US 10298644

US Patent 10298644 Summary

Title: Instant communications system having established communication channels between communication devices

Assignee: Individual

Inventor: Hong Jiang

Filing Date: November 30, 2015 (Application No. US14/954,693)

Issue Date: May 21, 2019

Abstract: A communication server and accompanying communication devices enable near-instantaneous communication between users. Each communication device can be configured with multiple channels, with each channel assigned to a corresponding communication device. With communication devices registered to the server, they are aware of other registered devices, allowing for nearly instantaneous communication. A single communication device can also host a conference call with other devices. Additionally, the devices feature multiple buttons for control and indicator lights to show call status.

Plain-Language Overview of Independent Claims:

Independent Claim 1:
This claim describes an instant communication device. It has a processor, memory, microphone, speaker, and communication circuitry. The memory stores instructions, and the communication circuitry is connected to a network. The device is configured to:

• Establish communication channels with other communication devices via a server before any calls are placed. These channels are kept alive using minimal signaling messages.
• Allow a user to initiate a call to a connected device by a single action on a user control (like pressing a button) without any call setup delay.
• Automatically play an incoming audio stream from a connected device through its speaker without the user needing to perform an action to pick up the call, and without a ringtone.
• Allow the user to control outgoing or incoming audio streams (or both) separately through user controls, making communication instant and direct, as if users were in the same room.

Independent Claim 10:
This claim focuses on an instant communication system that includes a plurality of communication devices and a communication server, all connected via a network.

• Each communication device has a processor, memory, microphone, speaker, and communication circuitry.
• The system is configured to establish communication channels between the devices prior to any calls, maintaining them with minimal signaling.
• A user can initiate a call to another device with a single user control action (e.g., pushing a button) without call setup.
• Incoming audio streams are automatically played on the receiving device's speaker without a pick-up action or ringtone.
• Users can individually control incoming and/or outgoing audio streams via user controls, enabling instant and direct communication.

Independent Claim 19:
This claim outlines a method for instant communication using an instant communication device connected to a server and other devices. The method involves:

• Establishing communication channels with other devices before calls are placed and maintaining them with minimal signaling.
• Initiating a call to a connected device in response to a single user action on a user control, without call setup.
• Automatically playing an incoming audio stream from a connected device through a speaker without a pick-up action or ringtone.
• Allowing separate control of incoming and/or outgoing audio streams through user controls, facilitating instant and direct communication.

CAFC 2026 Dockets:

As of April 26, 2026, a search of CAFC 2026 dockets for patent 10298644 did not return any direct listings for this specific patent number. However, the provided patent information indicates that the patent family has litigation in the "Texas Eastern District Court" under case number 2:26-cv-00041. While this is not a CAFC docket, it indicates ongoing litigation at the district court level within the 2026 timeframe. The search results for CAFC cases for 2026 show general patent infringement cases and updates, but no direct match for 10298644. Therefore, there is no authoritative information currently indicating that US10298644 is specifically involved in a case before the CAFC in 2026.

As of April 26, 2026, a search for patent litigation involving US patent 10298644 reveals the following:

Known Litigation:

• Jurisdiction: Texas Eastern District Court
• Case Number: 2:26-cv-00041
• Plaintiff(s): Not specified in the provided patent information.
• Defendant(s): Not specified in the provided patent information.
• Filing Date: Not specified in the provided patent information.
• Outcome or Current Status: Ongoing litigation at the district court level.

The available information from the patent (US10298644B2) explicitly states "Family has litigation" and points to the Texas Eastern District Court case. However, further details regarding the specific plaintiffs, defendants, and filing date are not available within the patent text itself or from the search results. While other litigation cases were found in the search, they do not pertain to US patent 10298644.

Proceedings overview

The USPTO ODP API returns no AIA trial proceedings for US Patent 10298644 as of the most recent ingest. A comprehensive web search also yielded no public records of Inter Partes Reviews (IPR), Post-Grant Reviews (PGR), or Covered Business Method (CBM) reviews having been filed against this patent. Therefore, there are no PTAB proceedings on file, and all claims of US10298644 remain unchallenged by AIA trials. This gives a defendant no immediate PTAB-related leverage, indicating the patent has not yet been subjected to this form of validity challenge.

Strategic summary

As of today, July 31, 2026, all claims (1-20) of US10298644 are currently SUSTAINED in the sense that they have not been challenged or adjudicated by the PTAB in any AIA trial proceeding. There are no claims that have been canceled or invalidated through IPR, PGR, or CBM. The patent has not been narrowed through PTAB proceedings, and its full scope, as granted, is theoretically available for assertion.

Regarding the estoppel landscape, since no AIA trial proceedings have been instituted or concluded, there are no estoppel bars under 35 U.S.C. § 315(e)(2) for any potential petitioner. This means all prior-art grounds (e.g., anticipation under § 102, obviousness under § 103) are still available for a new PTAB petition, should a defendant choose to pursue one. There are no pattern signals to observe, such as multiple filings by the same petitioner or aggressive appeals by the patent owner, as there has been no PTAB activity whatsoever for this patent.

Recommended next steps

Given the absence of any PTAB activity for US10298644, the following steps are recommended:

• If you are a defendant facing assertion of this patent: The lack of PTAB challenges means the patent's validity has not been tested in this forum. This presents both an opportunity and a challenge. You have a "clean slate" to potentially file a new IPR or PGR petition if you identify strong prior art. However, it also means there's no existing PTAB decision to lean on for invalidity arguments.
• Prior Art Search: Conduct a thorough prior art search to identify strong references that could form the basis of an IPR petition. The patent's priority date is May 4, 2012, so prior art predating this date would be relevant.
• Claim Construction Analysis: Perform a detailed claim construction analysis of the asserted claims to identify potential vulnerabilities for an IPR or district court invalidity defense.
• Consider filing an IPR/PGR: If a robust prior art search yields strong references, consider filing an IPR (for § 102/103 grounds) against the patent. This would introduce the first formal challenge to its validity in the PTAB.

The absence of PTAB activity is a noteworthy signal itself; well-asserted patents often become targets for IPRs. This could imply the patent has not yet been aggressively asserted, or that prior art challenges have not been deemed strong enough to pursue in this venue.

Inventors

• Hong Jiang (Individual at time of filing)

Original assignee

The original assignee, as per Google Patents, is "Individual". It is not determinable from the provided information whether "Individual" shipped a product embodying the claims, their primary line of business, or their current status.

Assignment timeline

A search of the USPTO Assignment Center for patent 10298644 shows no recorded assignments for this patent. Therefore, based on the USPTO records, the original assignee, "Individual" (Hong Jiang), is still the current owner of record.

Timeline diagram

timeline
    title Ownership of US 10298644
    2015 : Filed by Hong Jiang
    2019 : Issued to Hong Jiang

NPE / troll-pattern signals

1. Shell-entity transfer — not present
2. Known asserter in the chain — not present
3. Repeat correspondent across the chain — not present
4. Cascading transfers — not present
5. Pre-litigation transfer — not present
6. Bankruptcy fire-sale — not present
7. Privateering — not present
8. Defensive aggregator (anti-NPE) — not present

Verdict

Insufficient data
There are no recorded assignments for US 10298644 on the USPTO Assignment Center. Therefore, it is not possible to determine any NPE or troll-pattern signals. The patent remains assigned to the individual inventor, Hong Jiang, as of the issue date.
(Verification: https://assignmentcenter.uspto.gov/)

Most Relevant Prior Art for US Patent 10298644

As of April 26, 2026, the following prior art references are identified as potentially relevant to US Patent 10298644 based on the patent's own citations. A direct search of the USPTO database for the patent number 10298644 reveals the patent itself and its associated information, including cited prior art. The analysis below focuses on the citations listed within the US10298644B2 patent document.

Cited Patent: US6997014B2

• Full Citation: US6997014B2, titled "Coatings for gemstones and other decorative objects".
• Publication/Filing Date: The provided information for US10298644B2 lists a "Prior art date" of 2012-05-04 and a "Filing date" of 2015-11-30. However, US6997014B2's detailed information indicates its filing date as July 16, 2004, and its issue date as February 14, 2006.
• Brief Description: This patent describes coatings for gemstones and other decorative objects, specifically focusing on coatings that impart desirable color and methods for producing these coatings. It discusses optical interference coatings and highly reflective mirror coatings for enhancing optical properties.
• Potential Anticipation (35 U.S.C. § 102): US6997014B2, as described, pertains to coatings for decorative objects and appears to be entirely unrelated to communication systems or methods. Therefore, it is highly unlikely to anticipate any claims of US Patent 10298644 under 35 U.S.C. § 102. There might be a discrepancy in the provided patent document's "Prior art keywords" or the way this specific reference was extracted for the summary, as its subject matter does not align with the communication system claimed in 10298644. It is possible this citation is an error in the provided context or an irrelevant citation from the original patent.

I'll ground this analysis with targeted searches before drafting the § 103 analysis.

Let me ground a few more candidate references before drafting.

Obviousness Analysis — U.S. Patent No. 10,298,644 (35 U.S.C. § 103)

Prepared: April 26, 2026 (task-stated date; note the platform clock reads 2026‑09‑21 — flagged, not corrected)
Patent: US10298644B2, "Instant communications system having established communication channels between communication devices"
Inventor / Assignee: Hong Jiang / Individual
Priority: 2012‑05‑04 (provisional 61/642,616) → parent filed 2013‑03‑14 (13/804,854) → continuation filed 2015‑11‑30 (14/954,693) → issued 2019‑05‑21

---

0. Bottom line up front

1. The Prior Art section of this page cannot support a § 103 rejection. It lists exactly one reference, US6997014B2, which is directed to coatings for gemstones and other decorative objects. That reference is non-analogous art to an instant voice/video communications device, discloses none of the claim limitations, and supplies no rational underpinning for combination. A § 103 ground built on it would fail as a matter of law.
2. This is not the same as saying the patent is non-obvious. The claims have real prior-art exposure, but the exposure comes from art not listed in the Prior Art section (principally the OMA Push-to-talk-over-Cellular corpus). I supply those combinations below, clearly labeled as supplementary.
3. The strongest § 103 attack targets the independent claims 1, 10 and 19 via OMA PoC "Pre-established Session" + "Automatic Answer Mode" as a primary reference, secondarily combined with full-duplex-over-simplex art and IM-to-voice art.
4. The weakest link for a challenger is the recitation that device-to-device channels are established "before any calls are placed" and kept alive by minimal maintenance signaling — PoC's pre-established session is classically client-to-server, not device-to-device. Whether that survives depends entirely on claim construction, which I cannot fully test from the summary alone.

---

1. Threshold issue: a contradiction between the cited art and the patent's own metadata

The Prior Art section lists:

Searches confirm this reference's actual subject matter: optical-interference and absorbing films on gemstones, deposition methods, heat treatment (e.g., https://patents.google.com/patent/[US6997014](/patent/US6997014) ; https://www.freepatentsonline.com/[6997014](/patent/6997014).html ; https://patents.google.com/patent/[US7137275](/patent/US7137275)#5).

Meanwhile, the same patent page lists its own prior art keywords as "user, communication device, talk, processor, button" (https://patents.google.com/patent/[US10298644](/patent/US10298644)/en). Those keywords belong to US10298644's subject matter, not to US6997014B2.

Flagged contradiction: The single reference in the Prior Art section has zero technical overlap with the patent. This is consistent with a citation/metadata association error rather than a genuine prior-art citation. I will not "auto-correct" the identifier — I will simply report that it is unusable for §§ 102/103 purposes, and that any obviousness ground must be built on other art.

---

2. Governing framework

Statute version. The claims take an effective filing date of 2012‑05‑04, and the immediate parent was filed 2013‑03‑14 — both before the § 3(n)(1) AIA changeover date of 2013‑03‑16. Assuming no claim has an effective filing date on or after that date, pre‑AIA § 103(a) governs. Practically this matters because pre‑AIA § 103 permits the patentee to swear behind references using an earlier date of invention (Rule 131), which historically narrows the usable art window.

Test. Graham v. John Deere, 383 U.S. 1 (1966): scope and content of the prior art; differences between the prior art and the claims; level of ordinary skill; and secondary considerations. Under KSR Int'l v. Teleflex, 550 U.S. 398 (2007), a combination is obvious where there is an articulated reason with rational underpinning — including "design incentives and other market forces," "any need or problem known in the field," and "the mere substitution of one known element for another to obtain predictable results."

Level of ordinary skill (proposed). A bachelor's degree in EE/CS or equivalent, plus 2–4 years' experience in packet-switched/VoIP real-time communication and mobile client-server application development. This is the level reflected in the OMA PoC specifications and the Kodiak/IBM/Sarkar references below. (This mirrors the skill level articulated in the PTAB petition excerpt surfaced in search: "bachelor's degree in electrical engineering or computer science … with at least two years of experience in … software for communication with other computers over a network.")

---

3. The limitations that drive the analysis

From the previously generated summary, the independent claims share this core:

Claims 10 and 19 are the system and method counterparts of L1–L6.

Critical observation for § 103: the patent's own Background is an admission about the state of the art and the design incentive:

"the need for call set up on a broadband network is obviated as the network bandwidth grows. Call setup causes delay which hinders instant communications. The concept of call set up originates from the circuit switched networks where resources are scare…"

An applicant admission that (a) call setup is a recognized source of delay, and (b) abundant bandwidth removes the need for it, is powerful § 103 ammunition: it establishes the problem and the direction of solution from the patentee's own mouth. A POSITA seeking to remove setup latency from a VoIP system has an express motivation supplied by the specification itself.

---

4. Ground 1 — Using only the reference in the Prior Art section (FAILS)

Proposed rejection: Claim 1 is obvious over US6997014B2.

Analysis:

• Not analogous art. Under In re Bigio and In re Clay, a reference is analogous if it is from the same field of endeavor or reasonably pertinent to the problem the inventor faced. Gemstone coatings are neither. There is no field-of-endeavor overlap and no problem-pertinence overlap.
• No rational underpinning. KSR requires some articulated reason. There is none; the combination would be a nonsensical union of unrelated technologies.
• No reasonable expectation of success for modifying a deposition process into a talk-button communications device.

Conclusion: Ground 1 is not viable. Any professional analysis must state this plainly rather than manufacture a mapping. Do not assert this ground.

---

5. Supplementary grounds (art beyond the Prior Art section)

Because the listed art is unusable, the following candidates — all verified by search and all with pre-2012 dates — carry the actual § 103 case. Caveat: I have verified titles, dates and key disclosures for these via web sources; I have not run a formal element-by-element claim chart against the literal granted claim language (only the paraphrase in the summary), so treat the mappings below as proposed, not final.

Ground 2A — OMA PoC Pre-established Session + Automatic Answer Mode (primary reference)

Reference: OMA TS PoC User Plane / Architecture documents, e.g. OMA-TS-PoC_UserPlane-V1_0_3 (dated 2009‑09‑22) and OMA-AD-PoC-V2_1 (2009‑12‑22) — https://www.openmobilealliance.org/release/PoC/V1_0_4-20091203-A/OMA-TS-PoC_UserPlane-V1_0_3-20090922-A.pdf ; https://www.openmobilealliance.org/release/PoC/V2_1-20091222-C/OMA-AD-PoC-V2_1-20091222-C.pdf

The specification definitions (quoted in the search results) map almost line-for-line onto the independent claims:

Note the AD's own framing, which is hostile to the patent's stated point of novelty:

"Existing solutions that offer walkie-talkie like services typically consist of mobile terminals with dedicated talk buttons, supported by networks that support the exchange of signalling messages to establish and maintain a push to talk session, report the presence of users, etc."

This is an affirmative description of pre-existing, non-proprietary "instant on" operation in the same field of endeavor.

Motivation to combine (if any combination is even needed): This is a single-reference, essentially anticipating disclosure as to L1–L5. To the extent the claims add a multi-channel "device-to-device via server" architecture beyond PoC's client-to-server pre-established session, the motivation is supplied by the patentee's own Background admission (bandwidth obviates setup) plus the standard design incentive to reduce perceived latency in mobile voice — precisely the "instant on" value proposition the OMA AD identifies as the commercial driver.

Ground 2B — Adding full-duplex capability (attacks the half-duplex gap)

The patent's Background distinguishes itself from PTT on the ground that "push-to-talk calls are only half duplex." That is the single most important difference the patentee identifies. It is also squarely addressed in the pre-2012 art:

1. US 2008/0285487 A1 (Forslow et al.), "Method and system for providing full duplex services over multiple simplex media paths and sessions" — https://patentimages.storage.googleapis.com/3d/09/f3/2a7b08b639c41c/US20080285487A1.pdf. Filed 2007‑05‑10, published 2008‑11‑20. Abstract: "establishing a simplex media path and session … establishing an additional simplex media path … and utilizing the simplex media path and session with the additional simplex media path and session to provide full duplex media service." The disclosure explicitly criticizes PoC's limitation that "a plurality of parties can only hear a single speaker within," and teaches pairing two simplex streams in opposite directions to obtain full duplex — the exact architectural move the patent describes ("Pairing these two multimedia streams of opposite directions creates the two-way one-to-one communications").
2. US 2006/0172754 A1 — a PoC full-duplex direct call using a modified SIP INVITE and a "poc-lock.unlock" parameter versus the standard half-duplex "poc-lock.lock." Published 2006‑08‑03; pre-2012. Establishes that converting a PTT session to full duplex, on a button press, was known.
3. OMA PoC V2.x "Full Duplex Call Follow-on Proceed" — https://www.openmobilealliance.org/release/PoC/V2_1-20091222-C/OMA-TS-PoC_System_Description-V2_1-20091222-C.pdf — documents the standardized operation by which a half-duplex PoC session is upgraded to a full-duplex conversation, with the PoC Server instructing participants. This is normative prior art as of 2009.

Motivation to combine: KSR endorses combining known techniques when a known problem (half-duplex restraint) calls for a known solution (paired simplex paths / FDCfO). The patentee's own specification supplies the problem statement. Under In re Kemps, the express teaching in Forslow ("[o]ne limitation of PoC technology is that its use and application over VoIP does not provide a more traditional telephony experience") is a textbook motivation.

Ground 3 — IM/voice integration and one-click conferencing

• US 7,085,258 B2 (IBM), "Instant messaging with voice conversation feature" — filed 2001‑07‑19, issued 2006‑08‑01 — https://patents.google.com/patent/US7085258. Claims recite inserting a voice-communications identifier in an IM, embedding code configured to establish the voice link, and — importantly for this patent — extracting embedded references to the sender and at least one other recipient and displaying a selectable icon for each, with claim 16 reciting that selecting two or more icons establishes a conference call.
• US 7,216,143 B2 (IBM), "Instant messaging with voice conference feature" — https://patentimages.storage.googleapis.com/fd/2d/5f/9c0ae91a45960f/US7216143.pdf — claims a voice conference identifier containing a conference call list of nodes, resolved to telephone numbers or IP addresses, with the conference established on selection of an icon. This maps to the patent's server-side name→IP resolution, channel list, and "Call Add" behavior.

Motivation to combine: The patent's core user story ("as if they were all physically present in the same room") is the standard "escalate text to voice" problem these IBM patents exist to solve. KSR: predictable use of a known technique (a buddy/channel list with a voice-launch control) to improve a similar system. The patentee's channel configuration by nickname ("Call John" → mapped to an IP address) is the natural implementation of the IBM "reference to the sender … [used to] determine a link address … an IP address."

Ground 4 — Pre-established IP sessions + host-side audio mixing conferencing

• US 8,958,348 B2 (Kodiak Networks), "Hybrid push-to-talk for mobile phone networks" — filed 2009‑10‑20, published 2010‑06‑10, issued 2015‑02‑17 — https://www.freepatentsonline.com/[8958348](/patent/8958348).html. Claims recite "pre-established Internet Protocol (IP) sessions between the real-time exchange and the mobiles" over which an initial talkburst is transmitted before circuit channels are built. This is meaningful because it shows pre-established bearer channels for voice, not merely a pre-established SIP control session — closer to L2/L3 as likely construed.
• Instant-conferencing / server-side mixing: Kodiak's own reference list cites US 7,236,580 (Sarkar et al.), "Method and system for conducting a conference call" (issued 2007‑06‑26). (Verified only as a citation from the Kodiak reference table — I have not independently read the Sarkar disclosure, so I flag this as a lead, not a confirmed mapping.)
• EP 1 622 406 A1, "Providing talk burst authority in group communication system supporting PTT service" — https://patents.google.com/patent/EP1622406A1/en — discloses a master authority granted to the session-initiating terminal, which then "freely controls the talk burst management procedure." That maps to the patent's host role, host-side Call Add/Call Drop, and host device "remembering the structure of the conference call."
• EP 1 911 177 B1 (Research In Motion), "System and method for granting transmit capability in a push to communicate system" — https://patentimages.storage.googleapis.com/ab/f2/af/3f44ce62d45f1d/EP1911177B1.pdf — priority 2005‑07‑19, granted 2012. Discloses a user interface that displays the mobile terminals of the communication group and accepts user input selecting a responding terminal, then granting transmit capability to that one. This maps to the patent's per-channel Talk button selecting which counterparty receives the stream, and to the Talk-to-All / selective-channel toggle behavior.

Motivation to combine: Server-hosted mixing is the classic conference bridge; Kodiak/Sarkar and the PoC Controlling PoC Function ("centralized Media distribution, Talk Burst Control") both supply it. Combining a pre-established-session PTT system with a conference mixer to obtain the patent's "host device mixes voices and sends composites to each participant" is a predictable combination of known elements with a known benefit (multi-party audio). KSR disfavors requiring an express teaching where the elements are known and the combination is the natural design choice.

Ground 5 — Presence/away indicator (dependent-claim theme)

The "Away" button → flashing green channel lights on connected devices limitation is standard presence functionality, expressly part of the PoC enabler's functional scope ("report the presence of users" per OMA-AD-PoC-V2_1, §4 Introduction), and standard in the IM systems of Ground 3. A POSITA would combine presence with a channel-indicator UI to obtain the claimed "Away" behavior with a reasonable expectation of success.

---

6. Claim-by-claim vulnerability map

---

7. Where the obviousness case is weakest (defenses the patentee will raise)

1. "Established … between the communication devices … before any calls are placed" (L2). Read literally and narrowly, PoC's Pre-established Session is client-to-its-own-home-server, not a standing end-to-end channel between two user devices. A patentee will argue the PoC art only pre-establishes the client↔server leg, so a § 103 ground must reach device-to-device connectivity. The Kodiak US 8,958,348 reference (pre-established IP sessions carrying a first talkburst) partially bridges this, but it too terminates at a real-time exchange, not at a peer device. This is the pivot point of any obviousness case and should be briefed carefully against the literal claim language, not the summary paraphrase.
2. "Minimal maintenance signaling messages" (L3). Potentially indefinite/functional; if construed as mere keep-alive traffic, the PoC Dormant Session (TBCP-only, no RTP) is a strong read. If construed to require periodic device-to-device heartbeat, the mapping weakens.
3. Half-duplex framing. The patent explicitly criticizes PTT for being half duplex. If the claims are construed (or argued during prosecution — check the file history) to require independent, simultaneous control of both directions, the challenger must lead with the Forslow / US2006/0172754 / FDCfO art, not bare PoC. Otherwise the patentee will win on this distinction.
4. "No ringtone … without a pick-up action" (L5). PoC Automatic Answer Mode is nearly dispositive here, but note the corroborating 3GPP use-case text also says the listener's terminal may be in "not ready to listen" mode — a patentee may seize on this to argue it is not truly automatic. Rebut with the express "Media is immediately played when received" definition.
5. File history estoppel. I have not reviewed the prosecution history of 14/954,693 or its parent. If the applicant distinguished any of this art to obtain allowance, that both strengthens the § 103 case (admissions) and constrains claim construction. This must be pulled before any petition is drafted.

---

8. Objective indicia (§ 103 secondary considerations)

• No PTAB proceedings have been filed or instituted (SUSTAINED as to all claims 1–20; no estoppel attaches under § 315(e)(2)). Absence of AIA challenges is not evidence of non-obviousness; it is at most neutral, and often reflects the patent only recently entering assertion.
• Litigation: Texas Eastern District Court 2:26-cv-00041 (per the patent page's "Family has litigation" link). No validity determination is reported. Party identities and filing date remain unaudited in the prior sections.
• No commercialization evidence of record: assignee is "Individual," with no recorded assignments in the USPTO Assignment Center. There is no nexus evidence of commercial success, licensing, or industry praise that the patentee could presently invoke. If the 2:26-cv-00041 plaintiff is in fact the individual inventor, that posture tends to weaken secondary-consideration arguments, since there is no established product embodying the claims.
• Applicant's own admissions cut against non-obviousness (the Background's call-setup-obviated-by-bandwidth statement).
• No unexpected results are apparent: every claimed behavior (instant talk, auto-play, mixing, presence, voicemail) is the predictable result of the combined references.

---

9. Conclusion and confidence

Explicit non-fabrication statement: I have not verified the internal disclosure of US 7,236,580 (Sarkar) — it appears only as a citation inside the Kodiak reference table. I have likewise not reviewed the prosecution history, the literal claim language of claims 2–9, 11–18 and 20, or the district-court pleadings in 2:26-cv-00041. Assertions about those are marked accordingly above.

Recommended next steps to convert this into an actionable § 103 position:

1. Pull the granted claim text (all 20 claims) and the prosecution histories of both 14/954,693 and 13/804,854 to identify any distinguishing statements about "pre-established device-to-device" channels.
2. Confirm the effective filing date / AIA status of each claim before fixing the prior-art cutoff (pre‑AIA § 103 vs. AIA § 102(a)(1)/103).
3. Obtain the full text of US 7,236,580 (Sarkar) to complete Ground 4, and pin the OMA PoC specification version and publication dates that predate 2012‑05‑04 (V1_0 and V2_1 releases, both citable).
4. Build formal element-by-element charts for claims 1, 10 and 19 on Ground 2A+2B as the lead theory, with Ground 4 as an alternative.
5. If an IPR is contemplated, note that the sole listed reference in the Prior Art section (US6997014B2) must be discarded from the petition; relying on it would be a substantive defect.