VAN ENGELEN et al. V. LEE - Page 15





                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 '763 application supports such an interpretation of "dynamically isolated" frames.                                    
                 For example, the '763 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).                                                  
                The above indicates that reaction forces, e.g., dynamics of the one frame, are not transmitted to                                    
                the other frame and are therefore "dynamically isolated." This definition for dynamically                                            
                isolated, that the reaction forces are isolated, is a more reasonable interpretation of the term                                     
                "dynamically isolated" given the description in Lee's '763 specification and the first listed                                        
                definition for dynamic as previously discussed. Van Engelen's definition of "dynamically                                             
                isolated", in contrast, is derived from van Engelen's involved specification, and by importing an                                    
                element into Lee's claim 2 that simply is not claimed. To the extent that the second alternative of                                  
                the count, i.e., van Engelen's claim 2, should be interpreted to mean that there are necessarily                                     
                "dynamic isolators" in between the two frames does not mean that Lee's claim 2, the first                                            
                alternative of the count should also be interpreted the same way. The count is the disjunctive                                       


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