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Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 1 of 18 Page ID #:192

EXHIBIT J
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 2 of 18 Page ID #:193

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

Patent: 10,217,916 (“’916 patent”)


Title: Transparent light emitting diodes
Inventors: Shuji Nakamura, Steven P. DenBaars, Hirokuni Asamizu
Description: Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-
pack, Model CAD4W22G-2P (Walmart # 555602838)

SUMMARY

The below analysis of a Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)
purchased from Walmart demonstrates that this product, and all other products that include filament LEDs not more than colorably different
from the filament LEDs in this product, infringe at least claim 1 of the ‘916 patent under 35 U.S.C. § 271(a) and at least claim 14 of the ‘916
patent under 35 U.S.C. § 271(g).

Optical and x-ray images of one extracted filament LED are provided. A portion of the filament LED was cut and potted in epoxy mount. It was
mechanically polished and analyzed by SEM-EDS technique.

X-ray Imaging
Acquired on Nordson DAGE Quadra 7 X-ray system

SEM Imaging and SEM-EDS Spectroscopy


The sample was potted in a typical epoxy mount and cured overnight. It was polished mechanically to expose the relevant structures in cross-
section. The sample was sputter coated with a thin layer of Ir (a few nms thick) to reduce charging under electron beam during SEM
observations and SEM-EDS analysis. SEM images were acquired in Secondary Electron (SE) and Back Scatter Electron (BSE) mode on a FEI
Quanta FEG-SEM. Energy Dispersive X-ray spectra (EDS) were acquired from several regions of interest to identify the matrix level elemental
constituents. This analysis was performed using Oxford Instruments X-Max system running INCA software and installed on the SEM above.

Page 1
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 3 of 18 Page ID #:194

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


Claim 1
1. A light emitting device, The Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838) is
comprising: a light emitting device.

Page 2
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 4 of 18 Page ID #:195

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


a lead frame having a The Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)
transparent plate therein; includes a filament LED with a lead frame having a transparent plate therein.

Lead frame having a


transparent plate therein

Lead frame

X-ray side view X-ray side view

Lead frame having a Transparent plate


transparent plate therein

X-ray top view X-ray top view

Page 3
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 5 of 18 Page ID #:196

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


and a light emitting diode The below SEM image at 40x magnification shows a view of an LED chip mounted on the lead frame and placed on
(LED) chip, mounted on the or above the transparent plate in the lead frame. In operation, but not shown in this image, the LED chip emits light
lead frame and placed on or through at least front and back sides of the LED chip.
above the transparent plate
in the lead frame, emitting
light through at least front
and back sides of the LED
LED chip
chip;
Lead frame

Transparent plate

Page 4
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 6 of 18 Page ID #:197

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


Below are images of a filament LED taken from the Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack,
Model CAD4W22G-2P (Walmart # 555602838) product and turned on to show LED chips emitting light through at
least front and back sides of the LED chips.

Light Emitting From Front Side Light Emitting From Back Side

Page 5
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 7 of 18 Page ID #:198

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


The below SEM image at 100x magnification shows an additional view of an LED chip mounted on the lead frame
and placed on or above the transparent plate in the lead frame.

Lead frame
LED chip

Transparent plate

Page 6
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 8 of 18 Page ID #:199

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


The below SEM image at 500x magnification shows an additional view of an LED chip mounted on the lead frame
and placed on or above the transparent plate in the lead frame.

LED chip

Transparent plate

Page 7
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 9 of 18 Page ID #:200

‘916 PATENT INFRINGEMENT CLAIM CHART


Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


wherein the transparent The transparent plate in the lead frame is sapphire that allows the light emitted from the LED chip to be extracted
plate in the lead frame out of the LED chip from the front or back sides of the LED chip and through the transparent plate in the lead frame.
allows the light emitted Spectrum 3 (right panel) shows the elemental constituents of the transparent plate in the lead frame (left panel) as
from the LED chip to be obtained from SEM-EDS analysis. As shown in Spectrum 3 (right panel), the elements Aluminum (Al) and Oxygen (O)
extracted out of the LED are present in the transparent plate (left panel), which is consistent with the transparent plate comprising sapphire
chip from the front or back (Al2O3).
sides of the LED chip and
through the transparent
plate in the lead frame.
LED chip

Transparent plate

Page 8
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 10 of 18 Page ID
#:201
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


Below are images of a filament LED taken from the Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack,
Model CAD4W22G-2P (Walmart # 555602838) product and turned on to show LED chips emitting light through at
least front and back sides of the LED chips, wherein the transparent plate in the lead frame allows the light emitted
from the LED chips to be extracted out of the LED chips from the front or back sides of the LED chips and through
the transparent plate in the lead frame.

Lead frame having a transparent plate therein

Filament LED

Light Extracted From Front Side Light Extracted From Back Side

Page 9
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 11 of 18 Page ID
#:202
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


Claim 14
14. A method for The Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838) is
fabricating a light emitting a light emitting device made by the claimed method.
device, comprising:

Page 10
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 12 of 18 Page ID
#:203
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


providing a lead frame The Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838) is
having a transparent plate made by a method that includes providing a lead frame having a transparent plate therein.
therein;

Lead frame having a


transparent plate therein

Lead frame

X-ray side view X-ray side view

Lead frame having a Transparent plate


transparent plate therein

X-ray top view X-ray top view

Page 11
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 13 of 18 Page ID
#:204
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


and mounting a light The Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838) is
emitting diode (LED) chip made by a method that includes mounting a light emitting diode (LED) chip on the lead frame, wherein the LED is
on the lead frame, wherein placed on or above the transparent plate in the lead frame. The below SEM image at 40x magnification shows a
the LED is placed on or view of an LED chip mounted on the lead frame and placed on or above the transparent plate in the lead frame. In
above the transparent plate operation, but not shown in this image, the LED chip emits light through at least front and back sides of the LED
in the lead frame; wherein chip.
light is emitted through at
least front and back sides of
the LED chip;
LED chip
Lead frame

Transparent plate

Page 12
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 14 of 18 Page ID
#:205
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


Below are images of a filament LED taken from the Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack,
Model CAD4W22G-2P (Walmart # 555602838) product and turned on to show LED chips emitting light through at
least front and back sides of the LED chips.

Light Emitting From Front Side Light Emitting From Back Side

Page 13
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 15 of 18 Page ID
#:206
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


The below SEM image at 100x magnification shows an additional view of an LED chip mounted on the lead frame
and placed on or above the transparent plate in the lead frame.

Lead frame
LED chip

Transparent plate

Page 14
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 16 of 18 Page ID
#:207
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


The below SEM image at 500x magnification shows an additional view of an LED chip mounted on the lead frame
and placed on or above the transparent plate in the lead frame.

LED chip

Transparent plate

Page 15
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 17 of 18 Page ID
#:208
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


and wherein the The transparent plate in the lead frame is sapphire that allows the light emitted from the LED chip to be extracted
transparent plate in the out of the LED chip from the front or back sides of the LED chip and through the transparent plate in the lead frame.
lead frame allows the light Spectrum 3 (right panel) shows the elemental constituents of the transparent plate in the lead frame (left panel) as
emitted from the LED chip obtained from SEM-EDS analysis. As shown in Spectrum 3 (right panel), the elements Aluminum (Al) and Oxygen (O)
to be extracted out of the are present in the transparent plate (left panel), which is consistent with the transparent plate comprising sapphire
LED chip from the front or (Al2O3).
back sides of the LED chip
and through the
transparent plate in the
lead frame. LED chip

Transparent plate

Page 16
Case 2:19-cv-06570-PSG-RAO Document 1-10 Filed 07/30/19 Page 18 of 18 Page ID
#:209
‘916 PATENT INFRINGEMENT CLAIM CHART
Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack, Model CAD4W22G-2P (Walmart # 555602838)

‘916 Patent Claims Corresponding Product Features


Below are images of a filament LED taken from the Great Value LED Deco Vintage Edison Light Bulb 4 Watt 2-pack,
Model CAD4W22G-2P (Walmart # 555602838) product and turned on to show LED chips emitting light through at
least front and back sides of the LED chips, wherein the transparent plate in the lead frame allows the light emitted
from the LED chips to be extracted out of the LED chips from the front or back sides of the LED chips and through
the transparent plate in the lead frame.
Lead frame having a transparent plate therein

Filament LED

Light Extracted From Front Side Light Extracted From Back Side

Page 17

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