Appendix 4
`Ultravision’s Claim Chart for U.S. Patent No. 10,223,946 v. Samsung Array
`In these infringement contentions, Ultravision contends that at least the claims of U.S. Patent
`No. 10,223,946 (“the ’946 patent”) identified below are infringed by Samsung’s Array Gen2
`LED modules,1 including:
`
`•
`
`•
`
`50W Module, SL-IGR5E82SBWW;2 and
`
`70W Modules, SL-IGR7E970BWW, SL-IGR7E97SBWW, and SL-IGR7E9CoBWW.3
`
`Ultravision does not concede that any claims of the ’946 patent that are not listed below are not
`infringed by the identified products. Moreover, the citations to certain documents and other
`information below are intended to be exemplary only and in no way foreclose Ultravision from
`citing or relying on additional documents, information, and/or testimony at a later time. These
`contentions are preliminary in nature, and an analysis of Samsung’s products, internal
`documentation, and/or testimony from relevant witnesses may more fully and accurately describe
`the infringing features of its accused products. Accordingly, Ultravision reserves the right to
`supplement, correct, modify, and/or amend these contentions once such additional information is
`made available to Ultravision. Furthermore, Ultravision reserves the right to supplement, correct,
`modify, and/or amend these contentions as discovery in this case progresses; in view of the
`Court’s claim construction order(s); in view of any positions taken by Samsung, including but
`not limited to positions on claim construction, invalidity, and/or non-infringement; and in
`connection with the preparation and exchange of expert reports.
`
`Claim
`1. A light assembly
`comprising:
`
`Support
`The Samsung Array Gen2 LED modules are light
`assemblies.
`
`1[a] a thermally conductive
`support structure configured
`for outdoor use, wherein the
`support structure protects
`electronic components
`attached to the support
`
`The Samsung Array Gen2 LED modules comprise 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
`
`1 https://www.samsung.com/led/lighting/led-modules/outdoor-light-module/array-gen2/.
`2 https://cdn.samsung.com/led/file/resource/2017/11/Data_Sheet_Array_Gen2_SL-
`IGR5E82SBWW_Rev.2.0.pdf.
`3 https://cdn.samsung.com/led/file/resource/2017/11/Data_Sheet_Array_Gen2_SL-
`IGR7E9xxBWW_Rev.2.0.pdf.pdf.
`
`Page 1 of 18
`
`SAMSUNG EXHIBIT 1006
`
`

`

`Support
`structure to a weatherproof mount designed for outdoor use.
`
`Claim
`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;
`
`attachment
`points
`
`thermally
`conductive
`support
`structure
`
`1[b] a heat sink;
`
`
`See supra note 2 (“Samsung outdoor modules…”, “IP66 for
`durability and robustness”)
`
`Upon information and belief, the Samsung Array Gen2 LED
`modules comprise a heat sink.
`
`2
`
`Page 2 of 18
`
`

`

`Claim
`
`Support
`
`heat sink
`
`
`See supra note 2 (“7. Base plate heat sink Material:
`Extrusion aluminum”)
`
`1[c] a substantially planar
`circuit board attached to the
`support structure;
`
`Upon information and belief, the Samsung Array Gen2 LED
`module comprise a substantially planar circuit board
`attached to the support structure.
`
`3
`
`Page 3 of 18
`
`

`

`Claim
`
`Support
`
`substantially
`planar circuit
`board
`
`
`See supra note 2 (“4. LED board … Material: MC-PCB,
`aluminum”)
`
`The Samsung Array Gen2 LED modules comprise a
`plurality of LEDs attached to the circuit board, wherein the
`LEDs are arranged in an array configuration.
`
`1[d] a plurality of LEDs
`attached to the circuit board,
`wherein the LEDs are arranged
`in an array configuration; and
`
`4
`
`Page 4 of 18
`
`

`

`Claim
`
`Support
`
`plurality of
`LEDs
`
`
`See supra note 2 (“4. LED board … LED: LH351B Ceramic
`high flux rank (36 pcs)”)
`
`Upon information and belief, the Samsung Array Gen2 LED
`modules comprise 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.
`
`1[e] 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;
`
`5
`
`Page 5 of 18
`
`

`

`Claim
`
`Support
`
`substantially
`transparent
`substrate
`
`plurality of
`convex optical
`elements
`
`
`
`See supra note 2 (“Array lens cover”)
`
`
`
`1[f] 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
`
`Upon information and belief, the light assembly of the
`Samsung Array Gen2 LED module are 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
`
`6
`
`Page 6 of 18
`
`

`

`Support
`LEDs or some of the LEDs of the plurality of LEDs are
`functional.
`
`Claim
`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.
`
`
`On information and belief, the Samsung Array Gen2 LED
`module are 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.
`
`2. 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.
`
`7
`
`Page 7 of 18
`
`

`

`Claim
`
`Support
`
`3. The light assembly of claim
`1, wherein the heat sink
`includes a plurality of fins
`extending in a direction away
`from the circuit board.
`
`4. The light assembly of claim
`1, wherein a portion of the heat
`sink is in direct contact with
`the support structure.
`
`
`The heat sink of the Samsung Array Gen2 LED modules
`include a plurality of fins extending in a direction away from
`the circuit board.
`
`heat sink
`includes a
`plurality of
`fins extending
`in a direction
`away from the
`circuit board
`
`A portion of the heat sink of the Samsung Array Gen2 LED
`modules is in direct contact with the support structure.
`
`support
`structure
`also acts as
`heat sink
`
`
`
`8
`
`Page 8 of 18
`
`

`

`Claim
`5. 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.
`
`6. The light assembly of claim
`1, wherein the support
`structure and the heat sink are
`portions of a single integral
`component.
`
`7. 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.
`
`Support
`The heat sink of the Samsung Array Gen2 LED modules is
`directly exposed to the outside atmosphere and is not entirely
`enclosed by the support structure.
`
`heat sink
`directly exposed
`to the outside
`atmosphere and
`not entirely
`enclosed by the
`support
`structure
`
`The support structure and the heat sink of the Samsung
`Array Gen2 LED modules are portions of a single integral
`component.
`support
`structure
`and heat
`sink are
`portions of a
`single
`integrated
`
`unit
`Each convex optical element of the Samsung Array Gen2
`LED modules overlies a single associated LED and wherein
`each and every one of the plurality of LEDs has an overlying
`convex optical element.
`
`convex optical
`element
`overlies a
`single
`associated
`LED
`
`
`8. The light assembly of claim The circuit board of the Samsung Array Gen2 LED modules
`
`9
`
`Page 9 of 18
`
`

`

`Claim
`1, wherein the circuit board is
`in physical contact with the
`heat sink.
`
`Support
`is in physical contact with the heat sink.
`element.
`
`circuit
`board in
`direct
`contact with
`the heat sink
`(via thermal
`pad)
`
`thermal
`pad
`
`heat sink
`
`9. The light assembly of claim
`1, wherein the circuit board
`surrounded by a portion of the
`support structure.
`
`
`The circuit board of the Samsung Array Gen2 LED modules
`is surrounded by a portion of the support structure.
`
`10
`
`Page 10 of 18
`
`

`

`Claim
`
`Support
`
`circuit
`board
`
`portion of
`support
`structure
`surrounding
`circuit board
`
`
`
`10. The light assembly of
`claim 1, wherein each LED is
`located between the circuit
`board and one of the convex
`optical elements.
`
`
`Each LED of the Samsung Array Gen2 LED modules is
`located between the circuit board and one of the convex
`optical elements.
`
`11
`
`Page 11 of 18
`
`

`

`Claim
`
`Support
`
`optical
`element
`
`LED
`circuit
`board
`
`
`On information and belief, the Samsung Array Gen2 LED
`modules is configured 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.
`
`12. 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.
`
`12
`
`Page 12 of 18
`
`

`

`Claim
`
`Support
`
`14. The light assembly of
`claim 1, wherein each of the
`plurality of convex optical
`elements is substantially
`identical in shape and size.
`
`
`Each of the plurality of convex optical elements of the
`Samsung Array Gen2 LED modules is substantially identical
`in shape and size.
`
`each convex
`optical
`element is
`substantially
`identical in
`shape and size
`
`
`
`13
`
`Page 13 of 18
`
`

`

`Claim
`29. A light assembly
`comprising:
`
`Support
`The Samsung Array Gen2 LED modules are a light
`assembly. See preamble of claim 1.
`
`The Samsung Array Gen2 LED modules comprise 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.
`See claim element 1[a].
`The support structure serves as a heat sink. See claim
`element 1[b], claim 6.
`
`29[a] 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;
`
`29[b] a substantially planar
`circuit board attached to the
`support structure;
`
`The Samsung Array Gen2 LED modules comprise a
`substantially planar circuit board attached to the support
`structure. See claim element 1[c].
`
`29[c] a plurality of LEDs
`attached to the circuit board,
`wherein the LEDs are arranged
`in an array configuration; and
`
`The Samsung Array Gen2 LED modules comprise a
`plurality of LEDs attached to the circuit board, wherein the
`LEDs are arranged in an array configuration. See claim
`element 1[d].
`
`The Samsung Array Gen2 LED modules comprises 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. See claim
`element 1[e], claim 7.
`A surface of the transparent substrate is an outermost of the
`light assembly.
`
`29[d] 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 the
`transparent substrate is an
`outermost of the light
`assembly; 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
`
`14
`
`Page 14 of 18
`
`

`

`Support
`
`Claim
`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.
`
`surface of
`transparent
`substrate is an
`outermost of
`light assembly
`
`
`
`surface of
`transparent
`substrate is an
`outermost of
`light assembly
`
`
`Upon information and belief, the light assembly of the
`Samsung Array Gen2 LED modules 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.
`
`15
`
`Page 15 of 18
`
`

`

`Claim
`
`Support
`
`
`
`30. A light assembly
`comprising:
`
`The Samsung Array Gen2 LED modules are light
`assemblies. See preamble of claim 1.
`
`30[a] 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;
`
`The Samsung Array Gen2 LED modules comprises 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. See claim
`element 1[a].
`
`30[b] a substantially planar
`circuit board attached to the
`support structure;
`
`Upon information and belief, the Samsung Array Gen2 LED
`modules comprise a substantially planar circuit board
`attached to the support structure. See claim element 1[c].
`
`30[c] a plurality of LEDs
`attached to the circuit board,
`wherein the LEDs are arranged
`in an array configuration,
`
`The Samsung Array Gen2 LED modules comprise a
`plurality of LEDs attached to the circuit board, wherein the
`LEDs are arranged in an array configuration. See claim
`element 1[d].
`
`16
`
`Page 16 of 18
`
`

`

`Support
`All of the LEDs attached to the circuit board of the Samsung
`Array Gen2 LED modules are arranged in a single plane.
`
`Claim
`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
`
`LEDs
`arranged in
`single plane
`
`
`The thermally conductive support structure of the Samsung
`Array Gen2 LED modules are configured to serve as a heat
`sink and dissipate heat during operation of the LEDs. See
`claim element 1[b], claim 6.
`
`Upon information and belief, the Samsung Array Gen2 LED
`modules comprises 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. See claim element 1[e].
`
`30[d] 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,
`
`30[e] wherein the optical
`elements are configured to
`redirect light from the plurality
`of LEDs,
`each optical element being
`substantially the same as all
`
`Upon information and belief, the optical elements of the
`Samsung Array Gen2 LED modules is configured to redirect
`light from the plurality of LEDs. See claim element 1[f].
`Each optical element of the Samsung Array Gen2 LED
`modules is substantially the same as all other optical
`elements. See claim 14.
`
`17
`
`Page 17 of 18
`
`

`

`Support
`Each LED of the Samsung Array Gen2 LED modules is
`associated with a single optical element and each optical
`element is associated with a single LED. See claim 7.
`
`Each optical element of the Samsung Array Gen2 LED
`modules comprises a convex portion at least partially
`overlying the associate LED. See claim element 1[e].
`
`The optical elements of the Samsung Array Gen2 LED
`modules are part of an outer surface that forms an exposed
`surface of the light assembly. See claim element 29[d].
`
`Upon information and belief, the light assembly of the
`Samsung Array Gen2 LED modules 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. See claim element 1[f].
`
`Claim
`other optical elements,
`wherein each LED is
`associated with a single optical
`element and each optical
`element is associated with a
`single LED,
`
`30[f] wherein each optical
`element comprises a convex
`portion at least partially
`overlying the associated LED,
`and
`
`30[g] wherein the optical
`elements are part of an outer
`surface that forms an exposed
`surface of the light assembly;
`
`30[h] 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.
`63801229 v1
`
`18
`
`Page 18 of 18
`
`