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Hi Taku-san,
Case temperature for a QFN would mean at the power pad – as this is the thermal path from the chip to the board.
The Tj rating in the datasheet (e.g. 105 degC max) then you can calculate the die temp based on the estimated case (pad) temp or board temp
For example,
Psi-JB is 3.3 degC/W so if the board under the pad is 85 degC then the Tj will be (roughly) == [ 85 degC + ( 3.3 degC/W * 0.475W ) ] = 86.6 degC which is below 105 degC, so no concern
Please review Table 7.4 and the SPRA953 document, snapshot below, to determine if their thermal care-abouts are being met.
Regards,
Rob