PTAB

IPR2025-00334

Samsung Electronics Co Ltd v. Sinotechnix LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Light Emitting Diode (LED) Package
  • Brief Description: The ’913 patent describes a slim light emitting diode (LED) package designed to prevent delamination of the encapsulating resin from the lead frames. The purported invention achieves this by incorporating "resin-holding components," such as grooves or openings, on the lead frames to increase the bonding force with the resin.

3. Grounds for Unpatentability

Ground 1: Obviousness over Hsu and Iwamasa - Claims 1-4 and 6

  • Prior Art Relied Upon: Hsu (Application # 2004/0000727) and Iwamasa (Japanese Patent Publication No. 2006-005281).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Hsu taught a standard LED package comprising all the basic elements of independent claims 1 and 6, including first and second lead frames (terminals 70, 80), an LED chip (die 20), and a resin encapsulant. However, Hsu’s lead frames have largely planar surfaces susceptible to delamination. Petitioner argued that Iwamasa taught the missing element: the use of "resin-holding components." Iwamasa explicitly disclosed adding features like grooves and through-holes to lead frames to improve bond strength and adhesion with a sealing resin. The combination of Hsu’s package with Iwamasa’s adhesion-improving features allegedly rendered the claims obvious. For dependent claims 2 and 3, Iwamasa’s disclosure of a "Through Hole 6" filled with resin met the limitation of a hole that increases bonding force.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would have been motivated to combine the teachings of Iwamasa with the LED package of Hsu to solve the well-known problem of resin delamination from lead frames. Iwamasa was directed to the same technical field and provided an explicit solution (grooves and holes) for improving resin adhesion, which would have been a predictable improvement to Hsu's design.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. The modification involved applying a known technique for improving adhesion (from Iwamasa) to a conventional LED package structure (from Hsu), which would predictably result in enhanced bond strength between the lead frames and the resin.

Ground 2: Anticipation by Oshio - Claims 1-4 and 6

  • Prior Art Relied Upon: Oshio (Application # 2005/0280017).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Oshio disclosed every limitation of the challenged claims. Oshio described a semiconductor light emitting device with a pair of leads (20, 30), which function as the claimed first and second lead frames. The device included an LED chip and was embedded in resin. Crucially, Petitioner argued that Oshio taught multiple structures for enhancing bonding strength that qualify as the claimed "resin-holding components." These structures included "asperities 20H and 30H," "tapered portions 20T and 30T," and "anchor holes 180." Petitioner's analysis of Oshio’s figures asserted that these components were disposed along adjacent sides of the leads and were separated from each other at the corners, thereby anticipating the limitations of independent claims 1 and 6. Oshio's "anchor holes 180" were also argued to anticipate dependent claims 2 and 3.

Ground 3: Anticipation by Takasaki - Claims 1-4

  • Prior Art Relied Upon: Takasaki (Japanese Patent Publication No. 2007-134376).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Takasaki anticipated claims 1-4. Takasaki taught an LED device with first and second electrode plates (3, 4) that served as lead frames, an LED chip, and a resin encapsulant. Petitioner asserted that Takasaki disclosed two types of "resin-holding components." The first was "space 20a," a channel created by thinning portions of the electrode plates, which was filled with resin. The second was "through holes 3f, 4e" that were also filled with resin. Petitioner mapped these features from Takasaki’s figures, arguing that the through-holes and channels were disposed on adjacent sides of the electrode plates and were separated from each other at the corners, meeting all limitations of independent claim 1. The through-holes also met the limitations of dependent claims 2 and 3.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 1-4 and 6 are obvious over Hsu, Iwamasa, and Hui (Application # 2007/0252250), and over Oshio and Hui. These grounds argued that Hui provided a well-known alternative of using slanted sides on lead frames, which would have been an obvious component to substitute to enhance structural integrity.

4. Arguments Regarding Discretionary Denial

  • Advanced Bionics (§325(d)): Petitioner argued against discretionary denial, asserting that the primary references in its key grounds (Hsu, Iwamasa, Hui, Takasaki) were never considered during the original prosecution. Although Oshio was cited by the examiner, it was only applied as a secondary reference against now-canceled claims. Petitioner contended this constituted a material difference. Alternatively, Petitioner argued the examiner materially erred by failing to apply Oshio against the issued claims.
  • Fintiv (§314(a)): Petitioner argued that the Fintiv factors strongly favored institution. The parallel district court litigation was in its early stages with minimal investment. The trial date was scheduled only four months before the expected Final Written Decision (FWD), making the timing factor neutral. Critically, Petitioner offered a Sotera-type stipulation, agreeing not to pursue in district court any grounds raised or that reasonably could have been raised in the IPR. Petitioner asserted this stipulation eliminates concerns of inefficiency and weighs heavily in favor of institution.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-4 and 6 of the ’913 patent as unpatentable.