DCT

2:25-cv-00948

LED Wafer Solutions LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00948, E.D. Tex., 09/15/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Samsung Electronics America maintains a regular and established place of business in the district, and the other defendants are foreign corporations or have transacted business within the district. The complaint also cites a non-precedential Federal Circuit decision from July 2025 that found venue proper for Samsung in the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that LED components within Defendants’ smartphones, including various Samsung Galaxy models, infringe two patents related to the structure and manufacture of light-emitting diode (LED) packages.
  • Technical Context: The technology concerns methods for manufacturing compact, multi-layered LED devices to overcome cost, complexity, and heat dissipation issues associated with conventional LED packaging.
  • Key Procedural History: Both patents-in-suit were the subject of ex parte reexamination requests filed by Defendant Samsung after its petitions for inter partes review (IPR) were denied by the Patent Trial and Appeal Board. The U.S. Patent and Trademark Office granted the reexamination requests, resulting in amended claims and the addition of new claims, which are the basis of this suit.

Case Timeline

Date Event
2011-03-06 Earliest Priority Date for ’405 and ’822 Patents
2012-03-06 ’405 Patent Filing Date
2014-12-15 ’822 Patent Filing Date
2015-02-10 ’405 Patent Issue Date
2017-10-10 ’822 Patent Issue Date
2024-08-19 ’822 Patent Reexamination Certificate Issue Date
2024-08-28 ’405 Patent Reexamination Certificate Issue Date
2025-01-22 Accused Samsung Galaxy S25 Series Announced
2025-02-07 Accused Samsung Galaxy S25 Series Available for Purchase
2025-09-15 Complaint Filing Date

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

U.S. Patent No. 8,952,405 - "Light Emitting Diode Package and Method of Manufacture," issued February 10, 2015

The Invention Explained

  • Problem Addressed: The patent’s background section describes challenges with conventional LED packaging, which often requires a carrier substrate that increases manufacturing costs and, more critically, "greatly increases the thermal resistivity of the device and adversely affects its heat removal characteristics" (’405 Patent, col. 1:60-64; Compl. ¶26).
  • The Patented Solution: The invention proposes a vertically stacked LED package structure that avoids certain problems of conventional designs (’405 Patent, col. 2:7-11). The structure comprises multiple layers, including a semiconductor LED, a sapphire layer, an optically permissive layer (e.g., with phosphor), and a cover substrate, all arranged to promote desired mechanical, thermal, and optical properties (Compl. ¶27; ’405 Patent, col. 2:6-9, 2:15-27). Figure 3 of the patent illustrates an exemplary LED structure with a Gallium Nitride (GaN) layer on a sapphire substrate, including a recess (302) etched to allow for metallization contacts (320) (’405 Patent, Fig. 3).
  • Technical Importance: This design approach aims to create more integrated, compact, and thermally efficient LED packages suitable for wafer-level manufacturing, thereby reducing costs and improving performance (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts independent claim 21, which was added during ex parte reexamination (Compl. ¶33, ¶36).
  • Claim 21 recites a light emitting device with essential elements including:
    • A semiconductor LED with positively-doped, intrinsic, and negatively-doped regions, and featuring a recess to expose a negatively-doped surface.
    • An electrically conducting metallization layer on the doped surfaces.
    • A sapphire layer in direct contact with the LED.
    • An optically permissive layer (containing quantum dots and/or phosphor) in contact with the sapphire layer.
    • An optically permissive cover substrate.
    • A passivation layer that surrounds the other components, is reflective, and includes first and second contact holes exposing portions of the metallization layer.
    • A requirement that several specified layers are parallel with one another.

U.S. Patent No. 9,786,822 - "Light Emitting Diode Package and Method of Manufacture," issued October 10, 2017

The Invention Explained

  • Problem Addressed: Like its parent patent, the ’822 Patent addresses the shortcomings of conventional LED packaging, particularly the use of a carrier substrate that can "double the cost of making and packaging the LED device" and "greatly increases the thermal resistivity" (’822 Patent, col. 1:63-65).
  • The Patented Solution: The patent describes a multi-layer LED device structure that facilitates improved performance and manufacturing. The described device includes a semiconductor LED, a conducting carrier layer, an optically permissive layer, and a cover substrate, arranged in a vertical stack (’822 Patent, col. 2:18-30). This structure aims to manage thermal, optical, and electrical characteristics efficiently without the need for a traditional, separate carrier substrate (’822 Patent, col. 2:10-13).
  • Technical Importance: The invention provides an alternative LED package architecture intended to improve thermal management and streamline manufacturing by integrating components at the wafer level (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts independent claim 16, which was added during ex parte reexamination (Compl. ¶75, ¶78).
  • Claim 16 recites a light emitting device with essential elements including:
    • An optically transparent cover substrate.
    • An optically transparent layer covering the substrate and including an optically definable material.
    • A semiconductor LED that contacts the bottom surface of the optically transparent layer.
    • A carrier layer proximal to the opposite side of the semiconductor LED.
    • A passivation layer disposed on the carrier layer and the second side of the LED.
    • First and second electrical contacts disposed in contact holes defined in the passivation layer, with the second contact in communication with the first side of the LED.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Samsung smartphones, including the Galaxy S series (S25, S25+, etc.), Galaxy A series (A16 5G, etc.), and Galaxy Z series (Z Fold7, etc.) (Compl. ¶28). The infringement allegations are directed at the flash LED components within these devices (Compl. ¶28).

Functionality and Market Context

  • The complaint alleges that the accused phones contain LED chips, supplied by Defendant Seoul Semiconductor, that serve as the camera flash (Compl. ¶28, ¶29). To support its infringement allegations, the complaint presents a "Samsung LED Chip Diagram" which it claims depicts the infringing technology incorporated into the accused products (Compl. ¶43, ¶83). The diagram shows a layered structure including a Sapphire layer, N-GaN and P-GaN layers, and N- and P-Electrodes (Compl. ¶43).

IV. Analysis of Infringement Allegations

’405 Patent Infringement Allegations

Claim Element (from Independent Claim 21) Alleged Infringing Functionality Complaint Citation Patent Citation
a semiconductor LED including a positively-doped region, an intrinsic region, and a negatively-doped region...accommodating a first recess... The accused LED is a doped GaN LED with P-doped, N-doped, and intrinsic regions, and accommodates a recess to expose a negatively-doped surface. ¶44 col. 3:1-13
an electrically conducting metallization layer disposed on at least a portion of each of a positively-doped surface and said negatively-doped surface... The accused LED has a metallization layer (P-Electrode and N-Electrode) in direct contact with the doped GaN surfaces. ¶45 col. 3:15-18
a sapphire layer disposed on a first surface of said semiconductor LED... The accused LED includes a sapphire layer on a first surface of the semiconductor LED. This is shown in a teardown image of the S25 LED (Compl. ¶40). ¶46 col. 3:65-4:1
an optically permissive layer in direct contact with said sapphire layer, said optically permissive layer comprising an optically definable material containing quantum dots and/or phosphor... The accused LED includes an optically permissive layer with phosphor in direct contact with the sapphire layer. ¶47 col. 5:12-24
an optically permissive cover substrate covering... The accused LED includes an optically permissive cover substrate. ¶48 col. 5:29-34
a passivation layer surrounding said metallization layer...wherein said passivation layer is reflective...comprises a first contact hole...and a second contact hole... The accused LED includes a surrounding passivation layer that is reflective and contains contact holes for the upper and lower metal surfaces. ¶49, ¶50 col. 6:13-21; 6:46-54
  • Identified Points of Contention:
    • Scope Questions: The complaint's infringement theory for multiple structural limitations relies on a single, high-level "Samsung LED Chip Diagram" (Compl. ¶43). A central question will be whether this marketing-style diagram accurately represents the specific, complex structure required by Claim 21, which was added during reexamination to overcome prior art. For instance, does the term "surrounding" require the passivation layer to enclose the sides of the other components, as depicted in the patent's Figure 8, and is this structure present in the accused LEDs?
    • Technical Questions: What evidence does the complaint provide that the accused LED's passivation layer is "reflective by incorporating material particles," as specifically required by the claim? (Compl. ¶49). Further, what is the factual basis for the allegation that this layer contains the precise first and second "contact hole" structures for accessing distinct upper and lower metal surfaces? (Compl. ¶49, ¶50).

’822 Patent Infringement Allegations

Claim Element (from Independent Claim 16) Alleged Infringing Functionality Complaint Citation Patent Citation
an optically transparent cover substrate; an optically transparent layer covering an entire surface of said optically transparent cover substrate... The accused LED includes an optically transparent cover substrate and an optically transparent layer containing optically definable material. ¶84 col. 4:60-65; 5:20-25
a semiconductor LED including a positively-doped region, an intrinsic region, and a negatively-doped region... The accused LED is a doped GaN LED with P-Electrode and N-Electrode regions. A teardown image shows the infringing LED in the Galaxy S25 (Compl. ¶82). ¶85 col. 4:21-29
a carrier layer proximal to a second side of said semi-conductor LED... The accused LED has a carrier layer proximal to the second side of the semiconductor LED. ¶86 col. 4:2-3
a passivation layer disposed on said carrier layer and on said second side of said semiconductor LED... The accused LED includes a passivation layer on the carrier layer and second side of the LED, which surrounds both components. ¶87 col. 6:24-32
a first electrical contact disposed on said carrier layer in a first contact hole...; and a second electrical contact disposed in a second contact hole... The accused LED's passivation layer defines contact holes for a first electrical contact on the carrier layer and a second electrical contact. ¶88, ¶89 col. 7:19-27
  • Identified Points of Contention:
    • Scope Questions: Claim 16 requires a specific spatial arrangement: a "passivation layer disposed on said carrier layer and on said second side of said semiconductor LED." The infringement analysis may turn on whether the accused device's passivation layer meets this precise positional requirement.
    • Technical Questions: The complaint alleges the existence of first and second electrical contacts within distinct contact holes in the passivation layer (Compl. ¶88, ¶89). A technical question will be whether discovery confirms the presence of these separate, defined structures in the accused LEDs, as opposed to a more generalized electrical connection scheme.

V. Key Claim Terms for Construction

  • The Term: "a passivation layer surrounding said metallization layer, said sapphire layer, and said semiconductor LED" (’405 Patent, Claim 21)

    • Context and Importance: The spatial relationship defined by "surrounding" is likely to be a key point of dispute. The patentability of this reexamined claim may have depended on this specific structural arrangement. Whether the accused product's passivation layer "surrounds" the other components in the manner contemplated by the patent will be critical for infringement. Practitioners may focus on this term because the evidence presented in the complaint is a simplified diagram that may not show the full, three-dimensional relationship between the layers.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes applying a passivation layer "to surround certain portions of the device" (’405 Patent, col. 6:14-16), which may suggest that something less than complete encapsulation is sufficient.
      • Evidence for a Narrower Interpretation: Figure 8 of the patent depicts a passivation layer (870) that clearly encloses the vertical sides of the semiconductor LED (800) and sapphire layer (810). A defendant could argue this embodiment defines the scope of "surrounding," requiring side-wall coverage that may be absent in the accused device.

  • The Term: "contact hole defined in said passivation layer" (’822 Patent, Claim 16)

    • Context and Importance: The claims of both patents require "contact holes" in a passivation layer to allow electrical access. The definition of this term will be important because the accused products' manufacturing process may create apertures that Defendants argue are not "contact holes" in the semiconductor fabrication sense.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term itself is not explicitly defined, which might support giving it a plain and ordinary meaning of any opening that allows for contact.
      • Evidence for a Narrower Interpretation: The specification discusses creating these features "by use of a laser" or through plasma etch, referring to them as "laser drilled recess[es]" (’405 Patent, col. 6:46-53). A defendant might argue that a "contact hole" must be a distinct, intentionally formed void or via, rather than an incidental gap or exposed edge resulting from the assembly of components.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement based on Defendants’ affirmative acts of encouraging end-users to use the accused products in an infringing manner. Specifically, it alleges that Samsung’s website provides instructions and tutorials on how to use the camera flash ("flashlight feature"), thereby inducing direct infringement by customers (Compl. ¶¶63-67, 101-105). The complaint includes a screenshot from Samsung's support website titled "Use the flashlight on your Galaxy phone" (Compl. ¶66).
  • Willful Infringement: The complaint alleges willful infringement based on Defendants' actual knowledge of the patents, contending this knowledge arises from their own actions of filing IPR petitions and, subsequently, requests for ex parte reexamination for both patents (Compl. ¶52, ¶90). The core of the willfulness claim is that Defendants allegedly continued to import and sell infringing products—and launched the new Galaxy S25—after the reexamination certificates issued, which confirmed the patentability of the asserted claims (Compl. ¶53, ¶57, ¶91, ¶95).

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

  • A central issue will be one of evidentiary sufficiency: can the Plaintiff prove, through reverse engineering and expert testimony, that the microscopic, mass-produced LEDs in Defendants' phones possess the highly specific, multi-part structures recited in the reexamined claims? The case may depend on whether the simplified "Samsung LED Chip Diagram" referenced in the complaint withstands the scrutiny of technical discovery.
  • The case will also present a question of definitional scope: how will the court construe spatial terms like "surrounding" (’405 Patent) and structural terms like "contact hole" (’822 Patent)? The infringement outcome may hinge on whether these terms require the specific embodiments shown in the patents or permit a broader range of structures.
  • A key question for damages will be willfulness: given that Defendants initiated the reexaminations that led to the asserted claims, does their continued sale of accused products (particularly those launched after the reexamination certificates issued) represent the type of egregious conduct that warrants enhanced damages?