16. Wakalopulos' argues that the phrase "moveable member manipulating objects in a plurality
of directions within the reactive volume wherein the manipulated objects are sterilized" is
not described in Wakalopulos' specification. Paper 21, p. 6.
17. Wakalopulos says
[i]t is generally understood that the expression "moveable member
manipulating objects" refers to any device or apparatus capable of moving or
manipulating objects.
Paper 21, p. 6.
18. Wakalopulos does not provide any evidence supporting the alleged general understanding.
19. Wakalopulos also argues that "plurality of directions" means a multitude of directions. Paper
21, pp. 6-7.
20. In Wakalopulos' view the Bilstad application only describes linear or unidirectional
manipulation of objects, not manipulation in a multitude, i.e. "a plurality," of directions.
Paper 2 1, pp. 7-11.
21. hiresponse, Bilstad identifies variousportions of the specification saidto provide descriptive
support for the limitation. Paper 28, p. 6, 16.
22. With particular reference to Bilstad Figures 1, 2 and 3A-3D, and 5A-5D Bilstad argues that
these figures along with the corresponding portions of the specification describing the figures
demonstrate a specific embodiment of the invention:
These different Figures are interrelated, and together illustrate members
manipulating objects in a plurality of directions within an e-beam field."
Paper 28, p. 8 (emphasis added).
23. Bilstad argues that plurality means "two or more." Paper 28, p. 6, 14.
24. Bilstad argues that the Bilstad specification shows an apparatus which manipulates objects
in three directions which is said to be a "plurality of directions." Paper 28, pp. 8-11.
25. As part of the argument, Bilstad accepts the meaning of "moveable member manipulating
objects" asserted by Wakalopulos:
Wakalopulos argues that this language is "generally understood" to
mean "... any device or apparatus capable of moving ormanipulating objects
[Emphasis added]." (Wak. Motion 1, page 6, first line of second full
paragraph). Accepting this definition, Bilstad can show disclosure for a
-5-
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