PTAB

IPR2018-01223

Cree Inc v. Document Security Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Light Source
  • Brief Description: The ’771 patent discloses a light-emitting diode (LED) package designed for improved heat dissipation. The structure features a substrate with an aperture extending between its surfaces, a platform that covers the aperture's opening, and an LED die mounted on the platform within the aperture.

3. Grounds for Unpatentability

Ground 1: Obviousness over Carey and Arndt - Claims 2-4 and 7 are obvious over Carey in view of Arndt.

  • Prior Art Relied Upon: Carey (Patent 6,274,924) and Arndt (Patent 6,459,130).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Carey discloses the fundamental elements of an LED package, including a plastic substrate (leadframe 12) with an aperture, a heat-sinking slug (10) that serves as a platform for an LED die (16), and a transparent encapsulant. In Carey, the slug is placed into the aperture of the substrate. Petitioner contended that this combination teaches most limitations of the independent claims, with the key difference being that Carey’s platform is located within, rather than outside, the aperture. Dependent claims 3, 4, and 7 were argued to be obvious as Carey explicitly teaches a platform made of thermally conductive metal (like a copper slug) and a substrate made from an insulating plastic material.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would be motivated to modify Carey's device to have its platform (slug 10) project below the substrate’s bottom surface, as explicitly taught by Arndt. Arndt discloses a chip carrier that projects from a base body to make direct external contact with a printed circuit board for the express purpose of enhancing heat dissipation. Since Carey also identifies improved thermal management as a goal, a POSITA would combine Arndt’s external contact feature with Carey’s package to achieve the predictable result of improved heat sinking.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying a known thermal management technique from Arndt to the similar LED structure of Carey to achieve the well-understood and predictable benefit of improved heat dissipation.

Ground 2: Obviousness over Carey, Arndt, and Ishinaga - Claim 1 is obvious over Carey in view of Arndt and Ishinaga.

  • Prior Art Relied Upon: Carey (Patent 6,274,924), Arndt (Patent 6,459,130), and Ishinaga (Patent 6,495,861).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Carey/Arndt combination to further address the specific limitations of claim 1, which requires the aperture to have a "side wall tapering outwards" and the "platform extend[ing] over the side wall." Petitioner acknowledged that the base combination of Carey and Arndt results in an aperture with vertical sidewalls. To meet the tapering limitation, Petitioner introduced Ishinaga, which explicitly teaches chip-type LED devices with tapered, slanted reflector surfaces to enhance light emission efficiency.
    • Motivation to Combine: Petitioner argued that a POSITA, starting with the improved heat-dissipating device of Carey/Arndt and seeking to also improve light extraction, would naturally look to known methods for that purpose. A POSITA would combine Ishinaga’s well-known tapered reflector design with the Carey/Arndt device. This modification would replace Carey's vertical-walled aperture with a tapered one to achieve the predictable benefit of increased light output. Petitioner further argued this modification would also offer enhanced structural integrity and ease of manufacturing.
    • Expectation of Success: The combination of these known elements would have been successful because incorporating a tapered reflector was a standard, predictable method for improving the light emission efficiency of LED packages.

4. Key Claim Construction Positions

  • Petitioner dedicated significant argument to the construction of the phrase "said platform being located outside of said aperture," which appears in the challenged claims.
  • Petitioner proposed that this phrase should be construed as requiring only "a horizontal flat portion of the platform being located outside the aperture's first opening," meaning the entire platform does not need to be located outside the aperture. This construction, which allows a portion of the platform to reside within the aperture, was asserted to be essential for meeting the claim 1 limitation that the "platform extends over the side wall." Petitioner supported this interpretation by citing the ’771 patent’s own figures (e.g., FIG. 2) and arguments made during prosecution history.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate because the grounds presented in this petition are not redundant relative to two other pending IPRs filed against the ’771 patent (IPR2018-00265 and IPR2018-01167).
  • It was asserted that neither the specific prior art references nor the invalidity arguments presented in this petition overlap with those in the other two proceedings, entitling Petitioner to a separate review on the merits.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-4 and 7 of Patent 6,949,771 as unpatentable under 35 U.S.C. §103.