Van Engelen argues that Lee's application is devoid of a (1) discussion of how the frames
are "dynamically isolated" from one another (motion 1), (2) description of a stationary part of
the measuring system that is fastened to the second frame (motion 3), or (3) description of a
stationary part of the drive unit that is fastened to the reaction frame (motion 2). In essence, Van
Engelen argues that Lee's claims 2 and 8 are not enabled or described, and thus are indefinite.
However, the written description requirement and the enablernent requirement are separate and
distinct from the definiteness requirement. "Definiteness and enablement are analytically distinct
requirements." Process Control Corp. v. HydReclaim Corp., 190 F.3d 1350, 1358 n.2, 52
USPQ2d 1029, 1034 n.2 (Fed. Cir. 1999). Even if the written description does not enable the
claim, the claim language itself may still be definite. Union Pac. Res. Co. v. Chesgpeake Ener
Corp., 236 F.3d 684, 692, 57 USPQ2d 1293, 1297 (Fed. Cir. 2001). Since van Engelen has
failed to apply the correct standard and sufficiently demonstrate that Lee claims 2 and 8 are
indefinite, this part of van Engelen motions 1-3 is denied.
No interference-in-fact
Van Engelen argues that if Lee's claims are definite and are supported by Lee's
specification, then there is no interference-in-fact between Lee and van Engelen. Van Engelen,
in its preliminary motion 1, page 17, argues that Lee's claims should be interpreted such that the
"dynamically isolated" frames are physically isolated frames, which is in contrast with van
Engelen's "dynamically isolated" frames which are physically interconnected with a dynamic
isolator. Likewise, in its preliminary motions 2 and 3, van Engelen argues that when the van
Engelen and Lee claims are interpreted in light of the respective specifications, the parties'
claims are limited by their respective specifications, which describe different architecture for the
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