Contract analysis

1. INTRODUCTION AND PURPOSE This memorandum summarizes and analyzes the findings of Benchmark Semiconductor Analysis, LLC ("Benchmark"), located at 2244 Mission College Boulevard, Santa Clara, California 95054, in its follow-on teardown and reverse-engineering analysis of Lumicore Technologies, Inc.'s ("Lumicore") LumiLink 800G-DR8 transceiver module. Benchmark's Lead Engineer, Kevin Ng, personally conducted the tear

2. PRODUCT OVERVIEW — LUMILINK 800G-DR8 2.1 Product Description and Commercial Context The LumiLink 800G-DR8 is an 800-Gigabit-per-second silicon-photonics transceiver module designed and manufactured by Lumicore Technologies, Inc. for deployment in hyperscale data-center interconnect applications. The product is engineered for short-reach optical links — up to 2 km over single-mode fiber — and is marketed to hypersc

3. TEARDOWN METHODOLOGY 3.1 Procedures Benchmark followed its standard semiconductor teardown and reverse-engineering protocol in analyzing the LumiLink 800G-DR8. This protocol is consistent with the methodology employed by Benchmark in its prior teardown of the LumiLink 400G-ZR+ (as documented in Benchmark's December 12, 2022 report), ensuring methodological continuity across the two analyses and enabling direct com

4. KEY TECHNICAL FINDINGS The following subsections summarize the principal technical findings of Benchmark's teardown analysis that are relevant to the infringement analysis for each of the four asserted patents. Each finding is described in terms of the physical structure and features identified in the LumiLink 800G-DR8, the technical detail supporting the identification, and the relevance of the finding to specifi

5. CLAIM-LIMITATION CROSS-REFERENCE TABLES This section presents element-by-element cross-reference tables mapping each limitation of the asserted claims of the four patents-in-suit to the corresponding structure or feature of the LumiLink 800G-DR8 identified in Benchmark's teardown analysis. These tables are organized by patent and are intended to serve as a working reference for the case team in preparing infringem

6. COMPARISON TO LUMILINK 400G-ZR+ TEARDOWN FINDINGS The LumiLink 800G-DR8 is architecturally an evolution of the LumiLink 400G-ZR+, Lumicore's first-generation silicon-photonics transceiver module, which was commercially launched in Q3 2022 and was the subject of Benchmark's initial teardown report delivered on December 12, 2022. A comparison between the two products is instructive both for understanding the technic

7. IMPLICATIONS FOR WILLFUL INFRINGEMENT ANALYSIS The Benchmark teardown findings, when combined with the discovery and deposition record developed in this matter, support a strong case for willful infringement with respect to the LumiLink 800G-DR8. The following facts are relevant to the willfulness analysis under Halo Electronics, Inc. v. Pulse Electronics, Inc., 579 U.S. 93 (2016), and the Read factors. Pre-Launch

8. AREAS REQUIRING FURTHER INVESTIGATION 8.1 Supplemental Analysis with Lumicore Design Files Lumicore's photonic-IC layout files and register-transfer-level (RTL) schematics for the LumiLink 800G-DR8 were produced during discovery under the "Highly Confidential — Source Code" designation of the Protective Order entered by Judge Gilstrap. These design files provide a digital representation of the PIC layout at mask-l