PTAB

IPR2015-00751

Kingbright Co LLC v. Cree Inc

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Light Emitting Diode and Method for Manufacturing the Same
  • Brief Description: The ’605 patent discloses a surface mount device (SMD), such as a light-emitting diode (LED), featuring a casing that partially encases a plurality of electrodes. The invention focuses on specific electrode geometries, including leads and gaps, and various stabilizing features intended to enhance the mechanical stability and positioning of the electrodes relative to the casing.

3. Grounds for Unpatentability

Ground 1: Claims 25-28 are obvious over a combination of the teachings in Arndt I, Arndt II, Arndt III, Arndt IV, Sorg, and Yoshida.

  • Prior Art Relied Upon: Arndt I (Patent 6,376,902), Arndt II (Application # 2004/0188790), Arndt III (Application # 2004/0262717), Arndt IV (WO 2004/051757), Sorg (WO 2004/027882), and Yoshida (Application # 2005/0151231).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that every limitation of independent claim 25 is taught by the prior art. Specifically, all cited references were asserted to teach the basic elements of an SMD: a casing with a first surface and a recess extending into it. Petitioner contended that Arndt I, Arndt II, Arndt IV, Sorg, and Yoshida each teach a plurality of electrodes partially encased by the casing, where at least one electrode divides into multiple leads. Petitioner further argued that these references show the electrode widening as it extends toward the leads and disclose gaps between electrodes that are exposed through the recess. The argument for dependent claims 26-28 followed that the additional limitations—an exposed chip carrier (claim 26), optimizing stability (claim 27), and using casing material to fill gaps for stability (claim 28)—are either explicitly taught or are inherent properties of the structures disclosed in the same references.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the teachings because all references are in the same field of SMD LEDs and address common problems of manufacturability, thermal performance, and mechanical stability. A POSITA would look to these known solutions and combine them in a predictable manner to improve device performance.
    • Expectation of Success: A POSITA would have a high expectation of success, as combining known lead frame structures with known overmolding techniques using standard materials would predictably result in a functional and stable SMD device.
    • Key Aspects: Petitioner also asserted that claim 25 is anticipated under 35 U.S.C. §102(b) by each of Arndt I, Arndt II, Arndt IV, and Sorg individually, arguing each reference discloses every limitation of the claim.

Ground 2: Claims 29-38 are obvious over a combination of Arndt I-IV, Sorg, and Yoshida.

  • Prior Art Relied Upon: Arndt I (Patent 6,376,902), Arndt II (Application # 2004/0188790), Arndt III (Application # 2004/0262717), Arndt IV (WO 2004/051757), Sorg (WO 2004/027882), and Yoshida (Application # 2005/0151231).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that independent claim 29, which is similar to claim 25, is unpatentable for reciting "one or more stabilizing features." The proposed claim construction for this term was broad, and Petitioner contended that the basic manufacturing process of overmolding a polymer casing around a metal lead frame, as taught by all references, inherently constitutes a stabilizing feature. Furthermore, Petitioner pointed to explicit teachings of features intended to increase mechanical interlock, such as holes (apertures) in Arndt III and Arndt IV, and injection windows (inlets) in Sorg. The arguments for dependent claims 30-38 asserted that each merely recites a specific, well-known feature that falls under the umbrella of "stabilizing features," such as electrodes passing over multiple casing surfaces (Arndt I, II, IV), using thermally conductive material (all references), or employing specific shapes like apertures (Arndt III), inlets (Sorg, Yoshida), gaps (all references), indentations (Arndt II), angled surfaces (all references), extension portions (Arndt I), and head ends (all references).
    • Motivation to Combine: A POSITA would be motivated to incorporate known anchoring and stabilizing techniques from references like Arndt III and Sorg into an SMD design to address the well-understood and persistent problem of delamination between the casing and the lead frame.
    • Expectation of Success: There would be a high expectation of success because incorporating features like holes or barbs into a lead frame before overmolding is a standard and predictable method for enhancing mechanical strength in composite structures.

4. Key Claim Construction Positions

  • "stabilizing feature": Petitioner proposed this term be construed as "any feature that improves the stability of an electrode with respect to a housing formed around the electrode." This broad construction was central to Petitioner's argument that general features taught in the prior art, like the encasement of electrodes by a casing, meet this limitation, as do more specific features like apertures or gaps.
  • "lead": Petitioner proposed this term be construed as "a portion of an electrode separated from another portion of the electrode, by, for example, a gap, an aperture, an indentation, an inlet, or opening." This construction allowed Petitioner to identify this claim element in prior art references that showed any form of separation or division in an electrode structure.
  • "inlet": Petitioner proposed this term be construed as "a separation between two lead portions of an electrode," which supported its mapping of the term to features like the injection window in Sorg.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 25-38 of Patent 8,362,605 as unpatentable.