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LM317A: Thermal Resistance: Large Difference between Theta_JB and Theta_JC (Bottom)

Part Number: LM317A

Tool/software:

I refer to the TO-252 package for LM317AMDTX.

I am trying to understand what may be the reason(s) behind the large thermal resistance between the Theta_JC (Bottom) and Theta_JB values? 

Thank you 

https://www.ti.com/lit/ds/symlink/lm317a.pdf?ts=1727613381804&ref_url=https%253A%252F%252Fwww.ti.com%252Fproduct%252FLM317A (pg 5)