Ex Parte LEE - Page 22





                scope of the count with respect to two frames that are "dynamically isolated" when that term is                                      
                correctly interpreted.                                                                                                               
                        A machine frame which ...        sgpports in that order a radiation source                                                   
                        Lee claim 4 recites a machine frame which, seen parallel to a vertical Z-direction,                                          
                supports in that order a radiation source, a mask holder, a focusing system, etc. Van Engelen's                                      
                only argument, with respect to the '558 application, is that the illuminator 90 shown in Fig. 2 and                                  
                Fig. 5, does not indicate that there is any means of support for the illuminator or a description of                                 
                any particular order for such support with respect to any other element of the illustrated device                                    
                (motionatl7). Van Engelen fails to sufficiently discuss the remaining '558 application in any                                        
                manner to make its case.                                                                                                             
                        Lee '558 Fig. 2 shows an illuminator 90 above reticle 24. Central aperture 30, below the                                     
                reticle allows for the passage of light to the projection lens below. The order of the elements are                                  
                described throughout the '558 application. (See for example, page 5, lines 22-29). It is clear                                       

                from the '558 specification that the illuminator 90 is above all of the other elements. That is,                                     
                when seen parallel to a vertical Z-direction, the radiation source is the first in the order of                                      
                elements.                                                                                                                            
                        The van Engelen '558 specification does not explicitly state that the illuminator is                                         
                supported by a first frame, i.e., the machine frame. However, when considering the entire '558                                       
                specification, it is apparent that the elements shown in the figures must be supported by either                                     
                one of two frames, and that the radiation source (illuminator) is supported by the machine frame.                                    
                        As correctly noted by van Engelen, the term "support" means to bear the weight of an                                         
                object. Thus, the machine frame need only bear the weight of the illuminator. It need not                                            

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Last modified: November 3, 2007