1. “Whether the Board erred in finding that for the limitation ‘an LED circuit array comprising an LED circuit comprising a plurality of LEDs connected in series’ is properly construed to encompass a plurality of LED circuits/groups of LEDs being connected in series even when there are no LEDs are connected in series.”
2. “Whether the Board erred by determining that ‘an LED circuit comprising a plurality of LEDs connected in series’ was met in view of the cited references.”
3. “Whether the Board erred in construing the limitation ‘wherein a forward voltage of the LEDs … matches the rectified [] AC voltage output of the driver’ encompasses the rectified AC output voltage being ‘less than’ the forward voltage of the LEDs.”
4. “Whether the Board erred by determining that the limitation for the ‘forward voltage of the LEDs … matches the rectified [] AC voltage output of the driver’ in Claim 7 was met in view of the cited references.”
5. “Whether the Board erred in determining that the Martin reference, a published and later abandoned U.S. patent application that could only be prior art under pre AIA 35 § 102(e)(1), can be applied in an IPR as a ‘printed publication’ under 35 U.S.C. § 311(b).”
1. “Under the plain and ordinary meaning of the term, we conclude that ‘a plurality of LEDs connected in series’ may include either a plurality of individual LEDs or a plurality of LED circuits connected in series because both include a ‘plurality of LEDs.’ We therefore agree with the Board’s construction . . . .”
2. “Because we conclude that the Board did not err in construing the term, no dispute remains as to whether the prior art discloses this limitation. Indeed, it is undisputed that the prior art, Nerone, teaches a series of circuits, where the LEDs are connected in parallel within each circuit. . . . Therefore, we conclude that substantial evidence supports the Board’s finding that Nerone discloses this claim limitation.”
3. “Samsung argues, and the Board agreed, that the limitation, in view of the specification, ‘encompasses “the rectified input AC voltage output of the driver” that is less than “a forward voltage of the LEDs of the LED circuit. . . .”’ Based on the intrinsic record, we agree with Samsung and the Board.”
4. “[L]ike the Board, we are persuaded that ‘the combined teachings of Nerone and Martin teach or suggest [this] limitation,’ . . . particularly in light of the knowledge of a person of ordinary skill in the art.”
5. “Under § 102(e)(1), published patent applications, like Martin, are deemed prior art as of their filing date. Therefore, Martin—having been filed before the ’400 patent’s priority date—is a prior art printed publication as to the ’400 patent. Stated generally: because a published patent application is a ‘printed publication,’ § 102(e)(1) treats this type of printed publication as prior art as of a time before it became publicly accessible—i.e., as of its filing date.”
