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 7

U.S. Patent No. 7,588,828

Page 1 of 37

1. A nanoparticle comprising:

U.S. Patent No. 7,588,828: Claim 1
"1. A nanoparticle comprising:"
The Samsung Q60R QLED TV is an exemplary LED TV (the “Samsung TV”) that includes nanoparticles.

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

1

Upon information and belief, all Samsung QLED and QD-OLED 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 (Exhibit 12) 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 37

U.S. Patent No. 7,588,828: Claim 1
"1. A nanoparticle comprising:"

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 37

U.S. Patent No. 7,588,828: Claim 1
"1. A nanoparticle comprising:"

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 37

U.S. Patent No. 7,588,828: Claim 1
"1. A nanoparticle comprising:"

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

Page 5 of 37

U.S. Patent No. 7,588,828: Claim 1
"1. A nanoparticle comprising:"

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

Page 6 of 37

U.S. Patent No. 7,588,828: Claim 1
"1. A nanoparticle comprising:"

See e.g., https://www.cnet.com/news/quantum-dots-how-nanocrystals-can-make-lcd-tvs-better/.

Page 7 of 37

U.S. Patent No. 7,588,828: Claim 1
"(i) a molecular cluster compound incorporating ions from groups 12 and 16 of the periodic table, and"
(i) a molecular cluster compound
The Samsung Quantum Dots include a molecular cluster compound incorporating ions from groups 12 and 16 of
incorporating ions from groups 12
the periodic table.
and 16 of the periodic table, and
For example, the Samsung Quantum Dots include an InP core that is surrounded by an oxide layer and two Znbased outer shells.

Page 8 of 37

U.S. Patent No. 7,588,828: Claim 1
"(i) a molecular cluster compound incorporating ions from groups 12 and 16 of the periodic table, 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, 15.
Samsung demonstrates that a molecular interface exists between In, P, Zn, and S within their Quantum Dot cores.

Page 9 of 37

U.S. Patent No. 7,588,828: Claim 1
"(i) a molecular cluster compound incorporating ions from groups 12 and 16 of the periodic table, 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 Slide 8.
The interface between In, P, Zn, and S must reside within the InP core since the InP core is surrounded by an oxide
layer—separating it from the ZnS and ZnSe outer shells.

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.
This means that the InP core is formed on a molecular cluster compound including, at least, Zn and S, which are
ions from groups 12 and 16.
For example, S is an ions from group 16 of the periodic table. Group 16 elements include: O, S, Se, Te, Po, and
Uuh. Further, Zn is an ion from group 12 of the periodic table. Group 12 elements include: Zn, Cd, Hg, and Cn.

Page 10 of 37

U.S. Patent No. 7,588,828: Claim 1
"(i) a molecular cluster compound incorporating ions from groups 12 and 16 of the periodic table, and"

See e.g., https://www.jobilize.com/nanotechnology/course/optical-properties-of-group-12-16-ii-vi-semiconductornanoparticles.
Further, upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis process,
which uses a molecular cluster compound incorporating ions from groups 12 and 16 of the periodic table.
“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 11 of 37

U.S. Patent No. 7,588,828: Claim 1
"(i) a molecular cluster compound incorporating ions from groups 12 and 16 of the periodic table, and"

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.
For example, O is an ions from group 16 of the periodic table. Group 16 elements include: O, S, Se, Te, Po, and
Uuh. Further, Zn is an ion from group 12 of the periodic table. Group 12 elements include: Zn, Cd, Hg, and Cn.

See e.g., https://www.jobilize.com/nanotechnology/course/optical-properties-of-group-12-16-ii-vi-semiconductornanoparticles.

Page 12 of 37

U.S. Patent No. 7,588,828: Claim 1
"(ii) a core semiconductor material provided on said molecular cluster compound, wherein the core semiconductor material incorporates ions from groups
13 and 15 of the periodic table."
(ii) a core semiconductor material
The Samsung Quantum Dots include a core semiconductor material provided on said molecular cluster compound,
provided on said molecular cluster
wherein the core semiconductor material incorporates ions from groups 13 and 15 of the periodic table.
compound, wherein the core
semiconductor material
For example, the Samsung Quantum Dots include an InP core that is surrounded by an oxide layer and two Znincorporates ions from groups 13
based outer shells.
and 15 of the periodic table.

Page 13 of 37

U.S. Patent No. 7,588,828: Claim 1
"(ii) a core semiconductor material provided on said molecular cluster compound, wherein the core semiconductor material incorporates ions from groups
13 and 15 of the periodic table."

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.
The InP semiconductor core is provided on the molecular cluster compound.
As shown previously, Samsung demonstrates that a molecular interface, within the nanoparticle core, exists
between In, P, Zn, and S within their InP Quantum Dot cores.

Page 14 of 37

U.S. Patent No. 7,588,828: Claim 1
"(ii) a core semiconductor material provided on said molecular cluster compound, wherein the core semiconductor material incorporates ions from groups
13 and 15 of the periodic table."

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 15 of 37

U.S. Patent No. 7,588,828: Claim 1
"(ii) a core semiconductor material provided on said molecular cluster compound, wherein the core semiconductor material incorporates ions from groups
13 and 15 of the periodic table."
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, upon information and belief, Samsung’s Quantum Dots are formed using the following synthesis process,
which includes a core semiconductor material provided on said molecular cluster compound, wherein the core
semiconductor material incorporates ions from groups 13 and 15 of the periodic table.
“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 and (TMS)3P are provided on a
molecular cluster.

Page 16 of 37

U.S. Patent No. 7,588,828: Claim 1
"(ii) a core semiconductor material provided on said molecular cluster compound, wherein the core semiconductor material incorporates ions from groups
13 and 15 of the periodic table."
The InP semiconductor core in the Samsung Quantum Dots includes ions from groups 13 and 15 of the periodic
table. Group 13 elements include: B, Al, Ga, In, Tl, and Uut. Group 15 elements include: N, P, As, Sb, Bi, and
Uup.

See e.g., https://www.askiitians.com/iit-jee-s-and-p-block-elements/boron-family.html.

See e.g., https://periodictableprojectblog.wordpress.com/2016/02/14/group-15/.
Page 17 of 37

14. A method of producing
nanoparticles, the method
comprising the steps of:

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"
The Samsung Q60R QLED TV is an exemplary LED TV (the “Samsung TV”) that includes nanoparticles.

For example, the Samsung TV includes quantum dots (the “Samsung Quantum Dots”)2.

2

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 18 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 19 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 20 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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

Page 21 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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

Page 22 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 23 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 24 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 25 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 metal-organics
(“nanoparticle precursor composition”).

Page 26 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 27 of 37

U.S. Patent No. 7,588,828: Claim 14
"14. A method of producing nanoparticles, the method comprising the steps of:"

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 28 of 37

U.S. Patent No. 7,588,828: Claim 14
"providing a nanoparticle precursor composition comprising group 13 ions and group 15 ions; and"
providing a nanoparticle precursor
The method used to synthesize the Samsung Quantum Dots provides a nanoparticle precursor composition
composition comprising group 13
comprising group 13 and group 15 ions.
ions and group 15 ions; and
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:
“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 and (TMS)3P are precursor species
comprised of ions contained in Samsung’s resulting Quantum Dot nanoparticle core. Id.
Samsung also 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 29 of 37

U.S. Patent No. 7,588,828: Claim 14
"providing a nanoparticle precursor composition comprising group 13 ions and group 15 ions; 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 Slide 8.
Samsung’s precursor composition includes ions from groups 13 and 15 of the periodic table. Group 13 elements
include: B, Al, Ga, In, Tl, and Uut. Group 15 elements include: N, P, As, Sb, Bi, and Uup.
Page 30 of 37

U.S. Patent No. 7,588,828: Claim 14
"providing a nanoparticle precursor composition comprising group 13 ions and group 15 ions; and"

See e.g., https://www.askiitians.com/iit-jee-s-and-p-block-elements/boron-family.html.

See e.g., https://periodictableprojectblog.wordpress.com/2016/02/14/group-15/.

Page 31 of 37

effecting conversion of the
nanoparticle precursor into
nanoparticles,

U.S. Patent No. 7,588,828: Claim 14
"effecting conversion of the nanoparticle precursor into nanoparticles,"
The method used to synthesize the Samsung Quantum Dots effects conversion of the nanoparticle precursor into
nanoparticles.
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:
“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 and (TMS)3P are precursor species
comprised of ions contained in Samsung’s resulting Quantum Dot nanoparticle core. Id.
Samsung also 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 32 of 37

U.S. Patent No. 7,588,828: Claim 14
"effecting conversion of the nanoparticle precursor into nanoparticles,"

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 33 of 37

wherein said conversion is effected
in the presence of a molecular
cluster compound incorporating
group 12 ions and group 16 ions
under conditions permitting
nanoparticle seeding and growth.

The conversion in the method used to synthesize the Samsung Quantum Dots is effected in the presence of a
molecular cluster compound incorporating group 12 ions and group 16 ions under conditions permitting
nanoparticle seeding and growth.
For example, Samsung’s Quantum Dots are formed using the following synthesis process, which converts a
nanoparticle precursor composition to a material of the nanoparticles:
“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 conversion is effected in the presence of a molecular cluster. For example, 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 34 of 37

Samsung also demonstrates that a molecular interface exists between In, P, Zn, F, and S within their Quantum Dot
cores, which means that precursor species and a molecular cluster compound 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.
S and O are ions from group 16 of the periodic table. Group 16 elements include: O, S, Se, Te, Po, and Uuh.
Further, Zn is an ion from group 12 of the periodic table. Group 12 elements include: Zn, Cd, Hg, and Cn.
Page 35 of 37

See e.g., https://www.jobilize.com/nanotechnology/course/optical-properties-of-group-12-16-ii-vi-semiconductornanoparticles.
The conversion is effected under conditions permitting seeding and growth of nanoparticles. For example,
Samsung’s Quantum Dots are formed using the following synthesis process:
“During the InP synthesis, unlike the LaMer type growth, it has been known that the initial nucleation phase
completely consumes the highly reactive P precursor such as (TMS)3P, and further growth takes place
through the Ostwald ripening, which results in a large size distribution.”
“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 36 of 37

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.
Further, Samsung discloses its material design and synthesis process which permits seeding and growth of
nanoparticles.

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.

Page 37 of 37