Nanoco Technologies Ltd. v. Samsung Electronics Co., Ltd. et al

Filing 1

COMPLAINT against Samsung Advanced Institute of Technology, Samsung Display Co., Ltd., Samsung Electronics America, Inc., Samsung Electronics Co., Ltd., Samsung Electronics Co., Ltd. Visual Display Division ( Filing fee $ 400 receipt number 0540-7664317.), filed by Nanoco Technologies Ltd.. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14)(Henry, Claire)

Exhibit 9

U.S. Patent No. 7,867,557

Page 1 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"
1. A method for producing a
The Samsung Q60R QLED TV is an exemplary LED TV (the “Samsung TV”) that includes nanoparticles.
nanoparticle comprised of a core
comprising a core semiconductor
material,

For example, the Samsung TV includes quantum dots (the “Samsung Quantum Dots”)1.

1

Upon information and belief, all Samsung QLED TVs listed in Exhibit 6 include the same Quantum Dots. For example, Samsung QLED TV’s display stack includes a Blue LED and
layer of Quantum Dots in a Quantum Dot Layer.
See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (SAIT, Samsung Electronics), Quantum Dot Forum 2018 Presentation at Slides 11, 16.
see also e.g., https://www.techradar.com/news/samsung-qled-samsungs-latest-television-acronym-explained;
see also e.g., https://www.samsung.com/global/tv/blog/stained-glass-and-quantum-dot-technology/;
see also e.g., https://www.displaydaily.com/article/display-daily/future-of-quantum-dot-display-niche-or-mainstream;
see also e.g., https://www.techradar.com/news/samsung-qled-samsungs-latest-television-acronym-explained.
Samsung’s QD-OLED TV displays operate in substantially the same way in that they are comprised of a Blue OLED and Quantum Dot layer.
See e.g., https://www.cnet.com/news/samsung-reportedly-working-on-quantum-dot-oled-tv-hybrid/.

Page 2 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., https://www.samsung.com/us/televisions-home-theater/tvs/qled-4k-tvs/43-class-q60-qled-smart-4k-uhdtv-2019-qn43q60rafxza/.

See e.g., https://www.samsung.com/us/televisions-home-theater/tvs/qled-tv/technology/.
The Samsung Quantum Dots used in the Samsung TV are nanoparticles.

Page 3 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., https://news.samsung.com/global/how-qled-achieves-excellence-in-picture-quality;
See also e.g., https://www.hitechcentury.com/samsungs-next-gen-qled-tv-showcased-at-sea-forum-2017/;

Page 4 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., https://www.forbes.com/sites/johnarcher/2017/09/19/what-is-qled-and-why-does-itmatter/#732982817fb3.

Page 5 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., https://news.samsung.com/za/why-are-quantum-dot-displays-so-good.

Page 6 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., https://www.cnet.com/news/quantum-dots-how-nanocrystals-can-make-lcd-tvs-better/.
Samsung’s Quantum Dots include an InP-based core, a first ZnSe shell, and a second ZnS shell.

Page 7 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slides 8,
15.
Samsung demonstrates that a molecular interface exists between In, P, Zn, and S within their Quantum Dot cores.

Page 8 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 8.
Samsung’s Quantum Dots are produced using a method. For example, Samsung discloses the use of a “one pot
synthesis with high concentration” to make Quantum Dots.

Page 9 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"
See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 8.
Further, Samsung depicts a lab scale reaction setup for Quantum Dot synthesis and the injection of metalorganics (“nanoparticle precursor composition”).

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 13.
Further, Samsung discloses various large scale and mass production reaction setups for Quantum Dot synthesis.

Page 10 of 29

U.S. Patent No. 7,867,557: Claim 1
"1. A method for producing a nanoparticle comprised of a core comprising a core semiconductor material,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 10.

Page 11 of 29

U.S. Patent No. 7,867,557: Claim 1
"a first layer comprising a first semiconductor material provided on said core and a second layer comprising a second semiconductor material provided on
said first layer,"
a first layer comprising a first
The method used to synthesize Samsung’s Quantum Dots results in a Quantum Dot having a first layer
semiconductor material provided on
comprising a first semiconductor material provided on said core and a second layer comprising a second
said core and a second layer
semiconductor material provided on said first layer.
comprising a second semiconductor
material provided on said first layer,
For example, Samsung’s Quantum Dots include an InP-based core, a first ZnSe shell, and a second ZnS shell.

Page 12 of 29

U.S. Patent No. 7,867,557: Claim 1
"a first layer comprising a first semiconductor material provided on said core and a second layer comprising a second semiconductor material provided on
said first layer,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 8.
Upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis process, which
results in a ZnSe layer provided on an InP core and a ZnS layer provided on the first ZnSe layer.
“We injected (TMS)3P at 150 °C in the presence of both indium laurate (In(LA)3) and zinc oleate
(Zn(OA)2) precursors. At this mild temperature the In−P−Zn ligand complexes were first formed, and
then they were converted to InP MSCs as the temperature increased to 170 °C, showing a sharp absorption
peak at 370 nm.”
See e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics) (Exhibit 13), at 14972.
2

Dr. Eunjoo Jang of Samsung’s Advanced Institute of Technology (SAIT) is responsible for the synthesis of Samsung’s Quantum Dots. See e.g.,
https://news.samsung.com/global/quantum-dot-artisan-dr-eunjoo-jang-samsung-fellow. SAIT is Samsung’s Research and Development Center. See e.g.,
https://www.sait.samsung.co.kr/saithome/mobile/research/what.do. The cited paper—authored by Eunjoo Jang—describes a method for synthesizing InP/ZnSe/ZnS quantum dots. As

Page 13 of 29

U.S. Patent No. 7,867,557: Claim 1
"a first layer comprising a first semiconductor material provided on said core and a second layer comprising a second semiconductor material provided on
said first layer,"

Id., see also e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics), Supporting Information (Exhibit 14) at S-3.

previously shown, Samsung describes its quantum dots as comprising a core-shell structure of InP/ZnSe/ZnS. See e.g., “Environmentally Friendly Quantum Dots for Display
Applications,” Eunjoo Jang (Samsung Advanced Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slides 8.

Page 14 of 29

U.S. Patent No. 7,867,557: Claim 1
"said core semiconductor material being different to said first semiconductor material and said first semiconductor material being different to said second
semiconductor material,"
said core semiconductor material
The method used to synthesize Samsung’s Quantum Dots results in a Quantum Dot where the core
being different to said first
semiconductor material is different to said first semiconductor material and said first semiconductor material is
semiconductor material and said first different to said second semiconductor material.
semiconductor material being
different to said second
For example, Samsung’s Quantum Dots include an InP-based core, a first ZnSe shell, and a second ZnS shell.
semiconductor material,

Page 15 of 29

U.S. Patent No. 7,867,557: Claim 1
"said core semiconductor material being different to said first semiconductor material and said first semiconductor material being different to said second
semiconductor material,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 8.

Page 16 of 29

U.S. Patent No. 7,867,557: Claim 1
"the method comprising: effecting conversion of a nanoparticle core precursor composition to the material of the nanoparticle core;"
the method comprising: effecting
The method used to synthesize Samsung’s Quantum Dots comprises effecting conversion of a nanoparticle core
conversion of a nanoparticle core
precursor composition to the material of the nanoparticle core.
precursor composition to the material
of the nanoparticle core;
For example, upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis
process, which converts a nanoparticle precursor composition to a material of the nanoparticles core.
“We injected (TMS)3P at 150 °C in the presence of both indium laurate (In(LA)3) and zinc oleate
(Zn(OA)2) precursors. At this mild temperature the In−P−Zn ligand complexes were first formed, and
then they were converted to InP MSCs as the temperature increased to 170 °C, showing a sharp absorption
peak at 370 nm.”
See e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics) (Exhibit 13), at 1497.

Id., see also e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics), Supporting Information (Exhibit 14) at S-3.
The precursor composition comprises a fist precursor specific containing a first ion to be incorporated into the
nanoparticles and a separate second precursor species containing a second ion to be incorporated into the
nanoparticles. For example, Samsung’s Quantum Dot synthesis process demonstrates that, at least, In(LA)3,
Zn(OA)2, and (TMS)3P are precursor species comprised of ions contained in Samsung’s resulting Quantum Dot
nanoparticle core. Id.

Page 17 of 29

U.S. Patent No. 7,867,557: Claim 1
"the method comprising: effecting conversion of a nanoparticle core precursor composition to the material of the nanoparticle core;"
Samsung demonstrates that a molecular interface exists between In, P, Zn, F, and S within their Quantum Dot
cores, which means that precursor species containing, at least, In, P, Zn, and S are used in the synthesis process.

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 8.

Page 18 of 29

depositing said first layer on said
core; and

U.S. Patent No. 7,867,557: Claim 1
"depositing said first layer on said core; and"
The method used to synthesize Samsung’s Quantum Dots includes depositing said first layer on said core.
Samsung’s Quantum Dots include an InP-based core, a first ZnSe shell, and a second ZnS shell.

Page 19 of 29

U.S. Patent No. 7,867,557: Claim 1
"depositing said first layer on said core; and"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slides 8.
Upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis process, which
deposits a ZnSe layer on the InP core.
“We injected (TMS)3P at 150 °C in the presence of both indium laurate (In(LA)3) and zinc oleate
(Zn(OA)2) precursors. At this mild temperature the In−P−Zn ligand complexes were first formed, and
then they were converted to InP MSCs as the temperature increased to 170 °C, showing a sharp absorption
peak at 370 nm.”
See e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics) (Exhibit 13), at 1497.

Page 20 of 29

U.S. Patent No. 7,867,557: Claim 1
"depositing said first layer on said core; and"

Id., see also “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics), Supporting Information (Exhibit 14) at S-3.

Page 21 of 29

depositing said second layer on said
first layer,

U.S. Patent No. 7,867,557: Claim 1
"depositing said second layer on said first layer,"
The method used to synthesize Samsung’s Quantum Dots includes depositing said second layer on said first
layer.
Samsung’s Quantum Dots include an InP-based core, a first ZnSe shell, and a second ZnS shell.

Page 22 of 29

U.S. Patent No. 7,867,557: Claim 1
"depositing said second layer on said first layer,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slides 8.
Upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis process, which
deposits a ZnS layer on the ZnSe layer.
“We injected (TMS)3P at 150 °C in the presence of both indium laurate (In(LA)3) and zinc oleate
(Zn(OA)2) precursors. At this mild temperature the In−P−Zn ligand complexes were first formed, and
then they were converted to InP MSCs as the temperature increased to 170 °C, showing a sharp absorption
peak at 370 nm.”
See e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics) (Exhibit 13), at 1497.

Page 23 of 29

U.S. Patent No. 7,867,557: Claim 1
"depositing said second layer on said first layer,"

Id., see also e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics), Supporting Information (Exhibit 14) at S-3.

Page 24 of 29

U.S. Patent No. 7,867,557: Claim 1
"said core precursor composition comprising a first precursor species containing a first ion to be incorporated into the growing nanoparticle core and a
separate second precursor species containing a second ion to be incorporated into the growing nanoparticle core,"
said core precursor composition
The method used to synthesize the Samsung Quantum Dots uses a precursor composition comprising a first
comprising a first precursor species
precursor species containing a first ion to be incorporated into the growing nanoparticle core and a separate
containing a first ion to be
second precursor species containing a second ion to be incorporated into the growing nanoparticle core.
incorporated into the growing
nanoparticle core and a separate
For example, Samsung’s Quantum Dots include an InP-based core, a first ZnSe shell, and a second ZnS shell.
second precursor species containing a
second ion to be incorporated into the
growing nanoparticle core,

Page 25 of 29

U.S. Patent No. 7,867,557: Claim 1
"said core precursor composition comprising a first precursor species containing a first ion to be incorporated into the growing nanoparticle core and a
separate second precursor species containing a second ion to be incorporated into the growing nanoparticle core,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slides 8.
Samsung demonstrates that a molecular interface exists between In, P, Zn, F, and S within their Quantum Dot
cores, which means that precursor species containing, at least, In, P, Zn, and S are used in the synthesis process.

Page 26 of 29

U.S. Patent No. 7,867,557: Claim 1
"said core precursor composition comprising a first precursor species containing a first ion to be incorporated into the growing nanoparticle core and a
separate second precursor species containing a second ion to be incorporated into the growing nanoparticle core,"

See e.g., “Environmentally Friendly Quantum Dots for Display Applications,” Eunjoo Jang (Samsung Advanced
Institute of Technology, Samsung Electronics), Quantum Dot Forum 2018 Presentation (Exhibit 12) at Slide 8.
Upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis process, which
demonstrates that, at least, In(LA)3, Zn(OA)2, and (TMS)3P are precursor species comprised of ions contained in
Samsung’s growing nanoparticle core.
“We injected (TMS)3P at 150 °C in the presence of both indium laurate (In(LA)3) and zinc oleate
(Zn(OA)2) precursors. At this mild temperature the In−P−Zn ligand complexes were first formed, and
then they were converted to InP MSCs as the temperature increased to 170 °C, showing a sharp absorption
peak at 370 nm.”
See e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics) (Exhibit 13), at 1497.

Page 27 of 29

U.S. Patent No. 7,867,557: Claim 1
"said core precursor composition comprising a first precursor species containing a first ion to be incorporated into the growing nanoparticle core and a
separate second precursor species containing a second ion to be incorporated into the growing nanoparticle core,"

Id., see also e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics), Supporting Information (Exhibit 14) at S-3.

Page 28 of 29

said conversion being effected in the
presence of a molecular cluster
compound different from the
nanoparticle core precursor
composition.

The method used to synthesize Samsung Quantum Dots includes conversion being effected in the presence of a
molecular cluster compound different from the nanoparticle core precursor composition.
For example, Samsung’s Quantum Dots are formed using the following synthesis process, where conversion is
effected in the presence of a molecular cluster compound different from the nanoparticle core precursor
composition.
“We injected (TMS)3P at 150 °C in the presence of both indium laurate (In(LA)3) and zinc oleate
(Zn(OA)2) precursors. At this mild temperature the In−P−Zn ligand complexes were first formed, and
then they were converted to InP MSCs as the temperature increased to 170 °C, showing a sharp absorption
peak at 370 nm.”
See e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics) (Exhibit 13), at 1497.

Id., see also e.g., “Bright and Uniform Green Light Emitting InP/ZnSe/ZnS Quantum Dots for Wide Color Gamut
Displays,” ACS Appl. Nano Mater. 2019, 2, 1496−1504, Eunjoo Jang et. al. (Samsung Advanced Institute of
Technology, Samsung Electronics), Supporting Information (Exhibit 14) at S-3.
Samsung’s Quantum Dot synthesis process demonstrates that, at least, In(LA)3, Zn(OA)2, and (TMS)3P are
precursor species and a molecular cluster compound that are all different from each other and comprised of ions
contained in Samsung’s resulting Quantum Dot nanoparticle core. Id.

Page 29 of 29