PTAB

IPR2020-00151

Satco Products Inc v. Seoul Semiconductor Co Ltd

Key Events

Petition

petition

Title: Light Emitting Devices
Brief Description: The ’919 patent discloses light emitting device (LED) packages with specific structural configurations for the leads and body. The purported invention aims to provide high strength against external impact or stress while maintaining the luminous intensity of a typical LED.

Prior Art Relied Upon: Wang-588 (Application # 2013/0270588).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Wang-588, which discloses an LED package and lead frame assembly, teaches every limitation of claims 1-7. Key alleged disclosures include a first lead frame (11) and a second lead frame (12) corresponding to the claimed first and second leads. The "insulated housing" (2) and "filling portion" (22) of Wang-588 were asserted to constitute the claimed "body" and "base," respectively, which fill the separation region between the leads. Petitioner identified the wall defined by the interface between recess (21) and the insulated housing (2) in Wang-588 as the claimed "reflector" surrounding a "cavity." Further, Petitioner contended that the specific shape of Wang-588's filling portion (22) between the leads meets the claim limitation requiring asymmetrically configured halves, a feature added during prosecution to secure allowance of the ’919 patent. Dependent claims relating to protrusions, indentations, and fine protrusions were also allegedly disclosed by various structural features of Wang-588's lead frames and connecting pieces (13, 16).

Prior Art Relied Upon: Wang-588 (Application # 2013/0270588) and Admitted Prior Art (APA) from the ’919 patent’s specification.
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Wang-588 discloses nearly all limitations of the claims. The APA, which is described in the "Background" section of the ’919 patent itself (FIGS. 1A-1B), was asserted to teach a "typical" LED having a separate, non-integral reflector (23) disposed on the leads to reflect light. This separate component from the APA was argued to supply the reflector, cavity, and light-reflection limitations of claim 1.
- Motivation to Combine: A POSITA would combine the teachings because Wang-588 provides a complete LED package, and the APA teaches a common, known technique for improving such devices. Petitioner asserted a POSITA would be motivated to incorporate the separate, higher-reflectance reflector from the APA into the Wang-588 device to achieve enhanced luminous efficacy, which is a known benefit of using such reflectors. The motivation was presented as a simple application of a known feature to improve a known device.
- Expectation of Success: A POSITA would have had a reasonable expectation of success, as combining a separate reflector with an LED package was a conventional and predictable method for increasing light output.

Prior Art Relied Upon: Wang-588 (Application # 2013/0270588) and Seo-943 (Patent 7,964,943).
Core Argument for this Ground:
- Prior Art Mapping: This ground presented an alternative to Ground 2, using an external patent reference instead of the APA. Wang-588 again provided the base LED package structure. Seo-943 was relied upon for its disclosure of an LED with a separate reflector (160) formed on the top surfaces of the lead frame units. Petitioner argued this teaching from Seo-943 supplied the claimed reflector element.
- Motivation to Combine: The motivation was identical to that in Ground 2. Seo-943 explicitly teaches using its separate reflector to collect, scatter, and direct light in a desired direction. A POSITA seeking to improve the luminous efficacy of the Wang-588 device would have been motivated to incorporate the well-known, non-integral reflector taught by Seo-943 to achieve the predictable result of increased brightness.
- Expectation of Success: Petitioner asserted a high expectation of success, as the combination involved integrating a standard, performance-enhancing component (the Seo-943 reflector) into a conventional LED package (from Wang-588) using known manufacturing methods like transfer molding.

"Leads" vs. "Lead Frames": A central contention of the petition was that the term "leads" as used in the ’919 patent is synonymous with the term "lead frames" used in the primary prior art reference, Wang-588. Petitioner supported this position by comparing the structures and functions depicted in the figures of both documents and by citing the prosecution history of the ’919 patent, where the Examiner allegedly equated the "leads" of the claims to the "lead frames" of a prior art reference. This interpretation was foundational to the anticipation argument in Ground 1.

Petitioner requested the institution of an inter partes review and the cancellation of claims 1-7 of Patent 9,978,919 as unpatentable.