IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) SEOUL SEMICONDUCTOR CO., LTD.; ) and SEOUL VIOSYS CO., LTD., ) 1:24-cv-579 ) Plaintiffs, ) ) v. ) ) TECHNICAL CONSUMER PRODUCTS, ) INC., ) ) Defendant. ) MEMORANDUM ORDER This patent-infringement case concerns patents involving LED technology. The parties have briefed a number of disputes regarding claim construction; and the Court held a Hearing on December 4, 2025, to hear argument on six of the more significant disputed terms.1 After careful consideration of the parties’ briefs, the patents, the intrinsic evidence, and any specific extrinsic evidence that is noted in this order, the Court resolves the disputes, as follows: Dispute No. 1 Disputed The Court’s Seoul’s Proposal TCP’s Proposal term Construction “low-doped Plain and ordinary Plain and Indefinite;2 layer” meaning; ordinary

meaning Alternatively: Alternatively:

1 In a joint letter to the Court, the parties grouped the disputes for the hearing into seven different terms. ECF 125. It’s more accurate to say “six disputes,” as several of the disputes involve multiple related terms.

2 This is not intended to be a finding on the question of indefiniteness as to these ’800 Patent terms. Rather, TCP’s indefinite arguments are more suited for resolution on a developed record at summary judgment or trial. , No. CV 20-760 (MN),

, at *4 (D. Del. Sept. 29, 2021) (declining to rule on the indefinite issue and allowing defendant to re-raise the issue at summary judgment). ’800 Patent: • a semiconductor “a layer having a claims 1, 6, 7, layer containing a dopant 14, 17, 19, dopant wherein the concentration less dopant concentration than 1x1018/cm3” is less than a dopant concentration of the at least one intermediate doped layer (Claim 1) • a semiconductor layer containing a dopant wherein the dopant concentration is less than that of the doped layer (Claim 14) “intermediate Plain and ordinary Indefinite; Plain and doped layer” meaning; ordinary ’800 Patent: “a layer located meaning claims 1, 7, 8 “semiconductor layer between the first containing a dopant, which and second low is located between the first doped layers and and second low-doped having a dopant layers” concentration from 1×1018/cm3 to 1×1020/cm3” “doped layer” Plain and ordinary Indefinite; Plain and ’800 Patent: meaning; ordinary claims 14–17, “a layer having a meaning 19, 20 “a semiconductor layer dopant containing a dopant” concentration from 1×1018/cm3 to 1×1020/cm3” Dispute 2 Disputed The Court’s Seoul’s Proposal TCP’s Proposal term Construction “undercut a sidewall having a “sidewall(s) A sidewall sidewall” structure consistent with located inwardly having a ’967 Patent: material having been cut on the underside structure claims 17 & away from the underside so of an upper consistent 20 as to leave an overhanging overhanging with material portion in relief portion of a body” having been cut away from the underside so as to leave an overhanging portion in relief “fixing space” Plain and ordinary “opening An opening ’967 Patent: meaning for both patents; perforating and/or extending claims 17 & formed through a from the first 20; For the ’967 Patent: “a body in a vertical surface to the ’821 Patent: space that includes the direction (i.e., a second surface claims 1, 2, 5 area under the overhangs direction normal of the undercut sidewalls” to the surface of a light-emitting For the ’821 Patent: diode chip)” “outer fixing space”: “a space that includes the area under the overhang of the [inset sidewall]”

“inner fixing space”: “an opening extending from the first surface to the second surface” “fixing hole” Plain and ordinary “opening A fixing space ’967 Patent: meaning for both patents; perforating and/or that has a claims 17 & formed through a closed 20; For the ’967 Patent: “a hole body in a vertical boundary ’821 Patent: located in the interior direction (i.e., a claim 5 portion of a lead frame” direction normal to the surface of a For the ’821 Patent: “inner light emitting fixing space” diode chip) and surrounded by the body” The inventions here concern light emitting device designs meant to “enhance adhesive force between a lead frame and a molding unit.” Ex. 4 at 1:26-31. To increase the adhesive force, the designs focus on “forming a fixing space through the lead frame and integrally forming the molding unit on the top surface of the lead frame and in the fixing space.” But with this innovation has come limitations. Because of problems with the adhesive force between the molding unit and the lead frames, the LED and enclosed wires “may be damaged by being exposed to air or moisture.” Jd. at 1:59-62. The designs in the 967 Patent and the ’821 Patent seek to minimize moisture and air exposure to the wires and LED by improving the adhesive force. How is the adhesive force improved? By structurally designing the lead frames with various indents, holes, and spaces. The parties’ disputes here center on those different indents, holes, and spaces. Figure 1 & Figure 4 below detail two different embodiments of the 967 Patent.?

FIG 1

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3 Both the figures and specification in the 967 Patent and the ’821 Patent mirror each other with respect to the current dispute. The Court cites the "967 Patent for reference, but, to be clear, the Court is considering both patents in its analysis.

FIG 4

In Figure 1, the two lead frames (110 & 120) have fixing spaces on the sides of the frame (111 & 121). Jd. at 3:25-63. Within the fixing spaces are the fixing holes.

When the manufacturer places the molding unit on top of the frames, the molding resin fills in the fixing spaces and fixing holes, creating a secured adhesive on the top of the lead frames. Jd. Figure 4 details much the same as Figure 1, but describes another exemplary embodiment of the 967 patent. In Figure 4, the design is still focused on preventing the molding unit from separating from the lead frame. J/d. at 4:39-67. Just here, the fixing spaces are modified and include inner fixing holes, too (115 & 125). Jd. Based on the above, the Court makes the following three rulings. First, in construing the term “undercut sidewall,” the Court agrees with Seoul and will adopt its interpretation of the term. In doing so, the Court also agrees with

the Patent Trial and Appeal Board’s express definition when it considered the same term. , No. IPR2020-00410,

, at *5–6 (P.T.A.B. July 21, 2021). The Court finds that the Board’s definition accurately reflects the invention and is consistent with the description in the ’967 Patent. Second, in construing the terms “fixing space” and “fixing hole,” the Court finds that its construction best captures the purpose and meaning of the terms in both patents. The Court agrees with TCP that construing the terms “inner” and “outer” in the ’821 Patent as they relate to the fixing spaces and fixing holes is unnecessary. ECF 122 at 53. “Inner” and “outer” are relative to where the spaces or holes are on the lead frames and a jury can understand based on context what either descriptor means. Thus, the Court’s construction applies only to the terms “fixing space” and “fixing hole,” as TCP suggests. Third, in reaching its construction, the Court finds that neither parties’ proposal best captures the terms’ meaning in both patents. As noted in both figures, the location and shape of either a fixing space or hole may change depending on the embodiment. Ex. 4 at 4:39-67. What remains constant among all embodiments in both patents is that where a fixing space does not have a defined boundary on all sides, a fixing hole does. The Court finds that its construction of both terms accurately captures the meaning of both terms, consistent with the intrinsic evidence.4

4 If the parties wish to wordsmith “closed boundary” and have a better and clearer phrase, the Court is open to considering such an alternative. Dispute 3 Disputed The Court’s Seoul’s Proposal TCP’s Proposal term Construction “a plurality of Plain and ordinary “a plurality of Plain and thick film meaning; layers having a ordinary layers” thickness between meaning ’496 Patent: 1.5 nm and 3 nm” “semiconductor layers each claims 1 & 11 having a thickness greater than the thin film layers” “a plurality of Plain and ordinary “a plurality of Plain and thin film meaning; layers having a ordinary layers” thickness less meaning ’496 Patent: “semiconductor layers each than 1.5 nm” claims 1 & 11 having thickness not more than a thickness of the thick film layers” Dispute 4 Disputed The Court’s Seoul’s Proposal TCP’s Proposal term Construction “a second Plain and ordinary “a second light a second light light emitter meaning; emitter comprising emitter comprising at at least one comprising at least one light infrared ray least one “a structure including at emitting emitter” infrared ray least one light emitting structure” emitter device” ’836 Patent: claim 1 The ’836 Patent is a design for LED products to better mirror the effects of the sun. Ex. 1 at 1:24-48. To do so, the design seeks to “output light having a spectrum similar to that of the sunlight.” The sun emits a wide range of light; some visible, some not. According to one of the ’836 Patent’s exemplary embodiments, so too would the product. The embodiment would include “a first light emitter configured to emit visible light and . . . a plurality of light sources having color temperatures different from each other” and also “a second light emitter configured to emit infrared rays.” at 1:59-2:2. The device would also be designed to “disable the second light emitter” if enough infrared rays were already detected in the area. at 2:3-6. The dispute between the parties is whether the phrase “light emitting structure” is restricted to infrared rays. Seoul argues no; TCP argues yes. The Court agrees with TCP and construes the term to be limited to an infrared ray emitter. Defining the “light emitting structure” here to infrared rays is consistent with the intrinsic evidence. As TCP noted during the hearing, every embodiment within the ’836 Patent shows an emitter with visible light and an emitter with infrared rays. And that makes sense, given the stated purpose of the ’836 Patent is to “output light having a spectrum similar to that of the sunlight.” at 1:24-48. Dispute 5 Disputed The Court’s Seoul’s Proposal TCP’s Proposal term Construction “the molding “the molding part is made “the molding part the molding part is made of one or more of silicone, is made of part is made of of materials epoxy, materials one or more of including at polymethylmethacrylate, including at least silicone, epoxy, least one of polyethylene and one silicone epoxy, polymethylmet silicone, polystyrene” at least one hacrylate, epoxy polymethylmethac polyethylene polymethylme rylate (PMMA), at and thacrylate least one polystyrene (PMMA), polyethylene (PE) polyethylene and at least one (PE) and polystyrene (PS)” polystyrene (PS)” ’933 Patent: claim 15 The dispute here comes down to whether the term at issue is conjunctive or disjunctive. The Court agrees with Seoul and construes the term to be disjunctive. First, the Court relies on the evidence in the specification where the ’933 Patent clarifies that any grouping consisting of terms “X, Y, and Z” can mean “any and all combinations of one or more” of those terms. Ex. 2 at 4:27-34. Second, the Court relies on Seoul’s expert, where he found that a POSITA would understand the molding part would only have to have “at least one of the materials” cited. Ex. 22 at ¶ 53. Dispute 6 Disputed The Court’s Seoul’s Proposal TCP’s Proposal term Construction “groove” Plain and ordinary “opening formed in opening ’050 Patent: meaning; a surface of an formed on a claims 1, 2, & object that reduces lead frame 12 the thickness of that reduces “a set of long narrow the object within the thickness channels or depressions the opening” within the formed on a lead frame opening each having a triangular cross-section and filled with resin” “sub-groove” Plain and ordinary “opening(s) formed type of groove ’050 Patent: meaning; within a groove claims 1, 2, & formed in a 12 “a set of long narrow surface of an channels or depressions object that formed on a lead frame reduce(s) the each having a triangular thickness of the cross-section and filled with object within the resin” opening(s)” The ’050 Patent is a design patent that aims to both slim down the LED package while either improving or keeping the same the luminescence efficiency. Ex. 3 at 1:17-21. To reduce the thickness without hurting the lighting efficiency, the invention “allow[s] a transparent encapsulation material to directly support a lead frame without a housing.” at 1:66-2:4. This general design reduces the overall thickness while also exhibiting “good heat dissipation performance.” The dispute here concerns the word “groove,” both as a term on its own and as a separate term, “sub-groove.” Figure 2 and Figure 8(b) below depict the terms, where 122 and 142 are “grooves” and 122’ and 142’ are “grooves” made up of “a plurality of sub-grooves.” Jd. at 4:47-50.

Fig. 2

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10

Consistent with the intrinsic record, the Court finds that the term “groove” must have a broader definition than “a set of long narrow channels,” as Seoul suggests. ECF 122 at 39. The Court’s construction captures the central function of a groove—to act as an opening and ultimately reduce the overall thickness of the package. Ex. 3 at 1:17-21. Both Figure 2 and Figure 8(b) depict openings, just different types, which the Court’s construction recognizes. As for “sub-groove,” the Court finds that the prefix “sub” modifies the meaning of groove to indicate that this is a secondary class of groove, or type of groove. , (10th ed. 1997). Thus, in the context of claim 1, the ’050 Patent reads: “the groove comprises a plurality of sub-grooves, each [ ] having a triangular cross-section.” Ex. 3 at 7:10-11 (Court’s construction added). Because the claim itself goes on to describe the sub-grooves as having “a triangular cross-section,” it is unnecessary to further define sub-groove. The intrinsic record, as well as the claim itself, provide enough clarity for a jury to determine precisely what a sub-groove is with this construction. Agreed-upon Terms The parties also agreed upon construction of a number of claim terms, and the Court will adopt those constructions. ECF 122 at 7–8. The terms and constructions are as follows. Patent Term Construction ’800 “wherein the dopant concentration of the dopant concentration Patent: the first low-doped layer decreases within the first low-doped claim 1 with increasing distance from the layer begins at a local high intermediate doped layer and then at the intermediate doped increases with decreasing distance to layer, falls to a low, and the p-type contact layer” then increases to a local high at the p-type contact layer ’800 “the second low-doped layers include a the hole concentration Patent: hole concentration decreasing with within the second low- claim 14 increasing distance from the active doped layer begins at a local layer and then increasing with high at the active layer, decreasing distance to the doped falls to a low, and then layer” increases to a local high at the doped layer ’821 “the resin” “the resin” in claim 2 refers Patent: back to the recitation “a claims 2 & resin portion” as recited in 5 claim 1;

“the resin” in claim 5 refers back to the recitation “a resin portion” as previously recited in claim 5 ’496 “functional part” a plurality of active layers Patent: stacked in a direction from claim 1 the n-type semiconductor layer toward the p-type semiconductor layer ’675 “a thickness of the second converter is the second converter is at Patent: in a range of 0.07 mm to 1.5 mm” least 0.07 millimeters thick claims 1, and no more than 1.5 17, 18 millimeters thick ’675 “wherein a thickness of the second the second converter is at Patent: converter is in a range of 100 um to least 100 microns thick and claim 6 1000 um” no more than 1000 microns thick ’675 “wherein the light emission spectrum the first plurality of Patent: of the phosphors of the first converter phosphors each have an claims 8, includes at least one wavelength emission spectrum, and 16, 20 region where a portion of each light those emission spectra emission spectrum overlaps another overlap light emission spectrum” ’675 Patent “half-value width” full width at half maximum

’314 “wherein the second extension extend the second extension Patent: toward the first electrode pad and has extends [from the second claim 5 a curved shape near the first electrode electrode pad] in the pad” direction of [the first electrode pad] and curves near the end ’314 “in contact with” touching Patent: claims 1 and 5 ’967 “a first undercut sidewall, a second the first and second lead Patent: undercut sidewall, and a third frames each have at least claims 17 undercut sidewall that at least three [undercut sidewalls] and 20 partially define a fixing space and having overhangs, with the interior portions of the first and spaces under the overhangs second lead frames, the fixing space being a [fixing space] and being formed by the undercut the region of the lead sidewalls of the first lead frame and frames inward from fixing the second lead frame” space being interior portions ’967 “each fixing hole . . . includes an the shape of the interior Patent: undercut sidewall that envelopes volume within each fixing claims 17 inner bounds of the fixing hole” hole includes an undercut and 20

’821 at least one of the sidewalls one or more of the sidewalls Patent: comprising an inset sidewall partially contain an overhang, with claims 1 defining an outer fixing space the space under the and 5 overhang being part of an [outer fixing space]

Remaining Disputes The disputed six terms addressed above were all the focus at the Hearing. In addition to these disputes, the parties also briefed six other disputes.5 After careful review of the briefing of those disputes, the Court sees no benefit to construing those terms at this juncture. Based on the nature of those disputes, including those that relate to the question of indefiniteness, the parties may raise them in the context of any summary-judgment motions. ,

, at *4.

5 Specifically: 1. “The light emitting diode of claim 6, wherein the electrode pad is arranged directly on an upper surface of the transparent electrode layer outside of the opening.” (

Claim 7) 2. “well layer” (

Claims 1, 4, 9, 13, and 18) 3. “less than or equal to about 40 nm”; “ranges from about 520 nm to 570 nm”; “ranges from about 600 nm to 670 nm” (

Claim 15) 4. “user interface member” (

Claim 1) 5. “wherein one of the plurality of portions of the first extension is disposed between the plurality of portions of the second extension” (

Claim 3) 6. “second semiconductor layer” (

Claims 1 and 5) SO ORDERED.

DATED this 22nd day of December, 2025. BY THE COURT:

/s/ United States District Judge