PTAB

IPR2019-01259

Nichia Corp v. Lighting Science Group Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: LED Assembly for High Temperature Operation
  • Brief Description: The ’483 patent discloses a light emitting diode (LED) assembly designed for high-temperature operation, utilizing a low temperature co-fired on metal (LTCC-M) structure. The assembly includes a metal base for thermal management, an overlying layer of insulating material (e.g., ceramic) with an opening to house an LED die, and conductive traces to which the LED electrodes are connected.

3. Grounds for Unpatentability

Ground 1: Anticipation over Shimizu - Claims 11, 14, 15, and 16 are anticipated by Shimizu.

  • Prior Art Relied Upon: Shimizu (Patent 6,949,772)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shimizu's "Embodiment 3" disclosed every limitation of the challenged claims. Shimizu described a card-type LED illumination source with a metal base substrate (50) for thermal and structural support. A flip-chip LED die (53) with n and p electrodes was mounted over the base, electrically insulated by a multilayer circuit board (51). An optical reflector (52), disclosed as being made of insulating material, overlies the metal base and forms a cavity for the LED die. Conductive line patterns (59) insulated from the base connect to the LED electrodes via gold bumps (61). Finally, Petitioner asserted that Shimizu’s "feeder terminals" (54) connected to a "lighting drive circuit" (70) met the limitation of isolated terminals connected to decoder/driver electronics mounted within the overall assembly.
    • Key Aspects: The core of this ground rested on the assertion that Shimizu’s "lighting drive circuit," though external to the optical subassembly, was part of the overall "LED illumination apparatus" and thus met the claim limitation of being mounted "within the assembly."

Ground 2: Obviousness over Shimizu and Agari - Claims 11, 14, 15, and 16 are obvious over Shimizu in view of Agari.

  • Prior Art Relied Upon: Shimizu (Patent 6,949,772) and Agari (Japanese Laid Open Patent Application Publication No. 3-61556)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1. To the extent Shimizu’s decoder/driver electronics were not considered "mounted within the assembly," Petitioner argued this limitation was rendered obvious by Agari. Shimizu disclosed all other limitations of the claims. Agari, which related to an optical print head, explicitly taught mounting a driving device chip (22) and LED dies (20) together in the same package on a common ceramic substrate overlying a heat dissipating plate.
    • Motivation to Combine: A POSITA would combine Shimizu's LED package with Agari's teaching of co-locating driver electronics for well-understood benefits. There was a general motivation in the field to integrate electronic circuits into LED packages to save space and improve signal integrity. Agari provided an express example of this practice in the same technical field.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in incorporating the driver electronics of Shimizu within its optical subassembly, as taught by Agari, using known industrial practices like LTCC or LTCC-M.

Ground 3: Obviousness over Shimizu and Song - Claims 11, 14, 15, and 16 are obvious over Shimizu in view of Song.

  • Prior Art Relied Upon: Shimizu (Patent 6,949,772) and Song (Patent 6,707,069)

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground was presented as another alternative to Ground 1. If Shimizu’s optical reflector made of an "insulating material" was not considered "a layer of electrically insulating material" as claimed, Petitioner argued this feature was obvious in view of Song. Song was directed to an LED package and explicitly disclosed using a ceramic reflector housing (102, 152) to form a cavity in which an LED die is mounted.
    • Motivation to Combine: A POSITA would combine Shimizu’s package with Song's ceramic reflector to improve performance. Song recognized the benefits of using ceramics in LED packages for high heat conductivity and thermal stability. Given that Shimizu’s disclosure was silent on the specific type of insulating material for its reflector, a POSITA would have been motivated to use a well-known, high-performance material like ceramic, as taught by Song.
    • Expectation of Success: Fabricating insulating layers from ceramic over a metal base in an LED package was a routine practice for a POSITA at the time, using well-known LTCC or LTCC-M technologies.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) based on the combination of Shimizu, Agari, and Song, arguing that this combination would render the claims obvious if both deficiencies alleged in Grounds 2 and 3 were found in Shimizu.

4. Key Claim Construction Positions

  • Petitioner proposed a construction for the claim term "base" as "support or foundation."
  • This construction was argued to be consistent with the patent's intrinsic evidence, which repeatedly described the "metal base" (11) as a foundational structure and a "metal support board." It was also supported by the plain and ordinary meaning of the term.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 11, 14, 15, and 16 of Patent 7,098,483 as unpatentable.