PTAB

IPR2024-00987

IKEA Supply AG v. Everlight Electronics Co Ltd

Key Events

Petition

petition

Title: Light Emitting Device
Brief Description: The ’742 patent describes a light-emitting diode (LED) device that includes an LED carrier with a resin housing and an electrode portion. The invention focuses on the configuration of a "wing portion" of the electrode that is exposed outside the housing, characterized by a U-shaped structure comprising a central area and one or more edge areas.

Prior Art Relied Upon: Kim (Application # 2014/0054629).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kim discloses a light-emitting device with a lead frame extending outside a resin body in a U-shape, which anticipates every limitation of the challenged claims. Specifically, Kim’s lead part (23) was identified as the claimed "wing portion," which is exposed outside the resin body (10), extends in a lengthwise direction, and protrudes in a width-wise direction. Petitioner further contended that this lead part includes a "central area" and "edge areas" with the claimed dimensional relationships and that its cross-section is "not level" with the cross-section of the housing, as required by independent claim 1. Dependent claim limitations, such as the electrode having a curved surface (claim 2), were also alleged to be disclosed.

Prior Art Relied Upon: Kobayakawa (Patent 7,825,426).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Kobayakawa teaches a semiconductor light-emitting device that meets all limitations of the claims. Kobayakawa’s lead frame (1), which is "exposed out of the case 3," was mapped to the claimed electrode "wing portion." Petitioner argued this structure has the requisite central and edge areas, protrudes from the housing, and has cross-sections that are not level. The housing, described as a "white resin" case (3) that serves as a reflector, was argued to meet the limitation of a "resin housing containing a reflecting material."

Prior Art Relied Upon: Kobayakawa (Patent 7,825,426), Kim (Application # 2014/0054629), and Hayashi (Application # 2014/0117403).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Kobayakawa discloses all limitations of independent claims 1 and 11 but does not explicitly show that its electrode portion cross-section has a curved surface, as required by dependent claims 2 and 15. Both Kim and Hayashi were presented as disclosing U-shaped electrodes with curved surfaces.
- Motivation to Combine: A POSITA would combine the teachings because modifying Kobayakawa’s flat-surfaced U-shaped electrode to have a curved surface, as taught by Kim and Hayashi, would have been a simple and predictable design choice. Petitioner argued such a modification would be motivated by a desire to ease manufacturing or to better mate with a corresponding electrical connection.
- Expectation of Success: A POSITA would have a reasonable expectation of success in making this modification, as incorporating a known feature (a curved surface) onto a known component (an exposed electrode) involves predictable results and standard fabrication techniques.
Additional Grounds: Petitioner asserted an additional anticipation challenge based on Hayashi (Ground 3) and a general obviousness challenge combining Kim, Kobayakawa, and/or Hayashi with the knowledge of a POSITA (Ground 5).

Petitioner argued that for the purposes of the petition, most claim terms should be given their plain and ordinary meaning.
For terms construed in a recent claim construction order from a parallel litigation (the Walmart-Everlight Litigation), Petitioner adopted those constructions.
Regarding the key limitation "wherein the at least one housing cross section is not level with the electrode portion cross section," Petitioner noted that this term was found indefinite in the parallel litigation. However, Petitioner contended that the prior art structures are identical to the embodiments in the ’742 patent and clearly fall within any reasonable interpretation of the "not level" scope, making an indefiniteness finding irrelevant to the anticipation analysis for an inter partes review (IPR).

Petitioner argued against discretionary denial under Fintiv and 35 U.S.C. §325(d).
Fintiv Factors: Petitioner asserted that institution is favored because a joint motion to stay has been filed in the parallel district court litigation; the trial date (November 2025) is distant and likely to be moved if the IPR is instituted; and investment in the litigation has been minimal, with fact discovery not yet open.
§325(d) Factors: Petitioner argued that denial under §325(d) is inappropriate because the primary prior art references (Kim, Kobayakawa, and Hayashi) were not cited or considered by the examiner during the original prosecution of the ’742 patent.

Petitioner requests the institution of an IPR and the cancellation of claims 1-2, 5-16, and 20-22 of the ’742 patent as unpatentable.