The Federal Circuit ruled that the claim language of the '961 patent did not necessitate the first reflective layer to be distinct from the substrate.
The district court misunderstood the claim construction by requiring the reflective layer to be composed of different material than the substrate, leading to summary judgment error.
In the case of CAO Lighting, it was demonstrated that the reflective layers could include materials that were not distinct from the base substrate, maintaining patent validity.
CAO Lighting's claims involve semiconductor light sources that also efficiently manage heat, which is critical in LED technologies, as highlighted by the court’s reversal.
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