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

• Google Patents (authoritative full text): https://patents.google.com/patent/[US10142791](/patent/US10142791)/en
• Justia (issue data): https://patents.justia.com/patents-by-issue-date/2018/11/27?page=135
• Unified Patents portal (bibliographic data): https://portal.unifiedpatents.com/patents/patent/US-10142791-B2
• Unified Patents reexamination insights (2021)
• PacerMonitor/Justia dockets for district court cases

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.

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.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.)

• Plaintiff: Context Directions, LLC
• Defendants: Samsung Electronics Co., 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. 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.

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:

• https://www.unifiedpatents.com/insights/2021/3/29/context-directions-patent-challenged
• https://www.unifiedpatents.com/insights/2021/4/29/context-directions-791-reexamination-request-granted
• https://www.unifiedpatents.com/insights/2021/11/10/uspto-reexam-confirms-context-directions-patent-is-manifestly-indefinite
• https://pdfserver.amlaw.com/legalradar/45184723_complaint.pdf (complaint ¶ 29 confirming certificate issuance 2021-11-05)
• https://dockets.justia.com/docket/texas/txedce/2:2025cv00627/[238570](/patent/238570)
• https://dockets.justia.com/docket/texas/txedce/2:2025cv00626/[238563](/patent/238563)

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.

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").

I'll research the citations for US Patent 10142791 to identify its prior art references. Let me search multiple sources in parallel.

Let me search for the specific citation list on the patent's front page.

Let me try to access the citation list from Google Patents and other databases.

Prior Art Analysis — US Patent 10,142,791 (US10142791B2)

Methodology and source caveats (read first)

I attempted to pull the examiner's "References Cited" list from USPTO Patent Center/Google Patents for the 791 patent itself. The full patent text supplied (which is authoritative) does not include a Citations section, and my live searches did not return the complete, face-of-the-patent citation list for US10142791B2 specifically. What I did retrieve:

1. References expressly discussed in the 791 patent's own Background section (confirmed present in the patent text as filed) — these are the references the applicant itself identified as closest prior art.
2. A 23-entry "Patent Citations" list rendered by Google Patents on a family-member page (the publication US20210329412A1, i.e., continuation US17/365,325, filed 2021-07-01). This list cannot be assumed to be identical to the citation list on the face of the 791 grant, because it includes EP4033820A1 published 2022-07-27 — after the 791 patent issued (2018-11-27). I flag every reference below accordingly.

Because claim 1 and claim 14 are the only independent claims (both device claims), the § 102 anticipation analysis below maps each reference against their element sets. My anticipation conclusions are preliminary — they are based on titles, the patent's own characterizations, and snippets, not on full-text review of each reference. "Potentially anticipates" means the reference plausibly discloses all elements of the claim as claimed; a definitive § 102 finding requires full-text element-by-element verification.

Claim 1 elements (for mapping): (a) sensors in hierarchically arranged groups; (b) per-group classifiers each evaluating context from its own group's sensors; (c) activate lowest-level group classifier to evaluate a first context; (d) activate a second (higher-level) group's classifier after a result of the first; (e) adapt the lower classifier's configuration based on the higher classifier's result.

Claim 14 elements: (a) same hierarchical group/classifier structure; (b) evaluate a first context by activating at least two classifiers in sequence per the hierarchy; (c) adapt a lower-level classifier based on a higher-level classifier's result.

A. References expressly discussed in the 791 patent's Background (confirmed)

1. U.S. Patent Application Publication US 2002/0128000 A1

• Full citation: US 2002/0128000 A1, published September 12, 2002 (dates per the patent's reference; exact filing date not independently verified in this search).
• Description (as characterized by the 791 patent): A system for use in a mobile communication device including a subsystem for detecting movement of the device in a vehicle, by measuring average speed from cellular base-station signals or a global satellite positioning (GPS) receiver.
• § 102 analysis: Discloses context detection ("in a moving vehicle") using sensors (cellular radio, GPS). It does not disclose (per the available characterization) hierarchical sensor groups, sequential activation of higher-level classifiers, or cross-level classifier adaptation. Potential anticipation: likely not claim 1 or claim 14 (missing elements (b), (d), (e) / hierarchical sequencing and adaptation). It could support grounds against method/use aspects but the granted claims are device claims; low anticipation potential as a standalone reference.

2. U.S. Patent Application Publication US 2005/0255874 A1

• Full citation: US 2005/0255874 A1, published November 17, 2005 (per the patent's reference; exact date not independently verified in this search).
• Description: System/method for detecting movement in a vehicle using a low-range vehicle-mounted radio transmitter activated when the vehicle is in use, and a mobile device with a compatible radio receiver that detects the "in-vehicle" context by signal proximity.
• § 102 analysis: Discloses a context ("in vehicle") detected from a sensor (radio receiver). Missing hierarchical multi-group classification and classifier adaptation. Potential anticipation: low for claims 1 and 14; the disclosure is essentially single-sensor proximity detection.

3. WO 2010/133770 A1 (VTT)

• Full citation: WO 2010/133770 A1, Valtion Teknillinen Tutkimuskeskus (VTT), published November 25, 2010; priority May 22, 2009.
• Description: Method of detecting mobile-device context by retrieving sensor data, extracting features, classifying with an adaptive linear classifier, and adapting the classifier configuration based on user feedback (direct or inferred from user actions/inaction).
• § 102 analysis: This is the closest prior art the applicant itself identified. It discloses: sensor-based context detection, feature extraction, adaptive classification, and adaptation of classifier configuration. Missing (per the patent's own characterization): hierarchical groups of sensors and classifiers, and adaptation driven by higher-level classifier results rather than user feedback. Potential anticipation: claim 1 and claim 14 are likely not anticipated (single classifier, no hierarchy, no higher-level feedback). However, it may be the strongest § 102/103 starting point against dependent claims that add only generic limitations — e.g., claim 5 (numerical result indicating probability — a linear classifier commonly outputs a confidence/probability), claim 6 (threshold comparison — inherent to linear classifiers), claims 7–8 (continuous/periodic classification). Anticipation of claims 1/14 is unlikely absent a hierarchical disclosure.

4. U.S. Patent Application Publication US 2009/0128286 A1

• Full citation: US 2009/0128286 A1, published May 21, 2009.
• Description: System for controlling use of electronic devices within an automobile; a control module integrated with the automobile's electrical system identifies device usage, determines whether usage is permitted, and prevents non-permitted usage.
• § 102 analysis: Discloses an in-automobile context and a control action tied to that context. Missing hierarchical sensor groups, per-group classifiers, and cross-classifier adaptation. Potential anticipation: low for claims 1/14; at most relevant to dependent features concerning actions taken upon positive context detection (not present in the granted device claims as drafted).

B. References from the Google Patents family citation list (23 entries; 16 retrieved — flagged, not confirmed as the 791 face-of-patent list)

Source: Google Patents "Patent Citations (23)" rendered on the US20210329412A1 (family continuation) page. Because this list contains a 2022 publication, it reflects later-family prosecution, not necessarily the 791 examiner's list. Treat as indicative.

5. US 6,122,521 A — Wilkinson

• Full citation: US 6,122,521 A, issued September 19, 2000, "Telecommunications locating system."
• Description: Cellular-telephony-based locating system (position determination from base-station signals).
• § 102 analysis: Relevant only to the sensor/positioning aspect. Potential anticipation: very low for claims 1/14; no hierarchical classifiers or adaptation disclosed on the available information.

6. US 2006/0079180 A1 — Nokia

• Full citation: US 2006/0079180 A1, published April 13, 2006, "Methods, apparatus, systems and computer program products for energy management of short-range communication modules in mobile terminal devices."
• Description: Power/energy management for short-range radio modules in mobile devices.
• § 102 analysis: Relevant to power-state management (cf. claim 10: changing power state of sensors when a higher-level classification is activated). Potential anticipation: low for claims 1/14; possibly relevant to claim 10 in combination, but standalone anticipation unlikely.

7. US 8,096,069 B2 — Searete / The Invention Science Fund I, LLC

• Full citation: US 8,096,069 B2, issued January 17, 2012, "Repeatably displaceable emanating element display."
• Description: Display technology (emanating elements).
• § 102 analysis: Appears tangential to context-detection claims. Potential anticipation: very low / not applicable on available information.

8. US 2013/0182228 A1 — Searete

• Full citation: US 2013/0182228 A1, published July 18, 2013, "Repeatably displaceable emanating element display."
• Description: Related continuation/application of the Searete display technology.
• § 102 analysis: Same as #7 — potential anticipation: very low.

9. US 2011/0263240 A1 — Aegis Mobility

• Full citation: US 2011/0263240 A1, published October 27, 2011, "System and methods for monitoring the context associated with a mobile communication device."
• Description: Monitoring mobile-device context (e.g., driving) using device sensors/data.
• § 102 analysis: Discloses context determination (driving) and possibly multiple data sources. Potential anticipation: claims 1/14 unlikely (no demonstrated hierarchical multi-classifier + cross-level adaptation); relevant to context-evaluation elements.

10. US 2012/0264409 A1 — Aegis Mobility

• Full citation: US 2012/0264409 A1, published October 18, 2012, "Management of mobile device communication sessions to reduce user distraction."
• Description: Managing calls/messages based on detected context (e.g., driving) to reduce distraction.
• § 102 analysis: Context-triggered actions. Potential anticipation: low for claims 1/14 as structured; relevant to context-action features.

11. US 2014/0057616 A1 — Aegis Mobility

• Full citation: US 2014/0057616 A1, published February 27, 2014, "Monitoring mobile device context."
• Description: Context monitoring for mobile devices.
• § 102 analysis: Similar to #9. Potential anticipation: low for claims 1/14 standalone.

12. US 2014/0199987 A1 — Aegis Mobility

• Full citation: US 2014/0199987 A1, published July 17, 2014, "Context-based management of mobile devices."
• Description: Managing device behavior based on context.
• § 102 analysis: Potential anticipation: low for claims 1/14; relevant background.

13. US 2009/0099812 A1 — Kahn (d.b.a. Dp Technologies)

• Full citation: US 2009/0099812 A1, published April 16, 2009, "Method and Apparatus for Position-Context Based Actions."
• Description: Position-context detection (e.g., GPS/accelerometer) triggering device actions.
• § 102 analysis: Discloses context from sensors and actions. Potential anticipation: claims 1/14 unlikely (no hierarchical classifier/adaptation structure shown); possible § 102/103 relevance to sensor-based context evaluation.

14. WO 2010/133770 A1 — VTT (same as #3 above; listed again for completeness)

• See analysis in Section A, item 3.

15. EP 2 433 416 B1 — VTT

• Full citation: EP 2 433 416 B1, granted April 26, 2017 (application priority May 22, 2009), "Context recognition in mobile devices."
• Description: European counterpart of WO 2010/133770 A1 (adaptive context recognition in mobile devices).
• § 102 analysis: Same disclosure as #3. Potential anticipation: low for claims 1/14; relevant to dependent claims 5–6 as discussed.

16. US 2012/0109963 A1 — NEC Corporation

• Full citation: US 2012/0109963 A1, published May 3, 2012, "Classification hierarchy regeneration system, classification hierarchy regeneration method, and classification hierarchy regeneration program."
• Description: A system for regenerating a classification hierarchy — the most structurally relevant reference to the "hierarchy" element of claims 1 and 14 among the retrieved citations.
• § 102 analysis: Potentially relevant to element (a) (hierarchically arranged groups) if it discloses hierarchical classifiers over data groups. However, the disclosed hierarchy is a data-classification taxonomy, not a power-management/context-detection hierarchy with sequential activation of sensor groups. Potential anticipation: moderate-low for claims 1/14; strongest candidate among retrieved refs for the "hierarchy" limitation, but full-text review needed.

17. EP 4 033 820 A1 — Samsung Electronics (published 2022-07-27)

• Flag: This publication post-dates the 791 patent's issue date (2018-11-27) and therefore cannot be a citation on the face of US10142791B2. It appears in the later family member's list (likely cited in US17/365,325). It is not § 102 prior art to the 791 patent (not prior art under § 102(a)(1)/(2) relative to the 2012-02-17 effective filing date). Included only to explain the source discrepancy.

18. US 2011/0300875 A1 — Deutsche Telekom AG

• Full citation: US 2011/0300875 A1, published December 8, 2011, "Apparatus, method, and system for sensing suppression for location-based applications."
• Description: Suppressing sensor use in location-based applications to conserve power.
• § 102 analysis: Relevant to power-saving sensor management (cf. claim 10 — power-state changes; description's "powering off lower-level group"). Potential anticipation: low for claims 1/14 standalone; possible § 102/103 relevance to claim 10.

19. US 2012/0034867 A1 — Research In Motion (BlackBerry)

• Full citation: US 2012/0034867 A1, published February 9, 2012, "Communication system providing context-based mobile wireless communications device power consumption management and related methods."
• Description: Context-based power-consumption management for mobile devices.
• § 102 analysis: Combines context detection with power management. Potential anticipation: claims 1/14 unlikely (no hierarchical per-group classifiers + adaptation shown); relevant to claim 10 in combination analyses.

20. US 9,167,991 B2

• Full citation: US 9,167,991 B2, issued October 27, 2015 (title truncated in retrieved snippet — could not be retrieved in full; the assignment/specification details were cut off in the search result).
• Description: Unable to describe — retrieval was truncated.
• § 102 analysis: Cannot assess — flagged as an open item requiring direct USPTO/Google Patents lookup.

21–23. Remaining citations

• The Google Patents list shows 23 patent citations total; I retrieved 16 (with overlap, effectively 14 distinct retrievable references plus the truncated US 9,167,991 B2 and the post-issue EP 4 033 820 A1). Citations 21–23 were not retrievable in this session and are flagged as an open item. I do not speculate on their identity.

C. Claims-level summary of § 102 anticipation potential

Bottom line: On the available evidence, no single retrieved reference appears to anticipate independent claims 1 or 14 — the combination of (i) hierarchically arranged sensor groups, (ii) per-group classifiers, (iii) sequential activation of higher-level classification after a lower-level result, and (iv) adaptation of lower-level classifier configuration based on higher-level classification results is not shown in any one retrieved reference. The strongest individual references are WO 2010/133770 A1 (adaptive classifier) and US 2012/0109963 A1 (classification hierarchy), which are more likely to feature in § 103 obviousness combinations than standalone § 102 anticipations. Dependent claims 5, 6, and 10 have the most plausible standalone § 102 exposure (probability/threshold outputs in linear classifiers; power-state management in the Nokia/Deutsche Telekom/RIM references).

Open items (explicitly flagged, not resolved)

1. The complete face-of-patent citation list for US10142791B2 could not be retrieved from USPTO Patent Center in this session — the 23-entry list above came from a family-member page and includes one post-issue reference (EP 4 033 820 A1), so it is not verified as the 791 examiner's list.
2. US 9,167,991 B2 title/specification was truncated — unassessed.
3. The USPTO status of ex parte reexamination 90/014,712 (filed 2021-03-29, directed at the "classifier" limitations) and any added prior art from that proceeding was not retrievable in this session; any reexamination-added references would be highly relevant to a complete § 102 analysis.

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)

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.

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)

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.