DCT

2:19-cv-05065

Seoul Semiconductor Co Ltd v. Factory Depot Advantages Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:19-cv-05065, C.D. Cal., 06/11/2019
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiffs allege that Defendant’s Philips LED TV BDL4830QL display infringes ten patents covering a wide range of technologies, from the optical design of LED lenses to the microscopic structure and manufacturing of the LED semiconductor chips themselves.
  • Technical Context: The asserted patents relate to foundational aspects of light-emitting diode (LED) technology, which is critical for modern energy-efficient lighting and high-performance electronic displays.
  • Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2004-11-12 ’162 Patent Priority Date
2005-03-31 ’952 Patent Priority Date
2008-11-18 ’552 Patent Priority Date
2008-11-18 ’967 Patent Priority Date
2009-03-06 ’225 Patent Priority Date
2009-11-13 ’157 Patent Priority Date
2009-11-17 ’162 Patent Issue Date
2009-12-29 ’212 Patent Priority Date
2010-01-05 ’210 Patent Priority Date
2010-01-07 ’618 Patent Priority Date
2010-02-23 ’225 Patent Issue Date
2012-03-13 ’952 Patent Issue Date
2013-09-03 ’212 Patent Issue Date
2014-08-19 ’800 Patent Priority Date
2014-09-09 ’552 Patent Issue Date
2015-05-05 ’618 Patent Issue Date
2017-02-21 ’157 Patent Issue Date
2017-07-25 ’210 Patent Issue Date
2017-10-24 ’800 Patent Issue Date
2018-11-20 ’967 Patent Issue Date
2019-06-11 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,022,618 - "Aspherical LED Lens and Light Emitting Device Including the Same"

The Invention Explained

  • Problem Addressed: The patent describes a problem with conventional semispherical LED lenses, which tend to focus light at the center, creating uneven illumination with "bright and dark areas" when used in an array, such as a backlight for a display device (’618 Patent, col. 1:40-50).
  • The Patented Solution: The invention is an aspherical lens designed to counteract this central focusing. It achieves this through a combination of features: a "concavely depressed" light exit plane near the central axis, a conical light entrance plane, and "a plurality of protrusions arranged on a portion of a side surface of the light exit plane." This structure is intended to create a "double peak type pattern" of light distribution, spreading illumination more broadly and evenly (’618 Patent, Abstract; col. 2:19-35).
  • Technical Importance: This lens design addresses a key challenge in display technology by enabling more uniform backlighting, which is critical for visual quality and may allow for designs with fewer, more widely spaced LEDs (’618 Patent, col. 1:51-57).

Key Claims at a Glance

  • The complaint asserts exemplary independent claim 1 (Compl. ¶22).
  • Claim 1 of the ’618 Patent recites:
    • An aspherical lens, comprising:
    • a light entrance plane configured to receive light emitted from a light source;
    • a light exit plane configured to radiate the light received by the light entrance plane;
    • wherein the light exit plane comprises protrusions disposed on a portion of a side surface of the light exit plane, and a curved surface disposed on the side surface of the light exit plane; and
    • wherein the aspherical lens has a symmetrical structure.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,618,162 - "Irradiance-Redistribution Lens and Its Applications to LED Downlights"

The Invention Explained

  • Problem Addressed: The patent’s background section explains that conventional illumination lenses often fail to produce uniform illumination on a target because different parts of the lens are at widely varying distances from the light source, resulting in non-uniform illumination across the lens’s own exit aperture (’162 Patent, col. 1:16-21).
  • The Patented Solution: The invention is a thick aspheric lens that solves this problem in two stages. First, a specifically shaped "entry surface" receives the non-uniform light from a nearby LED and refracts it so that it becomes "predominantly uniform" by the time it reaches the opposing "exit surface." Second, the exit surface is shaped to take this now-uniform light and refract it into a desired output beam for illuminating a distant target (’162 Patent, Abstract; col. 1:57-64).
  • Technical Importance: This optical design enables a single, compact LED to efficiently produce a uniform spot of light on a target, a critical capability for applications like ceiling-mounted downlights (’162 Patent, col. 1:25-30).

Key Claims at a Glance

  • The complaint asserts exemplary independent claim 1 (Compl. ¶29).
  • Claim 1 of the ’162 Patent recites:
    • An irradiance-redistribution illumination lens comprising a transparent dielectric solid of revolution.
    • An entry surface that receives light of nonuniform irradiance from a nearby compact light source.
    • An opposing exit surface that forms a pre-specified diverging output beam.
    • The entry surface has a specific profile that refractively deflects received light so the exit surface receives it with "predominantly uniform irradiance."
    • The exit surface has a specific shape that refractively deflects the uniform irradiance into the output beam.
    • The entry surface has a first concavity and a second concavity, with the second being substantially greater than the first.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,132,952 - "Backlight Panel Employing White Light Emitting Diode Having Red Phosphor and Green Phosphor"

  • Technology Synopsis: The patent describes a backlight panel for a display that uses a white light-emitting diode as its light source. The white LED is constructed from a blue LED chip covered by red and green phosphors, a configuration intended to enhance color reproducibility compared to other methods of generating white light (’952 Patent, Abstract).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶37).
  • Accused Features: The complaint alleges the accused TV’s backlight uses a white light-emitting device comprising a blue LED covered by a phosphor layer containing particles of green and red phosphor (Compl. ¶39).

U.S. Patent No. 8,829,552 - "Light Emitting Device"

  • Technology Synopsis: The patent addresses the problem of a molding unit separating from an LED’s lead frame. The solution involves creating "fixing spaces" in the lead frames, such as holes or cutouts with stepped or inclined sidewalls, that become filled with molding resin. This creates a physical interlock that improves the adhesive force between the resin and the metal lead frames (’552 Patent, col. 1:20-31, col. 2:50-57).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶42).
  • Accused Features: The complaint alleges the accused LED packages contain a pair of lead frames with sidewalls that define fixing spaces filled with resin, which allegedly supports the lead frames (Compl. ¶46, 48).

U.S. Patent No. 10,134,967 - "Light Emitting Device"

  • Technology Synopsis: This patent is directed to a light-emitting device with first and second lead frames. The invention focuses on a specific geometry where each lead frame has three "undercut sidewalls" that define a "fixing space." This structure is designed to physically anchor a surrounding resin or molding material to the lead frames, preventing separation (’967 Patent, Abstract, col. 6:3-16).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶51).
  • Accused Features: The complaint alleges, based on optical and x-ray images, that the lead frames in the accused product have three undercut sidewalls that form a fixing space (Compl. ¶57-58).

U.S. Patent No. 9,577,157 - "Light Emitting Diode Chip Having Distributed Bragg Reflector and Method of Fabricating the Same"

  • Technology Synopsis: The patent describes an LED chip with a specialized mirror, known as a distributed Bragg reflector (DBR), located on the bottom of the substrate to improve light extraction efficiency. The DBR is composed of two distinct portions: an upper portion with relatively thick layers of alternating materials (e.g., SiO2 and TiO2) and a lower portion with relatively thin layers, where the optical thickness of the upper portion's layers is greater than that of the lower portion's layers (’157 Patent, Abstract, col. 6:49-61).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶61).
  • Accused Features: The complaint alleges the accused LED has a DBR with two portions, an upper one with thick layers and a lower one with thin layers, where the optical thickness of the upper layers is greater than the lower (Compl. ¶67).

U.S. Patent No. 8,525,212 - "Light Emitting Diode Having Electrode Extensions"

  • Technology Synopsis: This patent discloses an LED chip with a specific layout for its electrical contacts to improve current spreading. It describes two "n-extensions" extending from the n-electrode pad that are convexly bent, and three "p-extensions" extending from the p-electrode pad, with the top and bottom p-extensions enclosing the two n-extensions (’212 Patent, Abstract).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶70).
  • Accused Features: The complaint alleges the accused LED has two convexly bent n-extensions and three p-extensions that enclose the n-extensions, matching the claimed layout (Compl. ¶75-76).

U.S. Patent No. 9,799,800 - "Light Emitting Device and Method of Fabricating the Same"

  • Technology Synopsis: The patent details the structure of the p-type semiconductor layer in an LED. The invention describes a multi-layer structure comprising a p-type contact layer, a hole transport layer, and a hole injection layer. The hole transport layer itself has a specific, varying doping profile, with layers of relatively low Magnesium doping surrounding an intermediate layer with relatively high Magnesium doping (’800 Patent, Abstract).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶79).
  • Accused Features: The complaint alleges the accused LED has a p-type semiconductor layer with distinct contact, transport, and injection sub-layers, and that the hole transport layer has the claimed varying Magnesium doping profile (Compl. ¶82).

U.S. Patent No. 9,716,210 - "Light Emitting Diode and Method of Fabricating the Same"

  • Technology Synopsis: The patent describes an LED structure that includes a "spacer layer" disposed between the primary n-type contact layer and the active (light-generating) region. This spacer layer is specifically defined as comprising a stack of two distinct semiconductor layers, which can have different Indium concentrations and bandgaps (’210 Patent, Abstract, col. 2:48-56).
  • Asserted Claims: Exemplary claim 9 (Compl. ¶86).
  • Accused Features: The complaint alleges, based on transmission electron microscope images, that the accused LED's epi-structure includes a spacer layer comprising a stack of two semiconductor layers between the n-type contact layer and the active region (Compl. ¶90-91).

U.S. Patent No. 7,667,225 - "Light Emitting Device"

  • Technology Synopsis: The patent describes improving LED efficiency by creating "carrier trap portions" within the multi-quantum well (MQW) active layer. These traps are regions where the band-gap energy decreases from the periphery to the center, which can be achieved by varying the concentration of an element like Indium. These traps are intended to capture charge carriers (electrons and holes) and promote light-generating recombination (’225 Patent, Abstract, col. 2:19-23).
  • Asserted Claims: Exemplary claim 1 (Compl. ¶94).
  • Accused Features: The complaint alleges that the well layers in the accused LED's MQW structure contain indium, and that the concentration of indium varies across the layer, corresponding to the claimed carrier trap portions (Compl. ¶99).

III. The Accused Instrumentality

Product Identification

  • Philips LED TV BDL4830QL display (Compl. ¶8).

Functionality and Market Context

  • The accused product is an LED television. The complaint’s allegations focus on the technical components of the television’s backlight unit. This unit is alleged to include a panel with 66 LED-based light emitting devices, each paired with an associated lens, which together illuminate the television’s liquid crystal display panel (Compl. ¶23). The complaint provides detailed allegations about the structure of these components, including the shape and surface features of the lenses (Compl. ¶25), the use of phosphors on the LED chips to create white light (Compl. ¶39), the physical construction of the LED packages with lead frames and resin (Compl. ¶46), and the microscopic composition of the semiconductor layers within the LED chips themselves (Compl. ¶66, 73, 82, 90, 99). The image provided in the complaint shows the Philips BDL4830QL display, which is the subject of the infringement allegations (Compl. ¶8, p. 3).

IV. Analysis of Infringement Allegations

’618 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An aspherical lens... having a symmetrical structure The accused lens is alleged to be aspherical and rotationally symmetrical. ¶25 col. 2:39-41
a light entrance plane configured to receive light emitted from a light source The lens has a central cavity with a light entrance plane configured to receive light from an associated light emitting device. ¶25 col. 2:28-32
a light exit plane configured to radiate the light received by the light entrance plane The lens has upper and side surfaces comprising a light exit plane configured to radiate light. ¶25 col. 2:28-32
wherein the light exit plane comprises: protrusions disposed on a portion of a side surface... The substantially vertical portions of the side surfaces are alleged to be textured, resulting in protrusions extending above the surface of the lens. ¶26 col. 2:32-35
and a curved surface disposed on the side surface... The side surface of the lens is alleged to include a curved surface. ¶26 col. 4:5-10

Identified Points of Contention

  • Scope Questions: A central question may be whether the "textured" side surfaces alleged in the complaint (Compl. ¶26) meet the claim limitation of "protrusions extending above the surface of the lens." The complaint provides a cross-section image of the lens, which is intended to show these features (Compl. ¶25, p. 7). The construction of "protrusions" will be critical to determining if general surface roughness or more distinct features are required by the claim.
  • Technical Questions: The patent describes the invention as creating a "double peak" light distribution pattern (’618 Patent, col. 2:20-22). The complaint alleges the presence of the claimed physical structures but does not allege that the accused lens achieves this specific functional result. A potential dispute is whether the accused lens operates in the same way as the patented invention.

’162 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An irradiance-redistribution illumination lens comprising a transparent dielectric solid of revolution with external surface area... The accused lens is alleged to be a solid of revolution about a central axis and to be made of a transparent dielectric. ¶31, 32 col. 5:25-28
an entry surface that receives light of nonuniform irradiance from a nearby compact light source... The lens allegedly includes a central cavity with a light entry surface for light emitted from the light emitting device. The light source is alleged to be approximately 3 millimeters wide. ¶32, 34 col. 5:28-30
an opposing exit surface that forms from said received light a pre-specified diverging output beam The upper and side surfaces allegedly comprise a light exit surface configured to radiate the received light into a diverging output beam. ¶32 col. 5:30-32
said entry surface given a specific profile that refractively deflects said received light... such that said exit surface receives said deflected light with predominantly uniform irradiance The profile of the light entry surface is alleged to result in refraction of entering light, causing light incident at the light exit surface to have a "predominantly uniform irradiance." ¶33 col. 5:32-37
said exit surface given a specific shape that refractively deflects said uniform irradiance into said output beam The predominantly uniform irradiance at the light exit surface is then allegedly refracted to create an output beam. ¶33 col. 5:37-39
said entry surface having first concavity... and second concavity... said second concavity being substantially greater than said first concavity The light entry surface is alleged to comprise a first concave shape relative to the light source, and the light exit surface comprises a second concave shape relative to the light source, with the exit surface being substantially larger than the entry surface. ¶33 col. 5:40-44

Identified Points of Contention

  • Scope Questions: The claim requires the entry surface to create "predominantly uniform irradiance" on the exit surface. The complaint makes this functional allegation (Compl. ¶33), supported by a cross-section image of the lens (Compl. ¶33, p. 9). A key point of contention will be whether this conclusory allegation can be proven and whether the accused lens actually operates according to this specific two-stage optical principle.
  • Technical Questions: The infringement theory relies on the specific shapes of the entry and exit surfaces. While the complaint alleges these surfaces have concave shapes (Compl. ¶33), the dispute will likely focus on whether the precise curvature and relative dimensions of the accused lens, as depicted in the complaint's visual evidence, satisfy the claim limitations.

V. Key Claim Terms for Construction

For the ’618 Patent

  • The Term: "protrusions disposed on a portion of a side surface of the light exit plane"
  • Context and Importance: The infringement allegation for the ’618 Patent relies on the assertion that "textured" side surfaces of the accused lens meet this limitation (Compl. ¶26). The scope of this term will be dispositive; if it is construed narrowly to require distinct, regular structures, simple surface texturing may not infringe, whereas a broader construction covering general surface roughness could favor the plaintiff's position.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses solving the problem of chromatic aberration, and states that protrusions or "roughness" may be formed on the surface, suggesting the terms could be interpreted interchangeably (’618 Patent, col. 6:9-13).
    • Evidence for a Narrower Interpretation: Figure 8 of the patent depicts the protrusions (363) as distinct, somewhat regularly-spaced bumps on the lens surface, which could support an argument that random texturing is insufficient to meet the claim limitation (’618 Patent, Fig. 8).

For the ’162 Patent

  • The Term: "predominantly uniform irradiance"
  • Context and Importance: This term describes a functional, internal state of the lens, not just its physical shape. Infringement requires proving that the accused lens achieves this specific optical condition on its exit surface (Compl. ¶33). Practitioners may focus on this term because it creates a high evidentiary bar and allows for non-infringement arguments based on a different principle of operation, even if the lens shape appears superficially similar.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent’s summary describes the invention as providing "marked improvements over the conventional cans" and remedying a "current lack of suitable optics," which could suggest that "predominantly uniform" implies a significant improvement over the prior art rather than absolute uniformity (’162 Patent, col. 1:45-56).
    • Evidence for a Narrower Interpretation: The patent provides a detailed mathematical and graphical explanation of how to map a non-uniform input to a uniform output, including Figure 3, which contrasts a "highly nonuniform" distribution with a "parabolic curve... for uniform illuminance." This detailed technical disclosure may support a narrower, more quantitative definition of what constitutes "predominantly uniform" (’162 Patent, col. 4:25-34, Fig. 3).

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement. Each count alleges direct infringement under 35 U.S.C. § 271(a) (e.g., Compl. ¶22, 29).
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement and does not plead facts suggesting Defendant had pre-suit knowledge of the patents-in-suit.

VII. Analyst’s Conclusion: Key Questions for the Case

This case presents a broad challenge to the accused product, asserting infringement of ten patents that cover the device from its macro-level optical components down to its semiconductor-level material composition. The resolution will likely depend on the following key questions:

  • A core issue will be one of structural interpretation: For the numerous patents related to the physical construction of the LED package (e.g., the ’552 and ’967 patents) and the semiconductor chip itself (e.g., the ’157, ’212, and ’800 patents), can the features shown in Plaintiffs' microscope and x-ray images be definitively mapped to the specific, and often complex, claim limitations, such as "three undercut sidewalls" or a multi-layer p-type region with a specific doping profile?
  • A second key issue will be one of functional proof: For the optics-focused patents (e.g., the ’618 and ’162 patents), does the accused lens perform the specific, multi-part optical functions required by the claims—such as creating an internal "predominantly uniform irradiance"—or is there a fundamental mismatch in the technical principle of operation, despite any structural similarities?
  • A final question will be evidentiary sufficiency: Given the sheer number and technical diversity of the asserted patents, can the evidence presented in the complaint, which relies heavily on visual analysis of a deconstructed product, withstand scrutiny for each of the ten distinct infringement theories, or will certain allegations fail for lack of detailed proof on every claim element?