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CSD19535KCS: How Ambient Junction temperature is maintained while testing

Part Number: CSD19535KCS

As per the datasheet Rds(on)max=3.6mOHM with test condition like Id=100Amp.

If i allow to flow Id=100Amp continuous from MOSFET with Rds(on)max=3.6mOHM then i would have to dissipate Pd=36W(Pd=Id^2 * Rds(on)).

Now if i calculate Tj(Junction Temperature) without heat sink for above condition.

Tj=(Pd * Rtheta(ja)) + Ta,

=(36W * 62deg C/W) + 25deg C,

=2257deg C,

So without heat sink i can not even dissipate Pd=36W of power from MOSFET because, Tj would be out of specs.

I would like to know how TI has managed Tj within safe limits?

What different techniques is followed while testing this product?