UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`' GENERATION BRANDS LLC
`
`Petitioner
`v
`LIGHTING SCIENGE GROUP CORP.
`Patent Owner
`
`' IPR Trial No.: To Be Assigned
`
`’ DECLARATION OF DARYL SODERMAN IN SUPPORT OF
`
`PETITION FOR INTER PARTES REVIEW OF US. PATENT NO.
`
`8,201,968
`
`1, Daryl Soderman, declare as follows:
`
`1.
`
`I am the co~founder and President of Silescent Corporation, a
`
`Florida-based lighting company that designs, manufactures and sells lighting
`
`fixtures, including low-profile luminaires with light-emitting diode (“LED”)
`
`light sources.
`
`I am over the age of 18, am fully competent to make this
`
`affidavit, and make this declaration on personal knowledge.
`
`2.
`
`Silescent has designed, manufactured, and sold LED lighting
`
`fixtures since 2002.
`
`E
`
`PETITIONERS, Ex. 1017; PG. 1
`
`PETITIONERS, Ex. 1017; PG. 1
`
`

`

`3.
`
`Attached as Exhibit 1 is a true and accurate copy of the Silescent
`
`SIOO LP2 Product Sheet and Installation Guide. Both were made available to
`
`the public at least as early as June 2009.
`
`4.
`
`As part of our business, we distributed such installation guides and
`
`specification sheets, including Exhibit 1, to customers, typically along with the
`
`product or product samples.
`
`5.
`
`I note that the Silescent 8100 LP2 was designed to be powered by
`
`AC line voltage. It included an LED driver with an AC/DC power conditioner
`
`located in the box on top of the light fixture base, as shown in Figures 1 and 3 of
`
`the LP2 Product Sheet. Per the documents, the power conditioner fit within
`
`“Any UL Approved Junction Box,” including a standard 4—inch junction box or
`
`equivalent (or 4” can).
`
`6.
`
`I am ajoint inventor of US. Patent No. 7,980,736 filed November
`
`13, 2007, and issued July 19, 2011 (‘736 Patent) The Silescent SIOO LP2 is a
`
`commercial embodiment of the ‘736 Patent.
`
`‘ Signed under the penalty of perjury this 15th day 0
`
`uly,'
`
`PETITIONERS, Ex. 1017; PG. 2
`
`PETITIONERS, Ex. 1017; PG. 2
`
`

`

`EXHIBIT 1
`
`PETITIONERS, Ex. 1017; PG. 3
`
`PETITIONERS, Ex. 1017; PG. 3
`
`

`

`“...900 Lumens @ just 15 watts
`“...900 Lumens @ just 15 watts
` ... a 100,000 hour life...!”
` ... a 100,000 hour life...!”
`
`About
`Use the S100LP2 Line Voltage LED down
`light in commercial/office, industrial,
`residential, institutional and government
`applications where down lighting of any
`type is required. Its’ high lumen output
`is suited in/for ceiling applications where
`you would normally use/specify 5”, 6”
`or even 8” down lights. Use to replace
`existing inefficient fixtures having an outer
`diameter up to 10 inches. The S100LP2
`is available in 5 lamp temperatures
`from warm white (2700K) to cool white
`(5000K). Combined with multiple lensing
`options allows the designer/specifier to
`get just the right volume and color of light
`exactly where they need it. Used 12 hours
`per day the S100LP2 has an approximate
`lifetime of 22+ years. Multiple patents
`secured.
`
`Features & Benefits
`
`•
`
`•
`•
`
`•
`
`•
`
`•
`
`•
`•
`•
`
`•
`•
`
`•
`
`High efficacy - Low power consumption with high lumen
`output
`Ease of installation – Reduces labor & wiring costs
`Significantly lower ongoing MRO costs – eliminates replacing
`lamps and ballasts for years
`Phase Control dimmable – Compatible with most phase
`control dimming dim switches
`Serial number control – assures (should a failure happen) a
`replacement light can be matched to existing installed lights.
`Long 100,000 hour lamp life (w/ only 30% lumen degradation
`over lifetime)
`Ultra low plenum – Fixture height is just ¾”
`Safer - Instant on/off – no warm-up time, even in cold weather
`Manufactured in USA, exceeds NAFTA domestic product
`requirements with >80% domestic content
`Green is not just a word at Silescent, we live and breathe it:
`All fixtures are manufactured with up to with up to 80%
`recycled content and RoHS compliant
`Contain no mercury
`
`•
`
`•
`
`•
`•
`
`•
`•
`
`Give off no UV or IR radiation
`Designed to have the smallest environmental footprint – Ship 5
`S100LP2’s to one CFL down light
`Shipped in 100% recycled packaging
`Robust thermal management – Protects luminaire for both
`sustained and lifetime performance - reduces heat impact on HVAC
`Advanced Intelligent Driver (AID) – is designed as an integral
`component and protects both led and driver from failure
`Virtually unlimited aesthetic options – combine thermal rings and
`lens types to get the look and feel you need
`Hi CRI meets Energy Star Criteria for luminaries
`•
`Applications (New Construction or Remodel)
`Banks, Schools, Auditoriums, Universities, Retail Stores, Awning / Eves
`& Canopies, Building Entrances, Hospitality, Hallways, Lobbies, Condos,
`Co-Ops and Apartment Complexes, Offices, Conference Rooms,
`Restaurants, Museums, Elevators, Soffits & Eves, Cruise Ships, General
`Marine, Wall Washing and Grazing as well Low Plenum, and High
`Ceiling Applications.
`
`Suitable for covered
`ceiling mount only.
`
`PETITIONERS, Ex. 1017; PG. 4
`
`

`

`Line Voltage Phase Control Down Light
`Line Voltage Phase Control Down Light
`
`Silescent® S100 LP2 Performance
` CCT & Relative Performance
`
`27K
`30K
`35K
`40K
`50K
` CCT
`(2700K) (3000K) (3500K)
`(4000K) (5000K)
`
`15
`15
`15
`15
` WATTAGE
`750
`700
`675
`650
` LUMENS
`50
`47
`45
` EFFICACY 43
` (CoLoR RENdERING INdEx: 80 CRI)
` PoWER FACToR ALL KELvINS: 0.91
`
`15
`900
`60
`
`S100 LP2 - Ultra Low Profile Light and Fixture
` Figure 1 (Drawing Not to Scale)
`
`
`
`
`
`Thermal Ring Styles
`The Silescent® S100 LP2 Lights have optional thermal rings to pres-
`ent aesthetic choices in both shapes and finishes. Allowing the same
`efficient benefits throughout your project with a different look where
`
`desired. Additionally, with the illustrated versions shown here you
`can order custom shapes and finishes as well. Contact your lighting
`distributor for details.
`
`
`
`
`
`Round - 8 Inch
`Style Code “S01” - Modular
`Style Code “N01” - Integrated
`
`Square - 8 Inch
`Style Code “S02” - Modular
`Style Code “N02” - Integrated
`
`Octagonal - 8 Inch
`Style Code “S03” - Modular
`Style Code “N03” - Integrated
`
`Dish - 8 Inch
`Style Code “S04” - Modular
`Style Code “N04” - Integrated
`
`Finish Options
` Style Code “C01” - Powder Coat, White (Standard Finish); “C02” - Powder Coat, Beige (Special Order Optional Finish); “Cxx” Other colors available by Special Order.
`Style Code “Pxx” Plated, Options include: Bright Polished Gold, Bright Polished Silver, Anodized Matte Gold or Silver
`
`
`
`Electrical Information
`Operating temperature:
`-40°C to +75°C
`Operating Voltage (Vin):
`103.5 - 126.5 VAC
`Nominal Voltage (Vin):
`115 VAC
`Max. Current Draw:
`.145A @ 103.5 VAC
`Ambient Temp.:
`<35°C
`Manufacturer’s Information
`Rated Life:
`100,000 Hours
`Warranty:
`5 Years
`
`Submit Orders to:
`
`Silescent® Lighting Corporation 954.766.8448
`1417 SW 1st Avenue
`877.766.8448
`Fort Lauderdale, FL 33315
`Fax: 954.206.0071
`
`www.silescent.com
`
`Note: Specifications and dimensions subject to
`change without notice.
`
`PETITIONERS, Ex. 1017; PG. 5
`
`

`

`Installation Instructions
`(120 VAC Triac Dimmable Light)
`(June, 2009)
`Made and printed in the U.S.A. ©Copyright 2009 Inteltech Corp.
`
`EnginEErEd Lighting • ControL ProduCts • tEChnoLogy
`
`1417 SW 1st Avenue
`Fort Lauderdale, FL 33315
`954-766-8448
`954-206-0071 Fax
`877-766-8448 Toll Free
`info@inteltechcorp.com
`www.inteltechcorp.com
`
`SILESCENT™ Lighting & SILESCENCE™ Light Technology - Patented by INTELTECH
`
`Manufactured by Inteltech Corp. Patents Pending
`
`Installation Instructions
`(120 VAC Triac Dimmable Light)
`(June, 2009)
`
`Operation
`
`Package Contents and Parts Identification
`
`Please refer to the Electrical Installation for proper connection to power
`and control.
`
`The Silescent® S100 LP2 Line-Voltage Light provides phase dimming
`with normal triac incandescent wall dimmers.
`
`The light fixture may be operated as an ON/OFF or triac phase dimmed
`with only WHITE and BLACK wires and a normal wall switch or a triac
`incandescent dimmer.
`
`Important Notes (Please read before Installation)
`
`For use with 120 VAC power sources.
`
`Junction Box
`• Any appropriately sized, UL approved, junction box.
`
`Wiring Notes
`• Always turn off power before installation.
`• Install according to national and local electrical codes.
`
`Compatible Controls
`• This light is compatible with UL approved 120 VAC ON/OFF switch
`or a triac phase dimming control for 120V operation. Verify the triac
`dimmer can operate the power if all lights are attached.
`
`Cleaning Instructions
`• TURN LIGHT OFF BEFORE CLEANING
`• The light may be cleaned with water only. Do not use solvents to
`clean the plastic lens or LED arrays. Spray lens with water and wipe
`off. Spray the LED’s with water and allow water to dry. Do not touch
`the LED’s directly! If you need to remove the glare lens please refer
`to the assembly instructions.
`
`The back of the unit is physically protected by a metal box but is not
`water sealed, please keep dry. There are no serviceable parts or set-
`tings required for this unit. Removing the cover will void the warranty.
`
`Figure 1
`
`1.) Adaptor Plate
`
`2.) Silescent® Light Fixture Base
`
`3.) Silescent® Light Thermal Ring
`
`
`
`
`
`
` #6-32 x .25" female (Qty. 4)
`
`4.) Lens Mounting Standoffs,
`
`5.) Lens
`
`
`
`
`
` #6-32 x .5" (Qty. 4)
`
`6.) Lens Mounting Screws,
`
`7.) Wire Nuts, Orange (Qty. 5)
`
`
`
`
`
`
`
`
`
`
` Screws, #6-32 x 1", (Qty. 2)
` alternates #8-32 x 1” (Qty. 2)
`
`8.) Light Fixture Base Mounting
`
`Electrical Installation
`
`1. TURN POWER OFF to both the power supplies and controls.
`2. Unpack the shipping container and separate the components.
`3. Attach the adaptor plate to the junction box.
`
`Figure 2
`
`Junction box
`
`Adaptor Plate
`
`(Electrical Installation continued inside.)
`
`1
`
`PETITIONERS, Ex. 1017; PG. 6
`
`

`

`Electrical Installation (continued)
`
`Troubleshooting
`
`4. Locate the light fixture base with the three wires protruding from the
`back, connect GREEN wire to the safety ground.
`Note: The wires are strain relieved and will support the light as required
`during installation. Use the three wire nuts provided or a UL Listed
`equivalent.
`5. Connect the line power lead to the BLACK wire and the NEUTREL
`power lead to the WHITE wire. If you connect the wires backwards the
`light will work but not as efficiently. (See Figure 3.)
`
`Figure 3 Electrical Connections (ON/OFF Control and dimmed)
`For clarity power wires are not shown leading into
`junction box.
`
`LINE Power In
`
`BLACk
`
`Any UL Approved
`Junction Box
`
`NEUTREL
`
`WhITE
`
`GREEN
`
`Mechanical Installation
`
`Composite View - Silescent® S100 LP2
`Illustrating the modular integration of fixture.
`
`8 inch decorative
`Thermal
`Fixture Ring
`
`S100 LP2
`Light Fixture Base
`
`2. Attach Ring to Base:
`
`After the base has been secured to the adaptor plate, attach the Siles-
`cent® Light Fixture Ring (item 3) to the base (item 2) using the four (4)
`provided #6-32 x .25 female standoffs (item 4) as shown in Figure 5.
`Note: Be careful not to over tighten fasteners.
`Figure 5
`Mounting Silescent® Ring to the
`Silescent® Light Fixture Base
`
`Silescent® Light Fixture Base
`
`Silescent® Light Fixture Ring
`
`Frosted Diffuser Lens
`
`#6 - 32 x .25", Standoff (Qty 4)
`
`1. Attach the light fixture Base Assembly to the junction box:
`
`3. Attach the Lens to the Ring:
`
`After completing the electrical connections, align the light fixture base
`(item 2) to the adaptor plate (item 1) so that two opposing mounting
`holes align with the ceiling box mounting provisions. Using two (2) of the
`provided mounting screws (item 8), secure the base to the ceiling box as
`shown in Figure 4 below. Do not over tighten fasteners.
`
`After installing the Fixture Ring (item 3), align the Lens (item 5) onto the
`Ring and secure in place using the four (4) provided #6-32 x .5” screws
`(item 6) as illustrated in Figure 6. Note: Do not over tighten the screws.
`
`Figure 6
`Mounting the Lens to the Silescent® Ring
`
`Figure 4
`Mounting Light Fixture Base to Junction Box
`
`Junction Box
`
`Silescent® Light Fixture Base
`
`#6 - 32 x 1", Flathead Screw (Qty 2)
`
`Silescent® Light Fixture
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` Lens
`
`#6 - 32 x .375", Screw (Qty 4)
`
`1) Light does not turn on:
`
`a) If the thermal ring is installed:
`
`• Turn off power to the lighting system.
`
`• Remove the lens and the thermal ring. Once the ring and lens are removed,
`remove the fixture base from the adaptor plate by unscrewing the two mount-
`ing screws.
`
`• Let the fixture hang from the wires. You will see 3 colored wires at the back of
`the fixture. These are: BLACK for line power, WHITE for neutrel and Green for
`safety ground.
`
`b) Correct the wiring if necessary. Apply power, ON/OFF light should
`come to full bright, triac dim control lights should track the triac DIM
`controller.
`
`c) If fixture still does not operate correctly, or if the wiring is correct:
`
`• Undo the fixture wiring connections and remove the light fixture.
`
`• Next turn power back on and measure the power input voltage on the power
`wires. You should read between 90-132 VAC on the wires for the fixture to
`operate.
`
`• If power is good and the input control is correct then return the fixture to In-
`teltech for replacement. There are no serviceable parts inside the unit. Do not
`take the back cover off for any reason or you will void the warranty.
`
`• If no power voltage is measured, or the power reading is incorrecr troubleshoot
`the installation and make sure that power is available before reconnecting the
`fixture.
`
`• Before reconnecting the fixture turn off power.
`
`2) Light turns on but is flickering.
`
`• If it is the only light flickering in a zone then it could be a loose
`connection in the power wires or a loose connection in the control wires if
`used.
`
`• If no triac dimmer is installed, verify that you have 90-130 VAC going
`into the fixture, if not consult an electrician, if correct, return the fixture for
`replacement.
`
`• If triac dimmer is installed: remove the dimmer from the circuit and apply 120
`VAC direct to the fixture. If not full bright, return the fixture for replacement. If
`full bright, replace the triac dimmer.
`
`• If light still does not achieve full brightness then return the light for
`
` replacement.
`
`Technical Assistance
`
`If you have questions concerning the installation or operation of this product, call the Inteltech Corp Support Center. Please provide exact model
`number and serial number when calling.
`
`EnginEErEd Lighting • ControL ProduCts • tEChnoLogy
`
`1417 SW 1st Avenue
`Fort Lauderdale, FL 33315
`954-766-8448
`954-206-0071 Fax
`877-766-8448 Toll Free
`info@inteltechcorp.com
`www.inteltechcorp.com
`
`3-Year Limited Warranty
`Inteltech Corp. will, at its option, repair or replace any unit that is defective in materials or manufacture within 3 years after date of shipment. For warranty service, return unit to
`place of purchase or mail to: Inteltech Corp. 1417 SW 1st Avenue, Fort Lauderdale, FL 33315, postage prepaid.
`
`This warranty is in lieu of all other express warranties, and the implied warranty of merchantability is limited to five years from date of shipment. This warranty does not cover the
`cost of installation, removal or reinstallation, or damage resulting from misuse, abuse or damage from improper wiring or installation. This warranty does not cover incidental or
`consequential damages. Inteltech Corp’s liability on any claim for damages arising out or in connection with the manufacture, sale, installation, delivery, or use of the unit shall
`never exceed the purchase price of the unit. See Terms and Conditions sheet. © 2009 Inteltech Corp.
`
`2
`
`SILESCENT™ Lighting & SILESCENCE™ Light Technology - Patented by INTELTECH
`
`3
`
`PETITIONERS, Ex. 1017; PG. 7
`
`