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DS100BR210: Thermal Rsistance Error in Datasheet (???)

Part Number: DS100BR210
Other Parts Discussed in Thread: DS125BR111

The datasheet lists a junction to top case thermal resistance of 3.2 °C/W. The device is a 24 lead WQFN Package with an exposed ground paddle. I believe that the stated value (3.2) is to the paddle, not top case. Am I correct. If I am correct, does anyone know what the actual theta-jc (top) is? If I am incorrect, does anyone know what Theta J-Paddle is?

Thanks!!

Tom