PTAB
IPR2017-01260
Cree Inc v. OptoLum Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2017-01260
- Patent #: 6,831,303
- Filed: April 11, 2017
- Petitioner(s): Cree, Inc.
- Patent Owner(s): Optolum, Inc.
- Challenged Claims: 1-4 and 6-23
2. Patent Overview
- Title: Light Emitting Diode Light Source
- Brief Description: The ’303 patent discloses a light source using light-emitting diodes (LEDs) mounted on an elongate, thermally conductive member. The member is a hollow tube designed to cool the LEDs by allowing a fluid, such as air, to flow through its interior to dissipate heat.
3. Grounds for Unpatentability
Ground 1: Anticipation of Claims 1 and 19 by Begemann
- Prior Art Relied Upon: Begemann (Patent 6,220,722).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Begemann discloses every limitation of independent claims 1 and 19. Begemann’s LED lamp comprises a tubular, hollow "gear column" connected to a metal substrate and a lamp cap, which collectively form an "elongate thermally conductive member." LEDs are mounted on the outer surface of the substrate, which has multiple non-coextensive faces (e.g., a pyramid or cube shape). The hollow gear column contains a fan that circulates fluid (air) to conduct heat away from the LEDs. Petitioner asserted that features like the protruding threads of the lamp cap or the edges of the multi-faced substrate constitute the claimed "heat dissipation protrusions."
Ground 2: Obviousness of Claims 1 and 19 over Begemann and English
- Prior Art Relied Upon: Begemann (’722 patent), English (Patent 6,682,211).
- Core Argument for this Ground:
- Prior Art Mapping: As an alternative to Ground 1, if Begemann is found not to disclose "heat dissipation protrusions," Petitioner argued it would be obvious to add them based on English. English explicitly teaches adding "cooling fins or other heat dissipating structures" to the exterior of a hollow, metal base portion of an LED lamp to enhance heat dissipation away from the LED chips.
- Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine English's external cooling fins with Begemann's lamp to enhance the performance and efficiency of cooling the LEDs. Both patents address the common technical problem of managing heat in high-illumination LED light sources by using a hollow, thermally conductive member and would be readily combined to improve a known device.
- Expectation of Success: A POSA would have a high expectation of success, as adding cooling fins to a thermally conductive member was a well-known, straightforward, and predictable method for improving heat dissipation.
Ground 7: Obviousness of Claims 10 and 11 over Begemann, Arndt, and Asami
Prior Art Relied Upon: Begemann (’722 patent), Arndt (Patent 6,848,819), and Asami (Patent 4,296,539).
Core Argument for this Ground:
- Prior Art Mapping: This ground challenged dependent claims 10 and 11, which require the thermally conductive member to be an "extrusion," specifically an "aluminum extrusion." While Begemann teaches the base structure, Arndt discloses using aluminum for a hollow cooling member in an LED arrangement. Asami further teaches that heat transfer tubes with integral fins can be easily fabricated by the "extrusion of an aluminum alloy" as a single unit.
- Motivation to Combine: A POSA would be motivated to manufacture Begemann's tubular gear column using an aluminum extrusion process, as taught by Arndt and Asami. This modification would achieve ease of fabrication, reduce manufacturing costs, and allow for the integral formation of heat fins, a known design goal for such devices.
- Expectation of Success: Success would be predictable because extruding aluminum is a common and reliable manufacturing process for creating finned, tubular heat transfer structures, as explicitly taught by Asami for a similar purpose.
Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges against the remaining dependent claims. Key combinations included using Verdes (’678 patent) to teach a polygon-shaped member for mounting LEDs and Wu (’347 patent) to teach the application of a reflective coating to improve illumination.
4. Key Claim Construction Positions
- "Elongate": Petitioner proposed the plain meaning of "having more length than width," arguing this was consistent with the specification and the definition adopted during prosecution of a related application.
- "Thermally conductive member": Petitioner proposed "a structural unit that is thermally conductive." It was argued that this construction does not require the member to be made of a single, homogenous material.
- "Heat dissipation protrusions": Petitioner proposed "protrusions that dissipate heat." This construction was argued to be broader than "fins" and central to the anticipation argument in Ground 1, where Petitioner contended that features like screw threads or the sharp edges of a multi-faceted substrate would meet this limitation.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-4 and 6-23 of Patent 6,831,303 as unpatentable.
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