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 8

U.S. Patent No. 7,803,423

Page 1 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"
1. A method of producing nanoparticles The Samsung Q60R QLED TV is an exemplary LED TV (the “Samsung TV”) that includes nanoparticles.
comprising: effecting conversion of a
nanoparticle precursor composition to a
material of the nanoparticles,

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 (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 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"

See e.g., https://www.samsung.com/us/televisions-home-theater/tvs/qled-4k-tvs/43-class-q60-qled-smart-4kuhd-tv-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 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"

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 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"

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

Page 5 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"

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

Page 6 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"

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 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the 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 Slides 8, 15.
Samsung demonstrates that a molecular interface exists between In, P, Zn, and S within their Quantum Dot
cores.

Page 8 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"

Se e.g.e, “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 9 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"
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.

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”).

Page 10 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the 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.
Further, Samsung discloses various large scale and mass production reaction setups for Quantum Dot synthesis.

Page 11 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the 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 10.
Samsung’s Quantum Dot synthesis process effects conversion of a nanoparticle precursor composition to a
material of the 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.”

Page 12 of 20

U.S. Patent No. 7,803,423: Claim 1
"1. A method of producing nanoparticles comprising: effecting conversion of a nanoparticle precursor composition to a material of the nanoparticles,"
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.

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.

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
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 13 of 20

U.S. Patent No. 7,803,423: Claim 1
"said precursor composition comprising a first precursor species 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,"
said precursor composition comprising The method used to synthesize the Samsung Quantum Dots uses a precursor composition comprising a first
a first precursor species containing a
precursor species containing a first ion to be incorporated into the nanoparticles and a separate second precursor
first ion to be incorporated into the
species containing a second ion to be incorporated into the nanoparticles.
nanoparticles and a separate second
precursor species containing a second
Samsung’s Quantum Dot synthesis process effects conversion of a nanoparticle precursor composition to a
ion to be incorporated into the
material of the nanoparticles. For example, upon information and belief, Samsung’s Quantum Dots are formed
nanoparticles,
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 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, two of
Page 14 of 20

U.S. Patent No. 7,803,423: Claim 1
"said precursor composition comprising a first precursor species 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,"
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.
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 15 of 20

U.S. Patent No. 7,803,423: Claim 1
"said precursor composition comprising a first precursor species 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,"

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 20

U.S. Patent No. 7,803,423: Claim 1
“wherein said conversion is effected in the presence of a molecular cluster compound different from the first precursor species and the second precursor
species under conditions permitting seeding and growth of the nanoparticles.”
wherein said conversion is effected in
The conversion in the method used to synthesize the Samsung Quantum Dots is effected in the presence of a
the presence of a molecular cluster
molecular cluster compound different from the first precursor species and the second precursor species under
compound different from the first
conditions permitting seeding and growth of the nanoparticles.
precursor species and the second
precursor species under conditions
For example, Samsung’s Quantum Dots are formed using the following synthesis process, which converts a
permitting seeding and growth of the
nanoparticle precursor composition to a material of the nanoparticles:
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 compound different from the first precursor
species and the second precursor species under conditions permitting seeding and growth of 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 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 17 of 20

U.S. Patent No. 7,803,423: Claim 1
“wherein said conversion is effected in the presence of a molecular cluster compound different from the first precursor species and the second precursor
species under conditions permitting seeding and growth of the nanoparticles.”
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.
Page 18 of 20

U.S. Patent No. 7,803,423: Claim 1
“wherein said conversion is effected in the presence of a molecular cluster compound different from the first precursor species and the second precursor
species under conditions permitting seeding and growth of the nanoparticles.”
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.

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.

Page 19 of 20

U.S. Patent No. 7,803,423: Claim 1
“wherein said conversion is effected in the presence of a molecular cluster compound different from the first precursor species and the second precursor
species under conditions permitting seeding and growth of the 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 20 of 20