DCT

3:25-cv-00846

ams OSRAM Intl GmbH v. Nature Fresh Farms USA Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00846, N.D. Ohio, 04/28/2025
  • Venue Allegations: Venue is alleged to be proper as Defendant resides in the judicial district, maintains a regular and established place of business in the district, and has committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s horticultural LED lighting product infringes seven patents related to the design, manufacturing, and structure of optoelectronic semiconductor chips.
  • Technical Context: The technology at issue concerns fundamental aspects of Light Emitting Diode (LED) chip fabrication, focusing on methods to improve light extraction efficiency, manufacturing precision, and long-term reliability.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2004-04-30 Earliest Priority Date, ’999 Patent
2008-10-14 Issue Date, U.S. Patent No. 7,435,999
2011-02-14 Earliest Priority Date, ’143 Patent
2013-05-14 Earliest Priority Date, ’871 Patent
2014-05-28 Earliest Priority Date, ’229 Patent
2014-06-12 Earliest Priority Date, ’463 Patent
2016-08-05 Earliest Priority Date, ’540 Patent
2018-01-02 Issue Date, U.S. Patent No. 9,859,463
2018-03-13 Issue Date, U.S. Patent No. 9,917,229
2018-07-17 Issue Date, U.S. Patent No. 10,026,871
2018-12-25 Issue Date, U.S. Patent No. 10,164,143
2018-02-14 Earliest Priority Date, ’052 Patent
2022-09-06 Issue Date, U.S. Patent No. 11,437,540
2024-04-02 Issue Date, U.S. Patent No. 11,949,052
2025-04-28 Complaint Filing Date

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

U.S. Patent No. 7,435,999 - "SEMICONDUCTOR CHIP FOR OPTOELECTRONICS AND METHOD FOR THE PRODUCTION THEREOF"

  • Patent Identification: U.S. Patent No. 7435999, "SEMICONDUCTOR CHIP FOR OPTOELECTRONICS AND METHOD FOR THE PRODUCTION THEREOF," issued October 14, 2008.
  • The Invention Explained:
    • Problem Addressed: In thin-film optoelectronic chips, a significant portion of the generated light can be absorbed by the electrical contacts on the front (emission) side of the chip, which reduces overall efficiency ('999 Patent, col. 2:5-9).
    • The Patented Solution: The patent describes a semiconductor chip with a trench formed on its rear side. This trench is designed with oblique inner walls that act as reflective surfaces. Light traveling toward the rear of the chip is deflected by these angled walls away from the light-absorbing front-side contacts and redirected toward the emission surface, thereby increasing the light extraction efficiency ('999 Patent, Abstract; col. 2:10-25).
    • Technical Importance: This approach provided a structural solution to the persistent problem of light loss in thin-film LEDs, offering a method to increase brightness and energy efficiency without altering the fundamental semiconductor materials ('999 Patent, col. 2:48-51).
  • Key Claims at a Glance:
    • The complaint incorporates by reference a claim chart (Exhibit 1) that was not publicly filed and does not otherwise specify which claims are asserted. Assuming assertion of the first independent apparatus claim, its key elements are:
      • A thin-film layer with an emission side and a rear side.
      • At least one trench formed on the rear side.
      • At least one electrical front side contact structure on the emission side.
      • The trench defines at least one partial region on the rear side that does not overlap with the front side contact structure.
      • A carrier connected to the rear side.
      • Electrical rear side contacts formed only in the defined partial region.
      • The trench has oblique inner walls for deflecting radiation.
    • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,026,871 - "METHOD FOR PRODUCING AN OPTOELECTRONIC DEVICE WITH A CONTACT AREA OF ACCURATELY AND REPRODUCIBLY DEFINED SIZE"

  • Patent Identification: U.S. Patent No. 10026871, "METHOD FOR PRODUCING AN OPTOELECTRONIC DEVICE WITH A CONTACT AREA OF ACCURATELY AND REPRODUCIBLY DEFINED SIZE," issued July 17, 2018.
  • The Invention Explained:
    • Problem Addressed: The patent's background explains that conventional photolithography methods for creating electrical contact areas on LED chips are subject to adjustment tolerances, leading to variations in the contact area's size. This variability can negatively impact chip performance, such as forward voltage and light yield ('871 Patent, col. 1:25-44).
    • The Patented Solution: The invention discloses a device and method that uses a photoresist layer to define an opening, through which a dielectric layer is etched to expose the semiconductor crystal. The process is designed to create an underetch, where the opening in the dielectric becomes larger than the opening in the photoresist, allowing for the creation of a metal contact area with a highly accurate and reproducible size ('871 Patent, col. 4:25-58; Fig. 4).
    • Technical Importance: This manufacturing technique allows for greater precision and consistency in the production of optoelectronic devices, which is a critical factor for achieving high manufacturing yields and uniform performance in mass-produced components like LEDs ('871 Patent, col. 2:1-14).
  • Key Claims at a Glance:
    • The complaint incorporates by reference a claim chart (Exhibit 4) that was not publicly filed and does not otherwise specify which claims are asserted. Assuming assertion of the first independent apparatus claim, its key elements are:
      • A semiconductor crystal with a surface comprising first, second, and third lateral regions.
      • A contact area (with a first metal) on the surface in the first lateral region.
      • A first layer (comprising a dielectric) arranged on the surface in the third lateral region.
      • A second layer (optically transparent, electrically conductive material) arranged on the contact area, the first layer, and the second lateral region.
      • A third layer (with a second metal) arranged on the second layer.
    • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 10,164,143

  • Patent Identification: U.S. Patent No. 10164143, "OPTOELECTRONIC SEMICONDUCTOR CHIP AND METHOD FOR PRODUCING OPTOELECTRONIC SEMICONDUCTOR CHIPS," issued December 25, 2018.
  • Technology Synopsis: The patent addresses the problem of chip degradation caused by environmental factors like moisture or oxidation, particularly affecting reflective mirror layers. The invention is an optoelectronic chip with an "encapsulation layer" arranged between a connection layer and a carrier. This encapsulation layer projects beyond the side face of the semiconductor body, effectively sealing and protecting the sensitive internal layers from the surrounding environment to improve aging stability and reliability ('143 Patent, Abstract; col. 2:62-col. 3:2).
  • Asserted Claims: Not specified in the complaint; referenced in the non-public Exhibit 5 (Compl. ¶32).
  • Accused Features: The Agrolux WEGA PLUS 760W LED product is accused of infringement (Compl. ¶32).

Multi-Patent Capsule: U.S. Patent No. 11,437,540

  • Patent Identification: U.S. Patent No. 11437540, "COMPONENT HAVING METAL CARRIER LAYER AND LAYER THAT COMPENSATES FOR INTERNAL MECHANICAL STRAINS," issued September 6, 2022.
  • Technology Synopsis: This patent tackles the issue of internal mechanical strains that arise during the manufacturing of semiconductor components, which can cause undesirable deformations like wafer "roll up." The solution is a component carrier that includes a metallic carrier layer and a "compensating layer" arranged adjacent to it. The compensating layer is specifically designed with material properties and/or thickness to counteract the strain from the metallic layer, resulting in a mechanically stable, flat component ('540 Patent, Abstract; col. 1:15-27, col. 1:43-47).
  • Asserted Claims: Not specified in the complaint; referenced in the non-public Exhibit 6 (Compl. ¶38).
  • Accused Features: The Agrolux WEGA PLUS 760W LED product is accused of infringement (Compl. ¶38).

Multi-Patent Capsule: U.S. Patent No. 11,949,052

  • Patent Identification: U.S. Patent No. 11949052, "OPTOELECTRONIC SEMICONDUCTOR COMPONENT AND METHOD OF PRODUCING AN OPTOELECTRONIC SEMICONDUCTOR COMPONENT," issued April 2, 2024.
  • Technology Synopsis: The patent describes a structure for an optoelectronic component that enables efficient electrical contact with minimal optical losses. The invention uses an electrically insulating separation layer on the bottom side of the semiconductor, which contains numerous small openings. A continuous metallization layer is located below this separation layer and makes direct contact with the semiconductor through the openings. This design allows the metallization layer to function as both an electrical contact and a reflective mirror while minimizing the surface area that could absorb light ('052 Patent, Abstract; col.2:63-col.3:3).
  • Asserted Claims: Not specified in the complaint; referenced in the non-public Exhibit 7 (Compl. ¶44).
  • Accused Features: The Agrolux WEGA PLUS 760W LED product is accused of infringement (Compl. ¶44).

Note: The complaint also asserts U.S. Patent Nos. 9859463 and 9917229. The patent documents for these were not provided, precluding their analysis.

III. The Accused Instrumentality

  • Product Identification: The accused instrumentality is the "Agrolux WEGA PLUS 760W LED product" (Compl. ¶8).
  • Functionality and Market Context: The complaint identifies the accused instrumentality as an LED product but does not provide any specific technical details regarding its construction, operation, or features (Compl. ¶¶ 8, 14, 20, 26, 32, 38, 44). Similarly, the complaint makes no allegations regarding the product's market position or commercial importance. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendant’s use of the Agrolux WEGA PLUS 760W LED product directly infringes the seven patents-in-suit (Compl. ¶¶ 8, 14, 20, 26, 32, 38, 44). However, the complaint provides no narrative infringement theory or factual support for these allegations in its body. Instead, it incorporates by reference a series of claim chart exhibits (Exhibits 1-7) corresponding to each asserted patent. These exhibits were not attached to the publicly filed complaint. Consequently, a detailed analysis of the infringement allegations or construction of a claim chart is not possible from the provided documents.

  • Identified Points of Contention:
    • ’999 Patent: A central factual question for the court will be whether the accused product’s semiconductor chips incorporate a "trench" on their rear side with "oblique inner walls," as required by the claims. The existence, geometry, and light-deflecting function of such a microscopic structure will be a primary focus of discovery.
    • ’871 Patent: The infringement analysis will likely depend on the specific layered construction of the accused product's electrical contacts. A key question is whether the devices contain the claimed sequence of a dielectric "first layer", a transparent conductive "second layer", and a metallic "third layer" arranged in the precise configuration taught by the patent.

V. Key Claim Terms for Construction

’999 Patent

  • The Term: "trench" (from claim 1).
  • Context and Importance: The existence of a "trench" with specific properties is the central feature of the invention. The construction of this term will define the scope of the claim. Practitioners may focus on this term because Defendant may argue that it is limited to a structure with specific geometric or manufacturing characteristics, whereas Plaintiff may advocate for a broader, more functional definition.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the trench functionally as defining a partial region and having inner walls for deflecting radiation, without limiting it to a single method of formation ('999 Patent, col. 2:15-25).
  • Intrinsic Evidence for a Narrower Interpretation: The figures depict a distinct, sharply-defined channel that appears to be formed by an etching process ('999 Patent, Figs. 3, 4). A defendant may argue that the term "trench" implies a man-made, subtractive feature with defined walls, as opposed to any incidental groove or depression.

’871 Patent

  • The Term: "contact area" (from claim 1).
  • Context and Importance: The invention is directed to forming a "contact area" of a precise and reproducible size. The construction of this term is critical because it anchors the spatial relationships of all other claimed layers.
  • Intrinsic Evidence for a Broader Interpretation: The patent broadly describes the contact area's purpose as "electrically contacting the semiconductor crystal" ('871 Patent, col. 2:3-4), which could support a functional interpretation.
  • Intrinsic Evidence for a Narrower Interpretation: The specification and figures distinguish the "contact area" (410) as a specific metallized region (121) formed within an opening (210), which is itself surrounded by a "tolerance region" (122) ('871 Patent, col. 5:1-12; Fig. 5). A party could argue the "contact area" is limited to this specific, intentionally-defined structure and does not include the surrounding tolerance region, narrowing the claim's scope.

VI. Other Allegations

The complaint does not allege indirect or willful infringement.

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

  • An Evidentiary Question of Structure: Given the complaint’s lack of technical detail, a threshold issue for the court will be evidentiary. Can the plaintiff, through discovery and reverse engineering, demonstrate that the accused commercial LED product actually contains the highly specific and complex microscopic structures recited across the seven asserted patents, such as the rear-side "trenches" of the ’999 patent, the protective "encapsulation layer" of the ’143 patent, and the "strain-compensating layer" of the ’540 patent?
  • A Legal Question of Scope and Combination: The case presents a question of cumulative scope. The patents-in-suit claim distinct inventive concepts with priority dates spanning from 2004 to 2018. A central legal battle will likely be whether the claims of these multiple, independently-developed technologies can all be construed to read on the specific combination of features found in a single accused product, or if mismatches in technical details or claim language will preclude infringement of some or all of the patents.