Prosecution Insights
Last updated: October 22, 2026
Application No. 17/855,550

EUV LIGHT SOURCE AND APPARATUS FOR LITHOGRAPHY

Non-Final OA §103§112
Filed
Jun 30, 2022
Priority
Jun 29, 2018 — provisional 62/692,211 +1 more
Examiner
LOGIE, MICHAEL J
Art Unit
2881
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Taiwan Semiconductor Manufacturing Company, Ltd.
OA Round
9 (Non-Final)
63%
Grant Probability
Moderate
9-10
OA Rounds
0m
Est. Remaining
73%
With Interview

Examiner Intelligence

Grants 63% of resolved cases
63%
Career Allowance Rate
512 granted / 811 resolved
-4.9% vs TC avg
Moderate +10% lift
Without
With
+9.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
50 currently pending
Career history
871
Total Applications
across all art units

Statute-Specific Performance

§101
1.8%
-38.2% vs TC avg
§103
46.4%
+6.4% vs TC avg
§102
24.3%
-15.7% vs TC avg
§112
25.5%
-14.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 811 resolved cases

Office Action

§103 §112
DETAILED ACTION Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 10 September 2026 has been entered. Response to Arguments Applicant's arguments filed 10 September 2026 have been fully considered but they are not persuasive. Rejections under 35 USC § 103 The remarks take the position that the prior art fails to disclose the amended subject matter. This has not been found persuasive. Initially the claim is written as an apparatus configured to “provide a first source gas to generate the ICP for removing debris on the rotatable debris collection device, and switch from the first source gas to a second source gas to form a passivation layer on surfaces of at least the collector mirror and the rotatable debris collection device in the chamber.” However, the function does not follow the structure of the device, therefore the amended limitations are indefinite as discussed below. Moreover, the remarks point to support in paragraphs [0049]-[0050]. In particular paragraph [0050] recites: “In other embodiments, in the idle mode, after the plasma to remove the tin debris is generated and the tin debris is removed, the source gas is changed from a Cl containing gas to a Zr containing gas and/or a Si containing gas. Thus, a passivation layer made of ZrO.sub.2 and/or SiO.sub.2 is formed over cleaned surfaces of the parts inside the vacuum chamber of an EUV radiation source. In some embodiments, deposition of the passivation layer and etching by plasma are repeated.” Claim 1 requires “a second gas inlet for providing a source gas including one or more of SiH4, SiCl4, SiH2Cl2, and Zr(OC(CH3)3)4, for the ICP” Therefore claim 1 is further lacks written description because the instant specification teaches that it is not the Zr or Si containing gas for ICP, but rather the Cl containing gas, whereas the Zr or Si containing gas is for forming the passivation layer. With regards to the structure, it is apparent that since the claim requires the first and second gas inlets to provide a source gas, it is the first and second gas inlets that is structure to provide for the claimed subject matter (i.e. providing the first source gas and switch from the first source gas to a second source gas). Since there is no actual requirement for a first gas source coupled to the first/second gas inlets, nor a second gas source that is interchangeably coupled to the first/second gas inlets, the only requirement is that there is first and second gas inlets. As discussed previously, Derra teaches generating inductively coupled discharge instead of heat ([0021] teaches ICP having coils arranged at the same positions as the heatable elements); a first gas inlet (fig. 10 shows gas inlet 10) for providing a source gas including one or more of Sih4 and Zr(OC(CH3)3)4 containing gas (gas inlet passage inherently provides a source gas. Since the claim is written as the function of the gas inlet for providing Si or Zr containing gas, the gas inlet of Derra is capable of providing any gas, since it is merely an opening to receive a gas1. Similarly, Baek teaches the second gas inlet2. Therefore, since the structure was known, providing a first source gas to the first/second inlets and switching to a second gas source is a manner of operating the device and insufficient to distinguish the claimed invention over the prior art (MPEP 2114(II)). In response to applicant's argument that the examiner's conclusion of obviousness is based upon improper hindsight reasoning, it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin, 443 F.2d 1392, 170 USPQ 209 (CCPA 1971). Here the remarks take the position that there is no reasoning to combine Baek with the other references. This has not been found persuasive. As discussed on pages 15-16 of the last office action, Baek modifies the combined device by suggesting an induction coil around the perimeter of the collector. Since both devices are directed towards debris mitigation, it would have been obvious to one of ordinary skill in the art to incorporate the induction coil with the collector as suggested by Baek because it would allow for in situ cleaning of not only the EUV vessel but also the EUV collector simultaneously, therefore not requiring interruption of EUV generation to clean the EUV collector. That is, the additional cleaning coil of Baek would improve the cleaning ability of the combined device by extending the cleaning to the EUV collector in addition to the debris mitigation vanes, and the lower cone of the combined device. Moreover, as recognized by Baek “In situ cleaning provides the capability of cleaning of EUV collector and EUV vessel simultaneously with generating EUV light. In situ cleaning allows the EUV generation operation is not required to be interrupted for cleaning the EUV collector and the EUV vessel” ([0006]). Therefore, the additional coils would allow for cleaning of the collector cleaning without interrupting the device, therefore improving throughput of the EUV light generation. Additionally, it is noted that the rationale for the combination is taken only from the references, therefore since only the knowledge of the art is relied upon and no information is gleaned from the applicant’s specification, the reconstruction of the claim is proper. The remarks take the position that there is no teaching or suggestion of the specific spatial arrangement of the first coil on the debris collector, a second coil on the lower cone and a third coil in the collector mirror. This is clearly not true, as discussed in the last office action, Damen teaches at least one first coil covering the debris collection device (figs. 6 or 7 showing coils on vanes that collect debris), modified by Xia et al. which teaches a [[second]] coil covering a cone (figs. 9a-9B showing cone 512_9 covered and surrounded by coil 560_9), modified by Baek which teaches a [[third]] coil on the collector mirror (figures 8-9, coil is on the collector mirror (i.e. as in the specification a space between mirror and coil), see paragraph [0076] teaching inductive coil 804 disposed between nozzles and rim 30b of collector 30). In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). Here, since the combination of references would be obvious as evident by each rationale, the combination suggests that three coils at the claimed locations would have been obvious to one of ordinary skill in the art. Lastly, the remarks argue unexpected results. Initially, there is no disclosure that the combination of coils unexpectedly resulted in optimization and controllable plasma distribution. Indeed the instant specification has no suggestion of anything unexpected occurring, as evident by the fact that “unexpected” is not used. Moreover, MPEP 716.02 (b) recites: “The evidence relied upon should establish "that the differences in results are in fact unexpected and unobvious and of both statistical and practical significance." Ex parte Gelles, 22 USPQ2d 1318, 1319 (Bd. Pat. App. & Inter. 1992) (Mere conclusions in appellants’ brief that the claimed polymer had an unexpectedly increased impact strength "are not entitled to the weight of conclusions accompanying the evidence, either in the specification or in a declaration."); Ex parte C, 27 USPQ2d 1492 (Bd. Pat. App. & Inter. 1992)” Here, the remarks merely allege unexpected results without any evidence either in the specification or in a declaration that indeed the results would be unexpected. It appears from the applicant’s specification that the optimization and controlling of the plasma are the advantages of the claimed invention. MPEP 2144 (IV) recites: “The reason or motivation to modify the reference may often suggest what the inventor has done, but for a different purpose or to solve a different problem. It is not necessary that the prior art suggest the combination to achieve the same advantage or result discovered by applicant. See, e.g., In re Kahn, 441 F.3d 977, 987, 78 USPQ2d 1329, 1336 (Fed. Cir. 2006) ” As evident from the combination, there are different rationales for achieving the specific EUV light source arrangement. Therefore, as the evidence has shown that each element was known to the art and rationale has been established for the combination, even if the rationale is for a different purpose does not alter the conclusion that the combination would have been obvious for the reasons discussed herein below. Therefore, the remarks are unpersuasive and the rejection stands as reiterated herein below. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1-3, 9-13, 15, 21-22, 25-32 and 34 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Claim 1 lacks written description for “a first gas inlet and a second gas inlet for providing a source gas including one or more of SiH4, SiCl4, SiH2Cl2, and Zr(oC(CH3)3)4 for the ICP”. Specifically, as pointed out by the applicant’s remarks these chemicals are not disclosed for the ICP, but rather for generating a passivation layer on cleaned surfaces ([0050]). This is further supported by paragraph [0047]. That is, it is the Cl or Si containing gas that is “for” or generates the ICP, not the one or more of SiH4, SiCl4, SiH2Cl2, and Zr(oC(CH3)3)4. These gases are only disclosed to be for generating a passivation layer. There is no suggestion that “SiH4, SiCl4, SiH2Cl2, and Zr(oC(CH3)3)4” are for ICP, but rather for formation for a passivation layer ([0050]). Independent claims 12 and 21 require commensurate limitations that fail to meet the written description requirement for the same reasons above. All dependent claims fail to meet the written description requirement by virtue of their dependencies on rejected independent claims 1, 12 and 21. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-3, 9-13, 15, 21-22, 25-32 and 34 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 1 is vague and indefinite for reciting “a first gas inlet and a second gas inlet for providing a source gas including one or more of SiH4, SiCl4, SiH2Cl2, and Zr(oC(CH3)3)4 for the ICP… provide a first source gas to generate the ICP for removing debris on the rotatable debris collection device, and switch from the first source gas to a second source gas to form a passivation layer on surfaces of at least the collector mirror and the rotatable debris collection device in the chamber.” Specifically, it is not clear whether the claimed “first source gas” to generate the ICP is the same as the claimed “source gas” “for ICP” or if this is a separate gas. From the instant specification ([0050]), it appears that the source gas for ICP is actually Cl or Si containing gas, whereas the source gas for passivation is the claimed “source gas”. Therefore, the claim appears to contradict the instant specification by claiming the “one or more of SiH4, SiCl4, SiH2Cl2, and Zr(oC(CH3)3)4 for the ICP”. Because these compositions are disclosed for forming a passivation layer not to generate ICP. For the purposes of examination as the claim limitations do not particularly limit the structure of the device, the limitations are treated as merely the first and second gas inlets, which were known to the art discussed below and are capable of supplying different gases to achieve the claimed results (i.e. by supplying a gas to generate ICP or supplying a gas to form a passivation layer). Claim 1 recites the limitation “provide a first source gas to generate the ICP for removing debris on the rotatable debris collection device, and switch from the first source gas to a second source gas to form a passivation layer on surfaces of at least the collector mirror and the rotatable debris collection device in the chamber” is vague and indefinite because the claim does not provide a discernable boundary on what performs the function. The recited function does not follow from the structure recited in the claim i.e. gas inlets so it is unclear whether the function requires some other structure or is simply a result of operating the gas inlets in a certain manner. Thus, one of ordinary skill in the art would not be able to draw a clear boundary between what is and is not covered by the claim. See MPEP 2173.05(g) for more information. Independent claims 12 and 21 require commensurate limitations that fail to meet the definite requirement for the same reasons above. All dependent claims fail to meet the written description requirement by virtue of their dependencies on rejected independent claims 1, 12 and 21. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-3, 9, 12-13, 15 and 34 are rejected under 35 U.S.C. 103 as being unpatentable over Damen (WO2014/121873) (copy of publication submitted herewith) in view of Derra et al. (US pgPub 2010/0051827) in view of Zhao et al. (US pgPub 2016/0209753) and further in view of Xia (US pgPub 2021/0063899) or alternatively, Bykanov et al. (US pgPub 2009/0154642) and further in view of Baek et al. (US pgPub 2017/0215265). Alternatively, claims 1-3, 9, 12, 15 and 34 are rejected under 35 U.S.C. 103 as being unpatentable over Damen (WO2014/121873) (copy of publication submitted herewith) in view of Derra et al. (US pgPub 2010/0051827) in view of Zhao et al. (US pgPub 2016/0209753) (second interpretation of Zhoa) and further in view of Labetski et al. (WO2018127565) and further in view of Xia and further in view Baek and further in view of Banna. Regarding claim 1, Damen teaches an extreme ultra violet (EUV) radiation source apparatus (fig. 3), comprising: a collector mirror (50); a target droplet generator (71) for generating a tin (Sn) droplet ([0032]); a debris collection device (304, see paragraph [0040]); coils (fig 6 or fig 7 showing coils 524); a chamber (47) enclosing at least the collector mirror and the debris collection device (47 encloses 50 and 304), wherein the coils are configured such that the heat is spaced apart from the collector mirror (heat generated at vanes 304 thus spaced from collector mirror 50) the coils include at least one first coil covering the debris collection device (figs. 6 or 7 showing coils on vanes that collect debris). Damen teaches inductive heating to remove tin deposits from vanes, thus fails to disclose generating plasma; a gas inlet for providing a source gas including one or more of Si containing gas and Zr containing gas, for ICP. However, Derra teaches generating inductively coupled discharge instead of heat ([0021] teaches ICP having coils arranged at the same positions as the heatable elements); a first gas inlet (fig. 10 shows gas inlet 10) for providing a source gas including one or more of Sih4 and Zr(OC(CH3)3)4 containing gas (gas inlet passage inherently provides a source gas. Since the claim is written as the function of the gas inlet for providing Si or Zr containing gas, the gas inlet of Derra is capable of providing any gas, since it is merely an opening to receive a gas3), for ICP ([0018] teaches gases passing over hot surfaces to generate radicals, which may be replaced ICP ([0021]), thus for ICP), wherein the gas inlet and the one or more coils are configured such that the ICP is spaced apart from the collector mirror (as seen in figure 10 when substituted for ICP coils disclosed in paragraph [0021]). Derra modifies Damen by suggesting ICP as an alternative to heat to remove tin deposits. Since both inventions are directed towards heating elements of an EUV source to remove contamination, it would have been obvious to one of ordinary skill in the art to substitute the heatable elements of Demon for the ICP coils of Derra because it would lead to the predictable results of generating radical such that a higher lifetime of the optical components can be achieved ([0015], 0017 and [0021]). Moreover, the substitution would result in the ICP plasma being spaced apart from the collector 50 of Damen. The combined device fails to disclose a lower cone provided between the rotatable debris collection device and an EUV output port; wherein the first gas inlet is located at a position between the lower cone and the EUV output port; a gas outlet for exhausting the source gas located between the lower cone and the rotatable debris collection device. However, Zhoa teaches a lower cone (fig. 19, 95) provided between the rotatable debris collection device (6) and an EUV output port (outside of 4221); wherein the first gas inlet (fig. 20, 111 and paragraph [0108]) is located at a position between the lower cone and the EUV output port (see discussion in response to arguments in the final rejection of 10/07/2024) a gas outlet (fig. 19 drain in 91 is an outlet for fuel debris ([0105]), therefore any gas that is not evacuated by 112 may also exit via the drain 91) for exhausting (the drain in 91 is suitable for exhausting both fuel debris and gas) the source gas located between the lower cone and the rotatable debris collection device (91 is between 95 and 6, thus the drain is also between 95 and 6) and a rotatable collection device (fig. 4, fan 6 including blades 41, see paragraphs [0071]-[0072], note similar to Damen the blades may have attached heating elements see paragraph [0083]) such that the first gas inlet is configured to inject the source gas to generate a first gas flow in a first direction towards the gas outlet (See annotated figure 20 of Zhoa below: PNG media_image1.png 719 1001 media_image1.png Greyscale Wherein the gas outlet is shown in figure 19 as drain in 91 which is an outlet for fuel debris ([0105]), therefore any gas that is not evacuated by 112 may also exit via the drain 91). Zhoa modifies the combined device by suggesting rotation of the debris collection device and a gas inlet between the exit cone and EUV outlet. Since both inventions are directed towards debris traps in an EUV light source, it would have been obvious to one of ordinary skill in the art to adopt the trap of Damon to be rotatable as suggested in Zhoa because the fan in conjunction with inlet and either interpretation of the outlet generates “ a gas flow away from the optical axis of the source module, pump gas, guide or collect particles, reduce or prevent contamination from spitting particles, and reduce or prevent gas flow towards the collector” ([0071]) therefore reduces contamination by the debris to the system by ensuring that a recirculating or back flow does not arise and gas flow from the vicinity of the collector is directed away ([0071]). Moreover, the dynamic gas lock 110 (including 111) near effectively prevents particles from exiting the exit aperture ([0110]) therefore reducing contamination to components downstream of the exit aperture. While Zhoa teaches a lower cone 95, the combined device further fails to disclose at least one second coil on the lower cone. However, Xia et al. teach a coil covering a cone (figs. 9a-9B showing cone 512_9 covered and surrounded by coil 560_9). Xia modifies the combined device by suggesting plasma cleaning of interior surface. Since both inventions are directed towards cones, it would have been obvious to one of ordinary skill in the art prior to the claimed invention to add the coils to the lower cone of Zhoa because it would create plasma particles at the location next to the exposed interior surface of the line to ensure high removal rate of debris on the surface of the liner. It is noted that because Deman teaches coils located on the debris mitigation device and Zhoa teaches a lower cone with the outlet between the lower cone and the debris mitigation device and Xia suggests placing coils covering or surrounding the lower cone of Zhoa, the evidence suggests that such a combination would also result in positioning the gas outlet between the first coils and the second coil. That is, the modification does not change the position of the outlet between the debris mitigation device and the lower cone, it only adds a coil to the lower cone of Zhoa resulting in the claimed limitation. Alternatively to Xia, Bykanov et al. teaches at least one second coil covering or surrounding the lower cone (Figure 7 shows an embodiment of 1014B which has ICP coils 1070 ([0111]) around the conical structure 1022 (i.e. the lower cone)). Bykanov et al. modifies the Damen in view of Derra et al. in view of Zhao et al. by suggesting ICP coils around the lower cone. Since both inventions are directed towards debris mitigation via ICP coils, it would have been obvious to one of ordinary skill in the art to provide the coils of Bykanov et al. to the lower cone of Damen as modified by Derra as modified by Zhoa as suggested in Bykanov et al. because the plasma may reduce flow within the reduced cross-sectional area 1030 (i.e. conical area) thereby suppressing contaminant flow downstream of the intermediate focus (]0113]). It is noted that because Deman teaches coils located on the debris mitigation device and Zhoa teaches a lower cone with the outlet between the lower cone and the debris mitigation device and Bykanov suggests placing coils on the lower cone of Zhoa, the evidence suggests that such a combination would also result in positioning the gas outlet between the first coils and the second coil. That is, the modification does not change the position of the outlet between the debris mitigation device and the lower cone, it only adds a coil to the lower cone of Zhoa resulting in the claimed limitation. Alternatively, Zhoa (second interpretation of Zhoa) teaches a lower cone (fig. 19, 95) provided between the rotatable debris collection device (6) and an EUV output port (outside of 4221); wherein the first gas inlet (fig. 20, 111 and paragraph [0108]) is located at a position between the lower cone and the EUV output port (see discussion in response to arguments in the final rejection of 10/07/2024) a gas outlet (fig. 20, 112) for exhausting the source gas (as indicated by arrows from 111 to 112) located in the lower cone and downstream the rotatable debris collection device (112 is downstream of 101) such that the first gas inlet is configured to inject the source gas to generate a first gas flow in a first direction towards the gas outlet (from 111 to 112). Zhoa teaches a single cone 95 including a crossbar 93 wherein the single cone 95 has the outlets 112 and therefore fails to disclose the gas outlet positioned between the lower cone and the rotatable debris collection device and at least one coil on the lower cone. However, Labetski teaches an outlet 112 (fig. 9b), which may be either arranged symmetrically around a perimeter of the inner vessel wall (similar to the outlets 112 of Zhoa) or may extend around a full perimeter of the inner vessel wall ([000192]) at least one coil on the lower cone (fig. 9B showing lower cone formed by 112 extending around the full perimeter of the inner vessel wall 104, wherein figure 17 shows a flow splitter 150 as port of the exit portion of the cone 104, thus part of lower cone. Paragraph [000264] teaches flow splitter 150 may be inductively heated by a coil, thus a coil on the lower cone). Labetski modifies the combined device by suggesting extending the gas outlet 112 of Zhoa around the full perimeter of the inner vessel wall. Such a modification would place the outlet 112 of Zhoa between the lower cone 95 (segmented by the exhaust 112 extending around the whole perimeter) and the rotatable debris collection device 6 (as seen in figure 20 of Zhoa). Since both inventions are directed towards dynamic gas locks and exhausting gas in a cone of an EUV light source, it would have been obvious to one of ordinary skill in the art to substitute the single symmetric exit ports 112 of the combined device in view of Zhoa for that of the exhaust 112 extending around a full perimeter of the inner vessel wall 104 (lower cone) because it would lead to predictable results of exhausting the gas. That is, the combined device in view of Zhoa is a finding that the prior art contained a device which differed from the claimed device by the substitution of an exhaust port extending around the entire perimeter for an individual exhaust ports. Labetski is evidence that an exhaust extending around the entire perimeter of the cone was known to the art. Labetski is further evidence that one of ordinary skill in the art could have substituted an individual ports for a single port extending around the entire perimeter of the cone. Therefore the substitution of one known element for another yields predictable results of exhausting the gas input from the gas source. Moreover, an exhaust extending around the entire perimeter of the cone would improve the ability to exhaust the gas because the output of source gas would be accessible around the entire perimeter of the cone instead of individual ports. Xia modifies this interpretation as discussed above. It is noted that because Deman teaches coils located on the debris mitigation device and Zhoa teaches a lower cone with the outlet between the lower cone and the debris mitigation device and Xia suggests placing coils on the lower cone of Zhoa, the evidence suggests that such a combination would also result in positioning the gas outlet between the first coils and the second coil. That is, the modification does not change the position of the outlet between the debris mitigation device and the lower cone, it only adds a coil to the lower cone of Zhoa resulting in the claimed limitation. In any of the three combinations above, the combined device fails to disclose a second gas inlet, the second gas inlet is located at a position between the rotatable debris collection device and the collector mirror and at least one third coil on the collector mirror and the second gas inlet is configured to inject the source gas to generate a second gas flow in a second direction opposed to the first direction toward the gas outlet. However, Baek et al. teaches a second gas inlet (figures 8-9, 802), the second gas inlet is located at a position between the debris collection device and the collector mirror (figures 8-9 show hydrogen nozzles directly above collector 30, thus between debris collection device (150) and collector 30 of figure 1) and a coil on the collector mirror (figures 8-9, coil is on the collector mirror (i.e. as in the specification a space between mirror and coil), see paragraph [0076] teaching inductive coil 804 disposed between nozzles and rim 30b of collector 30) the second gas inlet is configured to inject the source gas to generate a second gas flow in a second direction (gas flow from 802 into area above collector 30). Baek modifies the combined device by suggesting an induction coil around the perimeter of the collector. Since both devices are directed towards debris mitigation, it would have been obvious to one of ordinary skill in the art to incorporate the induction coil with the collector as suggested by Baek because it would allow for in situ cleaning of not only the EUV vessel but also the EUV collector simultaneously, therefore not requiring interruption of EUV generation to clean the EUV collector. It is noted here that the combination teaches all three coils and two inlets and outlets in the claimed arrangement, modifications are only to the addition of coils and inlets/outlet. This combination would result in the second gas inlet is positioned between the one first coil and the at least one second coil (Baek teaches the inlet between the collector with the third coil around the collector (as modified by B2) and the debris collection device. In the combination since the first coil of Damen is located on the debris device and the third coil is located on the collector (Beak as modified by B2), the second gas inlet of Baek is also between the first and third coil) and the first and second gas inlets are positioned on opposite sides of the gas outlet along an axis of the EUV radiation source (Zhao inlet 111 at EUV outlet and Baek inlet near collector mirror, thus on opposite sides of the EUV source along the axis of EUV radiation). Moreover, as discussed in the response to arguments section above the combination would naturally result in second gas flow in the second direction of Baek to be opposed to the first direction towards the gas outlet as in Zhoa because that is the direction the gas would be pulled due to the rotating fan 101 which is shown in figure 18 of Zhao to pull gas in the direction towards. MPEP 2112 (IV) recites: “[I]n order to rely on inherency to establish the existence of a claim limitation in the prior art in an obviousness analysis – the limitation at issue necessarily must be present, or the natural result of the combination of elements explicitly disclosed by the prior art." Id. at 1195-96, 112 USPQ2d at 1952. But see, Persion Pharms. LLC v. Alvogen Malta Operations LTD., 945 F.3d 1184, 1191, 2019 USPQ2d 494084 (Fed. Cir. 2019)” Here, since Zhoa discloses the first inlet and gas outlet and Baek teaches a gas inlet and removing the gas from the chamber, the combination would inherently result in the gas from the second outlet to move in the opposing direction of the first direction indicated in the figure above due to the movement of the fan as indicated in figure 18 of Zhoa. Therefore, the amendment is insufficient to distinguish the claimed invention over that of Zhao. That is, this limitation does not further distinguish the claim than what is already suggested by the combination. Lastly with respect to the functionally claimed “provide a first source gas to generate the ICP for removing debris on the rotatable debris collection device, and switch from the first source gas to a second source gas to form a passivation layer on surfaces of at least the collector mirror and the rotatable debris collection device in the chamber”, it appears that the structure to provide the first and second source gases are the claimed first and second gas inlets, since the combined device teaches a first and second gas inlet, the combination is capable of receiving a first gas for ICP and switching the gas source for receiving a second gas source to form a passivation layer on the collector mirror and the rotatable debris collection device. That is, the first gas inlet and second gas inlet are positioned in the combined device as required by the claim, therefore providing a first gas source to achieve a result and a second gas source to achieve the second claimed result are inherent to the combination. That is, there is no structural requirement to the claimed inlets or outlets that would preclude them from receiving a gas source for ICP switching the gas source so as to create a passivation layer. The combined device teaches an EUV radiation source apparatus, the combined device further fails to disclose the apparatus is configured to adjust a distribution of the ICP by tuning a ratio between a first current of the at least one first coil and a second current of the at least one second coil. However, Banna teaches a RF power source configured to adjust a distribution of the ICP ([0038] control of plasma characteristics in zone (i.e. distribution of ICP, note: plasma is ICP see title and paragraph [0003]). Note by changing the relative RF power (i.e. current, see discussion above) the distribution of the plasma inherently changes as it is generated by the RF current ([0003])) by tuning a ratio between a first current of the at least one first coil and a second current of the at least one second coil ([0038] “the relative quantity of RF power provided by the RF power source 108 to the respective first, second, and third RF coils 110, 112, 113…controlling the amount of RF power”, wherein the relative quantity to first, second and third RF coils is a ratio. RF power source provides RF current ([0008]) thus relative RF power is the relative RF current, which is controlled (i.e. tuned) by the power source. Further note: paragraph [0064] teaches a power divider used to tune and control the RF power delivery and a variable capacitor to determine the current ratio between coils). Banna modifies the combined device by providing each of the coils with independent control and opposite phases (i.e. the first coil around the rotatable debris collection device and the second coil on the lower cone as suggested by Damen as modified by Derra by Zhoa as modified by Labetski or Bykanov). Since both inventions are directed towards coils for generating ICP, it would have been obvious to one of ordinary skill in the art to provide the phase difference and independently controllable coils of Banna in the combined device because the independent control allows control of plasma characteristics in zones corresponding to each coil ([0038]) thus allowing control of non-uniformities ([0004]), whereas the 180 degree phase difference improves plasma uniformity ([0034]). That is, the arrangement of the power supplies of Banna would facilitate more uniform exposure thus providing for more thorough and even cleaning in the combined device. Claims 2-3 are rejected for the same reasons above. That is, because the gas inlet is claimed functionally for supplying a particular gas and Derra teaches a gas inlet, the claim is not structurally distinguished over the combined device. See footnote 3 above. Regarding claim 9, Damen teaches an AC power for supplying AC power to at least one first coil and the at least one second coil ([0045]). Regarding claims 10-11, Demon teaches two or more coils are provided (figs. 6-7), however the combined device fails to disclose for each of the two or more coils is independently tunable. However, Banna teaches wherein current for each of the coils is independently tunable ([0038]) and wherein a phase of the current flowing in two or more of the coils is different by 180 degrees from a phase of the current flowing in another two or more of the coils ([0032]). Banna modifies the combined device by providing each of the coils with independent control and opposite phases. Since both inventions are directed towards coils for generating ICP, it would have been obvious to one of ordinary skill in the art to provide the phase difference and independently controllable coils of Banna in the combined device because the independent control allows control of plasma characteristics in zones corresponding to each coil ([0038]) thus allowing control of non-uniformities ([0004]), whereas the 180 degree phase difference improves plasma uniformity ([0034]). That is, the arrangement of the power supplies of Banna would facilitate more uniform exposure thus providing for more thorough and even cleaning in the combined device. Claim 12 is broader in scope than claim 1, thus taught as in the citations discussed herein above. Claim 15 is rejected for the same reasons as discussed in claim reasons as claim 6 above. Regarding claim 34, the combined device teaches wherein the EUV radiation source apparatus is further configured to switch from the first source gas to the second source gas after the ICP is generated and the debris on the rotatable debris collection device is removed (by changing a the source gas after ICP to a second gas source, that is the only structure for the gas source is the claimed inlets, since the combined device suggests two inlet and their respective positions, the manner of operating the device fails to distinguish the claimed invention over the prior art (see MPEP 2114 (II))). Claims 1, 12, 21, 22 and 25-34 are rejected under 35 U.S.C. 103 as being unpatentable over Zhao et al. (US pgPub 2016/0209753)4 in view of Derra et al. (US pgPub 2010/0051827) in view of Bykanov et al. (US pgPub 2009/0154642) in view of Baek et al. and further in view of Banna (US pgPub 2013/0106286). Regarding claim 1, Zhoa et al. teach an extreme ultra violet (EUV) radiation source apparatus (figs. 3, 4 and 18), comprising: a collector mirror (3); a target droplet generator (1) for generating a tin (Sn) droplet ([0070]); a rotatable debris collection device (6e); heating device for generating heat ([0083]); a lower cone (fig. 18-20, 95) provided between the rotatable debris collection device (6e/6d) and an EUV output port (outside of 4221); a first gas inlet (fig. 20, 111 and paragraph [0108]) for providing a source gas ([0108] and [0070]) for providing a source gas including one or more of Si or Zr containing gas ([0070] teaches radicles for cleaning purposes. See discussion above regarding MPEP 2114, wherein the first gas inlet is located at a position between the lower cone and the EUV output port (figures 19-20111 between 111 and 4221) wherein the first gas inlet is located at a position between the lower cone and the EUV outlet (fig. 20 111 located between 95 and EUV outlet 4221 seen in figure 19) a gas outlet (fig. 18 see two interpretations above for gas outlet) for exhausting (see discussion above) the source gas located between the lower cone and the rotatable debris collection device (91 is between 95 and 6, thus the drain is also between 95 and 6) such that the first gas inlet is configured to inject the source gas to generate a first gas flow in a first direction toward the gas outlet (see above); a chamber (fig. 2 shows the source chamber 4220) enclosing at least the collector mirror and the rotatable debris collection device (as seen in figure 2, 4220 enclosures contaminant trap 4230 not seen in figure 3 and figure 3 shows the collector mirror enclosed by chamber 4220), wherein the heating device are configured such that the heat is spaced apart from the collector mirror ([0083] teaches heating elements attached to blades thus spaced apart from collector CO) the heating device includes at least one first heating device surrounding or covering the rotatable debris collection device ([0083] teaches heating device attached to each vane thus covering both 6d and 6e). Zhoa teaches heating elements attached to the blade thus fails to disclose one or more coils for generating an inductively coupled plasma (ICP), a gas inlet for the ICP. However, Derra teaches generating inductively coupled discharge instead of heat ([0021] teaches ICP having coils arranged at the same positions as the heatable elements); a gas inlet (fig. 10 shows gas inlet 10) for providing a source gas including one or more of Si containing gas and Zr containing gas (gas inlet passage inherently provides a source gas. Since the claim is written as the function of the gas inlet for providing Si or Zr containing gas, the gas inlet of Zhoa is capable of providing any gas, since it is merely an opening to receive a gas5), for ICP ([0018] teaches gases passing over hot surfaces to generate radicals, which may be replaced ICP ([0021]), thus for ICP) wherein the gas inlet and the one or more coils are configured such that the ICP is spaced apart from the collector mirror (as seen in figure 10 when substituted for ICP coils disclosed in paragraph [0021]).. Derra modifies Zhoa by suggesting ICP with coils as an alternative to heat to remove tin deposits. Since both inventions are directed towards heating elements of an EUV source to remove contamination, it would have been obvious to one of ordinary skill in the art to substitute the heatable elements of Zhoa for the ICP coils of Derra because it would lead to the predictable results of generating radical such that a higher lifetime of the optical components can be achieved ([0015], 0017 and [0021]). The substitution would result in the plasma being spaced from the collector 50 of Zhoa. The combined device fails to disclose at least one second coil covering or surrounding the lower cone. Bykanov et al. teaches at least one second coil covering or surrounding the lower cone (figure 7 shows an embodiment of structure 14 as 1014B which has ICP coils 1070 ([0111]) around the conical structure 1022 (i.e. the lower cone)). Bykanov et al. modifies the Damen in view of Derra et al. in view of Zhao et al. by suggesting ICP coils around the lower cone. Since both inventions are directed towards debris mitigation via ICP coils, it would have been obvious to one of ordinary skill in the art to provide the coils of Bykanov et al. to the lower cone of Damen as modified by Derra as modified by Zhoa as suggested in Bykanov et al. because the plasma may reduce flow within the reduced cross-sectional area 1030 (i.e. conical area) thereby suppressing contaminant flow downstream of the intermediate focus (]0113]). It is noted that because Zhoa in view of Derra teaches coils located on the debris mitigation device and Zhoa teaches a lower cone with the outlet between the lower cone and the debris mitigation device and Bykanov suggests placing coils on the lower cone of Zhoa, the evidence suggests that such a combination would also result in positioning the gas outlet between the first coils and the second coil. That is, the modification does not change the position of the outlet between the debris mitigation device and the lower cone, it only adds a coil to the lower cone of Zhoa resulting in the claimed limitation. The combined device fails to disclose a second gas inlet, the second gas inlet is located at a position between the rotatable debris collection device and the collector mirror and at least one third coil on the collector mirror. However, Baek et al. teaches second gas inlet (figures 8-9, 802), the second gas inlet is located at a position between the debris collection device and the collector mirror (figures 8-9 show hydrogen nozzles directly above collector 30, thus between debris collection device (150) and collector 30 of figure 1) and a coil on the collector mirror (figures 8-9, coil is on the collector mirror (i.e. as in the specification a space between mirror and coil), see paragraph [0076] teaching inductive coil 804 disposed between nozzles and rim 30b of collector 30) and the second gas inlet is configured to inject the source gas to generate a second gas flow in a second direction (see above). Baek modifies the combined device by suggesting an induction coil around the perimeter of the collector. Since both devices are directed towards debris mitigation, it would have been obvious to one of ordinary skill in the art to incorporate the induction coil with the collector as suggested by Baek because it would allow for in situ cleaning of not only the EUV vessel but also the EUV collector simultaneously, therefore not requiring interruption of EUV generation to clean the EUV collector. It is noted here that the combination teaches all three coils and two inlets and outlets. This combination would result in the second gas inlet is positioned between the one first coil and the at least one second coil (Baek teaches the inlet between the collector with the third coil around the collector (as modified by B2) and the debris collection device. In the combination, since the first coil of Zhoa is located on the debris device and the third coil is located on the collector (Beak), the second gas inlet of Baek is also between the first and third coil) and the first and second gas inlets are positioned on opposite sides of the gas outlet along an axis of the EUV radiation source (Zhao inlet 111 at EUV outlet and Baek inlet near collector mirror, thus on opposite sides of the EUV source along the axis of EUV radiation). Moreover, as discussed in the response to arguments section above the combination would naturally result in second gas flow in the second direction of Baek to be opposed to the first direction towards the gas outlet as in Zhoa because that is the direction the gas would be pulled due to the rotating fan 101 which is shown in figure 18 of Zhao to pull gas in the direction towards. MPEP 2112 (IV) recites: “[I]n order to rely on inherency to establish the existence of a claim limitation in the prior art in an obviousness analysis – the limitation at issue necessarily must be present, or the natural result of the combination of elements explicitly disclosed by the prior art." Id. at 1195-96, 112 USPQ2d at 1952. But see, Persion Pharms. LLC v. Alvogen Malta Operations LTD., 945 F.3d 1184, 1191, 2019 USPQ2d 494084 (Fed. Cir. 2019)” Here, since Zhoa discloses the first inlet and gas outlet and Baek teaches a gas inlet and removing the gas from the chamber, the combination would inherently result in the gas from the second outlet to move in the opposing direction of the first direction indicated in the figure above due to the movement of the fan as indicated in figure 18 of Zhoa. Therefore, the amendment is insufficient to distinguish the claimed invention over that of Zhao. That is, this limitation does not further distinguish the claim than what is already suggested by the combination. Lastly with respect to the functionally claimed “provide a first source gas to generate the ICP for removing debris on the rotatable debris collection device, and switch from the first source gas to a second source gas to form a passivation layer on surfaces of at least the collector mirror and the rotatable debris collection device in the chamber”, it appears that the structure to provide the first and second source gases are the claimed first and second gas inlets, since the combined device teaches a first and second gas inlet, the combination is capable of receiving a first gas for ICP and switching the gas source for receiving a second gas source to form a passivation layer on the collector mirror and the rotatable debris collection device. That is, the first gas inlet and second gas inlet are positioned in the combined device as required by the claim, therefore providing a first gas source to achieve a result and a second gas source to achieve the second claimed result are inherent to the combination. That is, there is no structural requirement to the claimed inlets or outlets that would preclude them from receiving a gas source for ICP switching the gas source so as to create a passivation layer. The combined device teaches an EUV radiation source apparatus, the combined device further fails to disclose the apparatus is configured to adjust a distribution of the ICP by tuning a ratio between a first current of the at least one first coil and a second current of the at least one second coil. However, Banna teaches a RF power source configured to adjust a distribution of the ICP ([0038] control of plasma characteristics in zone (i.e. distribution of ICP, note: plasma is ICP see title and paragraph [0003]). Note by changing the relative RF power (i.e. current, see discussion above) the distribution of the plasma inherently changes as it is generated by the RF current ([0003])) by tuning a ratio between a first current of the at least one first coil and a second current of the at least one second coil ([0038] “the relative quantity of RF power provided by the RF power source 108 to the respective first, second, and third RF coils 110, 112, 113…controlling the amount of RF power”, wherein the relative quantity to first, second and third RF coils is a ratio. RF power source provides RF current ([0008]) thus relative RF power is the relative RF current, which is controlled (i.e. tuned) by the power source. Further note: paragraph [0064] teaches a power divider used to tune and control the RF power delivery and a variable capacitor to determine the current ratio between coils). Banna modifies the combined device by providing each of the coils with independent control and opposite phases (i.e. the first coil around the rotatable debris collection device and the second coil on the lower cone as suggested by Damen as modified by Derra by Zhoa as modified by Labetski or Bykanov). Since both inventions are directed towards coils for generating ICP, it would have been obvious to one of ordinary skill in the art to provide the phase difference and independently controllable coils of Banna in the combined device because the independent control allows control of plasma characteristics in zones corresponding to each coil ([0038]) thus allowing control of non-uniformities ([0004]), whereas the 180 degree phase difference improves plasma uniformity ([0034]). That is, the arrangement of the power supplies of Banna would facilitate more uniform exposure thus providing for more thorough and even cleaning in the combined device. Claim 12 is broader in scope, thus taught above with respect to claim 1. Claim 21 is a combination of claims 1, 4 and 7 and is rejected for the same reasons discussed in those claims above. Regarding claim 22, Zhoa et al. teach the rotatable debris collection device includes a plurality of rotating vanes supported by a first end support of the rotatable debris collection device (Zhoa, fig. 16, 10 bottom bearing) and a second end support of the rotatable debris collection device(Zhoa, fig. 16 10 top bearing), and the second end support of the rotatable debris collection device has a smaller diameter than the first end support of the rotatable debris collection device (Zhoa, as seen in figure 10, see also fig. 19). Regarding claims 25-27, the combined device teaches where the at least one third coil includes two or more third coils covering the convex rear side of the collector mirror and at least another one coil of the two or more third coils surround or cover the circumferential edge of the collector mirror (B2, note, 300A-c, see figure 6 and figure 4 see coil 250 surrounding edge of 30). The combined device in view of B2 fails to disclose independently tunable However, Banna teaches wherein current for each of the coils is independently tunable ([0038]) and wherein a phase of the current flowing in two or more of the coils is different by 180 degrees from a phase of the current flowing in another two or more of the coils ([0032]). Banna modifies the combined device by providing each of the coils with independent control and opposite phases. Since both inventions are directed towards coils for generating ICP, it would have been obvious to one of ordinary skill in the art to provide the phase difference and independently controllable coils of Banna in the combined device because the independent control allows control of plasma characteristics in zones corresponding to each coil ([0038]) thus allowing control of non-uniformities ([0004]), whereas the 180 degree phase difference improves plasma uniformity ([0034]). That is, the arrangement of the power supplies of Banna would facilitate more uniform exposure thus providing for more thorough and even cleaning in the combined device. Regarding claim 28, the combined device in view of Baek teach wherein the ICP generated by the at least one first coil touches the rotatable debris collection device (Zhoa teaches providing heat to blades by attachment of heating elements as modified by Derra, ICP replaces heating elements ([0021]). Thus since electrodes are placed at the same position by substitution, the electrodes are on the blades of Zhao, therefore resulting plasma touches the blades. Moreover, the gas flow in Derra is disclosed to be controlled ([0072]), therefore Zhoa in view of Derra is capable of achieving the claimed result by adjusting the gas flow. That is, the instant specification teaches the result of touching is achieved by adjusting gas flow amounts ([0040] of the published application), since the gas flow rate may be adjusted in Zhoa in view of Derra, the same result may be achieved.), the ICP generated by the at least one second coil touches the lower cone (Bykanov, similarly teaches gas flows may be adjusted ([0112]), therefore capable of achieving the claimed result. That is, the instant specification teaches the result of touching is achieved by adjusting gas flow amounts ([0040] of the published application), since the gas flow rate may be adjusted in Bykanov, the same result may be achieved.), and the ICP (Baek, fig. 8, 810) generated by the at least one third coil (Baek, 804) is spaced apart from the collector mirror (Baek, figure 8 shows 810 spaced from collector 30). Regarding claim 29, Zhao teaches the rotatable debris collection device includes a plurality of rotating vanes (6, best seen in figure 5) supported by a first end support of the rotatable debris collection device and a second end support of the rotatable debris collection device (bearing 10 supports both ends of vanes 6 best seen in figure 16). Regarding claim 30, Zhoa teaches the second end support of the rotatable debris collection device has a smaller diameter than the first end support of the rotatable debris collection device (fig. 16 shows conical shape, upper end is the second end of smaller diameter). Regarding claim 31, Zhoa teaches wherein: the first end support of the rotatable debris collection device and the second end support of the rotatable debris collection device are frustoconical support frames (as seen in figure 15 and 16). Regarding claim 32, Zhao teaches the rotatable debris collection device includes a plurality of rotating vanes (6, best seen in figure 5) supported by a first end support of the rotatable debris collection device and a second end support of the rotatable debris collection device (bearing 10 supports both ends of vanes 6 best seen in figure 16). Regarding claim 33, Zhoa teaches wherein: the first end support of the rotatable debris collection device and the second end support of the rotatable debris collection device are frustoconical support frames (as seen in figure 15 and 16). Regarding claim 34, the combined device teaches wherein the EUV radiation source apparatus is further configured to switch from the first source gas to the second source gas after the ICP is generated and the debris on the rotatable debris collection device is removed (by changing a the source gas after ICP to a second gas source, that is the only structure for the gas source is the claimed inlets, since the combined device suggests two inlet and their respective positions, the manner of operating the device fails to distinguish the claimed invention over the prior art (see MPEP 2114 (II))). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US20210063899 to Xia teaches an ICP coil around a collector mirror (see fig. 10a-10d, electrical conduct 560_10 generating plasma particles 575 towards the exposed collector 1043). Xia also teaches a coil around a cone for the same purposes, see figures 8A-9B. US20050199829 also teaches coils behind a collector mirror as seen in figure 5a. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL J LOGIE whose telephone number is (571)270-1616. The examiner can normally be reached M-F: 7:00AM-3:00PM. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Robert Kim can be reached at (571)272-2293. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /MICHAEL J LOGIE/Primary Examiner, Art Unit 2881 1 MPEP 2114 (II) recites “”[A]pparatus claims cover what a device is, not what a device does." Hewlett-Packard Co. v. Bausch & Lomb Inc., 909 F.2d 1464, 1469, 15 USPQ2d 1525, 1528 (Fed. Cir. 1990) (emphasis in original). A claim containing a "recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus" if the prior art apparatus teaches all the structural limitations of the claim.” Here since the claim does not structurally distinguish the gas inlet over the prior art and Derra teaches a gas inlet, it is capable of supplying a source gas including Si or Zr containing gases. 2 a second gas inlet (figures 8-9, 802), the second gas inlet is located at a position between the debris collection device and the collector mirror (figures 8-9 show hydrogen nozzles directly above collector 30, thus between debris collection device (150) and collector 30 of figure 1) and a coil on the collector mirror (figures 8-9, coil is on the collector mirror (i.e. as in the specification a space between mirror and coil), see paragraph [0076] teaching inductive coil 804 disposed between nozzles and rim 30b of collector 30) the second gas inlet is configured to inject the source gas to generate a second gas flow in a second direction (gas flow from 802 into area above collector 30). 3 MPEP 2114 (II) recites “”[A]pparatus claims cover what a device is, not what a device does." Hewlett-Packard Co. v. Bausch & Lomb Inc., 909 F.2d 1464, 1469, 15 USPQ2d 1525, 1528 (Fed. Cir. 1990) (emphasis in original). A claim containing a "recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus" if the prior art apparatus teaches all the structural limitations of the claim.” Here since the claim does not structurally distinguish the gas inlet over the prior art and Derra teaches a gas inlet, it is capable of supplying a source gas including Si or Zr containing gases. 4 Note the interpretation of Zhoa discussed on pages 20-21 of the Final Rejection of 14 January 2026 is still applicable to at least claims 1, 12 and 21. However, a new interpretation is taken such that Zhoa may additionally teach claims 29-33. 5 MPEP 2114 (II) recites “”[A]pparatus claims cover what a device is, not what a device does." Hewlett-Packard Co. v. Bausch & Lomb Inc., 909 F.2d 1464, 1469, 15 USPQ2d 1525, 1528 (Fed. Cir. 1990) (emphasis in original). A claim containing a "recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus" if the prior art apparatus teaches all the structural limitations of the claim.” Here since the claim does not structurally distinguish the gas inlet over the prior art and Derra teaches a gas inlet, it is capable of supplying a source gas including Si or Zr containing gases.
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Prosecution Timeline

Show 21 earlier events
Jun 01, 2026
Examiner Interview Summary
Jun 18, 2026
Response Filed
Jun 30, 2026
Final Rejection mailed — §103, §112
Jul 28, 2026
Interview Requested
Aug 25, 2026
Response after Non-Final Action
Sep 10, 2026
Request for Continued Examination
Sep 14, 2026
Response after Non-Final Action
Oct 05, 2026
Non-Final Rejection mailed — §103, §112 (current)

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