Abstract. Finding an easy-to-build coils set has been a critical issue for stellarator design for decades. Conventional approaches assume a toroidal "winding" surface.We'll investigate if the existence of winding surface unnecessarily constrains the optimization, and a new method to design coils for stellarators is presented. Each discrete coil is represented as an arbitrary, closed, one-dimensional curve embedded in three-dimensional space. A target function to be minimized that covers both physical requirements and engineering constraints is constructed. The derivatives of the target function are calculated analytically. A numerical code, named FOCUS, has been developed. Applications to a simple configuration, the W7-X, and LHD plasmas are presented.