HOSHINO et al V. TANAKA - Page 22




          Interference No. 103,208                                                    
          Hoshino et al. v. Tanaka                                                    

          senior party Tanaka.  In this first declaration, Mr. Utagawa                
          makes three points which are especially pertinent to the issue              
          of adding proposed new counts 2, 3, and 4:                                  
               (1) (pages 2-3) [W]hen focusing is based on a                          
               corrected conversion coefficient K determined in                       
               accordance with a formula having a first order term                    
               of the detected amount of defocus, there is a                          
               substantial improvement                                                
               in the accuracy of focusing, as compared to focusing                   
               based on a corrected conversion coefficient                            
               determined                                                             
               in accordance with a formula that lacks a first                        
               order term of the detected amount of defocus.  For                     
               example, a formula that has merely a second order                      
               term of the detected amount of defocus produces a                      
               substantial error in the corrected conversion                          
               coefficient, as is apparent from a comparison of                       
               line M1 and the second order curve superimposed on                     
               Fig. 3 in Exhibit A.                                                   
               (2) (pages 3-4) [W]hen the calculating means                           
               determines the corrected conversion coefficient in                     
               accordance with a formula having a first order term                    
               of the detected amount of defocus and that depends                     
               on both the magni- tude and the sign of the detected                   
               amount of defocus, there is a substantial                              
               improvement in focusing accu- racy, as compared with                   
               focusing based on a corrected conversion coefficient                   
               determined in accordance with   a formula that                         
               produces the same corrected conversion coefficient                     
               regardless of the sign of the detected amount of                       
               defocus.  This is apparent in Fig. 3 of Exhibit B                      
               attached hereto in which the first order dash line                     
               M1' (producing the same value of K regardless of the                   
               sign of ÎBf) shows a substantial error (divergence                     
               from line M1) in determination of the corrected                        
               conver- sion coefficient K for -ÎBf.  Similarly, in                    
               Exhibit A, there is a substantial error when the                       

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