physically contact the illuminator (radiation source). In the'558 summary of the invention
description, it is explained how there are two frames - a support frame (machine frame), for
supporting the photolithography apparatus projection lens and associated structures, and a reticle
stage mechanism support frame, also referred to as the independent support structure, for
supporting the reticle stage drive motors and the window frame drive motors (Ex. 2036 at 3, lines
27-36).
The Lee '558 specification describes the independent support structure 80 as providing
the advantage of transmitting reaction forces away from "the frame supporting the other elements
of the photolithogaphy aparatus" (emphasis added) (Ex. 2036 at 9, lines 17-21). The support
structure 80 is described as supporting the fixed guides 46A, 4613, 64A 64B and the window
guide members 40A, ..., 40D. The "other elements of the photolithography apparatus" are
supported by the other frame - the machine frame 94. Figure 4 shows the supporting structure for
the entire photolithography system. Figure 5 is a side view of Figure 4. Since the illuminator 90,
shown in Figure 5, is part of the elements supported by the support structure shown in Figure 4,
then illuminator 90 must be supported by either of the two frames shown in Figure 4. Since the
specification states that only the reticle stage mechanism is supported by 80, the remaining
elements, including illuminator 90 must be supported by 94. Still further, there is no discussion
throughout the Lee '558 specification of mounting any of the instruments or components of the
disclosed mechanism anywhere other than on the reaction frame or on the support frame.
Van Engelen's sparse discussion of what the '558 specification shows is not sufficient to
meet its burden of proving that the '558 specification fails to describe a radiation source that is
supported by a (machine) frame. Van Engelen should have discussed the specification in greater
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Last modified: November 3, 2007