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SNELL & WILMER L.L.P. Brian G. Arnold, Bar No. 186007 barnold@swlaw.com Marjorie A. Witter, Bar No. 250061 mwitter@swlaw.com 350 South Grand Avenue Suite 2600 Two California Plaza Los Angeles, California 90071 Telephone: 213.929.2500 Facsimile: 213.929.2525 Attorneys for Plaintiff INTERCONNECT DEVICES, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Case No. COMPLAINT FOR DECLARATORY JUDGMENT DEMAND FOR JURY TRIAL
18900107
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
Plaintiff Interconnect Devices, Inc. (IDI) brings this Complaint against Defendant Johnstech International Corp. (Johnstech) for a Declaratory Judgment that (1) IDI has not infringed U.S. Patent Nos. 7,059,866, 7,722,361, and 7,445,465; (2) that U.S. Patent Nos. 7,059,866, 7,722,361, and 7,445,465 are invalid pursuant to 35 U.S.C. 101, 102, 103 and 112; and (3) that this is an exceptional case under 35 U.S.C. 285 and for an award of all of IDIs attorneys fees and costs. THE PARTIES 1. Plaintiff Interconnect Devices, Inc. is a Delaware corporation with a principal
place of business at 5101 Richland Avenue, Kansas City, KS 66106. 2. Defendant Johnstech International Corporation is a Minnesota corporation with a
principal place of business at 1210 New Brighton Blvd., Minneapolis, MN 55413. JURISDICTION 3. 2201. 4. This Court has subject matter jurisdiction over this matter pursuant to 28 U.S.C. Plaintiff brings this action under the Federal Declaratory Judgment Act, 28 U.S.C.
1331 (Federal Question) and 1338(a) (Patent). 5. Upon information and belief, this Court has personal jurisdiction over Johnstech
because it has established minimum contacts with the forum. Johnstech maintains its Sales, Service, & Innovation Center in Santa Clara, California, and, on information and belief, has maintained this office in this district since 1995. On information and belief, the lead inventor of two of the patents-in-suit resides in this district and developed the purported inventions described in the patents-in-suit in this district. Johnstech has placed and continues to place products into the stream of commerce, which stream is directed at this district, and knows or should know that such products are used throughout the United States, including in this district. Further, Johnstech is registered to do business in California and maintains an agent for service of process in this district. VENUE
18900107
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
6.
Venue is proper in this Court pursuant to 28 U.S.C. 1391(b) and (c), and
1400(b) because a substantial part of the events giving rise to this action occurred within this Judicial District, and because a corporation defendant shall be deemed to reside in any judicial district in which it is subject to personal jurisdiction. In addition, Johnstech maintains its Sales, Service, & Innovation Center in Santa Clara, California, and, on information and belief, the lead inventor of two of the patents-in-suit resides in this district and developed the purported inventions described in the patents-in-suit in this district. Further, IDI maintains a sales and applications engineering office in this district in Milpitas, California. THE PATENTS-IN-SUIT 7. On June 13, 2006, the United States Patent and Trademark Office (USPTO)
issued U.S. Patent No. 7,059,866 (the 866 Patent), entitled Integrated Circuit Contact to Test Apparatus. Mathew L. Gilk is the named inventor on the face of the 866 Patent. On information and belief, the 866 Patent is assigned to Johnstech. A true and correct copy of the 866 Patent is attached hereto as Exhibit A. 8. On May 25, 2010, the USPTO issued U.S. Patent No. 7,722,361 (the 361
Patent), entitled Test Socket. Jose E. Lopez, Dennis B. Shell, and Mathew L. Gilk are the named inventors on the face of the 361 Patent. On information and belief, the 361 Patent is assigned to Johnstech. A true and correct copy of the 361 Patent is attached hereto as Exhibit B. 9. On November 4, 2008, the USPTO issued U.S. Patent No. 7,445,465 (the 465
Patent), entitled Test Socket. Jose E. Lopez, Dennis B. Shell, and Mathew L. Gilk are the named inventors on the face of the 465 Patent. On information and belief, the 465 Patent is assigned to Johnstech. A true and correct copy of the 465 Patent is attached hereto as Exhibit C. FACTUAL BACKGROUND 10. IDI provides spring contact probe based technology, including connectors,
advanced semiconductor test sockets, ATE interfaces and spring contact probes. For over three decades, test engineers and product designers have turned to IDI for the most reliable interconnect designs available. IDI is the originator of the spring contact probe text socket and continues to be the leader of innovations in the semiconductor test industry.
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
11.
On February 25, 2014, Johnstechs counsel set a cease and desist letter (the
Letter) to IDI, alleging that IDIs Archimedes test pin and socket directly infringes Johnstechs 866 Patent, 361 Patent, and 465 Patent (collectively, the patents-in-suit). A true and correct copy of the Letter is attached hereto as Exhibit D. 12. The Letter stated that its purpose was to advise IDI of the consequences of
infringement of one or more of these patents. It stated that Johnstech is aware that [IDI] will be exhibiting products at the upcoming BITS conference in Phoenix, AZ in March 2014 and warned that if IDI exhibits the Archimedes product, Johnstech will consider that an intentional infringement. 13. The Letter demanded a response in less than five business days, and stated that if
Johnstech do[es] not hear from [IDI] by March 1, 2014, we shall assume that settlement is of no interest, and continued infringement will certainly be willful. 14. By virtue of the foregoing, there is a continuing justiciable controversy between
the parties as to IDIs right to make, use, offer to sell and sell its Archimedes product, and as to the validity, enforceability and scope of the patents in suit. FEDERAL DECLARATORY JUDGMENT ACT 15. Pursuant to the Federal Declaratory Judgment Act, 28 U.S.C. 2201, this Court
may declare the rights and other legal relations of any interested party. 16. As set forth in the Letter, Johnstech has asserted that IDI infringes Johnstechs
866 Patent, 361 Patent, and 465 Patent. 17. 18. A real and actual substantial controversy exists between IDI and Johnstech. IDI and Johnstech have adverse legal interests with respect to the threats of patent
infringement made by Johnstech against IDI. 19. Johnstech has made antagonistic claims that are immediate and that indicate
imminent and inevitable litigation. 20. The interests of the parties will be best served if this Court enters a Declaratory
Judgment setting forth the rights of the parties with respect to this dispute.
18900107
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
21.
The relief sought by IDI will resolve the controversy relative to the respective
interests of IDI and Johnstech. COUNT I DECLARATORY JUDGMENT OF NON-INFRINGEMENT OF THE 866 PATENT 22. 23. 24. 25. Each of paragraphs 1 through 21 is incorporated herein by reference. On information and belief, 866 Patent is assigned to Johnstech. IDI has not infringed and does not infringe any valid claim of the 866 Patent. There is an actual, substantial and immediate controversy between the adverse
interests of IDI and Johnstech as to whether IDIs use, making, sale or offering for sale of its Archimedes test pin and socket infringes the claims of the 866 Patent. 26. IDI is entitled to a Judicial Declaration and Order that IDI has not infringed and
does not infringe, either directly or indirectly, literally or under the doctrine of equivalents, any valid claim of the 866 Patent. COUNT II DECLARATORY JUDGMENT OF INVALIDITY OF THE 866 PATENT 27. 28. 29. Each of paragraphs 1 through 26 is incorporated herein by reference. On information and belief, 866 Patent is assigned to Johnstech. The 866 Patent is invalid for failure to satisfy one or more of the conditions of
patentability set forth in Title 35 of the United States Code, including, but not limited to, 35 U.S.C. 101, 102, 103, and 112. 30. An actual, substantial and immediate controversy exists between IDI and
Johnstech as to whether the claims of the 866 Patent are valid. 31. IDI is entitled to a Judicial Declaration and Order that the 866 Patent is invalid. COUNT III DECLARATORY JUDGMENT OF NON-INFRINGEMENT OF THE 361 PATENT 32. 33. 34.
18900107
Each of paragraphs 1 through 31 is incorporated herein by reference. On information and belief, the 361 Patent is assigned to Johnstech. IDI has not infringed and does not infringe any valid claim of the 361 Patent. -5COMPLAINT FOR DECLARATORY JUDGMENT
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
35.
interests of IDI and Johnstech as to whether IDIs use, making, sale or offering for sale of its Archimedes test pin and socket infringes the claims of the 361 Patent. 36. IDI is entitled to a Judicial Declaration and Order that IDI has not infringed and
does not infringe, either directly or indirectly, literally or under the doctrine of equivalents, any valid claim of the 361 Patent. COUNT IV DECLARATORY JUDGMENT OF INVALIDITY OF THE 361 PATENT 37. 38. 39. Each of paragraphs 1 through 36 is incorporated herein by reference. On information and belief, the 361 Patent is assigned to Johnstech. The 361 Patent is invalid for failure to satisfy one or more of the conditions of
patentability set forth in Title 35 of the United States Code, including, but not limited to, 35 U.S.C. 101, 102, 103, and 112. 40. An actual, substantial and immediate controversy exists between IDI and
Johnstech as to whether the claims of the 361 Patent are valid. 41. IDI is entitled to a Judicial Declaration and Order that the 361 Patent is invalid. COUNT V DECLARATORY JUDGMENT OF NON-INFRINGEMENT OF THE 465 PATENT 42. 43. 44. 45. Each of paragraphs 1 through 41 is incorporated herein by reference. On information and belief, the 465 Patent is assigned to Johnstech. IDI has not infringed and does not infringe any valid claim of the 465 Patent. There is an actual, substantial and immediate controversy between the adverse
interests of IDI and Johnstech as to whether IDIs use, making, sale or offering for sale of its Archimedes test pin and socket infringes the claims of the 465 Patent. 46. IDI is entitled to a Judicial Declaration and Order that IDI has not infringed and
does not infringe, either directly or indirectly, literally or under the doctrine of equivalents, any valid claim of the 465 Patent. ///
18900107
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
COUNT VI DECLARATORY JUDGMENT OF INVALIDITY OF THE 465 PATENT 47. 48. 49. Each of paragraphs 1 through 46 is incorporated herein by reference. On information and belief, the 465 Patent is assigned to Johnstech. The 465 Patent is invalid for failure to satisfy one or more of the conditions of
patentability set forth in Title 35 of the United States Code, including, but not limited to, 35 U.S.C. 101, 102, 103, and 112. 50. An actual, substantial and immediate controversy exists between IDI and
Johnstech as to whether the claims of the 465 Patent are valid. 51. IDI is entitled to a Judicial Declaration and Order that the 465 Patent is invalid. PRAYER FOR RELIEF WHEREFORE, IDI respectfully requests that the Court enter judgment in its favor and against Johnstech as follows: A. B. C. D. E. F. G. The Court enter judgment that the 866 Patent is not infringed by IDI. The Court enter judgment that the 866 Patent is invalid. The Court enter judgment that the 361 Patent is not infringed by IDI. The Court enter judgment that the 361 Patent is invalid. The Court enter judgment that the 465 Patent is not infringed by IDI. The Court enter judgment that the 465 Patent is invalid. The Court find this case to be an exceptional case pursuant to 35 U.S.C. 285
and award IDI its attorneys fees in this action; and H. and proper. \\\ \\\ \\\ \\\ \\\
18900107
The Court enter an order for such other and further relief as this Court deems just
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
By: /s/ Brian G. Arnold Brian G. Arnold Marjorie A. Witter Attorneys for Plaintiff INTERCONNECT DEVICES, INC.
18900107
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SNELL & WILMER
ATTORNEYS AT LAW LOS ANGELES
DEMAND FOR JURY TRIAL IDI hereby demands a jury trial on any issue triable of right by a jury pursuant to Rule 38 of the Federal Rules of Civil Procedure. Dated: March 10, 2014 SNELL & WILMER L.L.P.
By: /s/ Brian G. Arnold Brian G. Arnold Marjorie A. Witter Attorneys for Plaintiff INTERCONNECT DEVICES, INC.
18900107
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EXHIBIT A
US007059866B2
(12)
US 7,059,866 B2
Jun. 13, 2006
(54)
APPARATUS
5,749,738 A 6,019,612 A
439/66 439/73
(75)
(73)
Inventor:
6,231,353 B1
6,244,874 B1
5/2001 Rathburn
6/2001 Tan ...... ..
439/66
439/66
6,572,388 B1
Minneapolis, MN (US)
(*) Notice: Subject to any disclaimer, the term of this
. . . y ays.
(65)
(57)
ABSTRACT
A contact test set for use in testing integrated circuits. The set includes a housing having oppositely-facing surfaces and one or more slots extending through the housing between the
2006 01 (2006'01)
( ' )
surfaces. A ?rst surface, during use of the test set, is approached by an integrated circuit to be tested, and a
second surface is proximate the load board at a test site. A
Contact is received in a Slot, each Contact having a ?rst end
(58)
engagable by a lead of the integrated Circuit device_ A second end of each contact is in engagement with a corre
(56)
sponding terminal. Each contact is movable between a ?rst orientation, unengaged by a corresponding lead of an IC and a second orientation in which the 1C is engaged by the corresponding lead of an IC and urged into its slot. An
elastomer biases the contact to its ?rst orientation. The contact, when moved between its ?rst and second orienta tions, does not slide across a terminal of the load board.
\\ 38
22 17
I
_ .J
$8 . s. V
f
9
44
m 13
US 7,059,866 B2
1
INTEGRATED CIRCUIT CONTACT TO TEST APPARATUS
2
In use, a lead of an integrated circuit Will be made to engage the nose of a contact at the curved surface. Such
claiming priority, under 35 U.S.C. ll9(e)(l), of provi sional application Ser. No. 60/465,022, previously ?led Apr.
23, 2003 under 35 U.S.C. 111(b).
BACKGROUND OF THE INVENTION
through the tail. A linear contact surface of the tail, adjacent the curved surface, is parallel to and in engagement With the terminal pad of the load board. This contact con?guration tends to substantially eliminate sliding motion of the contact against the terminal pad of the load board. The engagement portion of the contact With the terminal pad moves forWard
as a result of the rolling of the contact, simultaneously
positively prevent the contact from sliding along the termi nal of the load board by maintaining the position of the
contact relative to the housing. The front elastomer also
20
plays a role in achieving this by urging the tail of the contact toWard the housing Wall and maintaining the contact seated against that Wall.
The present invention is thus a contact set assembly Which
solves many of the problems of the prior art. It enables positive contact to be established along electrical paths, yet
it minimiZes erosion of a lead of a load board 12.
contact opposite an end engaged by the IC contacts a pad of the load board When the IC and test site are brought together.
reference to the folloWing description, taken in conjunction With the accompanying draWing Wherein like reference
numerals refer to the same part or feature, and Wherein: The FIGURE is a cross-section vieW of the present invention.
35
parallel opposed sides 22 essentially at right angles to pairs of opposed edges. Housing 10 is con?gured to effect elec
45
trical connection of an integrated circuit device (DUT) 14 to a load board 12. Device 14 has leads 17 and load board 12 has terminals or pads 16 Which are electrically connected by contacts 18 mounted Within housing 10.
Parallel sides of housing 10 bound generally equally spaced parallel slots 20, each for receiving a corresponding
50
contact 18 therein.
ment, positioned Within a housing, for facilitating connect ing the leads of an integrated circuit to corresponding
terminals of a load board. The housing typically has a
plurality of generally parallel slots for receiving a corre sponding plurality of contacts, one in each slot. Each contact
has a nose end that extends from its slot on one side of the housing, and a tail end that extends from its slot on an
Each slot 20, it is intended, contains a contact 18. Con tacts 18 are thin With generally planar surfaces. Each has a nose end 26 and a tail end 28 Which together de?ne an essentially S shaped structure. Nose end 26 is, as illus
55
trated, larger than tail end 28 to provide a greater outWard extension to protrude from housing 10 beyond one side to
contact leads 17 of device 14. Tail end 28 has a linear portion 29 to provide a positive electrical connection to terminals 16 of lead board 12.
through housing 10 along axes generally perpendicular to planes de?ned by slots 20 With front channel 31 being larger
than rear channel 33 to better conform to the corresponding
65
elastomer.
The nose of the contact has a curved surface to be engaged by a lead of an integrated circuit. The tail of the contact has
concave portion of edges of engaged nose ends 26 and tail ends 28. A cylindrical shaped front elastomer 30 is received Within front channel 31, and a cylindrical shaped rear
elastomer 32 is received Within rear channel 33.
US 7,059,866 B2
3
Nose end 26 has a concave inner edge 25 Which engages
4
tomers, the point of contact betWeen the lead 17 and the contact tail 28 Walks forWard on the load board 12 (translates horizontally) and travels along the loWer contact arc 13. The ?at portion 29 of the contact tail design 28 controls
location of contact nose 26 While alloWing the contact nose
the diameters of their respective channels 31, 33. This permits inserting elastomers 30 and 32 into channels 31, 33
26 to be pre-loaded in the uncompressed state, as illustrated in the FIGURE. The ?at portion 29 of the contact tail 28 constrains the contact 18 from achieving an ultimate rolling
This design can be alternatively con?gured as a single elastomer system. In this con?guration the rear elastomer 32 Would de?ne the applicable force necessary at both the contact nose 26 and contact tail 28. The design of housing 10 and contact 18 Would be modi?ed from the FIGURE to
25
respects, is only illustrative. Changes may be made in details, particularly in matters of shape, siZe, material, and arrangement of parts Without exceeding the scope of the
invention. Accordingly, the scope of the invention is as
30
a good electrical connection betWeen the leads and termi nals. In the dual elastomer con?guration as pictured in the
said housing from a ?rst of said oppositely facing surfaces to a second of said oppositely facing surfaces;
a contact receivable in said slot having a ?rst end eng
45
agable by the lead and a second end in engagement With the terminal, said contact being rollable across the terminal betWeen a ?rst orientation unengaged by the lead of the integrated circuit and a second orientation in Which said ?rst end of said contact is engaged by the
substantially eliminated.
2. Apparatus in accordance With claim 1 Wherein said
55
This contactor system has been designed to prevent contact translational relative motion (sliding) against the
load board 28. Sliding motion causes Wear on the load board
pads, an undesirable characteristic. The sloped terminus of contact tail 6 in engagement With housing Wall 15 is instru mental in preventing the contact 18 from sliding along the load board 12. The front elastomer 30 also plays a role in helping achieve this end by forcing the contact 18 in a direction to remain seated against Wall 15 of the housing 10. Rather than sliding along leads 17 as contacts of previous contactors do, the contact motion in the present invention is
a rolling action. As the contact 18 compresses the elas
60
interfacing With said second end of said contact. 4. Apparatus in accordance With claim 3 Wherein second end of said contact includes a protrusion, Wherein said housing de?nes a Wall engaged by said trusion to substantially eliminate sliding motion of
second end of said contact across the terminal.
EXHIBIT B
US007722361B2
US 7,722,361 B2
*May 25, 2010
TEST SOCKET
Inventors: Jose E. Lopez, 665 Santa Paula Ave.,
12/1991 Johnson
2/1993 Bregman et a1. 1/1997 Ludwig .................... .. 324/755
Sunnyvale, CA (US) 94044; Dennis B, Shell, 7243 40th St. West, Webster, MN (US) 55088; Mathew L. Gilk, 70537 Toledo Dr. North, Minneapolis, MN (US)
554435424
A A B1 B1
6,572,388 B2 *
6,794,890 B1
9/2004 Tokumo
(*)
Notice:
Subject to any disclaimer, the term of this patent is extended or adjusted under 35
U'S'C' 154(1)) by 0 days
_
6,854,981 B2
*
2004/0067665 A1 *
2004/0217771 A1
439/71
12/2004
(65)
Alloy;
Ive/Son, ~
(60) Provisional application No. 60/697,693, ?led on Jul. 8, 2005, provisional application No. 60/776,654, ?led on
(57)
223201
'
68 13588251011211apphCanOnNO' 60/69772 1
'
(51)
(52) 58
(2006 01)
"" "_ ""
' """ 439/72 """""""""" " 439/72
formed therein. Contacts can be received Within respective slots and maintained therein With rear ends of the contacts in
engagement With traces on a load board. Mounting is accom plished by means ofa pair of elastomers, and the elastomers
)
S
1e
73 754
(56)
4,980,245 A
12/1990 Marino
sq&\/WWWWW
, I s
,,
4,
US. Patent
Sheet 2 of2
US 7,722,361 B2
11))
US 7,722,361 B2
1
TEST SOCKET CROSS-REFERENCE TO RELATED APPLICATIONS
2
SUMMARY OF THE INVENTION
The present invention is an improved test socket. It includes a housing Which has a ?rst surface that is placed into engagement With a surface of a tester load board. The housing
119(e) (1): provisional application Ser. No. 60/697,693, pre viously ?led Jul. 8, 2005, under 35 U.S.C. 111(b); provi
sional application Ser. No. 60/776,654, previously ?led on Feb. 24, 2006, under 35 U.S.C. 111(b); and provisional application Ser. No. 60/697,721, previously ?led on Jul. 8, 2005, under 35 U.S.C. 111(b).
TECHNICAL FIELD
has a second surface Which is generally parallel to, and spaced from, the housing ?rst surface. The second surface of the housing faces in a direction opposite that in Which the ?rst surface faces. At least one slot, extending through the housing betWeen the ?rst and second surfaces thereof, is formed in the
housing. A contact is received in a corresponding slot. Such a contact has a front end Which normally extends beyond the
20
face engaging a corresponding trace formed on the surface of the tester load board. The contact is elastomerically mounted in its slot such that, When the front end of the contact is engaged by the lead or the pad of the device to be tested and urged into its slot, the arcuate surface of the contact rolls
across its corresponding trace on the surface of the tester load
Which interconnect and provide an electronic path betWeen a lead or pad of the electronic component to be tested and a
corresponding trace on a load board. The invention focuses
25
board With virtually no translational or rotational sliding. Abrasion betWeen the contact and the load board is, thereby,
substantially eliminated.
It is envisioned that the rear end of the contact, in addition to de?ning the arcuate surface in engagement With the load board, also de?nes a gradually arcing surface Which is angu
upon control and regulation of forces applied to a device lead or pad and a load board trace by a corresponding contact of
the test socket.
30
engaged by the gradually arcing surface of the rear end of the contact, and the spatial relationship betWeen the gradually
arcing surface and the Wall is such that, as the front end of the contact is engaged by the lead or pad of the device to be tested
surface moves along the Wall and causes the arcuate surface of the contact to roll across its corresponding trace. It is envi
load board in order to effectuate testing. A test socket having a plurality of contacts is interposed betWeen the device under
test and the load board in order to effectuate interconnection. One contact engages, at a front end, the lead orpad of a device under test With its corresponding trace on the load board. Over the years, shape and construction of such contacts have evolved in response to the construction of test sockets, load boards, and architecture of devices to be tested. For merly, it Was considered necessary to have a Wiping action at the various locations of engagement at the contact ends in
sioned that the Wall de?ned by the housing Would be angu larly spaced at an acute angle relative to the ?rst surface of the housing. This Would enable the arcuate surface of the contact
40
to roll across the trace of the tester load board With virtually no translational or rotational sliding.
A preferred embodiment of the invention employs a pair of elastomers, crossing perpendicularly across the slots, to
45
effect the elastomeric mounting of the contacts. A front elas tomer is positioned in a channel betWeen the surface of the tester load board and the contacts. The front elastomer is pre-compressed in vieW of the fact that a shoulder de?ned by the housing can be employed to engage the contacts and limit
order to provide a good transmission path. As technology has progressed, hoWever, it has become apparent that less Wiping
action is necessary to maintain a good transmission path than What Was formerly believed. Furthermore, it has become
apparent that excessive Wiping action damages component parts at the various points of engagement and signi?cantly
decreases the life of the test socket and tester load board.
pressed by the contacts as they are engaged by the leads or pads of the device to be tested and urged into their respective
55
slots.
The rear elastomer pre-loads the rear end of the contact. It thereby maintains contact betWeen the rear end of each con tact against its corresponding trace on the surface of the tester
60
load board. The present invention can employ contacts made of pre cious metals. Such contacts extend load board life. A Neyoro G contact is a solid gold alloy contact Without any plating. While it has been found that such a material extends the life of
US 7,722,361 B2
3
The present invention is thus an improved test socket Which
4
tester load board 12 on Which the traces 14 are formed. The
addresses the dictates of the prior art and solves problems thereof. More speci?c features and advantages obtained in
vieW of those features Will become apparent With reference to
housing 32 has a second surface 36 Which is generally parallel to, and spaced from, the ?rst surface thereof. The second surface 36 of the housing 32 faces oppositely from the ?rst surface 34. As previously discussed, the housing 32 carries a plurality of contacts 24. A plurality of slots 38 are provided,
each slot to receive a single one of the contacts 24.
FIG. 2 illustrates, in perspective, an individual contact in accordance With the present invention. The contact 24
includes ?rst, second and third protrusions 40, 42, 44. The
?rst protrusion 40 is de?ned by the rear end 30 of the contact 24 Which engages the trace 14 of the load board 12. The third protrusion 44 is de?ned by the front end 26 of the contact 24 Which is engaged by a lead 20 or pad of the device under test 18. The second protrusion 42 serves to engage, When mounted by a plurality of elastomers 46, 48, as Will be dis cussed hereinafter, a shoulder 49 de?ned by the housing 32.
present invention.
DETAILED DESCRIPTION OF THE INVENTION
serves to limit the degree of upWard movement of the contact 24 and the distance the front end 26 of the contact 24 Will
With a tester typically employed for ascertaining quality of integrated circuit devices used in electronic appliances. The
tester interfaces With a tester load board 12 Which has elec trically conductive traces 14 formed on a surface 16 thereof to enable electronic communication betWeen the tester and an
channels 50, 52 Which extend along axes generally transverse to planes de?ned by the slots 38 formed in the housing 32.
These channels 50, 52 are intended to receive elastomers 46,
48 Which serve to mount the contacts 24 in their slots 38. FIG.
1 shoWs a generally circular channel 50 receiving a larger, front elastomer 46, and a rectangular channel 52 receiving a
smaller, rear elastomer 48. The rear elastomer 48 is pre loaded and, because of the arcuate surface 28 of the rear end
plurality of leads 20, only one of Which is shoWn. FIG. 1 illustrates only a portion of the device under test 18, but it Will be understood that substantially identical leads extend along both of opposite sides of the device package 18.
FIG. 1 further illustrates a lead backer Which, When the device under test 18 is brought into engagement With its leads 20 in contact With corresponding contacts 24 of the test socket
10, deters bending of the leads 20. DoWnWard pressure is brought to bear upon the device 18 under test by a plunger
40
addition to de?ning the arcuate surface 28, also has a gradu ally arcing surface 56 at an edge of the rear end 30 of the contact 24 Which engages this angled Wall 54 de?ned by the housing 32. Disposition of a contact 24 is such that the gradu
end 30 of the contact 24 on a loWer edge thereof Will roll across a corresponding trace 14 on the load board 12 With virtually no translational or rotational sliding of that surface
brought to bear upon trace 14. Further, it has been found that, in vieW of the construction of the contact 24, translational sliding of the front end 26 of the contact 24 along the lead 20 of the device under test 18 to Which the contact corresponds Will be adequate to effect signi?cant scrub on the front end of
the contact but minimal scrub on a lead 20 of the device 18.
of the gradually arcing surface 56 is maintained in contact With the angled Wall 54. When the device under test 18 is
Withdrawn, rolling in a reverse direction Will occur.
As previously discussed, as WithdraWal of the device occurs, the second projection 42 Will engage the shoulder 49 de?ned by the housing 32 in order to limit upWard movement
lational sliding is on an order of 0.041 mm on the device 18. 65 of the contacts 24. The test socket 10 includes a housing 32 Which has a ?rst It Will also be noted that the point of application of force by
US 7,722,361 B2
5
cant distance from the point of engagement of the rear end 30 of the contact 24 With the trace 14 on the load board 12. This
6
arcuate surface, and said housing de?ning, Within the slot, a Wall, engaged by said gradually arcing surface of
said rear end of said contact, such that, as said front end
Will augment the bene?cial advantage achieved by the rolling action (that is, minimization of likelihood of damage to the load board).
Further, contacts made of precious metals can be employed
in the present invention. Such contacts tend to extend load board life also. A Neyoro G contact, Which is a solid gold
of said contact is engaged by the lead orpad of the device to be tested and urged into the corresponding slot, said gradually arcing surface of said contact moves along
said Wall and causes said arcuate surface to roll across
alloy contact not having any plating, is envisioned as being used. Such a material, it has been found, not only extends the life of the contact. It also, hoWever, extends load board life by minimizing damage to the traces thereon. It has been found
that load board life can be at least doubled over mechanisms
15
is only illustrative. Changes may be made in details, particu larly in matters of shape, siZe, material, and arrangement of
parts Without exceeding the scope of the invention. Accord ingly, the scope of the invention is as de?ned in the language of the appended claims. What is claimed is: 1. A test socket, comprising: a housing having a ?rst surface generally in engagement
With a surface of a tester load board, said housing further
20
having a second surface, generally parallel to, spaced from, and facing oppositely from said ?rst surface, and
at least one slot formed in said housing extending
through said housing betWeen said ?rst surface and said second surface;
a contact received in a corresponding slot and having a
front end extending beyond said second surface for engagement by a corresponding lead or pad of a device
to be tested, and having a rear end de?ning an arcuate surface in engagement With a corresponding trace on
prising a shoulder de?ned by said housing for engaging the contact and limiting the distance the contact extends beyond said second surface of said housing.
6. A test socket in accordance With claim 1 Wherein said contacts are made of Neyoro G.
* * * * *
EXHIBIT C
US007445465B2
US 7,445,465 B2
Nov. 4, 2008
(75) Inventors: g)
ennls
]I;IslelZllS1\1Vnng";a1ehgNA$SS));
. e, e ser, ;
5,634,801 A *
*
6,231,353 B1
6,244,874 B1*
(73)
*
Nome
2004/0067665 Al*
2004/0248448 A1*
Jul. 7, 2006
Prior Publication Data
* cited by examiner
US 2007/0032128 A1
Feb. 8, 2007
(60)
(57)
ABSTRACT
(51)
(52)
(2006.01)
439/72
formed therein. Contacts can be received Within respective slots and maintained therein With rear ends of the contacts in
engagement With traces on a load board. Mounting is accom
(58)
439/70, 71, 73; 324/754 See application ?le for complete search history.
(56)
4,980,245 A * 5,069,629 A *
References Cited
U.S. PATENT DOCUMENTS
12/1990 12/1991 Marino ..................... .. 428/671 Johnson ..................... .. 439/71
US. Patent
Nov. 4 2008
Sheet 1 of2
////// // ////
a
US. Patent
Nov. 4, 2008
Sheet 2 of2
US 7,445,465 B2
:23:
J
l/l/
US 7,445,465 B2
1
TEST SOCKET CROSS-REFERENCE TO RELATED APPLICATIONS
2
tion, Detailed Description of the Invention, appended claims
The present invention is an improved test socket. It includes a housing Which has a ?rst surface that is placed into engagement With a surface of a tester load board. The housing
111 (a) claiming priority, under 35 U.S.C. 119(e) (l) of provisional application Ser. No. 60/776,654, previously ?led
on Feb. 24, 2006.
has a second surface Which is generally parallel to, and spaced from, the housing ?rst surface. The second surface of the housing faces in a direction opposite that in Which the ?rst surface faces. At least one slot, extending through the housing betWeen the ?rst and second surfaces thereof, is formed in the
housing. A contact is received in a corresponding slot. Such a contact has a front end Which normally extends beyond the
111 (a) claiming priority, under 35 U.S.C. 119(e) (l) of provisional application Ser. No. 60/ 697,721, previously ?led
on Jul. 8, 2005.
TECHNICAL FIELD
20
face engaging a corresponding trace formed on the surface of the tester load board. The contact is elastomerically mounted in its slot such that, When the front end of the contact is engaged by the lead or the pad of the device to be tested and urged into its slot, the arcuate surface of the contact rolls
across its corresponding trace on the surface of the tester load
Which interconnect and provide an electronic path betWeen a lead or pad of the electronic component to be tested and a
corresponding trace on a load board. The invention focuses
board With virtually no translational or rotational sliding. Abrasion betWeen the contact and the load board is, thereby,
substantially eliminated.
30
upon control and regulation of forces applied to a device lead or pad and a load board trace by a corresponding contact of
the test socket.
It is envisioned that the rear end of the contact, in addition to de?ning the arcuate surface in engagement With the load board, also de?nes a gradually arcing surface Which is angu
larly spaced from the arcuate surface thereof. The housing, in this embodiment, de?nes a Wall Within the slot. The Wall is engaged by the gradually arcing surface of the rear end of the
arcing surface and the Wall is such that, as the front end of the contact is engaged by the lead or pad of the device to be tested
load board in order to effectuate testing. A test socket having a plurality of contacts is interposed betWeen the device under
test and the load board in order to effectuate interconnection. One contact engages, at a front end, the lead orpad of a device under test With its corresponding trace on the load board. Over the years, shape and construction of such contacts have evolved in response to the construction of test sockets, load boards, and architecture of devices to be tested. For merly, it Was considered necessary to have a Wiping action at the various locations of engagement at the contact ends in
45
sioned that the Wall de?ned by the housing Would be angu larly spaced at an acute angle relative to the ?rst surface of the housing. This Would enable the arcuate surface of the contact
to roll across the trace of the tester load board With virtually no translational or rotational sliding.
A preferred embodiment of the invention employs a pair of elastomers, crossing perpendicularly across the slots, to
effect the elastomeric mounting of the contacts. A front elas tomer is positioned in a channel betWeen the surface of the tester load board and the contacts. The front elastomer is pre-compressed in vieW of the fact that a shoulder de?ned by the housing can be employed to engage the contacts and limit
50
order to provide a good transmission path. As technology has progressed, hoWever, it has become apparent that less Wiping
action is necessary to maintain a good transmission path than What Was formerly believed. Furthermore, it has become
55
apparent that excessive Wiping action damages component parts at the various points of engagement and signi?cantly
decreases the life of the test socket and tester load board.
pressed by the contacts as they are engaged by the leads or pads of the device to be tested and urged into their respective
slots.
60
The rear elastomer pre-loads the rear end of the contact. It thereby maintains contact betWeen the rear end of each con tact against its corresponding trace on the surface of the tester
adequate to both maximize ef?ciency of the test socket and minimiZe abrasion and consequent deterioration of compo nent parts. It is to these problems and dictates of the prior art that the present invention is directed. Its advantages Will become more apparent With reference to the Summary of the Inven
65
load board. The present invention can employ contacts made of pre cious metals. Such contacts extend load board life. A Neyoro G contact is a solid gold alloy contact Without any plating. While it has been found that such a material extends the life of
US 7,445,465 B2
3
material for the contacts, load board life can, it has been found, be at least doubled over load board life in mechanisms knoWn in the prior art. The present invention is thus an improved test socket Which addresses the dictates of the prior art and solves problems
4
For example, in one embodiment of the invention, the trans
lational sliding is on an order of 0.041 mm on the device 18.
housing 32 has a second surface 36 Which is generally parallel to, and spaced from, the ?rst surface thereof. The second surface 36 of the housing 32 faces oppositely from the ?rst surface 34. As previously discussed, the housing 32 carries a plurality of contacts 24. A plurality of slots 38 are provided,
each slot to receive a single one of the contacts 24.
FIG. 2 illustrates, in perspective, an individual contact in accordance With the present invention. The contact 24
includes ?rst, second and third protrusions 40, 42, 44. The
?rst protrusion 40 is de?ned by the rear end 30 of the contact 24 Which engages the trace 14 of the load board 12. The third protrusion 44 is de?ned by the front end 26 of the contact 24 Which is engaged by a lead 20 or pad of the device under test 18. The second protrusion 42 serves to engage, When mounted by a plurality of elastomers 46, 48, as Will be dis cussed hereinafter, a shoulder 49 de?ned by the housing 32.
present invention.
DETAILED DESCRIPTION OF THE INVENTION
20
With a tester typically employed for ascertaining quality of integrated circuit devices used in electronic appliances. The
tester interfaces With a tester load board 12 Which has elec trically conductive traces 14 formed on a surface 16 thereof to enable electronic communication betWeen the tester and an
30
channels 50, 52 Which extend along axes generally transverse to planes de?ned by the slots 38 formed in the housing 32. These channels 50, 52 are intended to receive elastomers 46,
48 Which serve to mount the contacts 24 in their slots 38. FIG.
35
1 shoWs a generally circular channel 50 receiving a larger, front elastomer 46, and a rectangular channel 52 receiving a
smaller, rear elastomer 48. The rear elastomer 48 is pre loaded and, because of the arcuate surface 28 of the rear end 30 of the contact 24 being in engagement With the load board 12, Will engage an upper edge of the rear end 30 of the contact 24 at a location to urge the front end 26 of the contact 24
be understood that substantially identical leads extend along both of opposite sides of the device package 18.
FIG. 1 further illustrates a lead backer Which, When the device under test 18 is brought into engagement With its leads 20 in contact With corresponding contacts 24 of the test socket 10, deters bending of the leads 20. DoWnWard pressure is brought to bear upon the device 18 under test by a plunger
40
45
addition to de?ning the arcuate surface 28, also has a gradu ally arcing surface 56 at an edge of the rear end 30 of the contact 24 Which engages this angled Wall 54 de?ned by the housing 32. Disposition of a contact 24 is such that the gradu
55
end 30 of the contact 24 on a loWer edge thereof Will roll across a corresponding trace 14 on the load board 12 With virtually no translational or rotational sliding of that surface
brought to bear upon trace 14. Further, it has been found that, in vieW of the construction of the contact 24, translational sliding of the front end 26 of the contact 24 along the lead 20 of the device under test 18 to Which the contact corresponds Will be adequate to effect signi?cant scrub on the front end of
the contact but minimal scrub on a lead 20 of the device 18.
of the gradually arcing surface 56 is maintained in contact With the angled Wall 54. When the device under test 18 is
WithdraWn, rolling in a reverse direction Will occur.
US 7,445,465 B2
5
As previously discussed, as WithdraWal of the device occurs, the second projection 42 Will engage the shoulder 49 de?ned by the housing 32 in order to limit upward movement
of the contacts 24.
6
to be tested, and having a rear end de?ning an arcuate surface in engagement With a corresponding trace on
said surface of the tester load board; means for elastomerically mounting said contact in said
It Will also be noted that the point of application of force by a device under test 18 is spaced laterally a relatively signi? cant distance from the point of engagement of the rear end 30
of the contact 24 With the trace 14 on the load board 12. This
Will augment the bene?cial advantage achieved by the rolling action (that is, minimiZation of likelihood of damage to the load board).
Further, contacts made of precious metals can be employed
in the present invention. Such contacts tend to extend load board life also. A Neyoro G contact, Which is a solid gold
alloy contact not having any plating, is envisioned as being used. Such a material, it has been found, not only extends the life of the contact. It also, hoWever, extends load board life by minimizing damage to the traces thereon. It has been found
that load board life can be at least doubled over mechanisms
front end of said contact is engaged by the lead or pad of the device to be tested and urged into the corresponding slot, said gradually arcing surface of said contact moves along said Wall in constant engagement thereWith and
20
ing trace.
2. A test socket in accordance With claim 1 Wherein said means for elastomerically mounting said contact comprises a front elastomer pre-compressed by the contact and com pressed further by the contact as said front end of said contact
is only illustrative. Changes may be made in details, particu larly in matters of shape, siZe, material, and arrangement of
parts Without exceeding the scope of the invention. Accord ingly, the scope of the invention is as de?ned in the language of the appended claims. What is claimed is: 1. A test socket, comprising: a housing having a ?rst surface generally in engagement
With a surface of a tester load board, said housing further
25
is engaged by the lead or pad of the device to be tested and urged into the slot.
3. A test socket in accordance With claim 2 Wherein said means for elastomerically mounting said contact further com prises a rear elastomer that pre-loads the rear end of the contact against a corresponding trace on the surface of the tester load board. 4. A test socket in accordance With claim 3 further com
30
having a second surface, generally parallel to, spaced from, and facing oppositely from said ?rst surface, and
at least one slot formed in said housing extending
through said housing betWeen said ?rst surface and said second surface;
a contact received in a corresponding slot and having a
35
prising a shoulder de?ned by said housing for engaging the contact and limiting the distance the contact extends beyond said second surface of said housing.
* * * * *
EXHIBIT D
25 February 2014
Gabriel Guglielmi, President Interconnect Devices, Inc. and Smiths Connectors 5101 Richland Ave Kansas City, KS 66106 By email: Gabriel.guglielmil@idinet.com and certified mail Re: Our Reference: 04210.0018-US-AB Infringement of US Patents 7 059 866, 7 722 361, 7 445 465
Dear Sirs: We are Intellectual Property counsel for Johnstech International of Minneapolis, MN, a maker of patented test sockets and pins. We are sure you are familiar with Johnstech and its products. It has come to our attention that your company is advertising a test pin and socket under the Archemedes name (see attached). Our review of this product indicates that it is a direct infringement of the following US Patents, namely 7 059 866, 7 722 361 and 7 445 465. The purpose of this letter is to give you official notice under 35 United States Code Section 287 of our clients patents (though the patent numbers are already marked on the product, product literature, and the Johnstech web site) and to advise you of the consequences of infringement of one or more of these patents. Under US law, 35 United States Code Section 271, anyone who makes, uses, offers to sell, or sells a patented invention is liable for patent infringement. Further, under the same statute, if a person induces or contributes to another who ultimately infringes, the inducer and contributor are also liable for infringement. Likewise, a customer of an infringer also becomes an infringer by carrying out the process of the patent. We do not know if you have made, used or offered to sell the infringing product shown in the literature, but we are aware that your company will be exhibiting products at the upcoming BITS conference in Phoenix, AZ in March 2014.
1
If your company exhibits this product at the BITS conference, we will consider that an intentional infringement Under 35 United States Code Sections 284-285, intentional/willful infringement is subject to tripling of damages and Johnstechs attorneys fees in pursing the infringement. Without waiving any rights to obtaining an injunction against your company or its clients, we invite you to contact us to see if an amicable solution can be quickly achieved. If we do not hear from you by March 1, 2014, we shall assume that settlement is of no interest, and continued infringement will certainly be willful. . Very truly yours, s/Michael B. Lasky/ Michael B. Lasky Attorney MBL/jsa