throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`United States Patent No.: 8,530,250
`Inventors: Hirofumi Ichikawa,
`Masaki Hayashi, Shimpei Sasaoka,
`Tomohide Miki
`Formerly Application No.: 12/737,940
`Issue Date: September 10, 2013
`PCT Filing Date: August 27, 2009
`§ 371(c)(1), (2), (4) Date: May 13, 2011
`Former Group Art Unit: 2895
`Former Examiner: Caridad Everhart
`










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`Attorney Docket No.:
`112868-0001-653
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`Customer No.: 28120
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`Petitioner: VIZIO, Inc.
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`LIGHT EMITTING DEVICE, RESIN PACKAGE, RESIN-MOLDED
`For:
`BODY, AND METHODS FOR MANUFACTURING LIGHT EMITTING DE-
`VICE, RESIN PACKAGE AND RESIN-MOLDED BODY
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`DECLARATION OF DR. STANLEY R. SHANFIELD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 8,530,250
`
`NICHIA EXHIBIT 2001
`Vizio, Inc. v. Nichia Corporation
`Case IPR2018-00386
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`VIZIO Ex. 1003 Page 0001
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`

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`TABLE OF CONTENTS
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`2.
`3.
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`Introduction ...................................................................................................... 1
`I.
`Background and Qualifications ....................................................................... 1
`II.
`Priority Date and One of Ordinary Skill .......................................................... 6
`III.
`IV. Materials Relied Upon ..................................................................................... 8
`Background on the State of the Art ................................................................. 8
`V.
`VI. Analysis of the ’250 Patent ............................................................................ 15
`Overview of the ’250 Patent ................................................................ 15
`A.
`B.
`Overview of the ’250 Patent Prosecution History .............................. 22
`C.
`Claim Construction of the ’250 Patent Claims ................................... 25
`VII. The Challenged Claims are Invalid ............................................................... 28
`A.
`Legal Standards ................................................................................... 28
`Claims 1, 7, 17, 19 and 21 Are Obvious Under § 103 Over
`B.
`Park ’697, Park ’486, Urasaki, and/or Oshio ...................................... 33
`1.
`Overview of Japanese Patent Publication No.
`JP 2006-093697 (“Park ’697”).................................................. 33
`Overview of WO 2007/055486 (“Park ’486”) .......................... 39
`Overview of Japanese Patent Publication No. 2007-
`235085 (“Urasaki”) ................................................................... 44
`Overview of U.S. Patent Publication No. 2005/0280017
`(“Oshio”) ................................................................................... 46
`Invalidity of Claim 1 Over Grounds 1-8: (1) Park ’697;
`(2) Park ’697 and Oshio; (3) Park ’697 and Park ’486; (4)
`Park ’697 and Urasaki; (5) Park ’697, Park ’486, and
`Urasaki; (6) Park ’697, Park ’486, and Oshio; (7)
`Park ’697, Urasaki, and Oshio; (8) Park ’697, Park ’486,
`Urasaki, and Oshio .................................................................... 50
`Invalidity of Claim 7 Over Grounds 1-8: (1) Park ’697;
`(2) Park ’697 and Oshio; (3) Park ’697 and Park ’486; (4)
`Park ’697 and Urasaki; (5) Park ’697, Park ’486, and
`Urasaki; (6) Park ’697, Park ’486, and Oshio; (7)
`Park ’697, Urasaki, and Oshio; (8) Park ’697, Park ’486,
`Urasaki, and Oshio .................................................................... 84
`Invalidity of Claim 17 Over Grounds 1-2: (1) Park ’697;
`or alternatively, (2) Park ’697 and Oshio ................................. 92
`Invalidity of Claim 19 Over Grounds 1-2: (1) Park ’697,
`or alternatively, (2) Park ’697 and Oshio ................................. 95
`Invalidity of Claim 21 Over Grounds 1-2: (1) Park ’697;
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`4.
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`5.
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`6.
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`7.
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`8.
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`9.
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`i
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`VIZIO Ex. 1003 Page 0002
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`or alternatively, (2) Park ’697 and Oshio ................................. 97
`VIII. Secondary Considerations ............................................................................. 98
`IX. Conclusion ..................................................................................................... 99
`
`APPENDIX A (Curriculum Vitae)
`APPENDIX B (List of Materials Considered)
`APPENDIX C (Claim Charts)
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`ii
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`VIZIO Ex. 1003 Page 0003
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`I, Dr. Stanley Shanfield, hereby declare under penalty of perjury under the
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`laws of the United States of America:
`
`I. INTRODUCTION
`1.
`I have been retained to provide assistance regarding U.S. Patent
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`No. 8,530,250 (“the ’250 patent”). Specifically, I have been asked to consider the
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`validity of claims 1, 7, 17, 19, and 21 of the ’250 patent (the “Challenged Claims”).
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`I have personal knowledge of the facts and opinions set forth in this declaration,
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`and believe them to be true. If called upon to do so, I would testify competently
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`thereto. I have been warned that willful false statements and the like are
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`punishable by fine or imprisonment, or both.
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`2.
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`I am being compensated for my time at my standard consulting rate of
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`$385 per hour. I am also being reimbursed for expenses that I incur during the
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`course of this work. My compensation is not contingent upon the results of my
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`study, the substance of my opinions, or the outcome of any proceeding involving
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`the challenged claims. I have no financial interest in the outcome of this matter or
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`on the pending litigation between Petitioner and Patent Owner.
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`3.
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`A table of contents and a list of exhibits referenced herein are
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`included above.
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`II. BACKGROUND AND QUALIFICATIONS
`4.
`I offer statements and opinions on behalf of Petitioner VIZIO, Inc.
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`1
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`(“VIZIO” or “Petitioner”), generally regarding the validity, novelty, prior art,
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`obviousness considerations, and understanding of a person of ordinary skill in the
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`art (“POSITA”) as it relates to U.S. Patent No. 8,530,250 (“the ’250 patent”).
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`Attached hereto as Appendix A, is a true and correct copy of my Curriculum Vitae
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`describing my background and experience.
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`5.
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`As set forth in my curriculum vitae, I received a B.S. degree in
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`Physics from the University of California, Irvine in 1977, and was a member of the
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`Phi Beta Kappa Society. In 1975, I received the University of California Regents
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`Award for Outstanding Research on experimental and theoretical work on rotating
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`relativistic electron beams. Under full Energy Research and Development
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`Administration scholarship, I received a Ph.D. in Physics from the Massachusetts
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`Institute of Technology in 1981.
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`6.
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`Starting in 1985 at Raytheon Research Division, most of my work
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`focused on the development, packaging, and testing of semiconductor devices,
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`including devices made using GaAs, AlGaAs, InGaAs, GaN, and SiC. During the
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`late 1980s and most of the 1990s, I was directly involved in the epitaxial growth
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`and packaging of electronic devices and integrated circuits, specialized LED
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`devices and optical detectors. Along with other activities, I produced, packaged
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`and tested LEDs for government and commercial applications e.g. display
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`illumination devices, fiber optic modules, and detection instruments. Experimental
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`and small lot production LEDs were placed in metal-ceramic packaging and, later,
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`in compression or
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`transfer-molded
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`thermoset packages manufactured on
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`leadframes.
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`7.
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`During the time period of 1996-1999 at Raytheon Commercial
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`Electronics as Semiconductor Operations Director, I was responsible for integrated
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`circuit fabrication, device packaging, and electronic assembly manufacturing. This
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`included the operation of a large-scale, 24-hour component and integrated circuit
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`manufacturing facility with on-site and overseas (S. Korea) chip and optical device
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`packaging facilities. In addition to performing higher cost packaging efforts, these
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`facilities manufactured compression or transfer molded packaging with punched
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`and plated leadframes. I was directly involved in establishing packaging operations,
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`including equipment selection and evaluation, packaging process development,
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`final test and reliability evaluation. As part of my activities, I led teams that
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`investigated thermoset packaging issues for high power devices (including LEDs),
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`as well as packaging yield loss and in-depth device failure analysis.
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`8.
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`From 1999 to 2003 I co-founded a start-up company, AXSUN
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`Technologies, and became the VP of Operations. AXSUN developed a new
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`electro-optical assembly platform and used it to build miniature optical modules
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`for fiber optic communications systems. I was directly involved in the
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`development and manufacturing of the company’s flagship product, and devised
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`custom packaging of a high power super-luminescent LEDs. I received a patent for
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`the key electro-optical component in this product. The company, which grew to
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`more than 100 employees by 2001, was eventually sold.
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`9.
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`Since 2003 I have served at the Charles Stark Draper Laboratory
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`(“Draper Laboratory”) in Cambridge, Massachusetts, ultimately becoming a
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`Distinguished Member of the Technical Staff and Technical Director in the
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`Advanced Hardware Development Division. For several years, I led the Advanced
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`Hardware Development Division (consisting of approximately 80 staff members)
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`in their work on the laboratory’s high density multi-chip packaging technology.
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`This work involved the use of a multi-layer (miniature leadframe) and thermoset
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`encapsulation schemes suitable for packaging multiple chip components, including
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`LEDs and semiconductor lasers. I have led teams responsible for the design and
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`thermo-mechanical modeling of new packaging schemes and the development of
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`their manufacturing processes, and eventually received a patent for an ultra-high
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`density packaging process currently in use at Draper.
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`10. With respect to the manufacturing of packaged LED and other high
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`power semiconductor components, I have about 25 years of experience with most
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`of the possible manufacturing processes and materials involved, and understand the
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`relevant assembly and packaging manufacturing economics. My direct technical
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`experience includes work with plated copper leadframe assembly processes (and
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`plating processes in general, including masking and spot plating techniques),
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`thermoset molding methods and equipment (as well as other molding approaches),
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`die mounting (both eutectic and conductive epoxy), gold and aluminum
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`wirebonding techniques and equipment, molded leadframe dicing and singulation
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`methods, and a variety of package failure analyses on high power devices
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`(including an LED) in thermoset packages.
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`11.
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`I have authored more than 25 journal and conference papers,
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`including numerous papers on topics relating to semiconductor devices, electronic
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`circuit design and packaging.
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`12.
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`I have been invited to give professional talks at various conferences.
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`For example, in 1997, I gave an invited talk on “IC [Integrated Circuit]
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`Technologies for Wireless Applications Beyond 2000” and received an Author’s
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`award for my work in that area.
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`13.
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`I am a named inventor or co-inventor on the following nine U.S.
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`Patents:
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` U.S. Patent No. 8,653,897, entitled “Devices, systems, and methods for con-
`
`trolling the temperature of resonant elements”
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` U.S. Patent No. 8,248,173, entitled “Devices, systems, and methods for con-
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`trolling the temperature of resonant elements”
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` U.S. Patent No. 7,727,806, entitled “Systems and methods for high density
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`5
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`multi-component modules”
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` U.S. Patent No. 6,836,366, entitled “Integrated tunable fabry-perot filter and
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`method of making same”
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` U.S. Patent No. 6,525,880, entitled “Integrated tunable fabry-perot filter and
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`method of making same”
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` U.S. Patent No. 5,880,483, entitled “Semiconductor devices”
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` U.S. Patent No. 5,223,458, entitled “Method of manufacturing a III-V semi-
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`conductor device using a self-biased substrate and a plasma containing an
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`electronegative species”
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` U.S. Patent No. 4,526,673, entitled “Coating method”
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` U.S. Patent No. 4,440,108, entitled “Ion beam coating apparatus”
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`14.
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`I have previously testified in a number of patent cases, many of which
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`concerned integrated circuits and components, including optical components,
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`before various District Courts, the International Trade Commission and the Patent
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`Trial and Appeal Board. These engagements as well as a list of my publications
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`can be found on my curriculum vitae, attached as Appendix A.
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`15.
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`I have been qualified in multiple courts to offer expert opinions on
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`integrated circuits, optical and electronic devices, and their packaging technology.
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`III. PRIORITY DATE AND ONE OF ORDINARY SKILL
`16.
`I understand that the factors considered in determining the ordinary
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`level of skill in a field of art include the level of education and experience of
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`persons working in the field; the types of problems encountered in the field; and
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`the sophistication of the technology at the time of the invention, which I
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`understand is asserted to be September 3, 2008. I understand that a person of
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`ordinary skill in the art is not a specific real individual, but rather is a hypothetical
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`individual having the qualities reflected by the factors above. I understand that a
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`person of ordinary skill in the art would also have knowledge from the teachings of
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`the prior art, including the art cited below.
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`17.
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`In my opinion, on or before September 3, 2008, a person of ordinary
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`skill in the art (“POSITA”) relating to the technology of the ’250 patent would
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`have a minimum of a Bachelor’s degree in Physics, Electrical Engineering,
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`Material Science, or a related field, and approximately 5 years of professional
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`experience in the field of semiconductor technology, including manufacturing and
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`packaging processes for light emitting devices. Additional graduate education
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`could substitute for professional experience, or significant experience in the field
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`could substitute for formal education. A POSITA is presumed to have knowledge
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`of all relevant prior art, and would thus have been familiar with each of the
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`references cited herein, as well as the background knowledge in the art discussed
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`in Section V, and the full range of teachings they contain.
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`18. Well before September 3, 2008, my level of skill in the art was at least
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`that of a POSITA. I am qualified to provide opinions concerning what a POSITA
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`would have known and understood at that time, and my analysis and conclusions
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`herein are from the perspective of a POSITA as of September 3, 2008.
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`IV. MATERIALS RELIED UPON
`19.
`In reaching the conclusions described in this declaration, I have relied
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`on the documents and materials cited herein as well as those identified in Appendix
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`B attached to this declaration. These materials comprise patents, related
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`documents, and printed publications. Each of these materials is a type of document
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`that experts in my field would reasonably rely upon when forming their opinions.
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`20. My opinions are also based upon my education, training, research,
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`knowledge, and personal and professional experience.
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`V. BACKGROUND ON THE STATE OF THE ART
`21. Light emitting devices, and methods of manufacturing light emitting
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`devices, were well known in the art long before the claimed priority date of
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`the ’250 patent. E.g., Ex. 1004 (Park ’697) ¶ 12 (disclosing a “production method”
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`for an “LED optical semiconductor”); Ex. 1005 (Koung) ¶ 2 (disclosing “a
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`packaging method to manufacture a package for a light emitting diode”); Ex. 1006
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`(Park ’486), 5:7-8 (disclosing a “light emitting diode and a method of
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`manufacturing the same”); Ex. 1008 (Oshio) ¶ 2 (disclosing “a semiconductor light
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`emitting device”); Ex. 1007 (Urasaki) ¶ 1 (disclosing “a method of manufacturing
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`a package substrate for mounting an optical semiconductor element”); Ex. 1010
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`(Kuramoto) ¶ 1 (disclosing a “light emitting device” and “a manufacturing method
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`for
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`the
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`same”); Ex. 1011
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`(Wang) ¶ 2
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`(disclosing “a method of
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`manufacturing…light-emitting device packages and structure thereof”).
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`22.
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`It was further well-known to use a lead frame having notches in
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`manufacturing an LED package. E.g., Ex. 1004 (Park ’697) ¶ 13, Fig. 5
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`(disclosing a lead frame with notches); Ex. 1005 (Koung) ¶ 2, Figs. 2b, 4b
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`(disclosing a lead frame with notches); Ex. 1006 (Park ’486), 6:2-14, 17:17-20,
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`Figs. 6-7 (disclosing a lead frame with notches); Ex. 1008 (Oshio) ¶¶ 85-87, Figs.
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`11, 12 (disclosing a lead frame with notches).
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`23. Before the claimed priority date, it was also well-known in the art to
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`plate a lead frame and further well-known to plate all surfaces of a lead frame, to,
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`e.g., “increase the light reflectance…and the bonding strength of solder.” E.g., Ex.
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`1004 (Park ’697) ¶¶ 1, 12 (disclosing a “silver plated lead frame”); Ex. 1005
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`(Koung) ¶ 26 (disclosing that “the dissipating board (210) and the electrodes (220)
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`of each substrate (200) may be coated or plated with a reflective coating”); Ex.
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`1008 (Oshio) ¶¶ 69, 114, Fig. 4 (disclosing plating on all surfaces of the leads); Ex.
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`1011 (Wang) ¶¶ 9, 13, 39, 41, 53-54; Figs. 2-5 (disclosing plating on all surfaces of
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`the leads).
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`24.
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`It was further well-known in the art to form a resin-molded body on a
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`plated lead frame by performing the molding step after plating the lead frame. E.g.,
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`Ex. 1004 (Park ’697) ¶ 12 (disclosing “forming a transfer mold type reflector with
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`a white thermosetting resin” on a “silver plated lead frame”); Ex. 1006 (Park ’486),
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`6:1-17, 12:11-13:11 (disclosing forming a resin-molded body after plating a lead
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`frame); Ex. 1005 (Koung) ¶¶ 19-26 (disclosing forming a resin-molded body after
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`plating); Ex. 1008 (Oshio) ¶¶ 71, 49, Figs. 1-3, 13 (disclosing forming a resin-
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`molded body after plating).
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`25.
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`It was also well-known in the art to form a resin-molded body by
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`transfer-molding a thermosetting resin containing a light reflecting material. E.g.,
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`Ex. 1004 (Park ’697) ¶¶ 13, 1, 12, Abstract, Figs. 1-7 (disclosing that “the
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`reflection cup 91 having a reflector on the surface is produced from a TiO2-based
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`white thermosetting resin 9 by the transfer mold method”); Ex. 1007 (Urasaki) ¶¶
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`21, 24, 25 (disclosing using “transfer molding” to form “a thermosetting resin
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`composition for reflecting light” containing “an inorganic filler” and “a white
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`pigment” and “having a light reflectance after thermal curing of at least 80%”); Ex.
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`1010 (Kuramoto) ¶¶ 38-40, 48, 49, 50 (disclosing forming a “first resin
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`molding…through transfer molding…using thermosetting resin” containing a
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`“reflective substance[]” such as “titanium oxide and silica or alumina”). It was
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`also known in the art that “transfer molding allows the molding of moldings with a
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`complex shape,” including “concave part[s].” Ex. 1010 (Kuramoto) ¶ 38. It was
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`further known in the art that using thermosetting resin reduces deterioration and
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`extends the life of an LED. Ex. 1010 (Kuramoto) ¶ 39.
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`26.
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`It was also well-known to perform transfer-molding using an upper
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`mold on a first surface of the lead frame and a lower mold on a second surface of
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`the lead frame. E.g., Ex. 1007 (Urasaki) ¶¶ 24, 34, Figs. 1-2 (disclosing using an
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`upper mold on a first surface of the lead frame and a lower mold on a second
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`surface of the lead frame to transfer-mold a thermosetting resin); Ex. 1010
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`(Kuramoto) ¶¶ 48, 120-128, Fig. 10 (disclosing “a first lead and a second lead” that
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`are “sandwiched between the upper mold and a lower mold” and that
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`“thermosetting resin is filled into the recessed portion sandwiched between the
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`upper mold and lower mold by means of a transfer molding process”); Ex. 1001
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`(’250 patent), 2:16-29, Fig. 19 (the ’250 patent discloses it was “conventional” to
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`perform transfer-molding using an upper mold on a first surface of the lead frame
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`and a lower mold on a second surface of the lead frame).
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`27.
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`It was also well-known in the art to form a plurality of concave
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`portions (corresponding to convex portions of an upper mold) in a resin-molded
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`body, where each of the concave portions has an inner bottom surface at which a
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`portion of the lead frame is exposed. E.g., Ex. 1007 (Urasaki) ¶¶ 11, 37, 24, Fig. 1
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`(disclosing a plurality of concave portions in a resin-molded body corresponding to
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`convex portions of an upper mold, where each of the concave portions has an inner
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`bottom surface at which a portion of the lead frame is exposed); Ex. 1004
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`(Park ’697) ¶¶ 13, Figs. 1c, 7 (disclosing a plurality of concave portions in a resin-
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`molded body, where each of the concave portions has an inner bottom surface at
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`which a portion of the lead frame is exposed); Ex. 1005 (Koung) ¶ 21, Figs. 4c-4f
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`(disclosing a plurality of concave portions in a resin-molded body, where each of
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`the concave portions has an inner bottom surface at which a portion of the lead
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`frame is exposed).
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`28.
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`It was also well-known in the art to cut a resin-molded body and a
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`lead frame along a notch such that an outer surface of the resin part and an outer
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`surface of a lead frame are planar at an outer surface of the resin package. E.g., Ex.
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`1004 (Park ’697) ¶¶ 1, 12-13, 24, Figs. 1a, 3a, 4a, 5-7 (disclosing a lead frame with
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`notches and cutting along a notch such that an outer surface of the resin part and an
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`outer surface of the lead frame are planar at an outer surface of the resin package);
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`Ex. 1005 (Koung) ¶¶ 8, 18, 24, Figs. 2b, 2c, 3a, 3b, 4b-4f (disclosing a lead frame
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`with notches and cutting along a notch such that an outer surface of the resin part
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`and an outer surface of the at least one lead are planar at an outer surface of the
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`resin package); Ex. 1006 (Park ’486), 13:1-11, 15:12-16, 16:10-18, 17:17-20, Figs.
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`5-7, 11, 12 (disclosing a lead frame with notches and cutting along a notch such
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`that an outer surface of the resin part and an outer surface of a lead frame are
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`planar at an outer surface of the resin package).
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`29. Furthermore, it was well-known in the art that cutting a plated lead
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`frame forms an unplated outer side surface on the lead. E.g., Ex. 1008 (Oshio) ¶
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`114 (disclosing that “if the lead frame is plated with silver or the like, an unplated
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`surface of base material is exposed at the cut section”); Ex. 1004 (Park ’697) ¶¶ 1,
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`12, Figs. 1a, 1c, 3a, 3c, 4a, 4c (disclosing plating the lead frame, molding a resin,
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`then cutting the lead frame and resin, wherein the cut side of the lead is unplated);
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`Ex. 1005 (Koung) ¶¶ 19-26, Figs. 2b, 2c, 3a, 3b, 4b-4f (disclosing plating the lead
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`frame, molding the resin, then cutting the lead frame and resin, wherein the cut
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`side of the lead is unplated); Ex. 1006 (Park ’486), 12:12-15, 13:6-11, 15:12-16,
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`16:10-16 (disclosing plating the lead frame, molding the resin, then cutting the lead
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`frame and resin, wherein the cut side of the lead is unplated).
`
`30.
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`It was also well-known in the art before the claimed priority date to
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`use a step on a bottom surface or outer surface of a lead. E.g., Ex. 1004
`
`(Park ’697), Figs. 1a-1b (disclosing a step on an outer surface of at least one lead);
`
`Ex. 1005 (Koung) ¶ 33, Figs. 2A-2B (disclosing a step on a bottom surface of at
`
`least one lead); Ex. 1006 (Park ’486), Figs. 11-13 (disclosing a step on an outer
`
`surface of at least one lead); Ex. 1009 (Suenaga) ¶ 45, Fig. 12 (disclosing a step on
`
`a bottom surface or outer surface of at least one lead). Furthermore, it was well-
`
`known in the art to use a lead having two or more different levels. E.g., Ex. 1004
`
`(Park ’697), Fig. 1b (disclosing that each of the leads comprising two or more
`
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`13
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`VIZIO Ex. 1003 Page 0016
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`different levels); Ex. 1005 (Koung) ¶ 20, Figs. 2a (disclosing that the leads each
`
`have two or more different levels); Ex. 1008 (Oshio) ¶ 52, Figs. 1, 4 (disclosing
`
`that the leads 20 and 30 each have two or more different levels); Ex. 1009
`
`(Suenaga) ¶ 45, Fig. 12 (disclosing that the leads each have two or more different
`
`levels).
`
`31. And it was well-known in the art before the claimed priority date to
`
`provide a light emitting element in a concave portion of the resin package. E.g.,
`
`Ex. 1004 (Park ’697) ¶¶ 12-13, Figs. 1a-c, 2a-b, 3a-c, 4a-c (disclosing providing a
`
`“light-emitting diode chip” in a concave portion of the resin package); Ex. 1005
`
`(Koung) ¶ 18, Fig. 2a (disclosing providing an “LED chip” in a concave portion of
`
`the resin package); Ex. 1006 (Park ’486), 12:16-13:10, Fig. 10 (disclosing
`
`providing an “LED chip” in a concave portion of the resin package); Ex. 1007
`
`(Urasaki) ¶ 11 (disclosing providing “an optical semiconductor element” in a
`
`concave portion of the resin package); Ex. 1008 (Oshio) ¶¶ 61-63, Figs. 1-2
`
`(disclosing providing an “LED chip” in a concave portion of the resin package).
`
`32. Finally, it was also well-known in the art before the claimed priority
`
`date to dispose a portion of the resin part over a portion of the plating on the upper
`
`surface of the at least one lead. E.g., Ex. 1004 (Park ’697) ¶¶ 1, 12, Figs. 1a-c
`
`(disclosing that a portion of the resin part is disposed over a portion of the upper
`
`surface of the at least one lead); Ex. 1005 (Koung) ¶¶ 26, 20, 21, Figs. 2a, 2d
`
`
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`14
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`VIZIO Ex. 1003 Page 0017
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`
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`(disclosing that a portion of the resin part is disposed over a portion of the upper
`
`surface of the at least one lead); Ex. 1008 (Oshio) ¶¶ 49, 69, Figs. 1-4, 11-14
`
`(disclosing that a portion of the resin part is disposed over a portion of the upper
`
`surface of the at least one lead).
`
`VI. ANALYSIS OF THE ’250 PATENT
`A. Overview of the ’250 Patent
`33. The ’250 patent, entitled “[l]ight emitting device, resin package, resin-
`
`molded body, and methods for manufacturing light emitting device, resin package
`
`and
`
`resin-molded body”
`
`relates
`
`to semiconductor
`
`technology,
`
`including
`
`manufacturing and packaging processes for light emitting devices. E.g., Ex. 1001
`
`(’250 patent), 1:17-35. The ’250 patent states such light emitting devices are used
`
`for, e.g., “light equipment, a display, a backlight of a mobile telephone, a movie
`
`lighting auxiliary light source, and other general consumer light sources.” Id.
`
`The ’250 patent states “[a] light emitting device using light emitting elements is
`
`small, provides good power efficiency, and emits light of bright color.” Id., 1:25-
`
`27. The ’250 patent further states it is an object to “provide a simple and low-cost
`
`method for manufacturing, in a short time, multiple light emitting devices which
`
`has high adhesion between a lead frame and a thermosetting resin composition.”
`
`Id., 2:49-53.
`
`34. The ’250 patent states “[t]he method comprises: a step of sandwiching
`
`
`
`15
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`VIZIO Ex. 1003 Page 0018
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`a lead frame provided with a notch part, by means of an upper mold and a lower
`
`mold; a step of transfer-molding a thermosetting resin containing a light reflecting
`
`material in a mold sandwiched by the upper mold and the lower mold to form a
`
`resin-molded body in the lead frame; and a step of cutting the resin-molded body
`
`and the lead frame along the notch part.” Ex. 1001 (’250 patent), 3:1-9; see also,
`
`e.g., id., Abstract, 2:63-3:9, 4:25-36, 11:5-14.
`
`35. The ’250 patent describes that a lead frame (shown in blue) can be
`
`made from “a metal plate of a flat plate shape” or “a metal plate in which
`
`differences in level or concavity and convexity are provided.” Ex. 1001 (’250
`
`patent), 8:46-48, Fig. 7. The ’250 patent discloses that the lead may include a step.
`
`Id., 4:18-20, 13:7-11, 14:37-45, 14:64-15:2, 15:36-45, 16:8-16, 16:46-50, Figs. 6,
`
`9-13. The ’250 patent further describes that the lead frame can be formed by
`
`“punching or etching.” Id., 8:49-9:6. In addition, before the transfer-molding step,
`
`“metal plating using silver, aluminum, copper, gold or the like can be applied to
`
`the lead frame.” Id., 9:22-28; see also, e.g., id., 3:21-28, 11:62-67, 8:10-11, 17:36-
`
`18:22. The ’250 patent further states “plating processing is applied to the outer
`
`bottom surface 20a of the resin package 20 and the inner bottom surface 27a of the
`
`concave part 27.” Id., 17:38-40. The ’250 patent further discloses that the lead
`
`frame includes “notch parts” (shown in red) that provide “positive and negative
`
`leads…when the resin-molded body is singulated.” Id., 9:7-11; see also, e.g., id.,
`
`
`
`16
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`VIZIO Ex. 1003 Page 0019
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`

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`
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`12:46-57, 9:9-20, Figs. 5, 7, 10. In addition, the “notch parts” reduce “the area for
`
`cutting the leads…when the resin-molded body is cut.” Id., 9:9-11; see also, e.g.,
`
`id., 12:46-57. “[T]he notch parts…penetrate the lead frame.” Id., 3:38-39.
`
`The ’250 patent further states “the notch parts are preferably formed vertically and
`
`horizontally or linearly in an oblique direction.” Id., 9:11-20.
`
`Ex. 1001 (’250 patent), Fig. 7.
`
`
`
`36. The ’250 patent further discloses “sandwiching the lead frame 21
`
`provided with the notch parts 21a by means of an upper mold 61 and a lower mold
`
`62” (lead frame is shown in blue and molds are shown in purple). Ex. 1001 (’250
`
`patent), 11:6-8, Fig. 4; see also, e.g., id., Abstract, 3:1-9, 4:25-36, 11:5-14, 12:7-20.
`
`The ’250 patent next discloses “transfer-molding a thermosetting resin 23
`
`containing the light reflecting material 26…to form a resin-molded body 24 in the
`17
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`VIZIO Ex. 1003 Page 0020
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`

`

`
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`
`
`
`
`
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`
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`lead frame 21” (resin-molded body is shown in green). Id., 11:8-12, Fig. 4; see
`
`also, e.g., id., Abstract, 3:1-9, 4:25-36, 11:5-14, 12:7-20. The ’250 patent
`
`describes that the thermosetting resin contains a light reflecting material that
`
`includes “titanium dioxide”/“titanium oxide.” Id., 8:15-23, 17:29-30. The ’250
`
`patent also describes that concave parts of the resin-molded body are formed by
`
`convex parts of the upper mold. Id., 5:7-9, Figs. 4, 5. The ’250 patent discloses
`
`that each “resin package forms a concave part having an inner bottom surface and
`
`an inner side surface.” Id., 7:60-61. As shown in orange below, a “light emitting
`
`element 10 is placed on the lead frame 21 of the inner bottom surface 27a of the
`
`concave part 27.” Id., 12:27-29.
`
`
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`18
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`VIZIO Ex. 1003 Page 0021
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`Ex. 1001 (’250 patent), Fig. 4.
`
`
`
`37. After the transfer-molding step, the ’250 patent states that “the resin-
`
`molded body 24 and lead frame 21 are cut along the notch parts 21a” (shown in red)
`
`to singulate the resin-molded body (shown in green) and lead frame (shown in blue)
`
`into individual packages. Ex. 1001 (’250 patent), 12:40-46; see also, e.g., id.,
`
`Abstract, 2:63-3:9, 4:25-36, 11:5-14, 12:40-49, Figs. 5-7, 10. The ’250 patent
`
`discloses that through the cutting step, “the resin-molded body 24 and lead frame
`
`21 are in the substantially same plane.” Id., 12:47-49, 7:49-52. The notch parts
`
`provide for improved adhesion “between the lead frame 21 and resin-molded body
`
`
`
`19
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`VIZIO Ex. 1003 Page 0022
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`24” and can “prevent the lead frame 21 and resin-molded body 24 from being
`
`detached.” Id., 12:51-57; see also, e.g., id., 3:8-12. The ’250 patent also discloses
`
`that because the lead frame is plated before cutting, “plating processing is not
`
`applied to the cut parts of the leads.” Id., 17:47-18:22; see also, e.g., id., 17:36-42,
`
`3:21-28.
`
`Ex. 1001 (’250 patent), Fig. 6.
`
`38.
`
`I have considered the Challenged Claims (claims 1, 7, 17, 19, and 21)
`
`
`
`of the ’250 patent, which read as follows:
`
`1.[pre] A method of manufacturing a light emitting device, the
`method comprising:
`[1.A] providing a lead frame comprising at least one notch;
`[1.B] plating the lead frame;
`[1.C

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