is Lee claim 4 or van Engelen claim 10. Each alternative of the count is interpreted in light of the
parties' respective involved specifications. The first alternative of the count (Lee claim 4) is
interpreted in light of Lee's involved '762 specification.
With that in mind, a more reasonable interpretation of the term "dynamically isolated"
may be gleaned from the first definition for the word "dynamic" and from Lee's specification.
The first definition for dynamic is "of or relating to energy or to objects in motion" (Ex. 2016).
That definition, on its face, is a more reasonable definition for the term dynamic when considered
in the context of two frames and their relationship. Lee's '762 specification describes two
frames that are isolated from each other, such that the reaction forces from the elements of one
frame are not transmitted to the other frame. That is, the dynamics, e.g., motion, from one frame
are isolated from the other. In this light, and in view of the first definition for the term dynamic,
a more reasonable interpretation of the term dynamically isolated is that the dynamics are
isolated from one frame to the other - that the reaction forces from one frame are not transmitted
to the other frame. Note, that the proposed definition does not necessarily require structure in
between the two frames, but is merely descriptive of the relationship between the two frames.
Lee's involved '762 application supports such an interpretation of "dynamically isolated" frames.
For example, the '762 specification states that:
An additional aspect in accordance with the invention is that the reaction force of the
stage and window frame drive motors is not transmitted to the support frame of the
photolithography apparatus projection lens but is transmitted independently directly to the
earth's surface by an independent supporting structure. Thus, the reaction forces caused
by movement of the stage do not induce undesirable movement in the projection lens or
other elements of the photolithography machine (Ex. 2011 at 3, lines 4-9).
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