Contract analysis

I. EXECUTIVE SUMMARY A. Purpose This memorandum summarizes and annotates the teardown and reverse-engineering report prepared by Benchmark Semiconductor Analysis, LLC ("Benchmark") on the Lumicore Technologies, Inc. ("Lumicore") LumiLink 400G-ZR+ coherent optical transceiver module (the "Accused Product" or "400G-ZR+"). The underlying Benchmark report, dated December 12, 2022, was prepared by Kevin Ng, Lead Engineer

II. PRODUCT IDENTIFICATION AND SAMPLE ACQUISITION A. Product Description The accused product at issue in this teardown report summary is the LumiCore Technologies LumiLink 400G-ZR+ Coherent Optical Transceiver Module. The relevant product details are set forth below: The LumiLink 400G-ZR+ is a pluggable coherent optical transceiver module designed for deployment in data-center interconnect (DCI) and metro networking

III. TEARDOWN METHODOLOGY The Benchmark teardown followed a multi-stage methodology designed to systematically characterize the LumiLink 400G-ZR+ module from external form factor down to subsurface semiconductor structures. The methodology employed is consistent with established practices in the semiconductor reverse-engineering industry, as confirmed by Kevin Ng during his January 7, 2025 deposition. The principal s

X-Ray Imaging. X-ray imaging was performed to visualize the internal module architecture, including the placement and interconnection of major components within the QSFP-DD housing. The X-ray images revealed the spatial arrangement of the silicon photonic integrated circuit (PIC) die, the digital signal processor (DSP) ASIC, the transimpedance amplifier (TIA), the laser driver integrated circuit, and the tunable lase

IV. KEY PHYSICAL FINDINGS This section summarizes the principal physical findings from the Benchmark teardown report that are relevant to the infringement analysis. The findings are organized by structural feature, corresponding to the categories of claims asserted in the three patents at issue. A. Silicon Photonic Integrated Circuit (PIC) Architecture The LumiLink 400G-ZR+ module contains a silicon photonic integrat

V. CLAIM-LIMITATION CROSS-REFERENCE ANALYSIS: '847 PATENT (U.S. PATENT NO. 10,234,847) A. Patent Overview The '847 Patent is directed to a multi-channel silicon photonic waveguide multiplexer designed to achieve low insertion loss. The relevant details of the patent are as follows: The '847 Patent and the '562 Patent share a continuation relationship and are members of the same patent family. This familial relationsh

VI. CLAIM-LIMITATION CROSS-REFERENCE ANALYSIS: '193 PATENT (U.S. PATENT NO. 10,891,193) A. Patent Overview The '193 Patent is directed to a high-bandwidth coherent optical transceiver integrated on a silicon substrate. The relevant details of the patent are as follows: Claims 3 and 7 are asserted under both a theory of literal infringement and the doctrine of equivalents. Claims 1, 10, 15, and 18 are asserted under l

VII. CLAIM-LIMITATION CROSS-REFERENCE ANALYSIS: '562 PATENT (U.S. PATENT NO. 9,678,562) A. Patent Overview The '562 Patent is directed to a method for thermal management of photonic integrated circuits using embedded micro-channel heat sinks. The relevant details of the patent are as follows: The '562 Patent was originally assigned to Solara Optics, Inc., a California corporation that was dissolved in 2020. OWS acqui