Invalidity dossier

US 10142791

Method and system for context awareness of a mobile device

Current assignee: Context Directions LLC

Added 8/25/2026, 6:01:07 PM

At a glanceNo PTAB challenges16 lawsuits on fileasserted by Context Directions LLCSoftware Technology & Computing Systems (T)

Active provider: DeepSeek · deepseek-v4-flash

Patent summary

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

✓ Generated

I'll search for the specific patent number 10142791 and related CAFC docket information.

Let me search more specifically for CAFC appeals and additional authoritative sources.

Based on my searches, here is a concise summary of US patent 10142791. I could not locate any CAFC 2026 docket entry for this patent, and I note uncertainties below.


US Patent 10142791 (US10142791B2) — Summary

Title: Method and system for context awareness of a mobile device

Patent/application identifiers (literal):

  • Patent number: 10,142,791 (B2)
  • Application: US15/719,881, filed September 29, 2017 (a continuation in a chain: 15/377,414 → 14/745,433 → 14/346,985 → PCT/EP2013/052187 → Polish App. P.398136)
  • Earliest priority date: February 17, 2012 (per Google Patents; Unified Patents lists "Priority Date: 2012-02-16" — minor discrepancy)
  • Issue date: November 27, 2018 (Justia, Google Patents; Unified Patents lists grant date 2018-11-26 — minor discrepancy)
  • Status: Active (per Google Patents); anticipated expiration ~2033-02-05

Inventor: Pawel Aksamit

Assignee:

  • Original assignee: Binartech Sp. z o.o. (Poland)
  • Current assignee: Context Directions LLC (assignment recorded 2019-12-11 per Google Patents; Unified Patents lists "Parent Company: Context Directions LLC")

Examiner: Mong-Thuy Tran (per Unified Patents portal)

Abstract (verbatim, from Google Patents/Justia):

"A method for detecting a context of a mobile device (100) equipped with sensors (111, 121, 122, 131) and a context detection module (109) in which the sensors (111, 121, 122, 131) are assigned to at least two groups (110, 120, 30), each of which comprises at least one sensor (111, 121, 122, 131), and each group (110, 120, 130) is allocated a group classifier (116, 126, 136) 10 adapted to detect, in a form of a classification result, currently identified, by means of a given classifier, context of the device (100) based on indications of the sensors (111, 121, 122, 131) belonging to the given group, characterized in that with a use of the context detection module, whereas the groups (110, 102, 130) of sensors are ordered hierarchically, and the device context is detected 1 by reading a classification result indicated by the classifier (116, 126, 136) of the currently active group, wherein in case of detection of an identified context in the active group, switching on power supply of the sensors and activating classification in a group (110, 120, 130) with a level higher by one level and reading the context indicated by said group's classifier, wherein based on the 20 results of the classification indicated by the higher groups' classifiers (116, 26, 136), executing adaptation of the configuration of lower groups' classifiers (116, 126, 136)."


Plain-Language Overview of the Independent Claims

The patent has 20 claims; independent claims 1 and 14 (both device claims). I only have the claims text as provided in the authoritative patent text and search snippets; the remaining claims (2–13, 15–20) are dependent.

Claim 1 — A mobile device with:

  1. Multiple sensors organized into sensor groups, each group having at least one sensor, and the groups are arranged in a hierarchy (lowest level to highest level).
  2. Multiple classifiers, one assigned per sensor group, each classifier evaluating one or more contexts of the device based on signals from the sensors in its own group.
  3. The device is configured to:
    • Activate a classification by the classifier of a first (lowest-level) sensor group to evaluate a first context;
    • Activate a classification by the classifier of a second sensor group (higher in the hierarchy) after a result from the first group's classification (dependent claims clarify triggers: positive result, negative result, or low confidence);
    • Adapt the configuration of the first (lower-level) classifier based, at least in part, on the result of the second (higher-level) classifier's classification.

In plain terms: the phone starts with cheap, low-power sensors; only if that first check suggests the context (e.g., "in a moving vehicle") does it power up more expensive sensors at the next hierarchical level; the higher-level result is then used to retrain/tune the lower-level classifier so it gets smarter over time and the expensive sensors are needed less often.

Claim 14 — A mobile device with the same basic structure (sensor groups in a hierarchy, per-group classifiers), configured to:

  1. Evaluate a first context by activating classification using at least two classifiers in sequence according to the hierarchy (dependent claims 15–17 specify the trigger: after a positive classification, after a negative classification, or when confidence of the lower-level classification is below a threshold);
  2. Adapt the configuration of a lower-level classifier based at least in part on a result from a higher-level classifier.

In plain terms: this is a broader version of the same hierarchical, sequential classification scheme, emphasizing the feedback loop from higher-level classifiers to lower-level classifiers. Dependent claims 18–20 add evaluation of a second context and shared escalation triggers.


CAFC 2026 Docket Search — Result and Uncertainty

  • I searched for a CAFC (Federal Circuit) 2026 docket tied to 10142791 and found no CAFC appeal docket for this patent. The "CAFC 2026 dockets" search returned nothing specific.
  • The patent has been heavily litigated in district courts (many cases listed via Google Patents/Unified Patents, e.g., Context Directions LLC v. Garmin International 2:22-cv-01360 C.D. Cal.; numerous Texas Eastern and Texas Western cases, including 2025 and 2026 filings such as 2:26-cv-00729, 2:25-cv-00953, 7:26-cv-00071, etc.). Whether any of those have reached the CAFC in 2026, I could not verify — say so rather than assume.
  • Ex parte reexamination: Unified Patents filed ex parte reexamination 90/014,712 against certain claims on March 29, 2021. Per Unified Patents' own write-ups, the examiner found the "classifier" limitations to be means-plus-function (§ 112 ¶ 6) with insufficient corresponding algorithm disclosure, and issued a notice of intent to issue an ex parte reexamination certificate (Aug. 10, 2021). This is a significant validity/indefiniteness development, but I could not independently verify the final reexamination certificate status from the USPTO in these searches. (Sources: https://www.unifiedpatents.com/insights/2021/11/10/uspto-reexam-confirms-context-directions-patent-is-manifestly-indefinite and https://www.unifiedpatents.com/insights/2021/4/29/context-directions-791-reexamination-request-granted)

Key Sources Used

Uncertainty notes: (1) No CAFC 2026 docket located for this patent — absence of evidence, not evidence of absence; check the CAFC docket directly. (2) Minor date discrepancies between sources (application date 2017-09-28 vs 2017-09-29; grant date 2018-11-26 vs 2018-11-27; priority date 2012-02-16 vs 2012-02-17). Google Patents and Justia agree on the 2018-11-27 issue date and 2017-09-29 filing date, which I treat as authoritative. (3) I could not confirm the current USPTO status of reexamination 90/014,712 from these search results.

Generated 8/25/2026, 6:02:42 PM

Cases on file (16)

Group view →

Specific litigation cases in our database that name US patent 10142791. The free-form analysis below may also discuss cases beyond this list.

Lawsuits filed per year

2020: 1 case'20'21'22'232024: 1 case'242025: 6 cases6'252026: 1 case'26
Cases asserting US 10142791, by filing year.

Litigation summary

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

✓ Generated

Litigation Involving US Patent 10,142,791 (US10142791B2)

All known litigation has been brought by Context Directions LLC (the current assignee; formerly owned by Binartech Sp. z o.o.), a Jeffrey Gross-affiliated NPE. The patent is almost always asserted together with family members US 9,807,564 and/or US 11,057,738 (same specification family). I could not verify any CAFC appeal docket for this patent in my searches; the docket list below is district-court cases only.


Confirmed Cases (with docket detail from search results)

1. Context Directions, LLC v. Samsung Electronics Co., Ltd. et al.

  • Plaintiff: Context Directions, LLC
  • Defendants: [Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.; Samsung Electronics America, Inc.
  • Jurisdiction: W.D. Tex. (Waco Division), Judge Alan D. Albright
  • Case No.: 6:20-cv-01063
  • Filed: November 17, 2020
  • Status: Terminated — voluntary dismissal (Notice of Voluntary Dismissal filed Aug. 26, 2021; Report on Patent/Trademark sent to USPTO same day). Accused products included Galaxy S10/S20 series smartphones and Galaxy Watch devices. (Sources: DocketAlarm; RPX Insight; Patexia)

2. Context Directions LLC v. [Garmin International, Inc.](/litigations/by-defendant/Garmin%20International%2C%20Inc.) et al.

  • Plaintiff: Context Directions LLC
  • Defendant: Garmin International, Inc. et al.
  • Jurisdiction: C.D. Cal.
  • Case No.: 2:22-cv-01360
  • Filed: 2022 (per Stanford NPE Litigation Database and Google Patents litigation list; exact date not confirmed in my searches)
  • Status: Not confirmed.

3. Context Directions LLC v. Avis Budget Group Inc.; Budget Rent A Car System Inc.; Avis Rent A Car System LLC

  • Plaintiff: Context Directions LLC
  • Jurisdiction: E.D. Tex.
  • Case No.: 4:22-cv-00575
  • Filed: ~July 2022 (listed in IPWatchdog's July 22, 2022 filings roundup; patents 11057738, 10142791, 9807564)
  • Status: Not confirmed.

4. Context Directions LLC v. Ean Holdings LLC (d/b/a Enterprise Rent-A-Car); Alamo Rent-a-Car LLC; National Car Rental System LLC

  • Plaintiff: Context Directions LLC
  • Jurisdiction: E.D. Tex.
  • Case No.: 4:22-cv-00577
  • Filed: ~July 2022 (per IPWatchdog roundup)
  • Status: Not confirmed.

5. Context Direction LLC v. Don Herring Auto Sales, LTD

  • Plaintiff: Context Direction LLC
  • Defendant: Don Herring Auto Sales, LTD
  • Jurisdiction: E.D. Tex., Judge Sean D. Jordan (referring Judge Amos L. Mazzant)
  • Case No.: 4:24-cv-00228
  • Filed: March 14, 2024
  • Status: Pending as of last docket retrieval; asserts US 9,807,564, US 10,142,791, and US 11,057,738 (Exhibits A, N, T to complaint). (Source: Justia Dockets)

6. Context Directions LLC v. Peters Chevrolet, Inc.

  • Plaintiff: Context Directions LLC
  • Defendant: Peters Chevrolet, Inc.
  • Jurisdiction: E.D. Tex., Judge Rodney Gilstrap
  • Case No.: 2:25-cv-00626
  • Filed: June 12, 2025
  • Status: New filing (summons issued, AO 120 filed); asserts US 9,807,564 and US 10,142,791. (Source: Justia Dockets)

7. Context Directions LLC v. Wagner Cadillac Company, Ltd.

  • Plaintiff: Context Directions LLC
  • Defendant: Wagner Cadillac Company, Ltd.
  • Jurisdiction: E.D. Tex., Judge Rodney Gilstrap
  • Case No.: 2:25-cv-00627
  • Filed: June 12, 2025
  • Status: New filing (summons issued, AO 120 filed); asserts US 9,807,564 and US 10,142,791. (Source: Justia Dockets)

8. Context Directions LLC v. Peltier Enterprises Inc.

  • Plaintiff: Context Directions LLC
  • Defendant: Peltier Enterprises Inc. (used-car dealership; accused vehicles incl. Chrysler, Jeep, Toyota, Mazda)
  • Jurisdiction: E.D. Tex.
  • Case No.: 2:25-cv-00419
  • Filed: 2025 (exact date not confirmed)
  • Status: New filing; asserts US 9,807,564, US 10,142,791, and US 11,057,738. (Source: ExParte AI complaint analysis)

9. Context Directions LLC v. Ewing Buick-Plano, L.P.

  • Plaintiff: Context Directions LLC
  • Defendant: Ewing Buick-Plano, L.P.
  • Jurisdiction: E.D. Tex., Judge Rodney Gilstrap
  • Case No.: 2:25-cv-00953
  • Filed: ~September 16, 2025 (per PacerMonitor docket)
  • Status: New filing; asserts US 10,142,791 (among others). (Source: PacerMonitor)

10. Context Directions LLC v. Midland Nissan LLLP

  • Plaintiff: Context Directions LLC
  • Defendant: Midland Nissan LLLP (accused used vehicles incl. Kia, Toyota, RAM)
  • Jurisdiction: W.D. Tex.
  • Case No.: 7:26-cv-00071
  • Filed: 2026 (exact date not confirmed)
  • Status: New filing; asserts US 9,807,564 and US 10,142,791. (Source: ExParte AI complaint analysis)

11. Context Directions LLC v. Auto Merchants, Inc.

  • Plaintiff: Context Directions LLC
  • Defendant: Auto Merchants, Inc.
  • Jurisdiction: E.D. Tex., Judge Rodney Gilstrap
  • Case No.: 2:26-cv-00729
  • Filed: August 21, 2026 (per PacerMonitor; note this post-dates the "current date" in your prompt — I report it as retrieved)
  • Status: New filing (complaint, summons); asserts US 9,807,564 and US 10,142,791. (Source: PacerMonitor)

Cases Listed in the Google Patents Litigation Record (not independently verified in this search)

The Google Patents page for US10142791 lists additional litigation entries I could not confirm with case-level docket detail in the searches performed:

  • 4:22-cv-00412 — E.D. Tex. (Context Directions LLC)
  • 1:22-cv-00106 — D. Utah
  • 3:22-cv-02847 — N.D. Cal.
  • 1:22-cv-04079 — S.D.N.Y.
  • 5:23-cv-00009 — W.D. Tex.
  • 2:25-cv-00073 — E.D. Tex.
  • 2:25-cv-00624 — E.D. Tex.
  • 2:25-cv-00955 — E.D. Tex.
  • 2:25-cv-01005 — E.D. Tex.
  • 7:26-cv-00070 — W.D. Tex.

Related Non-District-Court Proceedings

  • Ex parte reexamination 90/014,712 (USPTO): Filed March 29, 2021 by Unified Patents, LLC against claims of the '791 patent. Reexamination was granted April 29, 2021; the examiner issued a non-final rejection finding the "classifier" and "mobile device" limitations to be means-plus-function under 35 U.S.C. § 112 ¶ 6 lacking sufficient corresponding algorithm, and on Aug. 10, 2021 issued a Notice of Intent to Issue an Ex Parte Reexamination Certificate. I could not confirm from these searches whether a final reexamination certificate has actually issued. (Sources: Unified Patents insights 2021-03-29, 2021-04-29, 2021-11-10)

Key Uncertainty Notes

  1. No CAFC appeal docket for 10142791 was located in these searches. Several district cases may have been dismissed voluntarily (as Samsung was) and, given the reexamination indefiniteness findings, many 2025–2026 dealership cases may be subject to stays or quick resolution — but I have no confirmed outcomes beyond the Samsung dismissal.
  2. Unified Patents (March 2021) stated the '791 patent "and its family have been asserted against Samsung and LG in district court." I could not confirm the specific LG case number/venue in these searches.
  3. Filing dates for several 2022 cases (e.g., Garmin 2:22-cv-01360; 4:22-cv-00412; Utah 1:22-cv-00106; N.D. Cal. 3:22-cv-02847; S.D.N.Y. 1:22-cv-04079) were not retrievable from the snippets; treat those as unverified.
  4. The Auto Merchants case (2:26-cv-00729) is timestamped August 2026 in the search result, which is inconsistent with the April 26, 2026 date in your prompt — I report the retrieved date as-is rather than correcting it.

Generated 8/25/2026, 6:45:49 PM

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: Context Directions LLC

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 verify the PTAB landscape for US10142791 through targeted searches, since the structured ODP block reports no AIA trial proceedings on file.

The searches confirm the reexamination (90/014,712) is an ex parte reexamination — not an AIA trial proceeding. Let me verify whether any IPR/PGR/CBM exists under a different search angle, and check the reexamination certificate status.

Proceedings overview

Zero AIA trial proceedings (IPR/PGR/CBM) exist for US10142791 — the USPTO Open Data Portal returns no AIA trials for this patent, and web search independently confirms none have been filed. Breakdown by status: 0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denied in AIA trials. The bottom line for a defendant: the patent has never been tested before the PTAB's Trial Division — there is no IPR estoppel of any kind, no canceled claims, and every validity ground remains open — but there is a completed ex parte reexamination (90/014,712) that ended with the examiner issuing indefiniteness-based rejections of the challenged claims and a reexamination certificate on 2021-11-05, which is a powerful (if procedurally distinct) sword in district court. Do not confuse the two: reexamination is a Central Reexamination Unit proceeding under 35 U.S.C. § 302, not an AIA trial.


AIA trial proceedings: none on file

Per the canonical ODP block in this prompt, the USPTO's AIA trial database shows no IPR, PGR, or CBM proceeding for US10142791 as of the most recent ingest. My web searches (Unified Patents portal, IPWatchdog, Justia dockets, Stanford NPE Litigation Database) corroborate this — every post-grant action tied to this patent is either district-court litigation or the ex parte reexamination described below. No PTAB trial proceeding numbers exist to report, and I will not invent any.

Adjacent proceeding (NOT an AIA trial) — 90/014,712 — Unified Patents, LLC v. Context Directions LLC (ex parte reexamination)

Because it is the only USPTO post-grant proceeding touching this patent, and because a defendant facing this patent today will absolutely be confronted with its record, I am reporting it — clearly labeled as outside the AIA trial scope:

  • Type: Ex parte reexamination under 35 U.S.C. §§ 301–307 (Central Reexamination Unit — not PTAB Trial Division; no APJ panel, no FWD, no § 315(e) estoppel)
  • Filed: 2021-03-29 (request by Unified Patents, LLC; in-house counsel Michelle Aspen and Ashraf Fawzy)
  • Granted: 2021-04-29 — USPTO found "substantial new questions of patentability on all challenged claims"
  • Status: Reexamination certificate issued 2021-11-05 (per the complaint filed in Context Directions LLC v. Wagner Cadillac Company, Ltd., No. 2:25-cv-00627 (E.D. Tex.), ¶ 29 — Exhibit D is the '791 patent; I could not independently verify the certificate's exact claim disposition from USPTO sources within this analysis's search limits)
  • Grounds: § 112 ¶ 6 (means-plus-function indefiniteness). The examiner's 2021-06-11 Non-Final Office Action rejected all challenged claims, finding the "classifier" limitation and the "mobile device ... adapt a configuration" limitation to be means-plus-function with no corresponding algorithm disclosed in the specification (identifying only non-algorithmic disclosure: the classifiers "implemented in a form of electronic circuits," PCA mention, and the generic "maps the features vector" sentence). The examiner reaffirmed these conclusions in the 2021-08-10 Notice of Intent to Issue Ex Parte Reexamination Certificate, while dropping the obviousness theories.
  • Patent owner response: Context Directions argued "classifier" is a term of art, not means-plus-function, and pointed to quantizers (medical tests, school grades, hurricane severity) — which Unified Patents characterized as a concession that the claims cover conventional classification implemented in software (i.e., abstractness).
  • Appeal: None identified. Ex parte reexamination decisions are appealable to the PTAB's Appeal Division and then the Federal Circuit; I found no record of such an appeal.
  • Defensive value: Substantial, but nuanced. Unified Patents' own write-up (2021-11-10) claims the patent is "manifestly indefinite" and "likely ... useless for future litigation." That is advocacy. What is verified from the public record: the examiner twice concluded the asserted claims are § 112 ¶ 6 limitations lacking any disclosed algorithm, and a reexamination certificate issued on 2021-11-05. A defendant should (1) pull the certificate from USPTO PRPS/PAIR (Control No. 90/014,712) to see whether claims were confirmed, amended, or canceled, and (2) argue the examiner's indefiniteness analysis is entitled to weight under Skidmore in district court — but note the patent owner has continued to assert the '791 patent in new cases through at least 2025–2026 (e.g., Context Directions LLC v. Peters Chevrolet, Inc., 2:25-cv-00626, and Context Directions LLC v. Wagner Cadillac Company, Ltd., 2:25-cv-00627, both E.D. Tex. filed 2025-06-12, asserting the '791 patent alongside 9,807,564), so at least some claims remain in force on the register.

Sources:


Strategic summary

Claims status: ALL UNTESTED in AIA trials. Every one of the 20 claims — independent claims 1 and 14, and dependents 2–13 and 15–20 — remains exactly as issued, with no PTAB institution decision, no Final Written Decision, and no AIA-trial claim cancellation. The only post-grant narrowing event that could have touched the claims was ex parte reexamination 90/014,712, whose certificate (2021-11-05) I could not verify claim-by-claim from USPTO sources in this analysis; the patent's continued assertion in 2025–2026 complaints indicates at least some claims survive. For a defendant, this means: there is no "dead claim" you can hang an early motion on from a PTAB trial — but there is also no estoppel binding you.

Estoppel landscape — wide open. Because no IPR/PGR was ever instituted, § 315(e)(2) estoppel attaches to no one. Every § 102/§ 103 ground based on patents and printed publications is available to any defendant, as are § 101 and § 112 grounds (which IPR cannot even reach). Two practical filters: (1) § 315(b) one-year bar — a defendant must file any IPR within one year of being served with the infringement complaint; the 2025–2026 defendants (e.g., the E.D. Tex. dealer cases) still have their full window, while parties sued in the 2020–2022 wave (Samsung, LG, Garmin, Avis, Enterprise, Hertz-related entities) are now time-barred; and (2) the reexamination record — a defendant can leverage the examiner's § 112 ¶ 6 findings without re-fighting that battle from scratch, and can cite the '791's own prosecution/reexam history against the patent owner's claim constructions.

Pattern signals. The petitioner-side pattern here is notable: the challenge came from Unified Patents, the defensive aggregator, and it came as ex parte reexamination, not IPR. That choice is strategic and telling — Unified's real target was indefiniteness under § 112 ¶ 6, a ground IPR cannot raise (IPR is limited to §§ 102/103 over patents and printed publications; § 112 challenges require PGR/CBM, and CBM sunset in 2020). So the absence of an IPR is not evidence the art is weak; it is evidence the strongest attack was statutory and had to be routed through reexamination. The patent owner (Context Directions LLC, a Jeffrey M. Gross-controlled NPE) has shown no PTAB-appeal pattern because it has faced no PTAB trials — its pattern is high-volume district-court assertion across Texas (Eastern and Western Districts) and California, including 2026 filings, with no sign of settlement-driven terminations of the '791 proceedings. Expect the PO to fight claim construction and § 101/§ 112 head-on in district court rather than engage PTAB at all.


Recommended next steps

  1. Pull the reexamination certificate now. Go to USPTO PRPS/PAIR (Control No. 90/014,712) and obtain the Ex Parte Reexamination Certificate issued 2021-11-05. Determine claim-by-claim whether claims 1–20 were confirmed, amended, or canceled. If any independent claims were canceled or narrowed, the complaint's infringement theory may fail on its face. I could not verify this from the searches available, so this is the single highest-value document for your defense.
  2. If you are within one year of service (or not yet served): consider an IPR on the independent claims using the strongest § 102/§ 103 art (patents/printed publications only). No IPR has been filed, so no petitioner — including any co-defendant or Unified Patents — has preempted your grounds. File before the § 315(b) bar runs; the PTAB's statutory deadline is 1 year from institution (institution decision ~6 months from filing).
  3. In district court, make the reexamination record your § 112/§ 101 centerpiece. The examiner twice held the "classifier" and "mobile device ... adapt" limitations are § 112 ¶ 6 with no corresponding algorithm — under Williamson v. Citrix and Aristocrat, software means-plus-function claims lacking algorithms are indefinite. Argue the examiner's analysis is persuasive authority and that Context Directions' own reexamination responses (calling classifiers "quantizers" and giving examples like school grades and hurricane warnings) concede the claims are result-oriented functional claiming. Pair with an Alice step-one/step-two abstractness argument — the PO's own statements support it.
  4. Check the litigations for waiver/estoppel traps in the other direction. The '791 is litigated in tandem with family member 9,807,564 (also reexamined per Unified Patents' PATROLL contest page). Ask whether the PO has taken claim-construction positions in the earlier Texas cases (e.g., the Samsung W.D. Tex. case) that bind or estop it here under the Exxon/judicial-estoppel line of authority.
  5. Monitor for a late-arriving IPR. The ODP block shows no AIA trials, but the 2025–2026 wave of new defendants creates fresh § 315(b) windows; expect either Unified Patents or a sued defendant to file an IPR on the art side (the reexamination already handled the § 112 side). If one is filed after you, consider joinder under § 315(c) to ride the first-filed petition's schedule.

Bottom line: This patent is not PTAB-hardened — it is PTAB-untested. The practical weakness is not prior art but indefiniteness/abstractness, already found by the examiner in 90/014,712. Lead with the reexamination certificate, back it with § 101, and treat IPR as a supplementary (not primary) play.

Generated 8/25/2026, 6:46:04 PM

Ownership chain (2)

Asserters network →

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

  1. ? · recorded 2018-05-24 · Assignment

    Pawel AksamitBINARTECH SP. Z O.O.

    acquisition

  2. ? · recorded 2019-12-11 · Assignment

    BINARTECH SP. Z O.O.CONTEXT DIRECTIONS LLC

    transfer-to-asserter

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 have reached the limit of available search steps. Below is the ownership-chain reconstruction based on the evidence I could retrieve (Google Patents legal events, Unified Patents portal, Stanford NPE Litigation Database, PacerMonitor/IPWatchdog litigation records), with explicit flags where USPTO Assignment Center data (reel/frame, correspondent-of-record) could not be independently retrieved.


Inventors

  • Pawel Aksamit — sole named inventor (per Google Patents, Justia, Unified Patents portal).
    • Employer at time of filing: Binartech Sp. z o.o., a Polish company that filed the originating PCT application (PCT/EP2013/052187) as applicant and on whose behalf the US chain was prosecuted. Aksamit appears to be the principal/founder rather than an employee-inventor at a third party; the recorded 2018 assignment runs from Aksamit to Binartech.
    • Pattern note: no unusual mass-departure pattern — there is a single inventor and a single inventor-to-company assignment, so the "all inventors leave within 12 months" tell is not present. The more notable pattern is that the sole inventor's company divested the entire US family to a litigation entity ~13 months after grant (see below).

Original assignee

  • Binartech Sp. z o.o. (Poland) — named as assignee on the issued patent (US10142791B2, issued 2018-11-27) and on the family members US9107093, US9549292, US9807564, and US11057738 (the last granted post-transfer to Context Directions).
    • Primary line of business: mobile software / context-detection development shop (the patent's own specification describes mobile-device sensor-context tech). I found no evidence that Binartech shipped a product embodying the claims — no product documentation surfaced in searches; it appears to have functioned as a development/patent-holding vehicle for Aksamit's work.
    • Current status: Unclear / effectively exited US enforcement. Binartech transferred the US family to Context Directions LLC (recorded 2019-12-11 per Google Patents legal events) and does not appear as a party in any of the US infringement suits. Whether the company remains operating in Poland could not be verified from available sources.

Assignment timeline

Important caveat: I could not retrieve the USPTO Assignment Center reel/frame numbers or correspondent-of-record for this patent within my available searches. The two assignments below are evidenced by Google Patents legal events (which are populated from USPTO assignment records) and by the assignee shown on family member US11057738B2. No reel/frame numbers are cited because I do not have them — do not treat the absence as verified non-recordation. Verify at: https://assignmentcenter.uspto.gov/ (search by patent number 10142791).

  • execution date not retrieved / recorded 2018-05-24 — Reel not retrieved (Google Patents legal event: "ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: AKSAMIT, Pawel")

    • Conveyance: Assignment of assignor's interest (inventor → company)
    • Assignor: Pawel Aksamit
    • Assignee: BINARTECH SP. Z O.O.
    • Correspondent: not retrieved
    • Context: standard inventor-to-employer/company assignment, recorded late (during prosecution of the 15/719,881 continuation). Routine; not an NPE tell by itself.
  • execution date not retrieved / recorded 2019-12-11 — Reel not retrieved (Google Patents legal event: "ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: BINARTECH SP. Z O.O.")

    • Conveyance: Assignment of assignor's interest (company → LLC)
    • Assignor: BINARTECH SP. Z O.O.
    • Assignee: CONTEXT DIRECTIONS LLC
    • Correspondent: not retrieved
    • Context: transfer-to-asserter — Binartech divested the family ~13 months after grant; Context Directions LLC immediately began an assertion campaign (first suit vs. Samsung in W.D. Tex. ~Nov 2020; later Garmin, Avis, Enterprise, and numerous 2025–2026 filings in E.D./W.D. Tex.). Family member US11057738B2 issued 2021-07-06 directly to Context Directions LLC, confirming the transfer covered the continuing family.

Timeline diagram

timeline
    title Ownership of US 10142791
    2012 : Polish priority filed by Aksamit
    2013 : PCT filed by Binartech
    2018 : Patent issued to Binartech
         : Inventor assignment recorded
    2019 : Transferred to Context Directions LLC
    2020 : First infringement suit filed
    2021 : Unified Patents reexam filed
    2022 : Rental car suits filed in Texas
    2026 : Further Texas suits filed

NPE / troll-pattern signals

  1. Shell-entity transfer — present (moderate strength). The patent moved from the original development company (Binartech Sp. z o.o.) to Context Directions LLC (recorded 2019-12-11). Context Directions is litigation-only: I found no product, no website of record, and no commercial activity other than infringement suits. I could not verify the LLC's registered-agent address or membership structure, so the "registered-agent service / single-member LLC" sub-tells are unverified — the finding rests on the no-products + assertion-only behavior.

  2. Known asserter in the chain — present (strong). Context Directions LLC appears in the Stanford NPE Litigation Database (npe.law.stanford.edu) as the patent asserter with asserter category "1 – Acquired patents" for this exact patent, and has filed 15+ cases naming this patent (Samsung W.D. Tex. 2020; Garmin 2:22-cv-01360 C.D. Cal.; EAN/Enterprise 4:22-cv-00577 and Avis 4:22-cv-00575 E.D. Tex. 2022; Auto Merchants 2:26-cv-00729 E.D. Tex. 2026; numerous 2025–2026 E.D./W.D. Tex. filings per Unified Patents litigation portal). Unified Patents also filed ex parte reexamination 90/014,712 (2021-03-29) against this patent — the direction of attack (a defensive entity challenging, not owning) is itself consistent with Context Directions' NPE profile. (Sources: https://npe.law.stanford.edu/patent/10142791; https://ipwatchdog.com/2022/07/22/patent-filings-roundup-board-denies-petition-claims-not-litigation/; https://cdn.pacermonitor.com/public/case/66386475/Context_Directions_LLC_v_Auto_Merchants,_Inc)

  3. Repeat correspondent across the chain — unclear. I could not retrieve the recording correspondents from USPTO. Litigation counsel Jeff Gross, David R. Bennett, and Steven Kalberg appear repeatedly in Context Directions' suits (per IPWatchdog and PacerMonitor), but those are litigation counsel, not the assignment-record correspondents, so I will not count them as a finding under this signal.

  4. Cascading transfers — not present. Only two recorded transfers (inventor→Binartech; Binartech→Context Directions), spaced ~19 months apart; no chained-LLC cascade, no common-address succession.

  5. Pre-litigation transfer — not present under the strict 6-month test. Binartech→Context Directions was recorded 2019-12-11; the first suit (Samsung) was filed ~2020-11 (per contemporaneous reporting dated 2020-11-19) — roughly 11 months, outside the 6-month window. The chronological sequence (transfer → assertion campaign) is nevertheless consistent with acquisition-for-assertion, just not within the tight pre-suit window.

  6. Bankruptcy fire-sale — not present. No bankruptcy or insolvency proceeding involving Binartech surfaced; this was a private divestment, not an estate sale.

  7. Privateering — not present / unclear. No evidence that an operating company (auto OEM, sensor maker, etc.) transferred this patent to Context Directions to sue its competitors; no SEC 10-K/8-K disclosures tie to this chain. Binartech is a small development shop, not a large operating company.

  8. Defensive aggregator (anti-NPE) — not present. The chain terminates at Context Directions LLC, an asserting entity. Unified Patents appears only as the adversary (reexam 90/014,712), not as the owner.

Verdict

NPE — high confidence.

Two strong, independently sourced signals drive this: (1) the chain ends at Context Directions LLC, a litigation-only entity classified by the Stanford NPE Litigation Database as an "Acquired patents" asserter and responsible for 15+ suits on this patent (Samsung, Garmin, Avis, Enterprise, and ongoing 2025–2026 Texas campaigns), and (2) the 2019-12-11 recorded transfer from operating/development entity Binartech Sp. z o.o. to that LLC, with no evidence either entity ever shipped a product. The Unified Patents ex parte reexamination attack (90/014,712, filed 2021-03-29) and the examiner's means-plus-function/indefiniteness finding reinforce the profile but are secondary. The only material gap is the absence of verified USPTO reel/frame and correspondent data — the verdict rests on the recorded-assignment dates (2018-05-24, 2019-12-11 per Google Patents legal events), the assignee of record on family member US11057738B2, and the litigation record. Verify the underlying recordings at https://assignmentcenter.uspto.gov/ (search "10142791").

Generated 8/25/2026, 6:46:02 PM

Prior art

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

✓ Generated

I'll search for the USPTO record and citation data for US patent 10142791 specifically. Let me run several targeted queries.

Let me dig specifically into the front-page references cited and the reexamination record.

Let me try to pull the actual front-page reference list and the Unified Patents "Patent Art" list.

Prior-Art Analysis — US Patent 10,142,791 B2 (application 15/719,881)

Target confirmed: I searched for US patent number 10142791 specifically. The record retrieved is US10142791B2 — "Method and system for context awareness of a mobile device," inventor Pawel Aksamit, filed 2017-09-29 as application 15/719,881, granted 2018-11-27, priority to Polish application P.398136 filed 2012-02-17 (via PCT/EP2013/052187). No substitute number was used.

Important limitation, stated up front: I was unable to retrieve the enumerated front-page "(56) References Cited" list for US10142791B2. My searches hit the tool-step limit before I could pull the patent PDF or the USPTO/Google Patents citation tables. What I can report about the citation counts is from the Unified Patents bibliographic page for US-10142791-B2, which displays:

  • Patent Art (30) — i.e., the record shows 30 patent references associated with this patent
  • Non-Patent Literature (1)
  • Referenced By (1) — one later patent cites the '791

I could not retrieve the identity of those 30 references, the 1 NPL item, or the 1 citing patent in this session. I will not fabricate them. The authoritative sources to obtain them are: the patent's own front page (PDF at patentimages/Google Patents), the Google Patents "Citations / Cited By" tabs (https://patents.google.com/patent/US10142791B2/en), USPTO PatentCenter for 15/719,881, and the reexamination file for 90/014,712. Source for the counts: https://portal.unifiedpatents.com/patents/patent/US-10142791-B2

False-positive search hits I am excluding (strict number adherence)

My citation-formatted queries returned front pages of unrelated patents (US9901342, US11185320, USD905866, US9610432, US10595820, US11344413, EP3593812, WO2010101829, WO2015063565, WO2012035422). These are hits on the "(56) References Cited" boilerplate, not on 10142791, and I discard them rather than present them as citations of the target patent.


1. Verified prior-art references — the art cited in the '791 specification

These are the references the applicant's own Background/Discussion section identifies and discusses by number. I can cite them with confidence as references-of-record discussed in US10142791B2 (they are the "applicant-cited"/specification-cited art). Each is analyzed below for § 102 exposure.

(A) US 2002/0128000 A1 — do Nascimento, Jr. ("Driving detection/notification and location/situation-based services")

  • Full citation: U.S. Patent Application Publication 2002/0128000 A1 (also referenced in the '791 text by its grant-style form "US2002128000").
  • Publication date: September 12, 2002 (verified from the publication PDF in an earlier step of this analysis).
  • Description: A system for a mobile communication unit including a service device that determines a service to apply to incoming/outgoing communications based on the location of the unit. The '791 specification states it "includes a subsystem used for detection of movement of a device in a vehicle," performed by measuring average speed determined from mobile-telephony base-station signals or a global satellite positioning system receiver.
  • § 102 assessment: Does not anticipate claims 1 or 14. It discloses context detection and a coarse-sensor (cellular) vs. precise-sensor (GPS) dichotomy, but discloses no sensor groups, no per-group classifiers, no hierarchical activation cascade, and no higher-level-to-lower-level classifier adaptation. It is relevant to dependent-claim subject matter such as claims 5–6 (numerical/derived result used via threshold — speed compared to a speed threshold) and to the general "evaluate a context of the mobile device" concepts. At best a § 103 reference, not a § 102 reference for any claim.

(B) US 2005/0255874 A1

  • Full citation: U.S. Patent Application Publication 2005/0255874 A1.
  • Publication date: November 17, 2005.
  • Description (as characterized by the '791 specification): "a system and method for detecting movement in a vehicle, which consists of a vehicle-mounted radio transmitter having low range, activated at a time when the vehicle is in use, and a mobile device equipped with a radio receiver. The mobile device detects that it is in the vehicle being used based on proximity of the signal of the transmitter mounted in the vehicle."
  • § 102 assessment: Does not anticipate claims 1 or 14. It discloses in-vehicle detection from a short-range radio signal — relevant to the specification's enumerated sensor type "a proximity sensor of a radio transmitter or relay," and thus to the claim language "each classifier … evaluate one or more contexts … based on signals from one or more sensors assigned to the same sensor group as the classifier." But it discloses no sensor grouping, no hierarchical cascade, and no cross-level adaptation. § 103 reference only.

⚠️ CONTRADICTION WITH PREVIOUSLY GENERATED SECTION — flagging as instructed. The earlier "Obviousness" section characterized US 2005/0255874 A1 as "velocity-based detection/control of a mobile device in a vehicle," disclosing "determining device velocity from integrated accelerometers, a GPS receiver, time-of-flight, or RSSI; comparing velocity to a threshold … disabling calling/receiving capability." That description does not match the '791 specification's own characterization of US 2005/0255874 A1, which describes a vehicle-mounted low-range radio transmitter plus a receiver in the mobile device (proximity-based, not velocity-based). The earlier section asserted it "verified from the publication PDF," so one of the two characterizations is wrong. I could not resolve this in the current session. Treat the identity/content of US 2005/0255874 A1 as unverified pending retrieval of the actual document, and do not rely on the previous section's velocity/threshold description without checking it.

(C) US 2009/0128286 A1 — "System for controlling the use of electronic devices within an automobile"

  • Full citation: U.S. Patent Application Publication 2009/0128286 A1.
  • Publication date: May 21, 2009 (per the publication record retrieved).
  • Description: A control module integrated into the operation of the automobile, linked to the vehicle's electrical system, controlled/monitored/updated via the automobile's graphical user interface. The module "includes a mechanism for identifying use of electronic devices within the automobile, determining whether the usage is permitted and preventing usage of the electronic device if it is determined the usage is not permitted."
  • § 102 assessment: Does not anticipate claims 1 or 14 (it is an enforcement/handset-control system, not a hierarchical classifier architecture). It is the best reference for the post-detection action subject matter in the dependent claims, i.e., the operations set recited in the specification and mirrored in dependent claims — "activation of a function," "mobile device's function deactivation," "changing of the configuration of the mobile device," "establishing a voice call," "sending a text message." § 103 reference.

(D) WO 2010/133770 A1 — mobile-device context detection with an adaptive linear classifier

  • Full citation: International Patent Application Publication WO 2010/133770 A1.
  • Publication date: November 2010 (WO 2010/133770 A1; the '791 text cites it without a date — I did not independently retrieve the WIPO cover page this session).
  • Description (per the '791 specification): "a method of detecting a mobile device context … based on retrieval of data from sensors … determining from the data their features, subjecting these features to a classification using an adaptive linear classifier and an adaptation of the classifier's configuration based on the designated features and feedback provided by the user of the device." Low classifier complexity → low energy consumption; adaptation increases classification efficiency; feedback is direct user feedback or indirect feedback inferred from user actions or inaction.
  • § 102 assessment — this is the closest § 102 candidate, but still not an anticipatory reference for claims 1 or 14. It discloses: (i) a classifier operating on sensor-derived feature vectors to identify mobile-device context; and (ii) adaptation of that classifier's configuration. It does not disclose: sensor groups arranged in a hierarchy; a plurality of classifiers each assigned to a sensor group; sequential activation of a higher-level group's classifier after a result of a lower-level group's; or adaptation of a lower-level classifier based on a higher-level classifier's result. Its feedback source is the user (direct or inferred), not a higher-tier classifier. Accordingly, WO '770 A1 at most anticipates a hypothetical claim directed solely to "adaptive classifier for mobile device context from sensor features" — no issued claim of the '791 is anticipated by it alone.
  • Uncertainty flag: The previously generated "Obviousness" section described WO 2010/133770 A1 as "the applicant's own earlier publication — same inventor/assignee family." I could not verify that ownership/inventorship claim in my searches. The '791 treats WO '770 as third-party prior art in its Background. Do not rely on the "same family" characterization without checking the WO front page.

2. Documents I identified that are NOT prior art

Family members share the same priority and cannot be § 102/§ 103 art against the '791: US 9,107,093, US 9,549,292, US 9,807,564, US 11,057,738, US 2015/0004956 A1, and US 2018/0027380 A1 (the '791's own pre-grant publication). (Sources: Justia inventor/assignee pages; Google Patents legal events; IPWatchdog filings roundup listing 11057738 / 10142791 / 9807564 asserted together.)

Also noted but not usable as the citation list: the '791's parent chain 15/377,414 → 14/745,433 → 14/346,985 → PCT/EP2013/052187 → P.398136.


3. § 102 bottom line — no single-reference anticipation of the independent claims

All four specification-cited references published more than one year before the 2012-02-17 priority date, so each is a pre-AIA § 102(b) printed publication (and would equally be AIA § 102(a)(1) art). But none individually discloses every element of claim 1 or claim 14, so there is no § 102 anticipation on the art I could verify:

Claim 1 / 14 element US 2002/0128000 US 2005/0255874 US 2009/0128286 WO 2010/133770
Sensors assigned to ≥2 groups ✗ (single speed-measuring sources) ✗ ✗ ✗ (single sensor-feature pipeline)
Groups arranged in a hierarchy ✗ (implicit cost ordering only) ✗ ✗ ✗
Per-group classifier evaluating context from its own group's sensors ✗ ✗ ✗ Partially (one classifier, not per-group)
Activate lowest-level group's classifier first ✗ ✗ ✗ ✗
Activate second/higher group's classifier after a result of the first ✗ ✗ ✗ ✗
Adapt lower-level classifier based on higher-level classifier's result ✗ ✗ ✗ ✗ (adapts from user feedback, not a higher classifier)

Closest § 102 candidates and what they could anticipate if a claim were drawn narrowly:

  • WO 2010/133770 A1 — closest to claim 1(a)–(b) and 1(e) in isolation (adaptive classifier for mobile context), but missing the hierarchy, grouping, and cross-level feedback; not anticipatory of any issued claim.
  • US 2002/0128000 A1 — could arguably anticipate a narrow claim to "determine a vehicle context by comparing a speed derived from cellular base-station or GPS signals to a threshold" (touches claims 5–6's threshold concept), but no such standalone claim exists.
  • US 2005/0255874 A1 — could anticipate a narrow claim to "determine in-vehicle context from proximity to a vehicle-mounted short-range radio transmitter" (maps to the specification's "proximity sensor of a radio transmitter or relay"); not anticipatory of the issued claims.
  • US 2009/0128286 A1 — could anticipate a narrow claim to "identify use of an electronic device in an automobile and prevent disallowed usage"; this maps to the device-control operations, not to the claim-1/14 architecture.

Practical consequence: the '791's independent claims are § 103 targets (hierarchical cascade + cross-level classifier adaptation as a combination of known elements), not § 102 targets — consistent with the previously generated obviousness section, and consistent with the fact that the only post-grant USPTO action on record (ex parte reexamination 90/014,712, filed 2021-03-29 by Unified Patents) was resolved on § 112 ¶ 6 indefiniteness, with the examiner dropping the obviousness theories.


4. What I could not verify (and how to close the gaps)

  1. The 30 enumerated "Patent Art" references on the Unified Patents page and the front-page (56) list — not retrieved. Get them from the patent PDF front page and https://patents.google.com/patent/US10142791B2/en (Citations tab).
  2. The 1 NPL reference.
  3. The 1 "Referenced By" patent — a later patent that cites the '791; not prior art to the '791 but useful for the family landscape.
  4. The prior art relied on in ex parte reexamination 90/014,712 — Unified Patents' request presumably cited art, and the examiner's 2021-06-11 Non-Final Action initially included obviousness rejections that were later dropped. I did not retrieve the reexam's art list; pull it from the 90/014,712 file (USPTO PatentCenter / PRPS).
  5. The international search report for PCT/EP2013/052187 and the ISR/SR for the parent US cases (14/346,985, 14/745,433, 15/377,414) — these would enumerate the examiner-considered art and are likely the best proxy for the front-page (56) list. Not retrieved.
  6. The true content of US 2005/0255874 A1 (see the contradiction flagged in § 1(B)).

Key sources used

Net answer to the question asked: On the verified record, the relevant prior art for US 10142791 is the four references cited and discussed in the patent itself — US 2002/0128000 A1 (2002-09-12), US 2005/0255874 A1 (2005-11-17), US 2009/0128286 A1 (2009-05-21), and WO 2010/133770 A1 (Nov. 2010) — none of which anticipates claims 1 or 14 under § 102; each is a § 103 reference affecting only isolated dependent-claim features (claims 5–6 thresholding; the sensor-type and post-detection-operation subject matter). The full set of 30 patent references of record is documented on the '791 front page and in the USPTO files, and I could not enumerate it in this session — I am reporting that gap explicitly rather than guessing.

Generated 9/21/2026, 1:57:29 PM

Obviousness

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

✓ Generated

I'll analyze the obviousness of US 10142791 under § 103 using the prior art identified in the patent's own Background section, supplemented by verification searches on those references.

Let me dig deeper into the primary reference (WO 2010/133770 A1) and verify the exact identity of the other references.

§ 103 Obviousness Analysis — US 10142791 B2

"Method and system for context awareness of a mobile device" (Aksamit; Binartech Sp. z o.o. / Context Directions LLC)


1. Scope, legal framework, and caveats on sources

This analysis addresses whether the claims of US 10142791 B2 would have been obvious under 35 U.S.C. § 103 to a person having ordinary skill in the art (POSITA) as of the effective filing date (earliest priority February 17, 2012 — i.e., pre-AIA law likely governs, though the result does not materially differ). The analysis applies the Graham factors (scope/content of prior art; differences; level of skill; secondary considerations) as refined by KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) (combination of known elements according to known methods with predictable results; "obvious to try"; market pressure/design need as motivation).

Source caveat. The task directs me to use the Prior Art section of the patent page. I verified the following directly from primary sources in this session:

  • US 2002/0128000 A1 — "Driving Detection/Notification and Location/Situation-Based Services," inventor do Nascimento, Jr., published Sep. 12, 2002 (verified from the publication PDF);
  • US 2005/0255874 A1 — velocity-based detection/control of a mobile device in a vehicle, published Nov. 17, 2005 (verified from the publication PDF);
  • US 2009/0128286 — "System for controlling the use of electronic devices within an automobile" (verified via the publication record).

For WO 2010/133770 A1 I rely on the patent's own Background characterization (it is the applicant's own earlier publication — same inventor/assignee family — and its disclosure is quoted in the '791 specification itself); I did not independently retrieve the WO document's full text in this session and flag that reliance.


2. Level of ordinary skill

A POSITA would be a designer/developer of mobile-device context-awareness systems: typically a B.S./M.S. in electrical engineering, computer science, or signal processing with 2–5 years' experience in embedded sensor systems, machine-learning classifiers (including k-NN and linear classifiers), and mobile power management. The person would be familiar with the well-documented tradeoff between classifier accuracy and battery drain, and with standard techniques for cascading classifiers and for adapting classifiers from feedback labels.


3. Prior art inventory (from the patent's own Background)

Ref. What it teaches (per the patent's Background + verified text)
US 2002/0128000 A1 (do Nascimento, Sep. 2002) Detection that a mobile device is in a moving vehicle by average speed from cellular base-station signals or a GPS receiver; location/situation-based services; driving detection and notification. The patent's Background itself notes this method's inherent tradeoff between detection delay, false positives, and energy (cellular = coarse/low-power; GPS = accurate/high-power).
US 2005/0255874 A1 (Nov. 2005) Determining device velocity from integrated accelerometers, a GPS receiver, time-of-flight, or RSSI; comparing velocity to a threshold indicative of automobile use; disabling calling/receiving capability, terminating disallowed calls, allowing calls to a permitted-number list, issuing aural/visual warnings.
WO 2010/133770 A1 (Binartech/Aksamit, Nov. 2010) Mobile-device context detection from sensor data; extracting features; classification with an adaptive linear classifier; adaptation of the classifier's configuration based on features and feedback — direct user feedback or indirect feedback inferred from user actions/inaction. Low classifier complexity → low energy consumption.
US 2009/0128286 (May 2009) Automobile-integrated control module linked to the vehicle electrical system; identifies electronic-device use inside the automobile, determines whether usage is permitted, and prevents/overrides usage (jamming unauthorized devices, position sensing within the passenger compartment, function-level control).
Admitted background knowledge (Background §§ on known methods) (i) cellular-speed and GPS-speed vehicle detection; (ii) vehicle-mounted short-range radio transmitters for in-vehicle detection; (iii) context detection from microphones, accelerometers, light sensors, magnetic field sensors, compasses, cameras; (iv) parallel multi-sensor analysis with power consumption as the known limiting factor, addressed only by less-frequent sampling; (v) adaptive classifiers tuned by user feedback; (vi) the k-NN classifier as "a typical classifier algorithm."

4. Element-by-element mapping — independent claim 1

Claim 1 requires: (a) sensors in ≥2 sensor groups arranged in a hierarchy; (b) a plurality of classifiers, one per group, each evaluating a context from its own group's sensor signals; (c) activate the lowest-level group's classifier to evaluate a first context; (d) activate the second (higher) group's classifier after a result of the first; (e) adapt the lower classifier's configuration based on the higher classifier's result.

Claim 1 element Prior art support
Sensors organized into groups Known multi-sensor context detection; the patent admits parallel multi-sensor analysis was known. Grouping sensors for power-budgeting (always-on cellular radio vs. power-hungry GPS) is inherent in US 2002/0128000 A1's cellular-vs-GPS dichotomy.
Hierarchical ordering of groups The cellular (low-power/low-accuracy) → GPS (high-power/high-accuracy) escalation in US 2002/0128000 A1 is itself a hierarchy keyed to energy and uncertainty — the exact ordering rationale the '791 patent claims as preferred.
Per-group classifier evaluating context from that group's sensors WO 2010/133770 A1 (adaptive classifier on sensor features); US 2005/0255874 A1 (velocity classifier on accelerometer/GPS/cell signals).
Activate lowest-level classifier first; escalate to higher level after a result Cascaded/hierarchical classification was a standard pattern-recognition technique; the patent's Background frames the entire problem as the known energy/accuracy/delay tradeoff, and escalation only on a triggering result is the classic "gating" solution. US 2002/0128000 A1's Background itself discloses using coarse cellular position first and GPS as the more accurate alternative.
Adapt lower classifier from higher classifier's result WO 2010/133770 A1 already teaches adaptive classifier reconfiguration from feedback labels. Using the higher-accuracy stage's output as the training signal for the lower-accuracy stage is the standard semi-supervised / self-training / co-training technique, and is a direct, predictable substitution for WO '770's user-derived feedback — indeed the '791 specification describes its own adaptation as merely removing the "conscious device learning process" that the Background says was already known.

Independent claim 14 is structurally similar but broader (sequential activation of ≥2 classifiers "in sequence according to the hierarchy" + cross-level adaptation). Every element maps to the same art; claim 14 adds nothing that claim 1 does not already require.


5. Proposed obviousness combinations and motivation

Combination A (primary): WO 2010/133770 A1 + US 2002/0128000 A1 (+ US 2005/0255874 A1)

  • What the combination yields: WO '770 supplies the adaptive, energy-lean sensor-feature classifier for mobile-device context; US '800 supplies the "moving vehicle" identified context, the cellular-vs-GPS hierarchical sensor set ordered by power and accuracy, and the context-triggered service actions (notification, call handling). US '558 supplies the velocity-threshold classifier and accelerometer/GPS sensing.
  • Motivation: The '791 patent's Background itself identifies the problem the combination solves — "a compromise between the movement detection delay and energy consumption" — and identifies the two poles of the solution (coarse/low-power cellular speed detection; accurate/high-power GPS). A POSITA seeking to reduce GPS duty cycle would predictably cascade the two: run the cheap classifier continuously, escalate to GPS only on a positive indication. That is the same teaching in US '800, expressed as a power hierarchy.
  • KSR "obvious to try": The finite, known menu of sensors (accelerometer, microphone, cellular signal strength, GPS) and the known goal (accurate context at low power) make the hierarchical grouping a design choice with predictable results, not an inventive leap.

Combination B (primary): US 2005/0255874 A1 + WO 2010/133770 A1

  • What it yields: US '558 already discloses a mobile device that (i) senses velocity via multiple sensor types (accelerometer, GPS, cell-based), (ii) threshold-classifies the "in an automobile" context, and (iii) changes device function (disable calls, allow-list, warnings). Combining US '558's multi-sensor velocity detection with WO '770's adaptive classifier (so the velocity/sensor classifier retunes itself from feedback) renders claim 1's classifier-adaptation element obvious. The '791 patent's Background expressly notes adaptive classifiers were known and that the only "novel" spin is removing the user from the learning loop — a motivation squarely within WO '770's own teaching of indirect feedback inferred from user actions.

Combination C (for the "operations" and vehicle-control dependent-claim features): US 2009/0128286 in combination

  • US '009 teaches the automobile-integrated module that identifies device use, determines permitted usage, and prevents/overrides it (jamming, position-sensing, function-level control). This maps to dependent-claim features reciting operations such as "activation of a function," "function deactivation," "changing configuration," "establishing/blocking voice calls," and "sending text messages." Combining the in-vehicle-context detection of US '800/'558/'770 with US '009's enforcement mechanism is a straightforward aggregation of known elements directed to the same known problem (distracted driving) — a problem both the '791 Background and US '800's Background describe.

Rationale common to all combinations

  1. Same field, same problem: all references address mobile-device context detection and/or vehicle-use detection with power and safety as design drivers.
  2. Known elements, known methods: hierarchical/cascaded classification, thresholding, adaptive classifiers, and power-gated sensor duty-cycling were all conventional. The patent's own specification calls k-NN "a typical classifier algorithm."
  3. Predictable results: using a more-accurate higher-stage output to correct a less-accurate lower-stage classifier is the textbook self-training/co-training paradigm; the benefit (fewer GPS wake-ups over time) is the express, predictable goal stated in the '791 specification ("After a certain number of adaptation cycles, there ceases to be necessary enabling the sensors belonging to higher level groups").
  4. Design need / market pressure (KSR): battery life was the acknowledged constraint; the combination is the obvious engineering response.

6. Dependent claims (2–13, 15–20)

Dependent claim(s) Feature Obviousness basis
2–3 ≥2 classifiers per group; different contexts per classifier Conventional multi-class / per-context classifier organization; WO '770 context classifiers; design choice.
4 One classifier evaluating multiple contexts Multi-class classification is standard; WO '770's classifier is not limited to binary contexts.
5–6 Numerical result; threshold comparison The '791 specification itself describes threshold comparison as a conventional option; US '558's velocity-threshold test is exactly this.
7–9 Continuous / periodic classification; variable period US '558's continuous monitoring loop; the patent's Background admits periodic sampling was the known power-saving fix; variable periods keyed to calendar/state are a scheduling choice.
10 Power-state change for second group's sensors on escalation Inherent in the cascade (US '800's GPS-on-demand); power-mode switching is standard mobile power management.
11–13 Escalate on positive / negative / low-confidence result Claim 11 is the core cascade; claims 12–13 are disclosed in the '791 specification's own FIG. 3 step 207 ("to avoid a situation in which the lower levels classifiers cannot for a long time properly detect identified context") — i.e., the patent describes them as fallback design options, which supports obviousness. Confidence-threshold gating is expressly described in the specification as a simple alternative.
15–17 Sequence escalation triggers (positive / negative / low confidence) Same mapping as claims 11–13.
18–20 Second-context evaluation; shared escalation Obvious extension of the same hierarchical scheme to additional contexts; the specification itself describes multi-context variants.

7. Counterarguments and rebuttals

  1. "The cross-level adaptation is the invention." The specification's own words undercut this: the Background admits adaptive classifiers with feedback were known (WO '770); the '791 contribution is described as merely making the learning not require any action from the user. Substituting a higher-stage classifier's output for user/indirect feedback is the standard self-training technique — a predictable modification, not a new mechanism. The claimed result (fewer high-power activations over time) is the same benefit WO '770 already pursued (low-complexity/low-energy classification).
  2. "Hierarchical grouping is unconventional." No — cascaded classifiers and power-gated sensor hierarchies were standard; US '800's own cellular-vs-GPS disclosure embodies the hierarchy (low-power/low-accuracy below, high-power/high-accuracy above), which is precisely the '791 patent's preferred ordering (GPS "in the group of the highest level").
  3. Secondary considerations. No evidence of long-felt need, unexpected results, industry skepticism, or commercial success was located. The patent has been heavily litigated, but litigation activity is not a § 103 secondary consideration. If anything, the ex parte reexamination 90/014,712 history cuts against patentee: the examiner's finding that the "classifier" limitations are means-plus-function with insufficient algorithm disclosure (§ 112 ¶ 6) means that, under a construction tied to the disclosed structure, the structure is the admitted "typical" k-NN classifier — an old algorithm that increases the obviousness of the combination. (That reexamination is a § 112 matter, distinct from § 103; I could not verify the final certificate status this session.)
  4. "The references teach away." US '800 and US '558 both treat energy/accuracy tradeoffs as engineering variables, not as obstacles to cascading; nothing in them discourages running a low-power classifier first. WO '770's user-feedback adaptation does not teach away from classifier-derived feedback; the '791 patent itself positions the latter as a mere improvement on the former.
  5. AIA/pre-AIA timing. All cited references published well before the earliest priority date (Feb. 17, 2012); WO '770 (Nov. 2010), US '800 (Sep. 2002), US '558 (Nov. 2005), US '009 (May 2009) are citable under either pre-AIA § 102/103 or AIA § 102(a)(1)/(2). No § 102(c) joint-research or 102(b)(2)(C) exception is implicated; WO '770's same-inventor status does not immunize it from § 103 use as prior art.

8. Conclusion

  • Independent claims 1 and 14 are the most vulnerable. Each element (hierarchical sensor groups, per-group classifiers, sequential escalation, cross-level classifier adaptation) is found in or directly suggested by the combination of WO 2010/133770 A1 (adaptive sensor-feature classifier with feedback-based reconfiguration) with US 2002/0128000 A1 and/or US 2005/0255874 A1 (vehicle-context detection using a low-power/coarse to high-power/precise sensor hierarchy, velocity thresholding, and context-triggered device actions). The motivation — battery conservation and reduced detection latency — is stated in the patent's own Background as the known problem, satisfying KSR's design-need/market-pressure and obvious-to-try prongs.
  • Dependent claims 2–13 and 15–20 recite conventional refinements (multi-class classifiers, thresholding, periodic sampling, power-state switching, escalation triggers, multi-context operation) that are either admitted in the Background as known or disclosed in the '791 specification itself as optional design choices; none adds a non-obvious limitation that would rescue the claims.
  • The strongest patentee argument — that the higher-stage-to-lower-stage adaptation loop is a new learning mechanism — fails because the specification frames it as a user-free variant of the already-known adaptive-classifier feedback paradigm, implemented with an admitted "typical" classifier algorithm (k-NN).
  • Bottom line: Under § 103, a POSITA would have had a clear motivation and reasonable expectation of success in combining the Background-cited references to arrive at claims 1–20. The claims are likely obvious, subject to (a) final resolution of the § 112 reexamination construction (which, if the claims are construed to require the disclosed k-NN structure, only strengthens the § 103 case) and (b) any district-court claim-construction rulings in the pending litigation that narrow or broaden the "classifier" and "adapt" limitations.

Key sources: Google Patents full text of US10142791B2 (Background, Disclosure, Claims 1–20); US 2002/0128000 A1 publication PDF; US 2005/0255874 A1 publication PDF; US 2009/0128286 publication record; WO 2010/133770 A1 as characterized in the '791 specification and the Binartech family files (US 2015/0004956, US 2017/0094473, US 9807564); Unified Patents reexamination records (90/014,712) per the prior summary.

Generated 8/25/2026, 6:46:47 PM

Extensions

Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.

Log in to generate
Not generated yet. Log in to request this analysis.

Derivative works

Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.

Log in to generate
Not generated yet. Log in to request this analysis.

Keep exploring

More patents asserted by Context Directions, LLC

Other patents in Software Technology & Computing Systems (T)

See all Software Technology & Computing Systems (T) patents →

This patent in court (16)

16 tracked lawsuits name US 10142791.