Ex Parte Lee

Board of Patent Appeals and Interferences

Dec 4, 2003

09449762 (B.P.A.I. Dec. 4, 2003)

ppý
0
The opinion in support of the decision being
entered today is not binding precedent of the Board.
Paper 130
Filed by: Trial Section Merits Panel
Mail Stop Interferences
P.O. Box 1450 Filed
Alexandria, VA 22313-1450 4 December 2003
Tel: 703-308-9797
Fax: 703-305-0942
UNITED STATES PATENT AND TRADEMARK OFFIC MAILED
BEFORE THE BOARD OF PATENT APPEALS DEC 4 - 2003
AND INTERFERENCES
PAT 11 TM. OFFICE BOARD Or PATFNT APPEALS
AND INTERFERENCEb
GERARD VAN ENGELEN, CORNELIS D. VAN DIJK, mi
JOHANNES M. M. VAN KIMMENADE, and JAN VAN EIJK
Junior Party,
(Patent 5,844,666),
V.
MARTIN E. LEE,
Senior Party,
(Application 09/449,762).
Patent Interference No. 104,814
Before LEE, LANE, and MEDLEY, Administrative Patent Judges.
MEDLEY, Administrative Patent Judge.
DECISION ON PRELIMINARY MOTIONS AND JUDGMENT
A. Introduction
This interference was declared on April 17, 2002. The interference is related to 104,813.
In this interference, Van Engelen has filed preliminary motions I and 2 under Rule 633(a) for
judgment against Lee on the ground that Lee claims 4-6 are unpatentable under 35 U.S.C. § 112,
11 for lack of written description support for certain claim terms, or alternatively that claims 4-6
are indefinite under 35 U.S.C. § 112, 12, or that there is no interference-in-fact (Papers 46 and
47). Van Engelen has filed a preliminary motion 3 under 37 CFR § 1.633(a) forjudgment
against Lee on the ground that Lee claims 4-6 are unpatentable under 35 U.S.C. § 112, 11 for
failing to provide an enabling disclosure for those claims (Paper 48). Through its preliminary
motion 8, van Engelen attacks the benefit granted Lee (Paper 53). Van Engelen, through its
preliminary motion 6, moves for benefit of an earlier van Engelen European application (Paper
51).
Through its preliminary motion 4, Van Engelen seeks to undesignate its claim 12 and Lee
claim 5 from corresponding to the count (Paper 49). Contingent upon the granting of that
motion, through its preliminary motion 5, van Engelen seeks to add to the interference a count 2
(Paper 50). Van Engelen moves for benefit of proposed count 2 (Paper 52, preliminary motion
7), and moves to deny Lee benefit of its earlier applications with respect to count 2 (Paper 54,
preliminary motion 9). Lee preliminary motions 8 and 12 (Papers 64 and 68) are also ultimately
contingent on the granting of van Engelen preliminary motion 4.
Lee filed preliminary motion 6 (Paper 51), for judgment against van Engelen on the
ground that van Engelen claim 12 is indefinite under 35 U.S.C. § 112, ý 2. Van Engelen filed
three responsive motions; miscellaneous motion 10 for entry of a certificate of correction for its
claim 12 (Paper 62), preliminary motion I I to file a reissue application to correct the error in
claim 12 (Paper 61 1/2), and preliminary motion 12 for benefit of an earlier application for its
reissue application (Paper 62 Y2).
-2-
In Lee preliminary motion 2% Lee requests that van Engelen claims 5-9, 13-16, and 18-22
be designated as corresponding to the count (Paper 39). Lee has filed several preliminary
motions under 37 CFR § 1.633(a), seeking judgment against van Engelen on the ground that van
Engelen's involved claims 1-3 and 10-12, and claims 5-9, 13-16, and 18-22 that Lee seeks to
designate as corresponding to the count are unpatentable under 35 U.S.C. §§ 102/103 based on
various prior art (Papers 40, 41, and 44). Lee has filed preliminary motion 5 seeking to be
accorded the benefit of earlier Lee applications. Lee has filed contingent preliminary motions to
(1) add claims 7-9 to its involved application (preliminary motion 9), (2) substitute the count
(preliminary motion 10), and (3) be accorded priority benefit as to the new count (preliminary
motion 11).
According to the junior party van Engelen's preliminary statement, van Engelen does not
allege a date that is earlier than the senior party Lee's effective filing date.
Oral argument was held on 29 April 2003. During oral argument counsel for van Engelen
withdrew van Engelen preliminary motion 3 (Paper 129 at 84, line 25 to page 86, line 2).
For the reasons that follow, van Engelen preliminary motions 1, 2, 4, and 8 are denied.
Van Engelen preliminary motion 6 is grante . Lee preliminary motion 2 is granted. Van
Engelen preliminary motions 3, 5, 7, 9-12, and Lee preliminary motions 3-12 are dismissed, and
judgment is entered against van Engelen.
B. Findings of fact
1. Van Engelen is involved on the basis of Patent 5,844,666 ('666), granted I December
1998, based on application 08/642,014, filed 2 May 1996.
Lee miscellaneous motion 1 to disqualify van Engelen's counsel was denied (Paper 34).
-3-
2. Lee is involved on the basis of application 09/449,762, filed 26 November 1999.
3. Lee has been accorded benefit for the purpose of priority of application 09/192,153,
filed 12 November 1998 and application 08/416,558, filed 4 April 1995.
4. Van Engelen real party in interest is ASML Netherlands, B.V.(Paper 9).
5. Lee real party in interest is Nikon Corporation (Paper 4).
6. Count 1, the sole count of the interference, is as follows:
Claim 4 of 09/449,762
or
Claim 10 of 5,844,666
7. Lee claim 4 is as follows:
A lithographic device with a machine frame which, seen parallel to a vertical Z
direction, supports in that order a radiation source, a mask holder, a focusing system with
a main axis directed parallel to the Z-direction, and a substrate holder which is
displaceable perpendicularly to the Z-direction by means of a positioning device, the
positioning device of the substrate holder including an object table and a drive unit by
which the object table is displaceable over a guide parallel to at least an X-direction,
which guide is fastened to a first frame of the positioning device while a stationary part of
the drive unit is fastened to a second frame of the positioning device which is
dynamically isolated from the first frame, wherein the first frame of the positioning
device of the substrate holder belongs to the machine frame of the lithographic device,
while the second frame of the positioning device of the substrate holder belongs to a force
frame of the lithographic device which is dynamically isolated from the machine frame;
and wherein a reaction force exerted by the object table on the drive unit during operation
and arising from a driving force exerted by the drive unit on the object table is
transmittable exclusively into the second frame.
8. Claim 10 of van Engelen is as follows:
A lithographic device with a machine frame which, seen parallel to a vertical Z
direction, supports in that order a radiation source, a mask holder, a focusing system with
a main axis directed parallel to the Z-direction, and a substrate holder which is
displaceable perpendicularly to the Z-direction by means of a positioning device, the
positioning device of the substrate holder, including an object table and a drive unit by
-4-
0
which the object table is displaceable over a guide parallel to at least an X-direction,
which guide is fastened to a first frame of the positioning device while a stationary part of
the drive unit is fastened to a second frame of the positioning device which is
dynamically isolated from the first frame, wherein the first frame of the positioning
device of the substrate holder belongs to the machine frame of the lithographic device,
while the second frame of the positioning device of the substrate holder belongs to a force
frame of the lithographic device which is dynamically isolated from the machine frame;
and wherein a reaction force exerted by the object table on the drive unit during operation
and arising from a driving force exerted by the drive unit on the object table is
transmittable exclusively into the second frame.
10. The claims of the parties are:
Van Engelen: 1-22
Lee: 1-6
11. The claims of the parties which correspond to Count I are:
Van Engelen: 1-3 and 10-12
Lee: 1-6
12. The claims of the parties which do not correspond to Count I are:
Van Engelen: 4-9 and 13-22
Lee: none
9. The level of ordinary skill in the art is defined by the prior art references made of
record.
C. Decision
Van Engelen preliminM motions 1 and 2
Van Engelen preliminary motions 1 and 2 are for judgment against Lee on the basis that
Lee's claims 4-6 are unpatentable under 35 U.S.C. § 112, T 1, or are indefinite under 35 U.S.C.
§ 112, 12, or that there is no interference-in-fact. As the movant van Engelen bears the burden
to demonstrate that it is entitled to the relief sought. 37 CFR § 1.637(a).
-5
MMMMMý
Written Description
Van Engelen argues that Lee's specification fails to provide support for (1) a second
frame that is "dynamically isolated" from a first frame (motion 1), (2) a machine frame which,
seen parallel to a vertical Z-direction, supports in that order a radiation source (motion 2) and (3)
a stationary part of the drive unit fastened to a second frame (motion 2).
Lee claims 4 and 6 are original claims that were filed the day the involved '762
application was filed. Lee claims 4 and 6 recite all of the limitations that van Engelen asserts are
not described in Lee's specification. Lee claim 5 depends from claim 4 and was amended.
However, the limitations that van Engelen asserts that the Lee '762 application does not describe
are in Lee claims 4 and 6 and not in amended Lee claim 5.
It is well established that original claims, in unamended form are a part of the original
specification as filed. See In re Koller, 613 F.2d 819, 823, 204 USPQ 702, 706 (CCPA 1980); in
re Gardner, 475 F.2d 1389, 1391, 177 USPQ 396, 397 (CCPA 1973). To the extent that van
Engelen is relying on the specification of Lee's parent applications to make the argument that the
involved Lee specification does not provide written description support for Lee claims 4-6 under
35 U.S.C. § 112, first paragraph, that is improper. See Reiffin v. Microsoft, 214 F.3d 1342,
1346, 54 USPQ2d 1915, 1918 (Fed. Cir. 2000). Accordingly, that portion of van Engelen's
preliminary motions I and 2 seeking judgment against Lee on the basis that Lee's involved
claims 4-6 lack written description support under 35 U.S.C. § 112, 11 is denied.
Indefiniteness
Van Engelen additionally argues that Lee's claims 4-6 are unpatentable under 35 U.S.C.
§ 112, T 2. Van Engelen argues that should the board determine that Lee's claims 4-6 are
-6-
ambiguous, any attempt to resolve the ambiguity only emphasizes the inconsistency between the
claim language and the '762 specification (motions 1 and 2 at 15, motion 3 at 17).
Van Engelen makes no real attempt to explain or prove that the involved claims 4-6 are
ambiguous in the first place. Van Engelen seems to invite the panel to make an independent
determination that the claims are ambiguous. We decline the invitation. It is the role of advocate,
not judge, to present a detailed analysis as to why the claims are, on their face, ambiguous. Van
Engelen bases the rest of its discussion on a presumption that the claims are ambiguous, and
discusses why Lee's involved specification fails to resolve the ambiguity. However, even that
analysis is flawed.
Van Engelen argues that Lee's application is devoid of a (1) discussion of how the frames
are "dynamically isolated" from one another (motion 1), (2) description of a machine frame
which, seen parallel to a vertical Z-direction, supports in that order a radiation source (motion 2),
or (3) description of a stationary part of the drive unit fastened to a second frame (motion 2). In
essence, Van Engelen argues that Lee's claims 4-6 are not enabled or described, and thus are
indefinite. However, the written description requirement and the enablement requirement are
separate and distinct from the definiteness requirement. "Definiteness and enablement are
analytically distinct requirements." Process Control Corp, v. Hydgeclaim Corp., 190 F.3d 1350,
1358 n.2, 52 USPQ2d 1029, 1034 n.2 (Fed. Cir. 1999). Even if the written description does not
enable the claim, the claim language itself may still be definite. Union Pac. Res. Co. v.
ChesMeake Enerpgy CoM., 236 F.3d 684, 692, 57 USPQ2d 1293, 1297 (Fed. Cir. 2001). Since
van Engelen has failed to apply the correct standard and sufficiently demonstrate that Lee claims
4-6 are indefinite, this part of van Engelen motions I and 2 is denied.
-7-
No interference-in-fact
Van Engelen argues that if Lee's claims are definite and are supported by Lee's
specification, then there is no interference-in-fact between Lee and van Engelen. Van Engelen,
in its preliminary motion 1, page 18, argues that Lee's claims should be interpreted such that the
"dynamically isolated" frames are physically isolated frames, which is in contrast with van
Engelen's "dynamically isolated" frames which are physically interconnected with a dynamic
isolator. Likewise, in its preliminary motion 2, page 23, van Engelen argues that when the van
Engelen and Lee claims are interpreted in light of the respective specifications, the parties'
claims are limited by their respective specifications, which describe different architecture for the
stationary part of the drive unit that is fastened to the second fi7ame (motion 2 at 23). Van
Engelen, in interpreting the nearly identical involved claims, proposes to import limitations into
the respective parties' claims. The specific structure that van Engelen imports from the
respective specifications is not recited in the parties' claims. For example, Lee claims 4 and 6
recite a relationship between two frames - that the frames are dynamically isolated, and not a
specific structure, as further discussed infra.
In any event, van Engelen fails to sufficiently demonstrate that even if the respective
parties' claims require the structure van Engelen urges that they do, that there is no interference
in-fact. Van Engelen argues that "assuming that the '762 application is prior art to the '666
patent, the disclosure in the '762 application does not anticipate or render obvious van Engelen's
'666 patent. Likewise, the '666 patent does not anticipate or render obvious the properly
construed claims of the '762 application" (motion I at 19, motion 2 at 23). Van Engelen's
-8-
conclusory statement falls far short from providing a detailed analysis required to demonstrate
that there is no interference-in-fact.
Van Engelen must demonstrate that no one claim of Lee claims the same patentable
invention as any one claim of van Engelen, or that no one claim of van Engelen claims the same
patentable invention as any one claim of Lee.
The definition of "same patentable invention" is set out in 37 CFR § 1.601(n) and is as
follows:
Invention "A" is the same patentable invention as an invention "B" when invention "A"
is the same as (35 U.S.C. 102) or is obvious (35 U.S.C. 103) in view of invention "B"
assuming invention "B" is prior art with respect to invention "A". Invention "A" is a
separate patentable invention with respect to invention "B" when invention "A" is new
(35 U.S.C. 102) and non-obvious (35 U.S.C. 103) in view of invention "B" assuming
invention "B" is prior art with respect to invention "A".
The proper analysis in determining that there is an interference-in-fact between the
parties' claims is a two-way "same patentable invention" analysis. The claimed invention of
Party A is presumed to be prior art vis-a-vis Party B and vice versa. See Eli Lilly v. Regents of
the Univ. Wash., 334 F.3d 1264, 67 USPQ2d 1161 (Fed. Cir. 2003).
The proper analysis then in determining that there is no interference-in-fact between the
parties' claims is a one-way analysis. Thus, van Engelen need only demonstrate that (1) no one
claim of Lee anticipates or renders obvious a claim of van Engelen or (2) no one claim of van
Engelen anticipates or renders obvious a claim of Lee. The moving party should discuss the
relevant prior art and explain why the prior art does not teach or suggest the modifications of the
one party's claims (e.g., van Engelen's claims) in view of the other party's claims (e.g., Lee's
claims).
-9-
Van Engelen makes no meaningful attempt to explain why Lee's claims are separately
patentable in view of van Engelen's claims or vise versa. It is not enough to point out differences
and conclude that there is no interference-in-fact. Nor is it meaningful to argue that one party's
specification is separately patentable over the other parties specification, or that one party's
claims are separately patentable over the opponents specification. The appropriate comparison is
between the claims and not the disclosures. For all of these reasons, van Engelen has failed to
sufficiently demonstrate that there is no interference-in-fact. Van Engelen preliminary motions I
and 2 are denied.
Van EnRelen preliminary motion 3
During oral argument, counsel for Van Engelen withdrew van Engelen preliminary
motion 3 from consideration (Paper 128 at 84-85). Accordingly, van Engelen preliminary
motion 3 is dismissed.
Van Engelen 12reliminM motion 4
Van Engelen moves to undesignate van Engelen claim 12 and Lee claim 5 from
corresponding to the count. Van Engelen claim 12 is reproduced below:
12. A lithographic device as claimed in claim 10, wherein the mask holder is
displaccable perpendicularly to the Z-direction by means of said positioning device as
claimed in wherein the first frame of the positioning device of the mask holder belongs to
the machine frame of the lithographic device, while the second frame of the positioning
device of the mask holder belongs to the force frame of the lithographic device.
Lee claim 5 is as follows:
5. A lithographic device as claimed in claim 4, wherein the mask holder is displaceable
perpendicularly to the Z-direction by means of a mask holder positioning device that is
similar to the positioning device of the substrate holder, and wherein a first frame of the
mask holder positioning device belongs to the machine frame of the lithographic device,
-10-
while a second frame of the mask holder positioning device belongs to the force frame of
the lithographic device.
A party moving to undesignate a claim from corresponding to the count must demonstrate
that the claim does not define the same patentable invention as any other claim whose
designation in the notice declaring the interference as corresponding to the count the party does
not dispute. 37 CFR § 1.637(d)(4)(ii).
As pointed out by van Engelen in its preliminary motion, Lee claim 5 and van Engelen
claim 12 are nearly identical, and depend from nearly identical claims 4 and 10 respectively. As
Van Engelen's analysis is limited with respect to Lee claim 5, so is ours. In its preliminary
motion 4, van Engelen argues that none of the claims render obvious the invention defined by
Lee claim 5 (motion at 11). Van Engelen compares Lee claim 5 with Lee claim 4 and Lee claim
6. Specifically, van Engelen argues that neither claim 4, nor claim 6, nor the combination of Lee
claim 4 and claim 6 teaches the device recited in claim 5, and then proceeds to discuss the
differences between Lee claims 4, 5 and 6. Van Engelen then concludes that since the examiner
determined that the count is patentable over the prior art of record, then Lee claim 5 is also
patentable over the prior art of record (motion at 13).
It is not enough to assert that there is no teaching in the compared claim that would lead
to the claim the party seeks to undesignate, as van Engelen has done here. Absent from the
preliminary motion is a demonstration that van Engelen is unaware of any prior art that would
render Lee claim 5 obvious in view of Lee claim 4 or Lee claim 6, or if it is aware of prior art
that is relevant, that the prior art would not, when combined with Lee claim 4 or Lee claim 6,
- 11 -
render obvious Lee claim 5, all consistent with the moving party's duty of disclosure under 37
CFR § 1.56.
Moreover, van Engelen's argument that since the count is patentable over the prior art of
record, then Lee claim 5 is also patentable over the prior art of record, and should therefore be
undesignated as corresponding to the count is based on a flawed premise. It does not follow that
if the count is patentable over the prior art of record, then the claim van Engelen seeks to
undesigDate is separately patentable from the count. If that were the test, then no claim would
ever be designated as corresponding to a count. The analysis is made with the premise that the
claim being compared is prior art. That is the starting point. It is firom that point that the analysis
is made with respect to obviousness. That is, van Engelen should have demonstrated that given,
for example Lee claim 4, that Lee claim 5 would not have been obvious in view of Lee claim 4
and any known prior art.
That analysis would include a discussion of at least those references that would appear to
be relevant and that were disclosed in either of Lee's involved application or van Engelen's
involved patented file. Van Engelen's discussion centers around the fact that neither Lee claim 4
nor Lee claim 6 teach a mask holder and a substrate holder that are connected, in-part, to a
common machine frame and, in-part, to a common force frame as recited in Lee claim 5. Van
Engelen argues that claim 5 introduces the concept of a frame shared between the two moving
holders (motion at 12). However, at least Isohata2 made of record in the involved van Engelen
application shows a frame shared between two moving holders. Isohata shows in Fig. 1 a
substrate 6 and a mask 5 supported by common frame 7. We make no determination whether it
2 U.S. Patent 5,359,389, issued 25 October 1994, filed 13 October 1993.
-12-
would have been obvious to employ the Isohata shared frame concept with the system claimed in
Lee claim 4 or Lee claim 6. However, as the movant, van Engelen should have at least discussed
any prior art, like Isohata, that appears relevant to the analysis. Van Engelen's failure to discuss
any prior art known to it, or to allege that it is unaware of any prior art that would render Lee
claim 5 obvious, given Lee claim 4 or Lee claim 6 is critical. Without such a discussion, we will
not simply imagine or suppose that van Engelen is unaware of any prior art that would render Lee
claim 5 obvious in view of Lee claim 4 or Lee claim 6, or that van Engelen is of the opinion that
given Lee claim 6 or Lee claim 4 as prior art, that the closest prior art that it is aware of would
not render Lee claim 5 obvious. To suppose such a fact would be unfair and prejudicial to the
party Lee. Lastly, we note that Lee claim 6 recites "a machine frame which, ... supports ... a
mask holder ... and a substrate holder." Lee claim 6 appears to recite the precise feature that van
Engelen states is "introduced" in Lee claim 5.
For all of these reasons, van Engelen preliminary motion 4 is denied. Since van Engelen
has failed to set forth aprimafacie case for the relief requested, we need not and have not
considered Lee opposition 4.
Van Engelen preliminaa motions 5, 7 and 9 and Lee preliminga motions 8 and 12
Van Engelen moves to add a count 2, identical to Lee claim 5, to the interference
(preliminary motion 5). Van Engelen moves for benefit of proposed count 2 (preliminary motion
7), and moves to deny Lee the benefit of its earlier filed applications with respect to proposed
count 2 (preliminary motion 9). Lee moves to be accorded benefit of van Engelen's proposed
count 2 (preliminary motion 8), or its modified count 2 (preliminary motion 12). Van Engelen
preliminary motions 5, 7 and 9, and Lee preliminary motions 8 and 12 are ultimately contingent
- 13-
upon the granting of van Engelen preliminary motion 4 to undesignate van Engelen claim 12 and
Lee claim 5 from corresponding to the count. Since Van Engelen preliminary motion 4 is denied,
van Engelen preliminary motions 5, 7 and 9, and Lee preliminary motions 8 and 12 are
dismissed.
Van EnRelen preliminM motion 6
Through its preliminary motion 6, van Engelen moves for benefit of European
Application No. 95201409.0 (EP '409), filed 30 May 1995. At the outset, we note that even if
van Engelen preliminary motion 6 is granted, that the 30 May 1995 EP '409 application date is
subsequent to Lee's benefit date of 4 April 1995. We further note, that in its preliminary
statement, the earliest date that van Engelen alleges is 30 May 1995.
The EP '409 application is nearly identical to the involved '666 van Engelen patent. As
pointed out by van Engelen in its motion, claim 10 of the EP '409 application is nearly identical
to, and describes all of the elements of the count, one alternative of which is van Engelen claim
10. Van Engelen further submits a chart in its discussion. The chart is a comparison between the
count and where in the EP '409 application each element of the count is described.
Lee opposes the granting of the motion primarily on the basis that van Engelen failed to
attach an appendix (claim chart) to its motion in accordance with § 21 of the Standing Order, and
that the certification accompanying the translation of the EP '409 application is fatally flawed.
Lee apparently does not oppose the preliminary motion on the merits. For example, Lee is silent
with respect to van Engelen's assertion that the translated claim 10 is nearly identical to the
count. In response to Lee's opposition, Van Engelen, in its reply, filed a corrected certification
and appendix (claim chart).
-14-
Van Engelen's preliminary motion is granted. Lee's arguments are based on
technicalities, that are not, based on the facts before us, fatal to van Engelen's preliminary
motion. Lee does not challenge the accuracy of the translation, but rather challenges the
certification of the translation. That the certificate is vague or ambiguous, does not by itself cast
doubt on the veracity of the actual translation. Lee has failed to direct us to evidence that would
demonstrate that the translation is erroneous. Indeed, Lee does not challenge van Engelen's
assertion that the EP '409 claim 10 discloses every element of the count, and thus demonstrates
that the EP '409 application describes an enabling embodiment within the scope of the count.
Even considering the untranslated EP '409, the figures therein appear identical to the figures in
the involved '666 van Engelen patent.
Although Van Engelen fails to attach a claim chart to its preliminary motion, van Engelen
discusses in detail in its motion, per a claim chart, how each element of the count is supported. It
is of no moment that the claim chart is in the body of the preliminary motion versus being
attached to the preliminary motion as an appendix. In any event, van Engelen has submitted into
the record, as part of its reply, an appendix with a claim chart, and a corrected certification.
Ideally, van Engelen should have complied with the procedures when it filed its preliminary
motion. However, Van Engelen's failure to follow the procedures to the 'T' is not fatal to it's
motion, especially where van Engelen satisfies its burden based on the merits in the first place.
For these reasons, van Engelen preliminary motion 6 is g[anted.
Van Engelen preliminga motion 8
Van Engelen has filed a preliminary motion under Rule 633(g), attacking the benefit
is -
accorded Lee in the notice declaring interference. At the time the interference was declared, Lee
was accorded benefit of application 09/192,153 ('153 application), filed 12 November 1998, now
U.S. Patent 6,246,202, granted 12 June 2001 and application 08/416,558 ('558 application), filed
4 April 1995, now U.S. Patent 5,874,820, granted 23 February 1999.
Van Engelen argues that Lee is not entitled to the benefit of the earlier filing date of the
Lee '558 application, since there is no support for Lee claims 4-6. The '558 application
incorporates by reference, Lee application 08/221,375('375). Lee was not accorded priority
benefit of the '375 application at the time the interference was declared. We note that Lee has
moved to be accorded priority benefit of its '375 application and that motion is addressed infra
in connection with Lee preliminary motion 5.
Van Engelen argues that the '558 application ineffectively incorporates by reference the
'375 application, or alternatively incorporates only a specific portion of the '375 application that
fails to describe certain ones of the claimed features in Lee claims 4-6. Alternatively, van
Engelen argues that neither the '375 application nor the '558 application, standing alone, provide
written description support for Lee's claims.
A party moving to attack the benefit accorded an opponent bears the burden of proof to
demonstrate, as to the count, why the opponent should not be accorded the benefit of the filing
date of the earlier application. 37 CFR § 1.637(a) and 37 CFR § 1.637(g). Weil v. Fritz, 572
F.2d 856, 865-66 n. 16, 196 USPQ 600, 608 n. 16 (CCPA 1978); Hunt v. Treppschuh, 523 F.2d
1386, 1389, 187 USPQ 426, 429 (CCPA 1975). In order to be accorded benefit, the '558
application need only describe an enabling embodiment within the scope of the count, Thus, it is
not necessary that the '558 application provide written description support for Lee's claims 4-6.
-16-
Accordingly, we address van Engelen's arguments only with respect to van Engelen claim 4,
which is an alternative of the count.
There is yet another flaw in the arguments advanced by van Engelen. Although van
Engelen takes the position that the '558 application fails to provide support for Lee claim 4, with
or without incorporating by reference the '375 application, van Engelen fails to discuss the '558
application with particularity with respect to at least one of the features it alleges is not supported
in the '558 application. Although Van Engelen discusses the '375 application in detail, the
inquiry should begin with what the '558 application describes. That is the application for which
Lee was accorded benefit. Until it is determined what the '558 application describes, there is no
need to look to the '375 application. The issue of incorporation by reference is moot, if the '558
application alone describes an enabling embodiment within the scope of the count.
Since van Engelen has failed to sufficiently demonstrate, that the '558 application,
standing alone, fails to describe an enabling embodiment within the scope of the count we need
not determine if the Lee '558 application has effectively incorporated by reference the '375
application, or determine if the '375 application describes an enabling embodiment within the
scope of the count. Our discussion pertains to what is set forth in the '558 application and not
the '375 application.
Dynamically isolated frames
Lee claim 4 (an alternative of the count) recites a first frame and a second frame. The
claim recites that the second frame is dynamically isolated from the first frame. Van Engelen
argues that the '558 application fails to describe a second frame that is dynamically isolated from
17-
a first frame (motion at 17). At the heart of van Engelen's argument is the meaning of the term
"dynamically isolated."
Van Engelen argues that the '558 application fails to support the broadest reasonable
interpretation of "dynamically isolated." The broadest reasonable interpretation of "dynamically
isolated", van Engelen argues, comes by way of definition for the terms isolated and dynamically.
Van Engelen argues that:
The term isolated is a verb which means "separate from a group or whole and set
apart." (Exh. 2015: Definition, page 956). The term "dynamically" is the adverbial form
of the word "dynamic", which is defined as being "[c]haracterized by continuous change,
activity, or progress." (Exh. 2016: Definition, page 574). Thus, in the context of the
claim language, the term "dynamically" is modifying how the second frame is "isolated"
from the first frame. The broadest reasonable meaning of these words requires that the
second frame be isolated from the first frame in a manner that is characterized by
continuous change, activity orprogress.
There is nothing in either the '375 or '558 application that shows such an
invention. To the extent that the '375 application or the '558 application discloses
separating the reaction frame from the XY stage support frame, that separation is not
characterized by continuous change, activity or progress but is static, physical isolation.
(See Exh. 2012: Kurfess Decl., 152 (regarding '762 application)). In fact, in the '558
application, Lee explains that reaction forces are transmitted independently to the earth's
surface by a structure that is physically isolated from the support frame. (Exh. 2032: '558
Appln., page 3, line 27 - page 4, line 11, page 9, lines 7-25; see also Exh. 2012: Kurfess
Decl., ý 48 (regarding '762 application) (emphasis in original) (motion at 15).
We understand van Engelen's definition of "dynamically isolated" to require that the
frames be isolated dynamically - that there necessarily be something in between the two frames
that provides the isolation, i.e. that the frames be physically interconnected with dynamic
isolatorS3. Van Engelen does not dispute that the '762 application as well as the '558
specification describe physically separate frames. Van Engelen does, however, disagree that two
During oral argument, counsel for van Engelen so represented (Paper 128 at 17-18).
- 18-
physically separate frames are "dynamically isolated" when applying the broadest reasonable
interpretation of that claim term.
Van Engelen's definition of "dynamically isolated" is derived by viewing the term in light
of van Engelen's specification, resulting in an importation of a structural element that is not part
of the count. Van Engelen's definition for dynamically isolated is not the broadest reasonable
interpretation of that term. When the term "dynamically isolated" is properly construed, the Lee
'558 application provides an enabling embodiment within the scope of the count.
Van Engelen's proposed definition of dynamic is the second listed definition, and the
example for that definition is that of a dynamic market (Ex. 2016). Van Engelen provides no
explanation why the term "dynamic" or dynamically should be interpreted under the second
listed definition as opposed to the first definition. Note, that Dr. Kurfess, van Engelen's expert,
provides no explanation as to why the proposed second definition is what one of ordinary skill in
the art would understand the definition to be (Ex. 2012 ý 49). Generally, it is the first listed
definition that is the most commonly used definition for a given word. A dynamic market would
appear to have nothing to do with two mechanical frames and the relationship between those two
frames. Furthermore, van Engelen's proposed definition would require a structural element
between the two frames. Lee's claim 4, however, does not recite an element for isolating the two
frames. Rather, the claim merely recites the relationship between the two frames. The
relationship is described by the term dynamically isolated. We will not read limitations into
Lee's claims that would require an element to be in between the two frames. Lee's claim 4 is not
so limiting. Van Engelen's proposed definition is ultimately obtained by looking to its own
specification and importing limitations from its specification into the count. However, the count
- 19-
is Lee claim 4 or van Engelen claim 10. Each alternative of the count is interpreted in light of the
parties' respective involved specifications. The first alternative of the count (Lee claim 4) is
interpreted in light of Lee's involved '762 specification.
With that in mind, a more reasonable interpretation of the term "dynamically isolated"
may be gleaned from the first definition for the word "dynamic" and from Lee's specification.
The first definition for dynamic is "of or relating to energy or to objects in motion" (Ex. 2016).
That definition, on its face, is a more reasonable definition for the term dynamic when considered
in the context of two frames and their relationship. Lee's '762 specification describes two
frames that are isolated from each other, such that the reaction forces from the elements of one
frame are not transmitted to the other frame. That is, the dynamics, e.g., motion, from one frame
are isolated from the other. In this light, and in view of the first definition for the term dynamic,
a more reasonable interpretation of the term dynamically isolated is that the dynamics are
isolated from one frame to the other - that the reaction forces from one frame are not transmitted
to the other frame. Note, that the proposed definition does not necessarily require structure in
between the two frames, but is merely descriptive of the relationship between the two frames.
Lee's involved '762 application supports such an interpretation of "dynamically isolated" frames.
For example, the '762 specification states that:
An additional aspect in accordance with the invention is that the reaction force of the
stage and window frame drive motors is not transmitted to the support frame of the
photolithography apparatus projection lens but is transmitted independently directly to the
earth's surface by an independent supporting structure. Thus, the reaction forces caused
by movement of the stage do not induce undesirable movement in the projection lens or
other elements of the photolithography machine (Ex. 2011 at 3, lines 4-9).
-20-
The above indicates that reaction forces, e.g., dynamics of the one frame, are not
transmitted to the other frame and are therefore "dynamically isolated." This definition for
dynamically isolated, that the reaction forces are isolated, is a more reasonable interpretation of
the term "dynamically isolated" given the description in Lee's '762 specification and the first
listed definition for dynamic as previously discussed. Van Engelen's definition of "dynamically
isolated", in contrast, is derived from van Engelen's involved specification, and by importing an
element into Lee's claim 4 that simply is not claimed. To the extent that the second alternative of
the count, i.e., van Engelen's claim 10, should be interpreted to mean that there are necessarily
"dynamic isolators" in between the two frames does not mean that Lee's claim 4, the first
alternative of the count should also be interpreted the same way. The count is the disjunctive
alternative of Lee claim 4 and van Engelen claim 10. Lee '558 need only describe an enabling
embodiment within the scope of the count, e.g., Lee claim 4. It need not describe an enabling
embodiment for both alternatives of the count.
Van Engelen fails to discuss with any particularity what the '558 application describes,
and because of that, its argument is not persuasive. However, we note, that the '558 application
describes a first frame (80 and 114A- I 14D), and a second frame (94 and 102A-I 02D) that are
physically isolated, such that reaction forces from one frame are isolated from the other frame.
As discussed above, when properly interpreted, the '558 application thus describes two frames
that are dynamically isolated. Van Engelen has failed to demonstrate otherwise. Accordingly,
we are not persuaded that van Engelen has satisfied its burden of proof to sufficiently
demonstrate that Lee's '558 application fails to describe an enabling embodiment within the
-21-
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
-22-
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
-23-
detail and should have discussed what one of ordinary skill in the art would have understood
from reading the specification and looking to the figures. Satisfaction of the written description
requirement does not require the description of claim terms to be ipsis verbis antecedent in the
originally filed application. In re Lukach, 442 F.2d 967, 969,169 USPQ 795, 796 (CCPA 1971).
It is what the specification would have conveyed to one of ordinary skill in the art as to what the
inventors possessed at the time of the invention. Based on the record before us, the '558
specification supports a radiation source supported by a machine frame.
A stationM part of the drive unit fastened to the first frame
Lee claim 4 recites a drive unit comprising a stationary part which is fastened to a second
frame of the positioning device. Van Engelen argues that Lee '558 fails to provide support for
any stationary part of the drive unit that isfastened to a second frame. Van Engelen provides no
meaningful explanation as to why the '558 application fails to describe a stationary part of the
drive unit that is fastened to a second frame, and thus has failed to meet its burden to demonstrate
that the '558 application fails to describe the claimed feature. Accordingly, we need not
independently make the determination as to whether the '558 application does describe a
stationary part of a drive unit that is fastened to the second frame.
hi any event, we note that the '558 application describes a reticle stage drive unit' that
includes X axis linear motors comprised of magnetic tracks 62A and 62B and magnetic coils
60A and 60B and Y axis linear motors comprised of magnetic tracks 70A and 70B and coils 68A
' We recognize that the '558 application describes an embodiment of a reticle drive unit
for moving a reticle stage and not a wafer stage drive unit for moving a wafer stage. However,
the '558 application states in at least two places that the embodiment described maybe used for
a wafer stage for processing a wafer (substrate) (Ex. 2036, at 3, lines 21-26 and 5, lines 31-33).
-24-
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
-25-
would demonstrate otherwise. In this regard, van Engelen's silence with respect to the '558
application is fatal to its motion.
Since van Engelen has failed to sufficiently demonstrate that the benefit accorded Lee at
the time the interference was declared was in error, we need not consider van Engelen's
arguments that its PCT application, WO 96/38767, filed on 5 December 1996 is prior art to Lee.
Lee has been accorded the benefit of the '558 application, filed 4 April 1995, which is prior to
van Engelen's PCT date.
For all of the above reasons, van Engelen, through its preliminary motion 8, has failed to
sufficiently demonstrate that Lee should be denied benefit of the '558 application. Accordingly,
van Engelen preliminary motion 8 is denied.
Lee preliminary motion 6 and Van Engelen preliminýa motions 10, 11, and 12
An issue in this interference that has generated several preliminary motions, is based on
an alleged error in van Engelen claim 12. Van Engelen claim 12, with the alleged error
underlined, is as follows:
12. A lithographic device as claimed in claim 10, wherein the mask holder is
displaceable perpendicularly to the Z-direction by means of said positioning device as
claimed in wherein the first frame of the positioning device of the mask holder belongs to
the machine frame of the lithographic device, while the second frame of the positioning
device of the mask holder belongs to the force frame of the lithographic device.
Lee seeks judgment against van Engelen on the basis that van Engelen claim 12 is
indefinite under 3 5 U. S.C. § 112, 12. Van Engelen filed a responsive miscellaneous motion 10
for entry of a certificate of correction, to correct the indefiniteness of its claim 12. Van Engelen
also filed a preliminary motion I I seeking to add to the interference a reissue application, in the
-26-
event the certificate of correction was not entered and Lee preliminary motion 6 is granted.
Lastly van Engelen has filed a preliminary motion 12 for benefit of the reissue application.
Van Engelen has failed to allege a date that is earlier than Lee's effective filing date.
Further, van Engelen's preliminary motion 8, attacking the benefit granted Lee is denied.
Accordingly, judgment will be entered against van Engelen. There is then no occasion to
consider Lee preliminary motion 6 or van Engelen contingent motions 10, 11, and 12. For these
reasons, Lee preliminary motion 6, and van Engelen preliminary motions 10, 11, and 12 are
dismissed.
Lee preliminary motion 2
Through its preliminary motion 2, Lee seeks to designate van Engelen claims 5-9, 13-16
and 18-22 as corresponding to the count. Lee discusses van Engelen's claims in five groups of
like features as follows: (1) van Engelen claims 5, 13, 15, and 16; (2) van Engelen claims 6 and
7; (3) van Engelen claims 8, 18, and 19; (4) van Engelen claims 9, 20, 2 1, and 22; and (5) van
Engelen claim 14.
Van Engelen claims 5, 13, 15 and 16
Van Engelen claims 5, 13, 15 and 16 relate to a force actuator system. Van Engelen
claim 5 depends on van Engelen claim 1. Van Engelen claims I and 5 are as follows:
1. A positioning device with an object table and a drive unit by which the object table is
displaceable over a guide parallel to at least an X-direction, which guide is fastened to a
first frame of the positioning device while a stationary part of the drive unit is fastened to
a second frame of the positioning device which is dynamically isolated from the first
frame, wherein a reaction force exerted by the object table on the drive unit during
operation and arising from a driving force exerted by the drive unit on the object table is
transmittable exclusively into the second frame.
5. A positioning device as claimed in claim 1, wherein the positioning device is provided
with a force actuator system controlled by an electric control unit and exerting a
-27-
compensation force on the first frame during operation, which compensation force has a
mechanical moment about a reference point of the first frame having a value equal to a
value of a mechanical moment of a force of gravity acting on the object table about said
reference point and a direction which is opposed to a direction of the mechanical moment
of said force of gravity.
Van Engelen claim 13 depends on van Engelen claim 11. Those claims are as follows:
11. A lithographic device with a machine frame which, seen parallel to a vertical Z
direction, supports in that order a radiation source, a mask holder which is displaceable
perpendicularly to the Z-direction by means of a positioning device, a focusing system
with a main axis directed parallel to the Z-direction, and a substrate holder which is
displaceable perpendicularly to the Z-direction by means of a further positioning device,
the positioning device of the mask holder including an object table and a drive unit by
which the object table is displaceable over a guide parallel to at least an X-direction,
which guide is fastened to a first frame of the positioning device while a stationary part of
the drive unit is fastened to a second frame of the positioning device which is
dynamically isolated from the first frame, wherein the first frame of the positioning
device of the mask holder belongs to the machine frame of the lithographic device, while
the second frame of the positioning device of the mask holder belongs to a force frame of
the lithographic device which is dynamically isolated from the machine frame; and
wherein a reaction force exerted by the object table on the drive unit during operation and
arising from a driving force exerted by the drive unit on the object table is transmittable
exclusively into the second frame.
13. A lithographic device as claimed in claim 11, wherein the positioning devices of the
substrate holder and the mask holder have a joint force actuator system which is
controlled by an electric control unit and which exerts a compensation force on the
machine frame of the lithographic device during operation which has a mechanical
moment about a reference point of the machine frame of a value which is equal to a value
of a sum of a mechanical moment of a force of gravity acting on the substrate holder
about said reference point and a mechanical moment of a force of gravity acting on the
mask holder about said reference point, and a direction which is opposed to a direction of
said sum of mechanical moments.
Van Engelen claim 15 depends on van Engelen claim 2, which depends on claim 1. Van
Engelen claims 2 and 15 are as follows.
2. A positioning device as claimed in claim 1, wherein the object table is coupled to the
stationary part of the drive unit exclusively by a Lorentz force of a magnet system and an
electric coil system of the drive unit during operation.
15. A positioning device as claimed in claim 2, wherein the positioning device is provided
with a force actuator system controlled by an electric control unit and exerting a
compensation force on the first frame during operation, which compensation force has a
mechanical moment about a reference point of the first frame having a value equal to a
-28-
0
value of a mechanical moment of a force of gravity acting on the object table about said
reference point and a direction which is opposed to a direction of the mechanical moment
of said force of gravity.
Van Engelen claim 16 depends on van Engelen claim 3, which depends on claim 2. Van
Engelen claims 3 and 16 are as follows.
3. A positioning device as claimed in claim 2, wherein the magnet system and the electric
coil system belong to a first linear motor of the drive unit, which drive unit comprises a
second linear motor with a stationary part fastened to the second frame and a movable part
which is displaceable parallel to the X-direction over a guide of the stationary part, the
magnet system of the first linear motor being fastened to the object table and the electric
coil system of the first linear motor being fastened to the movable part of the second linear
motor.
16. A positioning device as claimed in claim 3, wherein the positioning device is provided
with a force actuator system controlled by an electric control unit and exerting a
compensation force on the first frame during operation, which compensation force has a
mechanical moment about a reference point of the first frame having a value equal to a
value of a mechanical moment of a force of gravity acting on the object table about said
reference point and a direction which is opposed to a direction of the mechanical moment
of said force of gravity.
As the movant, Lee must show that the proposed claims define the same patentable
invention as another claim whose designation as corresponding to the count the moving party
does not dispute. 3 7 CFR § 1.63 7(3)(ii). Lee has sufficiently demonstrated that van Engelen
claims 5, 13, 15, and 16 define the same patentable invention as van Engelen claims 1, 2, 3, and
11, or Lee claims 1, 2, 3 and 6 respectively in view of Schutten 5, without the teachings of Lee
'820.
In its opposition, van Engelen's primary discussion is with respect to van Engelen claims
5, 13, 15, and 16. We understand van Engelen's argument to be that since van Engelen claims 5,
13, 15, and 16 do not define the same patentable invention as any other claim designated as
corresponding to the count, then neither do those claims that depend on van Engelen claims 5,
13, 15, and 16, i.e., van Engelen claims 6-9, 14, and 18-22.
5 U.S. Patent 4,821,205, granted 11 April 1989 (Ex. 1091).
-29-
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
-30-
0
Schutten. To the extent that van Engelen is arguing that its claims should not be added to the
interference since Lee cannot support such a claim, that argument is also rejected. It is of no
moment that Lee may or may not have support for a force actuator system. A party moving to
designate an opponent's claim as corresponding to the count, need demonstrate that the claim
defines the same patentable invention as any one claim designated as corresponding to the count.
Absent from that requirement is that the movant must also demonstrate that it has written
description support for the opponent's claim. The query is not can the movant support such a
claim, but rather does the claim define the same patentable invention as a claim already
designated as corresponding to the count.
Van Engelen argues that Lee '820 fails to teach a compensation force between two frames
(opposition at 17). As stated above, we do not interpret van Engelen's claims 5, 13, 15, and 16 to
require a force actuator system that exerts a compensation force between two frames. In any
event, Lee did not rely on the Lee '820 patent to teach a force actuator system that exerts a
compensation force between two frames. Rather, Lee alternatively relied on the '820 patent to
show an actuator system that compensates for movement of two stages, as opposed to one stage.
Van Engelen argues that Schutten fails to disclose a compensation force between two
frames and exerted on a first frame (opposition at 19). As discussed above, when properly
construed, van Engelen's claims 5, 13, 15, and 16 do not require that the force actuator system
exert a compensation force between two frames. However, even if van Engelen claims 5, 13, 15,
and 16 do require a force actuator system that exerts a compensation force between two frames,
van Engelen has failed to demonstrate that it would not have been obvious to combine the
Schutten actuator system to a two frame system.
Schutten discloses a force actuator system, with force actuators 74, 76 in between the
ground and a work table (frame). Thus, Schutten discloses a force actuator in between two
structures. Van Engelen has failed to sufficiently demonstrate that one of ordinary skill would
-31 -
0
not look to Schutten to teach placing force actuators in between two frames. Specifically, van
Engelen fails to explain why Schuffen's force actuators would not work in between two frames.
Schutten teaches a force actuator system for compensating for forces acting on the frame
(stage/table), or for tilting of the frame and for movement of the stage. Based on the record
before us, such a system teaches a compensation system regardless of whether that system is
placed in between two frames, or in between a frame and the ground. Note, absent from van
Engelen's claims 5, 13, 15, and 16 is a requirement that the compensation force compensate for
reaction forces in a second frame. Rather the claims recite that the compensation force
compensate for forces of gravity acting on the object table (substrate holder/mask holder).
Schutten apparently compensates for such forces. Van Engelen has failed to direct us to evidence
that demonstrates otherwise.
Van Engelen argues that the prior art fails to disclose a compensation force exerted in
response to gravity forces on two moving stages as recited in claim 13 (opposition at 2 1). Claim
13 recites that the mechanical moments of the forces of gravity for both the mask holder and
substrate holder are added in deter-mining the opposing compensation force exerted on the
reference frame. Van Engelen argues that Schutten only provides background information and
does not teach a compensation force in response to gravity forces exerted on a substrate holder
and a mask holder (opposition at 22). Van Engelen's response is dissatisfying.
In its preliminary motion, Lee explains that van Engelen claim I I recites that the mask
holder and the substrate holder are both supported on a common support - the machine frame.
The claimed compensation force exerted in van Engelen claim 13 takes into account the sum of
all forces acting on that common frame - from both the substrate and mask holders/tables. Lee
explains that, although the Schutten reference fails to disclose two stages, Schutten does teach
summing all of the forces acting on the supporting frame to arrive at the compensation force.
Lee then concludes that one of ordinary skill would have been motivated to use the Schutten
-32-
force actuator system to compensate for the forces of both the stages/holders acting on a common
frame, since Schutten itself teaches compensating for all forces acting on a common frame.
Van Engelen fails to sufficiently address Lee's argument. That Schutten fails to teach two
stages, and an actuator system that compensates for the movement of two stages misses the point.
Van Engelen should have explained why Lee's analysis was erroneous. Instead, van Engelen
side steps Lee's argument altogether. Accordingly, van Engelen has failed to sufficiently rebut
Lee's primajacie case with respect to van Engelen claim 13.
Van Engelen's discussion with respect to Schutten's horizontal forcers is irrelevant. Lee
did not rely on the Schutten horizontal forcers to teach the force actuator system claimed in van
Engelen claim 5, 13, 15, and 16.
Van Engelen argues that Lee fails to point to any teaching in the Lee '820 patent of an
electronic control unit. Lee's reliance on the '820 patent was in the alternative only. As stated
above, Lee made a prima facie case based on the van Engelen claims 1, 2, 3, and I I in view of
Schutten without relying on the '820 patent.
For the above reasons, van Engelen has failed to sufficiently rebut Lee's prima facie case
of obviousness with respect to van Engelen claims 5, 13, 15, and 16.
The remaining van Engelen claims (6-9, 18-22 and 14)
Van Engelen claims 6-9 and 18-22 depend either directly or indirectly from van Engclen
claim 5. Van Engelen claim 14 depends from van Engelen claim 13. Lee has sufficiently
demonstrated that the van Engelen claims 6 and 7 define the same patentable invention as van
Engelen claim I or Lee claim 1 in view of Schutten. Lee has also sufficiently demonstrated that
van Engelen claims 8, 9 and 18-22 define the same patentable invention as van Engelen claim 1,
or Lee claim I in view of Schutten and Akutsu 6 . Lastly, van Engelen has sufficiently
6 EOP 647 788 BI, published 12 April 1995 (Ex. 1092).
-33-
demonstrated that van Engelen claim 14 defines the same patentable invention as van Engelen
claim 11, or Lee claim 6, in view of Lee '820, Schutten and Akutsu.
As stated above, van Engelen's arguments are primarily directed to van Engelen claims 5,
13, 15, and 16. Van Engelen does, at the end of its opposition, briefly discuss van Engelen
claims 8, 18, and 19. Since van Engelen does not address the specific features of van Engelen
claims 6, 7, 9, 14, 20, and 21, van Engelen has failed to sufficiently rebut Lee'sprimafacie case
of obviousness with respect to those claims.
1. Van EnRelen claims 8, 18, and 19
Van Engelen claim 8 depends on claim 5. Van Engelen claim 18 depends on van Engelen
claim 6, and 19 depends on claim 7. Van Engelen claims 8, 18, and 19 are as follows:
8. A positioning device as claimed in claim 5, wherein the force actuator system is
integrated with a system of dynamic isolators by means of which the first frame is coupled
to a base of the positioning device.
18. A positioning device as claimed in claim 6, wherein the force actuator system is
integrated with a system of dynamic isolators by means of which the first frame is coupled
to a base of the positioning device.
19. A positioning device as claimed in claim 7, wherein the force actuator system is
integrated with a system of dynamic isolators by means of which the first frame is coupled
to a base of the positioning device.
Van Engelen argues that, with respect to its claims 8, 18, and 19, Akutsu's linear motor
and bellow diaphragm air cylinder do not equate with van Engelen's sophisticated dynamic
isolator and integrated force actuator. We understand van Engelen to argue that since its
dynamic isolator as disclosed in the '666 patent is of a complex structure, that the Akutsu air
cylinder cannot meet the limitation of the "dynamic isolator" recited in van Engelen claims 8, 18,
and 19. Van Engelen's argument is not persuasive. Van Engelen claims 8, 18, and 19 recite
dynamic isolators. There is no claimed structure associated with the dynamic isolators. Van
Engelen suggests that a specific structure be considered when interpreting the term "dynamic
-34-
isolator." However, van Engelen has failed to sufficiently demonstrate that the term "dynamic
isolator" has a common meaning to one of ordinary skill in the art that would require a structure
of something more than a bellow diaphragm air cylinder as taught in Akutsu.
Dr. Kurfess, van Engelen's expert, does not assert that a dynamic isolator, as that term is
understood by one of ordinary skill in the art, requires a complex structure other than an air
cylinder. Rather, Dr. Kurfess states that, given the complex structure of the dynamic isolator,
disclosed in '666, that one of ordinary skill would not have known how to assemble a dynamic
isolator and actuator as described in van Engelen's involved '666 patent (Ex. 2042 T56). The
structure of the dynamic isolator and actuator are not claimed. Furthermore, van Engelen has
failed to sufficiently explain why the specific structure of van Engelen's dynamic isolator must
be considered in determining obviousness. Claims are to be given their broadest reasonable
interpretation. Importing limitations into the claims from the specification is impermissible. For
these reasons, van Engelen has failed to sufficiently rebut Lee's primafacie case with respect to
van Engelen claims 8, 18, and 19.
For all of the reasons discussed above, Lee preliminary motion 2 is granted.
Lee prelimingy motions 3, 4 and 7
Lee moves for judgment against van Engelen on the basis that several of van Engelen's
claims (including newly added claims 5-9, 13-16, and 18-22) are unpatentable over certain prior
art. Van Engelen has failed to allege a date prior to van Engelen's effective filing date.
Furthermore, van Engelen's preliminary motion 8 attacking the benefit granted Lee is denied.
Accordingly, judgment will be entered against van Engelen. There is then no occasion to
consider Lee's preliminary motions farjudgment against van Engelen. For these reasons, Lee
preliminary motion 3, 4, and 7 are dismissed.
-35-
Lee preliminga motion 5
Lee moves for benefit of U.S. Patent Application No. 09/127,288, filed July 31, 1998 (now
U.S. Patent 6,049,186); U.S. Patent Application No. 08/627,824, filed April 2, 1996 (now U.S.
Patent 5,942,871); and U.S. Patent Application No. 08/221,375, filed April 1, 1994 (now U.S.
Patent 5,528,118) with regard to Count 1. Since van Engelen has failed to allege a date that is
earlier than the date accorded Lee at the time the interference was declared, and since van
Engelen's motion 8, attacking the benefit accorded Lee is denied, judgment will be entered
against van Engelen. Accordingly, it is not necessary to deter-mine if Lee should be accorded
benefit of the above named applications. Lee preliminary motion 5 is dismissed.
Lee preliminary motion 9
In its preliminary motion 9, Lee proposes to add claims 7-9 to its application and to designate
those claims as corresponding to count 1. Lee preliminary motion 9 is contingent upon the granting
of van Engelen preliminary motion 2. Since van Engelen preliminary motion 2 is denied, the
contingency has not materialized. Accordingly, Lee preliminary motion 9 is dismissed.
Lee preliminary motion 10
Lee moves to substitute new count I for existing count 1. The motion is contingent on
the granting of van Engelen preliminary motion 8. Since van Engelen preliminary motion 8 is
denied, the contingency has not materialized. Accordingly, Lee preliminary motion 10 is
dismissed.
Lee proliminM motion 11
Lee moves to be accorded benefit of certain of its prior applications for its proposed count
1. Since the proposed count I was not added to the interference, there is no occasion to decide
-36-
Lee preliminary motion 11. Accordingly, Lee preliminary motion I I is dismissed.
Lee motion to suppress
Lee moves to exclude paragraphs 21-24 of exhibit 2042, exhibit 203 1, and exhibit 2050.
Lee seeks to exclude paragraphs 21-24 of exhibit 2042, as those paragraphs were relied on by van
Engelen in support of van Engelen's opposition 7. Lee preliminary motion 7 was dismissed.
Accordingly, there was no occasion to consider van Engelen's opposition 7. Thus, we find it
unnecessary to consider the specific objections with respect to exhibit 2042.
Lee moves to suppress exhibit 2031, as being unauthenticated under FRE 901. Exhibit
2031 is a translation of FP '409, an application for which van Engelen sought and was granted
the benefit (van Engelen preliminary motion 6). The exhibit 2031 is accompanied by a
"translator's verification." Lee objected to the verification as lacking proper authentication due
to critical defects in the verification. In response to Lee's arguments in its opposition 6 and
objections to van Engelen exhibit 203 1, van Engelen filed and served, along with its reply 6, an
exhibit 2050, which is a corrected translator's verification. Lee argues that exhibit 2050 should
be suppressed as being submitted too late and not in accordance with Standing Order § 34,
We find it unnecessary to consider the specific objections to the admissibility of exhibits
2031 and 2050, since, despite being accorded the benefit of the '409 application, judgment is
entered against van Engelen based on priority, even assuming the exhibits to be admissible.
For these reasons, Lee's motion to suppress is dismissed.
-37-
D. Redeclaration of Interference
This interference is herein re-declared to the following extent:
1. The parties' claims corresponding to the count are:
Lee: 1-6
Van Engelen: 1-3, 5-16, and 18-22
2. Van Engelen is accorded benefit for the purpose of priority of European Application
No. 95201409.0 (EP '409), filed 30 May 1995.
E. Judgment
Junior party van Engelen has not alleged a date of invention or conception with respect to
the subject matter of the count prior to the senior party's earliest accorded benefit date of 4 April
1995. Furthermore, van Engelen's preliminary motion 8, attacking the benefit accorded Lee is
denied. Accordingly, judgment is entered against junior party van Engelen. Itis
ORDERED that judgment as to the subject matter of the count is herein entered against
junior party GERARD VAN ENGELEN, CORNELIS D. VAN DIJK, JOHANNES M. M. VAN
KIMMENADE, and JAN VAN EIJK;
FURTHER ORDERED junior party GERARD VAN ENGELEN, CORNELIS D. VAN
-38-
DUK, JOHANNES M. M. VAN KIMMENADE, and JAN VAN EIJK is not entitled to its claims
1-3, 5-16, and 18-22 which correspond to the count;
FURTHER ORDERED that if there is a settlement agreement, the parties should note
the requirements of 35 U.S.C. § 135(c) and 37 CFR § 1.666; and
FURTHER ORDERED that a copy of this judgment be filed in the respective involved
application or patent of the parties.
k ESOX
LEE
A ml ivdstrat e atentýJudge
)BOARD OF PATENT
SALLYG. LANE APPEALS AND
Administrative Patent Judge )INTERFERENCES
s?4
SALLY (7. MEDLEY
Administrative Patent Judge
-39-
cc (via federal express):
Attorney for Van Engelen:
(Real Party In Interest: ASML Netherlands, B.V.)
Jack S. Barufka (lead counsel)
Robert W. Hahl (backup counsel)
PILLSBURY WINTHROP LLP
1600 Tysons Boulevard
McLean, VA 22102
tel: (703) 905-2000
fax: (703) 905-2500
e-mail: ibarufkaCapillsbin-vwinthrop.coin
rhahl&pillsburywinthrop.com
Attorney for Lee:
(Real Party In Interest: Nikon Corporation)
William P. Berridge (lead counsel)
Mario A. Constantino (backup counsel)
Robert Z. Evora (backup)
OLIFF & BERRIDGE, PLC
277 South Washington Street
Suite 500
Alexandria, VA 22314
tel: (703)836-6400
fax: (703)836-2787
e-mail: commeenteroa oli ff.com
-40-
WEBSTERS
New Kiverýide
Univerýity
Didionary
5
Table'. of
Lexical and Electi
preface .........
Noah Webster an(
Words that are believed to be registered tradCmaiks have
Explanatory Diagri
been checked with authoritative sources. No investigation Explanatory Nom
has he= made of emmum-law tradcrunk rights m my
word, because such investigation a impracticable. Words A Concise Guide
thatare known Me shown with Style Guide ....
an mind capital and are also identified as trademarks. The
inclusion of any word in this Dictionary is not, however, an Problems in Englisl
expression of the Publislices opinion as to whether or not it ý - - .1ý1 clich6s .............
is subject to proprietary non. Indeed, no definitim in this -r r
Dictionary is to be regarded as affecting the validity of my Redundaat EXPýýi
trademark- students' Guide t,
Copyright 0 1984,1988 by Houghton Mifflin Company. All
rights reserved. Business Letter St I
No part of this work may be reproduced or transmitted in Forrasof Address
my form or by my mean& electronic, or mechanical, includ- Abbreviations am
ing photocopying and recording, or by my information stor
age or retrieval system without the prior written permission pronunciation Syi
of Houghton Nhfflin Compoy unless such copying is ex
pressly permitted by federal copyright law. Address m- A New Dictionar
quiries to Perindissions, Houghton Mifflin Company, 2 Pak
StreM Boston, NLA M108. Abbreviations
Library of Congress Cataloging in Publication Data Biographical Narr
Main entry under tide:
ýf
Wcbstees H new Riverside university dictionary.
Geographic Nain.t
1. English language-Dictionarics. 1. Riverside Pub-
Foreign W ords an
lish n Company. 11. Title: Webster's two, new Riverside Table of Measure
university dictionary. m. Title: webstees 2 new River
side university dictionary. signs and Syrnbo
PE1625.W244 1984 423 83-3799
LSBN: 0.395-33957-X (thumb index, trade edition)
0-395-37928-8 (high school edition)
Manufactured in the United States of America ýX
1020 1021
)'Stra) a var pl. of r8to9mvitre 0 rGunded e, 'eft, tfttalfe, -$Wt) adi. Ut amount, on the MednamuUm and in noulty anCIS, varying in diE emot Haling a beaklLke Pam Ite OCIPOW from About on, In file Pounds. f saugh"ey tledrr M, 16'suarn) a. Pl. roasvenna 0, avý. (ca, fo"ostra"vydbe) IL LIAL tarea, wheel + G&AVMR,) without ) vat -dri _&yk.,degeas To dry (laundry) .1 L A raised platform far public apes as hint
A ship's cand beaklike prow h The king 2. L=An*inm'dqf'ýol"dln'io'ý'hed-- " which Intern ad pictures me tough ament cnu-'ýý in ve "ousal, To make Or be. Use, deCoacted with the Paw, of espe, Paper Of Plasti C, in a "'M P-,ZPn.(PYIi1Ud -d =an I with of U, fraud, an Cause rough
mtlikc Or b ýd sentOO, Produced by ,Va,,a hat rough.hs,, eaklike prm,,UOU+ fea, tauny JUL 4.", (rlnydb) at -hwed Or -harwas -haý
"we'la's' am adi. gormar (rffmr) a [Cfacraccum Of 'MATO&] I A cutting pan of an L To da -L To 1,, (c.& ft
outh dZnInd the Pink or ad Color of ClOctuttl a' rucchlaical devim L An assembly of setting homna,. rough-he to Mush forms , _be,) coughly, without fintabutt Of Sulpsnae Of a a] airfoils, as that of , helicopter (ranous) a Rowdy, b0iftarous play or behavior. by optimism: 024 ýv -hoftavd. wiauassa A rotor 41111P a. A ship propelled by me or mom fall cylindrical rarm K To ,, -honartut, -issuavuL -vIL To cnpv I, roughhouse. ý re"laks, safts, [ME man < OE an,' Operated by wind power k mPontim, CIP rusam, decompmu. I -It rcýý (vaca-tin M, am" , mu. in fiso on
ROTC7171122.1 TO ,
O,'tnfth'Cug1Ag, -1113s.
[Ank-formation <
dark hat
fords d because of decaty. 3. To If : DICAT _toy plow zu te.-Cal and 1aM`k91d) a A hawk Boom Ingpuss. with
WdecaYoudec, eca Ro`tO`t'H"CC Wyn'tly3r) A md,..k 1. 1 ýoaazl, cultivaux. k ZZ ficathera cov"ingla legs MPM -a I P On'. rat-ten (Men) adi. u, anothlida(renek) a L An uscamb pCou, 2. A of king mean L st. Foot M Liver Of -ýt [MEme, I ON haries Cal, (Olefrdaa) a I A " ,d aides of It;.* t A th b, fluke M decsyed: DE I L Putrefied role nt do'cases neeked by the has rxmýýr of C11 who basks horac, for ruling 1. as 'aramcd U filogi, banana, of stalgeftla of d=Cuhyo`:0s1u2*HaviAg I W cadrocturt dricay of flnl, =M.4.A, LM=dlYCMmPt:DZrLnam, &Made uro,,,,"d m0,r"w1ajfkftb0ymf6Qtr Roosevel in the a U4 Volun wulfgaider A cal Cavalry regiment Under Theodore -interi.. _TJ Very bad -vviurrýD a, re to suggest borough Is An el= t4olawasa a jectin; nails arpo+ 'had) a4+ I Shod with horseshoe, hall, pe, wheel.] L afly But A Inner or MU W If or on of duties- but the same wrong came district havang only a few man sou'lade trabadmo mpleentift Sl1PPM9 I Marked by brand force
P tes "talt, ROU, rot-ten-stone tcPOWCr " other Mon Populates durness, LMu, II, A, r < and". of fall < Off. make , saraLl as am ecclessain on of decomposed sila"t6n) a A friable nety a repoli, the prod. mas saing to embellthtacat consisting of I rapid com of selecal A me tbue M Cal "'t cm, lim f smated the Rotary Club, 10tt'afett-Iftf (Ift'wrb crome, Used for poliWg AQ ", $716blt 12. A done call. I A slim of fees, called how "io, b wasone Geressay whe r, r6ely-) & Cc < ROwra city in vanda. ravaqea d Cooked
ýi. [Med. III, amounts wheeL] of fe It was, "4 dim of ra(rdb4W)',
r Cooked by nation Cap arld mose.ot hiring a stacky body, abort his bred I A Canum breed of dog 2014 MR K U A -zeauss, Or 4-far (40Y) [ft. < OF, aftel,
v trand 06-Mncr) adi. [Lt Ck far, and ran fare nuk,,gL' ustall Fall; My of ' took little wheat dim of for, h;ýjj I A
device that mer's Iýuad se IXU, 2. A mad by consulate: so facenho c -M wh"Ll I Casnacter. b"PiPhIt ' ý'"PPedinP-Per-LAmfi,,fcldofribbm tftffaý IMý L S.-ý I Quite Plow - Marlette (rft4l* Ao c, so a turbine, in which adv. _,U.,U;Muaaa a -CHUM Lat" IL rortuardas (VO-Quado) A < OFr < melk, dim, rd wh po"t, U . samblingum - mue, eel <
ad I'Pare, " llum I A radial engine L A carcular hall or boodin[LICIL K Lac, fres. Of mouths, second.) of a Coming disk , mug bat M which the Plants bet on which sjoat stationary cruskabaf, what withalughtifiLan h.,CrP-CftwithadomC.LAJW disk Of tampered stal Will come to Man in X A small method l1now Consisting of & series of a lobby- mom does, slim In Pf, asuChed -tomalrea"'I in" annual ravraggg'ditY(r&tdm`dl.te), L I MOM, ra-handlcamf;ýd of
,whaling, arPIUMPLARMandba 'P -s"U'LThtsumidblilground stamps &S1111 '" 'a cograling or an a affeet of
series of hors 21alrd -1 a ravell ct Of protrudon. MMP3 in tommutive - - P034P fe"'U"C"of (re-mbr`U', -cythe.) a she, far ansurs Made between individual Is IFF. < Off.
"Mught
to
L Is. motion in which he P2 mute et role (Mbsh, 9-F latune-sc,", Mfymg Completion I CLITUlar 2. ", th of every ject I. a antic , ad on card game ""e) a (Ft, red and black] A gambling IL Almm ULl0.Rrnk:jjvdy<.mU..
an Internal 2" <,he anal a clumandhplayed at A Cable Marked with Can ad and two black ft : UOUP'k'
tion Of , PEd Pon U, which ban , Placed ne: UrruSnAtrae <- .. ad falumamd> IL Done with fall Plen cycle or such man man -14h (rM aulf. a,, as, IME I OE 1h) 1 H, I" mmd. L , Something 'Paok'ng> -Z I The state of be. onsf-mutim consisting on: REVOLEn" bUmPY surface. I c,, land ILA founded as a circle, Sink, disk, or n.& that is InPlar displacement, of coordinate dUm> I Marked by violent shaggy C, the much < vW9 an =even
ut fund. I nt maum Tuar a tough woolen an 4 Ldd, 4L A of curled 'am Or Pam I A rung M, mud., an uniform sequential 'amasan 4-Sencely inclement : utafrr 14U Cut Of beef from the Pam Of the thigh between be no& 6. Nor gentle or Careful SPORhat I Boure and the 'UMP. S. A SatherLtIg of paph: mom C Movermar . V1 , am, unruly, of mwdy+ smund a Circle i. L Of, "bring of, CaMML Or Marked by ouge. L Rude: mute * OLIffy 7.Brut'l: c, , succaMum, of sea, me. &A Complete fim. H.Ih an th"'all of unpleasant an en- "... A Come a <. found of m.CUAP> 9..fi, found> IL Harsh or sharp to the to,, < cau <. rough. wrap Places- 19L A Complete succon"y 01 Prescribed duties ace Or that mutts. IL Lackas; house a 14 Canarm or up. IL 0.1 drink fm'.ch ons or =1414 immature wine> to a M y. 12. A singe ounnor person AVE) adj. I. ()f rehear M Caus. pan> X PohllL 11 Being in A Anural scar, 15-Rq.Wft physical .. gth cada, than intelligence dism, number of snows shot from a specified ý& L Rugged anotown Of to a target in Archery. x 4"norcastion using mount or Pff ý fair 11-aunrld and mettle VOUML 2- The Pan of I VOM that oct, - . An interval Of P12Y in Sarms and a
Vabol. I A rough, irregular, 0, play., I
PICS 2 sPecified mr,
Ulm ishtd. S. A Crude ill-Enarancred of more VOjCn in which each on 17 Mus. A turn mum for ova or run pence : sens- -M seethed, the SIMe mclody awand amn encers a, . different ft,, with The wood of sod breaking of conth'tas swesla& I To "a"AL awasuda, -n L To kody: make rough- 2. To fast mu" 01 vic, make found. 2. To prmoe,'wIthýý dn! It of " &To indicate 0, Ps: LAJR.Uý IT, C'"manic MiLl A medieval Hpd papsa sn"4110turdmi-ladfam< m2kcP'=P:ý Oý.4LTobriSWWMP]Ctim:Fný S.T. - dv. in a tough way I. the rough net A buUdizlg pbn> expan '; a mund number. 4L To m-XX fil . crude or ,fulished make make & complete cimult Of. 7 To U. Iowa. derris + -0M I A white cry. ance - Ugh it. To do Witham the usual convenjences and com, Wows ma 'bout Or tO the Other side of ... h. y> I TO Moomd -en - Mon: M the icide. men of dern, ad -rou'b'g, adv comPlus 9. To Man or Cause re PM - -- orrift'-fass Is we a not in a cucade COUTS: -n I To become found L To take a nor hqu., "Uth'sago (nIffl) n. The relanwi circular course. 3. TO ;.;ý bo Life um ain foods and fodder that . Yname, indigestible pur, ofc, note mughs,,drmadY (r, comm cuul,, comefillcdCamourvardUIP1 ut`a`UUmsd-:xEv1IUs.4LTobC. e Tar> -in the sound. L With saulgh lu"Ithing Of L An "Pulse sound in Greek like that of the stage in the center of the audience. 2- Fully shaped an as of =ad I . ' free of . background <. same in the =d> _rmad,..,, , 'ft in" a P=2' The a-pik, ý(') Pl .. dOver initial stands in round' (Mnd) n an .4 raund4n& musada. [ME roundem On < OE Id"'- I Archaic. To whisper .. 7 It Is .L A comse pWw used for outside wall sammulm-bout (ramd'obme) ad: Carol
nit Of weight Used in countries bordat- To FY _Vt to clea-lifting $hen kL 2. indirear, -M I A I, I (e , a wi PC or I CW Y But A = ciole, Chiefly Ant A overrytmen& C round Classes a 1b, qualng. 'let epat ebe hwahuch tpit Ibboot arece round date" a I A folk chn performed with Paw, for m miw db took th thin the dancers as a Cut at ranged in a circle. L A b.R,,m dance In which couples Proceed in "labus, -hvimým .& t, I'M, ble, A CIM - circular dý*mu -found the from. savand-ed (amm'did) adr. L Shaped in I circle at sphere L pm
stationary wave steal
stationary wave n. A standing wave. stanch. -see rl`ý .] LFilm and imadfitia. exc_ arýhh Station break C. A paime an a broadcast prograin to allow for strong Construction or common "ve he non. CAI Th ?lot 'ro I'll", the identification of the network or mum. Commonly spelled stclach. hot the verb foren aalat4-aa lave, pinch. -vi sta-tion-er (sti'sthartar) a [ME stacionner < Med. lat station- spelled stanch. adv. _Aaa. ., a% f finobt Arms, shopkeeper < eatic. shop < Lat, autionj L A seller of am- staunch' (sonsch, stanch) v. vat, of stAff", cast a ;0. 1Y 0 OF Of tortery. L Obs. A_ A Publisher. Is. A bookseller. Stalarro-lite (sift'a-Ift') a (Fr. < Ck. im ýp ,41 Follod gelling: rai
(sers[I n. LWoming paper and envelopes. black mincral, chiefly FeA4Silow(OH), often Cloij A IF rf act b"Icit. -0'
01 thing Jnvk 2. Writing or typing marefull. grown ClyStals, occas, used .. a gern. _Asasa.;.ý'h '41 ý;l;ý (PAE situation hostile n. L A Police SIALIML L A file lutiOn- telds) as L stave (glv) a [Back-frinflutiOn < Jimir, pL Of I , IS scene Cells (sd'3han-mJs'mr) a An official in charge of a strip Of wood fouling pan of the sides of a coo ilt (tiat frive
railroad sticion. of mb. L A nang of a ladder or chair & ýý Jl J!, eltht)
A Adf LN A q ;ý Stations of the Cross pl.n. L A devotion that consists of medi- 5. A set of verses: srrý . _v. aisla'" if tation before each of the images or representation, set up usu. in a ftvm -vt L To break in or Fulcrum Or jill' Y [ME a'
the stI QNI* 4 Igerat) ý The M! church in commemoram 14 events in the piumn of jesus. L The 14 smash a hole am I To crush or smash of 11.4 My h. Er ustages mprelienting the events of the passion of Christ crushed in. -vitsive CIL To le"Zor w -11 T, ;;fýt--fer,
Station wagon n. An automobile having An extended interim, sitaivess (stin) a For. Ill. off yrý.ý'j I on, ':
third seat or luggag, platform, And a tailgam. JaUvell-Acre C. 11, Aft OCC Or eO By folk any. c ME P , C Card aelf-tistfle (sta-dirtile) m [Rack-forfultion < ,AroI LA no- =Phu agna < CIL, wild ration.] L A lokespor osjlhk,ý e
isleatta., anericad digum. L An estimate of a parameter s, of the population gind Of 30uthern Europe, with greculish-win ' P 10 t k. cc mean or .nnce, obtained from a sample 3 random variable that Cam Aced" of the seavessem, fOmcffTused,1fl,0*,;,ý1L ll We b, takes on the characteristim of 2 autistic Star (ad) v staraid, ftrJzaa, sum [IQ 1 0 , I. A
(sta-da'd-Jul) adi. Of, relsong to of wing statistics; or esse, an stop < Ut suffe, to =oil J -11 L T. a' of banddi equip
the principles of statistics. -vu-d.'tJu,.l' 'dv. place or condition L To sojourn a a gout 0, lodger 3. To stop moving 44 cifti, A
sta-thiiticit (sta-elet1h) M (G. Statimik political science < Mat hold on:iurnjý. 6. To keep up in a:aý 'ILToar "x 4 "Ure.
Itstisticut. Of sure affairs < fit sortu% st]i, -ace srAra.] L (sing. to Poker without raising it -as. L To 7T [- Allies h in number). The mathematics of the collection, organ zation, And postpone: delay. I To delay or step th nall Qr14ý 'ht,' c d from L
ifusillmostiOn Of numerical d2u. L (pl. in number). A collection of legal action or mandatc. 41. To satisfy C effatfif ;0_00 dc"Vem M A.
folormil< laxis A"J"' ;Oswe. .... numerical dats. get with A arI S. Obs. To wait for. 1, filys. I ;&aCý6adsmg""' dir Statts- Pref [< CIL stams, standing placed.] L Resting: remaining baiting: ClUM L The act of win ' ' WAr " d Cylinder I
L Equilibrium: balance residence or visiting 4. Suspension or POSA A led 4, A (geratuar) n
stjatýblsurt (saeablist) a An Asexually produced encapsulated <4 =7 Of turecutiOn> Ponenewei all ip er d 'kS a ;0ý a, smace bud of a freshwater bryonan from which new individuals develop A EYM: YrAT, SOJO111I VMT P. M 04 ;aý_"Vojx - A blain
after the parent colony has disontegrated. gout of lodger <=Yed with firusI six
cl;ý astatýcyant (nie"ise) n. A small organ of balancc In many inCT J! - bi - star (sts) m arassruji. imarina sum [or, 1. ýaaxjxk
refutes, consulting Of A fluld-filled me containing statoliths that help ý eA=PPonOfcým2n'cOng]LTom on"OsIll;as tZ Vil "Caniship c!f I indicate position when the anim, moves sustain mentally Or Virtually. I To man 01 fppo'n Off PI figter (stIm
Stilt-whith (sull-Ith') a A small movable concretion of calcium L A support : line,. L A strip of Ill. sleatio d repair of I cubmilm found in statneysin bace pjAme faA' Qr;k 'a sdffCn A Patent I altaim. A COML carcZ wrion raft sy"mm" sta-tor (sti'mr) & (lat, One that sunds < asions, p.pare of store, an star In,) a [ME < OE$td%.1 L A heavy repc Or Qbk Frisian befi.
,_a,, is piped to lac
stand.] The stationary pan of a machine, such as a motor, dynarno, a bract Of COPPOll for A Coast 01 $par L A fol, used fand'N As 3 be W. .. A, two or turbine, about which a into, fores. something. _V 6"ye4 -M LTs assital fte"In the rticjc that Stllltý arjpac (som`ýskop') n. L A hammeter for recording small stly. 2. To Put (a ship) an the OPP"Ame uck -Va. To -k ,in on vanations on Atmospheric pleasure. L A device for indicating small 1111401118 POW" C- Sumina: endurance. millas 1.1aer clan St.
changes in an sirpliIne's altitude. afty-in strike (StAln') I A job idea this, manian a,,Pped wa istat-al-a" (stich'II a. Pl. 4m [partly < Lat. Coronado, an of down or work stoppage by employees who mme, st As W of irresistible force
making games, and partly < UL mceledill. sculptor, both < learn. place, level with 2 Anna of A game < statim. narlic.] L Signs collectively. 2. A sculp. a 910self " of To fully tity-Saill -all') 11 Al"t. A tria , force- mr. 3. The Am of making names. St. Bermard (silne har-rdrd') a The figula, oil blood Cris Start-ise (stifh'db) a [ME < OFr. ý lAt. am= < sontem. to act up. stlead (sad) n. [ME < Saint Bernall 'fil biP (,em'slilf
-SM rl`Aý .] A form or likenesic sculpted, modeled, Carved, at _n ,M-dnw
of advantag, in: .. k Shovel a A 9 vtuat-lzýqauc (such'itti-Esle) cell. Like a game, cspý in a=, grace, stead-fast a t ($led - "CAM table as. A tab I r. I d4 [ha "cam mu stexass or I or dignity: srArtuy. adv. OE amdefý : e, pl.C + fast f Air w. by Astatm-ecte (such,6ji-ae) a A small sumc. ing :: TIL&L'T. F. y loyal or -a ocý fatatxre (stich'zr) ii. [ME < Oft < Lat stim. c storts, ppra, of td t'n t..,,Cd aping Of thm" 111. AAuY (Areme) ad!- Mae. to stand.) L The natural height of a human or animal body in stead-V (smille) full. j .4 t. JL finn ,a kitchen> 2in upright position. L A level achieved: srArus. xuý L Direct and unu - I ev "T'Jiny ý 3. 'AaaAaAl.AA statsta (sareas sueas) a (Lat, Condition, p.p2n of aram. to standj quality, or a slo y t in (ste.aplan) L The legal chatiacter or condition of a person or thing L A stage of progrests or development. 3. st. Relgive :SORIK _V. st kid h 'Al, of pancleatic Page it A n 6 r. 7. 1 glycerol. position in a ranked group or in a social system Is. ffigh relative Position 4. A larly and excill lvel 's a aturic acid. =it of affairs: swillAnON. . a mvwqc (ste-Ar1k, stir stit-tual quo (struis kwW, stle2s) a (Lat., sum in which.] The Steady State n. A stable condition that does cor clo:, ce Or "I's, in 01 slacila existing condition: VAn OF ýxrjtsý or an which change to one direction a contOicav slaýav swearic sicial m A Status word n. A computer storage location which provides dau thing in Another. C)j0CFja).XOOH, occu in mature an interrupted program. stassaid-y-state theory (stEd'e-scit') & A cousilatca saw fria-ita-ria, (sa'Ar-In, sdr stoatmý-ljde (alch'a-ea-bol) ath. L Enacmd regulated, or autho- that assurnes; that the law-malle view of the unrincisime"aw ýcemvs tidolless, =1 ficed by sum. : 1717Aý Xr. L Legally punishable : recognized by of the position of the observer in space And nue led ýX :A. C.WCljjo,), used i stature <. immutable offecalI sm. of the universe, required on other grounds, umtý a ,n, L Sciatic acid. 3. sertat-arte (sticli'di5t) n. [ME < Off. earectut < LlAt. StOmmust I Ut., by the continuous Creation of marter. 'u-s-ropýterse (ste'z Amoutus, P-part. of sustialue, in set up < sumas p.part of store, in steak (st1k) a [ME sityk, < ON Mik) LA FL. Of Air A I The portion of . stand.] L A law enacted by the legislative zascWly of a nation or beef, typically cut In a thick Alice across the mu-ifle pria L 4 ý ,,ulLi.e wild 0 sum. L A limme of effict. 3. An established law or mle, cap. of a slice of a large fish cut acrou the body. 3. A pay it V= Aa u-a-Ute (ste'o-de) t corporaition. Chat has been prepared like A steak. -zý tallo..] A milassiv, statute law a A law established by legislative criactessent, steak hostile a A resuffunt specialifing in beruma dabas M L.Inon. u'ý statute smile a attax 1. steak leans , A uble knife with A sharp, co" se W 'I'Aukto-yeat. [Cla. e: st Staituft Of u. lAw. A statute Rating a time limit Steak itar-tuare (tietir) - fý ý Fr minfe. TarocIIIA1, star-aýf-"is (vtrý' on legal action in certain &,sea raw ground beef camed with onjo= ,4 ad .- M larin' in .Umaltion. stat-u-torry (soich'ýoef, -Mea) Odi L Of or latmg of 4 stature, steal (.tell V. .. 1. (501), A as civybo' viellia, w" el'fatývjrg+& (ste-4 L Emend, regulated, or Authorized by summ. IMEgilen < oEsul.] -n LTO take (Ih'Promm a'" ramp I Excesisive Acetic Statutory Offense a A legal offemse declared by stamitc. without right or mmusion, LTO get Or foor"I'loh "C'__ Flask (.pfl'lk, -pl'olk), Statutory rappe a Sexual untemourse: with a 0 who has not reached the mimicry age of consent
Staunch, (st6mcb. stailich) also stanch launch stinch) adj. ý, Apat tipay licarm Jfsuber epan fbc bwaske" ýust on out th t -est. [ME stanniche. waternigla < Off. sitaiI caracelizer, in I tic fir pier 6 pot a reas, 6 pow, for M no" " as was -buse all vision
MCGRAWHIR
DICTIONARY Of
SCIENTIFIC AND
TicuKICAI
TiRms
fifth Idition
Sybil P. Parker
Editor in Chief
McGraw-Hill, Inc.
New York San Francisco Washington, D.C.
Auckland BogotA Caracas Lisbon London Madrid Mexico City Milan
Montreal New Delhi San Juan Singapore Sydney Tokyo Toronto
On the cover: Photornicrograph of crystals of vitamin B,.
(Dennis Kunkel, University of Hawall)
Included in this Dictionary are definitions which have been published previously in the following works: P. B.
Jordain, Condensed Computer Encyclopedia, Copyright 0 1%9 by McGraw-Hill, Inc. All rights reserved. J.
Markus, Electronics and Nucleonics Dictionary, 4th ed., Copyright 0 1960, 1966, 1978 by McGraw-Hill, Inc.
All rights reserved. J. Quick, Arrists'and Iflustrators'Encyclopedia, Copyright 0 1969 by McGraw-Hill. Inc. All
rights reserved. Blakiston's Gould Medical Dictionary, 3d ed., Copyright 0 1956.1972 by McGraw-Hill, Inc. All
rights reserved. T. Baumeister and L. S. Marks, eds., Standard Handbookfor Mechanical Engineers, 7th ed.,
Copyright 0 1958,1967 by McGraw-Hill, Inc. All rights reserved.
In addition, material has been drawn fimm the following references: R. E. Huschke, Glossary of Meteorology,
American Meteorological Society, 1959; U.S. Air Force Glossary of Slandaralked Terms, AF Manual 11-1, vol.
1. 1972; Communications-Electronics Terminology, AF Manual 11-1, vol. 3,1970; W. H. Allen. ed., Dictionary
of Technical Terms for Aerospace Use, Ist cd., National Aeronautics and Space Administration, 1965; J. M.
Gilliland, Solar-Terrestrial Physics: A Glossary of Terms andAbbreviations, Royal Aircraft Establishment Tech
nical Report 67158,1967; Glossary qfAir Traffic Control Terms, Federal Aviation Agency; A Glossary qfRange
Terminology, White Sands Missile Range, New Mexico, National Bureau of Standards, AD 467-424; A DOD
Glossary of Mapping, Charting and Geodetic Terms, I st ed., Department of Defense, 1967; P. W. Thrush, comp.
and ed., A Dictionary ofMining. Mineral, and Related Terms, Bureau of Mines, 1968; Nuclear Terms: A Glossary,
2d ed., Atomic Energy Commission; F. Casey, ed., Comipilation of Terms in Infornustion Sciences Technology,
Federal Council for Science and Technology, 1970; Glossary ofStinfo Terminology, Office of Aerospace Research.
U.S. Air Force, 1963; Naval Dictionary ofElectronic, Technical. and Imperative Term, Bureau of Naval Person
net, 1962; ADP Glossary, Department of the Navy, NAVSO P-3097.
McGRAW-HILL DICTIONARY OF SCIENTIFIC AND TECHNICAL TERMS,
Fifth Edition
CopyrightD 1994,1989,1984,1978,1976,1974 by McGraw-Hill. Inc. Ali rights reserved. Printed in the United
States of America. Except as permitted under the United States Copyright Act of 1976. no pan of this publication
may be reproduced or distributed in my form or by my means, or stated in a database or retrieval system, without
the prior written permission of the publisher.
67890 DOWA)OW 03 02 01 00
ISBN 0-07-042333-4
Library of Congress Cataloging-in-Publication Data
McGraw-Hill dictionary of scientific and technical terms
Sybil P. Parker. editor in chief..-5Lh ed.
p. cm.
ISBN 0-07-0423334
I.Science-Dictionaries. 2-Technology-Dictionaries.
1. Parker, Sybil P.
Q123.M34 1993
503-dc2O 93-34772
CIP
INTERNATIONAL EDITION
Copyright 0 1994. Exclusive rights by McGraw-Hill. Inc. for manufacture and export. This book cannot be re
exported front the country to which it is consigned by McGraw-Hill.'Me International Edition is not available in
North America.
When ordering this title, use ISBN 0-07-113584-7.
1144 linear light
some previously known flow ane small compared with die speed lintuar-phaw [ýECTRI Pertainuilto
of sound; as a result, the equations of motion m be approxi- whose image phase constant is, lu"araffi*&ý%V.
=red by retaining only those temns which are linear in distur- I 'lm-&arfiiz I
bance in perturbation velocities. pressures, densities, and so linear polarization [omaj pb
forth. I :lin*ý,azddivait av'fidýdflii I =tic wave in which the elect .ric v ecuat Ofa;"
linear light INAVI In marine operatiom, a luminous signal remains; pointing in a fixed direction.
havingperciptible length, ascontrusted with a point light, which nitude. Alm known as; plane po
does not have perceptible length. I 'lin-&QrM I n'zashan I
linear - logarithmic Intermediate - frequency amplifier linearpolymer [ORGCHEMI Apolynia-,"
[ELEcTa] Amplifier used to avoid overload or saturation as a armaged in a chainlike fashion with le.
protection against jamming in a radar rectiver. I 'firr&*rI1g- between the chains. I 'tin-&w 'pill-imar
2'rith-mik Ilinearpower amplifier E I A
lineirly&'ýnd;ntquanilfles [atAý] Quantitiesthatut. the signal output voltma y
isfy a homogeneous Imm equation in which at least one of the input voltage. I 'lin-ftr' ar,
coefficierimisnotzem. I'tin-&*rledi;pen-d2nt'kwgn-tattz) linear programn, ig [ I
linearly disjoint extensions [ýý] Two extension fields E minimizing a Imear fure: i af
and F of a field k contained in a common field L, such that my straints which are linear itift but, li
finite set of elements in E that is linearly independent when E is I 'fin-ftr'liffi.grainto I
regarded as a vector space over k remains timmly independent linear-quadratic-gaussian problem IC
when E is regarded as a vector space over F. I :lime-2rle mal-suiteregulatorproblerocon * , DNT " :disj6int ik'stenchanz I the state and measurement equatium, in . I
linearly graded junction [ELEm] A pn junction in which value of the quadratic index is 14 the impurity concentration does not change abruptly from do- Abbreviated LQG lem. I
nom to acceptors, but varies smoothly across the junction, and prab-lm I
is a linear function of position. ( 'tiný la :grad-od 'jaille linear rectifier [ELEMI A rectifier"thl:
shm I voltage of which contains a wave * a
linearly Independent quantities [MATH] Quantities which that of the envelope of an impressed 14W
do not jointly satisfy a homogeneous aear equation unless all lrek-tafiar I
coefficients are zem. I 'Iirrdýrlg in-da:pcn-dant 'kivibrod- linear regression [STATI The mailli,
8z I the pointsof ascatterdiagrannaboutbidlifli
linearly ordered set [MAý] A set with an ordering ý such is smallest, as defined, fcrexm=plný by
that for my two elements a and b either a-sb in bgsa. Also I 'Ifiv&wri'grcshý ) . -'
known as chain; serially ordered set; simply ordered set. 111in- linear regulator problem [CONTSYS] A
ftrId:6H2rd 'set I trol problem in which the system to be
linear magnetic amplifier CEL.Ecritl A magnetic amplifier by linear differential equations and the
employing negative feedback to make its output load voltage a minimized is the integral of a
linear function of signal current. ( 'Un-ftr mag:ned-ik 'amr suite and control functions.. 50 Imourn a
P121111vt I problem; regulator problem I lintw
linearmanifold [MAm] A subset of a vectorspace which is Iam I
itself a voctor space with the induced operations of addition and Itnearrepeater JELý J A ask.
scalar multiplication. I I satellites to amplify input si a fixed
linear meter [ENG] A meter in which the deflectirm of the traveling-wave tubes or solid-state
pointer is proportional in the quantity measured. I 'lin-&2r lincarregion. I 'fin-&arri'pedýr)
LINEAR-SWEEP 1,11mir I linear scale See uniform scale. (:fin*,j*g .
DELAY CIRCUIT linear model (FTAT] A mathematical model in which linear linearscanning [ENGI Radarbearthidi
equations contact the random variables and the parameters. stant angular velocity through the scanning
known as linear hypothesis. I'lin-aar'nuidall be 2 complete 360'. 1 'fin-&w'
linear modulation [COMMUN) Modulation in which the ann- linear space See vector space. I'lin*X;" .v plitude of the modulation envelope (or the deviation from the linear speed method [ORD] Method of
testing frequency) is directly proportional to the amplitude of firing dam in which the form position a a
the intelligence signal at all modulation frequencies. ( 4in-a- determined by finding the direction of It N
armlp'liiýshm I speed of the target; by multiplying the gm d
linear Molecule [MYS CHEM] A molecule whose atoms are of flight of the projectile, die futare posi 4idm
arranged so that the bond angle between each is 180'; an cx- I 'Iin-E-ar'spaclmedrýd
ample is carbon dioxide. C0, ( 'Im*2r'mAI-akyfi1 ) linear Stark effect [ATompHys] Aspliniat,
V. linear momentum See momennim. I 'Iirveýr ma'men-tam I of hydrogenlike atoms placed in an electric
linear motion See rectilinear motion. ('Hn+ar'm&shanJ level of principal quantum numbers isslifitiso
linearmotor [ELwj An electric motor that twin effect been tant levels of separationproportionaltodiefield
T-ý split and urrolled into two flat sheets, so that the motion between ftr'stdrk ifekt I
rotor and stator is lincarrather than nutary. I 'lin-&x'miklýr) linear stopping power See stopping PD
linearnetwork [ELEcj Anetwork inwhich the parannetersof pauýr 1 -. 24
resistance, inductance, and capacitance are constant with respect llnearstrain [MECH) Theratioafthecht*
to current or voltage, and in which the voltage or current of a body to its initial length. Alsolmarmas,.,
sources is independent of or directly proportional to other volt- I 'Iin-eýr:stran ) I
Elements of linear-sweep delay ages and currents, or their derivatives, in die network. Also linear sweep (ELE(7rR1 A cathode-tay seq
circuit. T = delay time; Va = known w linear circuit. ( 'Iin-&ar'nctwark ) reference voltage; t, = time. bearn moves at constant velocity froinceeside
linear operator See linear transformation. I 'Im&e-ar'iiprar!d- the other, then suddenly maps back tothe
W I &ý:swap I
linearorder [mATm] Anyorder