Interference No. 104,703
Page No. 18
Goodall states that claims 7-11 claim a radiation sensitive composition having polymers
formed by addition polymerization in the presence of a single or multicomponent catalyst system.
(Paper No. 44, p. 7, ¶ 14). Goodall argues that these claims are patentably distinct from Counts
A, B and C as Goodall claims 7-11 recite specific methods of polymerization and catalysts that
are not recited in Counts A, B and C and are not taught or suggested by the prior art. (Paper No.
44, p. 7, ¶ 15).
Goodall states that the multi-component catalysts of the prior art Goodall ‘730 patent
would not generate a radiation sensitive polymer. (Paper No. 44, p. 8, ¶ 19). Further, Goodall
alleges that Suwa’s involved ‘620 application does not claim, teach or suggest the single or
multicomponent catalyst systems as well as the specific methods of polymerization recited in
Goodall claims 7-11. (Paper No. 44, p. 8, ¶ 20).
Mr. Andrew Bell has testified that it would not be obvious to form the addition polymers
having a pendant acid labile group as recited in Goodall claims 2, 4, 5 and 7-11 from norbornene-
functional monomers in view of the catalysts employed in the ‘730 patent, alone or further in
view of the ‘620 application. (GX 2005, ¶ 13). Specifically, Mr. Bell states that there is no
teaching or suggestion in the ‘730 patent of using the disclosed catalysts with norbornene
monomers bearing acid labile groups to form a radiation sensitive polymer. (GX 2005, ¶ 13).
Mr. Bell also testifies that there is no teaching or suggestion in the ‘620 claims for using addition
polymerization catalysts, such as those disclosed in the ‘730 patent, to prepare a radiation-
sensitive resin composition. (GX 2005, ¶ 13). Moreover, Mr. Bell testifies that he is of the
belief that even if the teachings of Suwa’s involved ‘620 application were combined with the
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