Ex Parte LEE - Page 25





                  and 68B. The magnetic tracks 70A and 70B are mounted on window frame guide members 40C                                             
                  and 40D respectively. The motor coils 68A and 68B are mounted on the reticle stage 10. The                                         
                  magnetic tracks 62A and 62B are mounted on fixed guides 64A and 64B respectively. The coils                                        
                  60A and 60B are mounted on guide members 40A and 40B respectively. The guide members                                               
                  40A-40D and the fixed guide members 64A and 64B are fastened to support structure 80 and                                           
                  114A-114D (first frame). The drive tracks cooperate with the drive coils to move the reticle                                       
                  stage. At least the drive tracks satisfy the limitation of a stationary part of the drive unit which is                            
                  fastened to a first frame as follows.                                                                                              
                          There are two parts to a motor: a stator and a rotor. A stator is defined as the stationary                                
                  part of a machine, such as a motor, and the rotor is defined as the rotating part (Webster's H New                                 
                  Riverside University Dictionary, Copyright 1988 (definitions attached)). A linear motor is                                         
                  defined as an electric motor that has in effect been split and unrolled into two flat sheets, so that                              
                  the motion between the rotor and stator is linear rather than rotary. (McGraw-Hill Dictionary of                                   
                  Scientific and Technical Terms - Fifth Edition, copyright 1994 (definition attached)). In the                                      
                  context of a linear motor, the rotor does not rotate, but rather moves in a linear fashion. The                                    
                  stator is that part of the motor which remains stationary relative to the rotor.                                                   
                          Lee describes a linear motor where the stationary parts of the motor, or the stator of the                                 
                  motor is understood to be the X and Y drive tracks. Thus, the '558 application describes a                                         
                  stationary part of the drive unit. Furthermore, the X and Y drive tracks, or stators are attached to                               
                  the first frame 80, 114A-1 14D through the guides, and are thus, fastened to the first frame.                                      
                          From the above, the '558 application describes an enabling embodiment within the scope                                     
                  of the count. Based on the record before us, van Engelen has failed to direct us to evidence that                                  

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