DCT

2:18-cv-00386

Seoul Semiconductor Co Ltd v. Fry's Electronics Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:18-cv-00386, E.D. Tex., 11/20/2018
  • Venue Allegations: Plaintiffs allege venue is proper because Defendant has a regular and established place of business within the district and has committed acts of infringement there, citing the purchase of accused products from a store in Plano, Texas.
  • Core Dispute: Plaintiffs allege that Defendant’s sale of various televisions and LED lighting products infringes fifteen patents related to a wide array of LED technologies, from semiconductor chip structure and packaging to lens design and phosphor composition.
  • Technical Context: The technology domain is light-emitting diodes (LEDs), fundamental semiconductor components that have become ubiquitous in modern lighting and display applications due to their efficiency and longevity.
  • Key Procedural History: The filing is an Amended Complaint. The complaint does not mention any prior litigation between the parties, licensing history, or post-grant validity proceedings before the U.S. Patent and Trademark Office concerning the patents-in-suit.

Case Timeline

Date Event
2000-08-30 U.S. Patent No. 6,942,731 Priority Date
2004-10-07 U.S. Patent No. 7,901,113 Priority Date
2004-11-12 U.S. Patent No. 7,618,162 Priority Date
2005-03-31 U.S. Patent No. 8,132,952 Priority Date
2005-06-22 U.S. Patent No. 7,951,626 Priority Date
2005-07-04 U.S. Patent No. 8,058,662 Priority Date
2005-09-13 U.S. Patent No. 6,942,731 Issued
2008-11-18 U.S. Patent No. 8,829,552 Priority Date
2009-11-13 U.S. Patent Nos. 9,577,157 & 9,343,631 Priority Date
2009-11-17 U.S. Patent No. 7,618,162 Issued
2009-12-29 U.S. Patent No. 8,525,212 Priority Date
2010-01-07 U.S. Patent No. 9,022,618 Priority Date
2010-06-04 U.S. Patent No. 9,716,210 Priority Date
2011-03-08 U.S. Patent No. 7,901,113 Issued
2011-05-06 U.S. Patent No. 8,608,328 Priority Date
2011-05-31 U.S. Patent No. 7,951,626 Issued
2011-11-15 U.S. Patent No. 8,058,662 Issued
2012-03-13 U.S. Patent No. 8,132,952 Issued
2013-08-26 U.S. Patent No. 9,530,947 Priority Date
2013-09-03 U.S. Patent No. 8,525,212 Issued
2013-12-17 U.S. Patent No. 8,608,328 Issued
2014-08-19 U.S. Patent No. 9,799,800 Priority Date
2014-09-09 U.S. Patent No. 8,829,552 Issued
2015-05-05 U.S. Patent No. 9,022,618 Issued
2016-05-17 U.S. Patent No. 9,343,631 Issued
2016-12-27 U.S. Patent No. 9,530,947 Issued
2017-02-21 U.S. Patent No. 9,577,157 Issued
2017-07-25 U.S. Patent No. 9,716,210 Issued
2017-10-24 U.S. Patent No. 9,799,800 Issued
2018-11-20 Complaint Filing Date

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

U.S. Patent No. 8,829,552 - “Light Emitting Device,” Issued September 9, 2014

The Invention Explained

  • Problem Addressed: The complaint does not explicitly quote the problem statement from the patent, but the allegations suggest the invention addresses the mechanical instability of lead frames within an LED package (Compl. ¶¶45-47). Lead frames provide electrical connection to the LED chip and must be held securely within the molded resin body of the package.
  • The Patented Solution: The invention proposes a specific lead frame geometry to improve mechanical anchoring within the molded package. It describes lead frames with "inset sidewalls" that create a "fixing space" undercutting the lead frame's upper surface (Compl. ¶47). When the package is filled with resin, the resin flows into this undercut space, creating a mechanical interlock that secures the lead frames against movement or delamination (Compl. ¶47).
  • Technical Importance: Enhancing the mechanical integrity of LED packages improves the long-term reliability of the device by preventing failures related to electrical connection breaks or physical stress.

Key Claims at a Glance

  • The complaint asserts exemplary independent claim 1 (Compl. ¶41). Based on the allegations, its essential elements include:
    • A pair of spaced-apart lead frames, each having an upper and lower surface and sidewalls connecting them.
    • A light-emitting diode chip on the top surface of one lead frame.
    • Inset sidewalls on the lead frames that at least partially define a fixing space.
    • The fixing space undercuts the upper surface of the lead frame.
    • The fixing space is filled with resin.
  • The complaint reserves the right to assert additional claims (Compl. ¶41).

U.S. Patent No. 8,525,212 - “Light-Emitting Diode Having Electrode Extensions,” Issued September 3, 2013

The Invention Explained

  • Problem Addressed: The complaint's infringement allegations imply the patent addresses non-uniform current distribution in LED chips (Compl. ¶¶61-62). Current injected through small electrode pads tends to concentrate nearby, causing uneven brightness, reduced efficiency, and localized heating.
  • The Patented Solution: The invention describes adding conductive "extensions" or fingers that project from the primary n-type and p-type electrode pads across the surface of the semiconductor layers (Compl. ¶¶61-62; '212 Patent, Abstract). These extensions serve to spread the electrical current over a wider area of the chip's active layer, promoting more uniform light emission and improving overall device performance (Compl. ¶¶61-62).
  • Technical Importance: Improved current spreading is a fundamental technique for increasing the light output and electrical efficiency of high-power LED chips.

Key Claims at a Glance

  • The complaint asserts exemplary independent claim 1 (Compl. ¶56). Based on the allegations, its essential elements include:
    • A light emitting diode with an n-electrode pad and a p-electrode pad.
    • Two n-extensions extending from the n-electrode pad.
    • Three p-extensions extending from the p-electrode pad.
    • A specific geometric arrangement where the top and bottom p-extensions enclose the two n-extensions, and a third central p-extension extends between the two n-extensions.
  • The complaint reserves the right to assert additional claims (Compl. ¶56).

U.S. Patent No. 7,901,113 - “Side Illumination Lens and Luminescent Device Using the Same,” Issued March 8, 2011

Technology Synopsis

The patent relates to a lens designed to redirect light from an LED chip sideways rather than forward (Compl. ¶65). The invention uses a combination of a "total reflection surface" and curved "refractive surfaces" to control the light path for side-illumination applications, such as in television backlights (Compl. ¶69).

Asserted Claims

Exemplary claim 1 (Compl. ¶65).

Accused Features

The lens assembly in the RCA LED TV LED24G45RQ television is accused of having the claimed total reflection and refractive surfaces (Compl. ¶¶66, 69).

U.S. Patent No. 9,022,618 - “Aspherical LED Lens and Light Emitting Device Including the Same,” Issued May 5, 2015

Technology Synopsis

This patent describes an aspherical and rotationally symmetrical lens for an LED (Compl. ¶75). The lens features a central cavity for the LED, a light entrance plane, and a specifically configured light exit plane with a textured, curved side surface to shape the output light beam (Compl. ¶¶75-76).

Asserted Claims

Exemplary claim 1 (Compl. ¶72).

Accused Features

The lens used in the RCA LED TV LED55C55R120Q is accused of having the claimed aspherical shape, central cavity, and textured light exit plane (Compl. ¶¶73, 75-76).

U.S. Patent No. 8,608,328 - “Light Source with Secondary Emitter Conversion Element,” Issued December 17, 2013

Technology Synopsis

The patent relates to creating white light by combining a primary light source (an LED chip) with a "secondary emitter conversion element" (a phosphor) (Compl. ¶82). The phosphor absorbs some of the LED's initial light (e.g., blue light) and re-emits it at a longer wavelength (e.g., yellow), with the combination of the two colors appearing as white light (Compl. ¶82).

Asserted Claims

Exemplary claim 33 (Compl. ¶79).

Accused Features

The light emitting devices in the RCA LED TV LED60B55R120Q are accused of using a phosphor layer over a blue LED to generate light, which allegedly constitutes the claimed secondary emitter conversion element (Compl. ¶¶80, 82).

U.S. Patent No. 7,618,162 - “Irradiance-Redistribution Lens and Its Applications to LED Downlights,” Issued November 17, 2009

Technology Synopsis

This patent describes a lens designed to take a non-uniform light input from a nearby LED and redistribute it to create a "diverging output beam" with "predominantly uniform irradiance" (Compl. ¶¶89-90). This is achieved through specifically shaped light entry and light exit surfaces (Compl. ¶90).

Asserted Claims

Exemplary claim 1 (Compl. ¶86).

Accused Features

The lens in the RCA LED TV LED55C55R120Q is accused of having the claimed concave light entry and exit surfaces that produce a diverging beam with uniform irradiance (Compl. ¶¶89-90).

U.S. Patent No. 9,530,947 - “Lens and Light Emitting Module For Surface Illumination,” Issued December 27, 2016

Technology Synopsis

The patent relates to a lens for diffusing light, featuring a central concavity that forms a light incident surface (Compl. ¶97). The upper surface, through which light exits, is described as having at least three sequential sections with changing curvature to shape the output beam (Compl. ¶¶98-99).

Asserted Claims

Exemplary claim 11 (Compl. ¶94).

Accused Features

The lenses in the RCA LED TV LED55C55R120Q are accused of having the claimed central concavity and an upper surface with at least three sequential sections of changing curvature (Compl. ¶¶95, 97, 99).

U.S. Patent No. 8,132,952 - “Backlight Panel Employing White Light Emitting Diode Having Red Phosphor and Green Phosphor,” Issued March 13, 2012

Technology Synopsis

The patent describes a backlight panel for a display that uses white LEDs created from a blue LED chip combined with red and green phosphors (Compl. ¶103). The combination of blue light from the chip and re-emitted red and green light from the phosphors produces white light for illuminating the display panel (Compl. ¶¶101-103).

Asserted Claims

Exemplary claim 1 (Compl. ¶101).

Accused Features

The backlight in the RCA LED TV LED60B55R120Q is accused of using white LEDs that employ a blue LED chip covered by a phosphor layer containing particles of green and red phosphor (Compl. ¶103).

U.S. Patent No. 8,058,662 - “Light Emitting Diode and Method of Fabricating the Same,” Issued November 15, 2011

Technology Synopsis

The patent covers an LED package where a molded resin is formed on a frame containing an LED chip (Compl. ¶108). The invention specifies that the molded resin is substantially flush with the edges of the frame and includes a fluorescent material covering the chip to convert the light's wavelength (Compl. ¶108).

Asserted Claims

Exemplary claim 1 (Compl. ¶106).

Accused Features

The light emitting devices in the RCA LED TV LED60B55R120Q are accused of having a molded resin that is flush with the frame edges and a layer of fluorescent particles over the LED chip (Compl. ¶¶107-108).

U.S. Patent No. 9,577,157 - “Light Emitting Diode Chip Having Distributed Bragg Reflector and a Method of Fabricating the Same,” Issued February 21, 2017

Technology Synopsis

The invention relates to an LED chip with a distributed Bragg reflector (DBR) located on the bottom of the substrate (Compl. ¶115). A DBR is a structure made of multiple alternating layers of different refractive index materials, designed to reflect light of specific wavelengths. The patent describes a DBR with two portions having layers of different optical thicknesses (Compl. ¶115).

Asserted Claims

Exemplary claim 1 (Compl. ¶111).

Accused Features

The LED packages in the NTE LED Wall Light 69-LL-10 are accused of containing an LED chip with a DBR on its substrate, allegedly comprising two portions of alternating silicon dioxide and titanium dioxide layers with different thicknesses (Compl. ¶¶112, 115).

U.S. Patent No. 9,343,631 - “Light Emitting Diode Chip Having Distributed Bragg Reflector and Method of Fabricating the Same,” Issued May 17, 2016

Technology Synopsis

The patent describes an LED chip with a two-part distributed Bragg reflector (DBR) designed to reflect light of different wavelengths (Compl. ¶122). The upper DBR is designed for higher reflectivity of shorter wavelength light (e.g., blue light from the active layer), while the lower DBR provides higher reflectivity for longer wavelength light (e.g., light converted by a phosphor) (Compl. ¶122).

Asserted Claims

Exemplary claim 1 (Compl. ¶118).

Accused Features

The LEDs in the NTE LED Wall Light 69-LL-10 are accused of containing a DBR with two portions that provide different reflectivity for shorter-wavelength blue light and longer-wavelength phosphor-converted light (Compl. ¶¶119, 122).

U.S. Patent No. 7,951,626 - “Light Emitting Device and Method of Manufacturing the Same,” Issued May 31, 2011

Technology Synopsis

This patent relates to a method of manufacturing an LED chip. The allegations suggest the claimed process involves forming a mesa with a sloped edge by using a photoresist, hard-baking it to create an inclined edge, and then etching the surface (Compl. ¶130).

Asserted Claims

Exemplary claim 9 (Compl. ¶125).

Accused Features

The RCA LED TV LED55C55R120Q television contains LED chips which Plaintiffs allege on information and belief are made by a process that infringes claim 9, resulting in a mesa with an angular slope (Compl. ¶¶125, 129-130).

U.S. Patent No. 9,799,800 - “Light Emitting Device and Method of Fabricating the Same,” Issued October 24, 2017

Technology Synopsis

The patent relates to the layered structure of an LED's semiconductor material, specifically the p-type layer (Compl. ¶136). The invention describes an p-type layer with multiple sub-layers, including a contact layer, a hole transport layer, and a hole injection layer, distinguished by varying levels of magnesium doping (Compl. ¶¶136-137). An electron blocking layer is also described between the active and p-type layers (Compl. ¶135).

Asserted Claims

Exemplary claim 1 (Compl. ¶133).

Accused Features

The LEDs in the RCA LED TV LED55C55R120Q are accused of having the claimed multi-part p-type semiconductor layer with varying magnesium dopant levels and an electron blocking layer (Compl. ¶¶134-137).

U.S. Patent No. 9,716,210 - “Light Emitting Diode and Method of Fabricating the Same,” Issued July 25, 2017

Technology Synopsis

The patent describes a specific epi-structure for an LED chip grown on a patterned sapphire substrate (Compl. ¶142). The structure includes a multi-quantum well active region, and below it, a superlattice layer and a spacer layer, each comprising multiple layers and having different bandgaps (Compl. ¶¶142-143).

Asserted Claims

Exemplary claim 1 (Compl. ¶140).

Accused Features

The LEDs in the NTE LED Wall Light 69-LL-10 are accused of having the claimed epi-structure, including a superlattice layer and a spacer layer below the active region (Compl. ¶¶141-142).

U.S. Patent No. 6,942,731 - “Method for Improving the Efficiency of Epitaxially Produced Quantum Dot Semiconductor Components,” Issued September 13, 2005

Technology Synopsis

This patent relates to a method for manufacturing semiconductor components with quantum dots (Compl. ¶145; '731 Patent, Abstract). The allegations suggest the claimed process involves interrupting crystal growth after a layer of quantum dots has been covered with another semiconductor material (Compl. ¶149). This interruption allegedly improves the efficiency of the device ('731 Patent, Abstract).

Asserted Claims

Exemplary claim 1 (Compl. ¶145).

Accused Features

The NTE LED Wall Light 69-LL-10 contains LED chips which Plaintiffs allege on information and belief are made by a process that includes the claimed growth interruption step after overgrowing quantum dot layers (Compl. ¶¶145, 148-149).

III. The Accused Instrumentality

Product Identification

The complaint names several categories of accused products sold by Fry's Electronics:

  • Televisions: RCA LED TV models LED24G45RQ, LED55C55R120Q, and LED60B55R120Q; Philips 55PFL5402/F7 (Compl. ¶¶8, 16).
  • Lighting Products: Ottlite LED Task Lamp 290G59; NTE LED Wall Light 69-LL-10; NTE LED Light Bar 69-LL-15 (Compl. ¶12).

Functionality and Market Context

  • The accused products are consumer electronics (televisions) and general lighting fixtures (task lamp, wall light, light bar) that utilize LED technology as their light source (Compl. ¶¶7, 41, 56, 65).
  • The complaint alleges infringement by components within these products, such as the LED chips themselves, the packaging for those chips, the lenses used to shape the light, and the phosphor systems used to create white light for the television backlights and lamps (Compl. Counts I-XV). The complaint provides images of the packaging for the accused RCA televisions and Ottlite and NTE lighting products (Compl. ¶¶9, 10, 13, 14, 15). A screenshot of the Fry's webpage for the Philips television is also provided, indicating its sale by the Defendant (Compl. ¶17).
  • The complaint does not contain specific allegations regarding the market positioning or commercial importance of these specific products beyond their sale by Fry's.

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,829,552 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a pair of spaced-apart lead frames, each having an upper and lower surface The accused Ottlite and NTE products contain packaged LEDs with two spaced-apart lead frames, each with an upper and lower surface. The complaint provides an x-ray image showing the two lead frames (Compl. ¶44). ¶45 col. 3:63-65
sidewalls that connect the upper and lower surfaces Each lead frame in the accused products allegedly has sidewalls connecting the top and bottom surfaces. ¶45 col. 4:1-3
inset sidewalls described...at least partially define a fixing space The accused products' lead frames allegedly have insets in their sidewalls, identified in an x-ray image as "relatively bright zones at the periphery," which define a fixing space. ¶47 col. 4:6-9
the fixing space...undercuts the upper surface The fixing space created by the inset sidewalls is alleged to undercut the upper surface of the lead frame, creating a feature for mechanical interlocking with the resin. ¶47 col. 4:9-11
The fixing spaces are filled with resin as shown in the images above to support the two lead frames The complaint alleges that the fixing spaces in the accused products are filled with resin, as shown in cross-sectional images, which serves to support and anchor the lead frames within the package. An optical cross-section shows resin filling these spaces (Compl. ¶44). ¶47 col. 4:11-13

Identified Points of Contention

  • Scope Questions: A central question will be the construction of "inset sidewalls" and a "fixing space that undercuts the upper surface." The Defendant may argue that the features identified by Plaintiffs are merely conventional manufacturing artifacts or variations inherent in the lead frame stamping process, rather than the specific, intentionally-designed structures required by the claims. The dispute may turn on whether the patent requires a particular geometry, depth, or function for the "undercut" that is absent in the accused devices.
  • Technical Questions: The evidentiary basis for infringement relies heavily on analysis of x-ray and cross-section images. A technical question will be whether these images conclusively demonstrate the presence and claimed function of the "fixing space." The degree to which the resin-filled space actually "supports" the lead frames in a manner distinct from conventional packaging may be a point of factual dispute.

U.S. Patent No. 8,525,212 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a light emitting diode comprising...an n-electrode pad...and a p-electrode pad The accused RCA television contains an LED with an n-electrode pad near the left edge and a p-electrode pad near the right edge, sitting atop n-type and p-type contact layers, respectively (Compl. ¶59). ¶59 col. 4:51-57
two n-extensions extend from the n-electrode pad toward the right edge The top-surface view of the accused LED allegedly shows two extensions extending from the n-electrode pad toward the p-electrode pad on the right (Compl. ¶59). ¶61 col. 4:58-62
The top n-extension is convexly bent towards the top edge and the bottom n-extension is convexly bent The complaint alleges that the two n-extensions are not straight but are convexly bent toward the top and bottom edges of the diode chip. This curvature is visible in the provided top-surface image (Compl. ¶59). ¶61 col. 4:65-67
three p-extensions extending from the p-electrode pad toward the left edge The top-surface view of the accused LED allegedly shows three extensions extending left from the p-electrode pad. ¶62 col. 5:1-3
The top and bottom p-extensions enclose the two n-extensions The complaint alleges that the outer two p-extensions are positioned to geographically "enclose" the two n-extensions, as seen in the top-surface image (Compl. ¶59). ¶62 col. 5:3-4
The third central p-extension extends between the two n-extensions The complaint alleges that the middle p-extension is located in the space between the two n-extensions. ¶62 col. 5:5-6

Identified Points of Contention

  • Scope Questions: The primary point of contention may be the term "enclose." The defendant could argue that the term requires a complete or near-complete surrounding of the n-extensions by the p-extensions, which may not be met if there are significant gaps. The interpretation of this spatial relationship will be critical to the infringement analysis.
  • Technical Questions: The complaint's allegations are based on visual inspection of the LED chip's surface. A technical question will be whether the visible metallic traces function as the claimed "extensions" for current spreading, or if their primary purpose is different. The specific conductivity and connection to the active semiconductor layers may be subject to further technical discovery.

V. Key Claim Terms for Construction

For the ’552 Patent

  • The Term: "fixing space that undercuts the upper surface"
  • Context and Importance: This term appears to define the novel structural feature for anchoring the lead frame. The entire infringement theory for the '552 patent rests on whether the accused products possess a space with this specific undercut geometry. Practitioners may focus on this term because its definition distinguishes the invention from prior art lead frames that might have simple indentations or surface roughness without a true undercut for mechanical locking.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint's description focuses on the function: a space "filled with resin as shown in the images above to support the two lead frames" (Compl. ¶47). This functional language could support an interpretation covering any feature that allows resin to provide support, regardless of its precise shape.
    • Evidence for a Narrower Interpretation: The term "undercuts" suggests a specific geometry where a lower part of the space is wider than the opening at the upper surface. The complaint's reference to cross-sectional images showing "small areas under each lead frame that are filled with resin" may support this narrower, geometrically limited interpretation (Compl. ¶47).

For the ’212 Patent

  • The Term: "enclose"
  • Context and Importance: This term defines the critical spatial relationship between the p-extensions and the n-extensions. Infringement of claim 1 hinges on whether the accused device's outer p-extensions are arranged in a way that can be construed as "enclosing" the n-extensions. Practitioners may focus on this term because it is a relational limitation that is potentially subjective and highly dependent on its construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract describes the invention as improving current spreading, suggesting a functional purpose. A party might argue "enclose" should be interpreted broadly to mean any arrangement that serves to channel current around and between the n-extensions, even if the geometric enclosure is incomplete.
    • Evidence for a Narrower Interpretation: The plain meaning of "enclose" suggests surrounding or closing in on all sides. The top-surface view in the complaint (Compl. ¶59) shows the p-extensions wrapping around the n-extensions but leaving the ends open. A party could argue this does not meet the plain meaning of the term, which would require a more complete boundary.

VI. Other Allegations

Indirect Infringement

The complaint does not provide sufficient detail for analysis of indirect infringement. The counts contain only conclusory allegations and do not plead specific facts showing that Defendant provided instructions or otherwise encouraged its customers to infringe.

Willful Infringement

The complaint does not provide sufficient detail for analysis of willful infringement. The counts do not allege any facts related to pre-suit or post-suit knowledge of the patents or of infringement by the Defendant.

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

This case presents a broad assertion of fifteen distinct patents spanning the field of LED technology, from the microscopic structure of the semiconductor chip to the macroscopic design of lenses and packages. The litigation will likely focus on two central questions:

  • A core issue will be one of definitional scope: can terms rooted in specific physical geometries, such as the "fixing space that undercuts the upper surface" of a lead frame ('552 Patent) or the "enclosure" of one set of electrode extensions by another ('212 Patent), be construed to cover features in the accused products that may have different shapes or arise from standard manufacturing processes?
  • A key evidentiary question will be one of technological breadth: given the large number of disparate patents asserted against multiple product lines, the case raises the question of whether the action is a targeted enforcement of specific innovations or a broader strategic effort to leverage a large portfolio to secure a licensing agreement covering a wide range of common industry practices.