In its opposition, van Engelen argues that since van Engelen claims I and I I require that
the first frame and the second frame be dynamically isolated (i.e., isolated with dynamic isolators
in between the two frames), and that the force actuator system of van Engelen claims 5, 13, 15,
and 16 is defined in van Engelen's specification as being integrated with the dynamic isolators,
then the compensation force recited in claims 5, 13, 15 and 16 must be between the two frames
and exerted on the first frame (opposition at 15-16).
Van Engelen's claim interpretation is erroneous. Van Engelen necessarily reads
limitations into its claims I and 11 that are not present. Note, that neither of van Engelen claims
I and I I provides any relationship between the function of "dynamically isolated" frames arid the
force actuator system. Furthermore, as discussed in connection with van Engelen preliminary
motion 8, one frame that is "dynamically isolated" from another frame does not mean that there
are necessarily dynamic isolators in between the two frames. Van Engelen's independent claims
I and 11 recite a relationship between the two frames, but do not recite any particular structure
associated with that relationship. Even if we were to interpret van Engelen claims I and I I to
require dynamic isolators in between the two frames, it does not necessarily follow that the force
actuator system must also be in between the two frames. Claims 5, 13, 15, and 16 recite a force
actuator system which exerts a compensation force on the first frame (machine frame). Absent
from van Engelen claims 5, 13, 15, and 16 is a requirement that the force actuator system be in
between the claimed first frame and the second frame (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 first frame (machine frame).
Van Engelen argues that Lee's involved specification fails to disclose a compensation
force between the first and second frame (opposition at 17). Van Engelen's argument is
misplaced. Lee does not rely on its own specification to demonstrate that van Engelen claims 5,
13, 15, and 16 would have been obvious over van Engelen claims 1, 2, 3, and I I in view of
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Last modified: November 3, 2007