machine frame, or that the force actuator system is integrated with dynamic isolators. All that is
required is that the actuator system exert a force on the reference frame.
Van Engelen argues that Lee's involved specification fails to disclose a compensation
force between the first and second frame. Van Engelen's argument is misplaced. Lee does not
rely on its own specification to demonstrate that van Engelen claims 4, 7 and 10 would have been
obvious over van Engelen claims 3, 6 and 9 in view of Schutten. To the extent that van Engelen
is arguing that its claims should not be added to the interference since Lee cannot support such a
claim, that argument is also rejected. It is of no moment that Lee may or may not have support
for a force actuator system. A party moving to designate an opponent's claim as corresponding
to the count, need demonstrate that the claim defines the same patentable invention as any one
claim designated as corresponding to the count. Absent from that requirement is that the movant
must also demonstrate that it has written description support for the opponent's claim. The query
is not can the movant support such a claim, but rather does the claim define the same patentable
invention as a claim already designated as corresponding to the count.
Van Engelen argues that Lee '820 fails to teach a compensation force between two
frames. As stated above, we do not interpret van Engelen's claims 4, 7 or 10 to require a force
actuator system that exerts a compensation force between two frames. In any event, Lee did not
rely on the Lee '820 patent to teach a force actuator system that exerts a compensation force
between two frames. Rather, Lee alternatively relied on the '820 patent to show an actuator
system that compensates for movement of two stages, as opposed to one stage.
Van Engelen argues that Schutten fails to disclose a compensation force between two
frames and exerted on a reference frame. As discussed above, when properly construed, van
Engelen's claims 4, 7 and 10 do not require that the force actuator system exert a compensation
force between two frames. However, even if van Engelen claims 4, 7 and 10 do require a force
actuator system that exerts a compensation force between two frames, van Engelen has failed to
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