Contract analysis

I. EXECUTIVE SUMMARY Purpose. This memorandum summarizes and analyzes the teardown report prepared by Benchmark Semiconductor Analysis, LLC ("Benchmark") for the Lumicore Technologies, Inc. ("Lumicore") LumiEdge 1600G-LR optical transceiver module. The memorandum cross-references the teardown findings to the claim limitations of the two asserted patents relevant to this product: U.S. Patent No. 10,891,193 (the "'193

1. LumiLink 400G-ZR+ — Report delivered December 12, 2022. This was the first teardown commissioned in the matter and supported the original infringement analysis that led to the filing of this action.

2. LumiLink 800G-DR8 — Report delivered June 2023. This teardown was commissioned after Lumicore launched the 800G-DR8 product and Optiwave Semiconductor Corp. ("OWS") identified it as an additional accused product.

3. LumiEdge 1600G-LR — Report delivered February 2024. This teardown is the subject of this memorandum. Product Examined. The product examined was the LumiEdge 1600G-LR transceiver module, manufactured and sold by Lumicore Technologies, Inc. (headquarters: 9200 Spectrum Boulevard, Building C, Austin, TX 78759). The LumiEdge 1600G-LR was launched in Q4 2023 and represents Lumicore's flagship coherent transceiver offer

II. BACKGROUND AND CHAIN OF CUSTODY A. Product Acquisition The LumiEdge 1600G-LR sample units examined in the Benchmark teardown were acquired through commercial distribution channels to ensure the authenticity and provenance of the product. Calderwood & Harkness LLP, on behalf of OWS, directed the acquisition of three (3) sealed LumiEdge 1600G-LR transceiver modules in late Q4 2023, shortly following the product's c

III. PRODUCT OVERVIEW — LUMICORE LumiEdge 1600G-LR A. Product Description The LumiEdge 1600G-LR is a 1600G (1.6 Tbps aggregate) long-reach coherent optical transceiver module designed for hyperscale data-center interconnect ("DCI") and telecom metro/long-haul applications. It represents Lumicore's highest-bandwidth product in its accused product line and is the most recently launched accused product in this litigatio

IV. CLAIM-LIMITATION CROSS-REFERENCE ANALYSIS — '193 PATENT (U.S. Patent No. 10,891,193) A. Patent Overview The '193 Patent, titled "High-Bandwidth Coherent Optical Transceiver Integrated on Silicon Substrate," was filed on April 7, 2017, claiming priority to Provisional Application No. 62/499,117, also filed on April 7, 2017. The patent issued on January 12, 2021. The original and current assignee is Optiwave Semico

1. A grating coupler, described at col. 7, ll. 14–35 and illustrated in Figures 4A–4C of the '193 Patent.

2. An edge coupler (also referred to as a "butt coupler" or "spot-size converter"), described at col. 7, ll. 36–48 and illustrated in Figure 4D of the '193 Patent. The Benchmark teardown identifies grating coupler structures at the fiber-to-chip interface of the LumiEdge 1600G-LR PIC die. As discussed in Section V (regarding the '015 Patent claims), the grating coupler is characterized in detail through SEM imaging,

V. CLAIM-LIMITATION CROSS-REFERENCE ANALYSIS — '015 PATENT (U.S. Patent No. 11,402,015) A. Patent Overview The '015 Patent, titled "Polarization-Diverse Grating Coupler for Silicon Photonic Transceivers," was filed on August 30, 2019, claiming priority to Provisional Application No. 62/499,117, filed April 7, 2017. The '015 Patent thus shares the same provisional priority date as the '193 Patent. The patent issued on