UNITED STATES DISTRICT COURT
`FOR THE
`NORTHERN DISTRICT OF ILLINOIS
`
`
`Plaintiff,
`
`Defendants.
`
`
`)
`
`)
`
`)
`Civil Action No.: 15-cv-04833
`)
`
`)
`) Hon. Virginia M. Kendall
`)
`
`JURY TRIAL DEMANDED
`)
`)
`)
`)
`)
`)
`
`
`
`
`
`
`LYNK LABS, INC.,
`
`
`
`v.
`
`
`JUNO LIGHTING LLC, and
`JUNO MANUFACTURING LLC,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`LYNK LABS, INC.’S INITIAL RESPONSE TO INVALIDITY CONTENTIONS
`PURSUANT TO LOCAL PATENT RULE 2.5
`
`Plaintiff Lynk Labs, Inc. (“Lynk”) hereby provides, pursuant to N.D. Ill. Local
`
`Patent Rule 2.5 of the Northern District of Illinois, the following Initial Response to
`
`Juno’s Invalidity Contentions including the attached responsive claim charts. At the
`
`threshold, Lynk specifically objects to Juno’s Invalidity Contentions insofar as they fail
`
`to comply with Local Patent Rule 2.3(b)(2). Local Patent Rule 2.3(b)(2) provides that a
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`party accused of infringement must identify combinations of prior in support of
`
`obviousness argument and also identify the reasons for such combinations. Juno’s
`
`Invalidity Contentions contain certain alleged prior art and, at best, formulaic assertions
`
`of motivations to combine. While Lynk has attempted to respond as best as it can
`
`understand Juno’s contentions, Lynk explicitly asserts that Juno has not provided any
`
`obviousness contentions. In addition, in responding to Juno’s Invalidity Contentions,
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`1
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`IPR PAGE 1
`
`Acuity v. Lynk
`Acuity Ex.
`
`1023
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`

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`
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`Lynk specifically does not concede and reserves the right to contest that the references
`
`cited are prior art and/or enabling.
`
`Additionally, for the unspecified instances which Juno appears to allege that the
`
`asserted claims are invalid under 35 U.S.C. § 103, Juno’s Invalidity Contentions fail to
`
`address the fact that several of the so-called “secondary considerations” with respect to
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`non-obviousness further support a finding that the asserted claims of the patent-in-suit are
`
`not obvious. Lynk reserves the right to introduce evidence of “secondary considerations”
`
`to the judge or jury.
`
`Further, as an initial matter, the patents-in-suit are entitled to a presumption of
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`validity under 35 U.S.C. § 282. Juno’s Local Patent Rule 2.3 Contentions fail to provide
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`the requisite clear and convincing evidence to overcome the presumption of validity. In
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`addition, Defendants’ rely on a hindsight reconstruction of prior art references. The
`
`accompanying claim charts reflect Lynk’s present understanding of why Juno has failed
`
`to prove that the portions of the identified prior art references cited by Juno, alone or in
`
`combination, anticipate or renders obvious the inventions set forth in the asserted claims.
`
`The prior art references relied on by Juno may contain additional support upon which
`
`Lynk may rely to distinguish the prior art references from the claimed inventions.
`
`Moreover, Lynk may also rely on other documents and information, including witness
`
`testimony, fact or expert, to explain, illustrate, demonstrate, or provide the necessary
`
`context to further distinguish Juno’s prior art references from the claimed inventions.
`
`Lynk’s Response reflects Lynk’s current knowledge, thinking and contentions as
`
`of this early date in the present action. Lynk’s Response is based in whole or in part on
`
`its present understanding of the asserted claims and Juno’s apparent positions as to the
`
`
`
`2
`
`IPR PAGE 2
`
`

`
`
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`scope of the asserted claims. Discovery in this litigation is ongoing. Therefore, Lynk
`
`reserves the right to revise, amend, and/or supplement the information provided herein,
`
`for reasons including, but not limited to additional discovery, any findings or conclusions
`
`as to priority date or claim construction, and any non-infringement or invalidity positions
`
`taken by Juno or Juno’s fact and expert witnesses. Lynk submits this Response without
`
`waiving any arguments about the sufficiency or substance of Juno’s Invalidity
`
`Contentions. Lynk’s Response is based on the information presently known to Lynk
`
`based on its investigations to date, and does not reflect information outside the
`
`possession, custody or control of Lynk. Lynk’s Response is made with the reservation of
`
`all applicable rights to amend or supplement its Response.
`
`
`
`
`
`
`
`3
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`IPR PAGE 3
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`

`
`Dated: October 22, 2015
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ James A. Shimota
`James A. Shimota
`
`James A. Shimota (IL Bar No. 6270603)
`Aaron C. Taggart (IL Bar No. 6302068)
`Braden J. Tilghman (IL Bar No. 6314143)
`HAYNES AND BOONE LLP
`180 North LaSalle Street, Suite 2215
`Chicago, Illinois 60601
`Telephone: 312-216-1620
`Facsimile: 312-216-1621
`jim.shimota@haynesboone.com
`aaron.taggart@haynesboone.com
`braden.tilghman@haynesboone.com
`
`Counsel for Plaintiff Lynk Labs, Inc.
`
`4
`
`IPR PAGE 4
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the Plaintiff’s
`
`Initial Response to Invalidity Contentions has been served on October 22, 2015, by
`
`
`
`electronic mail to:
`
`Benjamin J. Bradford
`Lisa M. Schoedel
`JENNER & BLOCK LLP
`353 N. Clark St.
`Chicago, Illinois 60654
`bbradford@jenner.com
`lschoedel@jenner.com
`
`Counsel for Defendants
`Juno Lighting, LLC and Juno Manufacturing, LLC
`
`/s/ James Rally
`
`5
`
`
`
`
`
`
`
`IPR PAGE 5
`
`

`
`1
`
`comorises two LED dies mounted with
`multi-die LED such that the LED pair
`of the invention provides, however, for a
`be n01mal single-die LEDs. Another aspect Ng does not disclose discretely packaged LEDs at all,
`of the invention, the LEDs in each pair will Ng is packaging multiple LEDs in a common package.
`describes that: "In most implementations
`citations indicate, the only type of packaging disclosed in
`discretely packaged. For example, Ng
`second LED each discretely packaged[." As Juno's own
`Ng teaches a first and second LED that are Lynk Labs denies that Ng discloses "at least a first and a
`(Col. 3, 11. 22-23)
`'AC LED' according to the invention."
`drawing of the simplest embodiment of an
`See also, Figme 1, which "is a circuit
`
`required by claim 1.
`much less discretely packaged LEDs ananged as
`
`packaged,
`second LED each discretely
`1 (b) at least a first and a
`
`31)
`always be producing light." (Col. 4, 11. 28-
`tum-on voltage, one LED of the pair will
`voltage is above the minimum fo1ward
`'AC LED' in that, as long as the supply
`LEDs D+ and D-thus operate as a single
`Ng also describes that: "The two paired
`
`alternating cmTent." (Abstract)
`somce, which may deliver unrectified
`least one resistor and driven by a voltage
`but with reverse polarity in series with at
`luminescent type, are connected in parallel
`one pair of LEDs, preferably of the super-
`For example, Ng describes that: "At least
`Ng teaches an AC-driven LED assembly.
`
`assembly comprising:
`l(a) An AC-driven LED
`
`Lynk Labs' Response
`
`U.S. Patent No. 7,053,560 to Ng
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Ng
`
`Exhibit C
`
`IPR PAGE 6
`
`

`
`"The PCB base may then be used to f 01m a
`
`Ng teaches LED packages mounted to a
`See also, Figures 1-2; claims 13, 18.
`
`preferably 2.0 mm or less.
`3 mm or less, and more
`of preferably approximately mounting substrate for the LED pairs."
`at a distance from the other
`being mounted to a substrate substrate. For example, Ng describes that:
`1 ( d) each LED package
`
`2
`
`than 1 rmn." (Col. 3, 11. 15-18)
`densely mounted, separated by no more
`circuit board (PCB) base, they may be
`LED pairs are mounted on a single printed
`plurality-in some cases even dozens-of
`applications of the invention in which a
`example, Ng describes that: "In
`at a distance less than 3 mm apaii. For
`Ng finiher teaches mounting the packages
`
`(Col. 2, 11. 40-41)
`
`each LED pair." (Col. 2, 11. 17-18)
`supplies unrectified alternating cunent to
`"Advantageously, the power source
`circuit. For example, Ng describes that:
`Ng teaches LEDs connected in an AC
`casing.
`further limiting claim 1 to a single LED
`See also, Figures 6-7, 11-12; claim 16
`
`casing." (Col. 3, 7-11)
`reverse polarity within a single LED
`
`and
`connected in an AC circuit
`1 ( c) the LEDs being
`
`Lynk Labs' Response
`
`U.S. Patent No. 7,053,560 to Ng
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Ng
`
`Exhibit C
`
`IPR PAGE 7
`
`

`
`claim 2.
`Ng discloses LEDs having the dimensions required by
`"packaged LEDs." Fmihennore, Lynk Labs denies that
`
`disclose each and eve1y limitation of claim 1.
`mm or less." As discussed above, Wang does not
`approximately 2.5 mm or less, and more preferably 2.0
`packaged LEDs each have a length of preferably
`LED assembly according to claim 1 wherein the
`
`August 6. 2007 ("Citizen"). As another
`0.8mm as shown in its datasheet dated
`CITILEDs with a package size of 1.6mm x
`Electronics Co., Ltd. sold CL-820-UlN
`the '855 Patent. For example, Citizen
`available for sale prior to the filing date of Fmihe1more, Lynk Labs denies that Ng discloses
`vai·ious LED package sizes were publicly
`One skilled in the aii would know that
`
`3
`
`Lvnk Labs denies that Citizen is orior aii under 35
`
`Ng provides an example "using standai·d 5 Lynk Labs denies that Ng discloses "The AC-driven
`17.
`See also, Figmes 6-7, 11-12; claims 3, 14,
`
`(Col. 8, 11. 14-17)
`and preferably no more than 1 mm apaii."
`just touch, or be no more than 3 rmn apaii,
`together; as before, the LEDs should either
`LEDs are preferably mounted close
`Ng finiher describes that: "Again, the
`
`6, 11. 6-9)
`components D+, D-and R mounted." (Col.
`side view of the PCB 300 with the
`preferably no more than 1 mm. FIG. 7 is a
`or be no more than 3 mm apart, and
`words, the LEDs should either just touch,
`Ng finiher describes that: "[I]n other
`
`Lynk Labs' Response
`
`U.S. Patent No. 7,053,560 to Ng
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Ng
`
`Exhibit C
`
`preferably 2.0 mm or less.
`2.5 mm or less, and more
`preferably approximately
`LEDs each have a length of
`1 wherein the packaged
`approximately 5mm." (Col. 6., 11. 3-4)
`assembly according to claim mm LEDs, which have a diameter of
`2. The AC-driven LED
`
`IPR PAGE 8
`
`

`
`packages" airnnged as required by claim 4.
`LEDs at all, and therefore does not disclose "LED
`
`not disclose each and eve1y limitation of claim 1.
`lineai· spatial relationship." As discussed above, Ng does
`packages ai·e aiTanged with respect to each other in a
`assembly according to claim 1 wherein the LED
`Lynk Labs denies that Ng discloses "the AC-driven LED
`
`("Wang")' U.S. Patent No. 4,271,408 to
`Publication No. 2007/0247852 to Wang
`vai·ious relationships. See, e.g., U.S. Patent Fmthe1more, Ng does not disclose discretely packaged
`it obvious to aiTange LED packages in
`
`U.S.C. § 102 or§ 103. Furthennore, Lynk denies that it
`Lynk Labs denies that Fairchild is prior art under 35
`
`U.S.C. § 102 or§ 103. Furthennore, Lynk denies that it
`
`Lynk Labs' Response
`
`U.S. Patent No. 7,053,560 to Ng
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Ng
`
`Exhibit C
`
`See claim 2.
`
`obvious to combine Fan with Ng.
`Fmthe1more, Lynk Labs denies that it would have been
`Lynk Labs denies that Fan discloses "packaged LEDs."
`
`See claim 2.
`25 ~Lm." (Col. 3, 11. 30-33)
`"dimensions of approximately 25 µm by
`describes an AC-driven LED having
`U.S. Patent No. 7,535,028 to Fan ("Fan")
`("Fairchild"). As yet another example,
`based on its datasheet dated 8/30/2001
`with 0805 packaging at least by 2001
`Semiconductor Corporation sold LEDs
`packages-smt.php.) For example, Fairchild would have been obvious to combine Citizen with Ng.
`light-emitting-diodes/led-configurations-
`electronics.com/info/data/semicond/leds-
`x 1.25 mm. (See http://www.radio-
`0805 indicates an LED package of 2.0 mm would have been obvious to combine Citizen with Ng.
`example, a standardized package size of
`
`4
`
`lineai· spatial relationship.
`respect to each other in a
`packages are aiTanged with Moreover, one skilled in the a1t would find
`1 wherein the LED
`assembly according to claim
`4. The AC-driven LED
`preferably 2.0 lllill or less.
`2.5 mm or less, and more
`preferably approximately
`LEDs each have a width of
`1 wherein the packaged
`assembly according to claim
`3. The AC-driven LED
`
`in a linear spatial relationship. (Figure 6)
`Ng's Figure 6 depicts two LEDs aiTanged
`
`IPR PAGE 9
`
`

`
`5
`
`asse1ted claim is found" as reauired bv LPR 2.3(b )(3).
`each alleged item of prior ait each element of each
`this claim. Juno has not identified "where specifically in
`Wojnai·owski, and Hollnberger references ai·e relevant to
`apparent contention that the Wang, Teshima, Maitin,
`Lynk Labs states that it is unable to respond to Juno's
`
`in an XY rectilineai· spatial relationship."
`not disclose LEDs "a1Tanged with respect to each other
`aiTanged as required by claim 5. Fmthe1more, Ng does
`at all, and therefore does not disclose "LED packages"
`claim 1. Ng does not disclose discretely packaged LEDs
`above, Ng does not disclose each and eve1y limitation of
`XY rectilinear spatial relationship." As discussed
`packages are ananged with respect to each other in an
`assembly according to claim 1 wherein the LED
`
`Hollnberger.
`Teshima, Maitin, Wojnarowski,
`vai·ious relationships. See, e.g., Wang,
`it obvious to atTange LED packages in
`Moreover, one skilled in the ait would find
`
`(Figure 10)
`in an XY rectilinear spatial relationship.
`Ng's Figure 10 depicts two LEDs aITanged Lynk Labs denies that Ng discloses "the AC-driven LED
`
`relationship.
`XY rectilinear spatial
`respect to each other in an
`packages ai·e airnnged with
`1 wherein the LED
`assembly according to claim
`5. The AC-driven LED
`
`Patent Rules.
`to supplement its responses to comply with the Local
`contentions with respect to these references if Juno seeks
`Lynk Labs reserves the right to respond to Juno's
`asse1ted claim is found" as required by LPR 2.3(b )(3).
`each alleged item of prior ait each element of each
`this claim. Juno has not identified "where specifically in
`Wojnai·owski, and Hollnberger references ai·e relevant to
`apparent contention that the Wang, Teshima, Maitin,
`Lynk Labs states that it is unable to respond to Juno's
`
`("Hollnberger").
`Patent No. 7,808,189 to Hollnberger
`Wojnarowski ("Wojnarowski"); U.S.
`("Maitin"); U.S. Patent No. 6,412,971 to
`Publication No. 2004/0206970 to Ma1tin
`Teshima ("Teshima"); U.S. Patent
`
`Lynk Labs' Response
`
`U.S. Patent No. 7,053,560 to Ng
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Ng
`
`Exhibit C
`
`IPR PAGE 10
`
`

`
`6
`
`Patent Rules.
`to supplement its responses to comply with the Local
`contentions with respect to these references if Juno seeks
`Lynk Labs reserves the right to respond to Juno's
`
`Lynk Labs' Response
`
`U.S. Patent No. 7,053,560 to Ng
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Ng
`
`Exhibit C
`
`IPR PAGE 11
`
`

`
`suoolv.
`power supply disclosed in Wang, if any, is a DC power
`connected in an AC circuit[.]" As noted above, the only
`Lynk Labs denies that Wang discloses "LEDs being
`
`the disclosed LEDs are packaged at all.
`"discretely packaged[.]" Wang does not disclose how
`Lynk Labs denies that Wang discloses any LEDs that are
`
`disclosed in Wang, if any, is a DC power supply.
`LED assembly[.]" In fact, the only power supply
`Lynk Labs denies that Wang discloses "an AC-driven
`
`Lynk Labs' Response
`
`1
`
`voltages ai·e 3V 6V, 12V, ... 120V
`"Any voltage is possible. Typical lighting
`circuit. For example, Wang describes that:
`Wang teaches LEDs connected in an AC
`pcs or nine chips." (Pai·aizraph 17)
`packed airny of three, four, five, six ... N
`mounted close to each other in a densely
`Wang finiher describes that "The chips are
`
`observer." (Paragraph 12)
`they are not noticeable by a casual
`cathode, but miniaturized to a degi-ee that
`industry. Each chip 150 has an anode and
`fabrication means commonly known in the
`150 are created by ordinaiy chip
`of the parabolic reflector 130. The chips
`multiples around the middle inside surface
`small and mounted closely together in
`thinking, the LED chips 150 should be
`Wang describes that: "Contra1y to popular
`are discretely packaged. For example,
`Wang teaches a first and second LED that
`(Abstract)
`mounted on a top surface of the reflector."
`reflector and a plurality of LED chips
`that: "A multi chip LED lamp comprises a
`assembly. For example, Wang describes
`Wang teaches an AC-driven LED
`
`2007/0247852 to Wang
`
`U.S. Patent Publication No.
`
`ExhibitD
`
`and
`connected in an AC circuit
`1 ( c) the LEDs being
`
`packaged,
`second LED each discretely
`1 (b) at least a first and a
`
`assembly comprising:
`l(a) An AC-driven LED
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Wang
`
`IPR PAGE 12
`
`

`
`would have been obvious to combine Citizen with Wang.
`U.S.C. § 102 or§ 103. Fmthennore, Lynk denies that it
`Lynk Labs denies that Citizen is prior ait under 3 5
`
`2
`
`One skilled in the ait would know that
`
`casual observer." (Paragraph 12)
`degree that they ai·e not noticeable by a
`anode and cathode, but miniaturized to a
`in the industry. Each chip 150 has an
`chip fabrication means commonly known
`130. The chips 150 ai·e created by ordinaiy Fmthe1more, Lynk Labs denies that Wang discloses an
`inside surface of the parabolic reflector
`together in multiples ai·ound the middle
`should be small and mounted closely
`to popular thinking, the LED chips 150
`
`LEDs having the dimensions required by claim 2.
`Furthe1more, Lynk Labs denies that Wang discloses
`"AC-driven LED assembly" or "packaged LEDs."
`
`disclose each and eve1y limitation of claim 1.
`Illill or less." As discussed above, Wang does not
`approximately 2.5 mm or less, and more preferably 2.0
`packaged LEDs each have a length of preferably
`LED assembly according to claim 1 wherein the
`Lynk Labs denies that Wang discloses "The AC-driven
`
`preferably 2.0 Illill or less.
`2.5 mm or less, and more
`preferably approximately
`LEDs each have a length of
`1 wherein the packaged
`assembly according to claim example, Wang describes that: "Contrn1y
`Wang teaches small LED packages. For
`2. The AC-driven LED
`18.
`See also, l(a), l(b), Abstract; claims 6, 11,
`
`from each other." (Pai·agraph 13)
`"Preferably the chips are less than 2 mm
`apait. For exainple, Wang describes that:
`packages at a distance less than 3 Illill
`
`discloses the limitation "mounted to a substrate(.]"
`package[.]" Lynk Labs fmther denies that Wang
`Wang teaches LED packages mounted to a Lynk Labs denies that Wang discloses an "LED
`240V, etc." (Paragraph 20)
`
`that: "The LED chips are small and/or
`
`preferably 2.0 Illill or less. Wang finther teaches mounting the
`3 nun or less, and more
`of preferably approximately PCB based." (Paragraph 20)
`at a distance from the other
`being mounted to a substrate substrate. For example, Wang describes
`1 ( d) each LED package
`
`Lynk Labs' Response
`
`2007/0247852 to Wang
`
`U.S. Patent Publication No.
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Wang
`
`ExhibitD
`
`IPR PAGE 13
`
`

`
`obvious to combine Fan with Wang.
`Fmthe1more, Lynk Labs denies that it would have been
`Lynk Labs denies that Fan discloses "packaged LEDs."
`
`would have been obvious to combine Citizen with Wang.
`U.S.C. § 102 or§ 103. Fmthennore, Lynk denies that it
`
`See claim 2.
`25 um." (Col. 3, 11. 30-33)
`"dimensions of approximately 25 µm by
`describes an AC-driven LED having
`U.S. Patent No. 7,535,028 to Fan ("Fan")
`("Fairchild"). As yet another example,
`based on its datasheet dated 8/30/2001
`with 0805 packaging at least by 2001
`Semiconductor Corporation sold LEDs
`packages-smt.php.) For example, Fairchild
`light-einitting-diodes/led-configmations-
`electronics.com/info/data/seinicond/leds-
`x 1.25 mm. (See http://www.radio-
`0805 indicates an LED package of 2.0 mm
`example, a standardized package size of
`August 6, 2007 ("Citizen"). As another
`0.8mm as shown in its datasheet dated
`CITILEDs with a package size of 1.6mm x
`Electronics Co., Ltd. sold CL-820-UlN
`the '855 Patent. For example, Citizen
`available for sale prior to the filing date of Lynk Labs denies that Fairchild is prior ait under 35
`various LED package sizes were publicly
`
`3
`
`See claim 2.
`
`oreferablv 2.0 mm or less.
`2.5 mm or less, and more
`preferably approximately
`LEDs each have a width of
`1 wherein the packaged
`assembly according to claim
`3. The AC-driven LED
`
`Lynk Labs' Response
`
`2007/0247852 to Wang
`
`U.S. Patent Publication No.
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Wang
`
`ExhibitD
`
`IPR PAGE 14
`
`

`
`4
`
`claim 1. Lvnk Labs further denies that Wang discloses
`Wang does not disclose each and eve1y limitation of
`XY rectilineru· spatial relationship." As discussed above,
`packages are ananged with respect to each other in an
`LED assembly according to claim 1 wherein the LED
`Lynk Labs denies that Wang discloses "The AC-driven
`
`XY rectilinear soatial
`oru·allel." (Parallraoh 20): "The chios 150
`respect to each other in an
`shows two rows of three chips 150 in
`packages ru·e ruTanged with
`example, Wang describes that: "FIG. 1
`rectilinear spatial relationship. For
`1 wherein the LED
`assembly according to claim with respect to each other in an XY
`5. The AC-driven LED
`
`Wang teaches LED packages ananged
`
`Patent Rules.
`7,808,189 to Hollnberger ("Hollnberger").
`to supplement its responses to comply with the Local
`("Wojnru·owski"); U.S. Patent No.
`contentions with respect to these references if Juno seeks
`6,412,971 to Wojnru·owski
`Lynk Labs reserves the right to respond to Juno's
`to Mrutin ("Mrutin"); U.S. Patent No.
`asse1ted claim is found" as required by LPR 2.3(b )(3).
`U.S. Patent Publication No. 2004/0206970
`each alleged item of prior rut each element of each
`No. 4,271,408 to Teshima ("Teshima");
`this claim. Juno has not identified "where specifically in
`No. 7,053,560 to Ng ("Ng"); U.S. Patent Wojnru·owski, and Hollnberger references ru·e relevant to
`vru·ious relationships. See, e.g., U.S. Patent apparent contention that the Ng, Teshima, Mrutin,
`it obvious to rurnnge LED packages in
`Moreover, one skilled in the rut would find
`
`Lynk Labs states that it is unable to respond to Juno's
`
`required by claim 4.
`Wang does not disclose "LED packages" ruTanged as
`that Wang discloses "LED packages" at all, and therefore
`"AC-driven LED assembly." Lynk Labs fmther denies
`lineru· spatial relationship.
`Fmthe1more, Lynk Labs denies that Wang discloses an
`respect to each other in a
`does not disclose each and eve1y limitation of claim 1.
`packages ru·e ruTanged with
`lineru· spatial relationship." As discussed above, Wang
`packages are ruTanged with respect to each other in a
`1 wherein the LED
`assembly according to claim with respect to each other in a linear spatial LED assembly according to claim 1 wherein the LED
`Lynk Labs denies that Wang discloses "the AC-driven
`4. The AC-driven LED
`
`led chips 150." (Pru·agraph 23)
`row ofled chips 150, or a double row of
`configuration can be rurnnged in a single
`lineru· configuration. The lineru·
`as a long trough where the chips ru·e laid in
`that: "The reflector can be lineru·ly fonned
`relationship. For example, Wang describes
`
`Wang teaches LED packages ananged
`
`Lynk Labs' Response
`
`2007/0247852 to Wang
`
`U.S. Patent Publication No.
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Wang
`
`ExhibitD
`
`IPR PAGE 15
`
`

`
`5
`
`Patent Rules.
`to supplement its responses to comply with the Local
`contentions with respect to these references if Juno seeks
`Lynk Labs reserves the right to respond to Juno's
`asse1ied claim is found" as required by LPR 2.3(b )(3).
`each alleged item of prior ali each element of each
`this claim. Juno has not identified "where specifically in
`Wojnarowski, and Hollnberger references are relevant to
`apparent contention that the Ng, Teshima, Maliin,
`Lynk Labs states that it is unable to respond to Juno's
`
`Hollnberger.
`Teshima, Maliin, Wojnarowski,
`various relationships. See, e.g., Ng,
`it obvious to anange LED packages in
`Moreover, one skilled in the ali would find ~manged as required by claim 4.
`
`therefore Wang does not disclose "LED packages"
`denies that Wang discloses "LED packages" at all, and
`an "AC-driven LED assembly." Lynk Labs fmiher
`
`Lynk Labs' Response
`
`(Paragraph 23); See also, Figs. 1 and 5.
`can be in rectangular anay anangement."
`
`2007/0247852 to Wang
`
`U.S. Patent Publication No.
`
`relationship.
`
`U.S. Patent 8,841,855
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,841,855 Based on Wang
`
`ExhibitD
`
`IPR PAGE 16
`
`

`
`embodiment described in Kastl.
`Juno products have the same characteristics as the
`Juno offers no proof for its apparent assumption that
`phase and negative phase of an AC power supply[.]"
`circuit being capable of emitting light during a positive
`circuit having at least one LED, the at least one LED
`Lynk Labs denies that Kastl discloses "at least one LED
`
`1
`
`provides a voltage UG for operating a
`high-frequency rectifier 12 whose output
`for example. It is additionally supplied to a
`UET is 12 VRMS /35 kHz ... 200 kHz,
`two halogen lamps HLl, HL2. The voltage
`voltage UET which is used for operating
`electi·onic ti·ansfonner 10 provides a
`describes that: "The output of the
`power supply. For example, Kastl
`positive and negative phase of an AC
`capable of emitting light during both a
`Patent, then Kastl teaches an LED circuit
`contentions infringe claim 1 of the '118
`in Lynk Labs' initial infringement
`Juno's '118 Accused Products as defmed
`
`of an AC power supply;
`phase and a negative phase
`light during both a positive
`being capable of emitting
`at least one LED circuit
`having at least one LED, the
`1 (b) at least one LED circuit To the extent the Comt finds that
`
`separate physical unit (14). "(Absti·act)
`diode (LD) being combined to fo1m a
`(12) and the at least one light-emitting
`diode (LD), the high-frequency rectifier
`is connected to at least one light-emitting
`rectifier (12) connected to it whose output
`ti·ansfo1mer (10) having a high-frequency
`(10), the output of the elech'onic
`(LD) comprising an electrnnic ti·ansfo1mer
`operating at least one light-emitting diode
`invention relates to an apparatus for
`example, Kastl describes that: "The
`Kastl teaches a lighting system. For
`
`compnsmg:
`l(a) A lighting system
`
`..
`
`Lynk Labs' Response
`
`U.S. Patent No. 6,380,693 to Kastl
`
`U.S. Patent 8,531,118
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,531,118 Based on Kastl
`
`Exhibit E
`
`IPR PAGE 17
`
`

`
`2
`
`higher frequency." First the Kastl reference appears to
`fixed voltage and the second frequency is a relatively
`frequency, which the second AC voltage is a relatively
`an output of a second AC voltage and a second
`an input of a first AC voltage and a first frequency and
`Lynk Labs denies that Kastl discloses "the driver having
`
`frequency, which the second hi!ili frequency output voltage"; claim 10:
`voltage and a second
`output of a second AC
`and a first frequency and an
`input of a first AC voltage
`1 ( d) the driver having an
`
`receives an input voltage and provides a
`See also claim 1 : "a ti·ansfonner that
`
`135 kHz ... 200 kHz
`See l(c), e.g., 230 V/50 Hz to 12 VRMS
`See also Col. 2, 11. 60-67; Figures 1-2.
`
`(Col. 2, 11. 43-51)
`plurality oflight-emitting diodes LD."
`provides a voltage UG for operating a
`high-frequency rectifier 12 whose output
`for example. It is additionally supplied to a
`UET is 12 VRMS /35 kHz ... 200 kHz,
`two halogen lamps HLl, HL2. The voltage
`voltage UET which is used for operating
`electi·onic ti·ansfonner 10 provides a
`ti·ansfo1mer 10. The output of the
`applied to the input of an electrnnic
`mains voltage, for example 230 V/50 Hz is
`shows a circuit anangement in which a
`LED circuit. Kastl describes that: "FIG. 1
`Kastl teaches a driver connected to the
`infringe claim 1 of the '118 Patent, then
`Labs' initial infringement contentions
`'118 Accused Products as defined in Lynk
`To the extent the Court finds that Juno's
`(Col. 2, 11. 45-51)
`plurality oflight-emitting diodes LD."
`
`least one LED circuit,
`voltage and cunent to the at
`the driver providing AC
`the least one LED circuit,
`1 ( c) a driver connected to
`
`Lynk Labs' Response
`
`U.S. Patent No. 6,380,693 to Kastl
`
`U.S. Patent 8,531,118
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,531,118 Based on Kastl
`
`Exhibit E
`
`IPR PAGE 18
`
`

`
`3
`
`subh'act anv discrete
`component; or, (ii) to add or
`ti·ansfo1mer." (Col. 1, 11. 51-59)
`connected to the output of the elech'onic
`value of any discrete
`the need to: (i) change a
`requires that this sepai·ate unit be
`akeady in place, and installation merely
`individual LED; (b) without
`range of light from any
`rectifier and the light-emitting diode is
`detennined desired output
`connection between the high-frequency
`significantly affecting a pre-
`level of installation complexity, since the
`not describe the limitations of the claim.
`exceeded: (a) without
`the invention, considerably simplifies the
`output of the driver is not
`accordance with the solution according to
`after the change." The quotations identified by Juno do
`fonn a separate physical unit, in
`the pre-existing driven circuit components which remain
`long as the total wattage
`and the at least one light-emitting diode to
`(ii) to add or subti·act any discrete components, or any of
`from the driven circuit so
`be added to or subti·acted
`combination of the high-frequency rectifier need to: (i) change a value of any discrete component; or,
`additional LED circuits can
`6-7) Kastl further describes that: "The
`such that one or more
`least one light-emitting diode." (Col. 1, 11.
`circuit being configured
`relates to an apparatus for operating at
`driver and the at least one
`describes that: "The present invention
`fonn a driven circuit and the circuit as claimed. For exainple, Kastl
`the at least one LED circuit
`added to or subh'acted from the driven
`1 ( e) wherein the driver and Kastl teaches that LED circuits can be
`
`range of light from any individual LED; (b) without the
`significantly affecting a pre-detennined desired output
`wattage output of the driver is not exceeded: (a) without
`subti·acted from the driven circuit so long as the total
`one or more additional LED circuits can be added to or
`and the at least one circuit being configured such that
`Lynk Labs denies that Kastl discloses that "the driver
`voltage."
`discloses a "second voltage" that "is a relatively fixed
`Third, Juno has identified no evidence that Kastl
`outputting a second AC voltage and a second frequency.
`Thus, what Juno appeai·s to label the "driver" is not
`first rectifies the mains voltage in "a first stage 16."
`as described in Kastl, the "elech'onic U-ansfonner 1 O"
`halogen lamp, rather than a driver as claimed. Second,
`describe the "electrnnic ti·ansfo1mer" as being paii of the
`
`having a frequency of 35 kHz to 200 kHz."
`
`"a transfonner that receives a mains input
`
`higher frequency
`frequency is a relatively
`fixed voltage and the second voltage and provides an output voltage
`AC voltage is a relatively
`
`Lynk Labs' Response
`
`U.S. Patent No. 6,380,693 to Kastl
`
`U.S. Patent 8,531,118
`
`LPR 2.5 Initial Response to Invalidity Chart For U.S. Patent No. 8,531,118 Based on Kastl
`
`Exhibit E
`
`IPR PAGE 19
`
`

`
`4
`
`hi!ili-frequencv rectifier 12 whose outout
`for example. It is additionally supplied to a
`UET is 12 VRMS /35 kHz ... 200 kHz,
`two halogen lamps HLl, HL2. The voltage
`voltage UET which is used for operating
`electi·onic ti·ansfonner 10 provides a
`ti·ansfo1mer 10. The output of the
`applied to the input of an electi·onic
`voltage, for example 230 V/50 Hz is
`circuit aITangement in which a mains
`Kastl describes that: "FIG. 1 shows a
`Kastl teaches an LED circuit. For example,
`separate physical unit (14). "(Absti·act)
`diode (LD) being combined to fo1m a
`(12) and the at least one light-emitting
`diode (LD), the high-frequency rectifier
`is connected to at least one light-emitting
`rectifier (12) connected to it whose output
`ti·ansfo1mer (10) having a high-frequency
`(10), the output of the elech'onic
`(LD) comprising an electrnnic ti·ansfo1mer
`operating at least one light-emitti