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ADS5400-SP: Thermal resistance

Part Number: ADS5400-SP

Hi team, 

Good day.

In the datasheet rev D., RθJC = 0.849 °C/W, while on the latest datasheet rev E. RθJC(bot) = 0.4 °C/W and  RθJC(top)= 3.5 °C/W. Is the  RθJC = 0.849  in rev D refers to top or bottom? 

Our customer would like to know the reason for updating the thermal resistance from the junction to case of ADS5400-SP.

Thank you in advance.