Invalidity dossier

US 10866100

Added 9/24/2026, 3:04:43 PM

At a glanceNo PTAB challengesNo litigation on fileSoftware Technology & Computing Systems (T)

Active provider: DeepSeek · deepseek-v4-flash

Patent summary

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

✓ Generated

I'll search for authoritative records on US 10866100, including any CAFC/litigation activity.

Let me check for litigation/docket activity and the full independent claim set.

Let me do one more targeted check for any 2026 appellate activity and for the patent's own claimset/independent claims.

US Patent 10,866,100 — Summary

Confidence note: Bibliographic data and claim 1 text below are grounded in the fetched Google Patents / Justia records. I could not locate any CAFC 2026 docket, appeal, or decision involving this patent; the appellate portion of your request returned no authoritative hits. Details below are flagged accordingly.

Bibliographic data (literal, as recorded)

Field Value
Patent number US 10,866,100 B2
Title Method of providing urban hiking trails
Inventors Jorge Carlos Kuri; Louis P. Huynh; Roger Obando
Assignee KAMINO LABS, Inc. (original and current per the record; assignment reel/frame 030172/0298, effective 2013‑03‑15)
Application no. 13/839,007
Priority date 2012‑10‑15 (provisional 61/713,903)
Filing date 2013‑03‑15
Issue/publication date 2020‑12‑15
Legal status Active; adjusted expiration 2033‑07‑13
Also published as US20140108137A1; continuation US20210199436A1 (appl. 17/094,207, filed 2020‑11‑10)
Classifications G01C21/00, G01C21/20, G01C21/3874, G06Q10/047, G06Q30/0259, G06Q30/0261

Source: https://patents.google.com/patent/US10866100/en (fetched 2026‑09‑24); https://patents.justia.com/patent/10866100

Abstract

Methods, apparatuses, and computer program products enable a user to create, log, experience, and share experiences, sites, editorial commentary, photographs, and videos along newly created or already-defined tours/routes/hikes ("urban hiking trails," i.e., city walking tours). Users choose among hikes with established sites, stops, and merchants, plus historical/editorial content along the route. Merchant partners can direct focused targeted advertising to users who have begun or are about to physically experience such walking tours.

Independent claims — plain language

Claim 1 — Method for generating a tour on a mobile device (independent)

  1. Receive an indication to generate a tour on the mobile device, where the tour is a user-accessible, downloadable set of temporally sequential GPS coordinates collected from the device in real time as it moves through the real world. The set includes:
  • at least one GPS coordinate assigned as the starting point;
  • a first subset of GPS coordinates as route information (enabling derivation of tour distance); and
  • a second subset of GPS coordinates as stop information, associated with stop content (enabling derivation of searchable tags and keywords).
  1. Obtain a real-time GPS coordinate and associate it as the starting point.
  2. Capture additional GPS coordinates as the tour is generated and associate them in sequence as route information (designated as the first subset).
  3. Determine subsets of GPS coordinates that are co-located within a pre-defined range, indicating candidate stops.
  4. For each candidate stop, determine that the coordinates stayed within the range longer than a predefined time threshold; those qualifying candidates become stops on the tour.
  5. Capture data for the stops, including the device's current location when a stop indication is received plus one or more of tips, recommendations, commentary, ratings, and images.
  6. Receive an indication that the tour is complete; the tour is configured to be stored or distributed via social networks.
  7. Store the tour by uploading it from the device to remote storage (including stop data and captured route/location information).
  8. Transmit a merchant interface to a merchant device that, when used by a merchant, is configured to: determine that the tour includes the merchant's location as a stop; display tracking of a user on the tour; display the user's profile (including whether the user has saved the merchant's location); determine that the user has saved that location; transmit a deal offer to the user's mobile device; and display a notification that the user is approaching the merchant's location.

Claim 6 — Apparatus for generating a tour (independent)
Same substance as claim 1, recast as an apparatus having at least one processor and memory with computer program instructions that cause the apparatus to perform the same operations (indication to generate a tour; downloadable chronologically ordered GPS coordinate set with starting point, route subset, and stop subset; real-time capture and sequencing; co-location/duration-based candidate-stop detection; capture of stop content; completion indication; upload to remote storage; and generation of a merchant interface for tracking users, detecting saved merchant locations, and pushing offers/near-approach notifications). Claim 6 is partially reproduced in the Justia record; the full text continues in the same pattern as claim 1.

Dependent claims 2–5 add: creation by an application user and sharing with other users (claim 2); receiving and linking tips/recommendations/commentary/ratings/images to a stop (claim 3); generating stop information from third-party data source providers (claim 4); and providing the completed tour to social networks (claim 5).

Uncertainty: I can confirm claims 1 and 6 as independent claims from the retrieved claim text, but the search snippets did not expose the full claim set of the '100 patent. Given the specification's parallel "generating a hike" / "negotiating (taking) a hike" embodiments, additional independent claims directed to taking/negotiating a tour and to computer program products likely exist in the family — notably claim 37 of continuation US20210199436A1, which recites taking a tour via a touch-screen mobile application, accessing tour information from a server, capturing real-time location, and uploading the temporally sequential GPS coordinate set. I do not have authoritative confirmation of the exact number/scope of every independent claim in the '100 patent itself.

Litigation / CAFC check

If you need claim-by-claim text of the full '100 claim set or a prosecution-history/PTAB check (e.g., any IPR), say so and I'll pull the authoritative claim listing and USPTO PatentCenter/PTAB records directly.

Generated 9/30/2026, 4:24:03 AM

Cases on file (0)

Specific litigation cases in our database that name US patent 10866100. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

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

✓ Generated

I'll search for litigation involving US Patent 10,866,100.

Let me search more specifically for litigation databases.

Let me narrow the search to the specific patent and its owner.

Findings: Litigation involving US Patent 10,866,100

Bottom line: I found no litigation asserting or challenging U.S. Patent 10,866,100 ("Method of providing urban hiking trails").

I searched general litigation indices, the Unified Patents/PTAB ecosystem, Justia Dockets, UniCourt, the Stanford NPE Litigation Database, and CourtListener. None of the results identify U.S. Patent 10,866,100 as a patent-in-suit in any district court, ITC, or Federal Circuit action, and no IPR/PGR naming it as the challenged patent surfaced either.

Important disambiguation — do not conflate these two

My searches surfaced a cluster of cases brought by an entity called "Kamino LLC," which looks similar but is not the owner of the '100 patent and did not assert the '100 patent:

  • The '100 patent's assignee is KAMINO LABS Inc (a walking-tour/social app company; inventors Jorge Carlos Kuri, Louis P. Huynh, Roger Obando).
  • The litigious "Kamino LLC" is a different entity — an NPE asserting unrelated display/backlight patents (e.g., U.S. Patent 6,435,686, "Light conducting plate for a back lighting device").

Examples of the Kamino LLC cases (which I am listing only to show they are NOT about the '100 patent, and which involved different patents):

  • Kamino LLC v. Fujifilm North America Corp., No. 6:20-cv-00001 (W.D. Tex.), filed 01/02/2020
  • Kamino LLC v. Honeywell Int'l Inc. et al., No. 6:19-cv-00707 (W.D. Tex.), filed 12/13/2019
  • Kamino LLC v. [Amazon.com, Inc.](/litigations/by-plaintiff/Amazon.com%2C%20Inc.), No. 6:20-cv-00052 (W.D. Tex.), filed 01/24/2020
  • Kamino LLC v. Best Buy Co., Inc., No. 6:20-cv-00054 (W.D. Tex.), filed 01/24/2020
  • Kamino LLC v. HP Inc., No. 6:20-cv-00055 (W.D. Tex.), filed 01/24/2020
  • Kamino LLC v. AOC International, No. 6:20-cv-00053 (W.D. Tex.), filed 01/24/2020
  • Kamino LLC v. Supersonic, Inc., No. 2:19-cv-07658 (C.D. Cal.), filed 09/04/2019 (voluntarily dismissed with prejudice 10/23/2019)
  • Kamino LLC v. TMAX Digital Inc. et al., No. 5:19-cv-00901 (C.D. Cal.), filed 05/14/2019 (patent US6435686; dismissed 12/19/2019)

These are unrelated to the '100 patent by (a) party, (b) patent, and (c) technology. I flag them solely so they aren't mistaken for '100-patent litigation.

Why "no litigation found" is the appropriate conclusion (with caveats)

  • The '100 patent issued very recently relative to typical assertion timelines — granted 2020-12-15 on an application filed 2013-03-15 (priority 2012-10-15) — and it is a software/business-method-style patent (CPC G06Q 10/047 route optimization; G06Q 30/0261 location-based targeted ads; G01C 21/20 navigation). Such patents are frequently the subject of § 101 eligibility challenges, but I found no such suit here.
  • Search limitations: No public search tool I can run guarantees complete coverage of every district-court docket, and recently filed or sealed complaints may not yet appear. "No litigation found" therefore means none located in the sources searched, not a certified negative.

Recommendation for a definitive answer

To confirm there is truly no litigation (rather than merely none indexed), check, restricted to the exact number 10,866,100:

  1. PACER / Docket Alarm / Lex Machina — full docket text search on "10,866,100."
  2. Unified Patents Portal (https://portal.unifiedpatents.com/litigation/caselist) — filter by patent number.
  3. RPX Insight / Stanford NPE database — search patent number, and search assignee "Kamino Labs Inc."
  4. USPTO Patent Center / PTAB — confirm no IPR/PGR against the number.

If you'd like, I can draft a short "no known litigation" representation paragraph suitable for a due-diligence memo, stating the scope of the search performed and the date of the search (April 26, 2026).

Generated 9/30/2026, 4:24:01 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.

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 start by verifying the structured block's default against the public record before writing anything down.

I ran targeted searches against the PTAB record for this patent and hit no AIA trial proceeding. Because the outcome here is an absence (which is itself a finding), I'm going to state my search limits plainly rather than pad the template with sections that would have to be invented.

Proceedings overview

Total: 0 AIA trial proceedings on file for US10866100. Breakdown by status: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials. The structured USPTO ODP block in the prompt reports no AIA trial proceedings, and supplemental web searches for an IPR/PGR/CBM naming Kamino Labs, Inc. or the '100 patent returned nothing on point.

Bottom-line defensive posture: none of the "hardened" or "narrowed" narratives applies — the patent is completely untested at the PTAB. Every claim (1–5 method claims, 6+ apparatus claims, and the balance of the granted set) stands exactly as issued on 2020-12-15. A defendant cannot point to a single canceled claim, estoppel event, or adverse institution decision. Conversely, the defendant also gets no free ride: the entire invalidity case, including § 102/§ 103 art you may already hold, is still on the table and has not been burned by anyone.

No proceedings to report

I cannot populate the per-proceeding sections (judge panel, petition grounds, institution decision, FWD, settlement, appeal) because there is no proceeding to describe. Inventing a docket number, panel, or disposition would be fabrication, and the instructions expressly forbid it.

Search limitations — stated honestly. My web searches returned no PTAB filing tied to this patent. One later query was cut off at the tool step limit, so I could not exhaust every possible index (PTAB E2E, Docket Navigator, CourtListener docket for the CAFC). Treat "0 proceedings" as well-supported by the authoritative ODP block plus my searches, but not as a cryptographic certainty. The place to confirm is PTAB E2E: https://ptacts.uspto.gov/ptabweb/ (search Application/Certificate number → 13/839,007 or 10866100). If nothing there, nothing exists.

One thing I did surface, and am flagging so you don't conflate it: a different entity called "Kamino LLC" filed a wave of W.D. Tex. (Judge Albright) and E.D. Tex. patent suits in 2019–2020 — e.g., Kamino LLC v. [Amazon.com, Inc.](/litigations/by-plaintiff/Amazon.com%2C%20Inc.), No. 6:20-cv-00052; Kamino LLC v. Fujifilm North America Corp., No. 6:20-cv-00001; Kamino LLC v. TMAX Digital Inc., No. 5:19-cv-00901. Those cases assert unrelated patents (the Korean-language dispute listing identifies US6435686, "Light conducting plate for a back lighting device") against consumer-electronics and tablet makers. That is a different patent portfolio and appears at least facially unconnected to Kamino Labs, Inc., the assignee of the '100 patent. I could not confirm whether the two entities share ownership or are a name collision, and I found no case tying Kamino LLC to US10866100. Do not assume the '100 patent is being actively asserted based on those dockets.

Strategic summary

Claim status. There is nothing to reconcile — all claims are SUSTAINED by default (never challenged), and nothing is CANCELED or NARROWED. Note the granted claim set is the narrowed one: it is materially different from the published application. Independent claim 1 as granted requires much more than the § 101-flavored "generate a tour" concept in the specification. It recites, in relevant part, a "user-accessible and downloadable set of temporally sequential GPS coordinates," designation of candidate stops by determining that co-located coordinates "stayed within the pre-defined range for a duration of time exceeding a predefined threshold," and — the commercially loaded piece — "transmitting a merchant interface to a merchant device" configured to display user tracking, display a user profile showing whether the user saved the merchant's location, transmit a deal offer to the user's mobile device, and display a "notification indicating that the user on the tour is approaching the location of the merchant." That merchant-side tracking/offer-push language is what you must meet element-by-element.

Untested continuation risk. I flag this because it matters more than the empty PTAB docket: the '100 patent has a pending continuation, US20210199436A1 (application 17/094,207, filed 2020-11-10, claiming priority to the same 2012-10-15 provisional via 13/839,007). Its published claims include independent claim 37 and dependents 38–43, drawn to the user-side "take a tour" flow, plus third-party merchant stop pre-population and merchant-offer redemption with arrival authentication. Per Google Patents legal events, that application has received a non-final action, response, final rejection, and advisory action — i.e., active prosecution. A defendant clearing only the '100 patent today may face new claims from the child later, and an IPR filed on the '100 patent will not estop challenges to claims that issue from the continuation.

Estoppel landscape. With zero IPRs, § 315(e)(2) estoppel is empty. No petitioner has been barred from anything; no defendant inherits a narrowed ground set. Every § 102 and § 103 combination available against the 2012-10-15/2013-03-15 priority art remains available to the first petitioner. Be aware of the General Plastic / Valve discretionary-denial framework if you are part of a defendant group where a co-defendant or coordinated party files first — the Board will weigh petitioner relationships and overlapping invalidity work, so sequence your filings with your co-defendants deliberately.

Pattern signals. No same-petitioner repeat filings (there are none at all). No PTAB-to-CAFC appeal history (no FWD to appeal). No defensive aggregator — my searches surfaced no Unified Patents or similar entity in the chain for this patent. The patent owner (Kamino Labs, Inc., San Diego, per the 2013 DMCA designation, officers Jorge Carlos Kuri, Louis P. Huynh, Roger Obando) has not litigated the '100 patent — the assignee's only public footprint I could find is the 2013 copyright-agent filing and continued prosecution of the continuation. This is a patent with a small, quiet owner and no assertion history, not a hardened war-chest patent.

Recommended next steps

  1. Confirm the null result, don't assume it. Pull PTAB E2E for the '100 patent and, separately, run the pending application 17/094,207 — a proceeding styled to the continuation would not show up under 10866100. E2E: https://ptacts.uspto.gov/ptabweb/. Cross-check the CAFC docket and CourtListener for any Kamino Labs appeal.

  2. Treat the board as open. Because nothing has been filed, you are the de facto first petitioner. That is the strongest posture you can hold procedurally: you get to pick the best art and the best claims, and you cannot be hit with General Plastic for a follow-on petition against the same claims — provided you file one clean, complete petition rather than a staged pair.

  3. PGR is closed; CBM is closed; only IPR remains. The patent granted 2020-12-15, so the 9-month PGR window under § 321(c) expired on 2021-09-15. CBM review is unavailable for petitions filed after the transitional-program sunset of 2020-09-16. Your only AIA vehicle is IPR. Per § 311(b), IPR is limited to § 102/§ 103 grounds on patents and printed publications — you cannot raise the § 101 eligibility or § 112 written-description arguments in an IPR, even though a "walking tour social app" patent is the kind of subject matter where § 101 has historically done work. Those must be litigated in district court or raised via Alice at the pleading stage.

  4. Get your § 315(b) clock under control now. If the patent owner or the pending continuation's claims ever reach you via a complaint, the one-year bar from service of the complaint (§ 315(b)) starts immediately, and the statutory 1-year trial deadline from institution (§ 316(a)(11)) means you will be tried to a FWD quickly. There are no existing trial-stage milestones to track (no institution decision, oral hearing, or FWD is scheduled, because no trial exists).

  5. If the asserted claims were claim 1: there is no FWD to link and no disposition to quote — claim 1 was never adjudicated. The only textual authority about that claim is the issued patent itself. Ground your defense on the granted claim text (Note: I retrieved the granted claims of claim 1 from the Justia patent page; the authoritative source is the patent document, https://patents.google.com/patent/US10866100/en), and build the invalidity case from scratch. Nothing you find is pre-empted by anyone else's prior work — which is exactly the opening, not a reason for comfort.

Generated 9/30/2026, 4:24:16 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. 2013-03-15 · recorded 2013-04-08 · reel 030172/0298 · Assignment

    KURI, JORGE CARLOS; HUYNH, LOUIS P.; OBANDO, ROGERKAMINO LABS, 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 verify the assignment record and check for any post-issuance transfers.

Let me check the assignee's corporate status and any successor transfers.

Inventors

Inventor Role at time of filing Basis
Jorge Carlos Kuri Kamino Labs, Inc. (first-named inventor; principal/founder — exact title not authoritatively confirmed) Named on the face of US 10,866,100 and on the recorded assignment as assignor (Reel 030172/0298), executing 2013-03-15
Louis P. Huynh Co-founder, Kamino Labs, Inc. TechCrunch (2014-05-08) identifies "Roger Obando and Louis Huynh, co-founders of Kamino"; assignor of record 2013-03-15
Roger Obando Co-founder, Kamino Labs, Inc. Same TechCrunch source; assignor of record 2013-03-15

Pattern notes. All three inventors conveyed to the same employer-assignee on the same effective date (2013-03-15), which is the standard founder/employee inception assignment — not a departure signal. I found no evidence that any inventor left Kamino Labs within 12 months of filing; conversely I found no evidence that they stayed. The one affirmative datapoint against departures is that all three reappear together as assignors on the separate assignment recording for the continuation application 17/094,207 (Reel 056529/0947, same effective date 2013-03-15) — meaning no inventor had to be chased down or separately dealt with years later.

Uncertainty flag: I could not authoritatively confirm Jorge Carlos Kuri's title (he is not named in the TechCrunch founder pair). Treat "founder/principal" as likely but unverified.

Original assignee

KAMINO LABS, INC. — named on the issued patent and as the assignee in the sole recorded assignment.

  • Business: Travel/social mobile-application publisher. Per its own company description (CB Insights profile), Kamino was "the neighborhood walking tour, reinvented" — users created "urban hikes" via the website gokamino.com and consumed them through a GPS-driven companion mobile app.
  • Did it ship a product embodying the claims? Yes, on the record I could verify. TechCrunch (2014-05-08) reviewed the shipped Kamino iOS app — crowdsourced "urban hikes" plotted on a map with photos, stop details, distance/stop counts, 1–5 star ratings, saving and sharing; hikes offered across ~50 cities; over 500 user-created guides at that time. This matches claims 1/6's create-and-publish-a-tour workflow and the "negotiating a hike" embodiment. The app was distributed free via iTunes.
  • Status today: Unclear / no authoritative dissolution, acquisition, or bankruptcy record located. Two cautions: (a) I found no SEC filing, press release, or court record evidencing an acquisition or wind-down of Kamino Labs, Inc.; (b) do not conflate it with the Slovenian mobile-app developer "Kamino" (Ljubljana, founded 2015, acquired by G+D Netcetera in Feb 2023) — a completely unrelated entity that dominates search results. The strongest live-status indicator is the USPTO maintenance-fee record: Google Patents legal events show a maintenance-fee reminder, a surcharge for late payment, and "PAYMENT OF MAINTENANCE FEE, 4TH YR, SMALL ENTITY" — consistent with Kamino Labs still holding and still paying to maintain the patent as a small entity into the 2024–2025 window. Google Patents continues to list KAMINO LABS Inc as current assignee, with adjusted expiration 2033-07-13.

Assignment timeline

One recorded assignment exists for US 10,866,100. There are no post-issuance recordings — no security agreement, no merger, no change of name, no license, no release, no correction of assignment. That is itself the finding: the patent has never left its original owner of record.

  • 2013-03-15 (executed; recited in the record as "Effective date: 20130315") / recorded 2013-04-08 — Reel 030172/0298
    • Conveyance: Assignment — "ASSIGNMENT OF ASSIGNORS INTEREST"
    • Assignor: KURI, JORGE CARLOS; HUYNH, LOUIS P.; OBANDO, ROGER
    • Assignee: KAMINO LABS, INC. (recorded jurisdiction/address on the assignment: CALIFORNIA)
    • Correspondent: ⚠️ Not retrievable. The Google Patents legal-events extract for Reel 030172/0298 exposes the reel/frame, owner name, assignors, conveyance text, and effective date, but not the correspondent of record. I will not guess at the attorney/firm name. This is directly checkable in the USPTO Assignment Center by searching the patent number and opening the reel/frame detail (see verification links below). Recurrence flag: not assessable — this is a one-link chain, so within-chain recurrence is impossible by construction; cross-portfolio recurrence of the recording firm can only be judged once the correspondent field is pulled.
    • Context: Inception/founder assignment to the operating startup — the three inventors assigned their rights to their own employer-company Kamino Labs, Inc. Not a fire-sale, reorganization, securitization, or transfer-to-asserter.

Separate record for the same family (not a link in this chain): the continuation application 17/094,207 → US20210199436A1 carries its own assignment recording at Reel 056529/0947, same three assignors → KAMINO LABS, INC., same effective date 2013-03-15. This is a duplicate-per-application recording of the same 2013 conveyance, not a second transaction. It is useful only as corroboration that no further transfer occurred.

Claim-set accuracy note (non-ownership): the Google Patents legal events also show a Certificate of Correction (CC) and prosecution events (non-final action, final rejection, notice of appeal, notice of allowance). A certificate of correction changes claim/specification text, not ownership, so it does not affect the chain — but any claim-scope analysis should use the post-correction text.

Timeline diagram

timeline
    title Ownership of US 10866100
    2012 : Provisional filed
    2013 : Application filed by Kamino Labs
         : Founders assign rights to Kamino Labs
    2014 : Kamino iOS app launched
    2020 : Patent issued
         : Continuation application filed
    2024 : Fourth year maintenance fee paid

NPE / troll-pattern signals

  1. Shell-entity transfer — NOT PRESENT. The only recorded conveyance runs to the operating company, not away from it: Reel 030172/0298 (executed 2013-03-15, recorded 2013-04-08) moves rights from the three individual inventors into KAMINO LABS, INC. There is no downstream assignment to any entity bearing an "IP / Patents / Licensing / Holdings / Ventures" suffix, and no single-purpose Delaware/Texas LLC anywhere in the chain.
  2. Known asserter in the chain — NOT PRESENT. The sole assignee of record, KAMINO LABS, INC., does not match any entity on the Acacia / Marathon / Intellectual Ventures / IPNav / Wi-LAN / Mosaid–Conversant / Vringo / Pendrell / Innovatio / Round Rock / Document Generation Corp roll-up, nor any Unified Patents or RPX high-frequency-plaintiff listing I could locate. Important disambiguation: the litigious NPE "Kamino LLC" (W.D. Tex., asserting unrelated backlight/display patents such as US 6,435,686) is a different entity and appears nowhere in this chain. Per the earlier litigation section of this analysis, no suit naming US 10,866,100 was located, so that name collision must not be read into this patent.
  3. Repeat correspondent across the chain — UNCLEAR / not assessable. Only one transaction exists in the chain, so there is no "repeat" to measure; and the correspondent field on Reel 030172/0298 was not exposed in the sources I could reach. Action item for verification: pull the reel/frame detail in Assignment Center and record the correspondent attorney/firm; then test that name against the other Kamino Labs patent and against the tracked-patent set for cross-portfolio recurrence.
  4. Cascading transfers — NOT PRESENT. Zero chained transfers. The chain is a single 2013 link followed by >12 years of static ownership, with no sub-24-month LLC-to-LLC hops and therefore no shared-address / common-principal clustering to analyze.
  5. Pre-litigation transfer — NOT PRESENT. No litigation asserting this patent was located (see prior section), so there is no suit to date against. The sole assignment predates issuance (2020-12-15) by roughly seven years and the priority date by five months — the opposite of an assertion-enabling, last-minute standing transfer.
  6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 record, no docket, and no assignment out of Kamino Labs. Absence of a sale is corroborated by continued small-entity maintenance-fee payments.
  7. Privateering — NOT PRESENT. No transfer from an operating company to an NPE asserting on its behalf; the operating company never transferred at all.
  8. Defensive aggregator (anti-NPE) — NOT PRESENT. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates where it began — at Kamino Labs, Inc.

Additional negative signal worth recording: there is no recorded security agreement (no lien/securitization conveyance) and no change-of-name or merger recording, which further argues against an anonymizing corporate restructuring of the kind that typically precedes a portfolio transfer.

Verdict

Insufficient data — in the strict sense of the rubric: the record contains only the original assignment. The assignment chain for US 10,866,100 consists of exactly one recording — the founders' inception assignment to KAMINO LABS, INC., executed 2013-03-15 and recorded 2013-04-08 at Reel 030172/0298 — with no post-issuance transfer of any kind. Because there is no downstream link to evaluate, no NPE signal can be scored affirmatively; the evidence (a single operating-company assignee, a shipped iOS product reviewed by TechCrunch in 2014, no assignment to any licensing entity, and continuing small-entity maintenance-fee payments on the 4th year) points away from an NPE chain, but the rubric's "Operating-company assertion" verdict requires the assignee to be actively suing competitors, and no such suit was found. Most probable reading: the patent remains owned by its original operating-company assignee, and there is no NPE chain to reconstruct.

Verification links:

Two open gaps I could not close and will not paper over: (1) the correspondent of record on Reel 030172/0298; and (2) the current corporate status of Kamino Labs, Inc. (no dissolution, acquisition, or bankruptcy record located). Both are directly resolvable in PatentCenter/Assignment Center and a California Secretary of State entity search respectively.

Generated 9/30/2026, 4:24:36 AM

Prior art

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

✓ Generated

I'll search for the authoritative citation records for US 10,866,100, since the fetched patent text I was given does not include a "References Cited" / "Patent Citations" section.

I've located the "Patent Citations" list. Let me pull the full "References Cited" list from the granted patent and get details on each cited reference.

I focused the search strictly on US 10,866,100 (not similar numbers). Here is what I found, with the sourcing problems flagged explicitly up front.


1. Sourcing note and a contradiction flag (read first)

The authoritative patent text you gave me does not contain a "References Cited" / "Patent Citations" section. The fetched Google Patents text terminates mid-sentence in the description ("...the memory 1104 could be configured") and never reaches the front-page reference list or the claim set. I therefore could not analyze the citation list from the document you designated authoritative.

To obtain the citations I had to use the sibling publication page US2014/0108137 A1 (the pre-grant publication of application 13/839,007 — the same application that issued as US 10,866,100) plus the Justia record for 10,866,100. Those two sources agree that the application family carries exactly 4 patent citations:

Patent Citations (4) — https://patents.google.com/patent/US20140108137 (and corroborated by https://patents.justia.com/patent/10866100, whose "Referenced Cited / U.S. Patent Documents" table is truncated in the retrieved text).

Flagged contradiction: the previously generated Patent summary section assumed there might be more/fewer independent claims and did not address citations; nothing there contradicts what I found, but note that the published claim 1 (broad) differs sharply from the granted claim 1 (narrow) — this materially changes the § 102 analysis below. See § 4.

Caveat I cannot eliminate: the printed front page of the granted patent (item (56)) can list references added during the later prosecution that do not appear on the pre-grant publication. I could not retrieve the granted patent's own (56) list. Everything below is therefore the application-level citation list, which is likely, but not certain, to be identical to the granted patent's list. A final confirmation should be done via USPTO Patent Center / the printed front page.


2. The four cited references (verbatim identifiers — not auto-corrected)

# Publication no. Pub. date Priority / filing Assignee / inventor Title
1 US 2008/0306826 A1 2008-12-11 prio 2006-01-30; PCT filed 2007-01-30 (appl. 12/161,554) Hoozware, Inc.; James F. Kramer, Paul C. Ning System for Providing a Service to Venues Where People Aggregate
2 US 2009/0157509 A1 2009-06-18 prio 2006-02-24 Lee Little Location-relevant real-time multimedia delivery and control and editing systems and methods
3 US 2012/0036467 A1 2012-02-09 prio/filed 2010-08-05 (appl. 12/850,956) GM Global Technology Operations / General Motors LLC; Tom, James, Tengler, Grau et al. System and method for producing a tour
4 US 2013/0179246 A1 2013-07-11 prio 2012-01-09 Bank of America Corporation Providing targeted offers based on aggregate demand and aggregate supply

All four are marked with an asterisk on the Google Patents table, i.e. examiner-cited (not applicant-cited). I could not retrieve any non-patent literature citations; the Justia "Referenced Cited" table is cut off in the retrieved text, so there may be NPL references I have not seen.

Note also — do not confuse these with the "Cited By (23)" and "Families Citing this family (16)" tables on the same pages. Those are later documents citing the '100 family; they post-date the 2012-10-15 priority and are not § 102 prior art against it.


3. Reference-by-reference § 102 analysis

Reference 1 — US 2008/0306826 A1 (Hoozware / Kramer)

  • Full citation: US 2008/0306826 A1, "System for Providing a Service to Venues Where People Aggregate," Kramer & Ning, Hoozware, Inc.; pub. 2008-12-11; priority 2006-01-30; PCT/US2007/061328. Continuation-in-part of appl. 11/307,262 (issued as US 7,788,188 B2, 2010-08-31); sibling US 7,856,360 B2 (2010-12-21).
  • Description: Mobile promotion system. Members' positions are tracked (GPS), promotions are matched to members by geography and "traits and behaviors," members check in at venues, venues get real-time highly targeted ads/offers, redemptions are tracked and the advertiser billed on a graduated/redemption basis. Notably it classifies members by trajectory (e.g., a member whose tracked route indicates "on the way to a nightclub"), informs a venue that a member is a candidate, and lets the venue push an offer with an "offer number."
  • § 102 assessment: Does not anticipate any claim. It teaches the merchant-side concepts that appear in the final limitation of granted claim 1 / claim 6 (targeted deal offer, tracking a user's approach, notifying a venue). But it is entirely missing the tour-generation subject matter that constitutes the bulk of the independent claims: a downloadable set of temporally sequential GPS coordinates, a first subset of coordinates as route information enabling distance derivation, a second subset as stop information, candidate-stop detection by co-location within a pre-defined range, and confirmation of a stop by dwell time exceeding a predefined threshold. At most this is a § 103 reference for the merchant-interface limitations, and it is a § 103 reference against any claim drawn solely to location-based targeted offers. No § 102 anticipation.

Reference 2 — US 2009/0157509 A1 (Lee Little)

  • Full citation: US 2009/0157509 A1, "Location-relevant real-time multimedia delivery and control and editing systems and methods," inventor Lee Little; pub. 2009-06-18; priority 2006-02-24.
  • Description: (as reflected by the title/record — I was unable to retrieve the full specification before my tool budget was exhausted) A system for delivering and editing location-relevant multimedia in real time; i.e. location-triggered media/content delivery.
  • § 102 assessment: Cannot anticipate. Nothing in the identified subject matter discloses generating a tour on the mobile device from the device's own real-time GPS-coordinate stream, the route-subset/stop-subset coordinate structure, dwell-time-based stop detection, or a merchant tracking/offer interface. § 103 relevance only, and limited — potentially as a secondary reference for per-location content delivery. I flag that I could not read this reference in full; this assessment is lower-confidence than for references 1, 3 and 4.

Reference 3 — US 2012/0036467 A1 (General Motors) — the closest art

  • Full citation: US 2012/0036467 A1, "System and method for producing a tour," GM Global Technology Operations, Inc. / General Motors LLC (inventors incl. Alfred C. Tom, Frances H. James, Steven C. Tengler, Thomas P. Grau); pub. 2012-02-09; appl. 12/850,956 filed 2010-08-05; status abandoned. Closely related sibling: US 2012/0095675 A1, "Method for creating and taking a driving tour" (pub. 2012-04-19), same family.
  • Description: Internet-accessible website/server on which a user composes a tour. The user inputs criteria (destination, time, POI type). Crowd-sourced POI inputs (identification, text description, audio/video commentary, ratings) and crowd-sourced "predefined tours" (multiple POIs plus the roads traveled between them) are stored server-side and sequenced into a tour. The tour is stored as an electronic file and downloaded to a portable device; the device's GPS triggers playback of the POI content as the user approaches within a "geobound." Users can provide feedback/ratings and upload commentary/images/video during the tour, and can even modify the tour on the fly. The specification expressly contemplates an application on a cell phone that "collects the content (text, audio, and pictures) and uploads the content to the website from the device."
  • § 102 assessment:
    • Against granted claim 1 / claim 6 — no anticipation. The tour in GM is composed server-side from a website and then downloaded; it is not "a user-accessible and downloadable set of temporally sequential GPS coordinates collected from the mobile device in real-time as the mobile device traverses a real-world environment," structured as a first coordinate subset = route information and a second coordinate subset = stop information, with stops confirmed by dwell time over a threshold. GM's POIs are discrete point records with geobounds, not co-located coordinate subsets qualified by a duration threshold. GM also lacks the claimed merchant interface with saved-location detection, user-profile display, deal-offer push and approach notification.
    • Against the published (pre-grant) claim 1 of US 2014/0108137 A1 — plausible § 102 anticipation. The original published claim 1 was far broader ("receiving an indication to create a tour using a device; determining a starting point of the tour; capturing route and location information corresponding to movement of the device; receiving indications of one or more stops; capturing data associated with the stops (tips, recommendations, commentary, ratings, images); receiving an indication the tour is complete; tour configured to be stored/distributed via social networks"). GM's disclosure of creating a crowd-sourced, downloadable tour with a start point, route, stops and per-stop content/ratings on a mobile device maps onto that broad claim much more directly. This is almost certainly why the examiner cited it, and it is consistent with the applicant having amended claim 1 down to the narrow GPS-coordinate/dwell-time/merchant-interface form that ultimately issued.
    • Against the granted dependent claims: GM is a strong § 103 reference for claim 3 (linking tips/recommendations/commentary/ratings/images to a stop) and claim 4 (generating stop information from third-party data-source providers — GM's crowd-sourced POI database and third-party/contributing-user inputs).

Reference 4 — US 2013/0179246 A1 (Bank of America)

  • Full citation: US 2013/0179246 A1, "Providing targeted offers based on aggregate demand and aggregate supply," Bank of America Corporation; pub. 2013-07-11; priority 2012-01-09.
  • Timing note (important, and literal): its publication date (2013-07-11) is after the '100 priority date (2012-10-15), but its priority date (2012-01-09) precedes it. It can therefore only be prior art under § 102(a)(2)/pre-AIA § 102(e) (as a U.S. application publication with an earlier effective filing date), not under § 102(a)(1) as a printed publication. I am reading the dates literally from the record, per your instruction not to auto-correct.
  • Description: systems/methods for targeting offers by matching offers to consumers based on aggregate demand and aggregate supply conditions.
  • § 102 assessment: Does not anticipate any claim. It is directed to offer-targeting economics and, on the subject matter identified, discloses nothing of the tour-generation elements of claims 1/6. Relevant at most as a § 103 secondary reference for the single limitation "transmit a deal offer to a mobile device of the user on the tour" (the last merchant-interface step of claim 1/claim 6). No § 102 anticipation.

4. Bottom line

  1. No cited reference anticipates the granted independent claims (claim 1, method; claim 6, apparatus). Each of the four is missing at least the defining tour-generation limitations — in particular the real-time device-collected, temporally sequential GPS-coordinate set structured as a first (route) subset enabling distance derivation and a second (stop) subset, and the candidate-stop/dwell-time-threshold determination — and none discloses the full merchant interface (determining the tour includes the merchant's location as a stop, displaying tracking of the user, displaying/deriving the user's saved-location status, transmitting a deal offer, and displaying an approach notification).
  2. The four references are best characterized as § 103 (obviousness) references, with Reference 3 (GM, US 2012/0036467 A1) the primary teaching (tour creation, crowd-sourced stops, per-stop content, download-to-device, location-triggered content, user feedback/ratings) and Reference 1 (Hoozware, US 2008/0306826 A1) the merchant-side teaching (location/behavior-targeted offers, user-approach tracking, venue notification).
  3. Reference 3 is the reference most plausibly tied to a § 102 rejection that was overcome by amendment — but I am inferring this from the difference between the published and granted claim text. I could not verify the actual rejection grounds, because I did not retrieve the prosecution file wrapper or PTAB records. "No anticipation by the cited art" here means based on the four recorded citations I could locate, not a certified negative.

5. What would make this definitive (not yet done)

  • Pull the printed front page (56) references of US 10,866,100 itself from USPTO Patent Center, to confirm the 4-reference list and capture any non-patent literature citations (which my sources do not show).
  • Pull the file wrapper (USPTO Patent Center / Global Dossier) to identify the actual § 102/§ 103 rejections and which claims each reference was applied to — that is the only authoritative way to answer "which claims it potentially anticipates."
  • Confirm no IPR/PGR (PTAB) names 10,866,100.

Want me to pull the granted patent's front-page (56) reference list and the file-wrapper rejection grounds? That would let me convert the § 102 "plausible/possible" statements above into confirmed, Art-Unit-cited applications to specific claims.

Confidence summary: Citations list (4 references, identifiers, dates) — high confidence (two independent sources agree). Reference 3 and Reference 1 substantive analysis — high confidence (specifications read). Reference 2 and Reference 4 substantive analysis — medium/low confidence (I saw titles, dates and, for #4, only the title/assignee; I did not read their full specifications). Actual examiner rejections/claim mapping — not verified.

Generated 9/30/2026, 4:24:58 AM

Obviousness

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

✓ Generated

I'll ground this analysis in actual prior-art references. Let me pull the cited art and similar references for US 10,866,100.

I have the patent's own citation record. Let me now examine the key cited references and adjacent prior art in the same field.

Obviousness Analysis — US 10,866,100 B2 under 35 U.S.C. § 103

Date of analysis: April 26, 2026
Builds on: the claim-1/claim-6 mapping and the "no litigation found" conclusion already generated above — not repeated here.

Confidence / grounding note up front. This analysis is grounded in (i) the prior-art references that appear on the face of US 10,866,100 ("the '100 patent") per the Google Patents / FPO records retrieved, and (ii) the patent's own Background admissions. I was able to retrieve the substance of the two most important cited references (GM's tour-patent application and Hoozware's venue/promotion patent) and the related GM "driving tour"/"packaged tour" family. I was not able to retrieve, within this session's tool budget, a specific document that expressly discloses the dwell-time stop-detection limitation (claim 1 step 4–5). I flag that limitation below as the probable point of novelty that survived prosecution, and I do not fabricate a reference for it.


1. Legal framework applied

  • Graham v. John Deere Co., 383 U.S. 1 (1966): scope/content of claims; differences over prior art; PHOSITA level; secondary considerations.
  • KSR Int'l Co. v. Teleflex Inc., 551 U.S. 398 (2007): motivation to combine may come from the references themselves, the "nature of the problem," "common sense," or a "finite number of identified, predictable solutions"; a combination of known elements according to known methods yielding predictable results is obvious. MPEP § 2143 sets the rationales (a)–(i).
  • Applicant's own admissions. Statements in the '100 patent's Background describing Yelp, TripAdvisor, The Layover, Groupon/LivingSocial/Amazon Local, and Facebook "like"-based offers are usable as prior art (In re Nomiya; In re Fracalossi). This matters because the patent concedes that every constituent piece was known and asserts novelty only in the combination.

Presumed PHOSITA: a software engineer/UX developer with ~2–3 years' experience building mobile, location-aware consumer applications (GPS, REST back-ends, social/messaging), plus familiarity with targeted-advertising and deal-redemption systems. This is a routine-engineering level of ordinary skill — a fact that bears on the "obvious to try" analysis.


2. The principal prior-art references

Ref ID (literal) Key teaching Status vs. '100 priority (2012‑10‑15)
GM‑467 US 2012/0036467 A1, "System and method for producing a tour" (General Motors LLC; Tom et al.), pub. 2012‑02‑09 Internet site to compose a tour; POIs arranged in sequence; crowd-sourced POI inputs and user‑supplied "predefined tours" including "the roads that were traveled between" POIs; download to mobile; GPS; user ratings, reviews, commentary, photos; feedback uploaded during the tour § 102(a)/(e) prior art; cited on face of '100
GM‑5675 US 2012/0095675 A1, "Method for creating and taking a driving tour" (GM; same family) Crowd-sourced tour creation from user criteria; guest/limited access; feedback and content uploaded from the mobile device during the tour; geographically synchronized "geobound" triggers Prior art (pub. 2012‑04‑19)
GM‑202/288 US 2008/0162042 A1 → US 9,841,288 B2, "Packaged tours with turn-by-turn navigation" (Huber et al., GM) Packaged tour object = directions + media keyed to upcoming POIs, delivered to a device; POIs with sequence numbers Prior art (pub. 2008‑07‑03)
Hoozware US 2008/0306826 A1 (Kramer & Ning, Hoozware, Inc.), pub. 2008‑12‑11; granted as US 7,788,188 / US 7,856,360 Promotions matched to a member's GPS position; server classifies a member as "on the way to," "in proximity to," or "at" a venue by tracking their route/trajectory; venue managers push targeted ads/offers ("offer numbers"); check‑in + reward points; predicted arrivals § 102(b) prior art; cited on face of '100
Little‑509 US 2009/0157509 A1 (Lee Little) Location‑relevant real‑time multimedia delivery and editing Cited on face of '100
BofA‑246 US 2013/0179246 A1 (Bank of America) Targeted offers based on demand/supply Cited on face of '100

Not prior art to '100 (flag): the Y‑citations in the WO 2015/109032 search report (PCT/US2015/011482, ISR completed 2015‑04‑27) — e.g., US 2003/0115095 A1 (Yamaguchi), US 2007/0275731 A1 (Alfert), US 2004/0167861 A1 (Hedley), US 2009/0018902 A1 (Miller), KR 10‑2012‑0066109 A, KR 10‑2012‑0076495 A. That PCT post‑dates the '100 priority date, so only its underlying references' own publication dates matter — I did not retrieve those dates, so I do not rely on them.


3. Element-by-element mapping of independent claim 1

Claim 1 limitation (plain language) Primary teaching
(a) receive indication to generate a tour on the mobile device; tour = downloadable set of temporally sequential GPS coordinates GM‑467 (user composes/uploads a tour; tour downloadable to a mobile device)
(b) obtain real‑time GPS coordinate as starting point GM‑467 (start/end address; position‑determining capability); GM‑5675 ("geobound" proximity triggers)
(c) capture successive GPS coords in sequence as route information (first subset) GM‑467 expressly: contributing users may "input entire tours that they have taken, including multiple POIs and the roads that were traveled between them"; GM‑202/288 (sequence‑numbered POIs)
(d) determine subsets of coords co‑located within a pre‑defined range → candidate stops Hoozware (server groups/tracks GPS positions against known fixed venue positions); GM‑467 (POI GPS + "geobound")
(e) determine coords stayed within the range longer than a predefined time threshold → stops NOT clearly located in the retrieved references — see § 6. This is the probable point of novelty.
(f) capture stop data = current location when stop indicated + tips/recommendations/commentary/ratings/images GM‑467 (POI inputs incl. identification, audio/video/text commentary, rating/ranking, reviews, uploaded photos; feedback from the device during the tour)
(g) receive indication tour complete; configured to be stored/distributed via social networks GM‑467 (storing the tour in an electronic file); '100 Background admission (Facebook/Groupon/LivingSocial sharing)
(h) upload tour (incl. stop data + route/location) to remote storage GM‑467 (server 14 / data storage 16; "continuously expanding database"); GM‑5675 (upload content to the website)
(i) transmit a merchant interface to a merchant device configured to: (i‑1) determine the tour includes the merchant's location as a stop; (i‑2) display tracking of a user on the tour; (i‑3) display the user's profile incl. whether the user saved the merchant's location; (i‑4) determine the user saved the location; (i‑5) transmit a deal offer to the user's device; (i‑6) display a notification that the user is approaching Hoozware maps nearly 1:1: venue‑manager‑facing promotion console; server determines member/venue geo‑match; classifies member as "on the way to" (approaching) or "at" a venue; pushes offers/"offer numbers" to the member's phone; check‑in/reward; member may save/favorite venues; predicted arrivals used for targeting. BofA‑246 supplies targeted‑offer generically.

Claim 6 (apparatus) is the same subject matter in processor‑plus‑memory form; it rises or falls with claim 1 (In re Beauregard; the apparatus and method claims stand together on the same disclosure).


4. Proposed combinations and why the PHOSITA would have combined them

Combination I (primary): GM‑467 + Hoozware

What each supplies. GM‑467 supplies the "generating-a-hike" (creator‑side) half of claim 1: crowd‑sourced tour composition, sequential POIs, route capture/download to a mobile device with GPS, and stop content (ratings/reviews/commentary/photos). Hoozware supplies the entire "merchant‑interface" half (claim 1 step (i)) plus the GPS‑tracking/geo‑match mechanics.

Motivations / rationales (MPEP 2143):

  1. Same field, same problem (rationale (a)). Both are mobile location‑based services that connect a moving user to physical venues. GM‑467's own Background criticizes guidebooks and prepackaged tours for lacking linkage to the user's progress and for POI selection driven by a publisher's fee — i.e., GM‑467 articulates the very "monetization/curation" problem Hoozware solves with geotargeted offers. A PHOSITA seeking to monetize a crowd‑sourced tour platform would look to the leader in location‑based venue promotion.
  2. Express teaching in the references of the missing pieces (rationale (b)). GM‑467 teaches "geobounds" that "trigger" content when a device "approaches to within a predetermined distance of" a POI — the same proximity/tracking primitive Hoozware uses to classify a member "on the way to" a venue and to fire an offer. Combining them is applying a known technique for its known purpose.
  3. Predictable result / obvious to try (KSR). Adding a merchant‑facing dashboard with location‑triggered offers and "approaching" notifications to an already‑crowd‑sourced GPS tour is the combination of known elements according to known methods, with the predictable benefit of higher offer redemption and inventory planning (the '100 patent itself touts only "right‑sizing" and staffing — a business result, not a technical one).
  4. The '100 patent's own Background concedes the constituent parts (Yelp/TripAdvisor = crowd‑sourced stop content; The Layover = Stops in sequence; Groupon/LivingSocial/Amazon Local = Offers; Facebook = social distribution). Under § 103 the invention reduces to the arrangement of admitted, known building blocks.

Net result. Combination I discloses every limitation of claim 1 except the dwell‑time threshold of step (e). That single gap is decisive for the obviousness conclusion on claim 1, and is addressed in § 6.

Combination II (reinforcing): GM‑467 + GM‑202/288 + Hoozware

  • GM‑202/288 adds the "packaged tour object" with sequence metadata and location‑triggered media, directly supplying "sequence" ordering and the "trigger content when approaching" primitive, and reinforcing the predictability of the merchant "approaching" notification. Useful if the examiner treats GM‑467 alone as not expressly disclosing the "first subset in sequence" structure.

Combination III (for step (i‑3), "saved places"): any of the above + Hoozware's favorite/venue‑list feature

  • Hoozware's member‑facing saved/favorite venues and its venue‑manager targeting to "venues you frequent" supply "display the user's profile including whether the user has saved the merchant's location" and "determine that the user has saved that location."

5. Dependent claims (2–5) and how they fall

Claim Subject matter Disclosed by
2 Tour created by an app user and shared with other users GM‑467 (contributing users share POIs/predefined tours; "crowd sourcing"); Hoozware
3 Link tips/recommendations/commentary/ratings/images to a stop GM‑467 (POI inputs = commentary/rating/photo; reviews "linked" to POI records)
4 Generate stop information from third‑party data source providers GM‑467 (server + API for third‑party applications, "POI parameters"); corroborated by the '100 Background admission re: Field Trip/Zagat's/Food Network
5 Provide the completed tour to social networks '100 Background admission (Facebook); GM‑467 (content "immediately available to other users")

Because claims 2–5 add only routine, separately‑known data‑handling features, they are obvious over Combination I and would not independently impart patentability.


6. Where the § 103 case is weakest — the dwell‑time stop‑detection limitation

Claim 1 steps (4)–(5) require (i) grouping GPS coordinates co‑located within a pre‑defined range and (ii) treating a group as a stop only if the device stayed within the range longer than a predefined time threshold. This "dwell‑time → waypoint" logic is the one limitation I could not map to a retrieved reference, and it is the most likely reason the examiner allowed the claims over the four cited references.

Assessment under KSR. Even if no single reference is located, this limitation is a strong candidate for an "obvious to try / predictable variation" attack, because:

  • Detecting a "stop" as remaining within a radius for a time threshold is the natural, near‑tautological algorithmic definition of a stop, and the '100 spec itself concedes the threshold is arbitrary (its Fig. 9 example merely says "such as ... at least ten minutes"). A recitation of an arbitrary numeric/threshold parameter is generally obvious (§ 103; cf. In re Aller, 220 F.2d 454 (CCPA 1955) on optimization of known parameters).
  • Proximity‑plus‑duration classification is functionally the same operation Hoozware performs when it infers a member is "at a nightclub" by observing the GPS trajectory persist/stop at a venue vs. "on the way to." A PHOSITA could reach steps (4)–(5) by making Hoozware's classification explicit.

Honest caveat. I did not retrieve a document expressly disclosing the radius+duration stop‑definition, and I decline to assert one. If you want a defensible obviousness position on claim 1 as a whole, the highest‑value next search is for:

  • Location‑history place/stop clustering art (e.g., "identify stay points," "stop detection," "point‑of‑interest extraction from GPS traces") predating 2012‑10‑15;
  • Fitness/route‑logging products and their patents (auto‑pause, lap detection) from the 2008–2012 window;
  • Platform APIs shipping before Oct 2012 that logged "visited places" by dwell time.
    One express such reference, combined with Combination I, would close the last gap.

7. Secondary considerations

No evidence of record (in the retrieved materials) of unexpected results, commercial success with nexus, copying, or industry praise specific to the claimed dwell‑time/merchant‑interface combination. The patent's stated advantages ("auditable trail," "customer actualization," "right sizing samples/staffing") are business/administrative benefits that flow predictably from combining known location‑tracking and offers, and generally carry little patentable weight absent a technical nexus.

(Scope note: a § 101 Alice challenge is a foreseeable but separate risk given the G06Q30/0261 and G06Q10/047 classifications; it is outside the § 103 question asked here and is flagged only for completeness.)


8. Conclusion

  • Claims 2–5: likely obvious over Combination I (GM‑467 + Hoozware), reinforced by the '100 Background admissions.
  • Claim 1 and claim 6: a strong prima facie § 103 case exists over GM‑467 (US 2012/0036467 A1) in view of Hoozware (US 2008/0306826 A1) — optionally further in view of GM‑202/288 (US 2008/0162042 A1 / US 9,841,288 B2) and BofA‑246 (US 2013/0179246 A1) — subject to locating a reference that discloses the co‑location‑plus‑duration stop‑detection of steps (4)–(5). That one limitation is the pivot point and the reason the four face‑cited references did not defeat the claims during prosecution.

Confidence: high on the element mapping to GM‑467 and Hoozware (I retrieved both texts); moderate on the overall obviousness conclusion for claim 1 (hinges on the unretrieved dwell‑time reference); high that no litigation/CAFC activity is on record (per the earlier section).

Primary sources:

If you want, I can (a) drive a targeted search for a pre‑2012 stop‑detection/place‑clustering reference to close step (4)–(5), and (b) pull the full independent‑claim text set of the '100 continuation (US 20210199436A1, claim 37) to run the same § 103 mapping against the currently pending claims.

Generated 9/30/2026, 4:24:56 AM

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