EXHIBIT 1 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

EPISTAR CORPORATION, 

Plaintiff, 

v. 

LOWE’S COMPANIES, INC., 

LOWE’S HOME CENTERS, LLC, 

Defendants. 

CASE NO.: 6:20-cv-00420-ADA

JURY TRIAL DEMANDED 

PLAINTIFF EPISTAR CORPORATION’S 

PRELIMINARY INFRINGEMENT CONTENTIONS 

Plaintiff Epistar Corporation (“Plaintiff” or “Epistar”) serves its Preliminary Infringement 

Contentions on Defendants Lowe’s Companies, Inc. and Lowe’s Home Centers, LLC 

(collectively, “Defendants” or “Lowe’s”) regarding U.S. Patent Nos. 7,489,068 (“the ’068 

Patent”), 8,240,881 (“the ’881 Patent”), 9,065,022 (“the ’022 Patent”), 9,664,340 (“the ’340 

Patent”), and 10,224,455 (“the ’455 Patent”) (collectively, “the Asserted Patents”). 

Discovery has yet to begin, and claim construction has not taken place. As a result, 

Epistar reserves the right to amend its contentions pursuant to Order No. 20 fn. 4 after claim 

construction has taken place and/or discovery has progressed. 

I. IDENTIFICATION OF ASSERTED CLAIMS 

Lowe’s infringes at least claims 1, and 4-6 of the ’068 Patent. For each asserted claim, at 

least 35 U.S.C. §§ 271(a), (b), (c), and (f) are applicable. 

Lowe’s infringes at least claims 1, 3, 9, and 17 of the ’881 Patent. For each asserted 

claim, at least 35 U.S.C. §§ 271(a), (b), (c), and (f) are applicable. 

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Lowe’s infringes at least claims 1, 2, 6, 8, 9, 12, 17, 19, 22, and 23 of the ’022 Patent. 

For each asserted claim, at least 35 U.S.C. §§ 271(a), (b), (c), and (f) are applicable. 

Lowe’s infringes at least claims 1-11, 13-16, 19, and 20 of the ’340 Patent. For each 

asserted claim, at least 35 U.S.C. §§ 271(a), (b), (c), and (f) are applicable. 

Lowe’s infringes at least claims 1, 3, 5, 6, 9, 10, 12, and 13 of the ’455 Patent. For each 

asserted claim, at least 35 U.S.C. §§ 271(a), (b), (c), and (f) are applicable. 

II. IDENTIFICATION OF ACCUSED PRODUCTS 

Discovery and claim construction have yet to occur. Epistar reserves the right to amend 

the following lists of accused products as discovery progresses. 

Epistar contends that at least Lowe’s GE Classic Series lightbulbs, GE Refresh Series 

lightbulbs, GE Relax Series lightbulbs, GE Basic Series lightbulbs, GE Reveal Series lightbulbs, 

and GE Vintage Series lightbulbs that include one or more LED filaments infringe the asserted 

claims of the ’068 Patent. 

Epistar contends that at least Lowe’s GE Classic Series lightbulbs, GE Refresh Series 

lightbulbs, GE Relax Series lightbulbs, GE Basic Series lightbulbs, GE Reveal Series lightbulbs, 

and GE Vintage Series lightbulbs that include one or more LED filaments infringe the asserted 

claims of the ’881 Patent. 

Epistar contends that at least Lowe’s GE Classic Series lightbulbs, GE Refresh Series 

lightbulbs, GE Relax Series lightbulbs, GE Basic Series lightbulbs, GE Reveal Series lightbulbs, 

and GE Vintage Series lightbulbs that include one or more LED filaments infringe the asserted 

claims of the ’022 Patent. 

Epistar contends that at least Lowe’s GE Classic Series lightbulbs, GE Refresh Series 

lightbulbs, GE Relax Series lightbulbs, GE Basic Series lightbulbs, GE Reveal Series lightbulbs, 

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and GE Vintage Series lightbulbs that include one or more LED filaments infringe the asserted 

claims of the ’340 Patent. 

Epistar contends that at least Lowe’s GE Classic Series lightbulbs, GE Refresh Series 

lightbulbs, GE Relax Series lightbulbs, GE Basic Series lightbulbs, GE Reveal Series lightbulbs, 

and GE Vintage Series lightbulbs that include one or more LED filaments infringe the asserted 

claims of the ’455 Patent. 

III. CHART IDENTIFYING CLAIM ELEMENTS WITHIN ACCUSED PRODUCTS 

Attached as Exhibits 1-5 are representative claim charts identifying where each element 

of each asserted claim of the Asserted Patents is found within the accused products. Epistar does 

not currently contend that any claim elements are governed by 35 U.S.C. § 112(6) (pre-AIA) or 

35 U.S.C. § 112(f) (post-AIA). 

The claim charts appended hereto as Exhibits 1-5 are exemplary, not limiting, and 

address the asserted claims without the benefit of full discovery. Any citations included in the 

claim charts are exemplary only and should not be construed as limiting. 

In the claim charts appended hereto as Exhibits 1-5, Epistar has subdivided certain 

asserted claims to better explain where each claim element may be found within the accused 

products, and other products and/or services. The subdivisions in the claim chart should not be 

taken as an indication of the boundaries of claim elements with respect to the doctrine of 

equivalents or any other issue. Additionally, the accused products may infringe the asserted 

claims in multiple ways. Epistar reserves the right to provide an alternative claim mapping or 

infringement contention. 

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IV. INDIRECT INFRINGEMENT 

Lowe’s has induced, and is continuing to actively and knowingly induce, with specific 

intent, direct infringement of the Asserted Patents under 35 U.S.C. § 271(b) by making, using, 

offering for sale, selling, and/or importing the accused products. Lowe’s had actual knowledge 

of the ’881 and ’022 Patents and/or their respective applications at least as of April 7, 2016. 

Lowe’s had actual knowledge of the ’068, ’340, and ’455 Patents and/or their respective 

applications at least as of May 22, 2020. As a result, Lowe’s knew or should have known that 

that its actions would result in infringement of the Asserted Patents. Lowe’s intentionally directs 

and encourages Lowe’s customers, resellers, retailers, and end users to make, use, sell, and/or 

offer to sell within the United States and/or to import into the United States one or more devices 

that embody the patented invention and that incorporate the accused products and systems 

identified above. Lowe’s provides support to instruct its customers on how to use the infringing 

technology. 

Lowe’s has also contributed to and continues to contribute to direct infringement of the 

Asserted Patents with knowledge of the Asserted Patents and its claims and that its actions would 

result in infringement by manufacturers, distributors, resellers, and end users. Lowe’s provided 

and continues to provide the accused products knowing that such products constitute a material 

part of the Asserted Patents, knowing those accused products to be especially made or adapted to 

infringe the Asserted Patents, and knowing that the accused products are not staple articles or 

commodities of commerce suitable for substantial non-infringing use. 

V. LITERAL INFRINGEMENT AND INFRINGEMENT UNDER THE DOCTRINE 

OF EQUIVALENTS 

Epistar contends that each asserted claim is literally infringed by Lowe’s accused 

products, as indicated by the infringement claim charts attached hereto as Exhibits 1-5. In the 

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alternative, Epistar contends that any asserted claim not found to be literally infringed is 

infringed under the doctrine of equivalents. 

VI. IDENTIFICATION OF PRIORITY DATES 

The asserted claims of the ’068 Patent are entitled to a priority date of at least as early as 

December 13, 2004. 

The asserted claims of the ’881 Patent are entitled to a priority date of at least as early as 

September 12, 2006. 

The asserted claims of the ’022 Patent are entitled to a priority date of at least as early as 

May 29, 2012. 

The asserted claims of the ’340 Patent are entitled to a priority date of at least as early as 

June 11, 2013. 

The asserted claims of the ’455 Patent are entitled to a priority date of at least as early as 

January 27, 2006. 

Epistar’s investigation relating to the conception and reduction to practice of the patented 

inventions is ongoing and it therefore reserves the right to supplement and/or modify this date as 

discovery in this case continues. 

VII. DOCUMENT PRODUCTION 

Copies of the file history for each Asserted Patent: EPISTAR-LCI_0000001-EPISTARLCI_0001588. 

Documents evidencing conception and reduction to practice for each claimed invention: 

EPISTAR-LCI_0001594-EPISTAR-LCI_0001614. 

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Dated: August 21, 2020 /s/ James C. Yoon

James C. Yoon (CA State Bar No. 177155) 

jyoon@wsgr.com

Ryan R. Smith (CA State Bar No. 229323) 

rsmith@wsgr.com

Albert Shih (CA State Bar No. 251726) 

ashih@wsgr.com

WILSON SONSINI GOODRICH & ROSATI, P.C. 

650 Page Mill Road 

Palo Alto, CA 94304-1050 

Telephone: (650) 493-9300 

Fax: (650) 493-6811 

Lucy Yen (NY State Bar No. 4871653) 

lyen@wsgr.com

WILSON SONSINI GOODRICH & ROSATI, P.C.

1301 Avenue of the Americas, 40th Floor 

New York, NY 10019-6022 

Telephone: (212) 999-5800 

Fax: (212) 999-5899 

Celine Liu (CA State Bar No. 268990) 

celine.liu@wsgr.com

WILSON SONSINI GOODRICH & ROSATI, P.C.

1700 K Street NW, Fifth Floor 

Washington, DC 20006 

Telephone: (202) 791-8800 

Fax: (202) 973-8899 

Attorneys for Plaintiff Epistar Corporation

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CERTIFICATE OF SERVICE 

The undersigned hereby certifies that a true and correct copy of the foregoing document 

has been served on August 21, 2020, via email on all counsel of record. 

By: /s/ Jonathan Rich . 

Jonathan Rich

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EXHIBIT 1 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 9 of 123
Exhibit 1: Infringement Claim Chart for U.S. Patent No. 7,489,068 

The Defendants infringe U.S. Patent No. 7,489,068 (“the ’068 Patent”) by making, using, selling, offering for sale, and 

importing at least certain GE Classic Series lightbulbs, GE Refresh Series lightbulbs, GE Relax Series lightbulbs, GE Basic Series 

lightbulbs, GE Reveal Series lightbulbs, and GE Vintage Series lightbulbs that include one or more LED filaments (the “Accused 

Product”). 

The asserted claims include elements that are implemented, at least in part, by proprietary hardware in the Accused Product. 

Plaintiff has provided these contentions based on analyzing the GE A19 Medium Base LED Filament Bulb as well as a review of 

the publicly available materials regarding the Accused Product. The chart is merely exemplary and may not show the functionality 

in its entirety. Furthermore, Plaintiff reserves the right to revise these contentions as discovery in the case progresses, in view of 

the Court’s final claim construction in this action and in connection with expert reports. 

As one non-limiting example, at least the GE A19 Medium Base LED Filament Bulb includes the features cited in the chart 

below: 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

1. A light emitting device, 

comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light emitting device. 

For example, as shown in the images below, the GE A19 Medium Base LED Filament Bulb 

includes a plurality of LED filaments.

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a transparent substrate; The GE A19 Medium Base LED Filament Bulb includes a transparent substrate. 

For example, as shown in the photograph and microscopic image below, the GE A19 Medium Base 

LED Filament Bulb includes at least one filament that includes a transparent substrate. 

transparent substrate 

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a light emitting stack having 

a first diffusing surface 

above the transparent 

substrate; and 

The GE A19 Medium Base LED Filament Bulb includes a light emitting stack having a first 

diffusing surface above the transparent substrate. 

For example, as shown in the microscopic images below, the light-emitting stack of the GE A19 

Medium Base LED Filament Bulb includes a diffusing surface with a plurality of protrusions above 

the transparent substrate. 

first diffusing surface

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transparent substrate 

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a transparent adhesive layer 

between the transparent 

substrate and the first 

diffusing surface, wherein 

an index of refraction of the 

light emitting stack is 

different from that of the 

transparent adhesive layer. 

The GE A19 Medium Base LED Filament Bulb includes a transparent adhesive layer between the 

transparent substrate and the first diffusing surface, wherein an index of refraction of the light 

emitting stack is different from that of the transparent adhesive layer. 

For example, as shown in the microscopic image below, between the transparent substrate and the 

first diffusing layer is a transparent adhesive layer. 

Based on a material analysis, the material for the transparent adhesive layer is silicone-based, and 

the material for the portion of the light-emitting stack immediately next to the transparent adhesive 

is sapphire. These two different materials have different indices of refraction. 

transparent substrate transparent substrate transparent adhesive layer 

sapphire 

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4. The light emitting device 

according to claim 1, 

wherein the first diffusing 

surface comprises a rough 

surface. 

The GE A19 Medium Base LED Filament Bulb includes a light emitting stack having a first 

diffusing surface above the transparent substrate, wherein the first diffusing surface comprises a 

rough surface. 

For example, as shown in the microscopic images below, the light-emitting stack of the GE A19 

Medium Base LED Filament Bulb includes a diffusing surface above the transparent substrate, 

wherein the diffusing surface has a plurality of protrusions. 

transparent substrate 

rough surface 

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5. The light emitting device 

according to claim 4, 

wherein the rough surface 

comprises a plurality of 

micro protrusions. 

The GE A19 Medium Base LED Filament Bulb includes a light emitting stack having a first 

diffusing surface above the transparent substrate, wherein the first diffusing surface comprises a 

rough surface. 

For example, as shown in the microscopic images below, the light-emitting stack of the GE A19 

Medium Base LED Filament Bulb includes a diffusing surface above the transparent substrate, 

wherein the diffusing surface has a plurality of micro protrusions. 

transparent substrate 

micro protrusions 

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6. The light-emitting device 

according to claim 5, 

wherein the micro 

protrusions have a shape 

selected from the group 

consisting of semi-sphere, 

pyramid, pyramid polygon, 

and combinations thereof. 

The GE A19 Medium Base LED Filament Bulb includes a light emitting stack having a first 

diffusing surface above the transparent substrate, wherein the first diffusing surface comprises a 

rough surface. 

For example, as shown in the microscopic images below, the light-emitting stack of the GE A19 

Medium Base LED Filament Bulb includes a diffusing surface above the transparent substrate, 

wherein the diffusing surface has a plurality of micro protrusions that resemble pyramid, pyramid 

polygon, and combinations thereof. 

transparent substrate 

micro protrusions 

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EXHIBIT 2 

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Exhibit 2: Infringement Claim Chart for U.S. Patent No. 8,240,881 

The Defendants infringe U.S. Patent No. 8,240,881 (“the ’881 Patent”) by making, using, selling, offering for sale, and 

importing at least certain GE Classic Series lightbulbs, GE Refresh Series lightbulbs, GE Relax Series lightbulbs, GE Basic Series 

lightbulbs, GE Reveal Series lightbulbs, and GE Vintage Series lightbulbs that include one or more LED filaments (the “Accused 

Product”). 

The asserted claims include elements that are implemented, at least in part, by proprietary hardware in the Accused Product. 

Plaintiff has provided these contentions based on analyzing the GE A19 Medium Base LED Filament Bulb as well as a review of the 

publicly available materials regarding the Accused Product. The chart is merely exemplary and may not show the functionality in its 

entirety. Furthermore, Plaintiff reserves the right to revise these contentions as discovery in the case progresses, in view of the 

Court’s final claim construction in this action and in connection with expert reports. 

As one non-limiting example, at least the GE A19 Medium Base LED Filament Bulb includes the features cited in the chart 

below: 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

1. A light-emitting device 

package comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light-emitting device package. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a light-emitting device package. 

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a carrier having a platform; 

and 

The GE A19 Medium Base LED Filament Bulb includes a carrier having a platform. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a column carrier attached to a platform. The platform is attached to four LED filaments. 

carrier

platform 

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a light-emitting device 

comprising: a transparent 

substrate having a first 

surface and a second surface; 

and 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb includes a 

light-emitting device comprising a transparent substrate having a first surface and a second surface. 

For example, as shown in the image below, a filament of the GE A19 Medium Base LED Filament 

Bulb includes a transparent substrate. 

As shown further in a microscopic image of the transparent substrate below, each transparent 

substrate has a first surface. The second surface is on the opposite side the first surface. 

transparent substrate 

first surface 

second surface 

transparent substrate 

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a light-emitting structure 

formed on the first surface of 

the transparent substrate, 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb includes a 

light-emitting structure formed on the first surface of the transparent substrate. 

For example, as shown in a microscopic image of the transparent substrate below, the transparent 

substrate has a plurality of light-emitting structures formed on the first surface of the transparent 

substrate. 

first surface 

second surface

light-emitting structures 

transparent substrate 

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wherein the light-emitting 

structure comprises at least a 

growth substrate and an 

active layer with p-n 

junction formed on the 

growth substrate, and 

The light-emitting structure of the GE A19 Medium Base LED Filament Bulb includes a growth 

substrate and an active layer with p-n junction formed on the growth substrate. 

For example, as shown in the microscopic images of the transparent substrate below, each lightemitting structure includes a growth substrate and an active layer with p-n junction formed on the 

growth substrate. 

growth substrate 

active layer with 

P-N junction 

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an angle between the first 

surface of the transparent 

substrate and the platform is 

45-135 degrees. 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb has an angle 

between the first surface of the transparent substrate and the platform that is between 45 and 135 

degrees. 

For example, as show in the image below, the filament is attached to the glass column via the 

platform at an angle between 45 and 135 degrees. 

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θ

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3. The light-emitting device 

package according to claim 

1, wherein the area of the 

first surface and/or the 

second surface is not smaller 

than the area of the p-n 

junction. 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb includes a first 

surface, a second surface, and a p-n junction, wherein the area of the first surface and/or the second 

surface is not smaller than the area of the p-n junction. 

For example, as shown in microscopic images below, both the area of the first surface and the area 

of the second surface appear larger than the area of the p-n junction. 

first surface 

second surface

light-emitting structures 

transparent substrate 

growth substrate 

active layer with 

P-N junction 

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9. The light-emitting device 

package according to claim 

1, further comprising a 

phosphor layer coated 

around the light-emitting 

device. 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb includes a 

phosphor layer coated around the light-emitting device. 

For example, as shown in the photo and the microscopic images below, a filament of the GE A19 

Medium Base LED Filament Bulb includes a phosphor layer that appears in color coated around the 

LED filament. 

phosphor layer 

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f

17. A light-emitting device 

package comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light-emitting device package. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a light-emitting device package. 

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a carrier having a platform; The GE A19 Medium Base LED Filament Bulb includes a carrier having a platform. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a column carrier attached to a platform. The platform is attached to four LED filaments. 

carrier

platform 

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and a light-emitting device 

comprising: a transparent 

substrate having a first 

surface and a second surface; 

and 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb includes a 

light-emitting device comprising a transparent substrate having a first surface and a second surface. 

For example, as shown in the image below, a filament of the GE A19 Medium Base LED Filament 

Bulb includes a transparent substrate. 

As shown further in a microscopic image of the transparent substrate below, each transparent 

substrate has a first surface. The second surface is on the opposite side the first surface. 

transparent substrate 

first surface 

second surface 

transparent substrate 

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a light-emitting structure 

formed on the first surface of 

the transparent substrate, 

wherein 

The light-emitting device package of the GE A19 Medium Base LED Filament Bulb includes a 

light-emitting structure formed on the first surface of the transparent substrate. 

For example, as shown in a microscopic image of the transparent substrate below, the transparent 

substrate has a plurality of light-emitting structures formed on the first surface of the transparent 

substrate. 

first surface 

second surface

light-emitting structures 

transparent substrate 

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the light-emitting structure 

has at least a growth 

substrate and an active layer 

with p-n junction formed on 

the growth substrate, and an 

angle between the p-n 

junction and the platform is 

not equal to zero degree. 

The light-emitting structure of the GE A19 Medium Base LED Filament Bulb includes a growth 

substrate and an active layer with p-n junction formed on the growth substrate. 

For example, as shown in the microscopic images of the transparent substrate below, each lightemitting structure includes a growth substrate and an active layer with p-n junction formed on the 

growth substrate. 

As shown in the image below, the light-emitting structure including the p-n junction forms an angle 

more than zero degree with the platform of the GE A19 Medium Base LED Filament Bulb. 

growth substrate 

active layer with 

P-N junction 

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carrier

platform 

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EXHIBIT 3 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 37 of 123
Exhibit 3: Infringement Claim Chart for U.S. Patent No. 9,065,022 

The Defendants infringe U.S. Patent No. 9,065,022 (“the ’022 Patent”) by making, using, selling, offering for sale, and 

importing at least certain GE Classic Series lightbulbs, GE Refresh Series lightbulbs, GE Relax Series lightbulbs, GE Basic Series 

lightbulbs, GE Reveal Series lightbulbs, and GE Vintage Series lightbulbs that include one or more LED filaments (the “Accused 

Product”). 

The asserted claims include elements that are implemented, at least in part, by proprietary hardware in the Accused Product. 

Plaintiff has provided these contentions based on analyzing the GE A19 Medium Base LED Filament Bulb as well as a review of 

the publicly available materials regarding the Accused Product. The chart is merely exemplary and may not show the functionality 

in its entirety. Furthermore, Plaintiff reserves the right to revise these contentions as discovery in the case progresses, in view of 

the Court’s final claim construction in this action and in connection with expert reports. 

As one non-limiting example, at least the GE A19 Medium Base LED Filament Bulb includes the features cited in the chart 

below: 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

1. A light emitting 

apparatus, comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light emitting apparatus. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a light-emitting apparatus. 

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at least one light emitting 

device, including: 

The GE A19 Medium Base LED Filament Bulb includes a light emitting device. 

For example, each of the GE A19 Medium Base LED Filament Bulb includes at least one LED 

filament. 

a substrate, having a 

support surface; and 

The light emitting device of the GE A19 Medium Base LED Filament Bulb includes a substrate 

having a support surface. 

For example, as shown in the photo and the microscopic image below, each light emitting device of 

the GE A19 Medium Base LED Filament Bulb includes a transparent substrate with a support 

surface. 

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substrate

support surface 

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at least one light emitting 

diode chip comprising a 

plurality of light emitting 

surfaces, disposed on said 

support surface of said 

substrate, 

The light emitting device of the GE A19 Medium Base LED Filament Bulb includes a plurality of 

light emitting diode chips disposed on the support surface, each of the light emitting diode chip 

includes a plurality of light-emitting surfaces. 

For example, as shown in the microscopic image below, there is a plurality of light emitting diode 

chips disposed on the support surface of the transparent substrate. Each light emitting diode chip 

includes a plurality of light emitting surfaces. 

support surface 

substrate

light emitting diode chip 

light emitting 

surfaces 

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one of said light emitting 

surfaces and said support 

surface forming a first main 

surface, wherein 

At least one of the light emitting surfaces of the light emitting chip disposed on a support surface of 

the GE A19 Medium Base LED Filament Bulb forms a first main surface. 

For example, as shown in the microscopic image below, the light emitting surface on the bottom 

side of the light emitting diode forms a main surface with the support surface. 

support surface 

light emitting diode chip 

light emitting 

surfaces 

first main surface 

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a light emitting angle of 

said light emitting diode 

chip is wider than 180°, and 

a portion of light emitted by 

said light emitting diode 

chip penetrates into said 

substrate from said support 

surface and emerges from a 

second main surface of said 

substrate opposing said first 

main surface; and 

The light emitting diode chip of the GE A19 Medium Base LED Filament Bulb has a light emitting 

angle wider than 180°, and a portion of light emitted by said light emitting diode chip penetrates 

into said substrate from said support surface and emerges from a second main surface of said 

substrate opposing said first main surface. 

For example, as illustrated for one of the light emitting diode chip in the microscopic image below, 

the light emitting diode chip of the GE A19 Medium Base LED Filament Bulb illuminates light in 

all directions and passes through a second main surface located on the bottom side of the 

transparent substrate. 

second main 

surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 44 of 123
-8- 

a support base, coupled to 

said light emitting device, 

and forming a first angle 

with said substrate. 

The GE A19 Medium Base LED Filament Bulb includes a support base, coupled to the light 

emitting device, and forming a first angle with the substrate. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a glass column with metal portions coupled to each filament and forming a first angle with 

the transparent substrate of the filament. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 45 of 123
-9- 

support base 

light emitting device 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 46 of 123
-10- 

support base 

light emitting device 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 47 of 123
-11- 

2. The light emitting 

apparatus of claim 1, further 

comprising a wavelength 

conversion layer disposed 

on said first main surface 

and/or on said second main 

surface of said light 

emitting device, wherein 

said wavelength conversion 

layer receives at least a 

portion of the light emitted 

by said light emitting diode 

chip and converts the 

wavelength thereof. 

The light emitting device of the GE A19 Medium Base LED Filament Bulb includes a wavelength 

conversion layer disposed on said first main surface and/or on said second main surface of said 

light emitting device, wherein said wavelength conversion layer receives at least a portion of the 

light emitted by said light emitting diode chip and converts the wavelength thereof. 

For example, as shown in the photo and the microscopic images below, each light emitting device 

of the GE A19 Medium Base LED Filament Bulb includes a wavelength conversion layer 

containing phosphors that covers the filament, and the light emitted by the LED chips goes through 

and is changed by the wavelength conversion layer. 

wavelength conversion layer

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 48 of 123
-12- 

phosphor

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 49 of 123
-13- 

6. The light emitting 

apparatus of claim 1, further 

comprising a lamp housing, 

wherein at least a portion of 

said light emitting device is 

disposed in the room 

formed by said lamp 

housing.

The GE A19 Medium Base LED Filament Bulb includes a lamp housing, wherein at least a lamp 

housing, wherein at least a portion of said light emitting device is disposed in the room formed by 

said lamp housing. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a bulb that houses the light-emitting device. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 50 of 123
-14- 

support base 

light emitting device 

lamp 

housing 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 51 of 123
-15- 

8. The light emitting 

apparatus of claim 6, 

wherein said lamp housing 

is coupled with said support 

base and at least partially 

covers said light emitting 

device. 

The GE A19 Medium Base LED Filament Bulb includes a lamp housing, wherein the lamp 

housing is coupled with said support base and at least partially covers said light emitting device. 

For example, as shown in the image below, the bulb is coupled to the support base and covers at 

least partially the light-emitting device. 

support base 

light emitting device 

lamp 

housing 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 52 of 123
-16- 

9. The light emitting 

apparatus of claim 6, 

wherein said lamp housing 

is a tube, a bulb, or a box. 

The GE A19 Medium Base LED Filament Bulb includes a lamp housing, wherein said lamp 

housing is a tube, a bulb, or a box. 

For example, as shown in the image below, the lamp housing is a bulb. 

support base 

light emitting device 

lamp 

housing 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 53 of 123
-17- 

12. The light emitting 

apparatus of claim 1, 

wherein said first angle 

ranges from 30° to 150°. 

The GE A19 Medium Base LED Filament Bulb includes a support base, coupled to the light 

emitting device, and forming a first angle with the substrate, wherein said first angle ranges from 

30° to 150°. 

For example, as shown in the images below, the GE A19 Medium Base LED Filament Bulb 

includes a glass column coupled to each filament and forming a first angle with the transparent 

substrate of the filament that range from 30° to 150°. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 54 of 123
-18- 

support base 

light emitting device 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 55 of 123
-19- 

17. The light emitting 

apparatus of claim 1, 

wherein said support base 

includes a support member 

and said light emitting 

device is disposed on said 

support member.

The GE A19 Medium Base LED Filament Bulb includes a support base, wherein said support base 

includes a support member and said light emitting device is disposed on said support member. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a glass column coupled to each filament. The glass column is connected to one or more 

metal portions, where each filament is disposed on one or more metal portions. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 56 of 123
-20- 

support base 

light emitting device 

support 

member

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 57 of 123
-21- 

19. The light emitting 

apparatus of claim 17, 

wherein said support 

member is flexible. 

The GE A19 Medium Base LED Filament Bulb includes a support base, wherein said support base 

includes a support member, wherein said support member is flexible. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a glass column coupled to each filament. The glass column is connected to one or more 

metal portions, where each filament is disposed on one or more metal portions. The metal portions 

are flexible. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 58 of 123
-22- 

support base 

light emitting device 

support 

member

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 59 of 123
-23- 

22. The light emitting 

apparatus of claim 1, 

wherein the material of said 

substrate is selected from 

the group consisting of 

aluminum oxide, sapphire, 

glass, plastics, and rubber. 

The GE A19 Medium Base LED Filament Bulb includes a substrate, the material of which is 

selected from the group consisting of aluminum oxide, sapphire, glass, plastics, and rubber. 

For example, as shown in the microscopic image and material analysis below, the substrate of the 

GE A19 Medium Base LED Filament Bulb is made of aluminum oxide. 

substrate 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 60 of 123
-24- 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 61 of 123
-25- 

23. The light emitting 

apparatus of claim 1, 

wherein the thickness of 

said substrate is greater than 

or equal to 200μm. 

The GE A19 Medium Base LED Filament Bulb includes a substrate with a thickness greater than 

or equal to 200μm. 

For example, as shown in the microscopic image below, the substrate of the GE A19 Medium Base 

LED Filament Bulb a thickness greater than 200μm. 

substrate 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 62 of 123
EXHIBIT 4 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 63 of 123
Exhibit 4: Infringement Claim Chart for U.S. Patent No. 9,664,340 

The Defendants infringe U.S. Patent No. 9,664,340 (“the ’340 Patent”) by making, using, selling, offering for sale, and 

importing at least certain GE Classic Series lightbulbs, GE Refresh Series lightbulbs, GE Relax Series lightbulbs, GE Basic Series 

lightbulbs, GE Reveal Series lightbulbs, and GE Vintage Series lightbulbs that include one or more LED filaments (the “Accused 

Product”). 

The asserted claims include elements that are implemented, at least in part, by proprietary hardware in the Accused Product. 

Plaintiff has provided these contentions based on analyzing the GE A19 Medium Base LED Filament Bulb as well as a review of 

the publicly available materials regarding the Accused Product. The chart is merely exemplary and may not show the functionality 

in its entirety. Furthermore, Plaintiff reserves the right to revise these contentions as discovery in the case progresses, in view of 

the Court’s final claim construction in this action and in connection with expert reports. 

As one non-limiting example, at least the GE A19 Medium Base LED Filament Bulb includes the features cited in the chart 

below: 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 64 of 123
-2- 

Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

1. A light-emitting device, 

comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light-emitting device. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a light-emitting device. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 65 of 123
-3- 

a carrier having a top surface 

and a bottom surface; 

The GE A19 Medium Base LED Filament Bulb includes a carrier having a top surface and a 

bottom surface. 

For example, as shown in the microscopic images below, the GE A19 Medium Base LED 

Filament Bulb includes a plurality of filaments. Each filament has a transparent carrier having a 

top surface and a bottom surface. 

a first electrode having a first 

part formed on the top 

surface, and a second part 

formed on the bottom 

surface; 

The GE A19 Medium Base LED Filament Bulb includes a first electrode having a first part 

formed on the top surface, and a second part formed on the bottom surface. 

As shown in the microscopic images below, each carrier of each filament includes a first electrode 

with a top part formed on the top surface of the carrier, and a bottom part formed on the bottom 

surface of the carrier. 

bottom surface 

carrier 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 66 of 123
-4- 

As further shown in the images below, each first electrode includes a first part formed on the top 

surface of the carrier, and a bottom part formed on the bottom surface of the carrier. 

second part 

first part 

first electrode 

top surface 

bottom surface

first part 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 67 of 123
-5- 

second part 

bottom surface

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 68 of 123
-6- 

a second electrode having a 

third part formed on the top 

surface, wherein the first part 

and the third part are 

arranged at two opposite 

sides of the carrier; 

The GE A19 Medium Base LED Filament Bulb includes a second electrode having a third part 

formed on the top surface, wherein the first part and the third part are arranged at two opposite 

sides of the carrier. 

As shown in the microscopic image below, each carrier of each filament includes a second 

electrode with a top part formed on the top surface of the carrier, the second electrode being 

positioned on the opposite side of the first electrode, the top part of the first electrode and the top 

part of the second electrode are arranged at two opposite sides of the carrier. 

As further shown in the image below, each second electrode includes a third part formed on the 

top surface of the carrier. 

first part third part

second electrode 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 69 of 123
-7- 

third part 

top surface

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 70 of 123
-8- 

a first light-emitting unit 

disposed on the top surface 

and electrically connected to 

the first electrode; and 

The GE A19 Medium Base LED Filament Bulb includes a first light-emitting unit disposed on the 

top surface and electrically connected to the first electrode. 

As shown in the microscopic images below, a LED chip is disposed on the top surface of the 

carrier and electrically connected to the first electrode. 

first light-emitting unit 

top surface 

first electrode 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 71 of 123
-9- 

a transparent body covering 

the first part, the second part, 

the third part and the first 

light-emitting unit. 

The GE A19 Medium Base LED Filament Bulb includes a transparent body covering the first part, 

the second part, the third part and the first light-emitting unit. 

As shown in the images below, the first and second electrodes of each carrier, including the top 

parts and bottom parts of the first and second electrodes, and a plurality of LED chips are covered 

by a transparent body. 

transparent body first part 

second part 

third part 

first light-emitting unit 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 72 of 123
-10- 

transparent body 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 73 of 123
-11- 

2. The light-emitting device 

of claim 1, wherein the first 

part overlaps the second part.

The GE A19 Medium Base LED Filament Bulb includes a first electrode having a first part 

formed on the top surface, and a second part formed on the bottom surface, wherein the first part 

overlaps the second part. 

As shown in the microscopic images below, each carrier of each filament includes a first electrode 

with a top part formed on the top surface of the carrier, and a bottom part formed on the bottom 

surface of the carrier. As shown, the first part overlaps the second part. 

second part 

first part 

first electrode 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 74 of 123
-12- 

3. The light-emitting device 

of claim 1, wherein the 

carrier comprises a 

transparent material or a 

non-transparent material. 

The GE A19 Medium Base LED Filament Bulb includes a carrier that comprises a transparent 

material. 

For example, as shown in the microscopic images below, the GE A19 Medium Base LED 

Filament Bulb includes a plurality of filaments. Each filament has a transparent carrier having a 

top surface and a bottom surface. 

bottom surface 

carrier 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 75 of 123
-13- 

4. The light-emitting device 

of claim 1, wherein the 

carrier has a side surface and 

the first part extends beyond 

the side surface. 

The GE A19 Medium Base LED Filament Bulb includes a carrier wherein the carrier has a side 

surface and the first part extends beyond the side surface. 

For example, as shown in the microscopic images below, the GE A19 Medium Base LED 

Filament Bulb includes a plurality of filaments. Each filament has a transparent carrier having a 

top surface and a bottom surface. 

As further shown in the image below, the first part is formed on the top surface of the carrier, and 

extends beyond the side surface. 

bottom surface 

carrier 

top surface 

side surface 

first part 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 76 of 123
-14- 

top surface 

side surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 77 of 123
-15- 

5. The light-emitting device 

of claim 1, wherein the first 

part and the third part are 

electrically separated from 

each other when the first 

light-emitting unit is not 

disposed on the top surface. 

The GE A19 Medium Base LED Filament Bulb includes a first part, a second part, and a third part 

wherein the first part and the third part are electrically separated from each other when the first 

light-emitting unit is not disposed on the top surface. 

As shown in the image below, the first part is spaced apart from the third part, and when the first 

light-emitting unit is not disposed on the top surface, the first part and the third part are 

electrically separated from each other. 

first part 

second part 

third part 

first light-emitting unit 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 78 of 123
-16- 

6. The light-emitting device 

of claim 1, wherein the 

second electrode has a fourth 

part formed on the bottom 

surface and electrically 

connected to the third part. 

The GE A19 Medium Base LED Filament Bulb includes a first part, a second part, and a third part 

wherein the first part and the third part are electrically separated from each other when the first 

light-emitting unit is not disposed on the top surface. 

As shown in the image below, the second electrode has a fourth part formed on the bottom and 

electrically connected to the third part. 

first part 

second part 

third part 

fourth part 

first electrode 

second electrode 

second 

electrode

bottom surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 79 of 123
-17- 

7. The light-emitting device 

of claim 6, wherein the 

transparent body covers the 

third part and fourth part. 

The GE A19 Medium Base LED Filament Bulb includes a transparent body that covers the third 

part and fourth part. 

As shown in the image below, the transparent body covers the third part and fourth part. 

first part 

second part 

third part 

fourth part 

first electrode 

second electrode 

second 

electrode

bottom surface 

transparent body 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 80 of 123
-18- 

8. The light-emitting device 

of claim 1, further 

comprising a connector 

electrically and physically 

connected to the first part 

and the second part. 

The GE A19 Medium Base LED Filament Bulb includes a connector electrically and physically 

connected to the first part and the second part. 

As shown in the images below, the first part is electrically connected to the second part via a 

connector. 

first part 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 81 of 123
-19- 

second part 

bottom surface

connector 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 82 of 123
-20- 

9. The light-emitting device 

of claim 8, wherein the 

connector covers a side 

surface of the carrier. 

The GE A19 Medium Base LED Filament Bulb includes a connector electrically and physically 

connected to the first part and the second part, wherein the connector covers a side surface of the 

carrier. 

As shown in the images below, the connector wraps around the carrier and covers a side surface of 

the carrier. 

first part 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 83 of 123
-21- 

second part 

bottom surface

connector 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 84 of 123
-22- 

10. The light-emitting device 

of claim 8, wherein the 

connector is shorter than the 

first part. 

The GE A19 Medium Base LED Filament Bulb includes a connector that is shorter than the first 

part. 

As shown in the images below, the connector wraps around the carrier and is shorter than the first 

part. 

first part 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 85 of 123
-23- 

second part 

bottom surface

connector 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 86 of 123
-24- 

11. The light-emitting device 

of claim 1, further 

comprising a second lightemitting unit, wherein the 

second light-emitting unit 

and the first electrode are 

arranged on opposite sides of 

the first light-emitting unit. 

The GE A19 Medium Base LED Filament Bulb includes a second light-emitting unit, wherein the 

second light-emitting unit and the first electrode are arranged on opposite sides of the first lightemitting unit. 

As illustrated in the image below, a second light-emitting unit is arranged on the right of the first 

light light-emitting unit, where the first electrode is arranged on the left side of the first lightemitting unit. 

first light-emitting unit 

second light-emitting unit first electrode 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 87 of 123
-25- 

13. The light-emitting device 

of claim 1, wherein the first 

light-emitting unit comprises 

a plurality of connecting 

pads, the plurality of 

connecting pads is formed 

on a same side of the first 

light-emitting unit. 

The GE A19 Medium Base LED Filament Bulb includes a plurality of connecting pads in the first 

light-emitting unit, the plurality of connecting pads is formed on a same side of the first lightemitting unit. 

For example, as shown in the images below, the GE A19 Medium Base LED Filament Bulb 

includes a plurality of connecting pads on a same side of the first light-emitting unit under the 

electrodes. 

first electrode 

active layer 

second electrode 

connecting pad 

connecting pad 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 88 of 123
-26- 

14. The light-emitting device 

of claim 1, wherein the first 

electrode fully covers an end 

portion of the carrier in a top 

view. 

The GE A19 Medium Base LED Filament Bulb includes a first electrode fully covering an end 

portion of the carrier in a top view. 

As shown in the images below, the first electrode fully wraps around an end portion of the carrier 

in a top view. 

first part 

carrier 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 89 of 123
-27- 

15. The light-emitting device 

of claim 1, wherein the 

transparent body comprises a 

wavelength conversion layer.

The GE A19 Medium Base LED Filament Bulb includes a transparent body wherein the 

transparent body comprises a wavelength conversion layer. 

As illustrated in the image below, a transparent body covers the carrier, the plurality of lightemitting units (chips). The transparent body alters the light wavelength as light emits from the 

light-emitting units (chips). 

transparent body 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 90 of 123
-28- 

16. The light-emitting device 

of claim 1, wherein the 

carrier has a side surface 

devoid of the transparent 

body. 

The GE A19 Medium Base LED Filament Bulb includes a carrier with a side surface devoice of 

the transparent body. 

As illustrated in the image below, a side surface of the carrier is not covered by the transparent 

body. 

transparent body side surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 91 of 123
-29- 

19. A light-emitting device, 

comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light-emitting device. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb 

includes a light-emitting device. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 92 of 123
-30- 

a carrier having a top surface 

and a bottom surface; 

The GE A19 Medium Base LED Filament Bulb includes a carrier having a top surface and a 

bottom surface. 

For example, as shown in the microscopic images below, the GE A19 Medium Base LED 

Filament Bulb includes a plurality of filaments. Each filament has a transparent carrier having a 

top surface and a bottom surface. 

bottom surface 

carrier 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 93 of 123
-31- 

a first electrode having a first 

part formed on the top 

surface and a second part 

formed on the bottom 

surface; 

The GE A19 Medium Base LED Filament Bulb includes a first electrode having a first part 

formed on the top surface and a second part formed on the bottom surface. 

As shown in the microscopic images below, each carrier of each filament includes a first electrode 

with a top part formed on the top surface of the carrier, and a bottom part formed on the bottom 

surface of the carrier. 

As further shown in the images below, each first electrode includes a first part formed on the top 

surface of the carrier, and a bottom part formed on the bottom surface of the carrier. 

second part 

first part 

first electrode 

top surface 

bottom surface

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 94 of 123
-32- 

first part 

top surface 

second part 

bottom surface

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 95 of 123
-33- 

a second electrode having a 

third part formed on the top 

surface, wherein the first part 

and the third part are 

arranged at two opposite 

sides of the carrier; 

The GE A19 Medium Base LED Filament Bulb includes a second electrode having a third part 

formed on the top surface, wherein the first part and the third part are arranged at two opposite 

sides of the carrier. 

As shown in the microscopic image below, each carrier of each filament includes a second 

electrode with a top part formed on the top surface of the carrier, the second electrode being 

positioned on the opposite side of the first electrode, the top part of the first electrode and the top 

part of the second electrode are arranged at two opposite sides of the carrier. 

As further shown in the image below, each second electrode includes a third part formed on the 

top surface of the carrier. 

first part third part

second electrode 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 96 of 123
-34- 

third part 

top surface

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 97 of 123
-35- 

a plurality of light-emitting 

units disposed on the top 

surface and electrically 

connected to the first 

electrode; and 

The GE A19 Medium Base LED Filament Bulb includes a plurality of light-emitting units 

disposed on the top surface and electrically connected to the first electrode. 

As illustrated in the image below, a plurality of light-emitting units disposed on the top surface. 

As shown in the close-up image below, the plurality of light-emitting units are electrically 

connected to the first electrode. 

light-emitting unit 

light-emitting unit first electrode 

electrically connected 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 98 of 123
-36- 

a wavelength conversion 

layer covering the first part, 

the second part, the third part 

and the plurality of lightemitting units. 

The GE A19 Medium Base LED Filament Bulb includes a wavelength conversion layer covering 

the first part, the second part, the third part and the plurality of light-emitting units. 

As shown in the images below, the first and second electrodes of each carrier, including the top 

parts and bottom parts of the first and second electrodes, and a plurality of LED chips are covered 

by a wavelength conversion layer. 

transparent body first part 

second part 

third part 

first light-emitting unit 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 99 of 123
-37- 

wavelength conversion layer 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 100 of 123
-38- 

20. The light-emitting device 

of claim of 19, further 

comprising a connector 

electrically and physically 

connected to the first part 

and the second part. 

The GE A19 Medium Base LED Filament Bulb includes a connector electrically and physically 

connected to the first part and the second part. 

As shown in the images below, the first part is electrically connected to the second part via a 

connector. 

first part 

top surface 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 101 of 123
-39- 

second part 

bottom surface

connector 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 102 of 123
EXHIBIT 5 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 103 of 123
Exhibit 5: Infringement Claim Chart for U.S. Patent No. 10,224,455 

The Defendants infringe U.S. Patent No. 10,224,455 (“the ’455 Patent”) by making, using, selling, offering for sale, and 

importing at least certain GE Classic Series lightbulbs, GE Refresh Series lightbulbs, GE Relax Series lightbulbs, GE Basic Series 

lightbulbs, GE Reveal Series lightbulbs, and GE Vintage Series lightbulbs that include one or more LED filaments (the “Accused 

Product”). 

The asserted claims include elements that are implemented, at least in part, by proprietary hardware in the Accused Product. 

Plaintiff has provided these contentions based on analyzing the GE A19 Medium Base LED Filament Bulb as well as a review of 

the publicly available materials regarding the Accused Product. The chart is merely exemplary and may not show the functionality 

in its entirety. Furthermore, Plaintiff reserves the right to revise these contentions as discovery in the case progresses, in view of 

the Court’s final claim construction in this action and in connection with expert reports. 

As one non-limiting example, at least the GE A19 Medium Base LED Filament Bulb includes the features cited in the chart 

below: 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 104 of 123
-2- 

Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

1. A light-emitting device, 

comprising: 

The GE A19 Medium Base LED Filament Bulb includes a light-emitting device. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a light-emitting device. 

an epitaxial structure 

comprising an active layer; 

The GE A19 Medium Base LED Filament Bulb includes an epitaxial structure comprising an active 

layer. 

For example, as shown in the microscopic images below, the GE A19 Medium Base LED Filament 

Bulb includes a plurality of filaments. 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 105 of 123
-3- 

Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

Each filament has a plurality of epitaxial structures. 

Each epitaxial structure has an active layer. 

epitaxial structure 

Case 6:20-cv-00420-ADA Document 53-2 Filed 04/23/21 Page 106 of 123
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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

a transparent substrate 

having a top surface being 

not less than 1.6 times an 

area of the active layer; 

The GE A19 Medium Base LED Filament Bulb includes an epitaxial structure comprising an active 

layer and a transparent substrate having a top surface being not less than 1.6 times an area of the 

active layer. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a 

transparent substrate having a top surface being not less than 1.6 times an area of the active layer. 

Width of the transparent substrate: not less than 1.6 times width of the active layer 

active layer 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

a first transparent layer, 

directly connected to the 

transparent substrate and 

comprising a widest width 

smaller than that of the 

transparent substrate and 

larger than that of the 

epitaxial structure; 

The GE A19 Medium Base LED Filament Bulb includes a first transparent layer, directly connected 

to the transparent substrate and comprising a widest width smaller than that of the transparent 

substrate and larger than that of the epitaxial structure. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a transparent adhesive layer directly connected to the transparent substrate, and comprising a widest 

width 

smaller than that of the transparent substrate, but larger than that of the epitaxial structure. 

top 

surface 

bottom surface 

transparent 

substrate 

Width of the active layer 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

width of the first transparent layer 

width of the epitaxial structure 

transparent 

substrate 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

Based on a material analysis, the material for the first transparent layer is silicone-based. 

a second transparent layer, 

made of oxygen and only 

one metallic element, 

arranged between the first 

The GE A19 Medium Base LED Filament Bulb includes a second transparent layer, made of 

oxygen and only one metallic element, arranged between the first transparent layer and the epitaxial 

structure. 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

transparent layer and the 

epitaxial structure; and 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a second transparent layer arranged between the first transparent layer and the epitaxial structure 

The EDX analysis of the second transparent layer shows that it is made of oxygen and only one 

metallic element. 

second transparent layer 

first transparent layer 

epitaxial structure 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

a first electrode arranged 

on the first transparent 

layer and the second 

transparent layer which are 

not covered by the active 

layer, 

The GE A19 Medium Base LED Filament Bulb includes a first electrode arranged on the first 

transparent layer and the second transparent layer which are not covered by the active layer. 

For example, as shown in the images below, the GE A19 Medium Base LED Filament Bulb 

includes a first electrode arranged on the first transparent layer and the second transparent layer 

which are not 

covered by the active layer. 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

first electrode 

second transparent layer 

first transparent layer 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

wherein the second 

transparent layer and the 

transparent substrate have 

outmost sidewalls which 

are not coplanar with each 

other. 

The GE A19 Medium Base LED Filament Bulb includes the second transparent layer and the 

transparent substrate have outmost sidewalls which are not coplanar with each other. 

For example, as shown in the images below, in the GE A19 Medium Base LED Filament Bulb, the 

second 

transparent layer and the transparent substrate have outmost sidewalls which are not coplanar with 

each other. 

first electrode 

active layer 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

3. The light-emitting 

device of claim 1, wherein 

The GE A19 Medium Base LED Filament Bulb includes a transparent substrate wherein the 

transparent substrate has a bottom surface being not less than 1.6 times the area of the active layer.

outmost sidewall of 

second transparent 

layer 

outmost sidewall of 

transparent substrate 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

the transparent substrate 

has a bottom surface being 

not less than 1.6 times the 

area of the active layer. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a 

transparent substrate having a bottom surface being not less than 1.6 times an area of the active 

layer. 

top 

surface 

bottom surface 

transparent 

substrate 

Width of the transparent substrate: not less than 1.6 times width of the active layer 

Width of the active layer 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

5. The light-emitting 

device of claim 3, wherein 

the top surface and the 

bottom surface 

substantially have the same 

width. 

The GE A19 Medium Base LED Filament Bulb includes a transparent substrate, wherein the top 

surface and the bottom surface of the transparent substrate substantially have the same width. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

a 

transparent substrate having a top surface and a bottom surface being substantially have the same 

width. 

6. The light-emitting 

device of claim 1, wherein 

the active layer is narrower 

than the second transparent 

layer. 

The GE A19 Medium Base LED Filament Bulb includes an active layer narrower than the second 

transparent layer. 

For example, as shown in the image below, the GE A19 Medium Base LED Filament Bulb includes 

an active layer that is narrower than the second transparent layer. 

top surface width 

bottom surface width 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

9. The light-emitting 

device of claim 1, wherein 

the transparent substrate is 

made of a nonsemiconductor material.

The GE A19 Medium Base LED Filament Bulb includes a transparent substrate, wherein the 

transparent substrate is made of a non-semiconductor material. 

The transparent as shown in the microscopic image below is not made of a semiconductor material. 

second transparent layer 

active layer 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

10. The light-emitting 

device of claim 1, wherein 

the second transparent 

The GE A19 Medium Base LED Filament Bulb includes a second transparent layer comprising a 

metal oxide. 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

layer comprises a metal 

oxide. 

The EDX analysis of the second transparent layer shows that it is made of a metal oxide. 

12. The light-emitting 

device of claim 1, wherein 

the first electrode is 

separated from the active 

layer. 

The GE A19 Medium Base LED Filament Bulb includes a first electrode wherein the first electrode 

is separated from the active layer. 

For example, as shown in the images below, the GE A19 Medium Base LED Filament Bulb 

includes a filament with a plurality of epitaxial structures, where each epitaxial has an active layer 

and a first electrode separated from each other. 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

13. The light-emitting 

device of claim 1, further 

comprising a second 

The GE A19 Medium Base LED Filament Bulb includes a second electrode arranged on the 

epitaxial structure. 

For example, as shown in the images below, the GE A19 Medium Base LED Filament Bulb 

includes a filament with a plurality of epitaxial structures, where each epitaxial has an active layer.

active layer 

epitaxial structure 

first electrode 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

electrode arranged on the 

epitaxial structure. 

Each epitaxial structure has a second electrode arranged on top. 

active layer 

epitaxial structure 

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Claims Exemplary Disclosures of Technical Features for GE A19 Medium Base LED Filament Bulb 

first electrode 

active layer 

second electrode 

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