`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`
`v.
`
`ULTRAVISION TECHNOLOGIES, LLC
`Patent Owner
`
`____________________
`
`Patent No. 10,223,946
`____________________
`
`DECLARATION OF DR. ERIC BRETSCHNEIDER
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 10,223,946
`
`
`
`
`
`Page 1 of 176
`
`SAMSUNG EXHIBIT 1002
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`V.
`
`
`TABLE OF CONTENTS
`
`INTRODUCTION .......................................................................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ................................................ 2
`II.
`III. MATERIALS REVIEWED ......................................................................... 12
`IV. PERSON OF ORDINARY SKILL IN THE ART AND THE TIME OF
`THE ALLEGED INVENTION .................................................................... 15
`TECHNICAL BACKGROUND .................................................................. 17
`A.
`Background of LED Devices and Related Lighting Systems ............ 17
`B.
`Lighting Design .................................................................................. 21
`C.
`Optical Design .................................................................................... 22
`VI. THE ’946 PATENT ...................................................................................... 29
`VII. CLAIM CONSTRUCTION ......................................................................... 33
`A.
`“area” (claims 1, 29, 30) ..................................................................... 33
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 34
`A.
`Shimada (US Patent Publication No. 2008/0084693) (Ex. 1011) ..... 34
`B. Marcoux
`(U.S. Patent Application Publication No.
`2010/0128488) (Ex. 1012) ................................................................. 38
`Holder (U.S. Patent No. 7,674,018) (Ex. 1020) ................................. 43
`C.
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL RECITED
`FEATURES OF CLAIMS 1-10, 12, 14, 16-17, 29, and 30 OF THE
`’946 PATENT ............................................................................................... 46
`A.
`Shimada Discloses and/or Suggests the Features of Claims 1-10,
`12, 14, 16-17, 29, and 30 .................................................................... 46
`1.
`Claim 1 ..................................................................................... 46
`a)
`1.a: A light assembly comprising: ................................. 46
`
`
`
`
`
`i
`
`
`
`Page 2 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`b)
`
`
`
`1.b: a thermally conductive support structure
`configured for outdoor use, wherein the support
`structure protects electronic components attached to
`the support structure from direct contact with
`rainwater, wherein the support structure comprises
`an attachment point for securing the support
`structure to a weatherproof mount designed for
`outdoor use; ................................................................... 50
`a thermally conductive support structure configured
`for outdoor use, .............................................................. 50
`wherein the support structure protects electronic
`components attached to the support structure from
`direct contact with rainwater, ........................................ 53
`wherein
`the support structure comprises an
`attachment point for securing the support structure
`to a weatherproof mount designed for outdoor use; ...... 60
`1.c: a heat sink ............................................................... 64
`a substantially planar circuit board attached to the
`support structure; ........................................................... 67
`a plurality of LEDs attached to the circuit board,
`wherein the LEDs are arranged in an array
`configuration; and .......................................................... 69
`a single transparent substrate overlying all LEDs
`attached
`to
`the circuit board, wherein
`the
`transparent substrate includes a plurality of convex
`optical elements, each convex optical element
`overlying an associated one or more of the LEDs; ....... 71
`wherein the light assembly is configured to direct
`light from the LEDs towards an area in a manner
`that does not create hot spots or result in dead spots
`on the area regardless of whether all of the LEDs of
`the plurality of LEDs or some of the LEDs of the
`plurality of LEDs are functional. ................................... 75
`Claim 2 ..................................................................................... 85
`ii
`
`
`1)
`
`2)
`
`3)
`
`c)
`d)
`
`e)
`
`f)
`
`g)
`
`2.
`
`
`
`
`
`Page 3 of 176
`
`

`

`
`
`a)
`
`The light assembly of claim 1, wherein the light
`assembly
`is
`further configured
`to provide
`illumination redundancy such that the average
`illumination to the area when all LEDs are
`functional and emitting light is no more than three
`times the average illumination to the area when two
`or fewer of the LEDs are not functional and not
`emitting light. ................................................................. 85
`Claim 3 ..................................................................................... 86
`a)
`The light assembly of claim 1, wherein the heat sink
`includes a plurality of fins extending in a direction
`away from the circuit board. .......................................... 86
`Claim 4 ..................................................................................... 87
`a)
`The light assembly of claim 1, wherein a portion of
`the heat sink is in direct contact with the support
`structure. ........................................................................ 87
`Claim 5 ..................................................................................... 88
`a)
`The light assembly of claim 1, wherein the heat sink
`is directly exposed to the outside atmosphere and is
`not entirely enclosed by the support structure. .............. 88
`Claim 6 ..................................................................................... 90
`a)
`The light assembly of claim 1, wherein the support
`structure and the heat sink are portions of a single
`integral component. ....................................................... 90
`Claim 7 ..................................................................................... 91
`a)
`The light assembly of claim 1, wherein each convex
`optical element overlies a single associated LED
`and wherein each and every one of the plurality of
`LEDs has an overlying convex optical element. ........... 91
`Claim 8 ..................................................................................... 94
`a)
`The light assembly of claim 1, wherein the circuit
`board is in physical contact with the heat sink. ............. 94
`
`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`
`
`
`
`iii
`
`
`
`Page 4 of 176
`
`

`

`
`
`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`9.
`
`Claim 9 ..................................................................................... 97
`a)
`The light assembly of claim 1, wherein the circuit
`board surrounded by a portion of the support
`structure. ........................................................................ 97
`10. Claim 10 ................................................................................... 99
`a)
`The light assembly of claim 1, wherein each LED is
`located between the circuit board and one of the
`convex optical elements. ................................................ 99
`11. Claim 12 ................................................................................. 101
`a)
`The light assembly of claim 1, wherein the light
`assembly
`is
`further configured
`to provide
`illumination redundancy such that failure of some
`of the LEDs will cause an illumination level of light
`emitted from the light assembly to decrease while a
`uniformity of the light emitted from the light
`assembly remains substantially the same. ................... 101
`12. Claim 14 ................................................................................. 105
`a)
`The light assembly of claim 1, wherein each of the
`plurality of convex optical elements is substantially
`identical in shape and size. .......................................... 105
`13. Claim 16 ................................................................................. 108
`a)
`The light assembly of claim 1, further comprising:
`a second circuit board attached to the support
`structure; a second plurality of LEDs attached to the
`second circuit board; and a second single
`transparent substrate overlying all LEDs attached to
`the second circuit board. .............................................. 108
`14. Claim 17 ................................................................................. 114
`a)
`The light assembly of claim 16, wherein a main
`surface of the second circuit board being parallel to
`a main surface of the circuit board. ............................. 114
`15. Claim 29 ................................................................................. 117
`
`
`
`
`
`iv
`
`
`
`Page 5 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`a)
`b)
`
`1)
`
`2)
`
`3)
`
`4)
`c)
`
`d)
`
`e)
`
`
`
`29.a: A light assembly comprising: ............................. 117
`29.b: a thermally conductive support structure
`configured for outdoor use, wherein the support
`structure protects electronic components attached to
`the support structure from direct contact with
`rainwater, wherein the support structure comprises
`an attachment point for securing the support
`structure to a weatherproof mount designed for
`outdoor use, and wherein the support structure
`serves as a heat sink; .................................................... 118
`a thermally conductive support structure configured
`for outdoor use, ............................................................ 118
`wherein the support structure protects electronic
`components attached to the support structure from
`direct contact with rainwater, ...................................... 118
`wherein
`the support structure comprises an
`attachment point for securing the support structure
`to a weatherproof mount designed for outdoor use,
`and ................................................................................ 118
`wherein the support structure serves as a heat sink; .... 119
`a substantially planar circuit board attached to the
`support structure; ......................................................... 120
`a plurality of LEDs attached to the circuit board,
`wherein the LEDs are arranged in an array
`configuration; and ........................................................ 120
`a transparent substrate overlying all LEDs attached
`to the circuit board, wherein the transparent
`substrate includes a plurality of convex optical
`elements, each convex optical element overlying an
`associated one of the LEDs, wherein a surface [of]
`the transparent substrate is an outermost of the light
`assembly; ..................................................................... 121
`
`
`
`
`
`v
`
`
`
`Page 6 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`f)
`
`
`
`wherein the light assembly is configured to direct
`light from the LEDs towards a substantially
`rectangular area that is off-center relative to the
`light assembly, the light being directed in a manner
`that does not create hot spots or result in dead spots
`on the substantially rectangular area regardless of
`whether all of the LEDs of the plurality of LEDs or
`some of the LEDs of the plurality of LEDs are
`functional. .................................................................... 124
`16. Claim 30 ................................................................................. 127
`a)
`A light assembly comprising: ...................................... 127
`b)
`30.b: a thermally conductive support structure
`configured for outdoor use, wherein the support
`structure comprises an attachment point for
`securing the support structure to a weatherproof
`mount designed for outdoor use, ................................. 127
`a thermally conductive support structure configured
`for outdoor use, ............................................................ 127
`wherein
`the support structure comprises an
`attachment point for securing the support structure
`to a weatherproof mount designed for outdoor use; .... 128
`a substantially planar circuit board attached to the
`support structure; ......................................................... 128
`a plurality of LEDs attached to the circuit board,
`wherein the LEDs are arranged in an array
`configuration, wherein all of the LEDs attached to
`the circuit board are arranged in a single plane, and
`wherein the thermally conductive support structure
`is configured to serve as a heat sink and dissipate
`heat during operation of the LEDs; and ...................... 128
`a plurality of LEDs attached to the circuit board,
`wherein the LEDs are arranged in an array
`configuration, ............................................................... 128
`
`1)
`
`2)
`
`c)
`
`d)
`
`1)
`
`
`
`
`
`vi
`
`
`
`Page 7 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`2)
`
`3)
`
`e)
`
`1)
`
`2)
`
`3)
`
`4)
`
`
`
`wherein all of the LEDs attached to the circuit board
`are arranged in a single plane, and .............................. 129
`wherein the thermally conductive support structure
`is configured to serve as a heat sink and dissipate
`heat during operation of the LEDs; and ...................... 130
`a single transparent substrate overlying all LEDs
`attached
`to
`the circuit board, wherein
`the
`transparent substrate includes a plurality of optical
`elements, each optical element overlying an
`associated one or more of the LEDs, wherein the
`optical elements are configured to redirect light
`from the plurality of LEDs, each optical element
`being substantially the same as all other optical
`elements, wherein each LED is associated with a
`single optical element and each optical element is
`associated with a single LED, wherein each optical
`element comprises a convex portion at least
`partially overlying the associated LED, and wherein
`the optical elements are part of an outer surface that
`forms an exposed surface of the light assembly; ......... 133
`a single transparent substrate overlying all LEDs
`attached
`to
`the circuit board, wherein
`the
`transparent substrate includes a plurality of optical
`elements, each optical element overlying an
`associated one or more of the LEDs, ........................... 133
`wherein the optical elements are configured to
`redirect light from the plurality of LEDs, .................... 134
`each optical element being substantially the same as
`all other optical elements, ............................................ 135
`wherein each LED is associated with a single
`optical element and each optical element
`is
`associated with a single LED, ...................................... 135
`
`
`
`
`
`vii
`
`
`
`Page 8 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`5)
`
`
`
`wherein each optical element comprises a convex
`portion at least partially overlying the associated
`LED, and ...................................................................... 135
`wherein the optical elements are part of an outer
`surface that forms an exposed surface of the light
`assembly; ..................................................................... 136
`wherein the light assembly is configured to direct
`light from the LEDs towards an area in a manner
`that does not create hot spots or result in dead spots
`on the area regardless of whether all of the LEDs of
`the plurality of LEDs or some of the LEDs of the
`plurality of LEDs are functional .................................. 138
`Shimada in view of Marcoux Discloses or Suggests the Features
`of Claims 1-10, 12, 14, 16-17, 29, and 30 ........................................ 139
`Shimada in view of Holder Discloses or Suggests the Features of
`Claims 1-10, 12, 14, 16-17, 29, and 30 ............................................ 145
`1.
`Claim 16 ................................................................................. 145
`a)
`The light assembly of claim 1, further comprising:
`a second circuit board attached to the support
`structure; a second plurality of LEDs attached to the
`second circuit board; and a second single
`transparent substrate overlying all LEDs attached to
`the second circuit board. .............................................. 145
`Claim 17 ................................................................................. 155
`b)
`The light assembly of claim 16, wherein a main
`surface of the second circuit board being parallel to
`a main surface of the circuit board. ............................. 155
`Claims 1-10, 12, 14, 29, and 30 ............................................. 156
`3.
`Shimada in view of Holder and Marcoux Discloses or Suggests
`the Features of Claims 1-10, 12, 14, 16-17, 29, and 30 ................... 161
`Public Availability of DES ......................................................................... 162
`X.
`XI. CONCLUSION ........................................................................................... 167
`
`6)
`
`f)
`
`2.
`
`B.
`
`C.
`
`D.
`
`
`
`
`
`viii
`
`
`
`Page 9 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`I, Eric Bretschneider, declare as follows:
`
`
`
`I.
`
`INTRODUCTION
`1.
`I have been retained by Samsung Electronics Co., Ltd. (“Petitioner”) as
`
`an independent expert consultant in this proceeding before the United States Patent
`
`and Trademark Office (“PTO”) regarding U.S. Patent No. 10,223,946 (“the ’946
`
`patent”) (Ex. 1001).1 I have been asked to consider whether certain references
`
`disclose or suggest the features recited in claims 1-10, 12, 14, 16-17, 29, and 30 (“the
`
`challenged claims”) of the ’946 patent. My opinions are set forth below.
`
`2.
`
`I am being compensated at a rate of $500/hour for my work in this
`
`proceeding. My compensation is in no way contingent on the nature of my findings,
`
`the presentation of my findings in testimony, or the outcome of this or any other
`
`proceeding. I have no other interest in this proceeding.
`
`3.
`
`I have also been asked to provide information regarding the public
`
`availability of a certain reference. My factual testimony, which is separate and apart
`
`from my opinions, regarding this information is set forth below in Section X.
`
`
`
`
`
`
`1 Where appropriate, I refer to exhibits that I understand are to be attached to the
`
`petition for Inter Partes Review of the ’946 patent.
`
`
`
`
`
`1
`
`
`
`Page 10 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`II. BACKGROUND AND QUALIFICATIONS
`4.
`I am an independent consultant. All of my opinions stated in this
`
`
`
`Declaration are based on my own personal knowledge and professional judgment.
`
`In forming my opinions, I have relied on my knowledge and experience in designing,
`
`developing, researching, and teaching regarding LED and lighting technology,
`
`optical design and information referenced in this Declaration
`
`5.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. I understand that a copy of
`
`my current curriculum vitae, which includes a more detailed summary of my
`
`education and professional and academic experience, is provided as Ex. 1003. The
`
`following provides an overview of some of my experience that is relevant to the
`
`matters set forth in this Declaration.
`
`6.
`
`I have 30 years of experience with lighting and LEDs, including a
`
`comprehensive background on a full range of LED production technologies,
`
`including Metal-Organic Chemical Vapor Deposition
`
`("MOCVD")
`
`hardware/process, fabrication, LED chip and package testing and reliability, optical
`
`design, thermal management, color conversion, and SSL fixture/lamp design,
`
`integration, and reliability. Throughout the course of my career I have worked with
`
`or modified numerous MOCVD systems from a number of different companies
`
`including VEECO, Aixtron, Nippon Sanso, Thomas Swan, Spire Corporation, and
`
`
`
`
`
`2
`
`
`
`Page 11 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`ASM as well as a number of custom designed systems. All of these systems were
`
`designed and intended for use in producing compound semiconductor structures for
`
`LEDs.
`
`7.
`
`I developed growth processes on these systems for a wide variety of
`
`semiconductor material systems including: gallium nitride (GaN), aluminum
`
`gallium indium phosphide (AlInGaP), aluminum gallium arsenide (AlGaAs), zinc
`
`selenide (ZnSe), and zinc sulfide (ZnS).
`
`8.
`
`I have also designed and fabricated LED die based on these
`
`semiconductor material systems.
`
`9.
`
`In addition, I have also designed dozens of different LED packages for
`
`a wide variety of applications including outdoor lighting applications. These
`
`packages had power dissipation ratings from about 100 mW to over 20W. My
`
`package experience also includes use of phosphor materials and quantum dots for
`
`color version as well.
`
`10.
`
`I am currently the Chief Technology Officer at EB Designs &
`
`Technology. In that capacity, I am, among other things, responsible for the design
`
`of solid-state lighting technologies for clients ranging from startups to Fortune 100
`
`companies.
`
`11.
`
`I also serve as Chief Technology Officer at QuarkStar, LLC. QuarkStar
`
`is primarily a technology development company that is focused on new approaches
`
`3
`
`
`
`
`Page 12 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`to improving performance and efficiency of products that rely on LED light sources.
`
`A significant portion of QuarkStar’s technology relates to optical methods for
`
`enhancing the uniformity of illumination while maintaining high optical efficiency.
`
`12. Prior to my position at EB Designs & Technology, I served as the
`
`Director of Engineering at HeathCo, LLC. In that capacity, I was responsible for
`
`advanced technology/product development related to solid-state lighting, sensors,
`
`notifications, and control products. The majority of HeathCo’s lighting products
`
`were designed for outdoor lighting applications.
`
`13. Prior to my position as Director of Engineering at HeathCo, I was at the
`
`Elec-Tech International Co., Ltd., where I held the positions of Chief Engineer, ETi
`
`Lighting Research Institute and VP of Research and Development, ETi Solid State
`
`Lighting. In my Elec-Tech capacities, my responsibilities included developing all
`
`technology and product roadmaps for markets in North America, China, Europe, and
`
`Japan. In this role, I also designed and developed lighting products for outdoor
`
`applications including street and area lights, tunnel lights, sign lighters and façade
`
`lighting in all four geographical markets.
`
`14. Between 2008 and 2011, I was at Lighting Science Group (LSG), first
`
`as a product development manager, and my responsibilities included developing
`
`solid state lighting products including optical and thermal designs. As VP of
`
`Research, and my responsibilities included developing advanced LED models for
`
`4
`
`
`
`
`Page 13 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`product development and production control. In these roles, I was involved in the
`
`design and manufacture of numerous LED-based lighting fixtures and products. In
`
`this role I developed some of the first LED based area lighting products including
`
`post top lamps, street and area lighting in the industry. I managed the teams that
`
`developed Lighting Science Group’s outdoor lighting products including the Prolific
`
`streetlights, the RoadMaster streetlights and the C2D (Curb to Door) family of
`
`products.
`
`15. Between 2004 and 2008, I was at Toyoda Gosei North America, where
`
`I served as the east coast sales manager. I also provided technical support for Toyoda
`
`Gosei’s LED die and package customers in the western hemisphere. My
`
`responsibilities included managing and developing LED die and package sales
`
`accounts with a focus on increasing sales by providing customers technical support
`
`and resources to speed the development of LED based products. The support I
`
`provided included design of LED packages and design of lighting fixtures and
`
`products that incorporated LED packages. This support included design of optical
`
`and thermal management systems as well as providing guidance on electrical drive
`
`circuits and components.
`
`16. Notable accomplishments at Toyoda Gosei included the introduction of
`
`Toyoda Gosei's first products to be used for backlighting on notebook computers.
`
`This work resulted in Toyoda Gosei being awarded sole supplier status in four
`
`5
`
`
`
`
`Page 14 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`different Apple displays, including the iPad, two notebook models and a desktop
`
`display. Similar success was achieved with Dell. Apple and Dell were the only two
`
`primary (>$100 million/year) supply contracts ever received by Toyoda Gosei for
`
`their LED products.
`
`17. Between 2003 and 2004, I was at Beeman Lighting, where I was
`
`Director of Solid-State Lighting Engineering. My responsibilities included leading
`
`development of solid-state lighting systems and materials, including advanced linear
`
`chip on board (COB) packages for various lighting applications, most notably
`
`outdoor lighting and landscape lighting. I was also responsible for the optical design
`
`of products.
`
`18. Between 1998 and 2003, I was at Uniroyal Optoelectronics where I held
`
`a number of positions including Team Leader for the Epitaxial Growth and Materials
`
`Characterization areas, Sr. Epi Scientist, Director of Intellectual Property, University
`
`Relations and Government Contracts. My responsibilities included MOCVD
`
`hardware modification, epitaxial process development as well as design,
`
`development and testing of new LED chip structures for both AlInGaP and GaN-
`
`based material systems. I was also responsible for providing technical support and
`
`assistance to customers on topics related to use of LED chips, design of LED
`
`packages and design of LED based lighting products and systems. This support
`
`included both optical and thermal design of LED packages and LED lighting
`
`6
`
`
`
`
`Page 15 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`products. I was also responsible for wavelength conversion research using inorganic
`
`phosphors and quantum dot materials.
`
`19. My design of LED die and packages included optical modeling and
`
`design using commercial optical design software. I also developed customized
`
`software to model the electrical aspects of LED die designs. Notably this included
`
`modeling current spreading behavior for different contact materials and
`
`configurations as well as different electrode structures.
`
`20. The LED die and package products produced by Uniroyal
`
`Optoelectronics spanned the full range of 390 nm to 690 nm and included power
`
`levels in up to about 3 W. During this time, I developed customized LED die and
`
`packages for use on the USAF XSS-11 satellite and an exterior lighting system for
`
`the USS Zumwalt (DDG-1000) stealth destroyer for the US Navy.
`
`21. Uniroyal Technology Corporation (the parent corporation of Uniroyal
`
`Optoelectronics) launched Norlux Corporation in about 2000. Shortly thereafter, I
`
`was assigned to Norlux Corporation as a technical resource to help develop COB
`
`packages and also help direct LED die development in support of Norlux products.
`
`I spent between 35% to 50% of my time working on behalf of Norlux in this role.
`
`In 2001, Norlux announced the "Hex" product which was one of the first LED COB
`
`devices to reach the market. The Hex operated at up to about 5W input power.
`
`
`
`
`
`7
`
`
`
`Page 16 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`Norlux also produced linear COB devices for a variety of applications including
`
`passenger cabin lighting for Boeing aircraft and landscape lighting.
`
`22. From 1996 to 1998 I worked at Emcore Corporation as a Process
`
`Engineer. There I was responsible for qualifying MOCVD capital equipment for
`
`production and manufacturing process development for epitaxial structures. Some
`
`of the processes I developed included both AlInGaP and GaN based LED structures.
`
`23.
`
`I have also authored and presented more than a total of 30 publications,
`
`presentations, and seminars, and I am a named inventor on 30 issued patents and
`
`over 25 pending patents.
`
`24.
`
`I earned a Ph.D. in Chemical Engineering from the University of
`
`Florida in 1997, where my graduate work focused on development of optoelectronic
`
`devices, including novel silicon based visible LEDs and sulfide based TFELD
`
`structures and zinc selenide blue LEDs. This work included development of ohmic
`
`contact structures to ZnSe and ZnS LED structures as well as design of the
`
`electrodes, packaging and thermal management systems to allow the devices to be
`
`operated for extended periods of time during testing.
`
`25.
`
`In 1989 I worked for Shell Oil Corporation in Norco, LA. I was tasked
`
`with modeling heat exchanger performance for the crude oil distillation column in
`
`order to identify cost saving opportunities. I developed an improved model for
`
`determining the operating efficiency of heat exchange units that incorporated
`
`8
`
`
`
`
`Page 17 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`determined the economic impact on different operating conditions. The model was
`
`designed to be compatible with all major operating units on site and resulted in costs
`
`savings of over $20 million/year at the Norco Facility. My work was quickly
`
`adopted throughout the entire corporation and has resulted in sustained annual cost
`
`savings of approximately $500 million/year.
`
`26.
`
`I received a Bachelor of Science and Engineering degree in Chemical
`
`Engineering from Tulane University in 1989.
`
`27.
`
`In 1998, less than a year after receiving my Ph.D. in Chemical
`
`Engineering from the University of Florida, I was invited to join the University of
`
`Florida Department of Chemical Engineering Advisory Board. I have remained a
`
`member of the Advisory Board since that time and am the current chair. I am also a
`
`member of the Dean's Advisory Board for the College of Engineering at the
`
`University of Florida.
`
`28.
`
`I have been a Conference Chair for LED Measurement and Standards.
`
`I am also a member of a number of professional societies, including the Illuminating
`
`Engineering Society (IES), the International Society for Optics and Photonics
`
`(SPIE), the Optical Society of America (OSA), the Materials Research Society
`
`(MRS), and the American Society of Agricultural and Biological Engineers
`
`(ASABE).
`
`
`
`
`
`9
`
`
`
`Page 18 of 176
`
`

`

`Declaration of Dr. Eric Bretschneider
`U.S. Patent No. 10,223,946
`
`
`Inside the IES, I am a founding member of the Science Advisory Panel
`
`29.
`
`which has oversight over all testing and technical committees and work groups
`
`inside the IES. I am also a full member of the Test Procedures Committee which
`
`develops test, measurement and reliability standards for lighting fixtures. Inside the
`
`Test Procedures Committee, I serve as chair of the solid-state lighting subcommittee
`
`which develops test, measurement and reliability standards for LED based lighting
`
`products including LED packages, LED modules, LED light engines and LED
`
`fixtures/luminaires. I recently lead the work group that revised TM-21 which is the
`
`internationally accepted standard for predicting reliability of LED packages. I also
`
`developed a new mathematical model that for the first time allows prediction of the
`
`chromaticity (color) shift of an LED package over its time. This model is the basis
`
`for a pending IES standard known as TM-35.
`
`30. During the course of my career, as detailed above, I have trained
`
`personnel at levels ranging from senior scientists to junior technicians in all aspects