Invalidity dossier

US 10217801

Added 9/24/2026, 5:33:22 AM

At a glanceNo PTAB challengesNo litigation on fileSemiconductor (T)

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

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US Patent 10,217,801 — Summary

Status of my search: I searched for this specific number (including as "10,217,801") plus BOE / docket / PTAB / Federal Circuit terms. I found no CAFC 2026 docket activity, no PTAB (IPR/PGR) proceeding, and no district-court case specifically asserting US 10,217,801. The BOE-related 2026 litigation I did find involves different patents (e.g., Longitude Licensing v. BOE, E.D. Tex. 2:23-cv-00515, asserting U.S. 7,705,948 / 8,223,093 / 10,181,462; and NeoLayer LLC v. BOE, E.D. Tex. 2:26-cv-00459). None of those assert '801. I could not directly query USPTO Patent Center or PACER/CAFC dockets in this session, so this is a "no hits found" rather than a certified "no litigation exists" — treat the litigation-free finding as provisional.

Bibliographic data

Item Value
Title Light-emitting structure, display device and light source device
Patent number US 10,217,801 B2
Application no. US 14/771,474 (national stage of PCT/CN2014/091134, filed 2014-11-14)
Pre-grant publication US 2016/0293674 A1 (2016-10-06)
Priority date 2014-08-20 (CN 201410412494.4)
Filing date 2014-11-14
Issue date 2019-02-26
Inventors Guang Yan; Chang Yen Wu (assignment style: Chang-Yen Wu)
Assignee (original and current) [BOE Technology Group Co., Ltd.](/litigations/by-plaintiff/BOE%20Technology%20Group%20Co.%2C%20Ltd.)
Status Active; adjusted expiration 2035-01-09; 4th-year maintenance fee paid 2022-08-16
Family US 10,217,801; CN 104218068 A; WO 2016/026223 A1
Claims 20 total

Abstract (as issued)

"A light-emitting structure, a display device and a light source device are disclosed; the light-emitting structure comprises a first light-emitting component (10) and a second light-emitting component (20). The first light-emitting component (10) comprises a first light-emitting layer (12) and a second light-emitting layer (14) and the second light-emitting component (20) comprises a third light-emitting layer (22). A combination of electrical connection of the first light-emitting component (10) and the second light-emitting component (14) is driven by AC current as a whole; the first light-emitting layer (12) and the second light-emitting layer (14) do not emit light at the same time; the third light-emitting layer (22) emits light at the same time either with the first light-emitting layer (12) or the second light-emitting layer (14). AC drive is adopted in the light-emitting structure and is easy to achieve adjustment of color and illumination intensity."

Plain-language overview of the independent claims

Claim 1 — the light-emitting structure (the core claim).

  • Two electrically connected light-emitting "components" whose combination is driven by AC as a whole (i.e., an AC-driven OLED-type stack, not a DC-driven one).
  • The first component contains a first and a second light-emitting layer that do not emit at the same time (each fires on opposite AC half-cycles).
  • The second component contains a third light-emitting layer that emits at the same time as the first layer and also emits at the same time as the second layer — i.e., that layer lights in both half-cycles of the AC period, so the structure puts out light continuously.
  • Structural hook that distinguishes granted claim 1: the first component has an intermediate electrode, the second component has a fourth electrode, and the intermediate electrode is connected to the fourth electrode via a second connection electrode that is in direct contact with the intermediate electrode; the center lines of the second connection electrode, the intermediate electrode, and the fourth electrode are substantially on the same straight line (a collinear/vertically aligned via-type connection).

Note a substantive discrepancy worth flagging: the abstract, summary, and spec describe the third light-emitting layer as emitting with either the first or the second layer, whereas granted claim 1 recites emitting at the same time as the first layer and also at the same time as the second layer. The claim is the operative text. Also, the collinearity/direct-contact limitation in claim 1 does not appear in the specification text I have, which suggests it was added during prosecution; I have not verified its written-description support or the prosecution history.

Claim 19 — light source device. A light source device comprising a plurality of light-emitting structures, where those structures are the claim-1 structure (compositions of the stacked device are not otherwise limited).

Claim 20 — display device. A display device comprising either (a) multiple pixel structures plus a drive circuit connected to them, with the pixel structures containing the claim-1 structure, or (b) a light source device that comprises the claim-1 structure.

Dependent claims 2–18 (context only): claim 2 adds the full electrode architecture (first electrode, intermediate electrode, second electrode with the two emitting layers between them; third electrode; intermediate electrode connected to fourth electrode); claim 3 adds the first connection electrode tying the first and second electrodes; claims 4–13 cover materials/thicknesses (metals such as Li, Mg, Ag, Al, Al–Li, Ca, Mg–In, Mg–Ag; metal oxides such as ITO, IZO, ZnO, AZO, In₂O₃, SnO₂; 5–500 nm ranges; "matched work functions" — claim 6 says "matched working functions" verbatim); claims 14–15 cover the first–sixth organic transport layers; claim 16 sets out the AC half-period light-emission scheme; claims 17–18 cover the third layer's bipolar/dual-transport material and the colors of the layers.

Uncertainty notes

  • Litigation: I cannot confirm from authoritative docket access that '801 is litigation-free as of April 2026; my searches surfaced none, but absence of search hits is not proof of absence.
  • Claim support / prosecution: I have not reviewed the file wrapper, so I cannot confirm the basis for the "center line ... substantially on a same straight line" and "direct contact" limitations in claim 1.
  • Reference-number inconsistency in the source document: the REFERENCE NUMBERS list labels "14—second light-emitting component," while the description consistently uses 14 as the second light-emitting layer and 20 as the second light-emitting component. I am reporting this as it appears rather than correcting it.
  • "tin indium oxide" is used in the patent for what is conventionally called indium tin oxide (ITO); I am quoting the patent's wording literally.

Generated 10/1/2026, 10:54:15 AM

Cases on file (0)

Specific litigation cases in our database that name US patent 10217801. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll search for litigation involving US patent 10217801 across patent litigation databases.

Let me search more targeted litigation databases for this specific patent.

Let me check patent litigation-specific databases and the patent's own litigation history.

Litigation Search Report — U.S. Patent No. 10,217,801

Patent identified literally as US 10,217,801 (US10217801B2)

  • Title: Light-emitting structure, display device and light source device
  • Application No. US 14/771,474 (National Stage of PCT/CN2014/091134)
  • Assignee/Patent Owner: [BOE Technology Group Co., Ltd.](/litigations/by-plaintiff/BOE%20Technology%20Group%20Co.%2C%20Ltd.) (Beijing, CN)
  • Inventors: Guang Yan; Chang Yen Wu
  • Priority: 2014-08-20 (CN 201410412494.4); Granted: 2019-02-26; Status: Active (adjusted expiration 2035-01-09)

Result: No litigation found

I did not locate any litigation — district court, Federal Circuit, ITC, or PTAB — in which U.S. Patent No. 10,217,801 is asserted as a patent-in-suit, challenged, or otherwise at issue.

Searches conducted (per your instructions, targeting patent-litigation sources such as Unified Patents' litigation case list, CourtListener/RECAP, PACER-adjacent document repositories, and USPTO/PTAB filings) returned no case naming 10,217,801 as an asserted or challenged patent.

Important caution — do NOT confuse this with the "'801 patent" hits

My searches surfaced several documents referencing an "'801 patent," but these are different patents and must not be conflated with US 10,217,801:

  1. U.S. Patent No. 7,226,801 — referred to as the "'801 patent" in Optronic Sciences LLC v. BOE Technology Group Co., Ltd., No. 2:23-cv-00549-JRG (E.D. Tex.). This is a totally different patent (LCD sealant-region/saw-tooth pattern claims) and a different number.
  2. U.S. Patent No. 8,319,512 and related numbers appear in PTAB filings (e.g., IPR2025-01413) involving BOE and Longitude Licensing, but that is not 10,217,801 either.

None of these involve U.S. Patent No. 10,217,801.

Caveats on confidence

  • I have high confidence that no litigation specifically asserting or challenging US 10,217,801 appeared in the public results I was able to retrieve.
  • However, I cannot rule out that: (a) litigation exists that is not well-indexed by the sources reachable through the searches performed; (b) a case exists in which BOE (the owner) is a party on other patents while 10,217,801 is not asserted; or (c) a very recent filing (after the indexed coverage window) has not yet appeared. The patent is owned by a large display manufacturer (BOE) that has been active in litigation (e.g., Samsung Display disputes, 337-TA investigations), but no action tied to this specific number surfaced.

Recommendation for confirmation

To definitively confirm the "no litigation" conclusion, verify directly against primary/paywalled dockets that were not fully reachable via web search:

  • PACER / CourtListener RECAP — search "10,217,801" and "10217801"
  • Docket Navigator (patent litigation module)
  • RPX Insight and Unified Patents Portal case lists
  • USPTO PTAB (IPR/PGR/CBM) and USITC EDIS (Section 337) databases

Bottom line: Based on available search results interpreted literally, there is no known litigation involving U.S. Patent No. 10,217,801. I did not return results for similar numbers, though I flagged the look-alike "7,226,801" references so they are not mistaken for this patent.

Generated 10/1/2026, 10:54:10 AM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

I'll verify the ODP "no proceedings" result against public PTAB/Federal Circuit sources before finalizing.

Let me dig into the two leads: the Law360 BOE IPR entry and any PTAB record tied specifically to 10,217,801.

One more verification pass to rule out any PTAB challenge under an alternate citation format.

Proceedings overview

US 10,217,801 ([BOE Technology Group Co., Ltd.](/litigations/by-plaintiff/BOE%20Technology%20Group%20Co.%2C%20Ltd.)) has zero AIA trial proceedings on file at the PTAB — no IPR, PGR, or CBM has ever been filed against it (0 active / 0 claims invalidated / 0 sustained / 0 settled / 0 institution-denied) — which leaves the patent uninvalidated and entirely untested at the Board, so a defendant cannot point to any canceled claim and must instead build its own invalidity record from scratch (or attack the narrow structural limitations in claim 1 that have never been construed by any tribunal).

This is consistent with — not in tension with — the earlier section's finding of no litigation involving this patent. The two findings reinforce each other: the patent has never been asserted as a patent-in-suit, so the usual trigger for a defensive IPR (a complaint) has never fired.

Verification performed (no fictional proceeding numbers)

The canonical source is the structured "PTAB proceedings on file" block (USPTO Open Data Portal ingest), which returns no AIA trial proceedings for application 14/771,474 / patent 10,217,801. I ran corroborating web searches for the patent number in both citation forms (10,217,801 and 10217801) combined with IPR/PGR/petitioner terms. Searches surfaced BOE-related PTAB activity on other patents only — see the near-miss table below. I found no petition, institution decision, FWD, or appeal naming this patent.

Because there are no proceedings, the per-proceeding template and the "strategic summary / estoppel" sections have no case-specific content to populate. I am stating that as a finding rather than filling the template with invented detail.


Near-miss BOE PTAB matters (NOT this patent — do not cite these as challenges to 10,217,801)

These are the BOE-related PTAB proceedings that show up in searches for "BOE" + "IPR." None of them involves US 10,217,801, and none should be represented to a client as an attack on this patent.

Proceeding(s) Parties Status (verbatim from source) Source
IPR2025-00238, IPR2025-00239 BOE Technology Group Co., Ltd. v. Optronic Sciences LLC Discretionary Denial — Acting Director Coke Morgan Stewart denied institution of both, per Paper 11 (PTAB July 29, 2025) Finnegan summary, Law360/ipverse
IPR2025-01482, IPR2025-01483 BOE Technology Group v. PanelTouch Technologies Discretionary Denial (Filed Sep 18, 2025) ipverse BOE competitive analysis
IPR2024-01130 and others; IPR2025-01267/-01245/-01246 BOE Technology Group v. Optronic Sciences LLC / PanelTouch Mixed — several instituted and passed to merits USPTO PTACTS petition papers
IPR2025-01413 (referenced in the earlier litigation section) BOE / Longitude Licensing — USPTO PTACTS

The patents actually at issue in the BOE–Optronic and BOE–PanelTouch matters are unrelated display patents (e.g., a voltage-compensation/pixel patent, a shift-register/clock-coupling patent, a light-shielding-layer patent, the '762 touch-panel patent, the '512 patent). None is 10,217,801. Treat these as background on BOE's PTAB posture only.

Cross-reference caution (carried forward): the "'801 patent" references in Optronic Sciences LLC v. BOE Technology Group Co., Ltd., No. 2:23-cv-00549-JRG (E.D. Tex.) are to U.S. Patent No. 7,226,801, a different patent. Do not conflate.


Per-proceeding detail

None available. No AIA trial proceeding exists for U.S. Patent No. 10,217,801. Accordingly there is:

  • no petitioner to identify,
  • no APJ panel,
  • no institution decision,
  • no Final Written Decision (so no claim of 10,217,801 has been canceled, confirmed, or held unpatentable),
  • no settlement/termination,
  • no Federal Circuit appeal (no CAFC docket number exists to report).

I will not manufacture any of these. Confirmed against the structured ODP block and corroborated via web search on 2026-10-01.


Strategic summary

Claim status: all 20 claims are live and completely untested. Claims 1–20 are in force, unamended, unadjudicated. There are no canceled claims and no sustained claims in the PTAB sense — there has simply never been a challenge. This means every claim, including independent claim 1 and its narrow structural hook (the "center line of the second connection electrode, a center line of the intermediate electrode, and a center line of the fourth electrode are substantially on a same straight line"), remains fully available to the patent owner. Anyone drafting a validity opinion must treat claim 1 as presumptively valid under § 282 and un-narrowed by any administrative proceeding.

Estoppel landscape: nothing is barred, and nothing is estopped in your favor either. Because no IPR/PGR was ever instituted against this patent, § 315(e)(2) estoppel has never attached — no petitioner or privy is barred from raising any ground. Conversely, a defendant today faces no adverse estoppel from this patent's history, but also gains no benefit from prior petitioners' work. Practically, the full universe of § 102/§ 103 art remains open. Note two structural limits if you do file: (1) an IPR may only raise § 102/§ 103 grounds based on patents and printed publications under § 311(b) — § 112 and public-use/on-sale theories must go to district court or an ITC/§ 282 defense; (2) the PGR window is closed — the patent issued 2019-02-26, so the 9-month post-grant window under § 321(c) expired on or about 2019-11-26. IPR is the only AIA vehicle now available. Also note the 2014 priority date means the AIA § 102(a)(1)/(a)(2) framework applies (first-inventor-to-file), not pre-AIA § 102(a)/(b)/(e) — relevant to which art qualifies.

Pattern signals: absent, but the owner is litigation-experienced on other patents. The patent owner (BOE) is clearly a sophisticated PTAB participant — it has filed multiple IPR petitions as petitioner against Optronic Sciences, PanelTouch, and others, and its petitions have been both instituted and discretionarily denied. But on this patent BOE has never been a respondent, and 10,217,801 is not in the Optronic or PanelTouch portfolios. There is no defensive aggregator (e.g., Unified Patents) in the chain for this patent, no serial-petitioner pattern, and no PTAB-appeal activity. The absence of any IPR is a straightforward consequence of the patent never being asserted (per the litigation section), not of any procedural bar or settlement.


Recommended next steps

If you are a defendant and 10,217,801 is asserted against you:

  • There is no FWD to cite and no cancelled claim to rely on. Do not represent to a court or to opposing counsel that any claim of this patent has been invalidated — none has. Any argument built on "claims 1–5 are already dead" would be false for this patent.
  • Your validity attack must be first-instance. IPR is available under § 311 (patents/printed publications, § 102/§ 103 only) and may be filed within one year of service of a complaint alleging infringement under § 315(b) — that clock has not started because the patent has not been asserted (consistent with the litigation section's no-litigation finding). Confirm service dates before relying on this.
  • The natural IPR target is the first connection electrode / intermediate electrode–fourth electrode interconnection and the claim 1 "substantially on a same straight line" center-line limitation — an unusual, potentially narrow structural recitation that appears nowhere in the cited prior art of record (the patent's own citations are to LEDs/OLED stacks such as US 8,089,074, US 2010/0283045, US 2014/0291643, and CN 103168374A). Whether that limitation is supported and how broadly it reads are untested questions.
  • Coordinate district-court invalidity contentions with any IPR to avoid § 315(e)(2) estoppel exposure once a trial is instituted.

If you are monitoring rather than defending:

  • Re-run the ODP/PTACTS query periodically. A patent on a broad, AC-drive OLED architecture — with a large display-manufacturer owner actively monetizing other portfolios — is the type of asset that attracts IPRs once it is asserted. The absence of proceedings is a signal of non-assertion to date, not hardening.

Primary sources to verify independently (no proceeding to link, so these are the checkpoints):

Bottom line: Zero AIA trials, zero canceled claims, zero estoppel. U.S. Patent No. 10,217,801 is a wholly untested patent with all 20 claims live; any invalidity position must be independently constructed.

Generated 10/1/2026, 10:54:36 AM

Ownership chain (1)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2015-08-18 · recorded 2015-08-28 · reel 036452/0971 · Assignment

    WU, Chang-Yen; YAN, GuangBOE TECHNOLOGY GROUP CO., LTD.

    ordinary employer assignment

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll research the assignment record for US 10,217,801, starting with the recorded assignment data in the patent record and cross-referencing the USPTO Assignment Center.

Let me verify the recorded assignment details and check for any post-issuance assignments.

Let me search for the correspondent of record and any additional assignment activity.

Assignment / Ownership Chain Analysis — U.S. Patent No. 10,217,801

Patent: US 10,217,801 B2 — Light-emitting structure, display device and light source device
App. No.: 14/771,474 (National Stage of PCT/CN2014/091134, filed 2014-11-14)
Granted: 2019-02-26 | Status: Active (adjusted expiration 2035-01-09)


Inventors

Inventor Role Employer at filing Basis
Guang Yan Co-inventor [BOE Technology Group Co., Ltd.](/litigations/by-plaintiff/BOE%20Technology%20Group%20Co.%2C%20Ltd.) (as assignor) Named as assignor on Reel/Frame 036452/0971
Chang Yen Wu Co-inventor BOE Technology Group Co., Ltd. (as assignor) Named as assignor on Reel/Frame 036452/0971; listed with 22 BOE-assigned patents (Patent Leaderboard, Chang Yen Wu — 22 Patents at BOE, https://www.patentleaderboard.com/boe/chang-yen-wu/[884958](/patent/884958))

Pattern note: Both inventors executed an assignment to BOE (recorded 2015-08-28), which is the ordinary employer-owns-invention pattern for a corporate R&D team — not a departure/fire-sale signature. There is no evidence of either inventor departing BOE within 12 months of filing, and Wu's continued accumulation of 22 BOE-assigned patents indicates sustained employment. No unusual inventor-side signal.


Original assignee

BOE Technology Group Co., Ltd. (Beijing, China) — the entity named on the issued patent and the sole recorded assignee.

  • Line of business: One of the world's largest display-panel manufacturers (LCD/OLED panels, display modules). This patent is squarely within BOE's core OLED/display business.
  • Product embodiment: The patent discloses an AC-driven OLED light-emitting structure with laminated light-emitting layers and an intermediate electrode, expressly contemplated for OLED display pixels, LCD backlight sources, and neon-lamp-style illumination (see spec, Second–Fourth Embodiments). BOE ships commercial OLED display products, so the claims read on the assignee's own product line.
  • Current status: Operating. BOE remains an active, publicly traded display manufacturer. Reassignment recorded 2015-08-28 (see below) and a 4th-year maintenance fee paid 2022-08-16 (Large Entity) confirm the patent is being actively maintained by the original corporate owner; no abandonment, bankruptcy, or divestiture event appears in the record.

Assignment timeline

Only one assignment is recorded against this patent in the record retrieved (Google Patents legal events, which mirrors USPTO Assignment Center data):

  • 2015-08-18 (executed) / recorded 2015-08-28 — Reel 036452 / Frame 0971
    • Conveyance: Assignment (recorded as "ASSIGNMENT OF ASSIGNOR'S INTEREST")
    • Assignor: WU, Chang-Yen; YAN, Guang (both, jointly)
    • Assignee: BOE Technology Group Co., Ltd. (Beijing, CN)
    • Correspondent: Not determinable from the sources retrievable here. Google Patents' legal-events field does not expose the recording correspondent (attorney/agent of record), and the Assignment Center page itself was not directly reachable via the search tools used. I will not fabricate a name. This is the one field the task specifically asks for that I could not confirm — see caveat below.
    • Context: Ordinary employer assignment of inventor rights (inventors → their corporate employer). This is the routine pre-issuance conveyance that establishes BOE's title; it is not an acquisition, fire-sale, internal reorg, securitization, or transfer-to-asserter.

No post-issuance assignments are recorded. There is no record of the patent ever leaving BOE.

Confidence caveat on the correspondent field: The recurring-attorney tell — the single most diagnostic NPE signal — cannot be evaluated here because the correspondent of record for Reel 036452/0971 was not surfaced by the available sources. To capture it, open https://assignmentcenter.uspto.gov/ and query patent number 10,217,801 (or app. 14/771,474) directly; the reel/frame record will display "Correspondent" with the attorney name and address.


Timeline diagram

timeline
    title Ownership of US 10217801
    2014 : Priority filing by BOE inventors
         : PCT filed naming BOE
    2015 : Inventors assign rights to BOE
         : Recorded at Reel 036452 Frame 0971
    2016 : US publication of application
    2019 : Patent granted to BOE
    2022 : 4th year maintenance fee paid
    2035 : Adjusted expiration

NPE / troll-pattern signals

# Signal Call Evidence
1 Shell-entity transfer Not present No transfer to any "IP / Patents / Licensing / Holdings / Ventures" entity. The only recorded assignment runs to the operating manufacturer BOE (Reel 036452/0971). BOE is a product-shipping company, not a single-purpose LLC.
2 Known asserter in the chain Not present Neither assignor nor assignee matches any public NPE list (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant, Vringo, Pendrell, etc.). Sole assignee = BOE Technology Group, an operating display maker.
3 Repeat correspondent across the chain Unclear There is only one link in the chain, so "recurrence" is definitionally impossible within this patent. The correspondent name itself was not retrievable (see caveat). No basis to flag.
4 Cascading transfers Not present No consecutive assignments at all — a single first-instance assignment from inventors to employer. Nothing cascades.
5 Pre-litigation transfer Not present The prior litigation search (see Litigation summary above) found no suit asserting or challenging US 10,217,801. There is therefore no lawsuit against which a pre-suit transfer could be timed. The 2015 assignment predates any hypothetical assertion by years and is the standard employer capture.
6 Bankruptcy fire-sale Not present No Chapter 7/11 event, no trustee sale, no patent-sale proceeding involving BOE or this patent appears in the record. BOE is operating and current on maintenance fees (2022-08-16).
7 Privateering Not present BOE has not transferred this patent to any third-party NPE; ownership never left BOE. No SEC/8-K or Patent Progress/EFF coverage ties this patent to a proxy assertion campaign.
8 Defensive aggregator (anti-NPE) Not present Chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. It terminates at the original operating manufacturer.

Verdict

Insufficient data — resolving to: Not an NPE; operating-company ownership.

Justification: The entire recorded chain is a single conveyance — inventors Wu and Yan to their employer BOE Technology Group Co., Ltd., executed 2015-08-18 and recorded 2015-08-28 at Reel 036452 / Frame 0971 — after which ownership never moved. Every NPE indicator (shell transfer, known asserter, cascading transfers, pre-litigation transfer, fire-sale, privateering) is absent, and the sole assignee is a product-shipping display manufacturer that is still paying maintenance fees (4th year, 2022-08-16). Because the recording correspondent was not retrievable from the sources available, I cannot fully close out signal #3 (repeat correspondent), which is why I frame the verdict as evidence-limited rather than a clean "operating-company assertion." This patent appears to be a defensive/organic corporate asset of BOE, not an NPE vehicle.

Verify directly at: https://assignmentcenter.uspto.gov/ (search patent no. 10,217,801 or app. 14/771,474) — this will confirm the single Reel 036452/0971 record and, critically, reveal the correspondent of record that I was unable to retrieve.

Generated 10/1/2026, 10:54:31 AM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll search for the patent and each cited reference to ground the prior-art analysis.

USPTO lookup — literal number check

I searched for the exact identifier 10217801 (and "10,217,801"). The record that resolves to this number is:

  • US 10,217,801 B2, Light-emitting structure, display device and light source device
  • Appl. No. US 14/771,474 — §371 national stage of PCT/CN2014/091134, filed 2014-11-14
  • Pre-grant pub. US 2016/0293674 A1 (2016-10-06); granted 2019-02-26; assignee [BOE Technology Group Co., Ltd.](/litigations/by-plaintiff/BOE%20Technology%20Group%20Co.%2C%20Ltd.)
  • Priority 2014-08-20 (CN 201410412494.4)
  • Source: https://patents.google.com/patent/US10217801/en (Google Patents mirrors the USPTO bibliographic/citation data; I could not open Patent Center directly in this session)

No similar-number record was substituted; the look-alike "7,226,801" (a different patent) is noted only so it is not confused with this one.


Framework for the §102 analysis

  • The effective filing date is 2014-08-20 (the CN priority date), and the application was filed after 16 March 2013, so the AIA version of 35 U.S.C. §102 governs.
  • §102(a)(1) art = printed publications/patents publicly available before 2014-08-20.
  • §102(a)(2) art = U.S. patents or U.S. application publications that were effectively filed before 2014-08-20, even if published later.
  • Anticipation requires a single reference disclosing every limitation of a claim. Where a reference discloses only some limitations, I say so and label it a §103 (obviousness) reference rather than an anticipation reference.

Reference-date caveat: two of the twelve cited references were published after the 2014-08-20 priority date and therefore can only be §102(a)(2) art (US 2014/0291643 A1, pub. 2014-10-02; US 8,994,011 B2, granted 2015-03-31). Every other citation is §102(a)(1) art.


The citations appearing on the face of US 10,217,801

Google Patents lists 12 patent citations on the '801 face, which collapse into six families/entities plus one "family-cited" document:

Ref Family / entity Pub./grant date Basis
US 2008/0211400 A1; US 8,089,074 B2; CN 101263610 A Seoul Opto Device (inorganic stacked LEDs) 2008-09-04; 2012-01-03; 2008-09-10 §102(a)(1)
US 2010/0283045 A1; CN 101911332 A Sharp / Hideki Uchida (OLED, AC drive) 2010-11-11; 2010-12-08 §102(a)(1)
US 2008/0116450 A1 Matsushita (mobility-engineered EL) 2008-05-22 §102(a)(1)
US 2011/0255185 A1 Hideyuki Hashi ("Drive unit") 2011-10-20 §102(a)(1)
CN 103168374 A; US 2013/0153879 A1; US 8,994,011 B2 LG Chem (organic light-emitting device) 2013-06-19; 2013-06-20; 2015-03-31 §102(a)(1) (pub.); §102(a)(2) (grant)
US 2013/0256637 A1; US 2014/0291643 A1 Semiconductor Energy Lab. (EL element / organic compound) 2013-10-03; 2014-10-02 §102(a)(1) (2013/0256637); §102(a)(2) (2014/0291643)
WO 2007/057138 A2 — listed under "Family Cites Families," not examiner citations Syngenta (biphenyl synthesis) 2007-05-24 §102(a)(1) (if relied on)

Reference-by-reference

1. Seoul Opto Device family — stacked LEDs driven from AC

Full citations: US 2008/0211400 A1, "Light Emitting Device Having Vertically Stacked Light Emitting Diodes," pub. 2008-09-04, App. 12/064,228 (§371 of PCT/KR2006/003844, filed 2006-09-26); granted as US 8,089,074 B2, 2012-01-03; CN 101263610 A, 2008-09-10.
Description (from the retrieved text): GaN-based inorganic LEDs in which a lower and upper light-emitting diode share a middle semiconductor layer, with a separating/semi-insulating layer option; multiple cells can be wired in series arrays connected in reverse parallel to an AC supply, so the lower and upper diodes fire alternately with AC phase. Emphasizes increased light output per chip area under AC drive.
Anticipation relevance: No anticipation of claim 1. It does disclose stacked emitters with an interior common electrode and AC/reverse-parallel operation (relevant to claim 2's intermediate-electrode architecture and claim 16's half-period scheme), and it is inorganic, not the claimed layered OLED. Critically, there is no third emitting layer that emits in both half-cycles simultaneously with each of the first and second layers, and no "second connection electrode … in direct contact … center lines … substantially on a same straight line." Best characterized as a §103 reference against claims 2/16 (and possibly 19/20) when combined with an OLED/AC-drive reference.

2. Sharp / Uchida family — the closest art on AC-driven "bipolar" emission

Full citations: US 2010/0283045 A1, "Organic electroluminescent element," pub. 2010-11-11, App. 12/811,058 (§371), priority 2007-12-28; CN 101911332 A (Sharp), 2010-12-08.
Description (from the retrieved text): Organic EL element in which the emitting layer is sandwiched by metal-oxide nanoparticle layers and a pair of electrodes. The specification expressly teaches AC drive, noting that on AC the device "appears that electrons and holes can be injected into the light-emitting layer in either electric field direction," that at least two emission centers form in the layer, that it can emit in each electric-field direction, and that AC drive (preferably ≥60 Hz) extends element life by avoiding a fixed emission center and DC stress.
Anticipation relevance: This is the closest citation to the rationale and structure of the second light-emitting component / third light-emitting layer (bipolar emission in both half-cycles; life extension under AC — directly parallel to the '801 spec's stated benefit). It is a strong §103 reference for claim 1's "third layer emits in both half-cycles" concept and for claim 17 (bipolar/electron-and-hole-transporting emitting material) and parts of claims 6/9 (metal-oxide layers). It does not disclose the first component (two emitting layers that never emit simultaneously) or the claimed second-connection-electrode geometry, so it does not anticipate claim 1.

3. Matsushita — mobility-engineered EL device

Full citation: US 2008/0116450 A1, "Mobility engineered electroluminescent devices," pub. 2008-05-22, priority/filing 2006-11-16.
Description: OLED-type device in which charge-carrier mobilities/transport are engineered (balanced electron/hole transport) to improve recombination and efficiency.
Anticipation relevance: Relevant to the claims 14–15 organic transport/hole-blocking layers and, indirectly, to claim 17 (a base material that transports electrons/holes). It discloses no stacked/AC architecture, no intermediate electrode, and no connection electrode. No anticipation; §103 material only.

4. Hashi — "Drive unit" (⚠ flagged discrepancy)

Full citation: US 2011/0255185 A1, "Drive unit," inventor Hideyuki Hashi, pub. 2011-10-20, priority 2010-04-15.
Description (as retrieved): The content matching this number/inventor that my search returned describes a camera/interchangeable-lens vibratory-actuator drive unit (lens frame, ultrasonic actuator) — i.e., not an OLED or display-drive disclosure.
Anticipation relevance: No anticipation of any claim. On its face (as retrieved) it is non-analogous art to a light-emitting structure/OLED drive scheme, and it shares no element of claim 1. If the examiner did cite it against the '801 disclosure, its pertinence is unclear from the text I retrieved — I flag this rather than assume a subject-matter match. (It may also be a search-index mismatch; I could not fully verify.) Treat as non-material / uncertain.

5. LG Chem family — "organic light emitting device"

Full citations: CN 103168374 A (株式会社LG化学), pub. 2013-06-19, priority 2010-08-17; US 2013/0153879 A1, "Organic light-emitting device," pub. 2013-06-20 (same priority); US 8,994,011 B2, "Organic light-emitting device," granted 2015-03-31.
Description: Organic light-emitting device (LG Chem's stacked/tandem-OLED line) — the family typically concerns multi-unit/stacked OLED structures and transport/charge-generation layer arrangements. (My search step for this family's detail was cut off; this description is based on title/assignee/priority and should be verified.)
Anticipation relevance: Potentially relevant as a §103 reference to claims 2 and 14 (stacked emitting layers with an interior electrode/charge-generation layer) and to the §102(a)(2) status of US 8,994,011 B2 (effectively filed 2010-08-17, before 2014-08-20). No single-reference anticipation of claim 1 (no AC dual-half-cycle third layer; no collinear direct-contact second connection electrode).

6. Semiconductor Energy Laboratory — EL element and organic compound

Full citations:

  • US 2013/0256637 A1, "Light-Emitting Element, Light-Emitting Device, Display Device, Electronic Appliance, and Lighting Device," pub. 2013-10-03, priority 2012-03-30 (§102(a)(1)).
  • US 2014/0291643 A1, "Organic Compound, Light-Emitting Element, Light-Emitting Device, Display Device, Electronic Device, and Lighting Device," pub. 2014-10-02, priority/filing 2013-03-26 → only §102(a)(2) art (published after the '801 priority date; effectively filed before it).

Description: The 2013/0256637 publication discloses a light-emitting element with an EL layer containing a first emitting layer on the anode side and a second emitting layer on the cathode side, each with electron-transporting host materials whose LUMO levels differ — i.e., two stacked emitting layers with tailored host/transport carriers. The 2014/0291643 publication concerns an organic compound and the element/device using it (host/emitting material chemistry).
Anticipation relevance: Relevant to claims 2/14/17 (multiple emitting layers, each with an electron/hole-transporting host) and to generic claim 18 (colors). Neither discloses AC drive, a third layer emitting in both half-cycles simultaneously with each of the first two, or the claimed connection-electrode geometry. No anticipation of claim 1; §103 and (for 2014/0291643) §102(a)(2)-only material. Because 2014/0291643 A1 published after the priority date, it cannot be §102(a)(1) art — do not treat it as pre-2014-08-20 public disclosure.

7. WO 2007/057138 A2 — Syngenta ("Family Cites Families")

Full citation: WO 2007/057138 A2, "Process for the production of biphenyls," Syngenta Participations Ag, pub. 2007-05-24, priority 2005-11-15.
Description: A chemical synthesis process for biphenyls.
Anticipation relevance: No anticipation. It is listed only as a "Family Cites Families" document (cited by family members), not among the examiner's face-of-patent citations, and it discloses no light-emitting structure or drive scheme. Its only conceivable use would be background on the biphenyl-based hole-transport compounds discussed in the '801 spec (claims 14/15 context) — a §103-support point at most.


Which claims, if any, are anticipated?

Bottom line: none of the cited references anticipates claim 1 (or claims 19/20, which incorporate it) as a single reference.

Claim 1 requires the conjunction of (i) a first component with first and second emitting layers that never emit at the same time, (ii) a second component whose third emitting layer emits in both half-cycles (i.e., simultaneously with the first layer and simultaneously with the second layer), and (iii) the structural hook: an intermediate electrode connected to the fourth electrode via a second connection electrode in direct contact, with the center lines of the second connection electrode, intermediate electrode, and fourth electrode substantially on a same straight line.

  • The Seoul family gives the stacked-emitter + AC/reverse-parallel concept but is inorganic and lacks the dual-half-cycle third layer and the connection-electrode geometry.
  • The Sharp/Uchida family gives AC-driven emission in both field directions with life extension but lacks the first component's two non-simultaneous emitting layers and the connector geometry.
  • No cited reference, alone, supplies both the "non-simultaneous first/second layers" and the "both-half-cycles third layer," let alone the collinear direct-contact second connection electrode (a limitation added during prosecution, per the earlier section of this analysis — its written-description support is unverified here).

Closest §103 combinations (for the narrower claims, not claim 1):

  • Claim 16 (AC half-period emission scheme): Seoul (reverse-parallel arrays) + Sharp/Uchida (AC, both-direction emission) + LG Chem or SEL (layered OLED architecture).
  • Claims 2 & 14 (electrode/stacked-layer architecture, transport layers): Seoul (stacked/interior electrode) + LG Chem or SEL 2013/0256637 (multi-emitting-layer OLED).
  • Claims 6/9/13 (metal-oxide layers, matched work functions): Sharp/Uchida (metal-oxide nanoparticle layers).
  • Claims 14/15/17 (organic electron/hole-transporting layers; bipolar doped emitting material): Matsushita (mobility engineering) + SEL 2013/0256637 (electron-transport host) + Sharp/Uchida (bipolar AC emission).
  • Claim 18 (colors of the three layers): generic; no specific reference is needed.

Confidence and caveats

  • Verified: the twelve face-of-patent citations, their dates/titles/assignees, and the two "family-cited"/non-analyzed items, all from the authoritative patent text and corroborating search results.
  • Unverified detail: I could not complete retrieval of the LG Chem (CN 103168374 A / US 2013/0153879 / US 8,994,011) subject matter before the search-step limit; that description rests on title/assignee/priority and should be confirmed against the full text.
  • Flagged discrepancy: the retrieved US 2011/0255185 A1 ("Drive unit," Hashi) text describes a camera-lens actuator, which is non-analogous to this patent; either the pertinence is minimal or my index match differs from the examiner's reference — reported as found, not corrected.
  • §102(a)(2) reminders: US 2014/0291643 A1 (published 2014-10-02) and US 8,994,011 B2 (granted 2015-03-31) are not §102(a)(1) art; they bear only on §102(a)(2) unless a 102(b)(2) exception applies (not apparent, as assignees differ).
  • Non-patent citations (Chinese Office Action 2016-07-26; ISR, Notice of Transmittal, and Written Opinion of PCT/CN2014/091134, all 2015-04-28) are prosecution documents, not prior art, and are not analyzed for §102.

Generated 10/1/2026, 10:55:13 AM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground my analysis in the prior art actually listed on the patent page, verifying each reference's disclosure through search.

Let me verify a few of the remaining listed references.

Obviousness Analysis — U.S. Patent No. 10,217,801 under 35 U.S.C. § 103

Analysis of the prior art listed in the "Prior Art" (Citations / Patent Citations) section of the Google Patents page for US10217801B2 (https://patents.google.com/patent/[US10217801](/patent/US10217801)/en). Building on the claim construction and litigation sections already produced; I do not repeat them.


1. Legal framework and critical date

Item Value
Earliest effective filing date (critical date) 2014-08-20 (CN 201410412494.4); PCT filed 2014-11-14
Governing statute AIA §§ 102/103 (filed after 2013-03-16)
Prior art window 102(a)(1): publicly available before 2014-08-20; 102(a)(2): U.S. patent/application publication effectively filed before 2014-08-20
Claim set 20 claims; independent claims 1 (structure), 19 (light source device), 20 (display device)

PHOSITA (proposed, for this art): a person with a bachelor's degree in electrical engineering, materials science, or applied physics and 2–3 years of experience designing OLED/light-emitting devices, including stacked (tandem) organic stacks, transparent/intermediate electrodes and charge-generation/connecting layers, and driver architectures for LEDs/OLEDs. This is a routine-skill art; the '801 itself acknowledges in its Background that OLED structure and drive mode were recognized as "the primary factors in improving its stability."


2. The prior art of record, and what it maps to

Everything below is from the Citations / Patent Citations lists on the '801 page. Verification status is stated per reference — I do not attribute disclosures to references I could not open.

Ref. (as listed) Date Verified this session? Disclosure / relevance '801 claim elements reached
US 8,994,011 B2 (LG Chem) — "Organic light-emitting device"; CN 103168374 A; US 2013/0153879 A1 Prio. 2010-08-17; CN pub. 2013-06-19; US patent 2015-03-31 Yes — https://patents.google.com/patent/US8994011 ("Definitions" text) Device with a substrate and two or more stacked light emitting elements each comprising "a first electrode, at least one intermediate electrode, a second electrode, and an organic material layer disposed between the electrodes"; a first group of electrodes electrically connected so at least two non-adjacent electrodes are at a common potential and a second group likewise; the stacked elements are "driven by an alternating current power source such that a form, in which a first group of electrodes of one stacked organic light emitting element … are directly connected to a second group of electrodes of another stacked organic light emitting element, is continuously repeated." Stated objects: AC drive without a converter, and "various light emission colors." Claim 1: two electrically connected light-emitting components; intermediate electrode; whole stack AC-driven; (and, at minimum, strongly suggestive of) cross-connection between an internal electrode of one unit and an electrode of the other
US 2013/0256637 A1 (Semiconductor Energy Lab) — "Light-Emitting Element, Light-Emitting Device, Display Device, Electronic Appliance, and Lighting Device" Prio. 2012-03-30; pub. 2013-10-03 Yes — https://patents.google.com/patent/US20130256637A1/en Light-emitting element with anode, cathode and an EL layer between them, the EL layer having at least a light-emitting layer comprising a first light-emitting layer on the anode side and a second light-emitting layer on the cathode side; each layer contains a host material and an emission-center substance; different hosts/LUMO relationships; express purpose is "a light-emitting element with a small degree of luminance degradation over driving time (a long-lifetime) element" Claim 1: plural light-emitting layers stacked between electrode pairs of one "component"; Claim 17: "base material doped with a light-emitting material"; the '801's stated life-extension advantage
US 8,089,074 B2 (Seoul Opto Device) — "Light emitting device having vertically stacked light emitting diodes"; US 2008/0211400 A1 and CN 101263610 A (same family, priority 2005-09-30) Prio. 2005-09-30 Yes — https://patents.google.com/patent/[US8089074B2](/patent/US8089074B2)/en (full text retrieved) Vertically stacked lower and upper LEDs sharing a common intermediate semiconductor layer (P-type layer 29) between the two active layers; lower/upper active layers "may be formed as different material layers such that light with different wavelengths can be emitted"; electrodes of adjacent cells connected by in-plane metal wirings (41, 42a/b); arrays of lower LEDs and upper LEDs connected in reverse parallel to an AC power supply, so that the two sets "are alternately operated" and "light is emitted throughout the entire region of a chip under an AC power supply"; background expressly discusses Sakai WO 2004/023568 (reverse-parallel LED arrays driven from AC) and the problem that alternately-operated arrays give limited light output Claim 1: stacked emitting layers sharing an intermediate electrode; different emission colors from the two (groups of) emitting layers; anti-parallel/alternating emission on opposite AC half-cycles; per-unit-area output motivation
US 2008/0116450 A1 (Matsushita) — "Mobility engineered electroluminescent devices" Prio. 2006-11-16; pub. 2008-05-22 Not verified this session Cited by examiner per the page. Title is self-describing as carrier-mobility engineering in electroluminescent devices. I will not assert specific disclosures. Potentially claims 14–15 (organic transport/blocking layers) — treat as unproven
US 2010/0283045 A1 (Uchida) — "Organic electroluminescent element"; CN 101911332 A Prio. 2007-12-28; pub. 2010-11-11 Not verified this session Titled as an organic EL element; CN counterpart assigned to 夏普 (Sharp) per the page. Likely relevant to stacked/intermediate-layer OLED architecture, but unverified. Potentially claim 1's intermediate electrode / claims 14–15
US 2014/0291643 A1 (Semiconductor Energy Lab) — "Organic Compound, Light-Emitting Element, Light-Emitting Device, Display Device, Electronic Device, and Lighting Device" Prio. 2013-03-26; pub. 2014-10-02 Not verified this session (search limit reached) Timing note: publication (2014-10-02) is after the '801 critical date, so it is not § 102(a)(1) art; it can only be § 102(a)(2) art, and only because its effective filing date (2013-03-26) precedes 2014-08-20 (subject to § 102(b)(2) exceptions). A sibling SEL filing in the same programme (US 2017/0263878) describes a light-emitting layer that is "a stacked-layer structure of: a first light-emitting layer …; a second light-emitting layer …; and a third light-emitting layer," each containing an emission material plus both an electron-transport material and a hole-transport material — i.e., the bipolar/mixed-host emitting layer. I flag this as consistent with, not proof of, '643's content. Claim 17 ("base material … able to transmit electrons and/or holes" / bipolar emitting layer)
US 2011/0255185 A1 (Hashi) — "Drive unit" Prio. 2010-04-15; pub. 2011-10-20 Searched — result is anomalous The document returned for application 20110255185 ("Drive unit") describes a lens frame, movable body and vibratory/ultrasonic actuator, not an OLED drive circuit (https://www.patents-review.com/a/20110255185-drive-unit.html). Taken literally and prioritizing the search result over my priors, this reference does not supply an AC-drive teaching for an OLED. I therefore exclude it from my grounds and note the anomaly rather than "fixing" it. None established

Non-prior-art items on the page (be careful not to rely on them): CN 104538553 B ("Color-adjustable organic electroluminescent device") and CN 104600095 B (北京维信诺科技有限公司) both carry a 2014-12-31 priority — after the '801 critical date — and appear only in the "Families Citing this family" list. They are citing documents, not citable art against the '801. WO 2016/026223 A1 and CN 104218068 A are the '801's own family; WO 2007/057138 A2 (Syngenta, biphenyls process) appears in "Family Cites Families" and is immaterial.

Net picture of the art of record: it collectively discloses (a) two or more organic emitting layers stacked between electrode pairs in one element, of different colors, for color mixing and lifetime improvement (SEL '637, LG Chem '011); (b) an intermediate electrode inside a stacked organic device, with the electrode groups cross-connected so the stack as a whole is AC-driven without a rectifier, giving adjustable color (LG Chem '011); and (c) two emitting elements alternately driven on opposite AC half-cycles — including via reverse-parallel connection and with different emission wavelengths — for continuous chip emission under AC (Seoul Opto '074, and the Sakai publication discussed in it). What the art of record does not clearly show is the exact geometry recited at the end of claim 1 (see §5).


3. Element-by-element reading of claim 1 against the art

Building on the claim-1 breakdown already produced:

Claim 1 element Primary teaching
(a) First + second light-emitting components electrically connected LG Chem '011 (two or more stacked light emitting elements with connecting electrode groups); Seoul Opto '074 (stacked lower/upper LEDs + wiring between cells)
(b) First component has first and second light-emitting layers SEL '637 (anode-side first emitting layer + cathode-side second emitting layer between the electrode pair); SEL '643-type mixed-host bipolar emitting layers
(c) Second component has a third light-emitting layer LG Chem '011 (an organic material layer with an emitting layer per element); Seoul Opto '074 (upper active layer of different material)
(d) Combination driven by AC as a whole LG Chem '011 expressly ("driven by an alternating current power source without a converter which converts alternating current into direct current"); Seoul Opto '074 (reverse-parallel arrays across an AC supply)
(e) First and second layers do not emit at the same time Seoul Opto '074 ("as the phase of the AC power supply is shifted, the arrays of the upper and lower … diodes are alternately operated"); inherent in anti-parallel connection; SEL '637's anode-side/cathode-side pair is the natural structural implementation
(f) Third layer emits with the first and with the second layer A bipolar emitting layer of the kind described in the SEL '643 programme (emission material plus both electron-transport and hole-transport materials, permitting carrier injection in both bias directions) — this is exactly the structure the '801's own specification describes for its second component ("bipolar organic light-emitting diode which may emit light through driving of bi-direction current")
(g) Intermediate electrode; fourth electrode; second connection electrode in direct contact with the intermediate electrode; center lines of the second connection electrode, intermediate electrode and fourth electrode substantially on the same straight line Not shown in any listed reference in this exact geometric form. LG Chem '011 gets close functionally (intermediate electrode + direct connection to another element's electrode); Seoul Opto '074 connects electrodes in-plane via metal wirings formed in the same layer. See §5.

4. Proposed § 103 grounds

Ground 1 — LG Chem '011 (+ CN 103168374 A / US 2013/0153879 A1) as primary, in view of SEL '637

Combination: the AC-drivable stacked structure and cross-connected intermediate electrode of LG Chem '011, populated with the anode-side/cathode-side stacked emitting-layer pair of SEL '637 as the first component's two layers, with the second component's emitting layer being a bipolar layer per the SEL '643 teaching.

Motivation (KSR factors):

  1. Same field, same problem. Both references address stacked organic light-emitting devices; LG Chem's stated objects are AC drive without a converter and "various light emission colors"; SEL '637's stated object is reduced luminance degradation/long lifetime. The '801 claims exactly these two benefits (adjustable color/intensity; "service life … prolonged").
  2. Predictable result. Because each of SEL '637's two stacked layers is on opposite sides of the stack's mid-plane, driving the stack with AC necessarily forward-biases one and reverse-biases the other on each half-cycle — so the layers inherently alternate. Placing a bipolar emitting layer in the other parallel branch yields emission every half-cycle. There is nothing unpredictable: the asserted phenomenon is the simple superposition of two anti-phase emitters integrated by persistence of vision (which LG Chem also invokes via "various light emission colors").
  3. Design incentive / obvious to try. Seoul Opto '074 itself states the recognized problem that alternately-operated AC-driven emitters give "considerably limited" light output; adding a branch that emits during the "off" half-cycles is the direct, predictable fix. LG Chem's own "continuously repeated" cross-connection scheme is an invitation to wire additional emitting elements into the repetition.
  4. Reasonable expectation of success. All components are known OLED constructs (emitting layers, transport layers, a thin metal intermediate electrode) in a known drive regime (AC). No new chemistry or new physics is required.

Ground 2 — Seoul Opto '074 (+ Sakai WO 2004/023568 as discussed therein) + LG Chem '011 + SEL '637

Combination: Seoul Opto's stacked, color-mixing, reverse-parallel AC emitters as the architecture; LG Chem '011 for the intra-stack intermediate electrode and the unified AC drive of the stack; SEL '637 for the two-in-one-element emitting-layer pair.

Motivation: Seoul Opto expressly frames its invention around two objects — "increase light output per unit area" and "improved light output which can be driven under an AC power supply" — and expressly criticizes reverse-parallel arrays where "LED arrays are alternately operated under an AC power supply, [so] its light output is considerably limited." A PHOSITA seeking to satisfy those stated objects would look to (i) stacking emitters and (ii) ensuring emission in both half-cycles; the '801's second component (bipolar, both-half-cycle emitter) is the predictable answer, and color adjustability follows from selecting different emission colors for the two alternately-driven layers, which Seoul Opto already teaches ("active layers … formed of different materials, a light emitting device capable of emitting light with various wavelengths can be provided"). Also note Seoul Opto enables the "connected by wiring" aspect of claim 1 via metal wirings 41/42a/42b formed in a single layer — the same fabrication approach as the '801's second connection electrode.

Ground 3 — any of Grounds 1–2 further in view of Matsushita '450 and/or Uchida '045 (dependent claims 4–15)

For claims 4–13 (metal/metal-oxide electrodes; 5–500 nm; "matched work functions") and 14–15 (first through sixth organic layers for electron/hole transport): these are conventional materials selections and thickness ranges for OLED electrodes and transport/injection/blocking layers. A PHOSITA optimizing an organic stack routinely selects Li, Mg, Ag, Al, Al–Li, Ca, Mg–In, Mg–Ag or ITO/IZO/ZnO/AZO/In₂O₃/SnO₂ and thicknesses in the few-nm-to-hundreds-of-nm range, and inserts electron/hole injection, transport and blocking layers. The Matsushita and Uchida references (examiner-cited, not verified by me) are titled to carrier-mobility engineering in EL devices and to an organic EL element respectively, and are the natural candidates for this role; I do not assert their specific disclosures. Even without them, "a metal layer thin enough to be transparent" and "matched work functions" (the '801 defines this as merely a difference "more preferable less than 0.5 eV") are the kind of predictable, result-effective variable optimization that KSR/In re Boesch-type reasoning treats as obvious in the absence of unexpected results.

Ground 4 — claims 19 and 20 (light source device; display device)

Claims 19–20 add nothing but application: a plurality of the claim-1 structures (claim 19), and pixel structures with a drive circuit, or a light source device, containing the claim-1 structure (claim 20). Both LG Chem '011 ("various light emission colors") and Seoul Opto '074 (arrays of light-emitting cells; reference to illumination/white LEDs in its Background) explicitly contemplate arrays and illumination/display uses, and the '801 itself flatly recites the intended uses (backlight for an LCD, neon-lamp ornament display, and "any product or component having a display function"). Choosing an AC drive circuit to drive AC-driven emitters is the use of a known element for its established function.


5. The crux: the "center line / direct contact" limitation of claim 1

The tail of claim 1 — intermediate electrode connected to the fourth electrode via a second connection electrode, in direct contact, with the center lines of the second connection electrode, the intermediate electrode and the fourth electrode substantially on the same straight line — does not appear in the specification text I have (consistent with the flag already raised in the summary section: this looks like a prosecution amendment). Since the examiner allowed claim 1 with this limitation while four of these references were of record, any § 103 challenge must defeat this limitation as an obvious design choice. The case is reasonably strong:

  1. The limitation is a same-layer lateral link, not a new device physics. The '801's own description states that the intermediate electrode 13 "is formed on the same layer as the fourth electrode 23" and that "it is only necessary to maintain the connection of the patterns of the intermediate electrode 13 and the fourth electrode 23 to form the second connection electrode 24." A continuous same-layer conductive strip joining two coplanar patterns, by definition, has its own center line collinear with the two patterns' center lines. The claim adds no dimension, tolerance, layer thickness or functional consequence; "substantially" renders the geometry indefinite in scope.
  2. The alternative in the same patent is harder, proving the choice is a design trade-off, not an invention. The first connection electrode 16 requires an insulation layer and a through-hole. Connecting electrodes without a via — i.e., in the same plane — is the simplest, lowest-mask-count option, so a PHOSITA has an express reason to choose it.
  3. The prior art already connects electrodes in-plane in the same layer. Seoul Opto '074 connects electrodes of adjacent stacked light-emitting cells "through metal wirings 41" formed "using an air-bridge or step-cover process," and its FIGS. 10–16 show in-plane wirings (42a/42b, 75a/75b) linking electrode pads of neighboring cells. LG Chem '011 claims direct connection of one stacked element's electrode to another's.
  4. No nexus / no unexpected result. Nothing in the '801 ties the collinearity or direct contact to the asserted benefits (color adjustability, prolonged life). Those benefits flow from the drive scheme and layer choice, not the connector geometry. Under KSR, "the improvement is [no] more than the predictable use of prior art elements according to their established functions."

Conclusion on the crux: if the collinear/direct-contact limitation is treated as the only distinction over LG Chem '011 + SEL '637 (+ Seoul Opto '074), it is vulnerable as an obvious design choice. This is, however, the strongest non-obviousness argument BOE retains, and it is the one the examiner apparently accepted.


6. Counterarguments a challenger must overcome (and where the obviousness case is weak)

  1. Everything was before the examiner, and the claim still issued. Four of the listed references are marked as examiner citations on the page (US 2008/0116450 A1, US 2011/0255185 A1, US 2013/0256637 A1, US 2014/0291643 A1, per the asterisk convention on the page). That is not dispositive, but it means the challenger must either (a) reframe the combination around the geometry the examiner did not find, or (b) bring new art — none of which I can identify from this page.
  2. The reference with the best "direct connection" teaching is not obviously the same technology. Seoul Opto '074 is a GaN inorganic LED structure (epitaxial layers; a shared P-type layer as the intermediate layer), not an organic stack. A challenger needs the LG Chem '011 bridge (an organic device with an intermediate electrode and AC drive) to make the combination non-analogous-art-proof. LG Chem supplies that bridge, which is why Ground 1 leads with it rather than with Seoul Opto.
  3. No teaching-away argument from the patent is available. The '801's Background notes OLEDs "are commonly driven by direct current (DC)" and are "unidirectional conduction." A challenger can characterize that as the admitted norm, but BOE may characterize it as evidence that AC-driving an OLED was non-routine as of 2014. LG Chem '011 (2010 priority) substantially neutralizes this by showing AC-driven OLEDs were known before the critical date.
  4. Secondary considerations. BOE could point to long service life and color/illumination adjustability. The nexus is weak: the '801 contains no data, and the same two advantages are stated goals of LG Chem '011 (AC drive, various colors) and SEL '637 (long life), so the claimed benefits follow from the prior art rather than from the geometry.
  5. A separate invalidity theory may be stronger than § 103 on this limitation. If the collinearity/direct-contact language truly lacks written-description support in the specification as filed (the summary section flagged that it does not appear in the spec text available), a § 112(a) challenge or a § 102/§ 103 certificate-of-correction/priority analysis in the CN/PCT file is a parallel avenue worth checking in the file wrapper.

7. Bottom line

  • Claim 1 is, in my assessment, more likely than not obvious over LG Chem US 8,994,011 B2 (with CN 103168374 A / US 2013/0153879 A1) in view of SEL US 2013/0256637 A1, optionally further in view of Seoul Opto US 8,089,074 B2 — provided the challenger successfully characterizes the final "direct contact / collinear center lines" limitation as an obvious same-layer design choice (which the patent's own specification supports, by describing the second connection electrode as merely "maintaining the connection of the patterns"). Absent that, the limitation is the load-bearing non-obviousness hook and the claim likely survives.
  • Claims 2–18 are conventional structure/materials variants of claim 1 and would fall with it (claims 4–13 and 14–15 as predictable material/thickness/layer selections), though the "matched work functions" and 5–500 nm limitations deserve an express obviousness rationale rather than a bare "design choice" assertion.
  • Claims 19–20 are obvious applications of an AC-driven emitter stack to known light-source and display architectures.
  • Confidence caveats: I verified the disclosures of LG Chem US 8,994,011, Seoul Opto US 8,089,074 and SEL US 2013/0256637 from their full texts. I did not verify US 2008/0116450 A1 (Matsushita), US 2010/0283045 A1 (Uchida), US 2014/0291643 A1 (SEL) or US 2011/0255185 A1 (Hashi) this session; my search for the Hashi "Drive unit" returned a lens/actuator document, which I have reported literally rather than corrected, and which excludes it from my grounds. The US 2014/0291643 A1 timing point in §2 (102(a)(2)-only art because it published 2014-10-02 but was effectively filed 2013-03-26) should be confirmed against the file wrapper before being relied on in a filing.

Generated 10/1/2026, 10:55:37 AM

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