PTAB

IPR2018-01222

Cree Inc v. Document Security Systems Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Light Source
  • Brief Description: The ’771 patent relates to a light-emitting diode (LED) package designed to improve heat dissipation. The invention describes a structure with a substrate having an aperture, where a platform covers the aperture's opening and an LED is mounted on the platform within the aperture, providing an efficient thermal path away from the LED.

3. Grounds for Unpatentability

Ground 1: Obviousness over Sharp - Claims 1, 2, 3, 4, and 7 are obvious over Sharp.

  • Prior Art Relied Upon: Sharp (Japanese Patent Application Publication No. 07-235696).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Sharp discloses a chip-component type LED that meets all limitations of the challenged claims. Specifically, Sharp’s insulating substrate (30) with a through-hole (32) corresponds to the claimed substrate and aperture. Petitioner asserted that Sharp’s metal layer (27), which covers the bottom opening of the through-hole, functions as the claimed "platform located outside of said aperture." In Sharp's FIG. 4 embodiment, this platform is formed by metal layer 27 combined with its extension, metal layer 29. In the FIG. 7 embodiment, the platform is formed by metal layer 27 alone. In both cases, an LED chip (21) is mounted on this platform within the aperture and encapsulated by a transparent resin (31).
    • Motivation to Combine (for §103 grounds): This ground is based on a single reference. Petitioner argued that Sharp’s embodiments inherently teach the claimed combination. For limitations not explicitly shown in one figure (e.g., the LED top surface being below the substrate top surface), Petitioner argued a person of ordinary skill in the art (POSITA) would look to other embodiments within Sharp (e.g., FIG. 7) or find it a routine design variation for improved protection of the LED.
    • Key Aspects: The argument relies on construing the platform as being formed by Sharp’s metal layers and being "outside" the aperture by covering its lower opening. Petitioner contended that Sharp, which was not considered during prosecution, renders the claims obvious.

Ground 2: Obviousness over Sharp and Arndt - Claim 2 is obvious over Sharp in view of Arndt.

  • Prior Art Relied Upon: Sharp (Japanese Patent Application Publication No. 07-235696) and Arndt (Patent 6,459,130).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplements the teachings of Sharp to explicitly address the limitation of claim 2 requiring the platform to present a "reflective surface to the light emitting diode." Petitioner argued that while Sharp’s metal platform would inherently be reflective, Arndt provides an express teaching of this feature. Arndt discloses an LED component where the inner surface of a trough (4), including the platform area where the LED chip rests, is polished or coated with a reflection-enhancing material (e.g., aluminum) to improve reflection.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Sharp with Arndt to improve the light reflection efficiency of Sharp’s device. Petitioner asserted that Sharp itself states a goal of increasing light reflection efficiency. Arndt directly addresses this same problem by teaching the use of reflective surfaces on the platform. Therefore, a POSITA would have been motivated to apply Arndt's known technique to Sharp’s similar LED structure to achieve a predictable improvement in light output.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because applying a reflective coating or using reflective metals, as taught by Arndt, was a well-known and straightforward method for enhancing light efficiency in LED packages like Sharp's.

Ground 3: Obviousness over Sharp, Bolton, and Graf - Claims 3 and 7 are obvious over Sharp in view of Bolton and/or Graf.

  • Prior Art Relied Upon: Sharp (Japanese Patent Application Publication No. 07-235696), Bolton (Engineering Materials 2, 1987), and Graf (The Modern Dictionary of Electronics, 7th Ed., 1999).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses the limitations in claims 3 and 7 requiring the platform to be made of "thermally conductive material" and the substrate to be "electrically and thermally insulating." Petitioner argued that Sharp’s platform is made of metal layers (27, 29), and its substrate (30) is an "insulating substrate" made of resin. The Bolton and Graf technical references were cited to confirm that a POSITA would have known that metals are inherently thermally conductive and that resins used for insulating substrates are inherently thermally insulating.
    • Motivation to Combine (for §103 grounds): Petitioner argued that Bolton and Graf do not need to be "combined" with Sharp, but rather provide evidence of the general knowledge of a POSITA at the time. A POSITA reading Sharp would have understood that the disclosed metal platform was for heat dissipation and thus thermally conductive, and the resin substrate was for electrical insulation and thus also thermally insulating, consistent with the known properties of those materials as confirmed by Bolton and Graf.
    • Expectation of Success: No combination is required; the argument is that Sharp’s materials inherently possess the claimed properties according to the general knowledge in the art.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claims 3 and 7 based on Sharp in view of Carey (Patent 6,274,924), which provided an alternative reference teaching that heat slugs (platforms) in LED packages are made of thermally conductive materials to dissipate heat.

4. Key Claim Construction Positions

  • Petitioner argued for a construction of the phrase "said platform being located outside of said aperture" that does not require the entire platform to be outside the aperture. Based on the patent’s specification (FIG. 2) and prosecution history, Petitioner contended the phrase means that at least a horizontal flat portion of the platform is located outside the aperture’s opening. This construction is critical because it allows the platform to have a portion that extends into the aperture to cover the sidewalls, which matches the structure disclosed in the Sharp prior art (metal layers 27 and 29).

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the grounds presented are not redundant relative to two other pending IPRs against the ’771 patent (IPR2018-00265 and IPR2018-01167). Petitioner stated that its grounds are substantially different because they focus on an embodiment of the Sharp reference (FIG. 7) not addressed in the other petitions and rely on different secondary references (Arndt, Bolton, Graf, Carey) and arguments.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 3, 4, and 7 of the ’771 patent as unpatentable.