from the strong absorption line for optimum operation.” Present Application at
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`1] [0232]. “The light source can use an excited gas that has at least one strong absorption line at
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`an infrared wavelength to produce a high brightness light,” for example, xenon. Id. at 11 [023 3].
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`“An ignition source 140 can be used to excite the gas within the chamber.” Id. “The excited gas
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`

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`Response to Non—Final Office Action
`Application N0.: 13/024,027
`Page 5 of 12
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`has electrons at an energy level that is higher than the energy of the gas at its ground state.” Id.
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`“The excited gas has at least one strong absorption line at an infrared wavelength, for example at
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`about 980 nm, 895 nm, 882 nm, or 823 nm.” Id. A laser can then provide energy “to the excited
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`gas within the chamber 128 to produce a high brightness light.” Id.
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`(1) “a chamber having a gas disposed therein .
`brightness light”
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`.
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`. to produce a high
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`Cheymol fails to disclose “a chamber having a gas disposed therein .
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`.
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`. to produce a high
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`brightness light” as recited in Applicants’ independent claim 1. In contrast to the high brightness
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`light (e.g., light in the ultraviolet and visible ranges) of Applicants’ invention, Cheymol describes
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`light sources of extreme ultraviolet, i.e. EUV, which are very short wavelengths at high energy
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`radiation. Specifically, Cheymol describes a device for “. .
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`. generating light in the extreme
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`ultraviolet, and to its application to a source for lithography using radiation in the extreme
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`ultraviolet .
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`.
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`.
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`. also referred to more simply as ‘EUV’ radiation.” See Cheymol at 1] [0001]-
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`[0002] (italics added); see also id. at [0013]. Cheymol’s light source seeks to “. .
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`. enable a
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`plurality of laser beams to be used simultaneously to increase strongly the incident laser power
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`while conserving a device that is effective in collecting EUV radiation .
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`.
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`.
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`. Id. at fll [0014]
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`(italics added.; The EUV wavelength typically covers the “. .
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`. radiation in the extreme
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`ultraviolet domain .
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`.
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`. wavelengths lying in the range 1 nanometer (mn) to 15 mn .
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`.
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`. .”. Id. at
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`ll [0002]. The EUV light of Cheymol is not the high brightness light of Applicants’ invention.
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`In View of the foregoing, Applicants respectfully submit that Cheymol fails to disclose
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`each and every element of Applicants’ independent claim 1, at least because Cheymol fails to
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`disclose “a chamber having a gas disposed therein .
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`.
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`. to produce a high brightness light.”
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`

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`Response to Non-Final Office Action
`Application No.: 13/024,027
`Page 6 of 12
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`Therefore, Applicants’ respectfully request reconsideration and withdraw of the rejection of this
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`claim under 35 U.S.C. § 102 in view of Cheymol. Furthermore, Applicants respectfully submit
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`that claims 2-8 are also allowable as each depends from an allowable independent claim.
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`(2) an “ignition source for exciting the gas, the excited gas having at least
`one strong absorption line at an infrared wavelengt ”
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`Cheymol also fails to describe an “ignition source for exciting the gas, the excited gas
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`having at least one strong absorption line at an infrared wavelength” as recited in Applicants’
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`independent claim 1. Applicants’ invention uses an ignition source for exciting a gas. The
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`excited gas has “. .
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`. at least one strong absorption line at an infrared wavelength .
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`.
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`. .” See
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`Present Application at claim 1. Noble gases, such as xenon, “can be transparent in the visible
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`and near infrared range of the spectrum, but this is not the case when the gas is at high
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`temperature or in the presence of excited molecular states, such as excimers.” Id. at 1] [0237]. A
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`gas like xenon in an excited state, even its lowest excited state, results in “the appearance of
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`strong absorption lines due to transitions between the relatively high energy state and any of the
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`several higher level states.” Id. at W [023 7]-[023 8]. When an electron moves between two
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`levels, a photon can be emitted or absorbed, e.g. a 980 nm photon.” Id. An example of an
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`absorption line in xenon is “about 980 rim and about 882 nm .
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`.
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`. .” Id. atjl [023 9]. Such
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`absorption lines do not exist in the unexcited gas. See id. at 1] [0240].
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`The light source of Cheymol emits “a plasma emitting radiation in the extreme
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`ultraviolet.” Cheymol at Abstract. The light source has an injector device “to create a
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`filamentary jet or a liquid microj et or a jet of individual droplets
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`constituting a target.” Id. at
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`jl [0052]. Laser beams are focused onto the target. Id. at 1[ [0053]. The “resulting emission 7
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`

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`Response to Non-Final Office Action
`Application No.: 13/024,027
`Page 7 of 12
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`can differ depending on whether each individual laser beam illuminates the target 4 sufficiently
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`to produce EUV, or whether it is only the superposition of a plurality of laser beams that makes it
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`possible to obtain optimum illumination for EUV emission.” Id. at 1] [U058].
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`Unlike Applicants’ claimed invention, the light source of Cheymol lacks an ignition
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`source for exciting a gas. The light source of Cheymol has an injector device to create a “jet” or
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`“liquid microjet” or “individual droplets,” which are not a gas as recited in Applicants’ claims.
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`Moreover, Cheymol does not excite a gas using an ignition source. As stated above, the excited
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`gas of Applicants’ invention has at least one strong absorption line at an infrared wavelength,
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`which, when ignited, generates a high brightness light at startup. The laser can then be tuned to
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`another wavelength further away from the strong absorption line for optimum operation.
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`Therefore, Cheymol lacks an “ignition source for exciting the gas, the excited gas having at least
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`one strong absorption line at an infrared wavelength” as recited in Applicants’ independent claim
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`1.
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`In view of the foregoing, Applicants respectfully submit that Cheymol fails to disclose
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`each and every element of Applicants’ independent claim 1 at least because Cheymol fails to
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`disclose an “ignition source for exciting the gas, the excited gas having at least one strong
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`absorption line at an infrared wavelength.” Therefore, Applicants respectfully request
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`reconsideration and withdraw of the rejection of this claim under 35 U.S.C. § 102 in view of
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`Cheymol. Furthermore, Applicants respectfully submit that claims 2-8 are also allowable as each
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`depends from an allowable independent claim.
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`b. Re'ecti0ns under 35 U.S.C.
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`102 — Kusunose
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`

`
`Response to Non—Final Office Action
`Application No.: 13/024,027
`Page 8 of 12
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`Applicants respectfully submit that Kusunose does not disclose each and every element of
`
`Applicants’ claims, at least because Kusunose fails to disclose each of the following elements of
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`Applicants’ independent claim 1:
`
`(1)
`
`“a chamber having a gas disposed therein .
`light,” and
`
`.
`
`. to produce a high brightness
`
`(2)
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`an “ignition source for exciting the gas, the excited gas having at least one
`
`strong absorption line at an infrared wavelength.”
`
`As discussed above, Applicants’ invention features a “light source for generating a high
`
`brightness light.” Present Application at 1] [OOO8]. To correct the imbalance between the
`
`“absorption needed to start a LDLS and the absorption needed to maintain or operate the LDLS,”
`
`the light source of the present invention has a “laser [that] is first tuned to a wavelength nearer
`
`the absorption line and then tuned to another wavelength further away from the strong absorption
`
`line for optimum operation.” Id. at 1] [O232]. “The light source can use an excited gas that has at
`
`least one strong absorption line at an infrared wavelength to produce a high brightness light,” for
`
`example, xenon.
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`Id. at 1] [O233]. “The excited gas has electrons at an energy level that is higher
`
`than the energy of the gas at its ground state.” Id. at 1] [023 3]. “The excited gas has at least one
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`strong absorption line at an infrared wavelength, for example at about 980 nm, 895 nm, 882 nm,
`
`or 823 nm.” Id. A laser can then provide energy “to the excited gas within the chamber 128 to
`
`produce a high brightness light.” Id.
`
`(1) “a chamber having a gas disposed therein .
`brightness light”
`
`.
`
`. to produce a high
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`

`
`Response to Non-Final Office Action
`Application No.: 13/024,027
`Page 9 of 12
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`Kusunose fails to disclose “a chamber having a gas disposed therein .
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`.
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`. to produce a high
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`brightness light” as recited in Applicants’ independent claim 1. In contrast to the high brightness
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`light (e.g., light in the ultraviolet and visible ranges) of Applicants’ invention, Kusunose
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`describes EUV light sources, similar to Cheymol, which are very short wavelengths at high
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`energy radiation. Specifically, Kusunose describes a light source device having a high pulse rate
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`capable of “emitting a high—Zuminance radiation pulse.” Kusunose at 11 [0001] (italics added);
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`see also id. at 1] [0021] (“radiation light”). Kusunose’s device generates “.
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`.
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`. ultraviolet light or
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`an X ray having .
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`.
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`. a wavelength band of EUV or UVU of which wavelength is about 13 nm. .
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`.
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`.
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`[where] the ultraviolet light or X ray subj ected to wavelength conversion is utilized as useful
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`radiation light.” Id. at 1] [0027]. The EUV light of Kusunose is not the high brightness light of
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`Applicants’ invention.
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`In view of the foregoing, Applicants respectfully submit that Kusunose fails to disclose
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`each and every element of Applicants’ independent claim 1, at least because Kusunose fails to
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`disclose “a chamber having a gas disposed therein .
`
`.
`
`. to produce a high brightness light.”
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`Therefore, Applicants’ respectfully request reconsideration and withdraw of the rejection of this
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`claim under 35 U.S.C. § 102 in view of Kusunose. Furthermore, Applicants respectfully submit
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`that claims 2-8 are also allowable as each depends from an allowable independent claim.
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`(2) an “ignition source for exciting the gas, the excited gas having at least
`one strong absorption line at an infrared wavelength ”
`
`Kusunose also fails to describe an “ignition source for exciting the gas, the excited gas
`
`having at least one strong absorption line at an infrared wavelength” as recited in Applicants’
`
`independent claim 1. As discussed above, Applicants’ invention uses an ignition source for
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`

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`Response to Non—Final Office Action
`Application No.: 13/024,027
`Page 10 of 12
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`exciting a gas. The excited gas has “. .
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`. at least one strong absorption line at an infrared
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`wavelength .
`
`.
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`. .” See Present Application at claim 1. An example of an absorption line in
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`xenon is “about 980 nm and about 882 nm .
`
`.
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`. .” ld. atfl [0239]. Such absorption lines do not
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`exist in the unexcited gas. See id. at 1] [0240].
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`Unlike Applicants’ claimed invention, the light source of Kusunose lacks an ignition
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`source for exciting a gas. The light source of Kusunose has “a high pulse rate and [is] capable of
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`emitting a high-luminance radiation pulse.” Kusunose at 1] [0002]. Multiple light sources (e. g.,
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`eight) are used along with a “rotating reflection body.” Id. at 1] [0020]. “The radiation light
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`emitted from each of the light sources
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`is incident onto a reflection surface 2a of the rotating
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`reflection body 2.” Id. at 1] [002l]. “The radiation light incident onto the rotating reflection body
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`2 is reflected by the reflection surface, is emitted along optical path L common to the respective
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`light sources, and used for the various kinds of processing.” Id. at 1] [0022]. The radiation light
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`emitted from the light sources and reflected along a path, is not an ignition source for igniting a
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`gas as recited in Applicants’ independent claim 1.
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`In view of the foregoing, Applicants respectfully submit that Kusunose fails to disclose
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`each and every element of Applicants’ independent claim 1 at least because Kusunose fails to
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`disclose “ignition source for exciting the gas, the excited gas having at least one strong
`
`absorption line at an infrared wavelength.” Therefore, Applicants respectfully request
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`reconsideration and withdraw of the rejection of this claim under 35 U.S.C. § 102 in view of
`
`Kusunose. Furthermore, Applicants respectfully submit that claims 2-8 are also allowable as
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`each depends from an allowable independent claim.
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`

`
`Response to Non-Final Office Action
`Application No.: 13/024,027
`Page 11 of 12
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`Dependent claims 6 & 7
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`Regarding dependent claims 6 and 7, the Office Action states that Radiometric
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`Characterization of Ultrahigh Radiance Xenon Short—arc Discharge Lamps, Nakar et al.
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`(“Nakar”) “specifies that the prominent absorption lines of xenon occur at 823, 882, and 992
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`nm.” See Office Action p. 3. Applicants submit that Nakar also fails to disclose each and every
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`element of claim 6 or 7 at least because Nakar fails to disclose (1) “a chamber having a gas
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`disposed therein .
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`.
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`. to produce a high brightness light” and (2) an “ignition source for exciting
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`the gas.
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`In View of the Applicants respectfully request reconsideration and withdraw of the
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`rejection of these claims under 35 U.S.C. § 102.
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`

`
`Response to Non-Final Office Action
`Application No.: 13/024,027
`Page 12 of 12
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`CONCLUSION
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`Applicants request that the Examiner reconsider the application and claims in light of the
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`foregoing remarks, and respectfully submits that the claims are in condition for allowance. The
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`Examiner is invited to call the undersigned at the number below to discuss the application.
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`Date: November 8, 2012
`Reg. No.: 62,751
`Tel. No.: (617) 526-9870
`Fax No.: (617) 526-9899
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`Respectfully submitted,
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`5
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`fig gag;
`
`Rebecca N. Barne /
`Attorney for the Applicants
`Proskauer Rose LLP
`One International Place
`Boston, MA 02110-2600
`
`2560/26045-O12 current/32682381v5