Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 1 of 22 Page ID #:2570
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page1of22 Page ID #:2570
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`EXHIBIT 6
`EXHIBIT 6
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page1of22 Page ID #:2570
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`EXHIBIT 6
`EXHIBIT 6
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 2 of 22 Page ID #:2571
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`EXHIBIT D-1
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`Claims 1, 5-8, 10 and 12 of U.S. Patent No. 9,929,314
`
`Preliminary Infringement Contentions
`
`FEIT Electric Co., Inc., (hereinafter “FEIT”) directly infringes the ’314 patent, either literally or under the doctrine of equivalents, pursuant
`to 35 U.S.C. § 271(a). Upon information and belief, FEIT uses, offers to sell, or sells the ’314 Infringing Products within the United States
`or imports them into the United States at least by without authority, in a manner that constitutes infringement of one or more claims of
`the ’314 patent. Upon information and belief, FEIT has infringed and continues to infringe one or more claims of the ’314 Patent, including
`but not limited to claims 1, 5-8, 10 and 12, pursuant to 35 U.S.C. § 271(a) at least by without authority making, using, offering to sell,
`and/or selling the ’314 Infringing Products within the United States or importing the ’314 Infringing Products into the United States.
`
`The ’314 Infringing Products include but are not limited to the FEIT T48/840/LED/2, all other charted products, and all products having
`substantially similar structure and/or operation with respect to infringement, which include but are not limited to products having the same
`or substantially similar components and/or structures as those identified to demonstrate infringement. Such products may include, but are
`not limited to products having the same or similar LEDs as those identified to demonstrate infringement.
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`1
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 3 of 22 Page ID #:2572
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`’314 Patent Claim
`
`FEIT Product: T48/840/LED/2
`
`1[pre]. A light emitting
`diode (LED) device
`comprising:
`
`FEIT imports into the United States, or sells, offers to sell, or uses within the United States, the FEIT
`T48/840/LED/2 LED lighting device, which incorporates a plurality of light emitting diodes(“LEDs”). This
`is shown by the photographs and microscope images below.
`
`
`
`2
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 4 of 22 Page ID #:2573
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`FEIT Product: T48/840/LED/2
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a substrate and a light emitting
`structure disposed over the substrate and including a first semiconductor layer, a second semiconductor
`layer, and an active layer disposed between the first semiconductor layer and the second semiconductor
`layer as shown in the Scanning Electron Microscope (“SEM”) images below. The first image is the top
`surface of an LED from the FEIT T48/840/LED/2 LED lighting device. The second image shows a hole in
`the LED created using a Focused Ion Beam (“FIB”). And the third image provides a cross-sectional view of
`the hole. As the third FIB-SEM image shows, the LED includes in relevant parts from bottom to top, a
`substrate, a first semiconductor layer, an active layer, and a second semiconductor layer.
`
`’314 Patent Claim
`
`1[a]. a substrate;
`a light emitting
`structure disposed over
`the substrate and
`including a first
`semiconductor layer, a
`second semiconductor
`layer, and an active
`layer disposed between
`the first semiconductor
`layer and the second
`semiconductor layer;
`
`
`
`3
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 5 of 22 Page ID #:2574
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`’314 Patent Claim
`
`1[b]. a first electrode
`pad disposed over the
`first semiconductor
`layer;
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a first electrode pad disposed over the
`first semiconductor layer as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`
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`4
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 6 of 22 Page ID #:2575
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`’314 Patent Claim
`
`1[c]. a transparent
`electrode layer disposed
`over the second
`semiconductor layer;
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a transparent electrode layer disposed
`over the second semiconductor layer as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`
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`5
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`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 7 of 22 Page ID #:2576
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`’314 Patent Claim
`
`1[d]. a second electrode
`pad disposed over the
`transparent electrode
`layer;
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a second electrode pad disposed over
`the transparent electrode layer as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`
`
`6
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`
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`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 8 of 22 Page ID #:2577
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`’314 Patent Claim
`
`1[e]. a first extension
`extending from the first
`electrode pad; and
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a first extension extending from the
`first electrode pad as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`1[f]. a second extension
`extending from the
`second electrode pad,
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a second extension extending from the
`second electrode pad as shown in the SEM images below.
`
`
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`7
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 9 of 22 Page ID #:2578
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`FEIT Product: T48/840/LED/2
`
`As discussed above, the LED of the FEIT T48/840/LED/2 LED lighting device includes a first extension.
`As shown in the SEM images below, the first extension includes first portions in contact with the first
`semiconductor layer and second portions not in contact with the first semiconductor layer.
`
`’314 Patent Claim
`
`1[g]. wherein the first
`extension includes first
`portions in contact with
`the first semiconductor
`layer and second
`portions not in contact
`with the first
`semiconductor layer,
`
`
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`8
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`
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`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 10 of 22 Page ID
`#:2579
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`’314 Patent Claim
`
`1[h]. wherein one of the
`first portions and one of
`the second portions are
`alternately disposed
`along the first
`extension, and
`
`FEIT Product: T48/840/LED/2
`
`As discussed above, the LED of the FEIT T48/840/LED/2 LED lighting device includes first portions and
`second portions. As shown in the Microscope and SEM images below, one of the first portions and one of
`the second portions are alternately disposed along the first extension.
`
`As discussed above, the LED of the FEIT T48/840/LED/2 LED lighting device includes a second extension.
`As shown in the SEM images below, the second extension includes a plurality of portions extending from
`the second electrode pad.
`
`
`
`1[i]. wherein the second
`extension includes a
`plurality of portions
`extending from the
`second electrode pad.
`
`
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`9
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`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 11 of 22 Page ID
`#:2580
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`’314 Patent Claim
`
`FEIT Product: T48/840/LED/2
`
`5[pre]. A light emitting
`diode (LED) device
`comprising:
`
`FEIT imports into the United States, or sells, offers to sell, or uses within the United States, the FEIT
`T48/840/LED/2 LED lighting device, which incorporate a plurality of light emitting diodes. This is shown
`by the photographs and microscope images below.
`
`
`
`10
`
`
`
`
`
`CONFIDENTIAL
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 12 of 22 Page ID
`#:2581
`
`FEIT Product: T48/840/LED/2
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a substrate and a light emitting
`structure disposed over the substrate and including a first semiconductor layer, a second semiconductor
`layer, and an active layer disposed between the first semiconductor layer and the second semiconductor
`layer as shown in the SEM images below. The first image is the top surface of an LED from the FEIT
`T48/840/LED/2 LED lighting device. The second image shows a hole in the LED created using FIB. And
`the third image provides a cross-sectional view of the hole. As the third FIB-SEM image shows, the LED
`includes in relevant parts from bottom to top, a substrate, a first semiconductor layer, an active layer, and a
`second semiconductor layer.
`
`’314 Patent Claim
`
`5[a]. a substrate;
`a light emitting
`structure disposed over
`the substrate and
`including a first
`semiconductor layer, a
`second semiconductor
`layer, and an active
`layer disposed between
`the first semiconductor
`layer and the second
`semiconductor layer;
`
`
`
`11
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`
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`
`
`CONFIDENTIAL
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 13 of 22 Page ID
`#:2582
`
`’314 Patent Claim
`
`5[b]. a first electrode
`pad disposed over the
`first semiconductor
`layer;
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a first electrode pad disposed over the
`first semiconductor layer as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`
`
`12
`
`
`
`
`
`CONFIDENTIAL
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 14 of 22 Page ID
`#:2583
`
`’314 Patent Claim
`
`5[c]. a transparent
`electrode layer disposed
`over the second
`semiconductor layer;
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a transparent electrode layer disposed
`over the second semiconductor layer as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`
`
`13
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`
`
`
`
`CONFIDENTIAL
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 15 of 22 Page ID
`#:2584
`
`’314 Patent Claim
`
`5[d]. a second electrode
`pad disposed over the
`transparent electrode
`layer;
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a second electrode pad disposed over
`the transparent electrode layer as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`
`
`14
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`
`
`
`
`CONFIDENTIAL
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 16 of 22 Page ID
`#:2585
`
`’314 Patent Claim
`
`5[e]. a first extension
`extending from the first
`electrode pad; and
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a first extension extending from the
`first electrode pad as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`5[f]. a second extension
`extending from the
`second electrode pad,
`
`The LED of the FEIT T48/840/LED/2 LED lighting device includes a second extension extending from the
`second electrode pad as shown in the SEM images below.
`
`
`
`
`
`15
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`
`
`
`
`CONFIDENTIAL
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 17 of 22 Page ID
`#:2586
`
`FEIT Product: T48/840/LED/2
`
`As discussed above, the LED of the FEIT T48/840/LED/2 LED lighting device includes a first extension.
`As shown in the SEM images below, the first extension includes first portions in contact with the first
`semiconductor layer and second portions not in contact with the first semiconductor layer.
`
`’314 Patent Claim
`
`5[g]. wherein the first
`extension includes first
`portions in contact with
`the first semiconductor
`layer and second
`portions not in contact
`with the first
`semiconductor layer,
`
`
`
`16
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`
`
`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 18 of 22 Page ID
`#:2587
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`’314 Patent Claim
`
`5[h]. wherein one of the
`first portions and one of
`the second portions are
`alternately disposed
`along the first
`extension, and
`
`5[i]. wherein the second
`extension extend
`toward the first
`electrode pad and has a
`curved shape near the
`first electrode pad.
`
`
`
`
`
`FEIT Product: T48/840/LED/2
`
`As discussed above, the LED of the FEIT T48/840/LED/2 LED lighting device includes first portions and
`second portions. As shown in the Microscope and SEM images below, one of the first portions and one of
`the second portions are alternately disposed along the first extension.
`
`As discussed above, the LED of the FEIT T48/840/LED/2 LED lighting device includes a second extension.
`As shown in the Microscope and SEM image below, the second extension extend toward the first electrode
`pad and has a curved shape near the first electrode pad.
`
`
`
`
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`17
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`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 19 of 22 Page ID
`#:2588
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`The LED of the FEIT T48/840/LED/2 LED lighting device further includes a first functional layer disposed
`between the substrate and the first electrode pad as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`’314 Patent Claim
`
`6. The LED device of
`claim 1, further
`comprising:
`a first functional layer
`disposed between the
`substrate and the first
`electrode pad.
`
`
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`18
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`CONFIDENTIAL
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`
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 20 of 22 Page ID
`#:2589
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`The LED of the FEIT T48/840/LED/2 LED lighting device further includes a second functional layer
`disposed between the substrate and the second electrode pad as shown in the SEM images below.
`
`FEIT Product: T48/840/LED/2
`
`’314 Patent Claim
`
`7. The LED device of
`claim 6, further
`comprising;
`a second functional
`layer disposed between
`the substrate and the
`second electrode pad.
`
`
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`19
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 21 of 22 Page ID
`#:2590
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`’314 Patent Claim
`
`8. The LED device of
`claim 7, wherein the
`first functional layer
`or/and the second
`functional layer include
`insulation material.
`
`FEIT Product: T48/840/LED/2
`
`As discussed with respect to claim 7 above, the LED of the FEIT T48/840/LED/2 LED lighting device
`includes a first functional layer and a second functional layer. As shown in the SEM images below and
`supported byEnergy Dispersive X-ray (“EDX”), the first functional layer and the second functional layer
`include insulation material.
`
`
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`20
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`CONFIDENTIAL
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`Case 2:22-cv-05097-AB-SHK Document 86-7 Filed 06/02/23 Page 22 of 22 Page ID
`#:2591
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`’314 Patent Claim
`
`10. The LED device of
`claim 7, wherein the
`second functional layer
`is disposed below the
`transparent layer.
`
`12. The LED device of
`claim 1, wherein the
`transparent layer
`includes an indium tin
`oxide (ITO) or material
`oxide.
`
`
`
`
`
`FEIT Product: T48/840/LED/2
`
`As discussed with respect to claim 7 above, the LED of the FEIT T48/840/LED/2 LED lighting device
`includes a second functional layer. As shown in the SEM images below, the second functional layer is
`disposed below the transparent layer.
`
`As discussed with respect to claim 1 above, the LED of the FEIT T48/840/LED/2 LED lighting device
`includes a transparent layer. As shown in the SEM images below, the transparent layer includes an indium
`tin oxide (ITO).
`
`
`
`
`
`21
`
`CONFIDENTIAL
`
`
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