INFRINGEMENT CLAIM CHART
U.S. PATENT NO. 10,891,193
("'193 PATENT")
Claims 1, 3, 7, 10, 15, 18
September 16, 2024
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INTRODUCTION
Plaintiff Optiwave Semiconductor Corp. ("OWS" or "Plaintiff") hereby serves these Infringement Contentions pursuant to P.R. 3-1 of the Patent Rules of the United States District Court for the Eastern District of Texas. This Infringement Claim Chart sets forth OWS's detailed identification of each claim of U.S. Patent No. 10,891,193 (the "'193 Patent") that OWS contends is infringed by Defendant Lumicore Technologies, Inc. ("Lumicore" or "Defendant"), along with a detailed mapping of each claim limitation to corresponding elements, structures, or method steps found in Lumicore's accused products.
The '193 Patent, entitled "High-Bandwidth coherent Optical Transceiver Integrated on Silicon Substrate," is directed to a coherent optical transceiver fabricated on a silicon photonic platform. The invention described and claimed in the '193 Patent addresses long-standing challenges in the design and manufacture of high-bandwidth coherent optical transceivers for data-center interconnect and telecommunications applications. The '193 Patent claims priority to Provisional Application No. 62/499,117, filed April 7, 2017, and was issued on January 12, 2021. OWS is the original and current assignee of the '193 Patent and possesses all rights, title, and interest in the patent, including the right to enforce the patent and recover damages for past infringement.
OWS asserts Claims 1, 3, 7, 10, 15, and 18 of the '193 Patent against three Lumicore products identified below. OWS's theories include literal infringement for all asserted claims and, in the alternative, infringement under the doctrine of equivalents for Claims 3 and 7, as further detailed herein.
ACCUSED PRODUCTS
OWS accuses the following Lumicore products of infringing Claims 1, 3, 7, 10, 15, and 18 of the '193 Patent:
1. LumiLink 400G-ZR+. The LumiLink 400G-ZR+ is a coherent optical transceiver module designed for data-center interconnect and metro-network applications operating at an aggregate data rate of 400 Gbps. Lumicore launched the LumiLink 400G-ZR+ in the third quarter of 2022. Based on publicly available information and documents produced in discovery, the LumiLink 400G-ZR+ generated approximately $94.8 million in revenue during fiscal year 2023. The LumiLink 400G-ZR+ is accused of infringing Claims 1, 3, 7, 10, 15, and 18 of the '193 Patent.
2. LumiLink 800G-DR8. The LumiLink 800G-DR8 is a coherent optical transceiver module designed for high-density data-center interconnect applications operating at an aggregate data rate of 800 Gbps. Lumicore launched the LumiLink 800G-DR8 in the first quarter of 2023. Based on publicly available information and documents produced in discovery, the LumiLink 800G-DR8 generated approximately $128.4 million in revenue during fiscal year 2023. The LumiLink 800G-DR8 is accused of infringing Claims 1, 3, 7, 10, 15, and 18 of the '193 Patent.
3. LumiEdge 1600G-LR. The LumiEdge 1600G-LR is a coherent optical transceiver module designed for long-reach data-center interconnect and wide-area network applications operating at an aggregate data rate of 1600 Gbps. Lumicore launched the LumiEdge 1600G-LR in the fourth quarter of 2023. Based on publicly available information and documents produced in discovery, the LumiEdge 1600G-LR generated approximately $41.7 million in revenue during fiscal year 2023. The LumiEdge 1600G-LR is accused of infringing Claims 1, 3, 7, 10, 15, and 18 of the '193 Patent.
Total accused-product FY 2023 revenue: approximately $264.9 million. Total accused-product revenue for the infringement period (Q3 2022 through Q1 2024): approximately $378.2 million.
Evidence Sources. OWS's infringement analysis is based on the following categories of evidence, among others:
• Benchmark Semiconductor Analysis, LLC Teardown Reports. Three independent teardown reports were commissioned and prepared by Benchmark Semiconductor Analysis, LLC, located at 2244 Mission College Boulevard, Santa Clara, CA 95054, under the direction of Kevin Ng, Lead Engineer. The teardown reports include: (i) LumiLink 400G-ZR+ teardown report, dated December 12, 2022; (ii) LumiLink 800G-DR8 teardown report, dated June 2023; and (iii) LumiEdge 1600G-LR teardown report, dated February 2024. Each report includes annotated die photographs, scanning electron microscope (SEM) images, energy-dispersive X-ray spectroscopy (EDS) analysis, and functional characterization data.
• Lumicore Design Documents and Engineering Specifications. Lumicore has produced, pursuant to the Court's Scheduling Order and the parties' agreed discovery protocols, design documents, engineering specifications, layout files, and related technical documentation for each accused product. Key Bates ranges are identified in the claim mappings below and consolidated in Appendix 3.
• Publicly Available Datasheets and Marketing Materials. Lumicore has published product datasheets, technical briefs, white papers, and marketing materials for each of the accused products. These materials are publicly available on Lumicore's website and have been collected and preserved by OWS.
• Deposition Testimony. OWS has taken the deposition of Dr. Sandra Michaud, Chief Technology Officer of Lumicore Technologies, Inc., on November 19, 2024. Dr. Michaud's testimony provides direct admissions regarding the design, architecture, and functionality of each accused product. Additional depositions of Lumicore personnel may be cited in supplemental filings.
• Lumicore SEC Filings. Lumicore's 10-K filings and annual reports describe the company's product lines, revenue breakdown, and market positioning for the accused products.
• Lumicore Application Notes and Customer Deployment Guides. These documents describe the operation and deployment of the accused products in customer environments, providing evidence of method-of-use infringement.
• Lumicore Product Qualification Reports. Internal product qualification reports confirm the performance parameters of the accused products under test conditions.
• Conference Presentations. Presentations by Lumicore personnel at industry conferences, including the Optical Fiber Communications Conference (OFC) and the European Conference on Optical Communication (ECOC), describe the architecture and performance of the accused products.
INFRINGEMENT THEORIES
Literal Infringement. OWS asserts literal infringement of Claims 1, 3, 7, 10, 15, and 18 of the '193 Patent by each of the three accused products. OWS's primary theory of infringement for all asserted claims is literal infringement. As detailed in the claim mappings below, each limitation of each asserted claim is met, element-by-element, by corresponding structures, elements, or method steps present in the accused products.
Doctrine of Equivalents. In addition to literal infringement, OWS asserts infringement of Claims 3 and 7 under the doctrine of equivalents. Specifically, to the extent Lumicore argues that its accused designs do not literally satisfy the "coherent detection module" limitation of Claims 3 and 7 (which depend from Claim 1), OWS contends that the corresponding elements in the accused products perform substantially the same function, in substantially the same way, to achieve substantially the same result as the claimed "coherent detection module" element. The function-way-result analysis for each of these claims is set forth in detail in Sections 2.3 and 3.3 below.
Prosecution History Estoppel. OWS acknowledges that during prosecution of the '193 Patent, the "coherent detection module" limitation was narrowed in response to a rejection under 35 U.S.C. § 102 over Takahashi et al., "Dense WDM Silicon Photonic MUX," published in IEEE Photonics Technology Letters, March 2014. OWS's position is that prosecution history estoppel does not bar the application of the doctrine of equivalents for Claims 3 and 7 because the amendment was tangential to the equivalent at issue. Specifically, the narrowing amendment was directed to distinguishing Takahashi's non-coherent WDM demultiplexer architecture and did not address or surrender the polarization-diversity receiver architecture or DSP integration approach used in Lumicore's accused products. Accordingly, the Festo tangential-relation exception applies. See Festo Corp. v. Fenmore & Co., 535 U.S. 722, 740–41 (2002); Honeywell Int'l, Inc. v. Hamilton Sundstrand Corp., 370 F.3d 1131, 1141–42 (Fed. Cir. 2004) (en banc). A separate internal prosecution history estoppel analysis memorandum, dated October 10, 2024, addresses this issue in further detail and is incorporated by reference herein.
IDENTIFICATION OF ASSERTED CLAIMS
The following claims of the '193 Patent are asserted against the accused products:
The full text of each asserted claim is reproduced verbatim in Appendix 1 to this Claim Chart.
SECTION 1: CLAIM 1 — INDEPENDENT CLAIM (Literal Infringement)
Claim 1 of the '193 Patent is an independent apparatus claim directed to a coherent optical transceiver integrated on a silicon substrate. OWS asserts that each of the three accused products — the LumiLink 400G-ZR+, the LumiLink 800G-DR8, and the LumiEdge 1600G-LR — literally infringes every limitation of Claim 1. The detailed element-by-element mapping is set forth below.
1.1 Claim 1 Preamble
Claim Language:
"A coherent optical transceiver integrated on a silicon substrate, comprising:"
OWS's Proposed Claim Construction. OWS has proposed the following construction for the term "integrated on a silicon substrate": "formed on or within a silicon-based wafer using semiconductor fabrication processes." This construction was set forth in the parties' Joint Claim Construction Statement filed on October 28, 2024. The term "integrated on a silicon substrate" is a disputed term. Lumicore proposes the construction "monolithically fabricated on a single silicon die without hybrid bonding or heterogeneous integration." OWS contends that Lumicore's proposed construction is improperly narrow and unsupported by the intrinsic record, as the '193 Patent specification expressly contemplates heterogeneous integration approaches (see, e.g., '193 Patent, col. 4, ll. 22–38; col. 6, ll. 10–25) and does not limit the claims to monolithic fabrication on a single die.
Regardless of which construction is adopted, each of the three accused products satisfies the preamble of Claim 1, as set forth below.
Accused Product — LumiLink 400G-ZR+:
The LumiLink 400G-ZR+ contains a silicon photonic integrated circuit (PIC) fabricated on a silicon-on-insulator (SOI) wafer. The Benchmark Semiconductor Analysis, LLC teardown report, dated December 12, 2022, identifies the LumiLink 400G-ZR+ as containing a silicon PIC with coherent transceiver functionality fabricated using CMOS-compatible silicon photonics processes on an SOI platform. Lumicore's own marketing materials describe the LumiLink 400G-ZR+ as employing "silicon photonics integration" for coherent optical transmission at 400 Gbps. Lumicore design documents produced in discovery, Bates Nos. LTC-00045231 through LTC-00045298, confirm that the transceiver is fabricated using CMOS-compatible silicon photonics processes on a silicon substrate. Additionally, Dr. Sandra Michaud, Lumicore's Chief Technology Officer, confirmed in her deposition on November 19, 2024, at pages 87:14 through 88:22, that the LumiLink 400G-ZR+ transceiver is fabricated on a silicon substrate. Dr. Michaud testified that the PIC is fabricated on an SOI wafer with a 220-nanometer top silicon layer, consistent with standard silicon photonics fabrication processes.
The LumiLink 400G-ZR+ is a "coherent optical transceiver" because it transmits and receives optical signals using coherent modulation and detection techniques, as further detailed in the limitations mapped below. The product is "integrated on a silicon substrate" under OWS's proposed construction because the PIC is formed on and within a silicon-based SOI wafer using semiconductor fabrication processes, including photolithography, etching, ion implantation, and thin-film deposition.
Accused Product — LumiLink 800G-DR8:
The LumiLink 800G-DR8 contains a silicon PIC fabricated on an SOI wafer with a multi-channel coherent transceiver architecture. The Benchmark teardown report, dated June 2023, identifies the LumiLink 800G-DR8 as incorporating a silicon photonic PIC on an SOI wafer. Lumicore datasheets for the LumiLink 800G-DR8 specify silicon-photonic integration for 800 Gbps data-center interconnect. Design specifications produced in discovery, Bates Nos. LTC-00078412 through LTC-00078503, describe the transceiver fabrication on silicon substrates using an SOI platform with CMOS-compatible processing. The LumiLink 800G-DR8 is a coherent optical transceiver integrated on a silicon substrate within the meaning of the Claim 1 preamble.
Accused Product — LumiEdge 1600G-LR:
The LumiEdge 1600G-LR contains a silicon photonic PIC fabricated on an SOI substrate with coherent transceiver functionality. The Benchmark teardown report, dated February 2024, confirms a silicon photonic PIC on an SOI substrate with coherent transceiver functionality supporting 1600 Gbps aggregate data rates. Lumicore product briefs and conference presentations describe the LumiEdge 1600G-LR as a "next-generation silicon-photonics-based coherent transceiver module" designed for long-reach data-center interconnect and wide-area network applications. Design files produced in discovery, Bates Nos. LTC-00112045 through LTC-00112189, confirm the SOI-based silicon photonic fabrication of the transceiver PIC. The LumiEdge 1600G-LR is a coherent optical transceiver integrated on a silicon substrate within the meaning of the Claim 1 preamble.
1.2 Claim 1, Limitation [a]
Claim Language:
"a transmitter section comprising at least one optical modulator formed in a silicon waveguide, the optical modulator configured to modulate an optical carrier signal with data at a rate of at least 100 Gbps per channel;"
This limitation requires: (i) a transmitter section; (ii) comprising at least one optical modulator; (iii) the optical modulator being formed in a silicon waveguide; and (iv) the optical modulator being configured to modulate an optical carrier signal with data at a per-channel data rate of at least 100 Gbps.
Accused Product — LumiLink 400G-ZR+:
The Benchmark teardown report, dated December 12, 2022, identifies Mach-Zehnder modulators (MZMs) formed in silicon rib waveguides on the silicon PIC of the LumiLink 400G-ZR+. The teardown analysis confirmed that the modulators are patterned in the top silicon layer of the SOI wafer, with p-n junction phase shifters formed by ion implantation in the silicon waveguide arms. Annotated teardown photographs (Benchmark Report, Figures 12 through 15) clearly show the silicon waveguide modulator structures, including the MZM interference arms, traveling-wave electrode structures, and waveguide routing to and from the modulator sections.
Each modulator channel in the LumiLink 400G-ZR+ operates at approximately 100 Gbps, with four channels providing an aggregate data rate of 400 Gbps (4 channels × 100 Gbps per channel = 400 Gbps aggregate). Lumicore specifications produced in discovery, Bates Nos. LTC-00045340 through LTC-00045367, describe the modulation scheme employed by the LumiLink 400G-ZR+ as dual-polarization QPSK operating at approximately 100 Gbaud per channel. This per-channel data rate of approximately 100 Gbps satisfies the claim requirement of "at least 100 Gbps per channel."
The transmitter section of the LumiLink 400G-ZR+ therefore comprises at least one optical modulator formed in a silicon waveguide, configured to modulate an optical carrier signal with data at a rate of at least 100 Gbps per channel, as required by this limitation.
Accused Product — LumiLink 800G-DR8:
The Benchmark teardown report, dated June 2023, confirms an 8-channel silicon MZM array in the LumiLink 800G-DR8, with each channel operating at 100 Gbps to provide an aggregate data rate of 800 Gbps (8 channels × 100 Gbps per channel = 800 Gbps aggregate). Design documents produced in discovery, Bates Nos. LTC-00078560 through LTC-00078601, specify the per-channel modulation rates and confirm that the modulators are formed in silicon waveguides on the SOI PIC. Teardown photographs from the Benchmark Report, Figures 8 through 14, identify the silicon waveguide modulators on the PIC die. The transmitter section of the LumiLink 800G-DR8 satisfies this limitation.
Accused Product — LumiEdge 1600G-LR:
The Benchmark teardown report, dated February 2024, identifies a 16-channel modulator array in silicon waveguides on the LumiEdge 1600G-LR PIC, with each channel operating at 100 Gbps to provide an aggregate data rate of 1600 Gbps (16 channels × 100 Gbps per channel = 1600 Gbps aggregate). Design files produced in discovery, Bates Nos. LTC-00112210 through LTC-00112278, confirm the per-channel data rate and silicon waveguide modulator architecture. Product specifications and conference presentations by Lumicore personnel reference the 100 Gbps per-channel modulation rate as a key design parameter. The transmitter section of the LumiEdge 1600G-LR satisfies this limitation.
1.3 Claim 1, Limitation [b]
Claim Language:
"a receiver section comprising a coherent detection module coupled to the silicon substrate, the coherent detection module configured to recover data from a received optical signal using coherent detection;"
This limitation requires: (i) a receiver section; (ii) the receiver section comprising a coherent detection module; (iii) the coherent detection module being coupled to the silicon substrate; and (iv) the coherent detection module being configured to recover data from a received optical signal using coherent detection.
Note: This is a key disputed limitation in this case. OWS's proposed construction treats the term "coherent detection module" broadly as "a module that uses coherent detection principles, including homodyne or intradyne detection, to recover data." Lumicore's proposed construction would require "a specific integrated coherent receiver with a local oscillator on the same die." OWS contends that Lumicore's proposed construction improperly imports a local oscillator integration requirement into the "coherent detection module" term that is not supported by the claim language or the specification. The claim language requires only that the coherent detection module be "coupled to the silicon substrate," not that all components of the module be fabricated on a single die. The specification of the '193 Patent discloses multiple embodiments including both on-chip and co-packaged local oscillator configurations. The dispute regarding this limitation is central to the parties' claim construction positions and will be addressed at the Markman hearing scheduled for March 14, 2025. Regardless of which construction is adopted, OWS contends that each accused product satisfies this limitation, as set forth below.
Accused Product — LumiLink 400G-ZR+:
The Benchmark teardown report, dated December 12, 2022, identifies a coherent receiver block on the silicon PIC of the LumiLink 400G-ZR+, including 90-degree optical hybrids and balanced photodetectors. The 90-degree optical hybrids mix the received optical signal with a local oscillator signal to produce in-phase (I) and quadrature (Q) interference products, which are then detected by balanced photodetector pairs. This architecture implements intradyne coherent detection, enabling recovery of both amplitude and phase information from the received optical signal.
Lumicore design documents produced in discovery, Bates Nos. LTC-00045401 through LTC-00045445, describe the coherent detection architecture of the LumiLink 400G-ZR+ in detail, including the intradyne detection approach with subsequent digital signal processing for carrier frequency offset compensation and data recovery. The coherent detection module is coupled to the silicon substrate via the SOI platform — the optical hybrids and waveguide structures of the coherent receiver are fabricated in the silicon layer of the SOI wafer, and the balanced photodetectors are either monolithically integrated or hybrid-bonded to the silicon PIC.
Dr. Sandra Michaud confirmed in her deposition on November 19, 2024, at pages 112:3 through 113:18, that the receiver section of the LumiLink 400G-ZR+ performs coherent detection of the received optical signal. Dr. Michaud testified that the receiver section employs intradyne coherent detection with a tunable local oscillator laser and 90-degree optical hybrids to recover the transmitted data. This testimony directly confirms that the LumiLink 400G-ZR+ includes a coherent detection module coupled to the silicon substrate that is configured to recover data from a received optical signal using coherent detection.
Accused Product — LumiLink 800G-DR8:
The Benchmark teardown report, dated June 2023, confirms a multi-channel coherent receiver with 90-degree optical hybrids per channel on the silicon PIC of the LumiLink 800G-DR8. Design specifications produced in discovery, Bates Nos. LTC-00078620 through LTC-00078689, describe the coherent detection module architecture for the 800G-DR8, including the multi-channel coherent receiver layout and the integration of balanced photodetectors on the silicon substrate. The balanced photodetectors are integrated on the silicon substrate, completing the coherent detection signal chain on or coupled to the SOI platform. The receiver section of the LumiLink 800G-DR8 satisfies this limitation.
Accused Product — LumiEdge 1600G-LR:
The Benchmark teardown report, dated February 2024, identifies a coherent receiver section in the LumiEdge 1600G-LR with optical hybrids and integrated photodetectors for each of the 16 channels. Design files produced in discovery, Bates Nos. LTC-00112300 through LTC-00112389, confirm the coherent detection approach employed by the LumiEdge 1600G-LR. Product documentation describes the receiver section as employing "coherent DSP-based detection" for long-reach applications, confirming the use of coherent detection to recover data from the received optical signal. The receiver section of the LumiEdge 1600G-LR satisfies this limitation.
1.4 Claim 1, Limitation [c]
Claim Language:
"a wavelength division multiplexing element integrated with the transmitter section, the wavelength division multiplexing element configured to combine a plurality of modulated optical signals onto a common output waveguide;"
This limitation requires: (i) a wavelength division multiplexing (WDM) element; (ii) the WDM element being integrated with the transmitter section; and (iii) the WDM element being configured to combine a plurality of modulated optical signals onto a common output waveguide.
Accused Product — LumiLink 400G-ZR+:
The Benchmark teardown report, dated December 12, 2022, identifies an on-chip WDM multiplexer on the silicon PIC of the LumiLink 400G-ZR+ that combines four modulated optical channels from the transmitter section onto a common output waveguide. Design documents produced in discovery, Bates Nos. LTC-00045450 through LTC-00045478, describe the WDM element as integrated on the transmitter side of the PIC, with waveguide routing from the individual modulator outputs to the WDM multiplexer and then to a common output waveguide. Annotated teardown photographs from the Benchmark Report, Figures 18 through 20, clearly show the waveguide routing from the individual modulators through the WDM multiplexer to the common output waveguide, confirming integration with the transmitter section. The WDM element of the LumiLink 400G-ZR+ satisfies this limitation.
Accused Product — LumiLink 800G-DR8:
The Benchmark teardown report, dated June 2023, identifies an 8-channel WDM multiplexer on the silicon PIC of the LumiLink 800G-DR8, integrated with the transmitter section. Design specifications produced in discovery, Bates Nos. LTC-00078700 through LTC-00078734, detail the WDM multiplexer design, which employs either an arrayed waveguide grating (AWG) or an echelle grating to combine the eight modulated optical channels onto a common output waveguide. The common output waveguide is then routed to the edge coupler or grating coupler for fiber coupling. The WDM element of the LumiLink 800G-DR8 satisfies this limitation.
Accused Product — LumiEdge 1600G-LR:
The Benchmark teardown report, dated February 2024, identifies a multi-stage WDM multiplexer on the silicon PIC of the LumiEdge 1600G-LR that handles 16 channels. The multi-stage design combines groups of channels in a cascaded architecture to produce a single common output waveguide carrying all 16 modulated optical signals. Design files produced in discovery, Bates Nos. LTC-00112400 through LTC-00112445, describe the WDM multiplexer architecture and confirm the common output waveguide. Layout files confirm the routing from the 16-channel modulator array through the multi-stage WDM multiplexer to the common output waveguide. The WDM element of the LumiEdge 1600G-LR satisfies this limitation.
1.5 Claim 1, Limitation [d]
Claim Language:
"a control circuit coupled to the transmitter section and the receiver section, the control circuit configured to monitor and adjust at least one of bias current, modulation amplitude, and wavelength of the optical carrier signal;"
This limitation requires: (i) a control circuit; (ii) the control circuit being coupled to both the transmitter section and the receiver section; and (iii) the control circuit being configured to monitor and adjust at least one of three specified parameters: bias current, modulation amplitude, and wavelength of the optical carrier signal.
Accused Product — LumiLink 400G-ZR+:
The Benchmark teardown report, dated December 12, 2022, identifies an electronic control IC (ASIC) wire-bonded to the silicon PIC of the LumiLink 400G-ZR+. The control ASIC is coupled to both the transmitter section and the receiver section of the PIC via wire-bond interconnections and on-chip electrical traces. Design documents produced in discovery, Bates Nos. LTC-00045490 through LTC-00045523, describe the control circuit as monitoring and adjusting bias currents (for the modulator p-n junctions and photodetectors), modulation amplitude (via drive voltage adjustment to the MZMs), and laser wavelength (via thermal tuning of the tunable laser source). The control circuit implements closed-loop feedback algorithms to maintain optimal operating conditions in real time.
Dr. Sandra Michaud confirmed in her deposition on November 19, 2024, at pages 134:8 through 135:14, that the control ASIC in the LumiLink 400G-ZR+ provides real-time control of bias current, modulation amplitude, and wavelength. Dr. Michaud described the control circuit as implementing wavelength-locking loops, automatic bias control for the MZMs, and modulation amplitude optimization based on feedback from the receiver section's signal quality metrics. This testimony confirms that the control circuit of the LumiLink 400G-ZR+ satisfies all three alternatives of this limitation.
Accused Product — LumiLink 800G-DR8:
The Benchmark teardown report, dated June 2023, confirms the presence of a control ASIC coupled to the silicon PIC of the LumiLink 800G-DR8. Design documents produced in discovery, Bates Nos. LTC-00078750 through LTC-00078789, specify the control functions implemented by the ASIC, including wavelength locking, bias optimization for each of the eight modulator channels, and modulation amplitude adjustment. The control circuit interfaces with both the transmitter section (for modulator bias and amplitude control) and the receiver section (for performance monitoring and feedback). The control circuit of the LumiLink 800G-DR8 satisfies this limitation.
Accused Product — LumiEdge 1600G-LR:
The Benchmark teardown report, dated February 2024, identifies a more advanced control ASIC in the LumiEdge 1600G-LR with additional thermal monitoring channels to support the 16-channel architecture. The control ASIC manages wavelength control, bias current adjustment, and modulation amplitude optimization across all 16 channels. Design files produced in discovery, Bates Nos. LTC-00112460 through LTC-00112498, describe the control circuit functionality, including per-channel wavelength locking, bias current monitoring, and modulation amplitude calibration. Product datasheets for the LumiEdge 1600G-LR confirm automated wavelength and bias control as key features of the transceiver module. The control circuit of the LumiEdge 1600G-LR satisfies this limitation.
SECTION 2: CLAIM 3 — DEPENDENT CLAIM (Literal Infringement AND Doctrine of Equivalents)
Claim 3 of the '193 Patent is a dependent claim that depends from independent Claim 1 and adds an additional limitation directed to the architecture of the coherent detection module. OWS asserts that each of the three accused products literally infringes Claim 3 and, in the alternative, infringes Claim 3 under the doctrine of equivalents.
2.1 Claim 3 Language
Full Claim Language:
"The coherent optical transceiver of claim 1, wherein the coherent detection module comprises a polarization-diversity coherent receiver configured to simultaneously process two orthogonal polarization states of the received optical signal."
Dependency. Claim 3 depends from Claim 1. All limitations of Claim 1, as mapped in Sections 1.1 through 1.5 above, are incorporated by reference into the infringement analysis for Claim 3. OWS contends that each accused product satisfies every limitation of Claim 1 as set forth in Section 1, and further satisfies the additional limitation of Claim 3 as set forth below.
2.2 Claim 3, Additional Limitation — Literal Infringement Analysis
Claim Language of Additional Limitation:
"the coherent detection module comprises a polarization-diversity coherent receiver configured to simultaneously process two orthogonal polarization states of the received optical signal"
This additional limitation requires that the coherent detection module (already mapped in Section 1.3 above) specifically comprise a polarization-diversity coherent receiver that is configured to simultaneously process two orthogonal polarization states (typically referred to as TE and TM polarization states) of the received optical signal.
Accused Product — LumiLink 400G-ZR+:
The Benchmark teardown report, dated December 12, 2022, identifies a polarization beam splitter/rotator (PBSR) on the silicon PIC of the LumiLink 400G-ZR+. The PBSR splits the incoming received optical signal into its two orthogonal polarization components — the transverse electric (TE) mode and the transverse magnetic (TM) mode — and rotates the TM component into the TE mode for processing in the silicon waveguide platform, which is optimized for TE-mode propagation. Separate 90-degree optical hybrids and balanced photodetector pairs are provided for each polarization state, enabling simultaneous coherent detection of both polarization components.
Design documents produced in discovery, Bates Nos. LTC-00045446 through LTC-00045470, describe the dual-polarization coherent receiver architecture of the LumiLink 400G-ZR+ in detail, including the PBSR design, the dual optical hybrid layout, and the parallel photodetection paths for TE and TM (rotated) signal components.
Dr. Sandra Michaud confirmed in her deposition on November 19, 2024, at pages 118:5 through 119:22, that the LumiLink 400G-ZR+ employs a polarization-diversity receiver approach. Dr. Michaud described the receiver as separating the incoming signal into two polarization states and independently performing coherent detection on each state simultaneously. This testimony directly supports the conclusion that the coherent detection module of the LumiLink 400G-ZR+ comprises a polarization-diversity coherent receiver configured to simultaneously process two orthogonal polarization states.
The LumiLink 400G-ZR+ therefore literally satisfies the additional limitation of Claim 3.
Accused Product — LumiLink 800G-DR8:
The Benchmark teardown report, dated June 2023, confirms a polarization-diversity coherent receiver per channel in the LumiLink 800G-DR8. Design documents produced in discovery, Bates Nos. LTC-00078690 through LTC-00078710, specify dual-polarization processing with separate coherent detection paths for each of the two orthogonal polarization states in each channel. The multi-channel architecture replicates the polarization-diversity coherent receiver across all eight channels, with each channel simultaneously processing both TE and TM polarization components. The LumiLink 800G-DR8 therefore literally satisfies the additional limitation of Claim 3.
Accused Product — LumiEdge 1600G-LR:
The Benchmark teardown report, dated February 2024, identifies polarization-diversity coherent receivers for each of the 16 channels in the LumiEdge 1600G-LR. Design files produced in discovery, Bates Nos. LTC-00112390 through LTC-00112399, confirm the simultaneous processing of TE and TM polarization states in each channel's coherent receiver. The LumiEdge 1600G-LR therefore literally satisfies the additional limitation of Claim 3.
2.3 Claim 3, Additional Limitation — Doctrine of Equivalents Analysis
Applicability. OWS asserts infringement of Claim 3 under the doctrine of equivalents as an alternative to the literal infringement theory set forth in Section 2.2 above. Specifically, to the extent that Lumicore argues that its "coherent detection module" does not literally meet the claim limitation — for example, because of alleged differences in the polarization-splitting architecture, the integration approach, or the manner in which the two orthogonal polarization states are separated and processed — OWS contends that the corresponding elements in the accused products infringe under the doctrine of equivalents pursuant to the function-way-result test. The analysis below applies to all three accused products.
Function-Way-Result Analysis for Claim 3 (All Three Accused Products):
Function. The accused element in each Lumicore product performs substantially the same function as the claimed "polarization-diversity coherent receiver configured to simultaneously process two orthogonal polarization states of the received optical signal." Specifically, the accused element in each product receives an incoming optical signal carrying data on two orthogonal polarization states, separates the signal into its two orthogonal polarization components (TE and TM), and independently detects each component using coherent detection techniques. The function of the accused element — polarization-diverse coherent reception and simultaneous dual-polarization processing — is substantially the same as the function of the claimed element.
Way. The accused element in each Lumicore product operates in substantially the same way as the claimed element. The accused element employs an on-chip polarization splitting element — whether implemented as a 2D grating coupler with inherent polarization splitting functionality, a PBSR, or an equivalent integrated polarization-handling structure — to route the two polarization components to separate coherent detection paths on the silicon PIC. Each coherent detection path includes optical mixing of the respective polarization component with a local oscillator signal via a 90-degree optical hybrid, followed by balanced photodetection. The parallel detection paths operate simultaneously to process both polarization states. This approach is substantially the same way as the claimed polarization-diversity coherent receiver operates.
Result. The accused element in each Lumicore product achieves substantially the same result as the claimed element. The result achieved is the recovery of the full data content of the received optical signal by exploiting both polarization states, thereby doubling the spectral efficiency of the coherent transceiver and enabling polarization-multiplexed communication at the specified aggregate data rates (400G for the LumiLink 400G-ZR+, 800G for the LumiLink 800G-DR8, and 1600G for the LumiEdge 1600G-LR). This result — full data recovery via polarization-diverse coherent detection — is substantially the same result achieved by the claimed "polarization-diversity coherent receiver."
Prosecution History Estoppel Consideration. OWS acknowledges that during prosecution of the '193 Patent, the "coherent detection module" term was narrowed in an amendment filed in response to an Office Action rejecting the claims under 35 U.S.C. § 102 over Takahashi et al., "Dense WDM Silicon Photonic MUX," published in IEEE Photonics Technology Letters, March 2014. The examiner's rejection was based on the assertion that Takahashi disclosed a coherent detection module on a silicon substrate. In response, the applicants amended the claims to distinguish Takahashi's non-coherent WDM demultiplexer architecture from the claimed coherent detection module.
OWS contends that the Festo tangential-relation exception applies and that prosecution history estoppel does not bar the application of the doctrine of equivalents for Claim 3. See Festo Corp. v. Fenmore & Co., 535 U.S. 722, 740–41 (2002). The narrowing amendment was directed to distinguishing Takahashi's non-coherent WDM demultiplexer from the claimed coherent detection module. The amendment did not address or surrender the specific polarization-diversity receiver architecture at issue in this case. The polarization-diversity coherent receiver architecture employed by Lumicore in the accused products is unrelated to the reason for the narrowing amendment — the amendment was made to distinguish a non-coherent optical multiplexing structure, not to limit the scope of the polarization-diversity receiver claim. Accordingly, the equivalent employed by Lumicore was not foreseeable at the time of the amendment and is tangential to the reason for the narrowing amendment.
A separate Prosecution History Estoppel Analysis — '193 Patent, dated October 10, 2024, prepared by Calderwood & Harkness LLP, addresses this issue in further detail and is incorporated by reference herein. Relevant excerpts from the prosecution history are reproduced in Appendix 5 to this Claim Chart.
SECTION 3: CLAIM 7 — DEPENDENT CLAIM (Literal Infringement AND Doctrine of Equivalents)
Claim 7 of the '193 Patent is a dependent claim that depends from independent Claim 1 and adds an additional limitation directed to the inclusion and functionality of a digital signal processing (DSP) unit within the coherent detection module. OWS asserts that each of the three accused products literally infringes Claim 7 and, in the alternative, infringes Claim 7 under the doctrine of equivalents.
3.1 Claim 7 Language
Full Claim Language:
"The coherent optical transceiver of claim 1, wherein the coherent detection module further comprises a digital signal processing unit integrated with the receiver section, the digital signal processing unit configured to perform chromatic dispersion compensation and carrier phase recovery on the detected optical signal."
Dependency. Claim 7 depends from Claim 1. All limitations of Claim 1, as mapped in Sections 1.1 through 1.5 above, are incorporated by reference into the infringement analysis for Claim 7. OWS contends that each accused product satisfies every limitation of Claim 1 as set forth in Section 1, and further satisfies the additional limitation of Claim 7 as set forth below.
3.2 Claim 7, Additional Limitation — Literal Infringement Analysis
Claim Language of Additional Limitation:
"the coherent detection module further comprises a digital signal processing unit integrated with the receiver section, the digital signal processing unit configured to perform chromatic dispersion compensation and carrier phase recovery on the detected optical signal"
This additional limitation requires: (i) a digital signal processing (DSP) unit; (ii) the DSP unit being part of the coherent detection module; (iii) the DSP unit being integrated with the receiver section; and (iv) the DSP unit being configured to perform both chromatic dispersion compensation and carrier phase recovery on the detected optical signal.
Accused Product — LumiLink 400G-ZR+:
The Benchmark teardown report, dated December 12, 2022, identifies a DSP ASIC co-packaged with the silicon PIC of the LumiLink 400G-ZR+. The DSP ASIC is electrically connected to the balanced photodetector outputs on the silicon PIC via wire bonding or flip-chip interconnections. The DSP receives digitized samples from the analog-to-digital converters (ADCs) that are either integrated within the DSP ASIC or located at the PIC-to-DSP interface.
The DSP performs chromatic dispersion (CD) compensation using digital finite impulse response (FIR) filters. These filters are programmed to apply the inverse transfer function of the optical fiber's chromatic dispersion, thereby compensating for the pulse broadening and inter-symbol interference caused by group velocity dispersion during fiber propagation. The CD compensation algorithms implemented in the DSP are described in Lumicore design documents, Bates Nos. LTC-00045525 through LTC-00045578.
The DSP also performs carrier phase recovery (CPR), which is implemented in the DSP firmware. The CPR algorithm tracks and corrects the phase offset between the received signal's carrier and the local oscillator, compensating for laser linewidth-induced phase noise and frequency offsets. The CPR implementation is described in the same design documents, including details of the phase estimation loop architecture and convergence characteristics.
Dr. Sandra Michaud confirmed in her deposition on November 19, 2024, at pages 141:2 through 142:19, that the DSP ASIC in the LumiLink 400G-ZR+ performs both chromatic dispersion compensation and carrier phase recovery. Dr. Michaud testified that the DSP processing pipeline includes, in order: (1) ADC sampling, (2) front-end equalization, (3) chromatic dispersion compensation, (4) polarization demultiplexing, (5) carrier phase recovery, and (6) forward error correction decoding. This testimony directly confirms that the DSP is configured to perform both CD compensation and CPR as required by the claim.
The DSP is "integrated with the receiver section" because it is co-packaged with the silicon PIC in the same multi-chip module (MCM) package, electrically coupled to the photodetector outputs of the receiver section, and operates as an integral part of the coherent detection signal processing chain. The LumiLink 400G-ZR+ therefore literally satisfies the additional limitation of Claim 7.
Accused Product — LumiLink 800G-DR8:
The Benchmark teardown report, dated June 2023, confirms the presence of a DSP ASIC with chromatic dispersion compensation and carrier phase recovery functionality integrated with the receiver section of the LumiLink 800G-DR8. Design specifications produced in discovery, Bates Nos. LTC-00078790 through LTC-00078845, detail the DSP processing pipeline, which includes enhanced CD compensation capability designed to support the higher data rates and increased bandwidth demands of the 800G architecture. The DSP is co-packaged with the silicon PIC and electrically coupled to the receiver section's photodetector outputs, satisfying the "integrated with the receiver section" requirement. The LumiLink 800G-DR8 therefore literally satisfies the additional limitation of Claim 7.
Accused Product — LumiEdge 1600G-LR:
The Benchmark teardown report, dated February 2024, identifies an advanced DSP ASIC in the LumiEdge 1600G-LR with an extended CD compensation range specifically designed for long-reach (LR) applications. The extended CD compensation capability supports fiber spans of up to 80 km or more, requiring the DSP to compensate for significantly greater chromatic dispersion than in shorter-reach applications. Design files produced in discovery, Bates Nos. LTC-00112500 through LTC-00112567, specify the DSP integration with the receiver section and the CPR algorithms employed by the LumiEdge 1600G-LR. Product specifications confirm that the DSP is "integrated with the receiver section" as a co-packaged or flip-chip-bonded component within the transceiver module. The LumiEdge 1600G-LR therefore literally satisfies the additional limitation of Claim 7.
3.3 Claim 7, Additional Limitation — Doctrine of Equivalents Analysis
Applicability. OWS asserts infringement of Claim 7 under the doctrine of equivalents as an alternative to the literal infringement theory set forth in Section 3.2 above. The doctrine of equivalents is asserted specifically with respect to the "coherent detection module" limitation that is the parent of the additional DSP limitation in Claim 7. To the extent that Lumicore argues that the "coherent detection module" as a whole — incorporating the DSP unit — does not literally meet the claim because of alleged differences in integration methodology (e.g., if Lumicore argues that the DSP is a "separate chip" rather than a component "integrated with the receiver section"), OWS contends that the accused element infringes under the doctrine of equivalents.
Function-Way-Result Analysis for Claim 7 (All Three Accused Products):
Function. The accused DSP element in each Lumicore product performs substantially the same function as the claimed "digital signal processing unit integrated with the receiver section." The function is performing post-detection digital processing to compensate for chromatic dispersion accumulated during fiber transmission and to recover the carrier phase for coherent demodulation. The DSP in each accused product receives digitized samples from the coherent receiver's photodetectors and applies computational algorithms to undo the impairments introduced by the fiber channel and the transmitter/receiver hardware. This function — digital compensation of chromatic dispersion and recovery of carrier phase — is substantially the same function performed by the claimed DSP unit.
Way. The accused DSP element in each Lumicore product operates in substantially the same way as the claimed element. Specifically, the accused DSP: (1) receives digitized samples from the balanced photodetectors via analog-to-digital converters at the receiver output; (2) applies digital FIR filtering (or equivalent frequency-domain equalization) to compensate for the chromatic dispersion accumulated during propagation through the optical fiber; and (3) implements a carrier phase estimation and recovery algorithm — such as a Viterbi-Viterbi algorithm, blind phase search algorithm, or equivalent carrier phase tracking loop — to estimate and correct the carrier phase offset between the received signal and the local oscillator. This processing approach is substantially the same way as the claimed DSP unit operates.
Result. The accused DSP element in each Lumicore product achieves substantially the same result as the claimed element. The result is enabling error-free (or near-error-free, pre-forward-error-correction) recovery of the transmitted data after propagation through optical fiber, by digitally compensating for impairments that would otherwise degrade signal quality below acceptable thresholds. Without CD compensation and CPR, the coherent transceiver would be unable to recover the transmitted data with acceptable bit error rates for the target link distances and data rates of the accused products. The result achieved by the accused DSP — successful coherent data recovery — is substantially the same result achieved by the claimed DSP unit.
Prosecution History Estoppel Consideration. The same prosecution history estoppel analysis set forth in Section 2.3 above for Claim 3 applies equally to Claim 7. The amendment to the "coherent detection module" term during prosecution was directed to distinguishing the non-coherent Takahashi reference and did not address or surrender the DSP integration approach used in the accused products. The Festo tangential-relation exception applies. The narrowing amendment concerned the distinction between coherent and non-coherent optical detection — it did not relate to the manner in which a DSP is integrated with the receiver section. The specific equivalent employed by Lumicore — a co-packaged DSP ASIC electrically coupled to the receiver section — was not surrendered during prosecution and is tangential to the reason for the narrowing amendment. See Festo Corp., 535 U.S. at 740–41; Honeywell Int'l, Inc., 370 F.3d at 1141–42.
The separate Prosecution History Estoppel Analysis — '193 Patent, dated October 10, 2024, addresses this issue in further detail and is incorporated by reference herein.
SECTION 4: CLAIM 10 — INDEPENDENT CLAIM (Literal Infringement)
Claim 10 of the '193 Patent is an independent method claim directed to a method for transmitting and receiving high-bandwidth coherent optical signals using a transceiver integrated on a silicon substrate. OWS asserts that each of the three accused products, when manufactured, tested, used, and operated in its intended manner, practices the method of Claim 10. The detailed step-by-step mapping is set forth below.
4.1 Claim 10 Preamble
Claim Language:
"A method for transmitting and receiving high-bandwidth coherent optical signals using a transceiver integrated on a silicon substrate, the method comprising:"
All Three Accused Products (LumiLink 400G-ZR+, LumiLink 800G-DR8, and LumiEdge 1600G-LR):
Each of the three accused products, when operated in its intended manner, practices a method for transmitting and receiving high-bandwidth coherent optical signals using a transceiver integrated on a silicon substrate. The evidence establishing that each accused product is a coherent optical transceiver integrated on a silicon substrate is set forth in Section 1.1 above and is incorporated by reference here.
Evidence that the method of Claim 10 is practiced during operation of each accused product includes: (i) product operation manuals and user guides that describe the steps for transmitting and receiving coherent optical signals using the transceiver; (ii) application notes published by Lumicore that describe customer deployment and operation of the products; (iii) customer deployment guides that walk end users through the configuration and operation of the transceiver modules; and (iv) Lumicore's own technical presentations at industry conferences, including OFC (Optical Fiber Communications Conference) and ECOC (European Conference on Optical Communication), which describe the operation of the accused products in customer data-center environments.
The Benchmark teardown reports confirm the silicon substrate integration for all three products, as detailed in Section 1.1 above. The method of Claim 10 is practiced by Lumicore itself during product testing and qualification, and by Lumicore's customers during normal product use in data-center interconnect and telecommunications applications. OWS reserves the right to assert theories of induced infringement and contributory infringement in separate complaint counts, supported by Lumicore's provision of operation manuals, application notes, and deployment guides that instruct and encourage customers to practice the claimed method.
4.2 Claim 10, Step [a]
Claim Language:
"modulating, in a transmitter section formed on the silicon substrate, an optical carrier signal with data using at least one optical modulator at a per-channel data rate of at least 100 Gbps;"
All Three Accused Products:
The mapping for this method step is identical to the apparatus mapping set forth in Section 1.2 above (Claim 1, Limitation [a]) for all three accused products. Each accused product, when operated, performs the step of modulating an optical carrier signal with data using at least one optical modulator formed in a silicon waveguide on the silicon substrate at a per-channel data rate of at least 100 Gbps. The transmitter section of each accused product is formed on the silicon substrate (the SOI wafer) and employs silicon MZMs operating at the specified data rates.
In addition to the evidence cited in Section 1.2, Lumicore application notes, Bates Nos. LTC-00056789 through LTC-00056812, describe customer operation of the modulation step at the specified per-channel data rates. These application notes instruct customers to configure the transceiver for operation at the specified data rates and confirm that the modulation step is performed during normal product use. Lumicore product qualification reports, Bates Nos. LTC-00089234 through LTC-00089267, confirm that per-channel modulation at rates of 100 Gbps or greater is achieved during product testing and qualification. The modulation step is practiced each time the transceiver is operated to transmit data, which occurs continuously during normal product use in data-center interconnect deployments.
4.3 Claim 10, Step [b]
Claim Language:
"multiplexing the modulated optical signals using a wavelength division multiplexing element to combine the modulated optical signals onto a common output waveguide;"
All Three Accused Products:
The mapping for this method step is identical to the apparatus mapping set forth in Section 1.4 above (Claim 1, Limitation [c]) for all three accused products. Each accused product, when operated, performs the step of multiplexing the modulated optical signals using a WDM element to combine them onto a common output waveguide. The WDM multiplexer on each accused product's silicon PIC combines the individually modulated optical channels — four channels for the LumiLink 400G-ZR+, eight channels for the LumiLink 800G-DR8, and sixteen channels for the LumiEdge 1600G-LR — onto a common output waveguide that routes the combined signal to the fiber coupling interface.
Evidence of the active practice of this method step during product operation is confirmed by datasheet operational descriptions and application guides published by Lumicore, which describe the multiplexing function as an inherent step in the transmit signal chain that occurs automatically during transceiver operation. The multiplexing step is practiced each time the transceiver transmits multi-channel coherent optical signals, which is the fundamental operating mode of each accused product.
4.4 Claim 10, Step [c]
Claim Language:
"receiving, in a receiver section on the silicon substrate, an incoming optical signal and performing coherent detection to recover the data, wherein the coherent detection comprises mixing the incoming optical signal with a local oscillator signal;"
All Three Accused Products:
The mapping for this method step parallels the apparatus mapping set forth in Section 1.3 above (Claim 1, Limitation [b]) for all three accused products. In addition, this method step includes an express requirement that the coherent detection comprises "mixing the incoming optical signal with a local oscillator signal." This additional requirement specifies that the coherent detection step involves optical mixing of the received signal with a local oscillator (LO) signal.
Each accused product, when operated, performs the step of receiving an incoming optical signal in a receiver section on the silicon substrate and performing coherent detection by mixing the incoming signal with a local oscillator signal. The Benchmark teardown reports for each accused product identify an on-chip or co-packaged tunable laser that functions as the local oscillator source. The 90-degree optical hybrids on the silicon PIC of each accused product mix the incoming optical signal with the LO signal to produce in-phase (I) and quadrature (Q) interference products, which are then detected by balanced photodetector pairs. This optical mixing step implements intradyne coherent detection and enables recovery of both amplitude and phase information from the received optical signal.
Design documents for each accused product confirm the LO mixing architecture:
• LumiLink 400G-ZR+: Bates Nos. LTC-00045446 through LTC-00045470
• LumiLink 800G-DR8: Bates Nos. LTC-00078690 through LTC-00078710
• LumiEdge 1600G-LR: Bates Nos. LTC-00112390 through LTC-00112399
Dr. Sandra Michaud confirmed in her deposition on November 19, 2024, at pages 115:7 through 116:23, that each accused product uses a local oscillator signal that is mixed with the received signal during coherent detection. Dr. Michaud testified that the 90-degree optical hybrid on the silicon PIC combines the received signal with the LO signal to produce the I and Q components necessary for coherent demodulation. This testimony directly supports the mapping of this method step for all three accused products.
4.5 Claim 10, Step [d]
Claim Language:
"controlling, via a control circuit, at least one of bias current, modulation amplitude, and wavelength of the optical carrier signal based on feedback from the transmitter section and the receiver section."
All Three Accused Products:
The mapping for this method step is identical to the apparatus mapping set forth in Section 1.5 above (Claim 1, Limitation [d]) for all three accused products. Each accused product, when operated, performs the step of controlling, via a control circuit (the control ASIC), at least one of bias current, modulation amplitude, and wavelength of the optical carrier signal based on feedback from both the transmitter section and the receiver section.
The control step is practiced continuously during product operation via real-time feedback loops implemented in the control ASIC firmware. The control ASIC monitors performance metrics from both the transmitter section (e.g., modulator bias voltage, laser output power, laser wavelength) and the receiver section (e.g., signal-to-noise ratio, bit error rate, received optical power) and adjusts the controlled parameters accordingly. This continuous closed-loop control is an inherent feature of normal product operation and is described in product operation manuals, firmware documentation, and application notes produced by Lumicore.
Evidence from product operation manuals confirms that the control step is automatically executed by the transceiver firmware upon power-up and during continuous operation, without requiring user intervention. The control algorithm adjusts bias current, modulation amplitude, and wavelength in real time to maintain optimal transceiver performance across varying operating conditions, including temperature variations, fiber link changes, and aging effects. This method step is therefore practiced each time any of the three accused products is operated.
SECTION 5: CLAIM 15 — INDEPENDENT CLAIM (Literal Infringement)
Claim 15 of the '193 Patent is an independent system claim directed to a silicon photonic transceiver system for data-center interconnect applications. OWS asserts that each of the three accused products literally infringes every limitation of Claim 15. The detailed element-by-element mapping is set forth below.
5.1 Claim 15 Preamble
Claim Language:
"A silicon photonic transceiver system for data-center interconnect applications, the system comprising:"
All Three Accused Products (LumiLink 400G-ZR+, LumiLink 800G-DR8, and LumiEdge 1600G-LR):
Each of the three accused products is a silicon photonic transceiver system designed, manufactured, marketed, and sold for data-center interconnect applications. The evidence establishing that each product is a silicon photonic transceiver system is set forth in Section 1.1 above and is incorporated by reference here.
Lumicore's marketing materials, customer-facing presentations, and product datasheets consistently describe each of the accused products as designed for hyperscale data-center interconnect and/or telecommunications intercon