demonstrate that it would not have been obvious to combine the Schutten actuator system to a
two frame system.
Schutten discloses a force actuator system, with force actuators 74, 76 in between the
ground and a work table (frame). Thus, Schutten discloses a force actuator in between two
structures. Van Engelen has failed to sufficiently demonstrate that one of ordinary skill would
not look to Schutten to teach placing force actuators in between two frames. Specifically, van
Engelen fails to explain why Schutten's force actuators would not work in between two frames.
Schutten teaches a force actuator system for compensating for forces acting on the frame
(stage/table), or for tilting of the frame and for movement of the stage. Based on the record
before us, such a system teaches a compensation system regardless of whether that system is
placed in between two frames, or in between a frame and the ground. Note, absent from van
Engelen's claims 4, 7, and 10 is a requirement that the compensation force compensate for
reaction forces in a second frame. Rather the claims recite that the compensation force
compensate for forces of gravity acting on the object table (substrate table/mask table). Schutten
apparently compensates for such forces. Van Engelen has failed to direct us to evidence that
demonstrates otherwise.
Van Engelen argues that the prior art fails to disclose a compensation force exerted in
response to gravity forces on two moving stages as recited in claim 10 (opposition at 20). Claim
10 recites that the mechanical moments of the forces of gravity for both the mask table and
substrate table are added in determining the opposing compensation force exerted on the
reference frame. Van Engelen argues that Schutten only provides background information and
does not teach a compensation force in response to gravity forces exerted on a substrate stage and
a mask stage (opposition at 21). Van Engelen's response is dissatisfying.
In its preliminary motion, Lee explains that van Engelen claim 9 recites that the mask
table and the substrate table are both supported on a common frame - the reference frame. The
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