Invalidity dossier

US 10346114

Digital content services over the internet that transmit or stream protected digital content to mobile devices, display devices, audio output devices, printing devices, televisions, or television controllers

Current assignee: Flexiworld Technologies, Inc.

Added 9/14/2026, 12:47:31 PM

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

Active provider: DeepSeek · deepseek-flash

Patent summary

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

✓ Generated

I'll run targeted searches on the patent number and any CAFC activity, then summarize.

Let me check for any CAFC activity tied to Flexiworld and confirm the abstract text.

Let me pull the patent's own claim text and check for any Federal Circuit docket naming it.

US Patent 10,346,114 B2 — Concise Summary

Searches run: Google Patents family page for US10346114B2, Unified Patents patent portal, Stanford NPE Litigation Database, Justia patent mirrors, PTAB/PTACTS petition documents, Docket Alarm IPR2021-00715 record, and a CAFC 2026 docket sweep (CAFC oral-argument and opinions/orders listings plus "Flexiworld + Federal Circuit" queries).


1. Bibliographic data

Field Value
Patent number US 10,346,114 B2 (interpreted literally; no auto-correction applied)
Title Digital content services over the internet that transmit or stream protected digital content to mobile devices, display devices, audio output devices, printing devices, televisions, or television controllers
Application no. 15/973,317
Pre-grant publication US 2018/0253264 A1 (published 2018-09-06)
Filing date 2018-05-07
Issue/grant date 2019-07-09
Claimed priority 2000-11-20 (Google Patents "Prior art date" / "Priority date"); parent application identified in the family record as 09/992,413
Inventors William Ho Chang; Christina Ying Liu
Assignee (original and current) Flexiworld Technologies, Inc.
Status Expired – Fee Related; Google Patents lists "Anticipated expiration 2021-11-18"
Classification G06F3/12 (digital output to print unit); G06Q20/32 (wireless payment); H04L63/0428 (protected payload); H04L67/565 (proxy content adaptation); H04L12/28 (home automation networks)

Two literal-reading notes:

  • The grant date is 2019-07-09 while the statutory end date is 2021-11-18. A patent granted in mid-2019 would not owe its first (3.5-year) maintenance fee until 2023, so the 2021-11-18 date is best read as the end of the 20-year term (20 years from 2000-11-20 plus term adjustment), not a fee lapse. Google's "Expired – Fee Related" is a coarse status bucket — do not state "lapsed for non-payment" as fact without pulling USPTO maintenance records.
  • The Unified Patents portal page rendered a priority date of "2000-11-19" for US-10346114-B2, whereas Google Patents and the patent's own face say 2000-11-20. One-day discrepancy, flagged rather than resolved; it is immaterial to a §102/§103 date line but worth knowing if you are quoting a source.

2. Abstract (verbatim)

"Digital content services provided over the Internet for transmitting or streaming protected digital content to client or output devices are herein disclosed and enabled. The protected digital content is encrypted and device dependent or specific for rendering or playing at a limited number of devices, including smart phones, information pads, audio players, wireless controllers, televisions, printers, etc. To illustrate, a client may include an application for accessing digital content from a subscribed content service or store over the Internet. To access the digital content, a client application may send, to the content service or store, authentication information, subscription information, and/or a reference to selected digital content. The service then generates encrypted device dependent output data, related to the selected digital content and associated with a device previously registered with the service, for transmitting or streaming to the client or output devices (e.g., smart phones, television controllers, speakers, printers) for rendering."

(Source: mirror of the granted front page at wiki.golden.com; matches the disclosure described in the patent's own specification, which is supplied in the case record.)


3. Plain-language overview of the independent claims

⚠️ Confidence statement first. The complete granted claim set is not reproduced in the material available to me — the full patent text in the record is truncated after the "Definitions/GUIs" portion and before the claims. The overview below is reconstructed from (a) claim language quoted in PTAB petition/declaration documents and (b) a Justia mirror of the granted claims. Treat claim numbers/wording below as probable, not certified. The granted claims should be pulled from USPTO Patent Center (application 15/973,317) before any infringement or invalidity chart is filed.

Which claims are actually in play. In Flexiworld Technologies, Inc. v. Roku Inc., No. 6:20-cv-00819-ADA (W.D. Tex.), Flexiworld's infringement case asserted claims 8, 14, 15, 16, and 18 of the '114 patent — so identified in the Almeroth rebuttal expert report filed in that action and carried into IPR2021-00715. That is the best primary evidence of which claims the owner treats as the commercially significant ones.

Independent claim 1 — "A system for accessing a digital content service…"

Recites a system (viewed from the client/server-services side rather than the handheld side) that:

  • accesses a digital content service over a network and receives output data from one or more servers;
  • includes a processor, an operating system, and a client application with a user interface;
  • is associated with an output device for rendering (display, projection, audio, or printing);
  • operates by having the application send information to the servers (authentication/security information and information about the selected content or the device) and receive back device-dependent output data for rendering.

Independent claim 8 — "An information apparatus for obtaining digital content from a digital content service provided by one or more servers over a network"

The device-side mirror image of claim 1. Plain-language: a mobile-ish computing device with at least one processor, an operating system, a user interface, and memory/storage holding software that, when run:

  • sends authentication information to the content service;
  • sends subscription information to the content service;
  • delivers one or more device objects (identifying/information about the device);
  • and obtains access to the digital content only after authentication and subscription are successfully presented — i.e., the content flow is gated on a paid subscription, not merely on login.

This subscription-gating element is the limitation Flexiworld leaned on most heavily in the IPR; it is the claim's commercial hook and its weakest link under the prior art.

Independent claim 15 — non-transitory computer memory / storage claim

A non-transitory computer-readable memory storing program instructions that, when executed:

  • cause an information apparatus to obtain a content object that includes at least a pointer or reference to selected digital content (rather than the content itself);
  • deliver that content object to the service;
  • receive back device-dependent output data that has a relationship to device information in the device object and that further includes an encryption scheme;
  • decode the received output data at the information apparatus;
  • and render/play it.

Plain-language: this is the claim that pulls encryption and the "pointer-not-payload" architecture directly into the claim, plus an affirmative step of decrypting/decoding on the user's device before output.

Independent claim 37 — system claim (client-side mirror)

Appears to be a further system claim on the client side, structurally parallel to claim 1/claim 8. Lowest confidence item in this summary — I could not recover its granted text, and the quotation I have does not self-identify by patent number (sibling Flexiworld patents use near-identical vocabulary).

What the dependent claims add (recovered)

Claim 16–20 and 27–30/35 add, in substance: the information apparatus being a smart phone, touch-screen phone, Internet pad, Internet appliance, television device, television controller, or digital camera; wireless communication circuitry; touch-sensitive interface; voice-activated command interface; output delivered to a wired- or wirelessly-connected printer, display device, television, television controller, or audio output device; and payment or subscription information parameters.

One-line synthesis: the claimed invention is "a server-side content service that authenticates you, checks your subscription, and streams you encrypted, device-specific output data for a registered device, where the client sends a reference rather than the content, and the client does the decoding before rendering — to a TV, speaker, printer or phone." That is the air-play/cast/cloud-print model, claimed with a 2000 priority date and a 2018 filing date.


4. CAFC / 2026 docket check — result

No Federal Circuit proceeding involving US 10,346,114 was identified. Specifically:

  • The CAFC's own published 2026 oral-argument and opinions/orders listings (through the April 2026 postings) contain no case captioned to Flexiworld and no appeal number tied to 10,346,114.
  • IPR2021-00715 (Roku v. Flexiworld, the one AIA trial filed against the '114) terminated 2022-10-25 by settlement after institution, with no Final Written Decision. No FWD means there was nothing for anyone to appeal — which is why no CAFC docket exists.
  • I did find Flexiworld appellate-adjacent activity only on other patents (e.g., counsel declarations describing Federal Circuit argument experience in other Flexiworld matters). Those do not attach to the '114.
  • Caveat: my check was against CAFC's public listings and secondary dockets, not a PACER/CM-ECF docket-by-docket search on the '114's own number. If a 2026 appeal exists under a caption that does not name Flexiworld, an exact-number docket search would be needed to exclude it. I am not confident enough to state categorically that no appeal exists — only that none surfaced.

Related USPTO-side activity on this exact number (for completeness, since it is not CAFC but is on-point):

  • IPR2021-00715 — Roku, Inc. v. Flexiworld; instituted 2021-10-26; oral hearing 2022-07-20; terminated by settlement 2022-10-25; challenged claims 8, 13–16, 18 on §103 grounds over Larsson (US 7,028,102) + Ortiz (US 2002/0058499 A1), and Larsson + Ortiz + DeMello (US 7,158,953). No claim was canceled and none was upheld.
  • Ex parte reexamination 90/014,721 — requested by Unified Patents on 2021-04-13, granted 2021-05-11 on a finding of substantial new questions of patentability.
  • Note the tension: the patent's term ended 2021-11-18, yet it was actively litigated and reexamined through 2022. An expired patent can still be challenged.

Data-integrity flag: the USPTO ODP API reportedly returns no AIA trial proceedings for this patent number, which contradicts the Board's own docket and the patent's Google Patents page. Treat the ODP "empty" result as an ingest gap, not as an absence of IPR activity.


5. What I could not verify (do not treat as established)

  1. The complete granted claim set — claims 1, 37 and several dependents are reconstructed from petition quotations, not from the granted text. → Pull application 15/973,317 from USPTO Patent Center.
  2. Which claims are independent vs. dependent, and the total claim count.
  3. The '114's own examiner-cited "References Cited" list — not retrieved.
  4. The exact bibliographic dates/titles of Larsson, Ortiz and DeMello (the art actually applied), and the content of DeMello.
  5. Whether any 2026 Federal Circuit appeal exists under a caption not naming Flexiworld.
  6. The 2000-11-20 vs. 2000-11-19 priority-date discrepancy between Google Patents and the Unified Patents portal.

6. Cross-reference note on the prior sections

Two items in the earlier-generated sections should be read with the updates above: (a) the asserted-claim set in the Roku case is now primary-sourced as claims 8, 14, 15, 16, 18 (from the Almeroth rebuttal report in 6:20-cv-00819-ADA), which is a narrower and more precise set than the earlier "claims 8, 13–16, 18" IPR-challenge list — the IPR challenged 13–16 and 18, while the district court case asserted 8, 14, 15, 16 and 18; these are different sets and should not be conflated. (b) The earlier caveat that the IPR2021-00715 target was "probable, not fully verified" is retired — the petition record captions it to Patent No. 10,346,114.

Generated 9/21/2026, 2:12:19 PM

Cases on file (2)

Group view →

Specific litigation cases in our database that name US patent 10346114. 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 10,346,114 across patent litigation sources.

Let me dig deeper into the specific cases and verify which ones assert this patent.

Litigation Involving U.S. Patent No. 10,346,114

Patent: US 10,346,114 B2 ("Digital content services over the internet that transmit or stream protected digital content to mobile devices, display devices, audio output devices, printing devices, televisions, or television controllers")
Owner: Flexiworld Technologies, Inc. (original assignee; inventors William Ho Chang and Christina Ying Liu)
Priority date: 2000-11-20 · Filing date: 2018-05-07 · Grant date: 2019-07-09 · Status: Expired – Fee Related


1. District Court Litigation

Flexiworld Technologies, Inc. v. Roku Inc. — CONFIRMED

Field Detail
Plaintiff Flexiworld Technologies, Inc.
Defendant Roku, Inc.
Jurisdiction U.S. District Court, Western District of Texas (Waco Division), Judge Alan D. Albright
Case No. 6:20-cv-00819
Filing date September 8, 2020
Status Closed (case docket shows status "Closed"; reported to have ended by settlement in 2022)

Relationship to US 10,346,114: This patent was asserted by Flexiworld against Roku. It appears as Exhibit 2 (US Patent 10,346,114) to the original complaint, alongside US 8,989,064 (Exhibit 1) and US 10,740,066 (Exhibit 3), with corresponding claim charts for the '064, '114, and '066 patents (Exhibits 4–6).

Notable docket activity: Roku moved for partial dismissal for lack of standing, arguing Flexiworld had assigned the asserted patents/inventions to Samsung. Judge Albright denied the motion on June 6, 2022, holding Flexiworld was the sole owner and had standing (6:20-cv-00819, Dkt. 198).

Outcome: No merits verdict on the '114 patent; the case was terminated (reported resolution by settlement in 2022). Note: a separate, later Flexiworld v. Roku action, No. 6:21-cv-00767 (W.D. Tex., filed July 27, 2021), asserted the '257 patent and also is reported as settled in 2022 — do not conflate this with the '114 case.


2. PTAB (Post-Grant) Proceedings — Related, Not District Court

Roku, Inc. v. Flexiworld Technologies, Inc. — IPR2021-00715

Field Detail
Petitioner Roku, Inc. (per the record exhibits in this IPR)
Patent Owner Flexiworld Technologies, Inc.
Forum USPTO Patent Trial and Appeal Board
Case No. IPR2021-00715
Status Terminated — Settlement (per Google Patents' litigation field for this patent)
  • Google Patents lists "PTAB case IPR2021-00715 filed (Settlement)" directly on the '114 patent page: https://portal.unifiedpatents.com/ptab/case/IPR2021-00715
  • IPR2021-00714 (a companion Roku IPR, filed April 9, 2021) targeted US 8,989,064 and reached a Final Written Decision on October 21, 2022 invalidating claims 1–10, 12, and 14 (no evidence the '114 patent was part of that FWD).
  • ⚠️ Caveat: I could not independently confirm the exact statutory claims/patent challenged in IPR2021-00715 from a primary source in this search window. The linkage of IPR2021-00715 to the '114 patent rests on Google Patents' litigation field and a Docket Alarm hit for patent:(10346114) returning IPR2021-00715 documents. Treat as probable, not fully verified.

3. Contested / Unverified — Do Not Rely Without Primary Confirmation

Flexiworld Technologies, Inc. v. Sony Corporation (2:23-cv-00616)

Flexiworld Technologies, Inc. v. LG Electronics / LG Electronics USA (Sept. 2025, E.D. Tex.)

  • Reported (Korean IP-NAVI dispute monitor, published 2025-10-31) as asserting six patents concerning wireless connection/streaming against LG (smart TVs, soundbars, remotes, LG ThinQ app).
  • The report does not list patent numbers; I could not verify whether US 10,346,114 is among the six. Unconfirmed — flagged, not asserted.

4. Cases That Do NOT Appear to Involve the '114 Patent

Flexiworld's other asserted-patent campaigns were surfaced in searches but show no linkage to '114: Amazon.com (6:20-cv-00553, W.D. Tex.), Canon (1:21-cv-00066; 6:21-cv-00143, W.D. Tex.), Epson America (8:21-cv-00807, C.D. Cal.), Brother (2:22-cv-02236; 2:22-cv-02250, W.D. Tenn.), Hisense (2:22-cv-00225; 2:22-cv-00228, E.D. Tex.; 1:22-cv-04338, N.D. Ga.), Xerox (6:23-cv-06370, W.D.N.Y.), Hewlett-Packard (4:24-cv-02691, S.D. Tex.), and Indeed (1:24-cv-01254, W.D. Tex.). Absence of a documented '114 assertion is not proof the patent was unasserted in these suits (complaints were not all inspected).


5. Certifications of Completeness

  • No CAFC appeal specific to US 10,346,114 was identified. (The IPR2021-00714 FWD on the '064 patent did not, on the record found, involve '114.)
  • No ITC (Section 337) proceeding involving '114 was identified.
  • No litigation outcome on the merits of the '114 claims (validity or infringement) was identified — the confirmed district court case ended without a merits ruling on this patent, and the related PTAB proceeding terminated by settlement.

Bottom Line

One confirmed district court case asserted US 10,346,114:

Flexiworld Technologies, Inc. v. Roku Inc., No. 6:20-cv-00819, W.D. Tex. (filed Sept. 8, 2020) — closed (settled), with Roku's standing challenge denied June 6, 2022.

Plus one related PTAB proceeding, IPR2021-00715 (Roku v. Flexiworld), which Google Patents ties to this patent and which terminated by settlement.

A potential second case (Flexiworld v. Sony, 2:23-cv-00616, E.D. Tex.) is listed by the Stanford NPE database as involving '114, but the primary complaint/docket evidence points to a different patent set — this entry should be independently verified before use. No other litigation involving US 10,346,114 was found.

Caveats: Case-status fields (e.g., "closed," "settled") drawn from aggregator sources should be re-verified against PACER before being relied upon for any legal conclusion. Where search results conflicted (notably the Sony case), I have reported the conflict rather than resolving it.

Generated 9/15/2026, 12:48:03 AM

Proceedings on file (0)

All PTAB activity →

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

Current assignee: 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

I'll research the PTAB record for US 10,346,114, starting with the proceeding identified in the patent's own litigation metadata.

PTAB proceedings on US 10,346,114 — analyst report (as of 2026-09-15)

Data-source note first. The structured block says the USPTO ODP API returns no AIA trial proceedings for this patent. That appears to be an ingest gap, not an absence of activity. The patent's own Google Patents family page lists "PTAB case IPR2021-00715 filed (Settlement)" (linking to portal.unifiedpatents.com/ptab/case/IPR2021-00715), and the Board's own decision paper in that case is captioned "IPR2021-00715 Patent 10,346,114 B2." So the canonical list from ODP is incomplete here; I'm reporting the proceeding that exists on the Board's docket.


Proceedings overview

One AIA trial proceeding has been filed against US 10,346,114: IPR2021-00715 (Roku, Inc. v. Flexiworld Technologies, Inc.), instituted 2021-10-26 and terminated by settlement on 2022-10-25 — one day before the statutory final-written-decision deadline — with no Final Written Decision. Breakdown: active 0 | claims invalidated 0 | claims sustained 0 | settled 1 | institution denied 0. Bottom line for a defendant: no claim of the '114 patent has ever been canceled, and none has ever been upheld. You cannot cite a PTAB invalidation to the troll, but the troll cannot cite a PTAB affirmance either — the patent is PTAB-untested, with a settled IPR and a publicly documented institution that tells you the Board thought Roku's art was good enough to try.


IPR2021-00715 — Roku, Inc. v. Flexiworld Technologies, Inc. (U.S. Patent No. 10,346,114 B2)

  • Type: Inter Partes Review (35 U.S.C. §§ 311–319)
  • Filed: 2021-04 (Roku's companion petition, IPR2021-00714, is docketed as filed 2021-04-09; the -00715 petition was filed in the same window. I could not retrieve Paper 1 to confirm the exact date — flagged rather than guessed.)
  • Status: "Termination Due to Settlement After Institution of Trial" (Paper 36, 2022-10-25) — gloss: the panel exercised its § 317(a) discretion to close the case before issuing a merits decision.
  • Judge panel: Terrence W. McMillin, Christopher L. Ogden (authoring the termination decision), Brent M. Dougal — all Administrative Patent Judges, PTAB.
  • Petition grounds: Two § 103 grounds directed at claims 8, 13–16, and 18, per Petitioner's demonstrative ground table:
    • Ground 1 — § 103 over Larsson (U.S. Pat. No. 7,028,102) in view of Ortiz (U.S. Pat. Pub. No. 2002/0058499);
    • Ground 2 — § 103 over Larsson + Ortiz + DeMello (U.S. Pat. No. 7,158,953).
    • No § 112 grounds appear in the record I retrieved. Claim 8 appears to be an independent apparatus claim ("An information apparatus for obtaining digital content from a digital content service provided by one or more servers over a network … including: at least one processor; an operating system; an interface for interacting with a user; memory or storage; software or firmware stored …").
  • Institution decision: INSTITUTED on 2021-10-26 (Paper 18) — confirmed verbatim in the termination decision: "We instituted trial in this proceeding on October 26, 2021. Paper 18." I was unable to pull the full Paper 18 text, so I cannot state whether institution was on all challenged claims or partially instituted — the only challenged-claim list I can verify is the petitioner's ground table (claims 8, 13–16, 18).
  • Final Written Decision: NONE — never issued. The parties expressly represented that "the Board has not yet decided the merits of this proceeding," and the panel accordingly "determine[d] that it is appropriate to terminate this proceeding without rendering a final written decision." Consequence: zero claim-level outcomes. Claims 8, 13, 14, 15, 16 and 18 were challenged and instituted but neither canceled nor held patentable.
  • Settlement / termination: Joint Motion to Terminate (Paper 34) filed 2022-10-24; a Settlement and Patent License Agreement was filed as Ex. 2036 (redacted) and Ex. 2037 (unredacted) on 2022-10-25. The panel granted the Request to Keep Separate (Paper 35) and held the agreement to be business confidential information under § 317(b) / 37 C.F.R. § 42.74(c) — terms are confidential. What is public: the parties settled their "entire dispute concerning the '114 patent," the deal included a patent license, and there were no disclosed collateral agreements. In practical terms this reads as a license-and-walk-away ending to the W.D. Tex. suit (Flexiworld Techs., Inc. v. Roku Inc., No. 6:20-cv-00819-ADA (W.D. Tex.)) and the follow-on 6:21-cv-00680.
  • Appeal: None. No FWD means nothing appealable; no CAFC docket exists for this proceeding. (The proceeding was nonetheless heavily litigated up to the eve of decision: a full oral hearing was held 2022-07-20 (Paper 32 transcript, 30 min/side, Canavera/Perkins Coie for Roku, Grochocinski/Nelson Bumgardner Conroy for Flexiworld), and the termination landed 2022-10-25 — the day before the one-year § 316(a)(11) FWD deadline.)
  • Defensive value: The patent has no PTAB estoppel and no PTAB invalidation attached to it, so a new petitioner is not blocked by anything Roku did, and there is no adverse judgment a plaintiff must distinguish. On the other side of the ledger, the Board did institute on Larsson+Ortiz and Larsson+Ortiz+DeMello — that institution is a public, citable signal that a reasonable § 103 theory exists, and the art (Larsson, Ortiz, DeMello) is now fully briefed and publicly available for reuse.

Primary record links:

Not counted (different patents — do not conflate):

  • IPR2021-00714 — Roku v. Flexiworld, filed 2021-04-09, FWD 2022-10-21 (panel: Dougal, Moore, Ogden; opinion author Dougal), challenging claims 1–10, 12, 14–20, with reported invalidations of claims 1–10, 12, 14 (and others). This is a sibling Flexiworld patent, not the '114. It is enormously useful as a § 103 roadmap and as evidence of how this family fares at the Board — but it is not an invalidation of any '114 claim, and I will not present it as one. (Source: https://services.patexia.com/lawsuits/Roku-Inc-v-Flexiworld-Technologies-Inc-id-[151681](/patent/151681))
  • PGR2021-00111 (Roku v. Flexiworld, U.S. 10,846,031) — not instituted on the merits, 2022-03-14; PGR2021-00112 (Roku v. Flexiworld, U.S. 11,029,903) — settled, terminated 2022-10-31. Again: different patents in the same family.
  • IPR2022-01114 (Roku v. Flexiworld, U.S. 9,965,233) — different patent; the Lexmark IPR surfaced in search against the '233 patent (Keeney/Vatland grounds) likewise is not a '114 proceeding.

Strategic summary

Claim status on '114: everything is UNTESTED. There are no CANCELED claims and no SUSTAINED claims. The only PTAB challenge ever filed on this patent reached institution on claims 8, 13–16 and 18, was tried through a July 2022 oral hearing, and then died by settlement on 2022-10-25 without any merits ruling. Every other claim of the '114 patent has never been tested in any AIA trial at all. If you are drafting an invalidity position, you are working from a blank PTAB slate on '114 — but from a rich record next door: the IPR2021-00714 FWD on the sibling patent and the instituted grounds on '114 itself (Larsson, Ortiz, DeMello) give you a pre-vetted art set and a clear-eyed view of which limitations the Board found weak.

Estoppel: there is none, and that cuts in your favor. Section 315(e)(2) estoppel — and § 315(e)(1) estoppel before the Office — attach only after a final written decision. Because IPR2021-00715 terminated "without rendering a final written decision," no estoppel attaches to Roku, Inc., Unified Patents, or any privy as to the '114 patent. Nothing stops Roku (or anyone else) from filing a fresh IPR on '114 raising Larsson/Ortiz/DeMello again, or new art. Conversely, you should assume no estoppel shield from Roku's work either — you will have to put in your own petition, your own § 315(b) one-year clock analysis, and your own § 325(d) argument. Note the § 325(d) risk: the Board has now seen Larsson/Ortiz/DeMello against these very claims in an instituted case, so a re-filed petition using the same art against the same claims will need a clean "what changed / what the Board got wrong" story (the Advanced Bionics / Becton Dickinson framing).

Pattern signals. Roku was a serial, coordinated petitioner across the Flexiworld portfolio: three IPRs filed in April 2021 (including -00715 on the '114) plus PGRs on two later family members — and it lost/walked away from every one that touched the asserted family patents (settled -00715 and PGR2021-00112). The settlement vehicle was a Settlement and Patent License Agreement kept confidential under § 42.74(c), and Roku's subpoenas to Apple, Philips and others in the -00715 record show it was building a systemic prior-art/inventorship case before folding. Unified Patents appears in the metadata chain via its litigation/PTAB portals (and its portal.unifiedpatents.com/ptab/case/IPR2021-00715 and patent pages), but I found no evidence of a Unified Patents-filed IPR on the '114 — treat it as a tracker, not a petitioner here, unless E2E shows otherwise. Flexiworld, for its part, has been an aggressive multi-front enforcer (W.D. Tex. 6:20-cv-00819 and 6:21-cv-00680 against Roku; E.D. Ky. 22-cv-110 against Lexmark; and later portfolio campaigns), and it has shown a willingness to settle on license terms rather than litigate to judgment — the practical implication being that a strong, early IPR posture has historically moved this patent owner to the table.


Recommended next steps

  1. Get the missing papers from PTAB E2E before relying on claim scope: Paper 1 (Petition, to confirm the 2021 filing date and the exact challenged-claim set) and Paper 18 (Institution Decision, 2021-10-26, to confirm whether institution was partial — the panel may have declined some of claims 8/13–16/18, which would itself be a strong defensive data point). Search E2E at https://ptacts.uspto.gov/ptacts/ or the PTAB decisions portal at https://developer.uspto.gov/ptab-web/#/search/decisions.
  2. Cite the termination precisely. The disposition language is: "ORDERED that the Joint Motion to Terminate … is granted; and … this proceeding is terminated with respect to both Petitioner and Patent Owner pursuant to 35 U.S.C. § 317(a) and 37 C.F.R. § 42.72." Use it to establish that no claim of the '114 patent has ever been canceled and that no § 315(e)(2) estoppel runs from this case.
  3. Mine the Roku record as a free prior-art roadmap. Larsson (U.S. 7,028,102), Ortiz (U.S. Pub. 2002/0058499) and DeMello (U.S. 7,158,953) were all good enough to institute on claims 8, 13–16 and 18. Pull Roku's Ex. 1023 demonstratives and the hearing transcript, and cross-reference the IPR2021-00714 FWD (2022-10-21) on the sibling patent — that FWD did invalidate claims and is your best template for how this family's claim language is being read.
  4. No litigation deadlines to track — because there is no live PTAB case. Nothing is pending before the Board on the '114 patent, so there is no institution deadline, no oral hearing, and no statutory one-year FWD deadline running. (For calibration, had -00715 survived, its FWD was due on or about 2022-10-26; the parties settled the day before.)
  5. Watch the family, not just the '114. Flexiworld continues to obtain and assert continuations (e.g., 10,846,031; 11,029,903; 10,740,066; and later-issued members). IPRs and PGRs against those siblings are the leading indicator of where the next '114-style petition should aim — and the -00714 FWD shows the Board will cancel claims in this family when the art is right.

Generated 9/15/2026, 12:48:28 AM

Ownership chain (1)

Asserters network →

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

  1. ? · reel 012325/0362 · Assignment

    William Ho Chang and Christina Ying LiuFlexiworld Technologies, Inc.

Assignment history

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

✓ Generated

I'll research the assignment chain for US 10,346,114 across USPTO Assignment Center, Google Patents legal events, and NPE directories.

Let me dig into Google Patents legal events and the Flexiworld assignment history.

Let me find the specific assignment reel/frame for the '114 patent and the Roku complaint's ownership paragraphs.

Ownership & Assignment Analysis — US Patent 10,346,114 B2

Method note (read before relying on the chain below). I was unable to query USPTO Assignment Center (assignmentcenter.uspto.gov / assignment.uspto.gov) directly in this session — I have no authenticated API or scraper access to that system, and a patent-number lookup there returns the reel/frame, conveyance type, assignor/assignee, execution date, recording date and correspondent of record, none of which surfaced in indexed search results for the '114 specifically. What follows is reconstructed from primary litigation documents in which Flexiworld itself recites the recordation data (which is admissible evidence of the reel/frame), cross-checked against Google Patents legal events, the Stanford NPE Litigation Database, Unified Patents' patent pages, and the court's standing order in Flexiworld v. Roku. Where a data element (especially the correspondent of record and the execution/recording dates) is not in hand, I say so rather than fill it in.


Inventors

Inventor Employer at filing Notes
William Ho Chang (a/k/a William H. Chang) Flexiworld Technologies, Inc. — founder and President Named on both the '114 and the entire asserted family. Per Flexiworld's own complaint (6:20-cv-00819 ¶16), Chang is "the founder and President of Flexiworld" and "has been granted over 88 United States patents and over 100 patents worldwide." Residence of record on sibling filings: Vancouver, WA.
Christina Ying Liu Flexiworld Technologies, Inc. — shareholder Per the same complaint (¶17), Liu "is a Flexiworld shareholder" with "over 65 United States patents and over 75 patents worldwide." Residence of record: San Francisco, CA.

Unusual-pattern check: the classic "all inventors depart within 12 months of filing" precursor to a portfolio fire-sale is not present — both inventors remained affiliated with Flexiworld at filing and through the assertion campaign (Chang as President). The relevant pattern is the opposite and worth flagging: this is a two-person, founder-owned inventor pair who are simultaneously the inventors, the shareholders, and the officers of the asserting entity. That structure means the "inventor → assignee" assignment is effectively a founder-to-own-company conveyance, not an arm's-length sale, and it is the only recorded transfer on this patent.


Original assignee

Flexiworld Technologies, Inc. — a Washington corporation, principal place of business at 2716 SE 169th Ave Q147, Vancouver, WA (as pleaded at 6:20-cv-00819 ¶2). Named as assignee on the face of the '114 patent.

  • Primary line of business: described by Flexiworld in its complaints as "a wireless technology company" and "a pioneer and leading innovator in the field of pervasive wireless technologies… engaged in research and development of technologies for wireless applications and embedded solutions in short-range wireless (e.g., Bluetooth, Wi-Fi) and mobile device markets." It claims to have been "[v]oted the best early-stage company in the Pacific Northwest in 2002," with a business plan ranked top-2 in 2002 and 2003 by the Silicon Valley Business Journal (multiple Flexiworld complaints, ¶¶10–15).
  • Did it ship a product embodying the claims? No — and it has admitted so in a court filing. Flexiworld pleaded: "Since issuance of each of the Patents-in-Suit, Flexiworld has not made, offered for sale, sold, or imported a product that practices any of the Patents-in-Suit or that would otherwise require marking under 35 U.S.C. § 287." (Amended complaint ¶57, quoted in Flexiworld Techs., Inc. v. Lexmark Int'l, Inc., No. 5:22-cv-00097-KKC, Dkt. 44 at 2.) The company's products never reached the market at scale; contemporaneous press coverage of Flexiworld appears in the litigation record only as 2002–2003 Portland Business Journal articles (PTAB Exs. 2002–2003 in IPR2021-00715), i.e., early-stage coverage.
  • Current status: non-operating / failed startup. The Stanford NPE Litigation Database classifies Flexiworld as a "Failed startup" asserter for patent 10346114 (https://npe.law.stanford.edu/patent/10346114). No evidence of bankruptcy, dissolution filing, or asset sale appears in the record retrieved — "failed startup" is the database's category, not a corporate-status filing I verified.
  • Entity-naming wrinkle (flag, not resolution): a separate record at patents-review.com shows a "Flexiworld, Inc." (Portland, OR) as assignee on one early application (last publication 2009-10-27), while the '114 and the litigation family are held by "Flexiworld Technologies, Inc." (Vancouver, WA). Whether this reflects a change of name, a reincorporation, or two distinct entities is not determinable from the sources retrieved. If a change-of-name conveyance exists, it should appear in Assignment Center and is a gap in this report.

Assignment timeline

⚠️ The Assignment Center record for this patent was not directly retrievable in this session. What is documented is the following.

  • Execution date: not confirmed. Recording date: not confirmed — Reel 012325 / Frame 0362
    • Conveyance: Assignment
    • Assignor: William Ho Chang and Christina Ying Liu (the named inventors)
    • Assignee: Flexiworld Technologies, Inc.
    • Correspondent of record: not retrieved — this is the single most important missing field for the troll-pattern analysis below. The reel/frame was recited in Flexiworld's own pleading (Flexiworld Techs., Inc. v. Roku, Inc., No. 6:20-cv-00819-ADA, Original Complaint ¶27: "An assignment of the '114 Patent from inventors Chang and Liu to Flexiworld is recorded at the PTO at 012325/0362."), and the same reel/frame is separately recited for US 9,037,577 in a sibling Flexiworld complaint (RPX litigation document 14324357, ¶21).
    • Context: founder/inventor-to-own-company conveyance — the standard original-recordation assignment. The same reel/frame appearing for two different Flexiworld patents is consistent with a single recordation covering a family of applications from the Nov-2000 priority chain (the '577 is a continuation in that chain, as is the '114). It is also consistent with a pleading copy-and-paste. Two integrity flags attach: (a) the same complaint paragraph set contains an obvious typo — ¶26 says "Flexiworld is the owner and assignee of all rights, title, and interest in and under the '072 Patent" in the middle of the '114 section; and (b) the complaint drops the "Reel/Frame" label entirely. Verify this reel/frame directly before relying on it.

Related conveyance — NOT on this patent (included for chain completeness): In November 2012, Flexiworld executed a Patent Purchase and License Agreement conveying to Samsung Electronics Co., Ltd. (Korea) U.S. Patent No. 7,941,541, U.S. Application Serial No. 13/103,958, and two continuation applications, "along with other various rights." (Court's order, 6:20-cv-00819-ADA Dkt. 198 at 2.) Roku argued this Nov-2012 agreement swept in the '114; Judge Albright rejected that argument on 2022-06-06, holding that § 1.1.1's specific four-item list controls over the "rights related thereto or arising thereunder" language and that "Flexiworld is the sole owner" of the '064, '114, and '066 patents (Dkt. 198 at 12–13). Net effect: the Samsung assignment does not touch US 10,346,114. No recorded assignment to Samsung exists for this patent number.

  • 2019-07-09 — no assignment on record; patent issues to Flexiworld Technologies, Inc.
  • No post-issuance assignment to any third party (no shell LLC, no aggregator, no securitization vehicle) was identified for US 10,346,114. On the evidence retrieved, Flexiworld Technologies, Inc. remains the owner.

If Assignment Center returns no additional records beyond the original recorded assignment, that is itself the finding: the original assignee still owns the patent, and the "chain" is exactly one link long.


Timeline diagram

timeline
    title Ownership of US 10346114
    2000 : Priority application filed
    2001 : Inventors assign family to Flexiworld
    2012 : Flexiworld conveys 541 patent to Samsung
    2018 : Application 15973317 filed
    2019 : Patent issues to Flexiworld
    2020 : Flexiworld sues Roku
    2021 : Ex parte reexam requested
         : Patent term ends Nov 18
    2022 : Standing challenge denied
         : Roku suit settles
    2023 : Sony suit filed
    2025 : LG suit reported

The 2001 placement of the inventor assignment is an estimate of the recording window implied by reel 012325 and by the Nov-2000 priority chain; the recording date is not confirmed. Treat the bracket, not the year, as the finding.


NPE / troll-pattern signals

# Signal Call Evidence
1 Shell-entity transfer Not present No assignment from an operating assignee to a "IP / Patents / Licensing / Holdings / Ventures" LLC exists on this patent. The assignee is the original assignee, Flexiworld Technologies, Inc. (Reel 012325/Frame 0362, per complaint ¶27). The signal's tells (registered-agent address, single-member LLC, no products) attach to a transferee — there is no transferee. Note the related fact that the assignee itself makes no product (¶57 admission), but that is an asserter-identity fact, not a shell-transfer fact.
2 Known asserter in the chain Present — directory match Flexiworld Technologies, Inc. is not on the enumerated legacy list (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg). It is, however, listed in the Stanford NPE Litigation Database as the patent asserter for 10346114 (category "Failed startup"), and it is tracked by Unified Patents (portal.unifiedpatents.com/patents/patent/10346114) and indexed by RPX. It is a serial plaintiff: Roku (6:20-cv-00819; 6:21-cv-00767), Amazon (6:20-cv-00553), Canon (6:21-cv-00143), Epson (8:21-cv-00807), Brother (2:22-cv-02236; 2:22-cv-02250), Hisense (2:22-cv-00225; 2:22-cv-00228), Xerox (6:23-cv-06370), HP (4:24-cv-02691), Lexmark (5:22-cv-00097 et seq.), Sony (2:23-cv-00616), LG (2025). This is the strongest signal in the file.
3 Repeat correspondent across the chain Unclear — data not retrieved The chain has only one link, so "recurrence" cannot be tested within this patent. The correspondent of record on Reel 012325/0362 was not obtainable in this session and is the key missing datum. For context only — and not assignment correspondents: Flexiworld's PTAB counsel is Brent N. Bumgardner (Reg. No. 48,476), Nelson Bumgardner Albritton P.C., 3131 W. 7th Street, Suite 300, Fort Worth, TX 76107, with Timothy E. Grochocinski (Nelson Bumgardner Conroy) on the IPR2021-00715 oral argument; Roku's PTAB counsel is Patrick McKeever / Kyle R. Canavera / Matthew Bernstein / Tyler Kendrick, Perkins Coie LLP. These are litigation, not recordation, appearances — flagged as leads, not as a finding.
4 Cascading transfers Not present One recorded conveyance (inventors → Flexiworld). No chained LLCs, no successive assignments inside 24 months.
5 Pre-litigation transfer Not present Flexiworld asserted the '114 in its own name in the 2020-09-08 Roku suit; there was no assignment to a litigating vehicle in the ~6 months before filing. The Nov-2012 Samsung transaction is the only other conveyance in the family and it predates the first '114 assertion by ~8 years — and was litigated against Roku's theory that it reached the '114.
6 Bankruptcy fire-sale Not present / unclear No Chapter 7/11 asset sale involving Flexiworld was identified. Flexiworld is characterized as a "Failed startup," which does not by itself establish a bankruptcy filing. Flagged as unclear only because no corporate-status filing was pulled.
7 Privateering Not present The direction of the one non-inventor transfer runs toward an operating company (Flexiworld → Samsung, Nov 2012, on the '541/'958 assets) — the opposite of privateering. Samsung did not assert the '114 for Flexiworld, and the court held Flexiworld retained the '114. No SEC 10-K/8-K disclosure of a Flexiworld privateering arrangement was found (Samsung discloses material IP acquisitions, but nothing tying the '114 to an assertion mandate).
8 Defensive aggregator Not present The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. Unified Patents and RPX track and challenge this patent (Unified requested the ex parte reexam) but are not assignees. Inverse signal absent — the patent is live and asserted, not neutralized.

Verdict

NPE — high confidence.

Justification. The strongest signals are identity-based rather than chain-based, and they are documented in primary sources: (1) the owner, Flexiworld Technologies, Inc., is listed as the patent asserter for 10346114 in the Stanford NPE Litigation Database (category "Failed startup") and is tracked by Unified Patents — a match to a public NPE/asserter directory, satisfying signal #2; and (2) Flexiworld conceded in its own amended pleading in Flexiworld v. Lexmark (5:22-cv-00097-KKC, Dkt. 44) that it "has not made, offered for sale, sold, or imported a product that practices any of the Patents-in-Suit," and it has asserted this patent (or its family) against at least a dozen operating companies — Roku, Sony, Amazon, Canon, Epson, Brother, Hisense, Xerox, HP, Lexmark, LG, Indeed. That is a non-practicing entity asserting a patent issued 2019-07-09 and expired 2021-11-18 (Reel 012325/Frame 0362 is the sole recorded conveyance; no transfer to an operating company or a defensive aggregator exists).

The caveat a reviewer should carry: this is not the classic shell-LLC cascade. The chain is one link long (inventors → original assignee), signals 1, 4, 5, 6, 7 and 8 are absent, and signal 3 could not be tested because the correspondent of record on Reel 012325/0362 was not retrievable. The high-confidence call rests on the asserter's own documented non-practice plus its directory listing — not on a transfer chain.

Verify at: https://assignmentcenter.uspto.gov/ (search by patent number 10346114; also search assignor "Chang, William Ho" and reel 012325 / frame 0362). Pull the recorded PDF on that reel/frame to capture the correspondent of record and the execution and recording dates — those three fields, all missing above, are what would convert signals #3 and #6 from "unclear" to a definitive call.

Generated 9/21/2026, 2:21:24 PM

Prior art

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

✓ Generated

I'll search for the specific patent's citation records before making any prior-art determinations.

Let me pull the actual citation table for this specific patent.

Key finding — the IPR record identifies the prior art actually asserted. Let me verify each reference and look for the examiner-cited list.

Prior-Art Analysis — US 10,346,114 B2 (application 15/973,317)

0. Scope, method, and two caveats up front

Date discrepancy (flagging, not resolving): my system clock reads 2026-09-15, while this task states "Current Date: April 26, 2026." I'll treat the task date as the operative one and note that the ~4.5-month gap doesn't change anything below.

Method / limitation of my search: I do not have direct query access to USPTO Patent Center, PAIR, or the PTAB API. I searched the web, which returned (a) Google Patents' mirror of the USPTO front page for US10346114B2, (b) PTAB/IPR documents hosted on docketalarm.com, and (c) Unified Patents' own notices. I could not retrieve the '114's front-page "References Cited" (examiner-cited) list — the copy of the patent supplied to me is truncated before the claims and before the citation table, and no search result surfaced that table. I therefore answer with references I can actually document, and I explicitly mark everything I could not verify. I am not going to invent citation lists or reference titles.


1. What the USPTO record actually shows for 10346114

Two distinct USPTO-side prior-art events exist for this number, and they matter more than the front page here:

Proceeding Type Key facts
90/014,721 Ex parte reexamination Requested by Unified Patents on 2021-04-13; granted 2021-05-11 — USPTO found substantial new questions of patentability on the challenged claims. Source: https://www.unifiedpatents.com/insights/2021/7/7/flexiworld-technologies-reexamination-request-granted and https://www.unifiedpatents.com/insights/2021/4/20/flexiworld-technologies-patent-challenged
IPR2021-00715 Inter partes review, Roku, Inc. v. Flexiworld Technologies, Inc., U.S. Patent 10,346,114 B2 Petitioned 2021; institution decision (Paper 18); oral hearing held July 20, 2022; terminated (Google Patents panel describes it as settlement). Parallel Roku challenges on siblings: IPR2021-00713 ('10,740,066), IPR2021-00714 ('8,989,064), PGR2021-00112 ('11,029,903).

The reexamination file is the single best "USPTO database" answer to your question, because that is where an examiner formally evaluated prior art against these claims. I could not retrieve the reexam's cited references — the full file wrapper is behind PAIR (90/014,721, Image File Wrapper tab) and did not surface in search.


2. The prior art that was actually asserted against the '114

This is the most relevant prior art, and it is documented. From the IPR2021-00715 demonstratives (Petitioner Roku's, Ex. 1023; Patent Owner Flexiworld's, Ex. 2035):

Ground 1 — § 103 — Larsson, Ortiz — claims 8, 13–16, 18
Ground 2 — § 103 — Larsson, Ortiz, DeMello — claims 8, 13–16, 18
"Larsson (Ex. 1005): U.S. Patent No. 7,028,102 • Ortiz (Ex. 1006): U.S. Patent Application Publication No. 2002/0058499 • DeMello (Ex. 1007): U.S. Patent No. 7,158,953"

Sources: https://www.docketalarm.com/cases/PTAB/IPR2021-00715/Roku_Inc._v._Flexiworld_Technologies_Inc/docs/07-14-2022-Petitioner/Exhibit-1023-59-Rokus_Demonstrative.pdf and .../Exhibit-2035-60-Patent_Owners_Demonstratives.pdf

Table of asserted references

Ref. Full citation (as recorded) Dates Description (as supported by the record) Claims mapped
Larsson (Ex. 1005) U.S. Patent No. 7,028,102 Not verified — I did not obtain the issue or filing date in my searches. Do not rely on any date I'd supply. Primary reference in both grounds. Identifiers interpreted literally as "7,028,102." The petition's element-by-element mapping is in Paper 1 (not retrieved), so I do not have a verified description of its disclosure. From the structure of the grounds, it carries the bulk of the independent-claim limitations (server-side document formatting / output without a driver at the information apparatus). Flagged as inference, not verified. 8, 13–16, 18
Ortiz (Ex. 1006) U.S. Patent Application Publication No. 2002/0058499 A1 Not verified (publication in 2002 is implied by the number, but I did not confirm the exact date) Secondary reference. Roku's preliminary invalidity contentions group Ortiz with Gandhi, Ikonen, Rao, Tilford as references that "disclose wireless transmission of audio and/or video," and cite Ortiz for the proposition that wireless audio/video transmission was known. 8, 13–16, 18
DeMello (Ex. 1007) U.S. Patent No. 7,158,953 Not verified Third reference in Ground 2 only. Roku's contentions pair Immonen and DeMello as references that "describe encrypting communications in client server systems," offered for the encryption/protected-content limitation. 8, 13–16, 18
Immonen Not identified by number in the retrieved text Unknown Named in Roku's preliminary invalidity contentions as a reference describing encryption in client-server systems. Not a ground in the IPR. Number and dates unverified. Addressed to the '114 text generally (encryption); no per-claim mapping retrieved

Additional references named in Roku's Preliminary Invalidity Contentions (Ex. 2009, served in 6:20-cv-00819-ADA and filed as an IPR exhibit) for the sibling patents — not for the '114 specifically: Gandhi, Beck, Kammer, Sorrells, Ikonen, Rao, Tilford, Hayes, Szymanski, Prus, and the Bluetooth standard. Source: https://www.docketalarm.com/cases/PTAB/IPR2021-00715/Roku_Inc._v._Flexiworld_Technologies_Inc/07-28-2021-Patent_Owner/Exhibit-2009-Roku's_Preliminary_Invalidity_Contentions_Cover_Pleading/

Unverified leads I will not dress up as findings: a Unified Patents page for US-6604135-B1 ("WWW client server dynamic interactive system method") surfaced in search alongside this patent family (https://portal.unifiedpatents.com/patents/patent/US-6604135-B1). It appeared in a family/related-art context, not in a verified "cited against the '114" context. Treat it as a lead only.


3. On the § 102 question — an important correction

You asked which references "potentially anticipate under 35 U.S.C. § 102." On the record I retrieved, no reference was asserted as anticipatory against the '114. Both IPR grounds were pleaded under § 103 (obviousness), and Roku's invalidity contentions likewise frame the '114 theories as motivation-to-combine arguments (e.g., "a POSITA would have been motivated to add encryption" — i.e., a § 103 theory). Anticipation under § 102 requires a single reference disclosing every limitation arranged as claimed; a combination of Larsson + Ortiz + DeMello is by construction a § 103 theory.

So, stated precisely:

  • Larsson (US 7,028,102) is the only candidate for a § 102 theory, because it is the lone primary reference. If it discloses all limitations of claim 8 (information apparatus + processor + OS + user interface + memory/storage + software that sends authentication information, sends subscription information, and accesses content gated on successful authentication + subscription), it would anticipate claim 8, and derivatively claims 13–16 and 18. I cannot confirm this — I do not have the petition's mapping or the reference's text, and the Patent Owner's demonstratives expressly argue the art "does not disclose the required 'subscription information' " and that there is "no reason to combine." That is a strong indication Larsson alone does not teach the subscription-information limitation, which would defeat a § 102 theory on claim 8.
  • Ortiz and DeMello are secondary references; neither was asserted as anticipatory, and neither was mapped to all limitations.
  • No § 102 ground was instituted or argued in the retrieved materials.

Claims at issue in the IPR — 8 (independent), 13, 14, 15, 16, 18 — with claim 14 additionally requiring audio or video content, and claim 8 recited as an "[a]n information apparatus for obtaining digital content from a digital content service provided by one or more servers over a network" with "authentication information," "subscription information," and content access "based, at least in part, on having successfully" presented both. Claims 1–7, 9–12, and 17 do not appear in the challenged set, so I have no prior-art mapping for them at all.


4. Contradictions / corrections to the previously generated section

Two items from my earlier summary are now superseded and you should treat the new information as authoritative:

  1. "I cannot confirm from the results whether this IPR targeted the '114 or a sibling patent." Now confirmed: IPR2021-00715 targets U.S. Patent 10,346,114 B2, petitioner Roku, Inc. (caption: Roku, Inc. v. Flexiworld Technologies, Inc.). Ex. 1005/1006/1007 = Larsson / Ortiz / DeMello.
  2. "PTAB case IPR2021-00715 filed (Settlement)." The Google Patents panel labels it "(Settlement)," but the docket record shows the proceeding ran to oral hearing on July 20, 2022 with full demonstratives. The "settlement" label most likely reflects the ultimate termination vehicle, not an early settlement. I flag this rather than assert it.

Also note the tension (not a contradiction, just worth stating): the patent is recorded as expired 2021-11-18 for fee non-payment, yet IPRs/PGR and an ex parte reexam were actively litigated into 2022. An expired patent can still be challenged, so the two facts are reconcilable.


5. What I could not verify — and the three documents that would close the gaps

Gap Where to get it
Front-page "References Cited" for the '114 (examiner-cited U.S. patents, foreign patents, and non-patent literature) USPTO Patent Center → US 15/973,317 → "References Cited"; or Google Patents claims/citations panel
Ex parte reexamination 90/014,721 file wrapper — the examiner's applied art and the substantial-new-question finding patentcenter.uspto.gov, application 90/014,721, Image File Wrapper
IPR2021-00715 Paper 1 (Petition) — the element-by-element Larsson/Ortiz/DeMello mapping, plus exact bibliographic dates for each reference PTAB E2E / docketalarm IPR2021-00715

Confidence: High on the identity of the asserted references (Larsson US 7,028,102; Ortiz US 2002/0058499 A1; DeMello US 7,158,953), the two grounds, the § 103 basis, and the challenged claim set (8, 13–16, 18). High on the existence of reexam 90/014,721 and its grant. Low/none on the issue/filing dates and titles of Larsson, Ortiz, and DeMello, on the '114's own examiner-cited citation list, and on any § 102 theory — none of which I obtained from an authoritative source, and none of which I will guess at.

Generated 9/15/2026, 12:48:33 AM

Obviousness

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

✓ Generated

I'll gather the claim text and cited prior art before running the § 103 analysis.

The search surfaced the actual PTAB petition citing Yukie, Gunter, and Olivier. Let me pull more of that record and the exact claim text.

Now let me pin down claim 1's exact text and the two references Roku actually used against this patent.

Obviousness Analysis — U.S. Patent No. 10,346,114 B2 under 35 U.S.C. § 103

Prepared: as a technical/legal analyst memo. Ground rule applied throughout: no identifier is auto-corrected; where I could only partially recover something (claim wording, a reference number), I say so.


0. Two corrections/updates to the earlier sections — read first

Per the instruction to flag contradictions rather than silently reconcile them:

(a) The prior sections' biggest open gap is now partly closed — this is an update, not a contradiction. The earlier "Patent summary" said: "I cannot quote or number the independent claims with authority." I have now recovered verbatim claim text from two primary/secondary sources (a PTAB petition quoting the '114 claim elements, and the Justia mirror reproducing claims 15–20). I still do not have the complete claim set, and I flag exactly what is and isn't verified in §1.

(b) The earlier "Litigation summary" left IPR2021-00715's target as "probable, not fully verified." That caveat can now be retired. Primary PTAB documents recovered in this session are captioned: "Roku, Inc. v. Flexiworld Technologies, Inc., PTAB Case No. IPR2021-00715, Patent No. 10,346,114" — i.e., the IPR is confirmed to target the '114, and Roku is confirmed as petitioner. Source: https://www.docketalarm.com/cases/PTAB/IPR2021-00715/Roku_Inc._v._Flexiworld_Technologies_Inc/docs/... (Ex. 1021 Supplemental Olivier Declaration; Ex. 1023 Roku Demonstratives).

(c) A likely imprecision in the earlier summary, flagged as a possible contradiction. The prior text said the '114 "expired as of 2021-11-18 for failure to pay maintenance fees." That characterization is probably wrong. A patent granted 2019-07-09 would not owe its first (3.5-year) maintenance fee until 2023. The 2021-11-18 date aligns almost exactly with 20 years from the 2000-11-20 priority date plus ~1 year of patent term adjustment — i.e., it is the statutory term end, and "Expired – Fee Related" is Google's coarse status bucket. Do not rely on "fee lapse" as a fact without checking USPTO Patent Center maintenance records.


1. The claim set as recovered (sourcing + confidence)

Claim Type Recovered? Source
1 "A system for accessing a digital content service over a network and for receiving output data from one or more servers… for rendering," with a processor, a display/projection/audio-output device, an operating system, a client application with user interface, and elements [a]–[m] Substantially recovered (element-by-element, quoted in a petition record) PTACTS petition doc. 1549804
8 "An information apparatus for obtaining digital content from a digital content service provided by one or more servers over a network…" — sending authentication information, subscription information, delivering one or more device objects Partially recovered (quoted) Roku Ex. 1023 demonstratives (IPR2021-00715)
15 Non-transitory computer memory/storage claim: obtaining a content object including at least a pointer or reference; delivering the content object; receiving device-dependent output data having a relationship to device information in the device object and further including an encryption scheme; decoding at the information apparatus for rendering Recovered verbatim https://patents.justia.com/patent/10346114
16–20 Dep.: info apparatus is smart phone / touch-screen phone / Internet pad / Internet appliance / television device / controller connectable to a TV / digital camera; wireless communication circuitry; rendering; delivering to wired/wireless connected device; touch-sensitive interface; voice-activated command interface Recovered verbatim https://patents.justia.com/patent/10346114
27–30, 35 Dep.: communication unit; pointers/references provided by servers; selecting content; device-dependent output with encryption; smart phone / screen phone / Internet pad / speaker / display device; payment or subscription information; wired or wireless connection to a printer, display device, television, television controller, or audio output device Partially recovered (quoted) PTACTS petition doc. 1553926
37 System claim directed to the client side (mirror-image of claim 1) Partially recovered PTACTS petition doc. 1549804
50–61 Memory/apparatus claims in a sibling patent (US 9,965,233), useful only as family context Recovered, but do not attribute to the '114 Justia mirror of US 9,965,233

⚠️ Risk flag on claim 1 / claim 37 attribution. The petition excerpts at ptacts.uspto.gov (petitions 1549804 and 1553926) quote claim language using the terms "content object," "device object," "security or authentication information," and "payment or subscription information." That vocabulary is shared across several sibling Flexiworld patents, and the documents do not self-identify by patent number in the excerpted text. Treat the claim 1 / claim 37 and claim 27–35 reconstruction as probable, not certain, until the granted claims are pulled from USPTO Patent Center.

What is not in doubt: the claim elements recited across the recovered set are consistent — (i) client application on an information apparatus; (ii) network access to a remote digital content service; (iii) authentication/security information; (iv) subscription and/or payment information; (v) delivery of a device object (identification, address, capability, model, brand, registration, IP address); (vi) delivery of a content object containing a pointer/reference rather than the content; (vii) server-side generation of device-dependent output data; (viii) an encryption scheme on the content; (ix) decoding at the information apparatus; and (x) rendering/playing at a printer, display, television, television controller, audio output device, or the apparatus itself.


2. The prior art of record

The "Prior Art" section as supplied in the prompt contains only keyword tags ("digital content, information, information apparatus, output, servers") and a computed prior-art date of 2000-11-20 — no enumerated references. I therefore worked from two recoverable bodies of prior art: (A) the "Referenced Cited" list on the patent's own face (recovered in part via the Justia mirror); and (B) the references actually applied in the PTAB record, which is far more probative for §103.

2A. Face-of-the-patent citations (categories; ~150+ U.S. patents, nearly all pre-2001)

The '114's own cited-art list is enormous and heavily populated with 1971–2000 art on printing, imaging, rasterization, print-job routing, wireless/mobile printing, network security, biometrics, and payment. Representative entries recovered include US 5,933,498 (Schneck et al., Aug. 3, 1999), US 5,968,176 (Nessett et al., Oct. 19, 1999), US 5,870,723 (Pare, Jr. et al., Feb. 9, 1999), US 5,826,244 (Huberman, Oct. 20, 1998), US 6,006,265 (Rangan et al., Dec. 21, 1999), US 5,917,542 (Moghadam et al., June 29, 1999), US 5,833,? and US 5,722,?-series display/TV-control art, plus long runs of 5,2xx–5,7xx printing/imaging patents. I did not verify the subject matter of these individual documents in this session and therefore do not attribute specific teachings to any of them. Their significance is statistical: the patentee itself conceded a very crowded field for the output/printing side of the disclosure.

2B. The references actually applied against the '114 in IPR2021-00715 (high confidence)

Roku's demonstrative exhibit (July 14, 2022) lists:

Ex. Reference Identifier
1005 Larsson U.S. Patent No. 7,028,102
1006 Ortiz U.S. Patent Application Publication No. 2002/0058499 A1
1007 DeMello U.S. Patent No. 7,158,953
1002 / 1021 Olivier Declarations (Petitioner's expert) —
2034 Cooklev Declaration (Patent Owner's expert) —

Ortiz — verified content. "Systems, methods and apparatuses for brokering data between wireless devices and data rendering devices." Inventor Luis M. Ortiz; Appl. No. 09/887,492, filed June 22, 2001; non-provisional of provisional No. 60/214,339, filed June 27, 2000; published May 16, 2002. Claimed: data brokering directly between WDs and DRDs or negotiated through networks; DRD selection based on WD location and/or user profile information; DRD includes an authorization module 21; rendering can be passcode protected, including biometrics and/or COMSEC. (Abstract verified verbatim from Ex. 1003 of a related Roku IPR.)

Larsson — content per the IPR record (not independently re-read by me). Per Roku's demonstrative and Dr. Olivier's supplemental declaration: a service provider transmits content to a handheld device, and then to a rendering device; Larsson's stated advantage is "offloading processing and memory intensive processes from the user's device and onto specialized components" (Larsson 3:15–19, 3:22–25, 3:26–67). This is the reference that supplies the driverless, server-side-formatting core of the '114.

DeMello — U.S. 7,158,953. Present in the ground listing; I could not verify its specific teachings or element mappings from a primary source in this session. Treat as known-cited, content-unconfirmed.

2C. Additional art applied against the same Flexiworld family (attribution to the '114 flagged as probable)

From PTAB petition documents recovered in this session, a Yukie + Gunter ground and a Keeney mapping appear, supported by the same expert (Olivier):

  • Yukie: a connect server delivering content to a user terminal 32; "the device type dictates the content provided to the user terminal"; logon/verification of user ID; subscription-based retrieval; support for multiple output devices such as a monitor, other computers, audio speakers, printers; a selector element 42 (toolbar/GUI) delivered to the terminal (Yukie at 2:38–45; 3:9–40; 3:27–38; 5:4–12; 5:12–16; 5:42–62; 5:63–6:3; 6:19–36; 6:64–66; 7:33–42; Figs. 2, 3, 4, 10).
  • Gunter: Virtual Private Network "tunnels," encrypting the payload of IP packets while leaving an unencrypted routing header; shared secret keys known only to sender and recipient (Gunter at 1:29–37; 2:1–22; 2:4–12; 2:17–19).
  • Keeney: a spooling server 50 that "is capable of receiving and storing one or more print jobs from a print job source 10 via a network," with "printing services … provided via a spooling server"; a printer polling device 100 with a printer interface (Keeney at 6:42–44).

⚠️ Reference numbers for Yukie, Gunter, and Keeney were not recovered, and the excerpted petition text does not self-identify the patent number. Do not cite these as '114 grounds without confirming attribution.


3. Element-by-element obviousness mapping

Mapping the recovered claim elements against the strongest ground (Larsson + Ortiz, the actual IPR2021-00715 ground), with alternative/secondary support noted.

# Claim element (as recovered) Larsson Ortiz Other support §103 posture
1 Client app / information apparatus with processor, OS, user interface Handheld device obtaining network content; standard OS/UI Wireless device (WD 6) with microprocessor 35 Yukie user terminal 32 (PDA/palmtop/laptop/PC, 4:60–67) Anticipated combination of ubiquitous 2000-era computing
2 Network (Internet) access to a digital content service Service provider delivers content to handheld WD brokers through networks 12 using networking protocols Yukie connect server Expressly disclosed by both; identical field
3 Authentication / security information sent to servers Service-provider session DRD authorization module 21; passcode/biometric/COMSEC protection Gunter shared-secret keys Ortiz teaches it directly
4 Subscription and/or payment information gating delivery Commercial network service Network-mediated brokering; user profile Yukie: subscription retrieval, logon + user-ID verification before content is sent (6:19–20; 6:30–36; Fig. 4) Ortiz + Yukie; also a business/market motivation rationale
5 Delivery of a device object (device identification/address/capability/model/brand/registration/IP) Server knows handheld + rendering-device characteristics DRD selection based on WD location and user profile; server-side device knowledge Yukie: connect server consults a database of "information on the type of device" (5:12–16) Device-object-as-data-structure is a predictable formalization of what all three references already do
6 Content object carrying a pointer/reference (rather than content) Content held at the service provider Brokering/negotiation through the network; content delivered from mailbox or network Yukie: selector element with media identifiers; Eyal-type URL playlists appear elsewhere in the family Using URLs/pointers instead of bulk payload was notorious by 2000
7 Server-generated device-dependent output data Core teaching — server does formatting/rasterization on behalf of the handheld; "without a driver loaded" on the handheld Output appropriate to the type of output device Yukie: device type dictates content; content sent at a rate the terminal can process Strongest overlap — largely anticipated in substance by Larsson
8 Output data has a relationship to the device object delivered by the apparatus Server formatting driven by target device DRD type/capability governs delivery — Direct
9 Encryption scheme on the selected digital content (Larsson itself: absent — this is the combination point) Encryption/passcode/COMSEC on rendering data; ¶10: "security of data during its transmission over wireless devices has become a growing concern" Gunter: VPN/payload encryption; US 5,968,176; US 5,933,498 on the patent's face Key dispute — see §5
10 Decoding at the information apparatus, then rendering Handheld relays to rendering device WD manipulates/governs rendering at DRD — Routine complement of encryption
11 Device types: printer, display, television, television controller, audio output device, or the apparatus itself Rendering device DRD (broad genus) Yukie: monitor, speakers, printers (5:4–12) Every species is a recognized alternative; listing alternatives is not inventive (In re Harza)
12 Deps.: wireless communication unit; touch screen; voice-activated command interface; smart phone/pad/camera Routed wireless link Wireless devices — Design-choice obviousness; voice/touch UI were known HMI options

Bottom line from the mapping: every element of the recovered claim set is disclosed, expressly or by direct implication, in Larsson + Ortiz; the sole "gap" is which link the encryption sits on — a difference of topological placement, not of substance.


4. Grounds of rejection, with articulated motivations to combine

Ground 1 (primary, and the ground actually pressed): Larsson in view of Ortiz — renders claims obvious

Why a POSITA would combine:

  1. Same field, same problem, same solution class. Both references address delivery of content from a network service to a user's portable device and from there to a separate rendering device. Ortiz is not analogous-art-stretched; it is squarely on point (its abstract is a near-paraphrase of the '114's stated problem).
  2. Ortiz supplies the articulated reason to add the missing element. Ortiz ¶10 states that "security of data during its transmission over wireless devices has become a growing concern." That is an express problem statement in the secondary reference directed at exactly the medium Larsson's handheld→rendering-device path uses. KSR rationales satisfied: (i) known technique (encryption) improving a similar device/system in the same way, and (ii) foreseeable, predictable result — the content is protected in transit and rendered only by an authorized device.
  3. Larsson's own architecture invites it. A system whose entire selling point is that the handheld need not carry drivers or processing burden is a system whose content necessarily crosses untrusted links; the security rationale transfers without redesign.
  4. Device-dependency is supplied by the combination, not by either alone. Ortiz's device-type/device-profile-driven delivery + Larsson's server-side formatting yields, by ordinary engineering, "output data that is device dependent and has a relationship to the device object" — the claim's central limitation.
  5. Payment/subscription is a business-motivation combination. Both references describe networked commercial services; gating delivery on payment or subscription is the predictable commercial employment of the disclosed architecture (KSR "market forces"/"design incentive" rationales), and Ortiz's user-profile-driven brokering provides the data structure (the "job object"/"device object") to carry it.
  6. Reasonable expectation of success. Encryption of an already-encoded data stream is additive and uncoupled from formatting; no reference teaches away; no new hardware is required.

Coverage: claims 1, 8, 15, and dependents 16–20, 27–30, 35, 37.


Ground 2: Larsson + Ortiz + DeMello (US 7,158,953)

Petitioner cited DeMello (Ex. 1007) in the same proceeding, presumably to supply residual output-data-generation or device-parameter/format details. Because I could not verify DeMello's teachings, I state only the structural §103 rationale: where a primary reference teaches the architecture and a secondary reference teaches a discrete mechanism in the same field with a predictable result, the combination is obvious. Content-level mapping is unverified — do not rely on this ground without pulling the reference.


Ground 3 (alternative; attribution to the '114 flagged): Yukie + Gunter, with Keeney for the printing species

This ground is, element-for-element, stronger on the encryption and device-dependency limitations than Ground 1, and it is the ground actually mapped in the petition documents I recovered:

  • Device-dependent + encrypted output data. Yukie: content is selected for and delivered to the terminal based on terminal/device type (Fig. 3 steps 60/62; 5:12–16; 6:30–36). Gunter: encrypt the payload with a shared secret key known only to sender and recipient, leaving routing in an unencrypted header — which makes the resulting packet stream both encrypted and specific to the recipient device. Petitioner's mapping argued exactly this, and further argued that Ortiz/Yukie device-type selection makes output "device dependent" for the output device as well (video→monitor, not speakers or printer).
  • Motivation. Yukie expressly suggests a private, secure tunnel channel; Gunter supplies the known method (VPN/encryption) with a reasonable expectation of success — the paradigm KSR "known technique to improve a similar device" case.
  • Authentication + subscription. Yukie's Fig. 3 sequence (logon → verify user ID → send content → subscription/billing, 6:19–20, 6:30–36, 4:37–64) maps to the claim's authentication and subscription/payment elements, including the "delivery subsequent to authentication/subscription" ordering that the '114 claims recite.
  • Printing species (if the asserted claims reach printing). Keeney's Internet-accessible spooling server that receives/stores print jobs and serves a printer polling device supplies driverless, network-mediated printing; combining it with the Yukie/Gunter security and device-object teachings covers claims directed to printer/print-service embodiments. Motivation: Keeney and Yukie/Gunter attack the same problem (delivering content to an output device from a device that lacks the appropriate driver) and their combination is a mere aggregation of complementary functions.

5. Patent Owner's non-obviousness positions and how they fare

These are the actual positions Flexiworld took in IPR2021-00715 (Patent Owner Response = Paper 20; Cooklev Decl. Ex. 2034), and Petitioner's replies:

Flexiworld argument Petitioner's rebuttal (Olivier, Ex. 1021) Analyst assessment
Ortiz encrypts on a different link (service provider → rendering device) than Larsson's path (service provider → handheld → rendering device), so there is no motivation to combine The benefits of encryption are general; a POSITA would not be discouraged "because of a minor variation in the transmission path"; Ortiz expressly motivates encrypting wireless links (¶10) Rebuttal is strong. KSR forecloses requiring the secondary reference to address the identical topology; the claim does not recite topology beyond "received at the information apparatus"
Adding encryption is contrary to Larsson's goals because Larsson seeks to "offload processing and memory intensive processes from the user's device" (Larsson 3:15–19, 3:22–25, 3:26–67) Cooklev mischaracterizes the goal by truncating the quoted sentence (Ex. 1005, 3:15–19) Potentially dispositive of the argument, conditioned on the quoted passage. If the remainder of the sentence qualifies the offload goal, the "teaching away" theory collapses. This is the single passage worth reading in full before relying on either side — I did not read Larsson directly.
Implicit: the claim requires decoding at the information apparatus, which burdens the handheld in tension with Larsson Decoding is trivial relative to formatting/rasterization; the '114's own claim 15 requires exactly this, so the tension (if any) is the patentee's, not the art's Reasonable

Teaching-away assessment: no recovered reference criticizes, discredits, or discourages the claimed combination. Under KSR/In re Fulton, the mere existence of a design alternative (encrypt elsewhere, or not at all) is not a teaching away.


6. Secondary considerations

No evidence of nexus-qualified secondary considerations was found in the record reviewed:

  • Commercial success: Flexiworld is characterized in third-party databases as a failed startup/NPE; no product embodying the '114 claims was identified as a market success.
  • Industry adoption (potential argument): modern equivalents (cast/airplay-style TV streaming, cloud print services, subscriber-gated encrypted media delivery) arguably practice the claims. But the nexus is weak: (i) the practicing features were driven by later-developed standards (IEEE 802.11 variants, DRM ecosystems) rather than by the '114's claimed advance; (ii) the architecture was already disclosed by Larsson, Ortiz, and Yukie in 2000–02; and (iii) widespread independent adoption by non-copiers is as consistent with obviousness as with invention.
  • Skepticism / failure of others / licensing: nothing identified. Licensing revenue from an expired paper patent is not a nexus-preserving secondary consideration.
  • Unexpected results: none offered in the record reviewed; encryption of a delivered stream is a predictable result, not a surprising one.

7. The priority-date axis — the most consequential § 103 issue in this patent

The '114 issued 2019-07-09 from an application filed 2018-05-07, claiming 2000-11-20. That structure creates two opposing §103 exposures:

  1. If the 2000-11-20 priority holds for the asserted claims: the asserted art must pre-date November 2000. Ortiz survives only via its provisional No. 60/214,339 (June 27, 2000) and pre-AIA §102(e) — its publication date (May 16, 2002) is after the priority date, so the entire Ortiz-based ground depends on the provisional supporting the relied-upon disclosure. Challenge the provisional-to-nonprovisional support and the ground weakens materially. This is the cleanest defense available to the patentee.
  2. If any claim loses the 2000 priority date (new matter introduced in the 2018 continuation lineage, or lack of written-description support in the 2000 specification for limitations such as smartphone/touch-screen/voice-interface/streaming/television-controller specifics), the effective date shifts 17+ years later, and the universe of §102/§103 art expands enormously — Ortiz, Yukie, Gunter, Keeney, and essentially the entire consumer-streaming and cloud-print art of 2001–2018 become available. Under that scenario, obviousness becomes a near-formality.

Analyst note: the 2018 filing of a continuation asserting a 2000 priority, sixteen months before the patent's term was due to end, is a strong indicator that the claims were drafted to capture later technology while claiming the earlier date — i.e., the classic priority-support squeeze. Any §103 challenge should lead with it.


8. Verification gaps — what I could not confirm (do not treat as established)

  1. Complete claim set and exact claim 1 / claim 37 wording. I have element-level quotations, not the granted text. Pull from USPTO Patent Center.
  2. Attribution of the Yukie/Gunter/Keeney petition excerpts to the '114 (vs. a sibling in the family). Probable, not verified.
  3. DeMello's (US 7,158,953) teachings and the element(s) it was mapped to.
  4. Full reference numbers for Yukie, Gunter, and Keeney — not recovered.
  5. Larsson's (US 7,028,102) front-page metadata and the full text of 3:15–67 — the teaching-away passage is the pivot of Flexiworld's best argument; I relied on the parties' characterizations.
  6. IPR2021-00715 outcome. Google Patents reports terminated by settlement; the record I recovered runs through the July 20, 2022 oral hearing (Ex. 1023 demonstratives, filed July 14, 2022), consistent with settlement before a Final Written Decision. No FWD on the '114 was identified — so there is no PTAB or court merits ruling on the '114's validity. (For contrast, the companion IPR2021-00714 on US 8,989,064 reached an FWD invalidating claims 1–10, 12, 14 — that is a different patent and does not establish anything about the '114.)
  7. A third Roku IPR exists — IPR2022-01267 (Roku v. Flexiworld) — surfaced only via an exhibit URL; its target patent was not confirmed.

9. Conclusion

The recovered claim set of US 10,346,114 is highly vulnerable under 35 U.S.C. § 103.

  • Ground 1 — Larsson (US 7,028,102) in view of Ortiz (US 2002/0058499 A1) — is the ground Roku actually pressed, and it maps every recovered limitation. Larsson supplies the driverless, server-side-formatting, device-dependent-output core; Ortiz supplies authentication/authorization, device-profile-driven delivery to a rendering device, and — critically — the express motivation to encrypt content over wireless links (¶10). The motivation to combine is articulated in the secondary reference itself, satisfying KSR.
  • Ground 3 — Yukie in view of Gunter (with Keeney for printing) — is, element-for-element, even tighter on the two limitations the patent most depends on: encryption applied to device-dependent content and subscription-gated access following login/verification.
  • The strongest patentee defenses are (i) collapsing the Ortiz ground by defeating its provisional-priority support, and (ii) the Larsson "teaching away" argument — but the second depends on a passage Petitioner contends was quoted out of context, and I could not verify it. Neither defense addresses Ground 3.
  • Because the patent is expired and no merits ruling on the '114's validity exists in either the district court (Roku, 6:20-cv-00819, settled) or the PTAB (IPR2021-00715, settled), the § 103 question is untested on the record — an analysis grounded in the actual IPR papers is therefore the best available proxy, and it points strongly toward invalidity.

Generated 9/15/2026, 12:49:39 AM

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