and 108 are located on top of the second frame 94. Although the supports are not described as
being fastened to the second frame, figure 4 suggests that they are. More importantly, Lee's '558
application 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 sqPport frame of the
Rhotolithogrgphv gpparatus 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.
This physically isolating the stage reaction forces from the projection lens and
associated structures prevents these reaction forces from vibrating the proiection lens and
associated structures. These structures include the interferometer system used to
determine the exact location of the stage in the X-Y l2lane and the wafer stage. Thus, the
reticle stage mechanism support is spaced apart from and independently supported from
the other elements of the photolithography machine and extends to the surface of the
earth. (Emphasis added). (VE Ex. 2011 at 3, lines 4-16).
From the above, the reaction force of the stage and window frame drive motors is not
transmitted to the support frame such that the reaction forces do not induce movement in the
instruments that are supported by the support frame - the projection lens and other elements of
the photolithography machine, including the interferometer system. Thus, the above description
in combination with Figure 4 indicate that the interferometer system is fastened to the support
frame (second frame). If it were otherwise, the Lee '558 specification would not go to great
lengths to explain that the reaction forces are not transmitted to the projection lens and associated
structures (including the interferometer system). For example, if the interferometer system were
mounted on a wall, the system would not be subjected to system vibrations and thus there would
be no discussion in the '558 specification about isolating vibrations for the interferometer
system. Furthermore, there is no discussion throughout the Lee '558 specification of mounting
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