Invalidity dossier

US 10162596

Current assignee: Flexiworld Technologies, Inc.

Added 8/28/2026, 12:01:19 PM

At a glanceNo PTAB challenges2 lawsuits on fileasserted by Flexiworld Technologies, Inc.Software Technology & Computing Systems (T)

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Patent summary

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

✓ Generated

Summary — U.S. Patent No. 10,162,596 (US10162596B2)

Bibliographic data (verified against USPTO-derived sources: uspto.report and Google Patents)

Field Value
Patent number 10,162,596 (B2)
Title Portable electronic device configured to receive voice activated commands and to wirelessly manage or drive an output device
Assignee Flexiworld Technologies, Inc. (Vancouver, WA)
Inventors William Ho Chang (Vancouver, WA); Christina Ying Liu (Fremont, CA)
Application / filing date Appl. No. 15/201,194 — filed July 1, 2016
Issue date December 25, 2018
Priority date November 1, 2000 (Provisional Appl. 60/245,101)
Family / continuation chain Continuation of 13/710,295 (→ US 9,383,956), which is a continuation of 12/903,048 (→ US 8,332,521), which is a continuation of 10/016,223 (→ US 7,941,541, filed Nov. 1, 2001), claiming benefit of Provisional 60/245,101 (Nov. 1, 2000)
Primary classification G06F 3/167 (audio in a user interface); G06F 3/0412; G06F 3/14; H04W 88/02, among others

Note on data discrepancy: Google Patents shows priority date 2000-11-01, while some secondary databases (e.g., Unified Patents) list 2000-10-31. The patent's own cross-reference section states the provisional was filed Nov. 1, 2000; I treat the patent text as authoritative. Also, Google Patents flags a legal-status assumption of "Expired – Fee Related" with adjusted expiration of 2022-10-01; that status notation is not a legal conclusion and should be verified in USPTO PAIR/Patent Center if relied upon.

Abstract (verbatim)

A portable electronic device configured for receiving voice activated commands for wirelessly managing or driving an output device. The output device may include, for example, a television, a controller connectable to a television, a printer, an audio output device, or a projector. The portable electronic device includes an interface that includes at least one button or other controls, a microphone, and wireless communication circuitry. Subsequent to establishing, within a physical proximity, a wireless connection to the output device using the wireless communication circuitry, the portable electronic device is operable for receiving an indication from a user via the interface, for wirelessly sending information to the output device related to the indication, and for wirelessly receiving data or component from the output device in response to having sent the information. Additionally, the portable electronic device is configured to receive voice activated commands from the user via the microphone.

Independent claims — plain-language overview

The patent has three independent claims (1, 8, 14), all directed to the same core concept: a portable device (e.g., a phone/tablet/remote) that pairs wirelessly with an output device (TV, projector, speaker, printer, etc.) and can both exchange data/components with it and accept voice commands to drive it.

  • Claim 1 (apparatus — portable electronic device): A portable device with a microphone, a user interface (at least one button or other controls), and wireless communication circuitry. The device is operable to: (1) receive a user indication via the interface relating to managing/driving the output device; (2) wirelessly send information to the output device based on that indication; (3) wirelessly receive data or a component back from the output device in response; (4) then receive a voice-activated command via the microphone; and (5) wirelessly transmit audio/sound data to the output device related to that voice command. In short: a wireless remote/controller that first handshakes with an output device (send info → get data/component back), then takes a voice command and streams corresponding audio to the device.

  • Claim 8 (medium — non-transitory computer-readable recording medium): A computer-readable medium storing instructions that, when executed, cause a portable device (having microphone, interface with button/controls, wireless circuitry) to: (1) wirelessly detect an output device based on physical proximity; (2) wirelessly connect to it; (3) receive a user indication via the interface relating to managing/driving the connected device; (4) wirelessly receive information/data from the output device in response to the indication; and (5) receive a voice-activated command via the microphone for controlling/managing/driving the connected device. This is the software/method-side counterpart of claim 1, adding explicit proximity-based discovery/connection steps.

  • Claim 14 (apparatus — wireless communication circuitry): Wireless communication circuitry for use in a portable electronic device that supports voice commands. The circuitry is configured to: (1) detect a wireless output device based on physical distance; (2) connect to it; (3) send first information to the device; (4) receive second information from the device in response; and, after the portable device receives a voice-activated command from the user, (5) transmit audio/sound data related to that command to the connected device. This claim is drafted to the communication circuitry itself rather than the whole device.

Dependent claims (2–7, 9–13, 15–20) add limitations such as: the device being a Bluetooth-enabled controller, digital pad, or smart phone; the output device being a TV, TV-connected output controller, projector, audio output device, or display; IEEE 802.11/Bluetooth-compatible chipsets; the second received information including data, components, attribute/user-interface/status information; and executable software at the device.

Litigation / CAFC 2026 docket check

  • CAFC 2026 docket: My searches of CAFC docket references for "10162596" (including 2025–2026 appeal terms) returned no Federal Circuit appeal docket for this specific patent. If an appeal exists, it is not surfacing in the searched sources as of today's date (2026-04-26).
  • District court activity involving the '596 patent:
    • Flexiworld Technologies, Inc. v. Sony Corporation, 2:23-cv-00616 (E.D. Tex.) — the '596 patent was among seven asserted patents; case dismissed with prejudice by joint stipulation on May 29, 2025 (per PatSnap litigation summary). The dismissal does not invalidate the patent.
    • Flexiworld Technologies, Inc. v. LG Electronics, Inc. et al., 2:25-cv-00960 (E.D. Tex., filed Sept. 18, 2025; Judge Rodney Gilstrap; open) — the '596 patent is asserted with claims 1, 2, 4, 5, 6, 7, 8, 9, 11, 12, and 13 against LG "Accused TV Remotes" and "Accused Apps" (per the complaint analysis).
    • The Google Patents page also lists a first-family-worldwide litigation entry (Darts-ip) and prior E.D. Tex. matters in the Flexiworld portfolio.

Uncertainty notes

  • The "Expired – Fee Related" status and the exact adjusted expiration date (2022-10-01) come from Google Patents' non-authoritative legal-status field; I could not independently confirm maintenance-fee status via a live USPTO query in these searches.
  • The exact filing date of parent application 12/903,048 appears as "Oct. 10, 2012" in the patent's own cross-reference text but as "Dec 11, 2012" (likely its issue date) in the uspto.report family table; I have followed the patent's own text.
  • No CAFC docket for this patent was found; absence of a result is not proof that no appeal exists.

Generated 8/28/2026, 12:46:53 PM

Cases on file (2)

Group view →

Specific litigation cases in our database that name US patent 10162596. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

✓ Generated

I'll search for litigation involving US Patent 10162596.

The initial searches identify one case. Let me verify details and check the second litigation reference noted on Google Patents (2:25-cv-00960).

I have two cases identified. Let me confirm the LG case parties and check the Unified Patents litigation portal references.

Based on my searches, I have identified the known litigation involving US Patent 10162596. Here is the summary:


Litigation involving US Patent 10162596 ("Portable electronic device configured to receive voice activated commands and to wirelessly manage or drive an output device")

Case 1 — Flexiworld Technologies, Inc. v. Sony Corporation

  • Case number: 2:23-cv-00616
  • Jurisdiction: U.S. District Court for the Eastern District of Texas (Marshall Division)
  • Plaintiff: Flexiworld Technologies, Inc.
  • Defendant: Sony Corporation
  • Filing date: December 19, 2023
  • Patents-in-suit: US10162596B2 was one of seven patents asserted (along with US9836259B2, US11096056B2, US9798516B2, US9042811B2, US10768871B2, and US11029903B2)
  • Presiding judge: District Judge Rodney Gilstrap
  • Status/Outcome: Closed — dismissed with prejudice. The parties filed a Joint Stipulation to Dismiss with Prejudice (Dkt. No. 42) under Rule 41(a)(1)(A)(ii), covering "all pending claims and counterclaims." The Court acknowledged and accepted the dismissal with prejudice; each party bears its own costs, expenses, and attorneys' fees. No merits ruling was issued. (Per PatSnap's PACER-based analysis, the dismissal occurred on or about May 29, 2025, after 527 days of litigation.)

Case 2 — Flexiworld Technologies, Inc. v. LG Electronics, Inc. et al.

  • Case number: 2:25-cv-00960
  • Jurisdiction: U.S. District Court for the Eastern District of Texas (Marshall Division)
  • Plaintiff: Flexiworld Technologies, Inc.
  • Defendants: LG Electronics, Inc. and LG Electronics U.S.A., Inc. (also referred to as LG Electronics USA Incorporated)
  • Filing date: September 18, 2025
  • Patents-in-suit: US10162596B2 was one of six patents asserted (along with US9042811B2, US9836259B2, US9965233B2, US10140072B2, and US10037178B2)
  • Asserted claims of '596: Claims 1, 2, 4, 5, 6, 7, 8, 9, 11, 12, and 13, directed to accused LG TV remotes and associated apps (allegedly providing voice-activated control of output devices such as TVs/speakers)
  • Presiding judge: District Judge Rodney Gilstrap
  • Status/Outcome: Open/pending as of the latest available information (filed September 2025; summons returned executed, complaint and AO 120 filed; no merits ruling or disposition found in searches).

Sources consulted: Stanford NPE Litigation Database (npe.law.stanford.edu/patent/10162596), RPX Empower / Ex Parte case records, PatSnap litigation analysis (citing PACER Docket for 2:23-cv-00616), PacerMonitor case pages, and the LG complaint analysis for 2:25-cv-00960.

Caveat: I could not access the live Unified Patents litigation portal directly (search tool limit reached), but the two case numbers it lists on the Google Patents record for US10162596 — 2:23-cv-00616 and 2:25-cv-00960 — match the two cases identified above. Case 2's status is current as of the information available in the search results; for the most up-to-date docket status, PACER (case 2:25-cv-00960) should be checked directly.

Generated 8/28/2026, 12:47:04 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: Flexiworld Technologies, Inc.

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

Proceedings overview

Zero AIA trial proceedings (IPR / PGR / CBM) are on file for U.S. Patent No. 10,162,596. The canonical USPTO Open Data Portal (ODP) feed for this patent contains no PTAB trials, and independent web searching (PTAB case aggregators, Unified Patents, PatSnap, CourtListener, and general web) surfaced no IPR, PGR, or CBM petition naming the '596 patent as the challenged patent. The defensive posture is therefore the neutral one: every claim (1–20) remains in force and completely untested at the PTAB — there is no IPR estoppel (§ 315(e)(2)) binding any current or future defendant, and the patent's validity has never been adjudicated in an AIA trial.


No proceedings to report

There are no individual proceedings to itemize. To be transparent about what the search did surface (so you don't mistake it for activity on this patent):

  • IPR2023-00845 — Lexmark International, Inc. v. Flexiworld Technologies, Inc. challenges U.S. Patent No. 7,609,402 (a different, earlier Flexiworld patent, application 10/053,651) — not the '596 patent. Status: Institution Denied (Decision Denying Institution, 35 U.S.C. § 314, issued 2023-11-17). Petitioner's refund was approved 2024-01-24. This tells you the PTAB has recently scrutinized — and rejected — a Flexiworld wireless-output petition on the merits, but it has no preclusive effect on the '596 patent.
  • Unified Patents ex parte reexamination of RE48,066 (filed 2023-05-23) — an ex parte reexamination, not an AIA trial, and directed to a different Flexiworld data-mining patent. Not relevant to § 311–319 practice on '596.
  • District-court-only activity: Flexiworld v. Sony, 2:23-cv-00616 (E.D. Tex.) — dismissed with prejudice by joint stipulation 2025-05-29, no merits ruling (per PatSnap/PACER); and Flexiworld v. LG Electronics, 2:25-cv-00960 (E.D. Tex., filed 2025-09-18, Judge Gilstrap, open) asserting claims 1, 2, 4–9, 11–13 of '596 against "Accused TV Remotes" and "Accused Apps." No IPR has yet been filed in connection with either case, and no CAFC appeal of any PTAB decision exists for this patent (there is no PTAB decision to appeal).

Strategic summary

Claim-by-claim status: all 20 claims (1–20) are UNTESTED at the PTAB. No claim of '596 has been canceled, no claim has been sustained in a Final Written Decision, and no institution decision — grant or denial — has ever been entered for this patent. Independent claims 1, 8, and 14 (device, medium, and wireless-circuitry forms of the voice-command/output-device concept) and all dependent claims 2–7, 9–13, and 15–20 remain exactly as issued on 2018-12-25. The only "narrowing" events in the patent's history are prosecution-side: the continuation chain back to the 2000 provisional and the 2016 continuation filing that produced the '596 itself.

Estoppel landscape — clean slate for any petitioner. Because no AIA trial has ever been instituted against this patent, § 315(e)(2) estoppel binds no one. A defendant sued today (e.g., in the LG case) is free to raise every ground available: § 102 anticipation, § 103 obviousness, and § 112 written-description/indefiniteness, over any prior art — including art that post-dates the 2000 priority date but predates the 2016 filing, a gap that matters enormously for this family because claim language was amended and re-presented across the 2001 → 2012 → 2016 continuations. The one timing trap to watch is § 315(b): an IPR petition must be filed within one year of service of a complaint asserting the patent. For the LG matter (filed 2025-09-18), that deadline is fast approaching — a would-be petitioner cannot afford to wait for an institution decision in someone else's case.

Pattern signals. No repeat petitioner exists for this patent (zero petitions). Flexiworld has, however, been a frequent district-court assertor (Sony, LG, Hisense, Lexmark matters), and the PTAB's 2023 denial of institution in IPR2023-00845 on a sibling patent shows the Board will engage with — and reject — weak Flexiworld challenges. There is no defensive-aggregator chain (e.g., Unified Patents) on this patent; Unified's only Flexiworld activity is the separate RE48,066 reexamination. The absence of any IPR after two-plus years of active assertion (Sony 2023, LG 2025) is itself a mild signal: either no defendant has yet identified strong enough art, or defendants are holding fire pending the LG case's claim-construction posture. It is not evidence the patent is strong — it is evidence the patent has not been tested.


Recommended next steps

  • If you are the defendant in the LG case (or expect a demand letter): there is no PTAB decision to cite because none exists. Do not let anyone represent otherwise. Your realistic PTAB path is a de novo IPR petition — and § 315(b) means the one-year clock from service of the LG complaint is your hard deadline. Prioritize prior art dated 2000–2015 to attack the continuation-added claim language (the 2012 and 2016 filings are the weak underbelly of this family; art between the 2000 priority date and those filings defeats the "new matter" claim scope without being barred).
  • Run a pre-petition search now, not later: the § 112 and § 103 angles on independent claims 1, 8, and 14 (e.g., "receiving data or component from the output device in response to having sent the information," and the voice-command-plus-audio-transmission limitation) have never been litigated at the Board. The claim charting in IPR2023-00845 (against the sibling '402 patent) is publicly available and shows how the Board evaluates Flexiworld's wireless-output claim language — a useful template, not a bar.
  • Verify maintenance-fee status before spending money: Google Patents flags an "Expired – Fee Related" notation with adjusted expiration 2022-10-01. That field is not authoritative. Confirm the fee status and any terminal-disclaimer/reissue activity in USPTO Patent Center/PAIR before investing in a petition — a dead patent needs no IPR.
  • Monitor the LG docket (2:25-cv-00960, E.D. Tex.) for the court's claim-construction order; if LG or a co-defendant files an IPR, the PTAB will likely be the first tribunal to construe these claims, and that construction will drive settlement leverage in the district case.
  • If you are evaluating the patent for acquisition or licensing: the "no IPR ever filed" posture cuts both ways — it means no adverse PTAB record exists to cite in renegotiation, but it also means the patent has no track record of surviving scrutiny. Treat the patent's validity as fully open, and price it accordingly.

Bottom line, stated plainly: there are no PTAB proceedings on U.S. Patent No. 10,162,596 — none filed, none instituted, none decided, none appealed. All 20 claims stand as issued, untested and unhardened, and the PTAB door is open to any defendant who moves before the § 315(b) one-year bar closes.

Generated 8/28/2026, 12:47:30 PM

Ownership chain (1)

Asserters network →

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

  1. ? · recorded 2016-09-21 · Assignment

    William Ho Chang; Christina Ying LiuFlexiworld Technologies, Inc.

    acquisition

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

Ownership chain analysis — US Patent 10,162,596 (US10162596B2)

Scope note on sources. USPTO's live Assignment Center could not be queried directly within this session's search budget. The chain-of-title facts below are drawn from the Google Patents legal-events feed for this patent (fetched 2026-08-28), the patent's own front page, and litigation documents (Epson answer admissions citing sibling-family reel/frames). Where a reel/frame could not be retrieved, I say so explicitly rather than reconstructing it. Verify final numbers at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (legacy mirror: https://assignment.uspto.gov/patent/index.html).


Inventors

Inventor Residence on the '596 patent Employer at time of filing (determinable)
William Ho Chang Vancouver, WA Flexiworld Technologies, Inc. — Chang is the founder and president of Flexiworld (founded 2001, the same year the original application 10/016,223 was filed). Prior employers: Sharp Laboratories (Inventor of the Year 1999), Amiable Technologies (acquired, NASDAQ:SVECF), Intergraph.
Christina Ying Liu Vancouver, WA (later San Francisco, CA in family filings) Flexiworld Technologies, Inc. — Liu is the co-inventor on the entire Flexiworld wireless-output family and co-assignor with Chang; she appears alongside Chang on dozens of family patents. Her independent employment history is not documented in the sources retrieved.

Pattern check: Both inventors are the principals of the original assignee (founder + co-inventor), not departing employees. The "all inventors leave within 12 months" precursor to a portfolio fire-sale is not present.


Original assignee

  • Entity named on the issued patent: Flexiworld Technologies, Inc., Vancouver, WA.
  • Line of business: Founded 2001 as a seed-funded software startup; developed the "FlexiCore" wireless-printing/output technology infrastructure ("print to ALL printers of ALL brands" from mobile devices, wireless presentation control, etc.).
  • Products embodying the claims: No evidence found of a commercial product shipped by Flexiworld embodying the voice-activated wireless-output claims. The company's current public footprint (its own executive bio) emphasizes patent counts, consulting to "listed technology companies" in the US and chip companies in Taiwan/China, and licensing — not product sales.
  • Current status: Operating/active as a legal entity (Crunchbase lists "Active"; the company website remains up), but its observable activity is patent assertion — it is the plaintiff in the Sony (2:23-cv-00616, E.D. Tex.), LG (2:25-cv-00960, E.D. Tex., open), and Epson litigations and has faced an IPR (Roku, IPR2022-01267, on sibling US9836257). Notably, in October 2020 Chang restructured a German entity as Flexiworld Technologies GmbH, Munich, whose stated corporate purpose is the "development, purchase, sale, holding, licensing and/or management of intellectual property, particularly patents" (German commercial register, HRB entry). That GmbH is not a recorded USPTO assignee of the '596 patent; it is context for how the founder organizes IP monetization.

Assignment timeline

Finding: the USPTO/Google Patents record for US10162596 shows exactly ONE recorded conveyance. There are no recorded post-issuance assignments — no transfer to an LLC, no security agreement, no merger. This is itself a finding: the original assignee still owns the patent.

  • Executed: not retrieved in this session / recorded 2016-09-21 — Reel not retrieved in this session (Google Patents legal-events feed for this patent does not display the reel/frame; sibling-family reel/frames recorded at 042385/0202, 043675/0454, and 046519/0534 per Epson's admissions suggest the family's recordations cluster in the 2018–2019 reel range, but I will not assign a number to this patent without a source)
    • Conveyance: Assignment of Assignor's Interest (recorded against application 15/201,194, filed 2016-07-01; this is the standard re-recordation of the inventors' assignment onto a continuation application — the underlying assignment was originally executed in connection with the Nov. 1, 2001 filing)
    • Assignor: William Ho Chang; Christina Ying Liu
    • Assignee: Flexiworld Technologies, Inc. (Vancouver, WA)
    • Correspondent: not retrieved in this session — no correspondent name is visible in the sources available, so the repeat-correspondent analysis cannot be performed from the recorded chain.
    • Context: original inventor-to-company assignment (internal chain-perfecting recordation on a continuation; ownership never left the original assignee).

Timeline diagram

timeline
    title Ownership of US 10162596
    2000 : Provisional filed Nov 1
    2001 : US application filed
    2016 : Inventors assign to Flexiworld
    2018 : Patent issued Dec 25
    2023 : Sony suit filed ED Tex
    2025 : LG suit filed ED Tex

NPE / troll-pattern signals

  1. Shell-entity transfer — NOT PRESENT. No assignment ever moved the patent from an operating company to a licensing-only LLC; the chain contains a single inventors→Flexiworld conveyance. Flexiworld Technologies, Inc. is the original assignee, not a transferee. (Context only: the founder separately formed Flexiworld Technologies GmbH in Munich in 2020 with an IP-licensing purpose — but that entity never appears in this patent's USPTO chain of title.)

  2. Known asserter in the chain — PRESENT (weak-to-moderate). Flexiworld is not on the enumerated classic list (Acacia, Marathon, IV, Wi-LAN, etc.), but it is exactly the "high-frequency plaintiff" profile the checklist contemplates: it asserts this same continuation family serially against Sony (2:23-cv-00616), LG (2:25-cv-00960, still open), and Epson, and the Unified Patents litigation dataset linked from this patent's own Google Patents page flags both E.D. Tex. cases. The asserter is the original assignee itself rather than a transferee, which weakens the classic chain-of-title version of this signal.

  3. Repeat correspondent across the chain — UNKNOWN. Only one recorded conveyance exists and its correspondent was not retrievable in this session. No recurrence analysis is possible.

  4. Cascading transfers — NOT PRESENT. No chained LLC transfers in any time window; the chain is static.

  5. Pre-litigation transfer — NOT PRESENT. No assignment of any kind precedes the 2023 or 2025 infringement suits; ownership has been constant since the 2016 recordation (and in substance since 2001). Venue/standing were not arranged via the recorded chain.

  6. Bankruptcy fire-sale — NOT PRESENT. Flexiworld has no Chapter 7/11 proceeding in the record, and no patents were sold out of a bankruptcy.

  7. Privateering — NOT PRESENT. No operating company transferred the patent to an NPE to assert against its competitors; Flexiworld asserts in its own name.

  8. Defensive aggregator (anti-NPE) — NOT PRESENT. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. Inverse signal: the patent is not neutralized; it remains an active enforcement asset (LG case pending; IPR2022-01267 by Roku on sibling US9836257 shows the portfolio is being fought, not aggregated).


Verdict

NPE — moderate confidence.

The recorded chain shows no shell transfers, no cascades, and no pre-suit transfer — the classic chain-of-title NPE architecture is absent, and Flexiworld Technologies, Inc. has owned the patent continuously since the 2016 recordation of the inventors' assignment. However, the sole owner is a seed-funded, founder-controlled company with no demonstrated products embodying the claims, that behaves as a serial high-volume plaintiff (Sony 2:23-cv-00616; LG 2:25-cv-00960; Epson) and whose founder organized a Munich entity in 2020 whose stated purpose is IP licensing and management. That is one moderately strong signal (repeat asserter with no product base) plus supporting context, but the single-record chain and the absence of any known-list match keep this below high confidence. A live USPTO Assignment Center query (by patent number 10162596) is the recommended verification step to capture the reel/frame and correspondent that this session could not retrieve.

Verification links: https://assignmentcenter.uspto.gov/ · https://assignment.uspto.gov/patent/index.html · https://patents.google.com/patent/US10162596/en

Generated 8/28/2026, 12:48:31 PM

Prior art

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

✓ Generated

I'll research the prior art citations for US Patent 10,162,596. Let me start by searching for the patent's cited references.

Let me search more specifically for the cited references on the patent record.

Let me search for the specific citations listed on the patent record from other patent database mirrors.

I reached the search-step limit before I could pull the complete USPTO front-page "References Cited" list for US10162596B2, so I want to be transparent about what is confirmed versus what needs verification. Here is the analysis based on the record I could access.


Prior Art Analysis — U.S. Patent No. 10,162,596 B2

Methodology and data caveat

The Google Patents full-text fetch provided in the working file does not include the front-page "References Cited" (the text jumps from the abstract/classifications to the definitions and description). My live searches were rate-limited before I could retrieve the complete examiner citation list from USPTO Patent Center (application 15/201,194) or Global Dossier.

What I can confirm from live search results:

  • US 6,748,195 B1 has a confirmed citation relationship with US10162596B2 (Google Patents lists US10162596B2 among documents citing US6748195B1).
  • The Flexiworld sibling publications (US 2002/0051200 A1, US 2002/0059415 A1, US 2002/0055984 A1) and the parent patents in the '596 priority chain (US 7,941,541 B2 → US 8,332,521 B2 → US 9,383,956 B2) are confirmed real publications with the dates shown below.
  • The '596 specification itself discloses (in the section quoted in the working file) that output "may be initiated by various means, such as by using a soft key, push button, keyboard, keypad, mouse, stylus, software GUI, command or voice activated command," which is the anchor for the voice-command element of the claims.

Bottom line up front: the strongest anticipatory disclosures for claims 1, 8, and 14 are the same-family 2001 Flexiworld publications — which are the closest art but carry a significant §102 qualification problem (common ownership and effective filing dates at/after the '596 priority date). The strongest third-party reference confirmed in my search is US 6,748,195 B1. For a complete, citable list of every examiner-cited reference, the definitive source is the front page of the patent and USPTO Patent Center/Global Dossier for application 15/201,194.


Confirmed third-party reference

US 6,748,195 B1 — Phillips et al., "Wireless device having context-based operational behavior"

Field Value
Full citation US 6,748,195 B1, Phillips et al., "Wireless device having context-based operational behavior," assigned to Intel Corporation
Filing date September 28, 2000
Issue date June 8, 2004
Confirmed as cited Yes — Google Patents' page for US6748195B1 lists US10162596B2 among documents citing it (https://patents.google.com/patent/US6748195B1/en)

Brief description: A wireless device (e.g., a mobile phone, PDA, or handheld) that determines its operational context — including its physical location and the presence of other devices in its environment — and automatically changes its operational behavior based on that detected context. This is directly relevant to the "within physical proximity / based on physical distance" detection-and-connection framework of claims 8 and 14.

Potential §102 anticipation assessment:

  • Claim 8 (steps 1–2) and claim 14 (steps 1–2): the proximity-based wireless detection and connection of an output device — Phillips is potentially strong on these elements (wireless device detecting nearby devices/context and acting on it). Partial.
  • Claims 1, 8, 14 as a whole: Phillips does not appear to disclose the full sequence of (i) a user indication via an interface with at least one button/control, (ii) sending information related to that indication, (iii) receiving data/component back from the output device, (iv) a voice-activated command via a microphone, and (v) transmitting audio/sound data related to that command. Phillips is therefore better characterized as a §103 combination reference for the proximity-detection elements than a standalone §102 anticipator of any full independent claim.

Same-family disclosures (the closest art; §102 qualification caveat applies)

These are the 2001–2012 Flexiworld filings that define the pervasive-output disclosure from which '596 descends. They were cited in this family's prosecutions and are the references the '596 claims had to clear. Note that the '596 patent claims benefit back to Provisional 60/245,101 (Nov. 1, 2000), so pre-AIA §102 governs (the application's effective filing date precedes March 16, 2013).

1. US 2002/0051200 A1 — Chang, "Controller for device-to-device pervasive digital output"

Field Value
Full citation US 2002/0051200 A1 (Chang, William Ho), "Controller for device-to-device pervasive digital output," application 10/003,594
Filing date October 31, 2001
Publication date May 2, 2002
Priority November 1, 2000 (60/245,101) — same provisional as '596

Brief description: Discloses an output controller connected to or integrated within an output device (printer, display, projector, audio device) that wirelessly communicates with a portable information apparatus. The controller negotiates services, identifies and uploads device-dependent software components/drivers/data to the apparatus so the apparatus can drive the output device without pre-installed drivers, and supports output initiated by various means including voice-activated commands. This is the mirror-image disclosure to the '596 claims, which are drafted from the portable-device side.

Potential §102 anticipation assessment: This is the single closest disclosure to claims 1, 8, and 14. It maps well onto: wireless connection within proximity; user indication via interface (buttons/soft keys disclosed); sending information to the output device; receiving data/component (driver/software) back from the output device in response; and voice-activated command initiation. The element most at risk of being missing is the final "wirelessly transmit audio/sound data to the output device related to the voice command" limitation of claims 1 and 14 — the 2001 disclosure is oriented to outputting documents/content rather than streaming voice-command-derived audio. Strong partial anticipation candidate for claims 8 and 14 (steps 1–4) and for claim 1 (steps 1–3); weaker on the voice-command-audio transmission element.

2. US 2002/0059415 A1 — Chang, "Manager for device-to-device pervasive digital output"

Field Value
Full citation US 2002/0059415 A1 (Chang, William Ho), "Manager for device-to-device pervasive digital output," application 10/000,732
Filing date October 31, 2001
Publication date May 16, 2002
Priority November 1, 2000 (60/245,101)

Brief description: Discloses the output manager (client-side software) residing in an information apparatus that performs wireless discovery of output devices, service negotiation, synchronization/upload of software components from the output controller, and generation of output data. It is the complementary client-side disclosure to the controller reference above.

Potential §102 anticipation assessment: Same analysis as US20020051200A1, viewed from the information-apparatus/output-manager side. Potentially strongest against claim 8 (the medium claim covering detection, connection, indication, receipt of information, and voice command) and the proximity/connection portions of claim 14. Same weakness on the voice-command-audio-transmission limitation.

3. US 2002/0055984 A1 — Chang, "Method for device-to-device pervasive digital output"

Field Value
Full citation US 2002/0055984 A1 (Chang, William Ho), "Method for device-to-device pervasive digital output," application 10/016,630
Filing date November 1, 2001
Publication date May 9, 2002
Priority November 1, 2000 (60/245,101)

Brief description: The method-counterpart of the pervasive output process — discovery, service negotiation, synchronization, and output — the same process later encoded in the '596 claims from the portable-device perspective.

Potential §102 anticipation assessment: Similar to the two references above; a method disclosure, so it maps conceptually onto the ordered steps of claims 8 and 14 but does not by itself disclose a portable electronic device or wireless communication circuitry as statutory subject matter for claims 1 and 14.

4. US 7,941,541 B2 — Chang, "Wireless data output method for rendering digital content accessed from a mobile information apparatus"

Field Value
Full citation US 7,941,541 B2 (Chang, William Ho), "Wireless data output method for rendering digital content accessed from a mobile information apparatus," application 10/016,223
Filing date November 1, 2001
Issue date May 10, 2011
Priority November 1, 2000 (60/245,101)

Brief description: The direct ancestor of '596 in the continuation chain. Discloses a mobile information apparatus that wirelessly discovers an output device, wirelessly receives components (drivers/data) from the output device, and renders/outputs digital content without pre-installed device drivers. This is the embodiment from which '596's disclosure is directly carried forward.

Potential §102 anticipation assessment: As the immediate parent, it is the most complete single-family disclosure of the wireless-discovery/component-receipt/output framework. Potentially anticipatory of claim 8's full step sequence except the voice-command element (which was added/emphasized in later continuations), and of claims 1 and 14's handshake steps. Same caveats as above regarding the voice-command-audio limitation.

5. US 8,332,521 B2 — Chang, "Internet-pad specification…" (intermediate parent, 12/903,048)

Field Value
Full citation US 8,332,521 B2 (Chang, William Ho), "Internet-pad specification…" (touch sensitive screen, digital camera, e-mail, wireless connectivity, digital content application, API-supporting OS)
Filing date October 12, 2010 (per patent text; some databases list Dec. 2012 as issue date)
Issue date December 11, 2012
Priority November 1, 2000 (60/245,101)

Brief description: Discloses the portable internet-pad/smart-phone device specification, including the touch-sensitive screen interface and wireless connectivity that underpin the "interface with at least one button or other controls" and "wireless communication circuitry" limitations of claims 1, 8, and 14.

6. US 9,383,956 B2 — Chang, "Smart phones that include touch sensitive screen and supporting voice activated commands for managing or replying to E-mails" (immediate parent, 13/710,295)

Field Value
Full citation US 9,383,956 B2 (Chang, William Ho), application 13/710,295
Filing date December 10, 2012
Issue date July 5, 2016
Priority November 1, 2000 (60/245,101)

Brief description: The immediate parent of '596. Adds explicit voice-activated command support (microphone + speech recognition) on a touch-screen smart phone, including wireless management of output. This is the reference that most directly bridges the family's pervasive-output disclosure to the voice-command features that are the centerpiece of the '596 title and abstract.

Potential §102 anticipation assessment: Along with US20020051200A1, this is the closest disclosure to the voice-command + wireless-output combination of claims 1, 8, and 14. It discloses the microphone, the touch/button interface, the wireless circuitry, and voice-command control — but its stated focus is managing/replying to e-mails on the phone itself, so the "transmit audio/sound data to the output device related to the voice command" element again is the limitation most likely absent.


§102 qualification caveat for all same-family references

Because '596 is a continuation claiming benefit to November 1, 2000, and because the references above are (a) commonly owned by Flexiworld Technologies/Chang and (b) have U.S. filing dates (Oct. 31 / Nov. 1, 2001 or later) that are not before the '596 priority date, their qualification as §102 prior art against the '596 claims is doubtful under both pre-AIA §102(e) and AIA §102(b)(2)(C) (commonly-owned subject matter exclusion). In practice, these references function as the primary §103 obviousness combination anchors and as the disclosure the applicant distinguished over during prosecution — not as clean §102 anticipators. US 6,748,195 B1 is the one reference in my confirmed set with a genuine third-party, pre-priority-date status (filed September 28, 2000, before Nov. 1, 2000), making it the strongest bona fide §102 candidate — but it lacks the full claim combination, so it more realistically supports §103.


Claim-by-claim summary of anticipation potential

Claim(s) Strongest reference(s) Element most at risk of being missing in the art
1 (portable device) US 2002/0051200 A1; US 9,383,956 B2; US 7,941,541 B2 "wirelessly transmit audio/sound data … related to the voice command"
8 (medium, proximity detection) US 2002/0059415 A1; US 2002/0051200 A1; US 6,748,195 B1 (proximity portion) voice-command control of the connected device; audio transmission
14 (circuitry, physical distance) US 2002/0051200 A1; US 6,748,195 B1 (proximity portion) "transmit audio/sound data … after receiving voice-activated command"
2–7, 9–13, 15–20 (dependents: Bluetooth/IEEE 802.11 chipsets, smart phone/digital pad, TV/projector/audio/display output devices, component/attribute/UI/status data) Bluetooth and IEEE 802.11 standards (background art in the spec); US 2002/0051200 A1 (communication units, output device types); US 7,941,541 B2 dependent limitations largely disclosed in the family; the voice-command-audio element remains the recurring gap

Recommended verification steps

Because my search budget ran out before retrieving the complete examiner citation list, the following should be pulled directly for the definitive record:

  1. USPTO Patent Center — application 15/201,194 (or Patent Center's "references cited" tab) for the exact front-page citation list, including any third-party references beyond US 6,748,195 B1.
  2. WIPO Global Dossier / USPTO file wrapper — for the examiner's reasons for allowance and any §102/103 rejections overcome during prosecution of 15/201,194, which will show which references the examiner treated as most relevant.
  3. Google Patents' "Patent Citations" section for US10162596B2 (https://patents.google.com/patent/US10162596B2/en) — to confirm the complete cited list.

If any additional references surface there (e.g., Bluetooth/IrDA standard documents, or third-party voice-control/remote-control patents), the §102 analysis for the voice-command-audio-transmission limitation should be revisited — that limitation is the one element for which the confirmed references are weakest.

Generated 8/28/2026, 12:49:26 PM

Obviousness

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

✓ Generated

Obviousness Analysis — U.S. Patent No. 10,162,596 (US10162596B2) under 35 U.S.C. § 103

0. Scope, sourcing, and confidence caveats

The fetched Google Patents text supplied for this patent does not include the "Prior Art" / "Citations" section (the fetched HTML dropped the cited-reference table). I therefore retrieved the USPTO face-of-patent reference list from the uspto.report record for grant 10162596. That search returned a partial list of U.S. patents cited during prosecution (truncated at 5,862,321). I can confirm the existence of those citations, but I could not retrieve the full list (the remainder of the U.S. citations, foreign patents, and non-patent literature) or the full text of each cited patent. Where I describe the content of a specific cited patent, I flag my confidence; where I cannot verify content, I say so rather than fabricate. The element-by-element mapping below therefore combines (a) the confirmed cited references, and (b) well-documented, high-confidence state-of-the-art knowledge as of the priority date (Nov. 1, 2000).

The claims are analyzed from the plain-language summaries in the previously generated sections of this analysis (claims 1, 8, and 14; dependent claims 2–7, 9–13, 15–20), which I treat as authoritative.


1. Legal framework and applicable law

  • Pre-AIA § 103 applies. Although the '596 patent issued in 2018 from an application filed July 1, 2016, it is a continuation in a chain reaching back to application 10/016,223 (filed Nov. 1, 2001) and Provisional 60/245,101 (Nov. 1, 2000). Because the chain began before March 16, 2013, the pre-AIA version of § 103 governs. For prior-art purposes, the claims are entitled to the Nov. 1, 2000 priority date (assuming written-description support in the earlier disclosures, which is the normal posture for this family).
  • Consequence: a reference must have been prior art before Nov. 1, 2000 to qualify. Every confirmed citation in the partial list is dated 1996–1999, so all qualify under pre-AIA § 102(b).
  • Graham framework: (1) scope and content of the prior art; (2) differences between the prior art and the claims; (3) level of ordinary skill; (4) secondary considerations.
  • KSR v. Teleflex (2007): a flexible, common-sense inquiry. A combination of known elements is obvious if it yields predictable results, if there was a design need or market pressure to solve a known problem, or if the combination was "obvious to try" among a finite number of identified, predictable solutions. No rigid teaching-suggestion-motivation test.

Person of ordinary skill in the art (PHOSITA): a designer with a B.S. or equivalent in electrical/computer engineering, roughly 2–4 years of experience in wireless communications (Bluetooth/IrDA/802.11), embedded systems, mobile-device user interfaces, and device-driver/printing architectures — i.e., the kind of engineer who built the Palm, early Bluetooth phones, and 1990s handheld printing solutions.


2. The record prior art (confirmed citations)

The confirmed partial list from the USPTO record (uspto.report, grant 10162596) includes, in order: 5,490,287 (Itoh); 5,515,480 (Frazier); 5,519,641 (Beers); 5,524,185 (Na); 5,537,107 (Funado); 5,537,517 (Wakabayashi); 5,546,079 (Wagner); 5,564,109 (Snyder); 5,566,278 (Patel); 5,568,595 (Yosefi); 5,580,177 (Gase); 5,589,889 (Kawaoka); 5,596,697 (Foster); 5,604,843 (Shaw); 5,613,123 (Tsang); 5,613,124 (Atkinson); 5,619,257 (Reele); 5,619,649 (Kovnat); 5,625,757 (Kageyama); 5,629,981 (Nerlikar); 5,636,211 (Newlin); 5,644,662 (Vuylsteke); 5,664,243 (Okada); 5,675,717 (Yamamoto); 5,687,332 (Kurahashi); 5,699,495 (Snipp); 5,710,557 (Schuette); 5,717,742 (Hyde-Thomson); 5,724,106 (Autry); 5,737,501 (Tsunekawa); 5,739,928 (Scott); 5,748,859 (Takayanagi); 5,754,655 (Hughes); 5,757,952 (Buytaert); 5,761,480 (Fukada); 5,796,394 (Wicks); 5,802,314 (Tullis); 5,822,230 (Kikinis); 5,826,244 (Huberman); 5,831,664 (Wharton); 5,832,191 (Thorne); 5,838,320 (Matthews III); 5,838,926 (Yamagishi); 5,845,078 (Tezuka); 5,852,721 (Dillon); 5,859,970 (Pleso); 5,862,321 (Lamming) — truncated there.

Three observations about this record:

  1. The list is a dense cluster of 1996–1999 wireless-communication, mobile-computing, printing/driver, and document-distribution patents. That clustering is itself evidence that the examiner (and the family's long prosecution) treated the claimed subject matter as built from known, interchangeable components.
  2. The patent's own specification describes the "known problems" the combination solves — burdensome pre-installation of device-specific drivers, mobile devices' small displays, cost/reliability/security drawbacks of network printing, and the desirability of local communication between the information apparatus and the output device (spec. sections "Conventionally, an output device (e.g., a printer) is connected…," "network printing may partially solve…," "another drawback of network printing is…"). These are the classic motivations a PHOSITA would have had to combine wireless proximity communication with on-demand component download.
  3. The specification itself lists voice-initiated output as a known initiation means ("The output may be initiated by various means, such as by using a soft key, push button, keyboard, keypad, mouse, stylus, software GUI, command or voice activated command, etc.") — a contemporaneous acknowledgment that voice activation was a known input modality for output processes.

3. Claim element analysis (independent claims 1, 8, 14)

The three independent claims are apparatus (1, 14) and medium (8) variants of the same concept. Synthesizing them:

Element Claim 1 (portable device) Claim 8 (medium) Claim 14 (wireless circuitry)
Device/circuitry portable electronic device; interface with ≥1 button/controls; microphone; wireless communication circuitry portable device w/ microphone, interface, wireless circuitry; stored instructions wireless communication circuitry for use in a portable device supporting voice commands
Proximity connection "subsequent to establishing, within a physical proximity, a wireless connection to the output device" "wirelessly detect an output device based on physical proximity; wirelessly connect" "detect a wireless output device based on physical distance; connect"
Indication receive user indication via interface relating to managing/driving output device receive user indication via interface (implied)
Send wirelessly send information to output device related to the indication (implied by instruction set) send first information to the device
Receive back wirelessly receive data or component from output device in response wirelessly receive information/data from output device in response receive second information from the device in response
Voice configured to receive voice-activated commands via microphone receive voice-activated command via microphone for controlling/managing/driving the connected device after the portable device receives a voice-activated command, transmit audio/sound data related to the command
Output device TV, TV-connected controller, printer, audio output device, or projector same class same class

The distinctive, claim-defining combination is: short-range/proximity wireless link to a local output device → button/control indication → send → receive a data/component back (a handshake/synchronization) → then voice command → audio/sound data transmitted to the same device. The invention is essentially "a wireless remote/controller for an output device that (a) performs a two-way setup exchange with the device and (b) also accepts voice commands and streams the corresponding audio to the device."


4. Obviousness combinations and motivation to combine

Combination A — Wireless pervasive output (discovery + on-demand component download) + voice-activated command

References:

  • Primary (pervasive output / two-way sync): the wireless printing and document-distribution art cited on the face of the patent — e.g., Lamming, 5,862,321 (Xerox; portable access to and distribution of electronic documents; moderate confidence in content from training data — it is the kind of Xerox proximate-printing/document-distribution reference that maps to discovery of a nearby output device), Kikinis, 5,822,230 (mobile/wireless computing; moderate confidence — Kikinis's Elonex portfolio covers portable computing with wireless links), and the other printing/driver references in the 5.5–5.8 million range (e.g., 5,748,859 Takayanagi; 5,832,191 Thorne; 5,838,320 Matthews III — content not verified).
  • Secondary (voice): voice-recognition/voice-command art known by 2000 — Dragon NaturallySpeaking (1997), IBM ViaVoice (1997), automotive voice dialing, and voice-activated TV/consumer-device remotes. High confidence in the state of the art; the specific cited patent in this record is not identifiable from the partial list.

Element mapping (claim 1):

  • Portable device with interface (buttons) + microphone + wireless circuitry: taught by any late-1990s handheld (Palm-class device, smart phone, wireless remote) with a button interface; adding a microphone was conventional.
  • Proximity wireless connection to output device: taught by the pervasive-output references (Bluetooth/IrDA local links) and by Bluetooth 1.0 (July 1999), which is built around 10-meter piconets and device discovery (high confidence).
  • Indication → send info → receive data/component in response: taught by the driver-on-demand/pervasive-output art — the very concept the '596 specification describes as "synchronization," and which the prior art (including the cited printing patents and Microsoft "Point and Print," 1996) already applied to networked printers; applying the same download-on-demand to a local wireless link was the natural extension the specification itself identifies as the problem to be solved.
  • Voice command via microphone → transmit audio to the output device: taught by voice-command references (voice-controlled phones/remotes) plus the audio-output-device art (TV/speaker/projector control).

Motivation: The specification's own problem statement supplies the motivation. A PHOSITA designing a mobile device that outputs to nearby printers/displays in 1999–2000 knew (i) users disliked manual driver installation, (ii) local wireless exchange was more secure/reliable than network printing, and (iii) voice was an established hands-free input modality for phones and consumer electronics. Combining a wireless on-demand component-download scheme with a microphone and voice recognition is the predictable use of known elements to solve the known problem of cumbersome mobile output — squarely within KSR's "predictable results" and "design need" rationales.


Combination B — Short-range wireless (Bluetooth/802.11) + Point-and-Print-style driver/component download + voice control

References:

  • Bluetooth 1.0 Specification (July 1999) — discovery, pairing, 10 m piconets (high confidence); IEEE 802.11 (1997/1999) (high confidence).
  • Microsoft Point-and-Print / network printer-driver download (1996) and the printer-driver art in the cited list (high confidence in the concept; individual cited patents' contents not verified).
  • Voice-command art as in Combination A.

Element mapping (claim 8, the medium claim with explicit discovery/connection steps): the instructions to (1) wirelessly detect an output device based on physical proximity, (2) connect, (3) receive a user indication, (4) receive information from the device in response, and (5) accept a voice command — map onto Bluetooth device discovery (steps 1–2), a user selecting a device (step 3), the device returning identity/attribute/UI/status data (step 4), and a voice-recognition module (step 5). Each step was individually old; the claim is a software recitation of the same combination.

Motivation: Bluetooth's own design goals were "cable replacement" for phones, headsets, and peripherals — including printing and AV control. A PHOSITA building a Bluetooth phone/remote with voice dialing (already known) would naturally extend voice control to drive a connected TV, projector, speaker, or printer, and would reuse the network printer's known driver-download mechanism over the local link to avoid driver installation. The result (a voice-enabled wireless remote that handshakes with the output device before/while controlling it) is the predictable integration of three mature technologies.


Combination C — Voice-enabled wireless remote control + output device (TV/audio/projector) with bidirectional data exchange

References:

  • Wireless/IR/RF TV remote controls with microphones and voice recognition (1990s voice-remote products) (moderate-high confidence in state of the art; specific patents not confirmed).
  • The "controller connectable to a television" and audio-output-device art reflected in the cited list and in the family's own later publications.
  • On-demand component download art as above.

Element mapping (claim 14, circuitry claim): circuitry that detects a nearby output device, connects, sends first information, receives second information in response, and — after a voice command — transmits audio/sound data. This maps onto a Bluetooth/802.11 radio plus a voice-command path in a remote/phone. The "receive second information in response" element is the only non-rote part; it is taught by the device-attribute/status exchange that was standard in discovery protocols (Bluetooth SDP, UPnP, Salutation, Jini — the last three are named in the '596 specification itself as known protocols).

Motivation: the market pressure to replace IR remotes with RF/BT remotes (no line-of-sight), and the consumer desire for hands-free TV/audio control; combining a back-channel for device data with voice control was an obvious enhancement to any "smart" remote.


5. Graham-factor assessment

  • Scope and content of prior art: Extensive. By Nov. 2000 the PHOSITA had: Bluetooth/IrDA/802.11 short-range links; handheld devices with microphones and voice recognition; wireless printing from handhelds (demonstrated by Ericsson/IBM and others in 1999–2000); driver-download-on-demand (Point and Print); and voice-controlled consumer devices. The examiner's cited-reference list (1996–1999 cluster) corroborates that all building blocks predate the invention.
  • Differences: The claims add a specific ordering (proximity connection → indication → send → receive component back → voice command → transmit audio). The genuinely limiting differences are (i) the two-way "receive data/component in response to sending information" handshake with a local output device, and (ii) voice commands tied to driving that specific connected device with audio streamed to it.
  • Level of skill: moderate; the combination would have been within the ordinary capability of a wireless-systems engineer in 2000.
  • Secondary considerations: No evidence in this record of long-felt need, industry skepticism, or unexpected results. The commercial success of voice assistants/smart speakers is post-priority-date evidence that does not retroactively prove non-obviousness of a 2000 concept. Litigation activity (E.D. Tex. cases against Sony and LG) is not evidence of non-obviousness; it merely reflects enforcement.

6. Weaknesses in the obviousness case (counterarguments)

  1. The handshake/synchronization element. The strongest non-rote limitation is "wirelessly receiving data or a component from the output device in response to having sent the information" — i.e., the output device itself supplies a driver/component/attribute set after the portable device initiates contact. A challenger needs a reference that teaches this local, two-way, device-sourced download (not merely a network print server or one-way IR printing). If the cited Lamming/Kikinis/printing references do not, in fact, disclose a device-sourced component download over a short-range link, this element may survive.
  2. Voice command → audio transmitted to the output device. The claims require the voice command to result in audio/sound data being sent to the connected output device (or, in claim 8, the voice command controlling/managing/driving the connected device). Voice-command references that merely recognize speech on the device for local functions do not meet this. The combination requires a reference showing voice-driven control of a remote display/audio device — the voice-remote art is the best fit, but its content must be proven.
  3. Claim 1's ordering ("subsequent to establishing…the portable electronic device is operable for receiving an indication…receiving data or component…[and is] configured to receive voice activated commands") may be read as a claim to a device capable of both modes (setup exchange and voice control), which broadens the claim and makes it more vulnerable — but a narrow reading (voice command must follow the component exchange) is harder to meet with a single reference and requires a solid combination.

7. Conclusions

  • The most plausible § 103 case is Combination A/B: short-range wireless proximity connection (Bluetooth/IrDA/802.11, all pre-2000) + on-demand download of device data/components (Point-and-Print / pervasive-printing art, including the cited 1996–1999 printing and document-distribution patents such as Lamming 5,862,321 and Kikinis 5,822,230) + voice-activated command via a microphone (voice-dialing/voice-remote art). The motivation is the known problem of cumbersome mobile output and the known convenience of hands-free control; the result is a predictable integration of mature components under KSR.
  • Claims 8 and 14 (medium and circuitry) are more vulnerable than claim 1 because they are drafted to the same idea at lower structural specificity, and claim 14's "detect based on physical distance" maps almost verbatim onto Bluetooth discovery.
  • The dependent claims (2–7, 9–13, 15–20) add conventional limitations (Bluetooth/IEEE 802.11 chipsets, smart-phone/digital-pad form factors, TV/projector/audio output devices, executable software, status/UI attribute data) that are individually well-known and would fall with the independent claims or add little non-obvious weight.

Confidence caveats, repeated for emphasis: I verified the existence of the cited references from the uspto.report record, but not their full text; content descriptions for Lamming 5,862,321 and Kikinis 5,822,230 are at moderate confidence from training data, and I could not confirm the content of the other cited patents (Takayanagi, Thorne, Matthews III, Yamagishi, Tezuka, Dillon, Pleso, etc.). A complete element-by-element prima facie case requires reading each reference. The pending LG case (2:25-cv-00960, E.D. Tex.), which asserts claims 1, 2, 4–9, and 11–13 against voice-enabled TV remotes, is the venue where these exact combinations are likely to be tested; the docket should be checked for any § 103 defenses raised.

Generated 8/28/2026, 12:49:48 PM

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