`
`
`Liza M. Walsh
`Christine I. Gannon
`Eleonore Ofosu-Antwi
`WALSH PIZZI O’REILLY FALANGA LLP
`One Riverfront Plaza
`1037 Raymond Boulevard, 6th Floor
`Newark, NJ 07102
`(973) 757-1100
`
`Attorneys for Plaintiff
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`
`
`
`Nitto Denko Corporation,
`
` Plaintiff,
`
`v.
`
`Hutchinson Technology Incorporated,
`
` Defendant.
`
`
`
`
`
`
`
`Civil Action No.
`
`
`
`Electronically Filed
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Nitto Denko Corporation (“Nitto”) brings this action against Hutchinson Technology
`
`Incorporated (“HTI”) and alleges as follows:
`
`PARTIES
`
`1.
`
`Nitto Denko Corporation is a Japanese corporation with its principle place of
`
`business located at 33rd Floor, Grand Front Osaka, 4-20, Ofuka-cho, Kita-ku, Osaka 530-0011,
`
`Japan.
`
`
`
`
`
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 2 of 138 PageID: 2
`
`
`2.
`
`On information and belief, Defendant HTI is incorporated in the State of Minnesota
`
`with its principal place of business at 40 West Highland Park Drive NE, Hutchinson, Minnesota
`
`55350.
`
`BACKGROUND
`
`Nitto Denko Corporation’s Technological Leadership
`
`3.
`
`Since its foundation in 1918, Nitto has conducted business globally across various
`
`industries including the electronics, automotive, housing, infrastructure, environmental, and
`
`medical sectors.
`
`4.
`
`To remain a market leader, Nitto spends tens of millions of dollars on research and
`
`development annually. Indeed, last year alone, Nitto spent the equivalent of over $250 million on
`
`research and development.
`
`5.
`
`Because innovation is key to Nitto’s success, Nitto is a leader in filing for, and
`
`receiving, patents on its inventions. Nitto files hundreds of patent applications a year and, annually,
`
`is issued, on average, over 1,000 patents a year. To date, Nitto owns over 10,000 patents, including
`
`over 6,500 patents in countries outside Japan, including the United States.
`
`Nitto’s Market-Defining Flexure Technology
`
`6.
`
`Nitto is the market leader in researching and developing “flexures,” a key
`
`component of suspension assembly mounted on high-end hard disk drives. Generally speaking, a
`
`flexure is a flexible strip that, at one end, supports a disk drive’s magnetic head for reading and
`
`writing data on a disk and, at the other end, connects to the hard drive’s circuit board. The
`
`technology in the flexure is critical to a hard disk drive’s performance, given the requirements that
`
`it carry high-speed data to and from the read-write head without interference, and that it position
`
`the read-write head at a precise location above a disk for reading and writing data.
`
`2
`
`
`
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`
`7.
`
`In order to protect its technology, Nitto filed over 250 patent applications on its
`
`flexure technology in the United States alone. This has resulted, to date, in over 160 issued United
`
`States patents.
`
`Hutchinson Technology’s Infringement of Nitto’s Technology
`
`8.
`
`HTI markets disk drive components, including flexures. Indeed, HTI sometimes
`
`purchases Nitto flexures to incorporate into its suspension assemblies for its customers.
`
`9.
`
`10.
`
`This lawsuit does not concern those flexures that HTI purchases from Nitto.
`
`Rather, this lawsuit concerns certain flexures that HTI is producing itself. HTI is
`
`making, using and selling flexures by infringing on Nitto’s patented technology. This includes
`
`Nitto’s technology for:
`
` novel and strengthened flexure terminals for connections to magnetic heads and
`
`hard drive circuitry;
`
` novel wiring patterns for the wiring traces in high-density disk drive flexures for
`
`reducing impedance of wiring patterns;
`
` novel designs for “reference holes” in a flexure, used for more accurately
`
`positioning a magnetic head;
`
` a novel configuration for lead wires in a flexure for reducing an electrical signal’s
`
`“blunt waveform” without increasing manufacturing cost;
`
` a novel flexure production method, controlling the variation in thickness at low
`
`cost; and
`
` a novel design of a suspension board assembly sheet with flexures, for preventing
`
`the assembly sheet from being warped in the manufacturing process.
`
`3
`
`
`
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`
`JURISDICTION AND VENUE
`
`11.
`
`HTI designs, manufactures, uses, markets, imports into the United States, sells,
`
`and/or offers for sale in the United States suspension assemblies incorporating “flexures” for hard
`
`disk drives.
`
`12.
`
`This action for patent infringement arising under the patent laws of the United
`
`States, 35 U.S.C. § 1 et seq., including but not limited to 35 U.S.C. § 271.
`
`13.
`
`This Court has subject matter jurisdiction over this controversy under 28 U.S.C. §§
`
`1331 and 1338(a).
`
`14.
`
`This court has personal jurisdiction over HTI because, upon information and belief,
`
`HTI does and has done substantial business in this District, including both independently and
`
`through and with third parties by placing its products, including those that infringe Nitto’s patents,
`
`into the stream of commerce, which stream is directed at the State of New Jersey and this District,
`
`with the knowledge and/or understanding that such products would be sold in the State of New
`
`Jersey and this District. These acts have caused and continue to cause injury to Nitto within this
`
`District.
`
`15.
`
`HTI derives substantial revenue from the sale of infringing products distributed
`
`within the District, and/or expect or should reasonably expect their actions to have consequences
`
`within the District, and derive substantial revenue from interstate and international commerce. In
`
`addition, HTI has induced and continues to knowingly induce infringement within this District by
`
`contracting with others to market and sell infringing products with the knowledge and intent to
`
`facilitate infringing sales of the products by others within this District and by creating and/or
`
`disseminating instructions and other materials for the products with like mind and intent.
`
`4
`
`
`
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`
`16.
`
`On information and belief, HTI has sufficient minimum contacts with the District
`
`that an exercise of personal jurisdiction over HTI would not offend traditional notions of fair play
`
`and substantial justice and would be appropriate under the long-arm statute of this state.
`
`17.
`
`Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b) and (c) and/or
`
`and 1400(b).
`
`COUNT I
`
`INFRINGEMENT OF THE ’737 PATENT
`
`18.
`
`Nitto repeats, realleges, and incorporates by reference as if fully set forth herein
`
`each and every allegation in paragraphs 1-17 above.
`
`19.
`
`Nitto owns United States Patent No. 6,841,737 (“the ’737 patent”), entitled “Wired
`
`circuit board,” which was duly and legally issued on January 11, 2005. A certified copy of the ’737
`
`patent is attached as Exhibit A.
`
`20.
`
`HTI’s infringing activities in the United States and this District include the
`
`development, manufacture, use, importation, sale, and/or offer for sale of products, including but
`
`not limited to HTI products incorporated in hard drives identified as “WD Blue 3.5 inch / 500GB
`
`(WD5000AAKX)” made by Western Digital Corporation and being sold in the United States.
`
`21.
`
`On information and belief, HTI’s infringement has been, and continues to be,
`
`willful and deliberate, and has caused substantial damage to Nitto.
`
`COUNT II
`
`INFRINGEMENT OF THE ’644 PATENT
`
`22.
`
`Nitto repeats, realleges, and incorporates by reference as if fully set forth herein
`
`each and every allegation in paragraphs 1- 17 above.
`
`5
`
`
`
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`
`23.
`
`Nitto owns United States Patent No. 7,923,644 (“the’644 patent”), entitled “Printed
`
`circuit board and method of manufacture the same,” which was duly and legally issued on April
`
`12, 2011. A certified copy of the ’644 patent is attached as Exhibit B.
`
`24.
`
`HTI’s infringing activities in the United States and this District include the
`
`development, manufacture, use, importation, sale, and/or offer for sale of products, including but
`
`not limited to HTI products incorporated in hard drives identified as “WD Blue 2.5 inch / 1.0 TB
`
`(WD10JPVX)” made by Western Digital Corporation and being sold in the United States.
`
`25.
`
`On information and belief, HTI’s infringement has been, and continues to be,
`
`willful and deliberate, and has caused substantial damage to Nitto.
`
`COUNT III
`
`INFRINGEMENT OF THE ’126 PATENT
`
`26.
`
`Nitto repeats, realleges, and incorporates by reference as if fully set forth herein
`
`each and every allegation in paragraphs 1-17 above.
`
`27.
`
`Nitto owns United States Patent No. 8,692,126 (“the ’126 patent”), entitled “Wired
`
`circuit board and producing method thereof,” which was duly and legally issued on April 8, 2014.
`
`A certified copy of the ’126 patent is attached as Exhibit C.
`
`28.
`
`HTI’s infringing activities in the United States and this District include the
`
`development, manufacture, use, importation, sale, and/or offer for sale of products, including but
`
`not limited to the HTI products incorporated in hard drives identified as “WD Blue 2.5 inch/1TB
`
`(WD10JPVX)” made by Western Digital Corporation and being sold in the United States.
`
`29.
`
`On information and belief, HTI’s infringement has been, and continues to be,
`
`willful and deliberate, and has caused substantial damage to Nitto.
`
`6
`
`
`
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 7 of 138 PageID: 7
`
`
`COUNT IV
`
`INFRINGEMENT OF THE ’870 PATENT
`
`30.
`
`Nitto repeats, realleges, and incorporates by reference as if fully set forth herein
`
`each and every allegation in paragraphs 1-17 above.
`
`31.
`
`Nitto owns United States Patent No. 8,895,870 (“the ’870 patent”), entitled “Printed
`
`circuit board and method of manufacture the same,” which was duly and legally issued on
`
`November 25, 2014. A certified copy of the ’870 patent is attached as Exhibit D.
`
`32.
`
`HTI’s infringing activities in the United States and this District include the
`
`development, manufacture, use, importation, sale, and/or offer for sale of products, including but
`
`not limited to the HTI products incorporated in hard drives identified as “WD Blue 2.5 inch / 1TB
`
`(WD10JPVX)” made by Western Digital Corporation and being sold in the United States.
`
`33.
`
`On information and belief, HTI’s infringement has been, and continues to be,
`
`willful and deliberate, and has caused substantial damage to Nitto.
`
`COUNT V
`
`INFRINGEMENT OF THE ’379 PATENT
`
`34.
`
` Nitto repeats, realleges, and incorporates by reference as if fully set forth herein
`
`each and every allegation in paragraphs 1-17 above.
`
`35.
`
`Nitto owns United States Patent No. 7,007,379 (“the ’379 patent”), entitled
`
`“Production method of printed circuit board,” which was duly and legally issued on March 7, 2006.
`
`A certified copy of the ’379 patent is attached as Exhibit E.
`
`36.
`
`HTI’s infringing activities in the United States and this District include the
`
`development, manufacture, use, importation, sale, and/or offer for sale of products, including but
`
`7
`
`
`
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 8 of 138 PageID: 8
`
`
`not limited to HTI products incorporated in hard drives identified as “WD Red 3.5 inch / 3TB
`
`(WD30EFRX)” made by Western Digital Corporation and being sold in the United States.
`
`37.
`
`On information and belief, HTI’s infringement has been, and continues to be,
`
`willful and deliberate, and has caused substantial damage to Nitto.
`
`COUNT VI
`
`INFRINGEMENT OF THE ’906 PATENT
`
`38.
`
`Nitto repeats, realleges, and incorporates by reference as if fully set forth herein
`
`each and every allegation in paragraphs 1-17 above.
`
`39.
`
`Nitto owns United States Patent No. 8,658,906 (“the ’906 patent”), entitled “Printed
`
`circuit board assembly sheet and method for manufacturing the same,” which was duly and legally
`
`issued on February 25, 2014. A certified copy of the ’906 patent is attached as Exhibit F.
`
`40.
`
`HTI’s infringing activities in the United States and this District include the
`
`development, manufacture, use, importation, sale, and/or offer for sale of products, including but
`
`not limited to HTI products incorporated in hard drives identified as “WD Red 3.5 inch / 3TB
`
`(WD30EFRX)” made by Western Digital Corporation and being sold in the United States.
`
`41.
`
`On information and belief, HTI’s infringement has been, and continues to be,
`
`willful and deliberate, and has caused substantial damage to Nitto.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff prays for the following relief:
`
`A.
`
`That the Court render judgment declaring that HTI has infringed the ’737 patent,
`
`the ’644 patent, the ’126 patent, the ’870 patent, the ’379 patent, and the ’906 patent (collectively,
`
`“the Nitto Patents”) in violation of 35 U.S.C. § 271;
`
`8
`
`
`
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 9 of 138 PageID: 9
`
`
`B.
`
`That the Court render judgment declaring HTI’s infringement of the Nitto Patents
`
`willful and deliberate;
`
`C.
`
`That Nitto be awarded damages adequate to compensate Nitto for HTI’s
`
`infringement of the Nitto Patents;
`
`D.
`
`E.
`
`That Nitto be awarded enhanced damages pursuant to 35 U.S.C. § 284;
`
`That Nitto be awarded pre-judgment and post-judgment interest to the full extent
`
`allowed under the law, as well as its costs and disbursements;
`
`F.
`
`That the Court enter an order finding that this is an exceptional case and awarding
`
`Nitto its reasonable attorney fees pursuant to 35 U.S.C. § 285;
`
`G.
`
`That the Court preliminarily and permanently enjoin HTI, its parents, affiliates,
`
`successors, assigns, subsidiaries and transferees, and its officers, directors, agents, servants, and
`
`employees, and all those persons in active concert or participation with them, or any of them, from
`
`making, using, importing, exporting, distributing, supplying, selling or offering to sell, or causing
`
`to be sold any product falling within the scope of the claims of the Nitto Patents, or otherwise
`
`contributing to or inducing the infringement of any claim thereof;
`
`H.
`
`I.
`
`That the Court award, in the absence of an injunction, an ongoing royalty; and
`
`That the Court award such other relief as it may deem appropriate and just under
`
`the circumstances.
`
`
`
`
`
`9
`
`
`
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 10 of 138 PageID: 10
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`WALSH PIZZI O’REILLY FALANGA LLP
`
`
`
`
`
`s/ Liza M. Walsh
`Liza M. Walsh
`Christine I. Gannon
`Eleonore Ofosu-Antwi
`One Riverfront Plaza
`1037 Raymond Boulevard, 6th Floor
`Newark, NJ 07102
`(973) 757-1100
`
`OF COUNSEL:
`
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`Alex V. Chachkes
`Hiroshi Sarumida
`Catrina W. Wang
`51 West 52nd Street
`New York, NY 10019
`(212) 506-5000
`
`David E. Case
`Izumi Garden Tower, 28th Floor
`6-1 Roppongi 1-Chome
`Minato-ku, Tokyo, 106-6028
`Japan
`81-3-3224-2900
`
`Hsiwen Lo
`2050 Main Street, Suite 1100
`Irvine, CA 92614-8255
`(949) 567-6700
`
`Attorneys for Plaintiff
`
`
`
`Dated: June 20, 2016
`
`
`
`
`
`10
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`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 11 of 138 PageID: 11
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`RULE 11.2 CERTIFICATION
`
`I certify that, to the best of my knowledge, the matter in controversy is not the subject of
`
`any other pending or anticipated litigation in any court or arbitration proceeding, nor are there any
`
`non-parties known to Plaintiff that should be joined to this action. In addition, I recognize a
`
`continuing obligation during the course of this litigation to file and to serve on all other parties and
`
`with the Court an amended certification if there is a change in the facts stated in this original
`
`certification.
`
`
`Dated: June 20, 2016
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`WALSH PIZZI O’REILLY FALANGA LLP
`
`s/ Liza M. Walsh
`Liza M. Walsh
`
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`11
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`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 12 of 138 PageID: 12
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`RULE 201.1 CERTIFICATION
`
`We hereby certify that the above-captioned matter is not subject to compulsory arbitration.
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`
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`Dated: June 20, 2016
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` WALSH PIZZI O’REILLY FALANGA LLP
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`s/ Liza M. Walsh
`Liza M. Walsh
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`12
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`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 13 of 138 PageID: 13
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 13 of 138 PagelD: 13
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`EXHIBIT A
`EXHIBIT A
`
`
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`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 14 of 138 PageID: 14
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`Case 2:16-cv-03595-CCC-MF Document miiVWWanita
`
`im
`
`«2, United States Patent (10) Patent No:—US 6,841,737 B2
`
`Komatsubaraetal.
`(45) Date of Patent:
`Jan. 11, 2005
`
`
`
`
`US006841737B206841
`
`Assi
`73)
`signee:
`(73)
`(*) Notice:
`
`(54) WIRED CIRCUIT BOARD
`(75)
`Inventors: Makoto Komatsubara, Osaka (JP);
`Shigenori Morita, Osaka (JP); Tadao
`Ookawa, Osaka (JP); Toshio Shintani,
`Osaka (JP)
`Osaka
`(JP
`: Nitto Denko C
`tion,
`Osaka (JP)
`Nitto
`Denko Corporation,
`Subjectto any disclaimer,the term of this
`patent is extended or adjusted under 35
`U.S.C. 154(b) by 0 days.
`(21) Appl. No.: 10/195,392
`(22) Filed:
`Jul. 16, 2002
`:
`«age
`(65)
`Prior Publication Data
`US 2003/0026078 Al Feb. 6, 2003
`.
`ar
`eo
`Foreign Application Priority Data
`(30)
`Jul. 17, 2001
`(IP)
`ececeeseceseeessctenserseseesenees 2001-216812
`
`(SL)
`
`Tint, C17 occ cceeessssssssssssssssssssssssesenenes HO5K 7/06
`
`(52) US. Ch oe 174/250; 174/255; 174/257,
`174/258
`
`(56)
`
`References Cited
`U.S. PATENT DOCUMENTS
`3,711,626 A *
`1/1973 Kilbyetal. wc 174/251
`5,446,245 A *
`8/1995 Iwayamaetal.0... 174/261
`6,388,201 B2 *
`5/2002 Yamato et al. cesses 174/255
`6,399,899 BL *
`6/2002 Obkawaetal... 174/261
`* cited by examiner
`Primary Examiner—John B. Vigushin
`(74) Attorney, Agent, or Firm—Jean C. Edwards, Esq.;
`Dickinson Wright PLLC
`(657)
`ABSTRACT
`A wired circuit board having a terminal portion formed as a
`flying lead that can provide enhanced strength of the con-
`ductive pattern, both sides of which are exposed, by simple
`construction to effectively prevent disconnection of the
`conductive pattern. The wired circuit board having the
`terminal portion formed asthe flying lead in which the both
`sides of the conductive pattern are exposed includes,
`in
`crossing areas where ends ofa cover-side opening and ends
`of a base-side opening and the conductive pattern are
`crossed each other, (i) the widened portions formed in the
`conductive pattern or (ii) cover-side projections and base-
`side projections formedin the coverlayer and the base layer,
`respectively.
`
`(58) Field of Search occ eee 361/749-751,
`174/254, 250, 255-258, 261
`
`7 Claims, 15 Drawing Sheets
`
`(a)
`
`(b)
`
`
`
`
`
`
`
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 15 of 138 PagelD: 15
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 15 of 138 PageID: 15
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 1 of 15
`
`US 6,841,737 B2
`
`FIG.
`
`1
`
`(a)
`
`(b)
`
`FIG. 2
`
`
`
`
`
`
`
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 16 of 138 PagelD: 16
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 16 of 138 PageID: 16
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 2 of 15
`
`US 6,841,737 B2
`
`FIG.
`
`3
`
`12
`
`14
`(bo) AAA
`VIZLLSLALLZLZELLLLA
`MARA
`12
`
`(c)
`
`(d)
`
`17
`
`14
`
`
`
`12°
`
`14
`
`17
`
`13
`
`13
`
`(e)
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 17 of 138 PagelD: 17
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 17 of 138 PageID: 17
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 3 of 15
`
`US 6,841,737 B2
`
`FIG. 4
`
`(a)
`
`(b)
`
`FIG. 5
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 18 of 138 PagelD: 18
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 18 of 138 PageID: 18
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 4 of 15
`
`US 6,841,737 B2
`
`FIG.
`
`FIG.
`
`FIG.
`
`6
`
`8
`
`
`
`
`7
`ip/
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 19 of 138 PagelD: 19
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 19 of 138 PageID: 19
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 5 of 15
`
`US 6,841,737 B2
`
`FIG.
`
`9
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 20 of 138 PagelD: 20
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 20 of 138 PageID: 20
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 6 of 15
`
`US 6,841,737 B2
`
` (o) ELLER TOSLEMEEK:
`
`OE
`
`32
`
`
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 21 of 138 PagelD: 21
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 21 of 138 PageID: 21
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 7 of 15
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`US 6,841,737 B2
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`FIG. 11
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 22 of 138 PagelD: 22
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 22 of 138 PageID: 22
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 8 of 15
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`US 6,841,737 B2
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`FIG. 12
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 23 of 138 PagelD: 23
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 23 of 138 PageID: 23
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 9 of 15
`
`US 6,841,737 B2
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`FIG. 13
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 24 of 138 PagelD: 24
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 24 of 138 PageID: 24
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 10 of 15
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`US 6,841,737 B2
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`FIG. 15
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 25 of 138 PagelD: 25
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 25 of 138 PageID: 25
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 11 of 15
`
`US 6,841,737 B2
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 26 of 138 PagelD: 26
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 26 of 138 PageID: 26
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 12 of 15
`
`US 6,841,737 B2
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`FIG. 17
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 27 of 138 PagelD: 27
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 27 of 138 PageID: 27
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 13 of 15
`
`US 6,841,737 B2
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`FIG. 18
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 28 of 138 PagelD: 28
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 28 of 138 PageID: 28
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 14 of 15
`
`US 6,841,737 B2
`
`FIG. 19
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 29 of 138 PagelD: 29
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 29 of 138 PageID: 29
`
`U.S. Patent
`
`Jan. 11, 2005
`
`Sheet 15 of 15
`
`US 6,841,737 B2
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`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 30 of 138 PagelD: 30
`Case 2:16-cv-03595-CCC-MF Document 1 Filed 06/20/16 Page 30 of 138 PageID: 30
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`US 6,841,737 B2
`
`1
`WIRED CIRCUIT BOARD
`
`invention claims priority from Japanese
`The present
`Patent Application Serial No. 2001-21812 filed Jul. 17,
`2001, which is herein incorporated by reference.
`
`BACKGROUND OF THE INVENTION
`
`1. Field of the Invention
`
`The present invention relates to a wired circuit board and,
`more particularly, to a wired circuit board suitably used for
`a suspension board with circuit.
`2. Description of the Prior Art
`The wired circuit boards used for electronic/electric
`equipment are usually provided with terminal portions to
`connect with external connecting terminals.
`In recent years, the so-called “flying lead” in which the
`terminal portions are formed on bothsides of the conductive
`pattern, rather than in only either side thereof, is in wide-
`spread use in order to meet
`the demand for electronic/
`electric equipment to have increasingly higher density and
`reduced size. It is known,for example, in a suspension board
`with circuit used for a hard disk drive that the terminals are
`provided in the form offlying lead.
`To be more specific,
`the suspension board with circuit
`comprises a supporting board 1 of stainless steel foil, a base
`layer 2 of an insulating material formed on the supporting
`board 1, a conductive pattern 3 formed on the base layer 2
`in the form of a specified circuit pattern, and a cover layer
`4 of an insulating material, for covering the conductive
`pattern 3, as shown in FIG. 21. The terminal portions 5
`provided in the form ofthe flying lead are formed on both
`sides of the conductive pattern 3 in the following manner.
`The cover layer 4 is opened to expose a front side of the
`conductive pattern 3, while also the supporting board 1 and
`the base layer 2 are opened to expose a back side of the
`conductive pattern 3. If necessary, metal plated layers 6 are
`formed on the both sides of the thus exposed conductive
`pattern 3 by nickel/gold plating and the like.
`Thereafter, these terminal portions formed as the flying
`lead are bonded to external connecting terminals by apply-
`ing supersonicvibration thereto by use of a bonding tool and
`the like.
`
`In this terminal portion formedas theflying lead,since the
`both sides of the conductive pattern are exposed, the super-
`sonic vibration is easily transmitted to the terminals. This is
`suitable for the bonding using the supersonic vibration: on
`the other hand,
`this provides the disadvantage that
`the
`conductive pattern exposed at both sides thereof is weak in
`physical strength and is subject to stress concentration at
`edge portions of the openings in the base layer and cover
`layer, to cause easy disconnection of the conductive pattern.
`
`SUMMARY OF THE INVENTION
`
`It is the object of the invention to provide a new wired
`circuit board having a terminal portion formed as a flying
`lead in which both sides of a conductive pattern are exposed
`that can provide enhancedstrength of the conductive pattern
`by simple construction to effectively prevent the occurrence
`of disconnection of the conductive pattern.
`The present invention provides a wired circuit board
`comprising a first
`insulating layer, a conductive pattern
`formed on the first insulating layer, a second insulating layer
`formed on the conductive pattern, and an opening, formed at
`the same position of the conductive pattern, for allowing the
`first insulating layer and the secondinsulating layer to open,
`
`10
`
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`
`20
`
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`
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`
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`
`40
`
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`
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`
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`
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`
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`so as to form a terminalportion in which front and backsides
`of the conductive pattern are exposed, wherein at least any
`one ofthe first insulating layer, the second insulating layer
`and the conductive pattern has reinforcing portions for
`reinforcing the conductive pattern formed at ends of the
`opening in crossing areas where endsof the opening and the
`conductive pattern cross each other.
`Also, the present invention provides a wired circuit board
`comprising a metal supporting layer, a first insulating layer
`formed on the metal supporting layer, a conductive pattern
`formed on the first insulating layer, a secondinsulating layer
`formed on the conductive pattern, and an opening, formed at
`the same position of the conductive pattern, for allowing the
`metal supporting layer andthe first insulating layer, and the
`second insulating layer to open, so as to form a terminal
`portion in which front and back sides of the conductive
`pattern are exposed, wherein at least any one of thefirst
`insulating layer, the second insulating layer and the conduc-
`tive pattern has reinforcing portions for reinforcing the
`conductive pattern formedat ends of the opening in crossing
`areas where ends of the opening and the conductive pattern
`cross each other.
`
`In the wired circuit boards mentioned above, since atleast
`any one of thefirst insulating layer, the second insulating
`layer and the conductive pattern has the reinforcing portions
`for reinforcing the conductive pattern formedat the ends of
`the opening in the crossing areas where the ends of the
`opening and the conductive pattern cross each other, the
`physical strength of the conductive pattern at the ends of the
`opening can be reinforced. This can producethe effect that
`for example, when the conductive pattern, both sides of
`which are exposed, is subject to stress concentration at the
`end portions of the opening in the process of bonding the
`terminal portion and the external connecting terminal by
`applying supersonic vibration of a bonding tool, the discon-
`nection of the conductive pattern can be effectively
`prevented, thus providing improved bondingreliability.
`In addition,the present invention provides a wired circuit
`board comprising a first insulating layer, a conductive pat-
`tern formed onthefirst insulating layer, a second insulating
`layer formed on the conductive pattern, and an opening,
`formed at the same position of the conductive pattern, for
`allowing the first insulating layer and the second insulating
`layer to open, so as to form a terminal portion in which front
`and back sides of the conductive pattern are exposed,
`wherein the conductive pattern has widened portions formed
`to extend in a widthwise direction substantially orthogonal
`to an extending direction of the conductive pattern in
`crossing areas where ends of the opening and the conductive
`pattern cross each other.
`Also, the present invention provides a wired circuit board
`comprising a metal supporting layer, a first insulating layer
`formed on the metal supporting layer, a conductive pattern
`formed on the first insulating layer, a second insulating layer
`formed on the conductive pattern, and an opening, formed at
`the sameposition of the conductive pattern, for allowing the
`metal supporting layer andthe first insulating layer, and the
`second insulating layer to open, so as to form a terminal
`portion in which front and back sides of the conductive
`pattern are exposed, wherein the conductive pattern has
`widened portions formed to extend in a widthwise direction
`substantially orthogonal to an extending direction of the
`conductive pattern in crossing areas where ends of the
`opening and the conductive pattern cross each other.
`In the wired circuit boards mentioned above, since the
`conductive pattern has widened portions formed to extend in
`
`
`
`Case 2:16-cv-03595-CCC-MF Document1 Filed 06/20/16 Page 31 of 138 PagelD: 31
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`US 6,841,737 B2
`
`4
`terminal portion of the wired circuit board; and (b) is a plan
`view of the terminal portion of the same.
`FIG.2 is an enlarged plan viewof FIG.1(6).
`FIG. 3 illustrates the production processes of a wired
`circuit board shown in FIG. 1:
`
`3
`a widthwise direction substantially orthogonal to the extend-
`ing direction of the conductive pattern in the crossing areas
`where the ends of the opening and the conductive pattern
`cross each other,
`the physical strength of the conductive
`pattern at the endsof the opening can be reinforced. This can
`produce the effect that for example when the conductive
`(a) shows the step of forming a conductive pattern on a
`pattern both sides of which are exposed is subject to stress
`base layer;
`concentration at the end portions of the opening in the
`(b) shows the step of forming a base layer on the con-
`process of bonding the terminal portion and the external
`ductive pattern;
`connecting terminal by applying supersonic vibration of the
`(c) shows the step of forming a cover-side opening on the
`bonding tool, the disconnection of the conductive pattern
`coverlayer at a portion thereof at which terminals are to be
`can beeffectively prevented, thus providing improved bond-
`ing reliability.
`formed;
`(d) shows the step of forming a base-side opening on the
`Further, the present invention provides a wired circuit
`15
`base layer at a portion thereof at which terminals are to be
`board comprisingafirst insulating layer, a conductivepat-
`formed; and
`tern formed onthefirst