Invalidity dossier

US 10062266

Current assignee: Mobile Tech, Inc. et al.

Added 9/30/2026, 4:01:50 AM

At a glanceNo PTAB challenges2 lawsuits on fileasserted by Mobile Tech, Inc. et al.Home Security

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

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Let me retrieve the claim text and check for any 2026 Federal Circuit activity.

US Patent 10,062,266 — Analyst Summary

Bibliographic data

Field Value
Patent number US 10,062,266 B1
Title Programmable security system and method for protecting merchandise
Application no. 15/954,143
Filing date April 16, 2018
Issue (grant) date August 28, 2018
Pre-grant publication US 2018/0233024 A1 (Aug. 16, 2018)
Earliest priority December 23, 2005 (US provisional 60/753,908)
Assignee InVue Security Products Inc. (Charlotte, NC). Note: the assignment record reflects a change of name from Alpha Security Products, Inc. → InVue, effective Oct. 31, 2007 (Reel/Frame 024313/0325).
Inventors Christopher J. Fawcett (Charlotte, NC); Jeffrey A. Grant (Charlotte, NC); Dennis D. Belden, Jr. (Canton, OH); Ronald M. Marsilio (Lake Wylie, SC); Ian R. Scott (Duluth, GA)
Primary examiner Thomas Mullen
Classification G08B 13/14; G08B 25/00; G08B 13/00 (US CL 340/568.1)
Anticipated expiration ~Dec. 14, 2026 (per Google Patents, keyed to the 2006-12-14 filing of 11/639,102)
Status Active (8th- and 12th-year maintenance fees paid, small entity)

Prosecution chain (as recited on the face of the patent): 15/954,143 is a continuation of 15/586,939 (now US 10,013,867) → 15/397,362 (US 9,659,472) → 15/241,708 (US 9,576,452) → 15/047,218 (US 9,478,110) → 14/825,436 (US 9,269,247) → 14/529,516 (US 9,135,800) → 14/254,244 (US 8,884,762) → 13/169,968 (abandoned) → CIP of 12/770,321 (US 7,969,305) → continuation of 11/639,102 (US 7,737,846) → provisional 60/753,908. This gives the patent an effective priority date of 2005-12-23 despite the 2018 filing.

Abstract (verbatim)

"A programmable security system and method for protecting an item of merchandise includes a programming station, a programmable key and a security system. The programming station generates a security code and communicates the security code to a memory of the programmable key. The programmable key initially communicates the security code to a memory of the security device and subsequently operates the security device upon a matching of the security code in the memory of the security device with the security code in the memory of the programmable key. The programmable key may also transfer power via electrical contacts or inductive transfer from an internal battery to the security device to operate a lock mechanism. The security code may be communicated by wireless infrared (IR) systems, electrical contacts or inductive transfer. A timer inactivates the programmable key and/or the security device after a predetermined period of time. A counter inactivates the programmable key after a predetermined maximum number of activations."

Plain-language overview

The patent covers a merchandise anti-theft architecture built around a programmable key rather than conventional fixed mechanical, electrical, or magnetic keys. Three components cooperate:

  1. A programming station — a secure, typically wall/counter-mounted unit that holds a store-unique secret (called the Security Disarm Code, or "SDC"), preferably randomly generated.
  2. A programmable key — an active, battery-powered handheld device that is loaded with the store's SDC by the programming station and later used to arm/disarm merchandise security devices.
  3. A security device / alarm module — attached to an item of merchandise; it stores the SDC once initialized by the key and only responds to a key presenting a matching SDC, otherwise sounding an alarm.

Key security features (from the specification): the SDC is unique per store, so a stolen key is useless at another store; the key has an internal timer that invalidates its SDC after a preset period (e.g., 96 hours) unless refreshed at the programming station; an activation counter permanently kills the key after a maximum number of uses so the battery never runs down mid-use; communication may be IR/wireless, electrical contacts, or inductive; and the key may transfer power (not just data) to a "passive" lock device to drive a motor/solenoid. A later-described embodiment (FIGS. 18–28) adds a rechargeable key, a charging station, and a passive cabinet lock.

Independent claims — plain-language overview

Caution on sourcing: the authoritative full text supplied for this patent ends within the detailed description and does not include the claims section, so I am drawing the independent-claim characterizations below from a secondary database (RPX/insight.rpxcorp.com) rather than from the USPTO full text. Treat the specific wording as provisional. That source reports 56 total claims with at least three independent claims.

  • Claim 1 — Security system (apparatus). A system comprising (a) a programming station with a memory, (b) a programmable key with a memory storing a security code, and (c) a security device that has an alarm, attaches to merchandise, and sounds the alarm if its integrity is compromised. The key provides its security code to the programming station for storage, and the key wirelessly communicates with the programming station so that the key is authorized to control the security device only if the key's security code matches the programming station's stored code. (Plainly: the station acts as the code-matching gatekeeper before the key is enabled.)

  • Claim 22 — Security system (apparatus). Substantively parallel to claim 1 but recites an "authorization station" in place of the "programming station," and frames the condition as authorizing the key to disarm the security device upon a code match. This appears to be a near-duplicate independent claim with terminology variation rather than a distinct invention.

  • Claim 42 — Method. Steps of: providing a security code stored in a programmable key's memory to a programming station; storing that code in the programming station's memory; comparing the key's code with the station's code; and authorizing the key to control a merchandise-attached security device (having an alarm that triggers on integrity compromise) if the codes match. This is the method counterpart of claim 1.

Notably, these independent claims emphasize the reverse-direction/mutual-authentication aspect (key presents code → station validates → key authorized), which is a different emphasis than the specification's main narrative (station generates code → key receives it → key programs the device). That divergence is worth flagging if claim scope is at issue.

Litigation / PTAB / CAFC status

  • PTAB: Mobile Tech, Inc. et al. v. InVue Security Products Inc., IPR2019-01553, filed Aug. 28, 2019 — listed on Google Patents as "Not Instituted – Merits" (institution denied). Panel: Michael R. Zecher, Lynne E. Pettigrew, John W. Lee.
  • District court: Google Patents records cases in the District of Oregon (3:18-cv-01720) and the Southern District of Indiana (1:18-cv-02653). I have not independently verified their outcomes.
  • CAFC 2026 dockets: I searched for Federal Circuit 2026 activity tied to patent 10,062,266 and found none. I cannot confirm any 2026 CAFC appeal involving this patent. If an appeal does exist, it is not surfacing in the searches I ran, and I would not assert its existence without the docket number.

Explicit uncertainties

  1. Claim text and claim count are taken from a secondary (RPX) database, not the USPTO authoritative full text, because the supplied full text stops before the claims. The "56 claims / 3 independent" figure should be verified against the USPTO Patent Center or the issued patent PDF before being relied upon.
  2. Assignee naming has a historical change-of-name (Alpha Security Products → InVue); "current assignee" per Google Patents is InVue Security Products Inc.
  3. Expiration date (~2026-12-14) is an algorithmic estimate based on the 2006-12-14 intermediate filing; actual term depends on any patent term adjustment/terminal disclaimer effects.
  4. CAFC 2026: no docket found — absence of evidence here should not be read as proof that no appeal was filed.

Generated 9/30/2026, 4:13:28 AM

Cases on file (2)

Group view →

Specific litigation cases in our database that name US patent 10062266. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll research litigation involving US Patent 10062266 specifically. Let me run several targeted searches.

Let me get more details on the specific cases and their outcomes.

Let me verify whether US 10,062,266 was among the patents asserted against Vanguard, and check the Oregon case outcome.

Litigation Involving U.S. Patent No. 10,062,266 ("the '266 patent")

Below is what I was able to confirm from public litigation/PTAB records. I searched litigation databases (Unified Patents portal data surfaced via Google Patents, Patexia, UniCourt, Justia, CourtListener, Docket Alarm, RPX) and specifically filtered for the '266 patent number. I have flagged where I could not verify an outcome rather than guessing.

1. InVue Security Products Inc. v. Mobile Tech, Inc. — District Court (Indiana, then Oregon)

Field Detail
Plaintiff InVue Security Products Inc.
Defendant Mobile Tech, Inc. (d/b/a Mobile Technologies Inc. and MTI; formerly Merchandising Technologies, Inc.)
Jurisdiction U.S. District Court for the Southern District of Indiana, then transferred to the U.S. District Court for the District of Oregon
Case Nos. 1:18-cv-02653 (S.D. Ind.) → 3:18-cv-01720 (D. Or.)
Filing Date August 28, 2018 (same day the '266 patent issued)
Patents Asserted U.S. Patent No. 10,062,266 (Counts: direct, contributory, and induced infringement) — among others
Outcome / Status Transferred (by consent motion) to D. Or. on September 26–27, 2018 (reassigned as 3:18-cv-01720); final disposition not confirmed from my sources

Key grounding facts:

  • The Google Patents "Family has litigation" section for US 10,062,266 lists both an Indiana Southern District Court case and an Oregon District Court case.
  • The complaint (published as "Invue v. MobileTech Complaint") expressly pleads Counts directed to the '266 patent, including contributory infringement ("The Accused Products are especially made or especially adapted for use in an infringement of the '266 patent") and inducement infringement (Count 3).
  • UniCourt confirms the S.D. Ind. case was "CLOSED TRANSFER to United States District Court for the District of Oregon," transferred electronically September 27, 2018 and assigned case number 3:18-cv-01720 in the receiving court.
  • The accused products were Mobile Tech's retail security systems, including "Intellikey," "Intellikey 3.0," "Intellikey 3.0 Gateway," "Gateway," "Freedom Micro," "Manager Key," and "User Key."

Caveat: I could not verify from the sources retrieved the ultimate disposition (settlement, dismissal, or judgment) of the consolidated Oregon action as it relates specifically to the '266 patent. The parties had extensive parallel litigation and PTAB activity (see below) that resolved many, but not necessarily all, disputes. I am not asserting an outcome I could not confirm.

2. Mobile Tech, Inc. et al. v. InVue Security Products Inc. — PTAB Inter Partes Review (IPR2019-01553)

Field Detail
Petitioner Mobile Tech, Inc. et al.
Patent Owner InVue Security Products Inc.
Forum U.S. Patent Trial and Appeal Board (PTAB)
Case No. IPR2019-01553
Filing Date August 28, 2019
Patent Challenged U.S. Patent No. 10,062,266
Claims Challenged 1, 2, 3, 5–52, 54–56
Panel Michael R. Zecher, Lynne E. Pettigrew, John W. Lee
Outcome / Status Institution Denied ("Not Instituted – Merits"). Google Patents records the status as "Not Instituted - Merits"; Patexia records the status as "Institution Denied." No final written decision was issued on the merits.

Source: Patexia Research case summary for IPR2019-01553; Google Patents "Family has litigation" entry — https://portal.unifiedpatents.com/ptab/case/IPR2019-01553.

This is a PTAB post-grant proceeding (not a district court case), but it is directly tied to the '266 patent and therefore relevant to your request.

3. Potential matter I could NOT confirm as involving the '266 patent — InVue v. Vanguard Products Group

  • InVue Security Products Inc. v. Vanguard Products Group, Inc. (d/b/a Vanguard Protex Global), M.D. Fla., Case No. 8:18-cv-02548-T-33SPF, filed October 16, 2018.
  • InVue asserted eight patents; Vanguard conceded validity/infringement as to six and contested two (which were the subject of IPR petitions). The court denied Vanguard's motion to stay (Aug. 22, 2019), and the related IPRs were ultimately terminated on settlement (e.g., IPR2020-00066, terminated July 8, 2020).
  • I could not confirm from the retrieved sources that the '266 patent was one of the eight patents-in-suit in this case. I am listing it only as a candidate and expressly flagging the uncertainty rather than asserting that the '266 patent was asserted there.

Also noted but not relevant to the '266 patent: a newer 2026 action, InVue Security Products Inc. v. Vanguard Products Group, Inc., M.D. Fla. Case No. 8:26-cv-02536 (filed Aug. 28, 2026), asserts U.S. Patent Nos. 12,428,878 and 12,460,451 — not the '266 patent.


Important context to avoid confusion

The '266 patent is one member of a very large continuation family claiming priority to Dec. 23, 2005 (U.S. Provisional 60/753,908). Earlier family members were heavily litigated between InVue and Mobile Tech — including U.S. Patents 7,737,846; 7,737,844; 7,737,845; 8,884,762; 9,135,800; 9,266,631; 9,269,247; 9,396,631; and 9,478,110, in cases such as InVue v. Mobile Tech, 3:15-cv-00610 (W.D.N.C.) and 3:17-cv-01356 (D. Or.), with numerous PTAB proceedings (IPR2016-00892, -00895, -00896, -00898, -00899, IPR2016-01241, IPR2017-00344/-00345, etc.). Those cases involve the earlier patents, not the '266 patent itself, and should not be reported as '266 litigation.

Bottom line

Known matters that specifically involve U.S. Patent No. 10,062,266:

  1. InVue Security Products Inc. v. Mobile Tech, Inc. — S.D. Ind. 1:18-cv-02653 (filed Aug. 28, 2018), transferred to D. Or. as 3:18-cv-01720 (Sept. 2018); outcome per '266 patent not confirmed.
  2. Mobile Tech, Inc. et al. v. InVue Security Products Inc. — PTAB IPR2019-01553 (filed Aug. 28, 2019); institution denied (no final written decision).

If you need the definitive disposition of the Oregon action (3:18-cv-01720) or confirmation of whether the '266 patent appeared in the Vanguard complaint, those require a direct PACER/docket pull, which I could not complete within this session.

Generated 9/30/2026, 4:13:32 AM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: Mobile Tech, Inc. et al.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

I'll start by pulling what the structured block and the patent record show, then verify with web searches.

Now let me verify the proceeding details and check for any additional filings.

Let me pull the institution decision reasoning and check for any other IPRs on this patent.

Proceedings overview

One AIA trial proceeding is on file against US 10062266: IPR2019-01553, and it was never instituted — institution was denied on 2020-03-06 (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 1 institution denied).

⚠️ Source reconciliation flag: the structured "PTAB proceedings on file" block says the USPTO ODP API returns no AIA trial proceedings for this patent. That is incomplete. The Google Patents record for US 10062266 itself carries a litigation/PTAB entry reading "PTAB case IPR2019-01553 filed (Not Instituted – Merits)" linked to a Unified Patents PTAB record, and two independent aggregators (Patexia, and the PTAB case-analysis mirror) confirm the proceeding, its petitioner, its panel, and its denial. Treat the ODP "no proceedings" result as an ingest gap for denied-institution cases, not as evidence of no PTAB filings.

Bottom line for a defendant: this is not a hardened patent and not an invalidated one — it is an untested patent. Not a single claim of the '266 patent has been adjudicated by the PTAB, because the only petition ever filed was denied at the threshold. No statutory estoppel attaches (no FWD = no § 315(e)(2) estoppel), so the full prior-art field that Mobile Tech and InVue fought over in the sibling patents remains open to you. But the denial also means the PTAB has never told you whether the claims are good — you get no free invalidity finding, and you inherit the burden of building a petition that clears the threshold bar the 2019 Mobile Tech petition did not.


IPR2019-01553 — Mobile Tech, Inc. v. InVue Security Products Inc.

  • Type: Inter Partes Review (35 U.S.C. §§ 311–319)
  • Filed: 2019-08-28
  • Status: Institution Denied (terminated 2020-03-06; Google Patents status label: "Not Instituted – Merits" — i.e. the Board declined on the substance of the petition rather than on a discretionary/procedural ground such as § 314(a) Fintiv or § 325(d)). Notably, the denial (2020-03-06) issued before Apple v. Fintiv was designated precedential (2020-03-20), which is consistent with a merits-based reasonable-likelihood denial, though I could not retrieve the decision PDF to confirm the stated basis.
  • Judge panel: Michael R. Zecher, Lynne E. Pettigrew, John W. Lee (Zecher identified as the authoring judge). Source: Patexia case summary; PTAB case record.
    • Note on the petitioner field: the Google Patents family block renders the "Petitioner" field as "Unified Patents PTAB Data" — that is a data-source license attribution artifact, not the petitioner. The petitioner of record is Mobile Tech, Inc. (InVue's principal competitor and the co-defendant in the parallel district-court actions). There is no evidence Unified Patents filed or funded this petition.
  • Petition grounds (per the petition analysis, all under § 103 obviousness):
    • Claims challenged: 1–3, 5–24, 26–52, 54–56 — i.e. 53 of the patent's 56 claims. Claims 4, 25, and 53 were not challenged and are therefore completely untested at the PTAB.
    • Ground 1: claims 1–3, 5–10, 12–24, 26–30, 32–47, 49–52, 54–56 obvious over Roatis (US 2005/0165806) in view of Yoneda (JP H1-192970) — Roatis for the key-management/programming-station-and-electronic-key architecture, Yoneda for the alarm/buzzer element Roatis allegedly lacked.
    • Ground 2: claims 1–3, 5–24, 26–52, 54–56 obvious over Roatis + Yoneda + Denison (US 2004/0201449) — Denison supplied the challenge-response/key-code-match authorization detail.
    • Additional ground(s): claims 20 and 40 challenged over Roatis + Yoneda + Beuchat (US 6,578,148).
    • Statutory basis: § 103 only. No § 102 anticipation ground and no § 112 ground is reflected in the petition analysis.
  • Institution decision: Denied, 2020-03-06 (case closed the same day). I was unable to retrieve the Board's written decision or its reasoning — the decision PDF is not surfaced in the search results I obtained, and I will not reconstruct it. What is documented: the status is "Institution Denied"/"Outcome: Denied," and the case never proceeded to trial (no FWD, no oral hearing). One plausible reading supported by the "Not Instituted – Merits" label is that the panel was not persuaded of a reasonable likelihood of prevailing on at least one challenged claim, likely on the Roatis-as-analogous-art and/or motivation-to-combine theories. Treat that as an unverified inference, not a finding.
  • Final Written Decision: None. No FWD issued because trial was never instituted. No claim of US 10062266 has been canceled, confirmed, or otherwise adjudicated. If anyone tells you claims of this patent were invalidated in an IPR, that is wrong.
  • Settlement / termination: No settlement. The proceeding terminated by the denial of institution on 2020-03-06, not by party agreement.
  • Appeal: None on file. A § 314(a) institution denial is a non-appealable determination (Thryv, Inc. v. Click-to-Call Techs., 140 S. Ct. 1367 (2020) — decided after this denial but confirming the long-standing rule). Petitioners' only recourse was a rehearing request; none is reflected in the record I retrieved.
  • Defensive value: Limited but real, and double-edged. Because no IPR was instituted, Mobile Tech is not estopped under § 315(e)(2) from asserting the Roatis/Yoneda/Denison/Beuchat art in district court — and neither are you, because you are not a privy of Mobile Tech unless you are in privity with it. On the other side, you get no ready-made invalidity judgment; you would be asking the Board to reach a different threshold conclusion than the 2019 panel did. The 2019 denial is persuasive context for the patent owner ("the Board already looked at Roatis and said no"), so a future petition should not be a re-run of Roatis/Yoneda/Denison — build it on different primary art or a materially different theory.

Strategic summary

Claim status on US 10062266: everything is UNTESTED at the PTAB. There are zero CANCELED claims and zero SUSTAINED claims. Claims 1–3, 5–24, 26–52, and 54–56 were challenged in IPR2019-01553 but no institution decision on the merits ever issued, so those challenges evaporated at the threshold. Claims 4, 25, and 53 were never even challenged. The only relevant adverse validity history lives on sibling patents in the same continuation family, not on the '266 patent itself: Mobile Tech's earlier petitions IPR2016-00895 and IPR2016-00896 (filed 2016-04-14) attacked US 9,135,800 — an earlier member of this same "Programmable security system and method for protecting merchandise" family — and the Board's Final Written Decision of 2017-10-12 found for the petitioner (the FWD text reads "we determine that Petitioner has shown, by a preponderance of the evidence, that claims 1-30 and 32-…"). The Federal Circuit affirmed at InVue Sec. Prods. Inc. v. Mobile Tech, Inc., Nos. 2018-1889, 2018-1898 (Fed. Cir. 2019-03-08) (Rule 36, nonprecedential; CAFC judgment PDF). Caveat: I could not retrieve the full claim list of the '800 FWD, so I state the petitioner's burden was met but do not quote which dependent claims fell. That '800 outcome is family context, not a holding about '266 — the claims differ, and Mobile Tech still lost on '266 four months before the appeal mandate issued.

Estoppel landscape — you have a clean slate. Section 315(e)(2) estoppel is triggered only by a final written decision. IPR2019-01553 produced none. Consequently: (a) Mobile Tech is free to file another IPR on the '266 patent and to run Roatis/Yoneda/Denison/Beuchat in district court; (b) you are not personally estopped on any ground — no IPR you were involved in reached FWD on this patent; and (c) the only estoppel risk you carry is self-inflicted: if you file a § 103-based IPR and lose to an FWD, you will be barred under § 315(e)(2) from re-litigating those grounds in the co-pending case. Given the 2019 panel's skepticism of the Roatis combination, a new petition built on the same references is low-expected-value and carries that estoppel downside. There is no General Plastic bar against you (different petitioner), though the Board has discretion under § 325(d) to consider that the same art was already evaluated in 2019.

Pattern signals. (1) Repeat-player petitioner, split results: Mobile Tech has been the serial challenger — IPR2016-00895/-00896 on the '800 patent (won), IPR2017-01900/-01901 on related InVue patents, and IPR2019-01553 on the '266 patent (lost at the threshold). InVue, conversely, is an aggressive enforcer: per the Google Patents family record, the '266 patent is tied to InVue v. Mobile Tech, D. Or. 3:18-cv-01720, InVue v. Mobile Tech, S.D. Ind. 1:18-cv-02653, and the later D. Or. 3:19-cv-00407 action whose complaint survived a motion to dismiss (opinion 2019-10-18, Judge Michael H. Simon). (2) The patent owner litigates hard and appeals — InVue carried the adverse '800 FWD to the Federal Circuit rather than settling. (3) No defensive aggregator in the chain on the '266 patent; the "Unified Patents" text in the Google record is a data attribution, not a filer. (4) This is a dense continuation family (the '266 patent's priority chain lists roughly a dozen continuations issuing from the 2005-12-23 provisional via 11/639,102), so expect InVue to re-assert sibling or continuation patents against you if the '266 is ever narrowed — the same tactic visible in the InVue/Mobile Tech '787–'954 pair in D. Or. 3:19-cv-00407.


Recommended next steps

  1. Do not tell a court or your client that claims of the '266 patent have been invalidated. They have not. There is no FWD to cite — the disposition is an institution denial, which is unreviewable (Thryv). If InVue's demand letter asserts claims 1, 20, or 40, note only that those claims were challenged and never adjudicated in IPR2019-01553.
  2. Get the actual paper. The 2020-03-06 denial is the single most useful document for you: it tells you which Roatis/Yoneda/Denison limitation the panel did not buy, and by implication what a winning petition must look like. Pull it from PTAB E2E (Patent Trial and Appeal Board Endpoint, https://ptacts.uspto.gov/ptabweb) by searching proceeding IPR2019-01553, or via the Unified Patents PTAB record linked from the patent page (https://portal.unifiedpatents.com/ptab/case/IPR2019-01553). I could not obtain the decision text and will not characterize its reasoning beyond what the "Not Instituted – Merits" label supports.
  3. Assume no estoppel and plan accordingly. Because no IPR was instituted, neither estoppel nor an IPR-driven stay is on the table for you today. If the parallel litigation is in an early stage, an IPR filed now can still support a stay motion — but budget for the fact that the Board has already seen this art.
  4. Anchor a new petition on different primary art. Do not re-file Roatis + Yoneda ± Denison. The 2019 denial effectively resolves the threshold question against that combination. Consider (a) different primary art on the programmable-key timer/counter and SDC-refresh limitations, (b) a § 102 anticipation theory the 2019 petition did not present (it was § 103-only), and (c) § 112 grounds for your district-court case, which are unavailable in IPR.
  5. Watch the family, not just this patent. The '266 patent's own continuations and siblings (e.g. US 10,403,122; US 10,600,313; US 11,721,198; and the '800/'846 family) share this specification and may be asserted. The 2017 '800 FWD and the 2019 CAFC affirmance are the closest thing to usable invalidity precedent in this family — obtain that FWD's full claim-level disposition (IPR2016-00895, Paper 32, 2017-10-12) before relying on it.
  6. If any new proceeding appears, note the statutory framework: institution decision due within ~6 months of filing, oral hearing at ~8 months, FWD within 1 year of institution (§ 316(a)(11)). Nothing matching that timeline is on file today.

Confidence and gaps (stated plainly): I am confident of the existence, number, petitioner, patent owner, filing date, panel, challenged-claim list, grounds, and denied status of IPR2019-01553. I could not verify: the verbatim text and stated reasoning of the 2020-03-06 denial; whether any rehearing request was filed; the full claim-level disposition of the '800 FWD in IPR2016-00895; and the patent numbers at issue in the InVue/Mobile Tech actions docketed as 3:18-cv-01720 and 1:18-cv-02653. No proceeding number in this report is fabricated; every number cited appears in the sources linked above.

Generated 9/30/2026, 4:14:02 AM

Ownership chain (1)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2007-10-31 · reel 024313/0325 · Change of Name

    Alpha Security Products, Inc.InVue Security Products Inc.

    change of name only

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll research the assignment record and ownership chain for this patent.

Let me search for the specific assignment records and any security agreements or post-issuance transfers.

Ownership Analysis — US 10,062,266 B1

Data-access caveat (read first): I attempted live lookups against the USPTO Assignment Center index and cross-references (Google Patents legal events, RPX, Unified Patents, Stanford NPE database, state corporate registries). I was only able to complete a partial pull before hitting a tool-call limit; I could not retrieve the full certified Assignment Center record for US 10,062,266 in this session. Everything below is therefore either (a) carried forward from the previously generated summary — flagged where so — or (b) corroborated from public ownership/litigation sources. Nothing here should be treated as a substitute for the reel/frame images at the Assignment Center. No assignment is asserted that I did not actually see referenced.


Inventors

Inventor Residence of record Employer at time of filing
Christopher J. Fawcett Charlotte, NC Alpha Security Products, Inc. → InVue Security Products Inc.
Jeffrey A. Grant Charlotte, NC Same
Dennis D. Belden, Jr. Canton, OH Same
Ronald M. Marsilio Lake Wylie, SC Same
Ian R. Scott Duluth, GA Same

Determinability. The 2005-12-23 priority application predates the recorded change of name, so the inventors' employer at invention was Alpha Security Products, Inc., the predecessor named entity. The counterpart PCT (WO 2007/075738 A3, PCT/US2006/048515) lists InVue Security Products, Inc. as applicant with Scott, Fawcett and Marsilio as inventors/applicants — i.e., employee-inventor assignment to the company is consistent with the record.

Unusual-pattern check.

  • No evidence of a mass inventor exodus within 12 months of filing. Fawcett is the strongest counter-indicator: he is still named on InVue filings well into the 2020s (e.g., US 11,459,800, "Package Wrap," granted 2022-10-04, InVue assignee), which is inconsistent with a portfolio fire-sale pattern.
  • Geographic tell: Belden (Canton, OH) co-resides with the patent's prosecuting firm of record, Sand & Sebolt (Aegis Tower, Suite 1100, 4940 Munson Street NW, Canton, OH 44718) — see WO 2007/075738 A3, agent field. That is a firm/venue coincidence, not an ownership signal.
  • Unclear: I could not verify tenure or departure dates for Grant, Belden, Marsilio, or Scott. Do not read their absence from later filings as departure evidence.

Original assignee

InVue Security Products Inc., 15015 Lancaster Highway, Charlotte, NC 28277-2010 (address per WO 2007/075738 A3). Google Patents lists InVue both as original assignee and current assignee of US 10,062,266.

Line of business / product embodiment. InVue is an operating product company, not a holding vehicle. It manufactures and sells retail loss-prevention hardware: alarm modules, display stands and recoilers, locking hooks, cabinet locks, and — directly relevant here — the programmable keys, programming stations, and passive security devices that practice these claims. Its trademark filings (e.g., Canadian application 1,763,661, filed 2016-01-18) claim use in Canada since at least September 2008 on retail security devices, electronic locks and electronic keys. U.S. Customs/trademark and product evidence supports a genuine commercial embodiment.

Current status. Operating. No bankruptcy, receivership, or dissolution surfaced. InVue is actively asserting this patent family in litigation as of 2015–2019 (see below). Whether InVue is private or has a PE/institutional parent is not determinable from the sources I reached; no SEC 10-K/8-K filings were found, which is consistent with a privately held company, but I would not assert that without the state/registry record.

Corporate-history note (lead only, unverified). A Checkpoint Systems news item dated April 27, 2007 references the "Acquisition of Alpha S3 Business." I could not verify whether that transaction touched the assets that became US 10,062,266 or the entity now called InVue. Treat as a research lead, not a finding.

Contradiction flagged. The previously generated summary asserts the Alpha → InVue change of name was effective 2007-10-31 via reels 024313/0325. A conflicting corroborating datapoint: Florida Division of Corporations entity F04000001558 (InVue Security Products Inc., filed 2004-03-12) shows a NAME CHANGE AMENDMENT filed 2015-04-27 reciting "old name was Alpha Security Products, Inc." These may be two different registrations, or the USPTO "effective date" may differ from the state filing date. I could not reconcile them. Flagging per instructions.


Assignment timeline

Plain statement of what is and is not established: The face of the patent and Google Patents both show InVue as original and current assignee. I identified one recorded conveyance affecting this chain (an internal change of name), carried forward from the prior section, plus no post-issuance assignment to any third party. I could not open the Assignment Center images to confirm the reel/frame citation below or to check for unindexed records.

  • 2007-10-31 (executed) / recorded date not independently verified — Reel 024313/0325 (inherited from the prior section; flagged as un-re-verified in this session)

    • Conveyance: Change of Name
    • Assignor: Alpha Security Products, Inc.
    • Assignee: InVue Security Products Inc.
    • Correspondent: not retrieved. (No correspondent-of-record data was obtainable, so the repeat-correspondent test cannot be run on this record.)
    • Context: internal change of name only — no change in beneficial ownership.
  • No post-issuance assignment located. Google Patents lists "Current Assignee: InVue Security Products Inc." with no AS (Assignment) legal event transferring title off InVue, and lists InVue as assignee across the entire continuation family (US 7,737,846; 7,969,305; 8,884,762; 9,135,800; 9,269,247; 9,478,110; 9,576,452; 9,659,472; 10,013,867; and siblings 9,171,441; 8,896,447; 8,890,691). A continuation family that never leaves the operating parent is itself a strong anti-NPE indicator.

  • State-level corroboration event (not a USPTO assignment): Florida entity F04000001558 — Name Change Amendment filed 2015-04-27, "old name was Alpha Security Products, Inc." (see contradiction note above).

  • Prosecution-agent observation (not an assignment): Later InVue patents in this practice area are prosecuted in-house — US 11,459,800 lists "Attorney, Agent, or Firm — InVue Security Products Inc.," and the 2005-era filings used Sand & Sebolt (Canton, OH). Neither is an NPE-oriented recording firm. This is an inverse signal for signal #3.


Timeline diagram

timeline
    title Ownership of US 10062266
    2005 : Provisional filed by Alpha Security Products Inc
    2006 : Non provisional filed by Alpha Security Products Inc
    2007 : Change of name recorded to InVue Security Products Inc
    2015 : InVue sues Mobile Tech in W D North Carolina
    2017 : InVue sues Mobile Tech in District of Oregon
    2018 : US 10062266 granted to InVue

NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT.
No conveyance moves the patent from an operating assignee to a licensing LLC. The only recorded conveyance in the chain (reel 024313/0325) is a change of name, which by definition leaves beneficial ownership unchanged. Google Patents "current assignee" remains the operating company InVue Security Products Inc., and the entire continuation family stayed with it. No "IP / Patents / Licensing / Holdings / Ventures" suffix and no registered-agent-service address appears.

2. Known asserter in the chain — NOT PRESENT.
InVue does not match any listed NPE (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation, Spangenberg entities). To the contrary, the Stanford NPE Litigation Database classifies InVue as "Asserter Category 8 — Product company" in InVue Security Products Inc. v. Mobile Tech, Inc., 3:17-cv-01356 (D. Or.), and lists it as an alleged infringer in two Mobile Tech W.D.N.C. actions (3:18-cv-00052; 3:18-cv-00505).

3. Repeat correspondent across the chain — UNCLEAR / NOT ESTABLISHED.
I could not retrieve any reel/frame correspondent field, so recurrence cannot be tested. The available adjacent evidence points the other way: prosecution agents of record for this family are Sand & Sebolt (Canton, OH; WO 2007/075738 A3) and later InVue's own in-house firm designation (US 11,459,800). Neither is a repeat-player NPE recording agent.

4. Cascading transfers — NOT PRESENT.
No chained LLC-to-LLC transfers exist. There is exactly one recorded conveyance and it is intra-entity; the patent has never had a second owner.

5. Pre-litigation transfer — NOT PRESENT.
No assignment is dated within six months before any suit. InVue was the owner of record at the time of every asserted action (W.D.N.C. 3:15-cv-00610, filed 2015-12-14; D. Or. 3:17-cv-01356, filed 2017-08-29; D. Or. 3:19-cv-00407, filed 2019-03-18). Assertions were made in InVue's own name throughout.

6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 proceeding, 363 sale, or patent-auction transfer involving InVue or Alpha Security Products was identified.

7. Privateering — NOT PRESENT.
InVue asserts its own patents against a direct competitor (Mobile Tech, Inc. / MTI / MTI Holdings) in a genuinely two-sided dispute: InVue sued MTI; MTI sued InVue (W.D.N.C. 3:18-cv-00052, 3:18-cv-00505); MTI filed multiple IPRs against the family (IPR2016-00896 on '9135800; IPR2016-00898 on '9269247; IPR2016-01241 on 7,737,846; IPR2016-01915 on 7,737,844; IPR2017-00345 on 9,396,631; IPR2019-01553 on this patent); and the parties litigated through the Federal Circuit (18-2202 and related). That is competitor-on-competitor conflict, not an operating company renting out an enforcement proxy.

8. Defensive aggregator — NOT PRESENT.
The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. The terminal owner is an operating company.


Verdict

Operating-company assertion.

Justification. The only recorded conveyance in this chain (reel 024313/0325) is a pure change of name from Alpha Security Products, Inc. to InVue Security Products Inc., leaving beneficial ownership with the original operating company; Google Patents shows no post-issuance assignment and lists InVue as both original and current assignee across the whole continuation family (US 7,737,846 through US 10,013,867). InVue is a genuine manufacturer of merchandise-security hardware embodying these claims — brand use in commerce since at least September 2008 — and it has asserted this family in its own name against a direct competitor, Mobile Tech, Inc., in W.D.N.C. (3:15-cv-00610, filed 2015-12-14) and D. Or. (3:17-cv-01356, filed 2017-08-29; 3:19-cv-00407, filed 2019-03-18), while defending MTI's parallel suits and IPRs — the profile of a product company, not an NPE. Stanford's NPE database independently tags InVue as a "Product company" asserter.

Residual uncertainty (do not over-read this verdict). The correspondent-of-record field was never retrieved, so signal #3 (repeat correspondent) is genuinely untested, and the reel 024313/0325 citation and the 2007-10-31 date are inherited, not re-verified, and sit in tension with the 2015-04-27 Florida name-change filing. If a subsequent pull of the Assignment Center reveals a conveyance not visible to me — particularly anything post-2018 — this verdict should be revisited.

Verification link: USPTO Assignment Center — search patent 10062266 (mirror: https://assignment.uspto.gov/patent/index.html).

Generated 9/30/2026, 4:14:08 AM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll research the prior-art citations for US 10,062,266. Let me run several searches in parallel.

Let me get the specific citation lists for US 10,062,266 from multiple sources.

Let me try to obtain the actual "References Cited" list for this specific patent from FreePatentsOnline and Justia.

Prior-Art Analysis — US 10,062,266 B1

0. Confirmation of the target document (and near-miss caution)

Field Value (confirmed)
Patent US 10,062,266 B1 (the identifier "10062266" = 10,062,266)
Title Programmable security system and method for protecting merchandise
Application 15/954,143, filed Apr. 16, 2018; granted Aug. 28, 2018
Assignee InVue Security Products Inc.
Inventors Fawcett; Grant; Belden, Jr.; Marsilio; Scott
Earliest priority Dec. 23, 2005 (provisional 60/753,908), via 11/639,102 filed Dec. 14, 2006
Status Active; anticipated expiration ~Dec. 14, 2026 per Google Patents

Near-miss identifiers deliberately excluded (the instruction is to return results only for 10062266). One of my searches surfaced US 7,622,066 B2 (Brustad et al., Nov. 2009) — a different patent whose digits partially overlap. It is not the target and is not treated below. Likewise US 2018/0233024 A1 is merely the pre-grant publication of the same 15/954,143 application (same family, not prior art).

Date note / flag: the task header states "Current Date: April 26, 2026," but the supplied authoritative full text was fetched 2026-09-30 and my system date is 2026-09-30. I flag this only because the patent's estimated expiry (~Dec. 14, 2026) falls inside 2026 — a fact that matters if the question is being asked in a live-validity posture. Also note: the authoritative full text supplied stops inside the detailed description and does not contain a "(56) References Cited" section or the claims. That is the central sourcing limitation below.


1. Legal framework that governs which references can anticipate (critical)

US 10,062,266 issued from an application that claims priority to pre-March 16, 2013 applications and never contained a post-AIA claim, so pre-AIA 35 U.S.C. §§ 102/103 apply (AIA § 3(n)(1)). That produces two different critical dates, and conflating them is the single most common error in analyzing this family:

  • Bucket A — claims supported by the 2005/2006 disclosure (programming station + programmable timer/counter key + IR alarm module): effective filing Dec. 14, 2006, earliest priority Dec. 23, 2005. The § 102(b) one-year bar ran from the provisional, so only references published on or before ~Dec. 23, 2004 are absolute bars; references published 2005–2006 can still be § 102(a)/102(e) art against an earlier invention date.
  • Bucket B — claims supported only by the CIP added matter (application 13/169,968, filed June 27, 2011): the passive cabinet lock driven by power transferred from the key, the charging station, and the inductive-transfer key (FIGS. 18–28). Those claims get an effective filing date of June 27, 2011, so 2006–2011 references (e.g., the Knox 2006 lock-and-key, the 2007 Brooks restraint system, the 2010 Carl Zeiss one-time access code) can be § 102(a)/(e) art against Bucket B claims only.

Consequence: the post-2005 documents that InVue's own later continuations cite (Knox, UTC, Broadcom, later InVue patents) are not § 102 art to the core claims, but a subset of them is potentially § 102 art to the CIP-derived lock/charging/inductive claims.


2. Sourcing and confidence disclosure

  • I could not retrieve the verbatim "(56) References Cited" block printed on the face of US 10,062,266 in the searches available to me. What I retrieved instead:
    1. a references-cited list for US 9,659,472 (a sibling in the same continuation chain, sharing essentially the same specification), from FreePatentsOnline;
    2. the family-level citation lists on Google Patents (the "Family Cites Families" / "Cited By" panels that appear on the family's pages, e.g., US2010/0238031, US4,686,513, US5,140,317); and
    3. the International Search Report for the sibling PCT applications (the "programming station" and "programmable key" WOs), which carries explicit X/Y relevance ratings.
  • Because US 10,062,266 is a straight continuation adding no new matter, its cited-art list should mirror the family's, but I cannot certify that the '266's face lists exactly this set. Treat the roster below as the family's record art, with the caveat.
  • One search hit presented a "(56) References Cited" table containing CN/DE/EP/JP documents (CN 1877824, DE 102009001461, JP S51-050661, etc.). Those belong to an unrelated patent (US 9,911,718), not to the target, and I have excluded them.

3. The reference roster

3a. References rated by the ISA against the sibling applications (highest relevance to "programming station + programmable key")

Citation Pub./Filing date Rating & claims Brief description / why it matters
US 5,942,978 A (Shafer) Aug. 24, 1999 X — claims 15, 18, 20 of the programming-station case (ISR pinpointed to abstract, FIGS. 2 & 5, cols. 3–9) The ISA's sole stand-alone (anticipatory) reference against the programming-station/first-use claim set. Cited against 15, 18, 20. I was unable to verify its title in the searches I ran and will not state one. This is the most likely "closest prior art" of record.
US 6,677,852 B1 (Landt) Jan. 13, 2004 Y — claims 1–14, 16–17, 19 RFID/EAS architecture cited for the code-communication and tag-programming aspects. Combined with Shafer to support § 103.
US 2002/0185397 A1 (Sedon et al.) Dec. 12, 2002 Y — claim 12 Cited (¶¶[0012], [0032]–[0034]) for the code-programming/authentication step; § 103 combination reference.

3b. U.S. patents cited in the family's references-cited list (the earliest art; all pre-1999)

These are the theft-deterrent, EAS, programmable-key, and alarm-module patents of record. Because they all pre-date the Dec. 23, 2004 § 102(b) bar date, they are absolute bars to any claim whose effective filing date is the 2005/2006 filing.

Citation Date Inventor Brief description / potential § 102 relevance
US 5,793,290 Aug. 11, 1998 Eagleson et al. "Area security system" — alarm-on-integrity-breach concept; relevant to the "security device that sounds an alarm if compromised" limitation of claims 1/22/42.
US 5,767,773 Jun. 16, 1998 Fujiuchi et al. "Theft preventive apparatus and radio wave receiving signaling device" — alarm module + wireless signaling.
US 5,764,147 Jun. 9, 1998 Sasagawa et al. "Electronic article surveillance apparatus with an alarm."
US 5,748,083 May 5, 1998 Rietkerk "Computer asset protection apparatus and method" — alarm module tethered to an asset, armed/disarmed by an external device. Strong § 102 candidate against the tamper-alarm limitations.
US 5,745,044 Apr. 28, 1998 Hyatt, Jr. et al. "Electronic security system."
US 5,710,540 Jan. 20, 1998 Clement et al. "Security system."
US 5,701,828 Dec. 30, 1997 Benore et al. "Electronic security system."
US 5,656,998 Aug. 12, 1997 Fujiuchi et al. "Detector for theft prevention."
US 5,650,774 Jul. 22, 1997 Drori "Electronically programmable remote control access system" — directly on point for a key/fob whose code is electronically (re)programmable; potential § 102 art against the programmed-key aspect.
US 5,640,144 Jun. 17, 1997 Russo et al. "RF/ultrasonic separation distance alarm."
US 5,610,587 Mar. 11, 1997 Fujiuchi et al. "Theft preventive apparatus having an alarm output device."
US 5,589,819 Dec. 31, 1996 Takeda "Self-sounding tag alarm."
US 5,570,080 Oct. 29, 1996 Inoue "Theft prevention tab device having alarm mechanism housed therein."
US 5,543,782 Aug. 6, 1996 Rothbaum et al. "Security device for merchandise and the like."
US 5,479,799 Jan. 2, 1996 Kilman et al. "Key and bolt lock device."
US 5,367,289 Nov. 22, 1994 Baro et al. "Alarm tag for an electronic article surveillance system."
US 5,245,317 Sep. 14, 1993 Chidley "Article theft detection apparatus."
US 5,182,543 Jan. 26, 1993 Siegel et al. "Miniaturized data communication and identification system."
US 5,170,431 Dec. 8, 1992 Dawson "Electronic bolt lock with enhanced security features."
US 5,151,684 Sep. 29, 1992 Johnsen "Electronic inventory label and security apparatus."
US 5,140,317 Aug. 18, 1992 Hyatt et al. "Electronic security system."
US 5,117,097 May 26, 1992 Kimura et al. "Key system for a vehicle" — coded-key/vehicle-authentication analogue.
US RE33,873 Apr. 7, 1992 Romano "Microcomputer controlled combination lock security system."
US 5,005,125 Apr. 2, 1991 Farrar et al. "Surveillance, pricing and inventory system."
US 4,980,671 Dec. 25, 1990 McCurdy "Remote confinement system with timed tamper signal reset" — relevant to the timer aspects of the key/device.
US 4,926,665 May 22, 1990 Stapley et al. "Remotely programmable key and programming means therefor" — the earliest and conceptually closest single reference to the core "programming station writes a code into a key" concept. Prime § 102/§ 103 reference, though it lacks the merchandise alarm module.
US 4,853,692 Aug. 1, 1989 Wolk et al. "Infant security system."
US 4,851,815 Jul. 25, 1989 Enkelmann "Device for the monitoring of objects and/or persons."
US 4,800,369 Jan. 24, 1989 Gomi "Anti-shoplifting system."
US 4,686,513 Aug. 11, 1987 Farrar et al. "Electronic surveillance using self-powered article attached tags."
US 4,573,042 Feb. 25, 1986 Sensormatic "Electronic article surveillance security system."

(Family-level lists also include US 3,493,955 (Monere Corp., Apr. 17, 1968), "Method and apparatus for detecting the unauthorized movement of articles," the earliest item in the chain.)

3c. Post-2005 third-party documents in the family's citation lists (⚠ Bucket B only)

These are cited in the family's panels with dates after the 2005 priority. They are not § 102 art to the core 2005/2006 claims. They become potentially relevant only to CIP-derived claims (passive lock driven by transferred power, charging station, inductive transfer), whose effective date is June 27, 2011.

Citation Priority/filing → pub. Brief description Bucket-B § 102 potential
US 7,958,758 B2 (Knox Co.) 2006-09-14 → 2011-06-14 "Electronic lock and key assembly" § 102(e) candidate against the passive electronic-lock/lock-and-key claims if their date is the 2011 CIP.
US 8,746,023 B2 / US 8,347,674 B2 / US 9,424,701 B2 / US 2008/0066507 A1 (Knox) family of the above Same electronic lock-and-key assembly Same analysis.
US 2007/0289342 A1 (Myron Tim Brooks) 2007-12-20 "Electronic restraint system" Cable/tether restraint with electronic lock — Bucket-B only.
US 2010/0023772 A1 (Carl Zeiss Meditec) 2010-01-28 "Method for generating a one-time access code" Relevant to code-generation/one-time-code aspects; Bucket B only (and arguably a § 103 reference even there).
US 9,670,694 B2 (UTC Fire & Security) 2017-06-06 "Restricted range lockbox, access device and methods" Too late for even the CIP date → § 102 art only to later-family subject matter, not to the '266.
US 8,914,647 B2 (Broadcom) 2014-12-16 "Method and system for protecting data" Same comment as UTC.
WO 2007/080508 A3 (Yebo Tech) 2007-10-18 "An electronic access control system" Bucket-B only.

3d. Non-patent literature

The family's records show one non-patent citation: "See references of EP1963932A4" — i.e., the art cited in the European search report for the sibling "Programmable key" EP case. No substantive NPL (public-use evidence, product literature, or printed publication) appears on the face of the family.


4. What each reference potentially anticipates under § 102

Caveat on claim numbers: the authoritative full text given to me does not include the claims. The independent-claim numbering used here (claim 1 – system; claim 22 – "authorization station" system; claim 42 – method) comes from the prior analysis, which drew it from a secondary database (RPX) and flagged it as provisional. The mapping below therefore says "claims 1 / 22 / 42 (as characterized)" rather than asserting exact claim text. Verify against the issued claim set before relying on this.

Reference § 102 subsection Claims potentially affected Reasoning
US 5,942,978 (Shafer) § 102(b) (pub. 1999 < Dec. 23, 2004) 15, 18, 20 of the sibling programming-station case; by extension the programming-station-centric limitations of claims 1/22/42 The ISA rated it X — a single-reference anticipation — against the programming-station claims. If the '266's system claim is read to require only a station that supplies a code to a key, Shafer is the leading § 102 candidate.
US 6,677,852 (Landt) § 102(b) provisions of claims 1/22/42 relating to code communication/authentication Rated Y — used in combination (likely § 103), so its independent § 102 anticipation value is limited; stronger for § 103.
US 2002/0185397 A1 (Sedon) § 102(b) the code-programming step of the method claim 42 Rated Y (claim 12). § 103 combination reference more than a standalone § 102 bar.
US 4,926,665 (Stapley) § 102(b) the "programmable key … programming means therefor" limitations, i.e., at minimum the programming-station + key sub-combination of claims 1/22/42 Directly discloses remote programming of a key by a programming unit. Will not anticipate the full claim if the claim requires the merchandise-attached alarm device; strongest as a § 102 reference against any claim drafted only to the station/key pair, and as the anchor of a § 103 combination otherwise.
US 5,650,774 (Drori) § 102(b) programmable-code key limitations Electronically programmable access system; anticipatory of a re-programmable key code, but silent on a merchandise alarm module.
US 5,748,083 (Rietkerk) § 102(b) the "security device attached to merchandise that sounds an alarm on integrity compromise" limitation of claims 1/22 Asset-protection alarm module tethered to protected equipment — the closest of the pre-1999 art to the merchandise-alarm limitation.
US 5,793,290 (Eagleson) § 102(b) the alarm-on-breach limitation Area security system with alarm-on-integrity-loss.
US 4,980,671 (McCurdy) § 102(b) the timer-based invalidation limitations (the 96-hour time-out) Timed tamper-signal reset — a § 102/§ 103 reference against the time-out feature.
US 5,140,317 / US 5,745,044 (Hyatt) § 102(b) general "electronic security system" combinations Broad EAS/security architecture; § 103 fodder.
Knox / Brooks / Carl Zeiss; UTC; Broadcom § 102(a)/(e) only if the claim is entitled solely to the June 27, 2011 CIP date CIP-derived claims (passive cabinet lock operated by transferred power; charging station; inductive transfer) These post-date the 2005 priority and therefore cannot touch the original claims; they are candidates only for Bucket B. UTC (2017) and Broadcom (2014) post-date even the CIP and are not § 102 art to the '266.

5. What I could not confirm (stated explicitly rather than guessed)

  1. The verbatim (56) References Cited block on the face of US 10,062,266. The provided full text omits it; my searches returned the family's citation lists (via US 9,659,472 and the Google Patents family panels) rather than the '266's own front page. The roster in §3 is therefore the family record art, which for a no-new-matter continuation should be identical — but I have not verified it.
  2. The title/subject matter of US 5,942,978 (Shafer). It is the ISA's X reference, yet I did not retrieve a title I could verify. I have deliberately not invented one.
  3. The grounds asserted in IPR2019-01553 (Mobile Tech, Inc. et al. v. InVue Security Products Inc., filed Aug. 28, 2019; not instituted – merits). The petition's grounds would be the single best source for "most relevant prior art" in a litigation context, because a petitioner typically identifies the strongest § 102/§ 103 combinations. I could not retrieve the petition or the institution decision; its prior-art references should be pulled next if litigation-grade prior art is the goal.
  4. The independent-claim text and count (previously flagged; sourced from a secondary database, not the authoritative text). All § 102 claim mappings above inherit that uncertainty.
  5. The two district-court cases (D. Or. 3:18-cv-01720; S.D. Ind. 1:18-cv-02653) and any resulting invalidity contentions/institution-stage art — not retrieved.

6. Bottom line — the most relevant prior art

Ranked by likely pertinence to US 10,062,266:

  1. US 5,942,978 (Shafer), Aug. 24, 1999 — the ISA's X reference against the programming-station claim set; the leading single-reference § 102 candidate for the programming-station-centric claims.
  2. US 4,926,665 (Stapley), May 22, 1990 — "Remotely programmable key and programming means therefor"; the earliest and most conceptually direct antecedent of the programmed-key core, and the natural § 103 anchor when combined with a merchandise-alarm reference.
  3. US 6,677,852 (Landt), Jan. 13, 2004 and US 2002/0185397 (Sedon), Dec. 12, 2002 — the ISA's Y references; § 103 combinations rather than standalone § 102 anticipation.
  4. US 5,748,083 (Rietkerk), May 5, 1998 and US 5,793,290 (Eagleson), Aug. 11, 1998 — best pre-1999 art against the "merchandise-attached alarm sounds on integrity compromise" limitation.
  5. US 5,650,774 (Drori), Jul. 22, 1997 and US 4,980,671 (McCurdy), Dec. 25, 1990 — respectively the re-programmable-key and the timed-invalidation features.
  6. Bucket B only (June 27, 2011 date): Knox US 7,958,758 / 8,746,023 / 9,424,701, Brooks US 2007/0289342, Carl Zeiss US 2010/0023772 — relevant only to the CIP-added passive-lock/charging/inductive-transfer claims.

Two structural conclusions worth carrying forward: (i) the family's prior art is overwhelmingly pre-1999 EAS/theft-deterrent art, so the novelty of the '266 rests on the specific combination (programming-station-generated store-unique SDC + programmable key + timer/counter invalidation + merchandise alarm module) rather than on any single element; and (ii) the CIP splits the patent's claims across two effective dates (2005/2006 vs. 2011), which is the decisive fact for whether any post-2005 reference can be § 102 art at all.

Generated 9/30/2026, 4:14:48 AM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll research the prior-art references associated with this patent before building the § 103 analysis.

Let me retrieve the full cited prior-art list from the patent's front page (Justia) and the Google Patents citation section.

Let me pull the substance of the key third-party references cited on the patent's face.

Obviousness Analysis — U.S. Patent No. 10,062,266 B1 under 35 U.S.C. § 103

Builds on: the "Patent summary" and "Litigation summary" sections already generated. This section does not repeat the claim characterization, family chain, or litigation posture — it assumes them and extends them into a § 103 analysis.


1. Preliminary caveats (read before relying on anything below)

Three limitations on this analysis must be stated up front, because they materially affect confidence:

  1. I still do not have the authoritative claim text. As flagged in the earlier "Patent summary," the full text supplied for this patent stops inside the Detailed Description (mid-sentence in the FIG. 23/24 passage) and does not include the claims. The only claim characterization available is the secondary-source (RPX-derived) description of independent claims 1, 22, and 42. A rigorous § 103 opinion is claim-element-by-element; without the issued claim language this is necessarily a framework analysis, not a validity opinion. This limitation should be treated as significant, not boilerplate.

  2. The "Prior Art section" of the fetched Google Patents page was not machine-readable in the text I was given. The page text I received contained the "Prior art keywords" tags (security, programmable key, key, programmable, station) and the family/litigation data, but the "Patent Citations" / "Cited By" tables were not captured. I therefore reconstructed the cited-art universe from (a) the patent's front-page References Cited list as mirrored by Justia (https://patents.justia.com/patent/10062266) and (b) the Google Patents family/citation listings (e.g., https://patents.google.com/patent/US20100238031). Number, date, and inventor for each reference come from that front-page list; I could independently re-confirm the disclosure of only a few of them in this session.

  3. A conflation trap to avoid. Several search hits referenced U.S. Patent No. 10,785,266 and its IPR (IPR2022-00445 / related petitions discussing Law, Wood, and Jungck "packet security gateways"). Those documents repeatedly use the shorthand "the '266 Patent" — but that is 10,785,266, a networking/packet-security patent, not our 10,062,266. Do not import that art (Law/Wood/Jungck) into this analysis; it is irrelevant to a merchandise-security patent. Per the operating rule to read identifiers literally, these are two different patents.


2. Governing legal framework

  • Statute: Because every claim of the '266 patent traces to disclosure dated no later than the 2011-06-27 CIP (13/169,968) and ultimately to the 2005-12-23 provisional, the pre-AIA version of § 103(a) governs (no claim has an effective filing date on or after March 16, 2013). The critical date for § 102(b) statutory bars is therefore December 23, 2004, and for § 102(a)/(e) art, December 23, 2005 (invention/priority). Caveat: if any claim is later shown to rely on matter first added in a filing on/after March 16, 2013, AIA § 102/103 would apply to that claim — worth confirming, though the continuation chain makes this unlikely.
  • Standard: Graham v. John Deere factors; KSR Int'l v. Teleflex (motivation may flow from the problem to be solved, common sense, predictable variation, market demand, and design incentives; the "finite number of identified, predictable solutions" rationale).
  • Reference qualification: Each reference below must independently qualify as prior art (printed publication > 1 yr before filing, or a § 102(e) patent/application with a pre-critical-date filing). Several cited references issued after 2005 (e.g., the 2006–2010 patents) and can only be § 102(e) art if their underlying filings predate Dec. 23, 2005 — that must be checked reference-by-reference.

3. Level of ordinary skill in the art (POSITA)

A POSITA here would be a designer of retail loss-prevention / electronic-article-surveillance hardware, with a working knowledge of: (i) EAS and tethered merchandise-alarm modules; (ii) short-range wireless credential exchange (IR, RF, inductive); and (iii) electronic lock/access-control systems using powered keys or keycards. The patents cited on the '266 face are consistent with this profile — they cluster in G08B 13/14 (theft alarms for portable articles) and G07C 9/00 (electronic locks/keys), the same two classes the '266 patent itself carries.


4. The cited prior-art universe (grouped by technical contribution)

Group I — Electronic lock + powered/electronic key (the "hardware" half of the invention)

  • Davis (Videx, Inc.) family: U.S. 6,474,122 (Electronic locking system), 6,564,600, 6,604,394, 6,615,625, 6,718,806, 6,895,792. I independently re-confirmed 6,474,122: an electronic cylinder lock with a solenoid that imposes/removes a rotational restriction, i.e., an electrically-powered lock actuated by an electronic credential. (FreePatentsOnline mirror: https://www.freepatentsonline.com/6474122.html.) This family is the closest thing in the record to the '266 specification's powered lock embodiment (FIGS. 18–28 cabinet lock driven by motor/solenoid from the key's battery).

Group II — EAS / merchandise alarm modules with alarms triggered on integrity compromise (the "alarm" half)

  • Sedon et al., U.S. 7,053,774; Belden, Jr. et al., U.S. 7,385,522 / 7,629,895; Stillwagon, U.S. 6,525,644 (intelligent EAS tags / transaction data); Matsudaira, U.S. 6,531,961 (theft-prevention); Chung, U.S. 6,961,000; Irizarry, U.S. 6,512,457; Johnston et al., U.S. 6,819,252; Deconinck et al., U.S. 7,002,467 (wireless-linked alarm); Nguyen et al., U.S. 6,535,130. These provide the "security device attached to merchandise that sounds an alarm when a sense loop / tether / attachment is compromised" element, which is the admitted prior art in the '266 Background section itself.

Group III — Programmable / coded wireless keys and keyless entry (the "code exchange" half)

  • Tsui, U.S. 6,441,719; Okuno, U.S. 6,474,117; Anders et al., U.S. 7,102,509; Denison et al., U.S. 7,482,907 and 7,821,395. These relate to programmable/rolling-code wireless keys and coded authorization. (I could not re-verify the precise disclosures of the Anders and Denison references in this session; their dates place them in the programmable-key/access-control space and they should be verified before being relied on.)
  • Landt, U.S. 6,677,852 (RFID/EAS article-security lineage) — relevant to coded identification of protected articles. (Title/disclosure not re-verified this session.)
  • Knox Company electronic lock-and-key family (U.S. 7,958,758; 8,746,023; 9,424,701) and UTC Fire & Security, U.S. 9,670,694 (Restricted range lockbox) surfaced in the Google Patents "Cited By"/similar-art listing for this family; they are relevant to the time-/range-restricted credential concept but post-date the priority date and would require § 102(e) qualification.

Group IV — Time-limited / expiring credentials

  • The concept of a credential that self-invalidates after a period (the '266 "timer" feature) appears in the access-control art reflected by the Knox/UTC references and by Brooks, US 2007/0289342 (Electronic restraint system) and Carl Zeiss Meditec, US 2010/0023772 (one-time access code) in the "Cited By" listing. These are useful only for the timer dependent feature and only if they qualify as art.

5. Feature-to-reference mapping (independent claims 1 / 22 / 42 as characterized)

The table maps the characterized elements of independent claim 1 (claim 22 recites the same elements under the term "authorization station" plus a "disarm" framing; claim 42 is the method counterpart) to the cited art.

Claimed element (per earlier characterization) Primary reference(s) Notes
Programming/authorization station with a memory storing a security code Denison '907/„395; Anders '509; Knox family; any rolling-code/key-programming system Programming stations that write codes into keys were well known
Programmable key with a memory storing a security code Tsui '719; Okuno '117; Anders '509; Denison Programmable/rolling-code wireless keys
Security device attachable to merchandise, with an alarm that triggers on integrity compromise Sedon '774; Stillwagon '644; Matsudaira '961; Chung '000; Deconinck '467 — and the '266 patent's own admitted Background art This element is expressly conceded as old in the '266 Background
Key provides its security code to the station; code stored in station Denison/Anders; Davis challenge-response tokens Code-transfer-to-reader is conventional
Key wirelessly communicates with the station Tsui; Nguygen '130; Deconinck; Landt IR/RF credential exchange well known
Key authorized to control the device only if key code = station code Davis-family electronic locks; Denison; Anders; Landt This is a generic match-gate / challenge-response authorization
(Claim 22) authorizes disarm on match Same as above Disarm-on-valid-credential is the core of every EAS detacher/key
(Claim 42) method steps: provide code → store → compare → authorize Same as above Method mirrors the apparatus

Analytic consequence: the independent claims, as characterized, reduce to (a) an old EAS merchandise alarm + (b) an old programmable wireless key + (c) an old match-gate authorization. Each of (a)–(c) is independently old in the cited art. That is the classic KSR fact pattern.


6. Proposed obviousness combinations and motivations

Combination A — Davis (electronic lock/key) + an EAS merchandise alarm module (Sedon '774 / Stillwagon '644 / Matsudaira '961) + a programmable wireless key (Tsui '719 / Anders '509)

  • Covers: all elements of characterized claims 1, 22, and 42.
  • Motivation: Both fields are the same field (retail anti-theft hardware) and the same problem — preventing a thief or dishonest employee from using a stolen key to defeat a merchandise-protection device. Substituting a coded, reprogrammable credential (Tsui/Anders) for a mechanical/magnetic key in an EAS alarm module (Sedon/Stillwagon/Matsudaira) is the natural, predictable design choice — a "finite number of identified, predictable solutions." KSR expressly sanctions combining known elements to solve a known problem with predictable results.
  • Why a POSITA would look to Davis: Davis provides the powered lock (solenoid) that the '266 FIGS. 18–28 embodiment needs — i.e., the key supplies power to actuate the lock. Combining Davis's powered-lock actuation with an EAS alarm body and a programmable key yields the claimed system.

Combination B — EAS-coded tags (Stillwagon '644 / Landt '852 / Irizarry '457) + wireless keyless-entry coding (Tsui '719 / Okuno '117) + wireless alarm module (Deconinck '467)

  • Covers: the coded-article + wireless-credential + alarm combination; supports claim 1/22's "wireless communication" limitation and the dependent EAS-detector limitation.
  • Motivation: These references all concern matching a security code between a credential and a protected article and alarming on mismatch — the identical objective. Combining coded EAS (Stillwagon/Landt) with a wireless coded key (Tsui/Okuno) is a predictable aggregation of known functions.

Combination C — Base combination (A or B) + a time-/use-limited credential (Knox family; Brooks US 2007/0289342; UTC '694; Carl Zeiss US 2010/0023772)

  • Covers the timer dependent feature ("SDC invalidated after a predetermined period," e.g. 96 hours) and the activation counter feature.
  • Motivation: Auto-expiring access credentials and "expire-after-N-uses" tokens were known in access-control and metering arts. Applying a known self-expiration timer to a known programmable key to address the admitted problem of lost/stolen keys is a predictable mechanical application of an old technique — the classic KSR "arrange old elements with each performing the same function it had been known to perform."
  • Caveat: Whether any of these actually teaches key-side (as opposed to lock-side or system-side) expiration must be verified; the '266 timer is located in the key and invalidates the SDC in the key.

Combination D — Davis-powered-lock family + inductive/power-transfer art

  • Covers the dependent features of powering a "passive" lock from the key (electrical contacts or inductive transfer).
  • Motivation: Videx/Davis electronic locks are electrically actuated; transferring power from a portable credential to a lock (or, conversely, using inductive coupling for data/power) was routine in access-control and RFID/inductive-coupling art. Using a known inductive coil to convey power where a wired contact was used is a predictable substitution.

7. Motivation-to-combine analysis (KSR factors, applied)

  1. Same field of endeavor / analogous art. All cited references are from retail security, EAS, electronic locking, or coded access — squarely analogous under In re Bigio / KSR.
  2. Same problem. The '266 Background itself identifies the problem ("keys may be stolen … and used at the same store or at another store"). A POSITA confronting exactly that admitted problem would look to programmable/per-store codes and time-limited credentials — the predictable solutions.
  3. Predictable results / finite solution set. Replacing a fixed key with a programmable, code-validated key, and adding an auto-expiration timer to mitigate key theft, are the conventional, low-risk choices. KSR holds these obvious.
  4. Design incentive / market demand. The '266 specification concedes the commercial pressure (lost key liability, cost of many keys). Economic motivation is a recognized KSR rationale.
  5. Reasonable expectation of success. Each sub-combination is an aggregation of known components performing known functions; no unpredictable interaction is apparent on the face of the characterized claims.

8. Where a § 103 challenge is weaker — and the key real-world signal

  • The strongest independent-claim theory is the "mutual authentication" framing. Ironically, the independent claims (as characterized) recite that the key sends its code to the station and is authorized only on a match — i.e., a challenge-response / match-gate. That is more vulnerable than the specification's actual narrative (station generates a per-store random SDC → writes it to the key → key writes it into the device). If the claims read on generic mutual authentication, Davis-style challenge-response tokens and Denison/Anders make those claims quite exposed under § 103.
  • The dependent features are the real defensive core: (i) a randomly generated, store-unique SDC that "always remains with that programming station" (spec ¶ re: FIG. 1); (ii) in-key timer invalidation of the SDC; (iii) an activation counter that permanently kills the key; (iv) key-side power transfer to a passive device; (v) the master-key/employee-key dual-key architecture with the device recognizing both old and new codes after a rollover. None of these is clearly and fully taught by the references I could verify. A well-targeted § 103 challenge should attack the independent claims first and then try to bridge these dependents; the dependents are where the patent is strongest and where the "motivation" argument is thinnest.
  • Litigation/PTAB signal (non-dispositive): In IPR2019-01553 (Mobile Tech v. InVue, filed 2019-08-28) the Board denied institution on the merits ("Not Instituted – Merits" per Google Patents; "Institution Denied" per Patexia), challenging claims 1, 2, 3, 5–52, 54–56. A denial is not a merits ruling and creates no estoppel on the art actually presented, but it does indicate at least one panel did not find a reasonable likelihood that the art of record there rendered even the independent claims unpatentable. That is meaningful context and should temper any claim that these claims are plainly obvious. Sources: https://portal.unifiedpatents.com/ptab/case/IPR2019-01553; https://services.patexia.com/lawsuits/Mobile-Tech-Inc-et-al-v-InVue-Security-Products-Inc-id-128057.

9. Secondary considerations to test (Grahan factor 4)

If the patent owner wished to rebut these combinations, the available angles are: (a) long-felt need / failure of others — the admitted inability of the industry to prevent stolen-key reuse; (b) industry adoption — the very fact that InVue and Mobile Tech litigated extensively over this family (see the "Litigation summary") suggests commercial significance; and (c) unexpected results, e.g., the per-store randomness + in-key expiration cooperating so the key is useless both across stores and within the store after timing out. Any such argument must show nexus to the claimed subject matter (not merely to the commercial product).


10. Bottom line

  • On the characterized independent claims (1, 22, 42), a § 103 challenge is credible: the claims appear to recite a combination of (i) a known EAS merchandise alarm that alarms on integrity compromise, (ii) a known programmable wireless key, and (iii) a known code-match authorization — all predictable, motivated combinations under KSR, with a stated, admitted problem to be solved.
  • On the dependent features — per-store random SDC, in-key timer invalidation, activation counter, key-powered passive lock, and dual-key rollover — the cited record I could verify is insufficient on its face, and the 2019 PTAB denial is consistent with that.
  • This is a framework, not an opinion. To convert it into a defensible obviousness position you still need: (1) the issued claim text (currently absent from the authoritative source); (2) the actual disclosures of Anders '509, Denison '907/'395, Landt '852, and the Knox/UTC references (only dates/inventors confirmed here); and (3) a § 102(e) date check on each post-2005 reference.

Do not conflate this analysis with the 10,785,266 packet-security IPRs (Law/Wood/Jungck) that surfaced during research — that is a different patent.

Sources: https://patents.google.com/patent/US10062266B1/en; https://patents.justia.com/patent/10062266; https://www.freepatentsonline.com/6474122.html; https://services.patexia.com/lawsuits/Mobile-Tech-Inc-et-al-v-InVue-Security-Products-Inc-id-128057; https://portal.unifiedpatents.com/ptab/case/IPR2019-01553.

Generated 9/30/2026, 4:14:47 AM

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