DCT
1:24-cv-00272
Sensor Electronic Technology Inc v. Laser Components USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sensor Electronic Technology, Inc. (South Carolina)
- Defendant: Laser Components USA, Inc. (New Hampshire)
- Plaintiff’s Counsel: Hinckley Allen; Radulescu LLP
- Case Identification: Sensor Electronic Technology, Inc. v. Laser Components USA, Inc., 1:24-cv-00272, D.N.H., 08/30/2024
- Venue Allegations: Plaintiff alleges venue is proper in the District of New Hampshire because Defendant is incorporated there and maintains a regular and established place of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s ultraviolet light-emitting diode (UV LED) product infringes four patents related to semiconductor heterostructure design and fabrication.
- Technical Context: The technology at issue involves the design of semiconductor layers in UV LEDs to improve efficiency and reliability, a field critical for applications such as disinfection, optical sensing, and polymer curing.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2013-01-09 | U.S. Patent No. 9,966,496 Earliest Priority Date |
| 2013-09-03 | U.S. Patent No. 11,508,871 Earliest Priority Date |
| 2013-09-03 | U.S. Patent No. 11,611,011 Earliest Priority Date |
| 2015-10-01 | U.S. Patent No. 10,854,785 Earliest Priority Date |
| 2018-05-08 | U.S. Patent No. 9,966,496 Issues |
| 2020-12-01 | U.S. Patent No. 10,854,785 Issues |
| 2022-11-22 | U.S. Patent No. 11,508,871 Issues |
| 2023-03-21 | U.S. Patent No. 11,611,011 Issues |
| 2024-08-30 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,966,496 - “Light Emitting Heterostructure with Partially Relaxed Semiconductor Layer”
The Invention Explained
- Problem Addressed: The patent’s background section describes that the process of growing layered semiconductor materials for devices like LEDs creates internal stresses, which can lead to crystal defects such as dislocations and cracks that degrade device efficiency (ʼ496 Patent, col. 1:25-34).
- The Patented Solution: The invention introduces a “partially relaxed semiconductor layer” as a sublayer within one of the device’s contact layers. This layer is designed to intentionally relax, thereby containing stress and associated defects, and preventing them from propagating into the critical light-generating part of the device. The solution may also include a “dislocation blocking structure” to further impede the spread of defects (ʼ496 Patent, Abstract; col. 2:25-47).
- Technical Importance: This approach seeks to enable the fabrication of higher-quality semiconductor crystals with fewer defects, a key factor for improving the performance and lifespan of high-power UV LEDs (ʼ496 Patent, col. 1:25-29).
Key Claims at a Glance
- The complaint asserts one or more claims, including exemplary independent claim 1 (Compl. ¶29).
- The essential elements of claim 1 include:
- A substrate and an adjacent buffer layer.
- A light generating structure.
- An n-type and a p-type contact semiconductor layer on opposite sides of the light generating structure.
- An embedded “partially relaxed sublayer” within at least one of the contact semiconductor layers.
- A “dislocation blocking structure” located between the partially relaxed sublayer and the light generating structure, where this blocking structure has a “graded composition.”
U.S. Patent No. 10,854,785 - “Contact Configuration for Optoelectronic Device”
The Invention Explained
- Problem Addressed: The patent’s background explains that metal contacts used to apply electricity to an LED can absorb the light generated by the device, which reduces its overall light extraction efficiency (’785 Patent, col. 1:57-63).
- The Patented Solution: The invention discloses a multi-layer contact configuration that separates the electrical and optical functions. It includes a first metallic layer designed to form a good “ohmic contact” for electrical conductivity, and a second metallic layer made of a different, “reflective metallic material” to reflect light away from the contact area and out of the device, thereby improving light extraction (’785 Patent, Abstract; col. 2:10-25).
- Technical Importance: This design aims to increase the external quantum efficiency of optoelectronic devices by simultaneously optimizing for low electrical resistance and high optical reflectivity at the contact interface (’785 Patent, col. 1:16-19).
Key Claims at a Glance
- The complaint asserts one or more claims, including exemplary independent claim 1 (Compl. ¶34).
- The essential elements of claim 1 include:
- An n-type semiconductor layer with a surface, upon which a "mesa" structure is located.
- An n-type contact region distinct from the mesa.
- A first n-type metallic contact layer over a portion of the contact region, forming an “ohmic contact.”
- A second n-type metallic contact layer over another portion of the contact region, formed of a “reflective metallic material.”
- The first and second layers are formed of distinct metals.
- The n-type semiconductor layer includes at least one “scattering element.”
U.S. Patent No. 11,508,871 - “Heterostructure Including a Semiconductor Layer With a Varying Composition”
- Technology Synopsis: The patent addresses performance degradation in UV LEDs caused by defect formation and inefficient movement of charge carriers (holes) in the p-type doped layers (’871 Patent, col. 2:20-29). The described solution involves a heterostructure with a specially designed electron blocking layer, comprising a “superlattice” of alternating sublayers, and an adjacent p-type interlayer with graded and constant composition regions to manage internal strain and improve device reliability (’871 Patent, Abstract; col. 2:31-46).
- Asserted Claims: The complaint asserts one or more claims, including exemplary claim 6 (Compl. ¶42).
- Accused Features: Plaintiff alleges that the accused UV LED chip’s heterostructure includes an active region, a p-type layer, a superlattice electron blocking layer, and a p-type interlayer with graded and constant aluminum alloy compositions that correspond to the elements of claim 6 (Compl. ¶46).
U.S. Patent No. 11,611,011 - “Heterostructure Including a Semiconductor Layer With a Graded Composition”
- Technology Synopsis: This patent, related to the ’871 Patent, also focuses on reducing degradation in UV LEDs by optimizing the layers adjacent to the active region (’011 Patent, col. 2:20-29). The solution centers on a heterostructure with a graded electron blocking layer and a p-type interlayer that itself includes a region of “linearly graded transition” and a region of constant composition, designed to manage material properties for improved device performance (’011 Patent, Abstract; col. 12:20-29).
- Asserted Claims: The complaint asserts one or more claims, including exemplary claim 12 (Compl. ¶49).
- Accused Features: Plaintiff alleges the accused UV LED chip contains a heterostructure with a graded electron blocking layer and a p-type interlayer having both a linearly graded transition and a region of constant composition, which are alleged to meet the limitations of claim 12 (Compl. ¶53).
III. The Accused Instrumentality
Product Identification
- The accused product is the PHOTON WAVE PKD-H10-F35 UV LED (Compl. ¶29).
Functionality and Market Context
- The complaint identifies the accused product as a UV LED chip comprising a semiconductor heterostructure (Compl. ¶¶ 30, 44, 51). Plaintiff provides Transmission Electron Microscope (TEM) and other microscopic images purporting to show the cross-section of the accused device’s layered structure (Compl. ¶¶ 30, 37-38, 45, 52). The complaint provides one such annotated TEM image showing, among other things, a cross section of a heterostructure including various layers such as the substrate, buffer layer, and light generating structure (Compl. ¶30). The complaint alleges that Defendant makes, uses, sells, offers to sell, or imports this product in the United States (Compl. ¶29).
IV. Analysis of Infringement Allegations
’496 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a substrate; a buffer layer adjacent to the substrate; | The complaint alleges the accused device includes a substrate and an adjacent buffer layer. | ¶31 | col. 7:15-17 |
| a light generating structure having a first side and a second side wherein the substrate is transparent to light generated by the light generating structure; | The device is alleged to have a light generating structure and a substrate transparent to the light it generates. | ¶31 | col. 7:17-20 |
| an n-type contact semiconductor layer located on the first side of the light generating structure; a p-type contact semiconductor layer located on the second side of the light generating structure... | The device is alleged to include n-type and p-type contact semiconductor layers on opposing sides of the light generating structure. | ¶31 | col. 7:26-30 |
| wherein at least one of the contact semiconductor layers includes an embedded partially relaxed sublayer, and wherein at least one of the contact semiconductor layers is located between the light generating structure and the buffer layer... | The complaint, referencing an annotated TEM image, alleges that one of the contact semiconductor layers includes an "embedded partially relaxed sublayer" located between the buffer and active layers. | ¶31 | col. 5:58-62 |
| a dislocation blocking structure located between the partially relaxed sublayer and the light generating structure, wherein the dislocation blocking structure includes a graded composition that changes from a first side of the dislocation blocking structure to the second side thereof. | A "dislocation blocking structure" is alleged to be located between the sublayer and the active region, which includes a graded composition. | ¶31 | col. 6:1-5 |
- Identified Points of Contention:
- Scope Questions: A central question may be the construction of "partially relaxed sublayer." The parties may dispute the degree of crystalline relaxation required to meet this limitation and the evidence sufficient to prove it.
- Technical Questions: The complaint alleges the dislocation blocking structure has a "graded composition" (Compl. ¶31). What evidence supports this specific compositional profile in the accused device, as opposed to other structures described in the patent, such as alternating tensile and compressive layers ('496 Patent, col. 8:1-12), will likely be a key factual issue.
’785 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an n-type semiconductor layer having a surface; a mesa located over a first portion of the surface of the n-type semiconductor layer and having a mesa boundary; an n-type contact region located over a second portion of the surface...entirely distinct from the first portion... | Based on FIB-SEM images, the complaint alleges the accused device has an n-type semiconductor layer, a mesa structure on its surface, and a distinct n-type contact region. The complaint provides an annotated cross-section image of this structure (Compl. ¶38). | ¶38 | col. 5:8-14 |
| a first n-type metallic contact layer located over at least a portion of the n-type contact region in proximity of the mesa boundary, wherein the first n-type metallic contact layer forms an ohmic contact with the n-type semiconductor layer; | The device is alleged to have a first n-type metallic contact layer near the mesa boundary that forms an ohmic contact with the semiconductor layer. | ¶38 | col. 2:18-22 |
| a second metallic contact layer located over a second portion of the n-type contact region, wherein the second metallic contact layer is formed of a reflective metallic material... wherein the first metal is distinct from the second metal... | The device is alleged to have a second n-type metallic contact layer made of a reflective material that is distinct from the material of the first contact layer. | ¶39 | col. 9:25-29 |
| and wherein the n-type semiconductor layer includes at least one-scattering element. | The complaint alleges, based on FIB-SEM images, that at least one scattering element is arranged in the n-type semiconductor layer. | ¶39 | col. 11:39-42 |
- Identified Points of Contention:
- Scope Questions: The definition of "scattering element" will likely be a focus of claim construction. The question may arise whether the term is limited to intentionally engineered structures, such as the patent’s disclosed “photonic crystal” (’785 Patent, col. 11:45), or if it can also read on incidental features or voids within the semiconductor layer.
- Technical Questions: A factual question will be whether the two accused metallic layers are, in fact, formed of "distinct" metals and perform the separate ohmic and reflective functions as claimed.
V. Key Claim Terms for Construction
’496 Patent
- The Term: "partially relaxed sublayer"
- Context and Importance: This term is central to the asserted claim and describes the core inventive concept. Whether the accused device infringes will depend heavily on whether a sublayer within its structure meets the technical and legal definition of being "partially relaxed."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines a layer as partially relaxed when "stresses in the layer are reduced by a few hundredth of a percent due to relaxation process" (’496 Patent, col. 6:15-18). This functional definition could support a broader interpretation that is not tied to a specific method of formation.
- Evidence for a Narrower Interpretation: The patent describes forming the layer using a "three-dimensional growth technique" that facilitates dislocation formation and results in islands coalescing (’496 Patent, col. 7:15-30). This may support an argument that the term is limited to layers with these specific structural characteristics or methods of manufacture.
’785 Patent
- The Term: "scattering element"
- Context and Importance: This is a specific structural element required by the asserted independent claim. The presence or absence of a feature meeting this definition in the accused device could be dispositive for infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that "scattering elements 82 can comprise voids within the layer 16" (’785 Patent, col. 11:40-41). This could support an argument that any void or structural irregularity that scatters light meets the claim limitation.
- Evidence for a Narrower Interpretation: The same section of the specification also discloses that "the scattering elements 82 comprise an array of voids, where the array can comprise a photonic crystal" (’785 Patent, col. 11:43-45). This reference to an ordered, engineered structure like a photonic crystal may support a narrower construction that excludes incidental or randomly formed voids.
VI. Other Allegations
- Willful Infringement: The complaint requests enhanced damages pursuant to 35 U.S.C. § 284, which is associated with findings of willful or egregious infringement (Compl. p. 14, ¶D). The complaint does not, however, plead any specific facts to support a finding of willfulness, such as allegations of pre-suit knowledge of the patents or copying.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary issue will be one of structural verification and function: Does the accused UV LED possess the highly specific, multi-layered nanostructures alleged in the complaint—such as a "partially relaxed sublayer" (’496 Patent), distinct ohmic and reflective contacts (’785 Patent), and precisely graded superlattices (’871 and ’011 Patents)—and do these structures function in the manner required by the claims? The dispute may hinge on detailed analysis of microscopic and material composition data from the accused product.
- A core legal issue will be one of definitional scope: The case will likely turn on the construction of key technical terms. For instance, can the term “scattering element” in the ’785 patent, which the specification links to engineered photonic crystals, be construed to cover the features observed in the accused device? Similarly, the interpretation of what constitutes a "partially relaxed" layer will be critical to the ’496 patent analysis.