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`Ex. 1002
`
`EX. 1002
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`

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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SATCO PRODUCTS, INC.
`Petitioner
`v.
`LIGHTING SCIENCE GROUP CORP.
`Patent Owner
`IPR Trial No.: To Be Assigned
`
`DECLARATION OF DR. VICTOR ROBERT IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,672,518
`
`I, Victor Roberts, Ph.D., declare as follows:
`
`1.
`
`I am over the age of 18 and am competent to make this declaration in support of Satco
`
`Product’s Inc. (“Satco”) Petition for Inter Partes Review. The information set forth here
`
`is from my own personal knowledge. If called to testify, I could and would provide
`
`testimony regarding the substance, contents, and reasons and bases for these statements.
`
`2.
`
`I have been retained as an expert witness by Satco to address issues concerning the
`
`validity of U.S. Patent No. 8,672,518 (“the ’518 Patent”) for the above captioned inter
`
`partes review. I am being compensated for my time at a rate of $250 per hour.
`
`3.
`
`I am familiar with the technology at issue (i.e. LED luminaires). I am also familiar with
`
`the level of skill of a person of ordinary skill in the art with respect to the technology at
`
`issue as of October, 2009. In preparing this declaration, I reviewed the ‘968 Patent and
`
`considered each of the documents cited below in light of my knowledge of the
`
`technology at issue. When forming my opinions I considered the viewpoint of a person of
`
`ordinary skill in the art as of October, 2009.
`
`QUALIFICATIONS
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 1
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`4.
`
`I have attached a current copy of my curriculum vitae as Exhibit A. Over the past four
`
`years I have testified as an expert either at a trial, hearing, or deposition in two patent
`
`infringement matters. The details of these cases are shown in Appendix B
`
`5.
`
`I received a Bachelor of Science degree in Electrical Engineering from University of
`
`Maryland; a Master of Science degree in Engineering, with a major in Electrical
`
`Engineering, from Case Western Reserve University, and a Ph.D. in Electrical
`
`Engineering and Applied Physics from Case Western Reserve University.
`
`6.
`
`I am an electrical engineer with a Ph.D. and over 45 years of experience in the design and
`
`construction of lighting systems and controls.
`
`7.
`
`I am the named inventor on 39 United States Patents, and numerous associated foreign
`
`patents, related to lighting technology, plus one patent related to advanced appliance
`
`controls.
`
`8.
`
`Since becoming an independent technology consultant over 16 years ago, I have been
`
`retained as an expert or expert witness in 22 other patent infringement matters.
`
`9.
`
`I have over 52 years of experience conducting research & development in electrical
`
`engineering, laser physics, plasma physics, discharge physics and related disciplines,
`
`including more than 45 years of experience conducting and managing research &
`
`development on high efficacy linear fluorescent, compact fluorescent and metal halide
`
`lamps; low-mercury and mercury-free fluorescent lamps; electrodeless induction-coupled
`
`fluorescent and metal halide lamps; capacitively- and cavity-coupled sulfur lamps;
`
`selective emitters for high efficacy incandescent lamps; electronic ballasts and drivers for
`
`conventional and electrodeless fluorescent and HID lamps and lighting controls.
`
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 2
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`10.
`
`I am also a co-developer of the first retrofit energy-saving fluorescent lamp and a pioneer
`
`in the development of electrodeless fluorescent and metal halide lamps. I established and
`
`lead teams at the GE Research and Development Center that developed the Genura®
`
`compact fluorescent reflector lamp, world's first integrally-ballasted electrodeless
`
`fluorescent lamp; and an electrodeless metal halide lamp that remains the highest
`
`efficacy, high output, gas discharge, white light source ever demonstrated.
`
`11.
`
`I am the co-editor (for technical content) of the revised edition of Lighting, Volume 1 of
`
`the E Source Technology Atlas Series, published in 2005 by Platts, a Division of the
`
`McGraw-Hill Companies, Inc., ISBN 1-58167-002-8. This volume, often known as The
`
`Lighting Technology Atlas, includes a section on light emitting diodes (LEDS). .
`
`STANDARDS USED AND RELIED UPON
`
`12.
`
`I have been informed that a patent’s claims determine the scope of the invention. How
`
`those claims are construed is a matter of law that will ultimately be determined by the
`
`Board.
`
`13.
`
`I have been informed that, for purposes of my opinions as to the validity of the claims of
`
`the ‘518 Patent, I am to give the claims the broadest reasonable interpretation in light of
`
`the specification.
`
`14.
`
`I have been informed and understand that a patent claim can be invalid as anticipated if
`
`all of the limitations of a claim are disclosed in a single reference and are arranged in a
`
`similar manner.
`
`15.
`
`I understand that a reference does not have to use the same terminology as the claim.
`
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 3
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`16.
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`I understand that a reference can anticipate a claim even if the reference discloses
`
`additional functions or components not in the claim.
`
`17.
`
`I have been informed and understand that a patent claim can also be invalid as being
`
`obvious to a person of ordinary skill in the art at the time the application was filed. I
`
`understand this to mean that even if all of the elements of a claim are not found in a
`
`single reference, the claim is still not patentable if the differences between the subject
`
`matter disclosed in the reference and what is claimed would have been obvious to a
`
`person of ordinary skill in the art at the time the application was filed.
`
`18.
`
`I have been informed and understand that the determination of whether a claim would
`
`have been obvious should be based on several factors, including, among others:
`
` The level of ordinary skill in the art at the time the application was filed;
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` The scope and content of the prior art;
`
` What differences, if any, existed between the claim and the prior art;
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` Objective indicia of non-obviousness, such as recognition of a problem or
`
`failure of others.
`
`19.
`
`I have been informed and understand that the teachings of two or more references may be
`
`combined in the same way as disclosed in the claims, if such a combination would have
`
`been obvious to one having ordinary skill in the art. In determining whether a
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`combination would have been obvious, it is appropriate to consider, among other factors:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 4
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` Whether the teachings of the prior art references disclose known concepts
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`combined in familiar ways, and when combined, would yield predictable
`
`results;
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` Whether a person of ordinary skill in the art could implement a predictable
`
`variation, and would see the benefit of doing so;
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` Whether the claimed elements represent one of a limited number of known
`
`design choices, and a person of ordinary skill in the art would have a
`
`reasonable expectation of success;
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` Whether a person of ordinary skill in the art would have recognized a
`
`reason to combine known elements in the manner described in the claim;
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` Whether there is some teaching or suggestion in the prior art to make the
`
`modification or combination of elements claimed in the patent;
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` Whether the innovation applies a known technique that has been used to
`
`improve a similar device or method in a similar way.
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`20.
`
`I understand that one of ordinary skill in the art has ordinary creativity and is not an
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`automaton.
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`21.
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`I understand that in considering obviousness, it is important not to use the benefit of
`
`hindsight (i.e. having the benefit of knowing the claimed invention).
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`LEVEL OF ORDINARY SKILL IN THE ART
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 5
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`22. Patents are written to be understood by persons of ordinary skill in the art. A person of
`
`ordinary skill in the art, in relation to the asserted claims of the patents-in-suit, would
`
`have at least at least a bachelor’s degree in either mechanical or electrical engineering
`
`and at least 3-4 years of experience designing light fixtures based on light emitting diodes
`
`(LEDs), or basic knowledge of the operational characteristics of LEDs and 3-4 years of
`
`experience designing equipment that uses power semiconductors and heat sinks.
`
`OVERVIEW OF THE ‘518 PATENT
`
`Technology
`
`23. Lighting fixtures come in a variety of shapes and sizes. One particular shape is a low-
`
`profile fixture such as a low-profile ceiling fixture. Low-profile fixtures generally sit
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`close to the wall or ceiling and do not protrude substantially into the room. Low-profile
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`fixtures are commonly constructed of metal, plastic and glass in a wide variety of forms
`
`or trims, reflecting a wide variety of aesthetic choices. Low profile fixtures include
`
`fixtures that sit entirely on a surface, such as a wall or ceiling, and have a lateral extent
`
`that is significantly greater than their “height” as measured from the surface; plus fixtures
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`that have a portion that extends into an opening in the surface while the exposed portion
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`has a lateral dimension that is significantly greater than the “height” of the fixture above
`
`the surface.
`
`24. Some lighting fixtures, including low profile lighting fixtures, use light emitting diodes
`
`(“LEDs”) to produce light. LEDs produce heat. That heat must be dissipated. The waste
`
`heat from LEDs that produce light that can illuminate a surface or room, as opposed to
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`low power LEDs used as indicators, is commonly dissipated by means of a heat sink –
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 6
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`one or more pieces of thermally conductive material (e.g. metal) that carry the heat away
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`from the LEDs and dissipate it into the air.
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`25. LEDs also require power conditioning. Rather than using residential or commercial line
`
`voltage (e.g. 120 volts AC), LEDs commonly require lower-voltage, current-controlled,
`
`DC power. LED power converters (commonly referred to as “drivers”) come in a wide
`
`variety of sizes, shapes and power levels.
`
`The ‘518 Patent
`
`26. The ‘518 Patent generally concerns heat dissipation in LED-based lighting fixtures,
`
`including low-profile lighting fixtures; and means to connect said fixtures to the building
`
`power lines. ‘518 Patent at Abstract; 1:15-17, 2:42-58. The luminaire of the ‘518 Patent
`
`includes one or more LEDs, a heat spreader, a heat sink, and an optic for focusing or
`
`diffusing light into the illuminated area. Id. at 1:46-53. The LED generates heat; the heat
`
`spreader transfers the heat to a heat sink; and the heat sink dissipates the heat into the air.
`
`Id. 1:47-53, , 2:23-32. The ‘518 Patent defines “low-profile” in terms of the height-to-
`
`diameter ratio of the combined heat spreader, heat sink, and optic. Id. at 1:53-56, 2:16-
`
`19, 4:52-56. Essentially, the ‘518 Patent describes using the fixture’s own trim as the
`
`heat sink in order to keep the fixture cool and low-profile.
`
`27. Specifically, the ‘518 Patent claims a luminaire comprising a heat spreader, a “ring
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`shaped” heat sink around its outer periphery, an optic, an LED light source, and a means
`
`to connect the fixture to the building power lines, wherein the heat sink, heat spreader
`
`and optic in combination have a combined height-to-diameter ratio of 0.25 and are sized
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`to cover the opening of a standard 4-inch light can fixture or junction box.
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 7
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`28. Claim 1 is illustrative:
`
`1. A luminaire and accessory kit in combination, the combination comprising:
`
`a luminaire, comprising:
`
`a heat spreader; a heat sink disposed in thermal communication with the heat spreader;
`
`light source comprising a plurality of light emitting diodes (LEDs) disposed in
`
`thermal communication with the heat spreader; a power supply electrically
`
`connected to the light source; an electrical supply line having a first end
`
`connected to the power supply, and a second end connected to a plug-in
`
`connector; and, an optic disposed in optical communication with the LEDs; and
`
`an accessory kit, comprising:
`
`at least one of: a first pre-wired jumper comprising a pair of insulated electrical wires
`
`having a first plug-in connector electrically connected at one end and an Edison
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`base electrically connected at the other end; and, a second pre-wired jumper
`
`comprising a pair of insulated electrical wires having a second plug-in connector
`
`electrically connected at one end and cut wire ends at the other end;
`
`wherein the plug-in connector of the first pre-wired jumper and the second pre-wired
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`jumper are each configured to electrically engage with the plug-in connector of
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`the electrical supply line.
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 8
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`Id. at Fig. 12.
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`
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`29. As shown in Figure 12, the LED light source 120 is mounted on the “heat spreader” 105
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`which is in thermal communication with heat sink 110. An outer optic 115 spans the heat
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`spreader 105. A power conditioner 140, 160 mounted on the heat spreader 105 provides
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`DC power to the LEDs 120. The heat spreader 105, heat sink 110, and outer optic 115 in
`
`combination define an overall outer dimension (i.e. diameter) of the light fixture large
`
`enough to cover the opening of a standard four-inch light can fixture and standard four-
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`inch junction box (not shown). ‘518 Patent at 6:7-31.
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`30. FIG. 31 depicts the claimed accessory kit.
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`Id. at Fig.31
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 9
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`31. The accessory kit includes a first pre wired jumper 520 and a second pre wired jumper
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`525 with each pre wired jumper including a pair of wires 521 and 526 and a plug in male
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`connector 535. The first pre wired jumper 520 includes a pre wired Edison base 540.
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`The second pre wired jumper 525 includes open wire ends 527. ’518 Patent at 10:58-
`
`11:24.
`
`Overview of Chou
`
`OVERVIEW OF THE PRIOR ART
`
`32. U.S. Pat. No. 7,670,021 (“Chou”) (Ex. 1010), which issued on March 2, 2010 from an
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`application filed on May 20, 2008, claiming priority to provisional application
`
`60/975,657 filed on October 10, 2007, discloses a low-profile ceiling LED luminaire that
`
`dissipates heat into the surrounding air via an exterior trim. Chou at 1. Chou discloses
`
`one embodiment as follows:
`
`
`
`
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`Chou (Ex. 1005) at Fig. 2a, 2b.
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`33. Chou dissipates heat in two ways. The first is through a metal trim 12 on the underside
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`of the fixture. Id. at 3:44-47, 4:4-16, Fig. 2b at 12. LEDs 15 are mounted on the
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 10
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`underside of the trim 12. An LED driver, circuit board 17, is mounted on the top side.
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`Id. at 4:21-27. The center portion of the trim transfers heat out to the outer portion of the
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`trim, flange 22. Id. at 5:1-11. From there it is dissipated into the air. Id. at 5:5-11, 7:44-
`
`46. The “trim” in Chou thus has two portions: (1) a flat interior portion that spreads the
`
`heat, and (2) an outer, ring-shaped flange that dissipates the heat into the air. See also
`
`Figs. 4a and 4b (showing flat portion and flange). The trim’s height (including optic) is
`
`42 mm; its diameter 200 mm; the ratio is 0.21. Id. at 5:24-28.
`
`34. The second way in which Chou dissipates heat is through an additional, secondary
`
`heatsink 14, mounted on the top side of the fixture, which extends up into a conventional
`
`ceiling “can.” Id. at Fig. 2b, 3, 8; 4:40-54. Because the upper heat sink is trapped up
`
`inside the can, “a majority of the heat [is] dissipated [through the] trim 12 outside the
`
`housing,” i.e., into the room. Id. at 5:9-10.
`
`
`
`Overview of Zhang
`
`35. U.S. Pat. No. 7,722,227 (“Zhang”), which issued on May 25, 2010 upon an application
`
`filed on October 10, 2008 claiming priority to provisional application 60/979068, filed on
`
`October 10, 2007, likewise discloses a low-profile ceiling fixture that dissipates heat to
`
`the surrounding air via a ring-shaped trim. Zhang at 1. An illustration of Zhang is as
`
`follows:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 11
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`Zhang at Figs. 5 and 10.
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`36. Zhang dissipates heat as follows: The LEDs and a driver are mounted onto a thermally-
`
`conductive “trim cup” (112) at the top of the fixture. Id. at 8:10-12, 9:44-48. The trim
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`cup spreads the LED-generated heat to a peripherally surrounding baffle/heat sink/trim
`
`combination (98, 100, 52). Id. 7:63-8:1, 9:37-47, Fig. 5. The baffle/heat sink/trim
`
`combination is shaped like a top hat. The trim portion of the top hat is ring-shaped. Id. at
`
`Fig 5 (item 52). The trim portion dissipates the heat into the air. Id. at 7:9-13, 7:31-34.
`
`
`
`Overview of Tickner
`
`37. Tickner, U.S. Patent Pub. No. 2009/0086476, was filed on September 22, 2008. Because
`
`the Tickner was filed more than twelve months before the ‘844 patent, it is valid prior art
`
`under 35 U.S.C. 102 and 35 U.S.C. 103. An illustration of Tickner is as follows:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 12
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`38. For purposes of the Petition, the relevant portions of Tickner are the heat spreader 330,
`
`heat sink 320, LED package 305, power driver 315 and junction box 315. Tickner
`
`discloses that the heat spreader 310 is in thermal communication with the heat sink 320.
`
`Tickner, para. [0052].
`
`39. Tickner also discloses a power driver 315 supplying power to the LED package 305.
`
`Tickner, Fig. 8; para. [0045]. Tickner also discloses the Edison base adapter that
`
`removable connects to the driver of the fixture. See Figs 15 and 16 of Tickner.
`
`Overview of Van De Ven
`
`40. Van De Ven, U.S. Patent No. 8,777,449, was filed on September 25, 2009 and is also
`
`valid prior art under 35 U.S.C. 102 and 35 U.S.C. 103. An illustration of Van De Ven is
`
`below:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 13
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`41. The relevant portions of Van De Ven include the trim element 102, light emitting diodes
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`113, driver circuit board 105, outer optic 119 and trim element 109. See Figs 5 and 7.
`
`Van de Ven discloses that the trim element 109 is in thermal communication with the
`
`trim element 102 and the light emitting diodes 113 via a thermally conductive pad 111.
`
`Van De Ven at 18:53-64, 25:38-26:13, 27:35-41
`
`Overview of Sung
`
`42. Sung, U.S. Patent No. 6,292,375, was filed on January 5, 2000 and is also valid prior art
`
`under 35 U.S.C. 102 and 35 U.S.C. 103. An illustration of Sung is below:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 14
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` Sung at Figs. 4a, 4b & 4c.
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`43. Sung teaches a lighting device with a light source, a power supply, Edison screw base,
`
`and a removable translucent cover through which the light passes, where the translucent
`
`cover can be retained by interlocking tabs that are rotationally attached and detached.
`
`Sung at Abstract, 1:6-7, 1:13-16, 1:63-64, 2:6-8, 2:13-30, 3:6-16, 3:38-43 and Fig’s 4a,
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`4b & 4c.
`
`Overview of OptoElectronix ULE5000
`
`44. The OptoElectonix ULE5000 was advertised in a document titled “OptoElectonix Plug-
`
`&Play LED Light Engine Products” with a copyright of 2008 and is also valid prior art
`
`under 5 U.S.C. 102 and 35 U.S.C. 103. An illustration of ULE5000 is shown below:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 15
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`45. Using the dimensions displayed in the document, the ratio of the height (1.44”) to the
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`
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`diameter (8.09”) is 0.17.
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`Lightolier Model 6618 Lighting Fixture
`
`46. The Lightolier Model 6618 lighting fixture shown in the images below was commercially
`
`available in the late 1980’s.
`
`47. The label of the fixture shows the manufacturer, Lightolier, the model number, 6618, and
`
`the manufacturing date: the 16th week of 1987.
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`Label on Lightolier Model 6618 Lighting Ficture
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 16
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`48. The Lightolier Model 6618 lighting fixture has a removable lens that is rotationally
`
`attached use three tabs on the base of the fixture and three tabs on the cover.
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`Lightolier Model 6618 Operating
`
`
`
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`Lightolier Model 6618 with Lens Removed
`Showing Three Tabs Used to Hold the Lens
`And Instructions to Rotate the Lens to Remove or Attach
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 17
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`Open/Lock Instructions and One Lens Attachment Tab on Lightolier Model 6618
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`Lightolier Model 6618 Lens
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`One of Three Attachment tabs on Lens of Lightolier Model 6618 Lighting Fixture
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`CLAIM CONSTRUCTION
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` “heat spreader” and “heat sink”
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 18
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`49. The term, “heat spreader,” ordinarily refers to a device used to move thermal energy from
`
`a (typically concentrated) heat source to another location where the thermal energy can
`
`be absorbed or dissipated. The heat spreader can be integrated into the heat sink, or can
`
`be a small thermal gap pad sandwiched between a heat source and a heat sink to
`
`accommodate small geometric discontinuities, or it can be a separate device made from
`
`thermally conducting material. The broadest reasonable interpretation of these terms, in
`
`light of the specification, is that the “heat spreader” is that which moves heat from the
`
`heat source to the heat sink. The “heat sink” is that which dissipates the heat into the air.
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`“ring-shaped”
`
`50. The broadest reasonable interpretation of “ring-shaped” is: generally round with a hole or
`
`cavity in the middle. A “ring-shaped” structure surrounds a space or cavity. Id. It need
`
`not be perfectly circular nor perfectly smooth. Id. Similarly, the interior hole need not be
`
`perfectly round nor perfectly smooth. Id. The specification neither defines, limits, nor
`
`uses the term – further suggesting a broad interpretation.
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`GROUNDS FOR INVALIDITY
`
`GROUND 1: CLAIMS 1-2 AND 5-8 ARE ANTICIPATED BY TICKNER
`
`51. Tickner teaches elements corresponding to each and every limitation of claims 1-3 and 5-
`
`8, arranged as in the claims.
`
`Claim 1
`
` “a heat spreader; a heat sink disposed in thermal communication with the heat
`spreader”
`
`52. FIG. 8 of the Tickner shows a heat spreader 310a that forms the bottom surface of heat
`
`sink 310. Id. at para. [0050]. (“As illustrated in FIG. 10, the heat sink 310 is configured to
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 19
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`dissipate heat from the LED package 305 along a heat-transfer path that extends from the
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`LED package 305, through the bottom surface 310a of the heat sink, and to the fins 311
`
`via the core 905.) Further, the specification of the Ticker states “In certain exemplary
`
`embodiments, the reflector housing is formed integrally with the heat sink” and “the
`
`reflector housing 320 is configured to act as a secondary heat sink for conducting heat
`
`away from the LEDs.” Tickner, ¶0052. Therefore, Tickner discloses the claimed heat
`
`spreader and heat sink in thermal communication.
`
`
`Tickner at FIG. 8.
`
`
`
`“a light source comprising a plurality of light emitting diodes dispose in
`thermal communication with the heat spreader”
`
`53. Tickner discloses a LED package 305 in thermal communication with the heat spreader
`
`310a. Tickner, FIG. 8, ¶0044.
`
`“a power supply electrically connected to the light source”
`
`54. Tickner discloses a power driver 315 supplying power to the LED package 305. Fig. 8,
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`Tickner, ¶0045.
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 20
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`“an electrical supply line having a first end connected to the power supply, and
`a second end connected a plug in connector”
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`55. Tickner discloses “In step 1425, the person plugs wiring 1530 from the LED module 300
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`into the Edison base adapter 1520. For example, the person can plug one or more quick-
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`connect or plug connectors 350 from driver 315 into Edison base adapter 1520.” Tickner,
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`¶0063 and Fig. 15.
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` Id. at Fig. 15
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`“an optic disposed in optical communication with the LEDs”
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`56. Tickner discloses “An optic coupler can be mounted to the reflector housing, for covering
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`electrical connections at the substrate of the LED package and/or for guiding or reflecting
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`light emitted by the LED package.” Tickner, ¶0011.
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 21
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`“an accessory kit, comprising, at least one of a first pre-wired jumper
`comprising a pair of insulated electrical wires having a first plug in connector
`electrically connected at one end and an Edison base electrically connected on
`the other end.”
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`57. Tickner discloses
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`“In step 1425, the person plugs wiring 1530 from the LED module 300 into the
`Edison base adapter 1520. For example, the person can plug one or more quick-connect
`or plug connectors 350 from the driver 315 into the Edison base adapter 1520.
`Alternatively, the person may connect wires without connectors from the driver to the
`Edison base adapter 1520. In step 1430, the person mounts the Edison base adapter 1520
`and the socket 1505 to the mounting bracket 335 on the LED module 300. For example,
`the person can snap, slide, or twist the Edison base adapter 1520 and socket 1505 onto the
`Edison base socket bracket 345 on the mounting bracket 335, and/or the person can use
`one or more screws, nails, snaps, clips, pins, and/or other fastening devices to mount the
`Edison base adapter 1520 and socket 1505 to the Edison base socket bracket 345 and/or
`mounting bracket 335.” The Edison base adapter 1520 includes an Edison base 1520b,
`wiring 1520a and plug-in connector 1520c. Tickner, ¶0063, Fig.15 and Fig. 16.
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`58. Therefore, Tickner discloses the claimed accessory kit with an Edison base and a
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` Id. at Fig 16.
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`connector.
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`“a second pre-wired jumper comprising a pair of insulted electrical wires
`having a second plugin connector electrically connected at one end and cut wire
`ends at the other end”
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`59. Tickner also discloses:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 22
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`“Returning to step 1410, if the installation will be Title 24 compliant, then
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`the "yes" branch is followed to step 1450, where the person cuts wires in the existing
`fixture to remove the Edison base, including the Edison base socket 1505, from the
`existing fixture. In step 1455, the person cuts wires 1520a on the Edison base adapter
`1520 to remove an Edison screw-in plug 1520b on the adapter 1520. The person connects
`the wires 1520a from the Edison base adapter 1520 to wires (not shown) in the existing
`fixture, and plugs wiring 1530 from the LED module 300 into a connector 1520c on the
`adapter 1520, in step 1460. These connections complete an electrical circuit between a
`power source at the installation site, the Edison base adapter 1520, and the LED module
`300, without using an Edison base socket 1505. In step 1465, the person mounts the
`Edison base adapter 1520 to the mounting bracket 335 on the LED module 300,
`substantially as described above in connection with step 1430.” Tickner, ¶0065.
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`60. Therefore, Tickner also discloses removing the Edison base to provide insulated electrical
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`wires at the opposite end of the connector.
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`“wherein the plug-in connector of the first pre-wired jumper and the second
`pre-wired jumper are each configured to electrically engage with the plug-in
`connector of the electrical supply line”
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`61. Tinker discloses
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`“In step 1425, the person plugs wiring 1530 from the LED module 300 into the
`Edison base adapter 1520. For example, the person can plug one or more quick-connect
`or plug connectors 350 from the driver 315 into the Edison base adapter 1520.” Tickner
`¶0063. And, “Returning to step 1410, if the installation will be Title 24 compliant, then
`the "yes" branch is followed to step 1450, where the person cuts wires in the existing
`fixture to remove the Edison base, including the Edison base socket 1505, from the
`existing fixture. In step 1455, the person cuts wires 1520a on the Edison base adapter
`1520 to remove an Edison screw-in plug 1520b on the adapter 1520. The person connects
`the wires 1520a from the Edison base adapter 1520 to wires (not shown) in the existing
`fixture, and plugs wiring 1530 from the LED module 300 into a connector 1520c on the
`adapter 1520, in step 1460. These connections complete an electrical circuit between a
`power source at the installation site, the Edison base adapter 1520, and the LED module
`300, without using an Edison base socket 1505.” Tickner ¶0065 and Fig. 14.
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`62. Therefore, Tickner discloses a connector on an end of the jumper opposite the Edison
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`base or the open wires. Tickner, ¶0065. Ticker also discloses the connector 1520c
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`engaging a plug in connector 350 on the electrical supply line as shown below:
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 23
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`Tickner at Fig. 15.
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`
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`63.
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`In my opinion, Claim 1 of the ‘518 Patent is anticipated by Tickner.
`
`Claim 2
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`64. Dependent claim 2 is further limited by “the accessory kit includes both the first pre-
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`wired jumper and the second pre-wired jumper.” ‘518 claim 2. As discussed above,
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`Tickner discloses an accessory kit with the first pre-wired jumper and the second pre-
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`wired jumper.
`
`65.
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`In my opinion, Claim 2 of the ‘518 Patent is anticipated by Tickner.
`
`Claim 3
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`66. Dependent Claim 3 is further limited by “wherein the heat sink is substantially ring-
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`shaped, and is disposed around and coupled to an outer periphery of the heat spreader.”
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`‘518 patent at claim 3. Tickner teaches this limitation:
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`67. Tickner teaches a reflector 320 that also functions as an secondary heat sink. “In certain
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`exemplary embodiments, the reflector housing 320 is configured to act as a secondary
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`heat sink
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`for conducting heat away
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`from
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`the LEDs.Tickner ¶0052. The
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`reflector/secondary heat sink of Tickner is ring-shaped. Tickner Fig. 11. The
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`reflector/heatsink of Tickner is attached to the periphery of the heat spreader 310a. “In
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 24
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`certain exemplary embodiments, a reflector housing 320 is coupled to the bottom surface
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`310a of the heat sink 310.” Tickner ¶0051 and Fig. 8. (Shown above in discussion of
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`Claim 1.)
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`68.
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`In my opinion, Claim 3 of the ‘518 Patent is anticipated by Tickner.
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`
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`Claim 5
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`69. Dependent claim 5 is further limited by “the heat spreader, the heat sink and the optic, in
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`combination, are so dimensioned as to cover: an opening defined by a nominally sized
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`four-inch can light fixture; and, an opening defined by a nominally sized four-inch
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`electrical junction box.”
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`70. Tickner teaches “The invention provides a recessed light fixture with an LED light
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`source. The light fixture includes a housing or "can" within which an LED module is
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`mounted.” Tickner ¶0008. And “The person slides the LED module 300 into a can 115 of
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`the existing light fixture, aligns the bracket ends 340a with slots in the can 115, and
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`releases the bracket ends 340a to install the bracket ends 340a within the can 115, in step
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`CHICAGO/#3000182.2
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`Satco's Ex. 1002, Page 25
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`1440.” Tickner, ¶0064, Fig3. 2, 3 & 5, and Cree LR6 Product Information Sheet, LR6PI-
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`7/200, dated July 2009. Therefore, the Tickner discloses this element of the claims.
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`71.
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`In my opinion, Claim 5 of the ‘518 Patent is anticipated by Tickner.
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`Claim 6
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`72. Dependent claim 6 is further limited by “the LEDs are disposed on the heat spreader, the
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`heat spreader being configured to dissipate heat from the LEDs.” FIG. 8 of the Tickner
`
`shows that the LEDs 305 are in thermal communication with the heat spreader 310a,
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`which is also in thermal communication with the reflector/secondary heat sink 320.
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`Tickner states “the heat sink 310 is configured to dissipate heat from the LED package
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`305 along a heat-transfer path that extends from the LED package 305, through the
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`bottom surface 310a of the heat sink, and to the fins 311 via the core 905.” Tickner
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`¶0050. Further, Tickner states “the reflector housing is formed integrally with the heat
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`sink” and “the reflector housing 320 is configured to act as a secondary heat sink for
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`conducting heat away from the LEDs.” Tickner, ¶0052. Therefore, the Tickner discloses
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`the claimed heat spreader and heat sink in thermal communication.
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`73.
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`In my opinion, Claim 6 of the ‘518 Patent is anticipated by Tickner.
`
`Claim 7
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`74. Dependent claim 7 is further limited by “the accessory kit further comprises a set of
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`springs, each spring having a first portion configured to secure