PTAB

IPR2015-01290

Wangs Alliance Corp v. Philips Lighting Holding BV

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Luminaire Comprising a Plurality of Lighting Units
  • Brief Description: The ’774 patent discloses a luminaire designed for more efficient light utilization. The system comprises a housing containing at least one "lighting module," which in turn is composed of a set of "lighting units." Each lighting unit includes at least one LED chip and an optical system, configured to illuminate different portions of an object. A key feature is that each LED chip supplies a luminous flux of at least 5 lumens (lm) during operation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Turnbull in view of Kish - Claims 1, 3, 5, and 14 are obvious over Turnbull in view of Kish.

  • Prior Art Relied Upon:
    • Turnbull (Patent 5,803,579)
    • Kish (F.A. Kish, et al., High luminous flux semiconductor wafer-bonded AlGaInP/GaP large-area emitters, Electronics Letters (Oct. 13, 1994))
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Turnbull disclosed the fundamental structure of the claimed luminaire, while Kish provided the missing element of high-lumen LEDs.
      • Independent Claims 1 and 14: Petitioner asserted that Turnbull taught an "illuminator assembly" that meets the definition of the claimed "luminaire" and "lighting system." Turnbull's assembly included a housing, multiple lighting units (each with an LED chip and its own optical system like lenses or reflectors), and was designed to illuminate an external object. The only element Petitioner argued was not explicitly disclosed in Turnbull was an LED chip supplying "at least 5 lm" of luminous flux. Petitioner contended that Kish supplied this missing element, disclosing transparent-substrate AlGaInP/GaP LEDs that exhibited a luminous flux of 84 lm under DC operation. Petitioner’s expert declaration calculated that even at lower, more typical operating currents (e.g., 1A), the Kish LEDs would still produce a luminous flux well in excess of the claimed 5 lm threshold.
      • Dependent Claim 3: This claim adds a primary and a secondary optical system, with the primary system having a reflector and a transparent envelope for the LED chip. Petitioner argued that Turnbull taught all these elements, describing a "miniature reflector cup" adjacent to the LED chip (primary reflector), a "polymer matrix enclosure" that encapsulates the chip (transparent envelope), and larger conical reflectors (secondary optical system).
      • Dependent Claim 5: This claim adds an optical system with a transparent body having a first part for refraction and a second part for reflection. Petitioner argued Turnbull disclosed this by teaching various optical elements that operate via refraction (lenses, deviators) and reflection (reflectors), and noted that catadioptric elements, which use both principles, were also taught by Turnbull as suitable for the system.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would have been strongly motivated to combine the teachings of Turnbull and Kish. Turnbull expressly stated a desire to use LEDs with "high luminous intensity" and "very high luminous efficacy." Kish disclosed the development of exactly such LEDs, which provided a "two order of magnitude improvement" over conventional LEDs. Furthermore, Turnbull specifically suggested that transparent substrate AlInGaP amber LEDs would be desirable for high efficacy, which is precisely the type of LED described in Kish. A POSITA seeking to improve the performance of Turnbull’s illuminator would have naturally looked to state-of-the-art, high-flux LEDs like those in Kish to achieve Turnbull’s stated goals.
    • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success in this combination. The Kish reference described its high-flux LEDs as part of a complete package, including a copper submount and a standard TO-66 header, designed for easy incorporation into larger lighting systems like Turnbull’s. The physical integration was therefore straightforward, and the performance benefits were clearly articulated and predictable.

4. Key Claim Construction Positions

  • Petitioner asserted that several key terms should be given their broadest reasonable construction based on the specification of the ’774 patent. These constructions were foundational to mapping Turnbull onto the claims.
    • "Luminaire": Construed as a "lighting device," which Petitioner argued encompassed the "illuminator assembly" disclosed in Turnbull.
    • "Lighting module": Construed as a "set of lighting units," allowing the collection of individual LED-and-optic assemblies in Turnbull to be considered a single module.
    • "Lighting unit": Construed as "at least one LED chip and an optical system cooperating therewith," which mapped directly to the individual LED assemblies described in Turnbull.

7. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1, 3, 5, and 14 of the ’774 patent as unpatentable.