DCT

2:13-cv-00702

Nichia Corp v. Everlight Electronics Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:13-cv-00702, E.D. Tex., 09/11/2013
  • Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant Everlight Americas, Inc. is incorporated in Texas, maintains a principal place of business within the district, and sells or offers for sale the accused LED products within the judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s LED products infringe a patent related to the physical structure of a semiconductor device, specifically a design intended to prevent adhesive bleeding during the manufacturing process.
  • Technical Context: The technology relates to the packaging of semiconductor devices like LEDs, where ongoing miniaturization creates manufacturing challenges such as controlling the flow of die-bonding adhesives on small components.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

Date Event
2006-04-19 '589 Patent Priority Date
2008-10-07 '589 Patent Issue Date
2013-09-11 Complaint Filing Date

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

U.S. Patent No. 7,432,589 - "Semiconductor Device"

  • Patent Identification: U.S. Patent No. 7,432,589, “Semiconductor Device,” issued October 7, 2008.

The Invention Explained

  • Problem Addressed: The patent addresses a problem in the manufacturing of small semiconductor devices where an adhesive used to bond a semiconductor element (die) to a lead electrode can spread, or "bleed," onto an adjacent area on the same electrode that is reserved for wire bonding (’589 Patent, col. 2:1-10). This adhesive contamination can interfere with or prevent the subsequent electrical connection of wires, a problem exacerbated as devices become smaller (’589 Patent, col. 1:26-35).
  • The Patented Solution: The invention proposes a physical barrier, or "wall," formed on the surface of the lead electrode to partition the die-bonding area from the wire-bonding area. To solve the problem of the wall itself having poor adhesion and allowing leakage, the patent teaches creating a "cut-out portion," such as a notch, in the lead electrode directly beneath the wall. This allows the molding material of the device's housing to flow through the notch, creating a strong physical connection between the housing and the wall, which improves the wall's adhesion to the electrode and more effectively prevents adhesive leakage (’589 Patent, col. 3:1-29; Fig. 2C).
  • Technical Importance: This structural design enables more reliable manufacturing of smaller and thinner semiconductor devices by providing a robust solution to the adhesive overflow problem, even when using adhesives with low surface tension that are prone to spreading (’589 Patent, col. 2:60-65).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶10).
  • The essential elements of Claim 1 include:
    • A semiconductor device comprising a semiconductor element, a housing with a recess, first and second lead electrodes, an adhesive layer, and conductive wires.
    • The housing has at least one wall formed to extend across the first lead electrode, dividing its surface into a die bonding area and a wire bonding area.
    • The first lead electrode has a notch formed by cutting off a portion of an edge of the electrode, located at least just below the wall.
    • The wall and the bottom portion of the housing are connected to each other through the notch.
  • The complaint’s phrasing ("at least claim 1") suggests a reservation of the right to assert other claims, including dependent claims.

III. The Accused Instrumentality

Product Identification

  • The complaint specifically identifies "Everlight's LED model 61-238/RSGBB7C-B02/ET" as an infringing product (Compl. ¶10).

Functionality and Market Context

  • The complaint identifies the accused instrumentality as an "LED product" (Compl. ¶10). The complaint does not provide sufficient detail for analysis of the device's specific internal construction, materials, or manufacturing methods.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendants infringe "at least claim 1 of the ‘589 Patent" through the "manufacture, use, importation, sale, and/or offer for sale" of their LED products (Compl. ¶10). However, the complaint does not provide a detailed, element-by-element breakdown of its infringement theory or a claim chart. The infringement allegation is stated in a conclusory manner, asserting that the accused products meet the limitations of the claim.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Evidentiary Question: A primary question will be evidentiary: what proof will Plaintiff offer to demonstrate that the accused Everlight LED products contain the specific structural features recited in Claim 1? This analysis will likely require discovery, including disassembly and technical imaging of the accused devices to reveal their internal structure.
  • Structural Question: The infringement analysis will likely focus on whether the accused LED products possess a "wall" separating die and wire bonding areas on a single lead electrode, and critically, whether that lead electrode contains a "notch" through which the device's housing material connects to the wall, as required by the final two limitations of Claim 1 (’589 Patent, col. 16:6-18).

V. Key Claim Terms for Construction

The Term: "notch"

  • Context and Importance: This term defines a central physical feature of the invention. The scope of "notch" will determine what kind of physical void or cut in the lead electrode can meet this limitation.
  • Intrinsic Evidence for a Broader Interpretation: The specification also refers to the feature more generally as a "cut-out portion" which may have the "form of a notch... or a form of through hole" (’589 Patent, col. 3:41-43), potentially supporting an interpretation not strictly limited to the edge of the electrode.
  • Intrinsic Evidence for a Narrower Interpretation: Claim 1 itself defines the term more restrictively as "a notch which is formed by cutting off a portion of an edge of the first lead electrode" (’589 Patent, col. 16:10-12). A defendant may argue this express language limits the claim scope to features on the electrode’s periphery, as depicted in figures like Fig. 2B (element 36).

The Term: "wall"

  • Context and Importance: This term defines the barrier structure. Practitioners may focus on this term because its construction will determine what type of physical feature constitutes the claimed barrier—for instance, whether it must be of a certain material or formed in a specific way.
  • Intrinsic Evidence for a Broader Interpretation: The claim requires a "wall formed to extend across the bottom surface of the recess so as to divide the surface" (’589 Patent, col. 16:6-9). This functional language could support reading the term on any raised structure that performs the dividing function.
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes the wall as being formed from molding material and integrally with the housing during the molding process (’589 Patent, col. 8:8-11, 30-34). A party could argue that a "wall" must be an integrally molded feature of the housing, not a separately attached component or a feature formed from a different material.

The Term: "connected to each other through the notch"

  • Context and Importance: This phrase is critical as it describes the required structural relationship between the housing, the wall, and the notch. The dispute will likely center on the required nature and extent of this connection.
  • Intrinsic Evidence for a Broader Interpretation: A plaintiff might argue that any physical continuity of the housing material that passes through the notch and contacts the wall satisfies the "connected" limitation.
  • Intrinsic Evidence for a Narrower Interpretation: The patent explains that this connection serves to "improve adhesiveness" and "increase[] the strength of the first wall" (’589 Patent, col. 6:55-59). A defendant may argue that a merely incidental or trivial contact is insufficient, and that the term requires a structural integration that achieves this strengthening function.

VI. Other Allegations

Willful Infringement

  • The complaint includes a prayer for a finding that Defendants' infringement has been "willful and deliberate" (Compl., Prayer for Relief D). The pleading does not allege any facts suggesting pre-suit knowledge by Defendants, such as a prior notice letter. The basis for willfulness may therefore rest on notice provided by the filing and service of the complaint itself, targeting post-suit conduct.

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

Given the "notice pleading" style of the complaint, the specific factual and legal contours of the dispute will be defined in later stages of litigation. However, the initial documents point to two central questions:

  • A core issue will be one of factual existence: do the accused Everlight LED products physically contain the specific structural combination recited in Claim 1—namely, a wall on a lead electrode that is mechanically anchored to the device housing via a notch cut into the edge of that same electrode? Answering this will depend entirely on evidence developed during discovery.
  • A determinative legal issue will be one of claim construction: can the term "notch", which is explicitly defined in Claim 1 as being on the "edge" of the electrode, be interpreted more broadly to cover other types of "cut-out portions" described in the patent's specification? The court’s ruling on this and other key terms will likely be pivotal to the outcome of the infringement analysis.