US 11451860

I'll search for authoritative information on US 11,451,860, including any CAFC 2026 docket activity.

I found the patent record. Let me now verify litigation and CAFC activity specific to this patent number.

Let me check for PTAB challenges and any Federal Circuit appeal specifically involving the '860 patent.

US Patent 11,451,860 ("the '860 patent") — Analyst Summary

Source note: Core bibliographic and specification content below comes from the authoritative full text of US 11,451,860 B2 furnished in the prompt (Google Patents, https://patents.google.com/patent/US11451860/en). Litigation facts are corroborated by Federal Register notices and ITC/USITC-derived reporting. Claim text was not retrievable and is flagged accordingly.

1. Bibliographic data

Continuity chain (from the patent's own "Incorporation by Reference"):

• US 16/269,662 (the '860 application) is a continuation of US 15/891,085 (filed Feb. 7, 2018)
• which is a continuation of US 15/208,886 (filed July 13, 2016, now US 10,129,590)
• which is a continuation of US 12/260,410 (filed Oct. 29, 2008, now US 9,420,212)
• which claims priority to JP 2007-306750 (Nov. 28, 2007).

Note: US 9,420,212's face lists the assignee as Hitachi Maxell, Ltd.; the patent later passed to Maxell, Ltd. via a recorded merger/name-change (MAXELL HOLDINGS, LTD. merger 2021-11-29; MAXELL, LTD. name change 2021-12-03).

2. Abstract (verbatim)

"While presenting on a display apparatus videos of high picture quality obtained from portable video processing apparatuses such as a camera and a cellular, it is possible to communicate with the Internet and/or a home network. A display apparatus includes a first radio communication unit capable of receiving video information by radio from an external video processing apparatus, a second radio communication unit capable of connecting by radio to a network, and a control unit for controlling assignment of connection by radio transmission for each of the first and second radio communication units. The control unit assigns connection of the first radio communication unit with higher priority and controls the assignment of the transmission rate such that the transmission rate between the first radio communication unit and the external video processing apparatus is more than that between the second radio communication unit and the network."

3. Plain-language overview of the independent claims

⚠️ Explicit uncertainty: The full text supplied did not include the granted claims, and my searches did not return the issued claim language of the '860 patent. The descriptions below are reconstructed from the patent's own Summary of the Invention (which the specification expressly frames as "According to one aspect … there is provided …"), from the abstract, and from the claim scope asserted in the ITC complaint. They should be treated as a faithful paraphrase of the claimed subject matter, not as a verbatim quotation of claims 1 and 7.

There appear to be two independent claims (at least 11 claims total — the ITC asserted claims 7–11):

Independent Claim 1 — Display apparatus (receiver side)
A display apparatus comprising:

1. a first radio communication unit able to receive video information by radio from an external video processing apparatus (e.g., a camera or cell phone feeding high-quality video to the TV);
2. a second radio communication unit able to connect by radio to a network (internet and/or home network); and
3. a connection assignment control unit that controls the assignment of radio-transmission connection for each of the first and second units,
   where the control unit gives the first radio communication unit higher priority and controls the assignment so that the transmission rate between the first unit and the external video processing apparatus is greater than the transmission rate between the second unit and the network.

Independent Claim 7 — Video processing apparatus (source side)
The mirror-image apparatus claim: a video processing apparatus comprising a first radio communication unit able to transmit video information by radio to an external display apparatus, a second radio communication unit able to connect by radio to a network, and a connection assignment control unit — again with the first unit prioritized and its transmission rate set higher than the second unit's network rate.

Supporting concepts disclosed in the specification (may appear in dependent claims):

• Modems operate via OFDM; the controller varies transmission rate by changing modulation/demodulation scheme, frequency band, and number of carriers (Fig. 9: "scheme 1" = 17 Mbps vs. "scheme 2" = 5 Mbps — more than a 3× difference).
• Rate assignment may also be triggered by a user indication or by the resolution/precision of the video (e.g., SD 640×480 → HD 1920×1080, spelled "1980×1080" in the text).
• Alternative embodiment (Fig. 4 / Fig. 8): several fixed-capacity radio modems (bands A–D) that are pooled/combined, so that in a high-bandwidth HD scenario three modems are allocated to video and only one to the network.
• Optional MIMO control of the radio modems.
• Alternative independent claims of the family (per the '590 reexamination certificate referenced in Samsung's IPR exhibits) recite first/second/third radio communication circuits with different modulation schemes and different frequency bands, plus receiving an OS/application update over the internet — but that language belongs to the '590 patent, not confirmed for the '860.

4. Litigation and 2026 docket findings

ITC

• Inv. No. 337-TA-1420, "Certain Smart Televisions." Instituted September 24, 2024 (89 FR 79307, published Sept. 27, 2024) on Maxell's complaint of August 22, 2024. The asserted patents are U.S. 8,549,109; 11,451,860; 11,924,502; and 10,958,971. The '860 patent's asserted claims are claims 7–11. Respondents are the TCL entities (TCL Electronics Holdings, TCL Industries Holdings, T.C.L. Industries Holdings (H.K.), TTE Technology, TCL King, Manufacturas Avanzadas, TCL Smart Device (Vietnam), Shenzhen TCL New Technology, TCL Optoelectronics (Huizhou), TCL Overseas Marketing, TCL Technology Group) plus TTE Corporation. Remedy sought: limited exclusion order + cease and desist orders.
  • Commission partial final determinations (April 29 and May 28, 2025) terminated the investigation as to the '502 patent and as to several TCL respondents based on withdrawal of the complaint (ALJ IDs Nos. 11 and 14, not reviewed).
• Inv. No. 337-TA-3769 is also listed under "Family has litigation" on the Google Patents page. I could not independently corroborate this investigation number, and it does not fit the apparent numeric range of contemporary Section 337 investigations; I report it literally as listed without correcting it.
• A separate Darts-IP entry records "first worldwide family litigation" for family 40669376.

District court / PTAB (related, not directly the '860)

• E.D. Tex., Maxell, Ltd. v. Samsung Elecs. Co., No. 5:23-cv-00092 — May 28, 2025 jury verdict of ~$111.7M. On September 19, 2025 Judge Robert Schroeder III granted Samsung's JMOL, overturning the verdict, invalidating claims in two of the three asserted patents, and denying enhanced damages/interest/permanent injunction. That decision is on appeal. The patents at issue there were from the first assertion set; I did not find the '860 among them.
• PTAB IPR2024-00906 and IPR2024-00907 (Samsung v. Maxell) target U.S. 10,129,590, the parent of the '860 patent, using the Nokia N93 User Manual as prior art. A Law360 entry dated April 28, 2026 reports the PTAB "threw out all the claims Samsung challenged in a pair of Maxell Ltd. video processing patents." That pair is most consistent with the '590-family IPRs, but I cannot confirm from available sources that the '860 patent itself was the subject of those decisions.

Federal Circuit — 2026

I found no Federal Circuit appeal docket in 2026 naming U.S. Patent 11,451,860 or Maxell v. TCL. Searches of the CAFC April 2026 scheduled-cases list and general 2026 CAFC docket material returned no case tied to this patent number. The only Maxell-related appeal I could identify is the EDTX JMOL appeal referenced in Samsung's PTAB briefing (patents from the first Texas action — not the '860). Stated plainly: I do not have authoritative confirmation of any CAFC 2026 docket for US 11,451,860. Absence of a hit in my searches is not proof that no such docket exists.

5. Caveats

1. Claim text is not verified. The overview in §3 is a reconstruction from the specification's summary/abstract plus the ITC's identification of asserted claims 7–11. Treat it as directional.
2. Two minor date discrepancies exist between Google Patents and Unified Patents for the priority date (Nov. 28 vs. Nov. 27, 2007), filing date (Feb. 7 vs. Feb. 6, 2019), and grant date (Sept. 20 vs. Sept. 19, 2022). I have reported both rather than silently reconciling them.
3. 337-TA-3769 is reported as listed but unverified.
4. No CAFC 2026 docket for the '860 was located; this is a negative finding from limited search coverage.

I'll research litigation involving US 11,451,860 across patent litigation trackers, ITC records, and court dockets.

Let me dig into the parallel district court actions and the ITC docket for the '860 patent specifically.

Let me confirm the parallel district court case and check the other ITC reference on the patent page.

Litigation Report — U.S. Patent No. 11,451,860 (the "'860 patent")

"Display apparatus and video processing apparatus" | Maxell, Ltd. (current assignee/patentee) | Application No. 16/269,662 | Filed Feb. 7, 2019 | Granted Sept. 20, 2022 | Anticipated expiration Oct. 29, 2028 | Priority claim (via continuation chain) to JP 2007-306750, filed Nov. 28, 2007

Bottom line: I verified one litigation matter in which the '860 patent was actually asserted — an ITC Section 337 investigation against the TCL entities — which terminated by settlement in September 2025 without any merits determination on the '860 patent. I could not independently verify any district court (PACER) complaint asserting the '860 patent, nor any IPR/PGR challenging it. Details and caveats below.

1. ITC Investigation No. 337-TA-1420 — Certain Smart Televisions

Procedural history (all verified):

• Apr. 7, 2025 — Order No. 11: investigation terminated as to all asserted claims of the '502 patent (11,924,502) based on complainant's withdrawal; not reviewed by the Commission Apr. 29, 2025. (Note: this did not touch the '860 patent.)
• May 7, 2025 — Order No. 14: investigation terminated as to six "Terminated Respondents" (T.C.L. Industries Holdings (H.K.) Ltd.; TTE Corporation; Shenzhen TCL New Technology; TCL Optoelectronics Technology (Huizhou); TCL Overseas Marketing; TCL Technology Group Corp.) based on Maxell's unopposed motion and withdrawal of allegations; not reviewed May 28, 2025.
• Aug. 11, 2025: Maxell and the Active Respondents filed a joint motion to terminate the entire investigation based on settlement; OUII supported it.
• Aug. 22, 2025 — Order No. 19 (ID): ALJ granted the joint motion.
• Sept. 15, 2025: Commission determined not to review the ID; investigation terminated in its entirety. Published at 90 FR 45053 (Sept. 18, 2025).

Citations:

• https://www.govinfo.gov/content/pkg/FR-2025-09-18/pdf/2025-18090.pdf (termination by settlement)
• https://regulations.justia.com/regulations/fedreg/2025/09/18/2025-18032.html
• https://www.govinfo.gov/app/details/FR-2024-09-27/2024-22187 (institution; scope: "claims 7-11 of the '860 patent")
• https://www.usitc.gov/secretary/fed_reg_notices/337/337_1420_notice05282025sgl.pdf (Order No. 14)
• https://edis.usitc.gov (EDIS docket, Investigation No. 337-TA-1420)

Practical significance: Because the matter settled, there is no ALJ initial determination, no Commission final determination, and no exclusion order construing or adjudicating claims 7–11 of the '860 patent. Any estoppel/issue-preclusion value for the '860 patent is nil; the settlement agreement itself is confidential (public/redacted versions filed per 19 C.F.R. § 210.21(b)(1)). USPTO PTO practice caution: the settlement does not itself resolve the '860 patent's validity, and no IPR statutory estoppel arises from a Section 337 investigation.

2. Unverified / conflicting item on the patent's face

The Google Patents page for US 11,451,860 lists as "Family has litigation" two ITC citations: 337-TA-1420 and 337-TA-3769 (https://portal.unifiedpatents.com/litigation/International%20Trade%20Commission/case/337-TA-3769).

I am not able to confirm 337-TA-3769 as a real FT investigation number associated with the '860 patent, and I flag it rather than endorse it:

• I could not retrieve any ITC notice, Federal Register publication, or EDIS record for investigation number 337-TA-3769.
• The number is anomalous relative to ITC numbering chronology (Section 337 investigation numbers were in the ~1370s in 2023 and ~1420 by late 2024), which suggests a possible indexing artifact on the third-party aggregator rather than a genuine investigation.
• Per your strict instruction, I have not auto-corrected or substituted any other number. If you need certainty, the authoritative check is the ITC EDIS docket (https://edis.usitc.gov) searched by investigation number and by patent number.

3. What I could NOT verify — stated explicitly

• No district court complaint asserting the '860 patent was confirmed. I searched for district litigation by Maxell involving the '860 patent and did not find a verified PACER/CourtListener docket naming the '860 patent as a patent-in-suit. In particular:
  • Maxell, Ltd. v. TCL Electronics Holdings Ltd., No. 5:23-cv-00108 (E.D. Tex.) (filed Oct. 12, 2023; docket shows closed May 20, 2025) — asserts smart-TV patents (e.g., 7,924,366 and 10,650,780 appear in the amended-complaint analysis), not the '860 patent on the record I could see.
  • Maxell Ltd. v. TCL Electronics Holdings Ltd., No. 5:25-cv-00067 (E.D. Tex.) — asserts different patents (e.g., 8,107,007; 7,730,507); no '860 confirmation.
  • Maxell, Ltd. v. Samsung — 5:23-cv-00092 (E.D. Tex., filed Sept. 7, 2023) asserted 8,073,161; 8,982,086; 10,129,590; 10,176,848; 11,017,815; 11,223,757; 11,445,241; and 5:25-cv-00052 asserted ten others (7,577,417; 7,952,645; 8,180,198; 8,471,950; 10,783,228; 10,812,646; 11,026,088; 11,277,650; 11,812,091; 12,160,681). The '860 patent does not appear in either list. Note the familial relationship: the '860 patent is a continuation in the same family as 10,129,590 and 11,445,241 (per the '860 specification's incorporation-by-reference paragraph), but that does not put it at issue in those cases.
  • Maxell, Ltd. v. Coretronic Corp., No. 5:24-cv-00088 (E.D. Tex.) — active docket through 2026; I did not confirm whether the '860 patent is asserted there. This is the most plausible candidate for an unverified '860 district action and should be checked directly in PACER.
• No IPR, PGR, or CBM petition against the '860 patent was confirmed in my searches. (Given the TCL settlement, any TCL-filed challenges would likely have been dismissed/settled.)
• No CAFC appeal involving the '860 patent was confirmed.

4. Recommended verification steps (authoritative sources)

1. ITC EDIS — https://edis.usitc.gov — search Investigation No. 337-TA-1420, and search "11,451,860" across investigations to catch any second ITC matter (e.g., to test the 337-TA-3769 entry).
2. PACER / CourtListener RECAP — full-text search for "11,451,860" in district court complaints (E.D. Tex., W.D. Tex., D. Del., C.D. Cal., N.D. Cal.).
3. Unified Patents Portal — https://portal.unifiedpatents.com/patents/patent/US-11451860-B2 (this is the aggregator whose ITC entries also feed the Google Patents "litigation" panel — note it reports a priority date of 2007-11-27 and application date 2019-02-06, which differ by one day from the Google Patents/official 2007-11-28 and 2019-02-07 dates, another sign of aggregator date drift).
4. USPTO Patent Trial & Appeal Board — https://ptacts.uspto.gov — search for petitions naming U.S. 11,451,860.
5. Maxell investor/litigation disclosures — Maxell Holdings, Ltd. historically disclosed patent-licensing litigation in its securities filings; useful for confirming settlements.

Summary table

Caveat: This report rests on public Federal Register notices, ITC/USITC published notices, Unified Patents/Google Patents patent pages, and secondary reporting (RPX). I did not have direct PACER or EDIS access during this session, so items in Section 3 are negative findings from search, not affirmative clearances. Nothing here is legal advice or a legal conclusion as to validity, infringement, or enforceability.

I'll research PTAB activity on this patent. Let me start with several targeted searches.

Let me dig deeper into specific PTAB filings and the ITC investigations.

PTAB Activity Report — U.S. Patent No. 11,451,860 ("Display apparatus and video processing apparatus")

Bottom line up front: The canonical structured data (USPTO ODP) returns zero AIA trial proceedings on this patent. My web research corroborates that — I found no IPR, PGR, or CBM petition naming U.S. Patent No. 11,451,860 as the challenged patent. What I did find is a large, live, related-patent campaign against the same Maxell family and the same accused products, which is the materially important context for a defendant. Details and confidence levels below.

Proceedings overview

Total AIA trial proceedings on US 11,451,860: 0. Breakdown: 0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denied. The patent has never been through an instituted AIA trial, so no claim of the '860 patent has been canceled, confirmed, or even subjected to a PTAB institution decision.

The defensive posture is therefore not "hardened by surviving IPRs" and not "claims are dead." It is the third, less common posture: untested at the PTAB, but sitting inside a family that is under active, sustained IPR attack — and running out of term. The '860 patent has an anticipated expiration of 2028-10-29 (per the Google Patents legal-status data), i.e., roughly two years of life remaining as of today (2026-09-28). That short remaining term, combined with the 2025–2026 wave of discretionary denials at the Board, makes an IPR an unusually poor return on investment for a defendant and makes a license/settlement calculation more realistic than a validity kill.

Proceedings on this patent

None on file — no IPR / PGR / CBM naming US 11,451,860

• Type: N/A
• Filed: N/A
• Status: The "PTAB proceedings on file" structured block states the ODP API returns no AIA trial proceedings as of the most recent ingest.
• Judge panel: N/A
• Petition grounds: N/A — no petition exists to characterize. Do not infer grounds from the sibling-patent IPRs below; they target different patents and different claims.
• Institution decision / FWD / settlement / appeal: N/A.
• Defensive value: The absence of any IPR is itself the signal. Maxell has asserted this patent in a Section 337 action (below) against well-resourced respondents (TCL et al.) who routinely file IPRs. Either (a) they chose not to, (b) they filed and it is not yet indexed in the ODP, or (c) they ran out of the § 315(b) window. I could not confirm a filing through web search.

Confidence note: I have high confidence in the "zero proceedings" result because it comes from the canonical ODP-sourced block and was not contradicted by search. I have lower confidence that nothing was filed in late 2025 / 2026, because the ODP ingest lags and I was unable to complete a primary-source check of PTAB E2E for this patent number. Treat the zero as "nothing on the docket I can cite," not as an absolute.

Adjacent proceedings that actually matter

These are not proceedings on the '860 patent. They are listed because a defendant facing '860 needs them. All share the '860 specification (the '860 is a continuation of the application that issued as US 10,129,590, which is itself a continuation of the application that issued as US 9,420,212; priority JP 2007-306750, 2007-11-28).

IPR2024-00907 — Samsung Electronics Co., Ltd. et al. v. Maxell, Ltd.

• Type: Inter Partes Review
• Target patent: U.S. Patent No. 10,129,590 — the '860 patent's immediate parent (same specification, same inventors Kurita/Owashi). Filed 2024-05-31.
• Why it matters: This is the closest thing to a challenge on '860's claims. Whatever the Board does with the '590 claims bears directly on claim-construction and prior-art positions available against the '860. (Source: Maxell's 37 C.F.R. § 42.8 mandatory notices in IPR2024-00906, which states: "Petitioners have also filed IPR2024-00907 against related patent 10,129,590.")

IPR2024-00906 — [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd. et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.) v. Maxell, Ltd.

• Type: Inter Partes Review
• Target patent: U.S. Patent No. 11,445,241 — another member of the same continuation family ('241 issued from application 17/568,166, a sibling of the '860's chain). Patent Owner's mandatory notices dated 2024-06-07.
• Related litigation identified by Maxell: Maxell, Ltd. v. Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 5:23-cv-00092-RWS (E.D. Tex.).

Ex parte reexamination Control No. 90/014,651 — on U.S. Patent No. 10,129,590

• Type: Ex parte reexamination — not an AIA trial. This is why it does not appear on a PTAB AIA-trials list at all.
• Third-party requester: Apple Inc. (per the file-history exhibit: "APPLE INC. (3RD PTY. REQ.)"), filed 2021-01-12, handled in the CRU (Art Unit 3999).
• Why it matters: It shows the family has been attacked on the patent side (reexam) as well as the IPR side, and that Apple — not just Samsung — has been in the validity fight over this specification.

ITC Investigation No. 337-TA-1420 — Certain Smart Televisions (Maxell, Ltd., complainant)

• Instituted: 2024-09-24 (89 FR 79307); complaint filed 2024-08-22, supplemented 2024-09-10.
• Asserted patents: U.S. 8,549,109; U.S. 11,451,860 (the '860 patent at issue here); U.S. 11,924,502; U.S. 10,958,971.
• Respondents: 13 named companies, including TCL Electronics Holdings Ltd. (HK), TCL Industries Holdings Co., Ltd., and TTE Technology, Inc.
• Status: On 2025-04-29 the Commission declined review of ALJ Initial Determination No. 11 (2025-04-07) and terminated the investigation as to the '502 patent only, based on complainant's withdrawal. The '860 patent was not part of that termination. (Source: 商务部 trade-remedy reporting on the Commission notice; I did not locate the underlying Commission notice directly.)
• Why it matters for § 315(b): The Board generally treats service of an ITC complaint as a "complaint alleging infringement" that starts the one-year IPR clock. If that holds, the ITC-1420 respondents' § 315(b) window on '860 closed on or about August/September 2025. That would explain the zero IPR count — the respondents may be time-barred from filing on '860 today. Verify this against the actual service dates; I am inferring the bar date, not citing an order.

Also on the IPR docket involving Maxell (different patents, same campaign)

Samsung's 2024–2025 filings against the Maxell portfolio include IPR2024-00735 ('815), IPR2024-00777, IPR2024-00828 (FWD 2025-10-30, outcome "unpatentable," on appeal), IPR2024-00867 (FWD 2025-11-06, appeal docket 2026-1625, panel Trock/McMillin/Melvin, opinion by Trock), and the 2025 wave IPR2025-01308/-01309/-01312/-01314/-01315/-01316 targeting patents 7,577,417; 7,952,645; 8,180,198; 8,471,950; 10,783,228; 10,812,646; 11,026,088; 11,277,650; 11,812,091; and 12,160,681. None of these names the '860 patent. I am citing these from secondary aggregators (Docket Alarm, Patexia, ex parte's AI lab) rather than PTAB E2E FWDs; treat panel/outcome details as provisional.

Note on the anomaly: The structured litigation data lists a second ITC case, 337-TA-3769. I could not corroborate that number in any search result, and it is inconsistent with the ITC's numbering range for the relevant period. I am reporting it because the structured block lists it, but I would not rely on it. 337-TA-1420 is the verified investigation.

Strategic summary

Claim status on '860. No claim has been canceled, confirmed, or construed by the PTAB. Claims 1–23 and 26–28 — the set Maxell's own licensing correspondence identifies as the asserted claims against Galaxy devices — are UNTESTED at the Board. (Source: Maxell's 2023-09 letter to Samsung, attached as an exhibit in the Samsung IPR papers, table row 6: "11,451,860 | 1-23, 26-28 | Galaxy A, S, Z, Note, XCover series phones; Galaxy Tab A, Tab X, and Book series tablets.") There is no narrowing IPR history to rely on, and correspondingly no PTAB claim construction estate to inherit.

Estoppel landscape. Because no petitioner has obtained a Final Written Decision on the '860 patent, § 315(e)(2) estoppel does not attach to the '860 patent at all. No defendant is barred from anything on this patent. That cuts both ways: your prior-art runway is wide open, but the same is true for every other defendant, and there is no one else's invalidity win to ride. The only real constraints on you are (i) the § 315(b) one-year bar running from service of the complaint against you, and (ii) the Board's current discretionary-denial practice, which as of 2025 denies institution on "settled expectations" / parallel-litigation grounds at high rates (figures cited to Congress put discretionary denial at ~61% of decisions in the May–October 2025 window). Against a 2007-priority patent expiring 2028-10-29, expect a serious discretionary-denial fight even on strong merits.

Pattern signals. (1) Maxell is a serial, organized enforcer across a large acquired Hitachi portfolio, asserting overlapping families against Apple (E.D. Tex. 5:19-cv-00036; W.D. Tex. 6:20-cv-00646), LG (E.D. Tex. 5:23-cv-00152, transferred to N.D. Cal. 5:24-cv-04972), Samsung (E.D. Tex. 5:23-cv-00092; a 2025 wave; a $112M jury verdict reported 2025-05-29), ZTE, and the ITC-1420 TV respondents. (2) Samsung is the repeat petitioner — it filed a coordinated set of IPRs against this family in 2024 (including IPR2024-00906 on '241 and IPR2024-00907 on '590) and a second wave in 2025, and it has appealed adverse FWDs (e.g., 2026-1625). (3) Maxell fights hard at the Board — its counsel (Mayer Brown) filed discretionary-denial briefs invoking settled expectations, and the record shows aggressive procedural sparring (offers of proof, ex parte communication complaints). (4) Maxell has also settled at least one prior IPR (Apple v. Maxell, IPR2020-00202, terminated 2021-04-20 on a joint motion to terminate under § 317(b)) — a reminder that settlement, not a merits win, is often the outcome. (5) No defensive aggregator (Unified Patents, RPX) appears in the chain for this patent.

Recommended next steps

1. Verify the zero directly. Check PTAB E2E (https://ptab.uspto.gov) and the Patent Trial and Appeal Board's API for U.S. Pat. No. 11,451,860, and separately search the FH on Patent Center for any ex parte reexam control number on the '860 itself (the family has one on the '590: control 90/014,651). The ODP block in this prompt is the canonical source and it is empty — but ODP ingest lags, so a late-2025/2026 filing is the one thing that would change this report.
2. Calendar your § 315(b) date. No IPR can be instituted more than one year after you are served with a complaint alleging infringement of the '860 patent. If you have been sued, that window is your hard deadline; if service has already occurred more than a year ago, an IPR is off the table and you are litigating validity in court (or seeking a stay for a co-defendant's petition).
3. Mine the sibling proceedings, don't cite them as your own. The Samsung IPRs on '590 (IPR2024-00907) and '241 (IPR2024-00906) and the Apple-requested reexam of '590 are your best sources for prior art, expert testimony, and claim-construction positions on this shared specification. They create no estoppel on '860 — you can reuse the art.
4. Weigh the term. With expiration anticipated 2028-10-29, an IPR that institutes in 2027 and issues an FWD in 2028 buys very little. Run the damages exposure against the cost of the petition and the realistic odds of institution given the current discretionary-denial climate. A design-around, a § 101 challenge, or a negotiated royalty may dominate a PTAB strategy.
5. If Maxell's demand letter to you cites claims 1–23 or 26–28 of '860, note that those claims are entirely untested — there is no FWD to attack or to hide behind. Anyone telling you the claims are "already invalidated at the PTAB" is confusing this patent with its siblings.

Explicit uncertainty statement: I did not locate, and therefore cannot cite, any institution decision, Final Written Decision, judge panel, or appeal for any proceeding on U.S. Patent No. 11,451,860, because none appears to exist. Everything above attributed to sibling patents and to the ITC is labeled with its source, and the panel/outcome details drawn from aggregators (Docket Alarm, Patexia, ex parte AI lab) should be re-confirmed against the primary PTAB and Commission documents before you rely on them in a filing.

I'll search for the assignment records before constructing the timeline, since I must not fabricate reel/frame numbers.

Assignment & Ownership Reconstruction — U.S. Patent No. 11,451,860

Patent: US 11,451,860 B2, "Display apparatus and video processing apparatus" · App. 16/269,662 · Filed 2019‑02‑07 · Granted 2022‑09‑20 · Assignee of record: Maxell, Ltd.

Sourcing note / limitation up front: I was able to reach the substance of the chain (executed vs. recorded dates, conveyance types, assignor/assignee names) via the Google Patents legal‑events panel for this patent and corroborating family records, and I located the corresponding USPTO assignment records in third‑party mirrors (Plainsite assignment IDs 10949077 and 11310005). However, I could not retrieve the reel/frame numbers, execution dates, or the correspondent‑of‑record attorney for either entry from the Assignment Center in this session. I am flagging those fields as not retrieved, not guessing them. Verification belongs at the source: https://assignmentcenter.uspto.gov/ (mirror: https://assignment.uspto.gov/patent/index.html), searchable by patent number 11451860.

Inventors

Pattern notes:

• No inventor-side assignments appear anywhere in the recorded chain. Neither inventor is a named assignor on any recorded assignment for this patent — consistent with a standard "hereby assign to the company" employment posture, not a later inventor buy-back or inventor-to-LLC transfer.
• Employer-at-invention is genuinely ambiguous and I will not assert it. The JP priority (JP 2007‑306750) was filed 2007‑11‑28, i.e. five to six years before Hitachi Maxell acquired Hitachi's consumer‑electronics business and the Hitachi Consumer Electronics ("HCE") patent portfolio (2013–2014, per Maxell's own E.D. Tex. filing in Maxell v. Apple, No. 5:19‑cv‑00036, Dkt. 170). If the invention was made in the Hitachi CE organization, the inventors were Hitachi/HCE employees at invention and became Maxell‑affiliated only by later portfolio transfer. This is an inference from the corporate chronology; the record before me does not identify their 2007 employer.
• No "inventors departed within 12 months of filing" pattern is detectable — and importantly, that pattern is not the relevant one here anyway. This is a 2007–2008 invention whose patent issued in 2022. There is a 14‑year gap between conception and grant, so inventor mobility is not a meaningful fire‑sale tell for this asset.

Original assignee

Maxell, Ltd. (1 Koizumi, Oyamazaki, Otokuni‑gun, Kyoto, Japan), current assignee of record per the '860 front page and the 2021‑12‑03 change‑of‑name recording.

• Line of business: Consumer and industrial products — batteries, optical/storage media, projectors, precision components, and B2B electronics. Maxell is a publicly listed, currently operating company (Tokyo Stock Exchange Prime Market, ticker 6810). It is not dissolved, in bankruptcy, or an empty licensing vehicle.
• Corporate history relevant to title (all from Maxell's own litigation narrative and the EP register for family member EP1580954):
  • Formerly Hitachi Maxell, Ltd. ("HMX"), a majority/wholly‑owned Hitachi subsidiary.
  • 2013: HMX purchased Hitachi's consumer electronics business, and with it Hitachi's smartphone patent portfolio previously held by Hitachi Consumer Electronics Co., Ltd. ("HCE"). Per the EP register for EP1580954, the HCE→Hitachi Maxell transfer ran by deed of assignment dated 2014‑04‑04.
  • 2017‑10‑01: Hitachi Maxell de‑merged/renamed to Maxell, Ltd. and dropped "Hitachi"; Hitachi's stake fell to ~3%.
  • 2021‑10‑01: Maxell, Ltd. → Maxell Holdings, Ltd. (merger), then Maxell Holdings, Ltd. → Maxell, Ltd. (change of name) — the two events recorded in the US in Nov./Dec. 2021.
• Does Maxell ship a product embodying the '860 claims? No evidence that it does. The '860 claims a display apparatus / video processing apparatus with a first radio link to a portable video source and a second radio link to a network. Maxell does not currently market televisions or the portable camera/phone devices described in the specification. The patents it asserts in this family are monetized, not practiced. That is a material observation for the verdict below, but it is not an assignment‑chain signal, and I do not treat it as one.

Assignment timeline

Records do exist for this patent — two post‑filing corporate‑restructuring recordings against application 16/269,662. What follows is what is verifiable; reel/frame and correspondent are explicitly marked unresolved.

• 2021‑10‑01 (executed, per the 01.10.2021 effective date used in the parallel EP/GB registers) / recorded 2021‑11‑29 — Reel not retrieved/NNNNNN — Frame not retrieved/NNNN

  • Conveyance: Merger (recorded as "MERGER"; assignor's rights vest in the surviving entity by operation of the merger)
  • Assignor: Maxell, Ltd. (Kyoto, JP)
  • Assignee: MAXELL HOLDINGS, LTD. (Kyoto, JP)
  • Correspondent: Not retrieved. (Maxell's US IP filings in litigation are handled through its in‑house IP Department and Maxell Research and Development of America, LLC — per the witness list in Maxell v. Apple, No. 5:19‑cv‑00036, Dkt. 160‑2 — but that is not the assignment correspondent and I do not treat it as one.)
  • Context: Internal corporate reorganization (holding‑company step of the 2021 group restructuring) — not an arm's‑length acquisition, not a fire‑sale.
  • Mirror record: Plainsite assignment ID 10949077, "Patent Assignment from Maxell, Ltd. to Maxell Holdings, Ltd."

• 2021‑10‑01 (executed) / recorded 2021‑12‑03 — Reel not retrieved/NNNNNN — Frame not retrieved/NNNN

  • Conveyance: Change of Name (recorded as "CHANGE OF NAME")
  • Assignor: MAXELL HOLDINGS, LTD.
  • Assignee: MAXELL, LTD.
  • Correspondent: Not retrieved.
  • Context: Change of name only — the post‑restructuring entity took back the "Maxell, Ltd." name; no change in beneficial ownership. This is the office action the patentee's title rests on today.
  • Mirror record: Plainsite assignment ID 11310005.

What is not in the record (a finding in itself):

1. No recorded assignment from Hitachi, Ltd. or Hitachi Consumer Electronics Co., Ltd. to Hitachi Maxell appears against the '860 file. If the HCE→HMX 2014 transfer (EP deed dated 2014‑04‑04) and the 2017 Hitachi Maxell→Maxell rename were recorded in the US at all, they were recorded against the earlier applications in the chain (originally US 12/260,410, filed 2008‑10‑29, now US 9,420,212) rather than against each continuation. That is normal practice for continuations, but it means the '860's own Assignment Center page will look shorter than its true provenance and the underlying chain must be reconstructed through the parent's file. Worth confirming at the source.
2. No assignment to any third party — ever. No license, security agreement, release, correction, or pre‑litigation transfer appears in the chain. Notably, no assignment was recorded in connection with the ITC action against TCL (see below), because none was needed: Maxell has owned the patent continuously since at least 2014.

Timeline diagram

timeline
    title Ownership of US 11451860
    2007 : JP priority JP2007-306750 filed
    2008 : US parent 12260410 filed
    2013 : Hitachi Maxell buys Hitachi CE business
    2014 : HCE portfolio deeded to Hitachi Maxell
    2017 : Hitachi Maxell renamed Maxell Ltd
    2019 : Continuation 16269662 filed by Maxell
    2021 : Maxell Ltd merged into Maxell Holdings
         : Maxell Holdings renamed Maxell Ltd
    2022 : Patent 11451860 granted to Maxell
    2024 : ITC 337-TA-1420 filed against TCL
    2025 : ITC case settled and terminated

NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT. The chain contains no "IP / Patents / Licensing / Holdings / Ventures"‑suffixed licensing LLC, no registered‑agent service address, and no single‑purpose Delaware or Texas LLC. The one "Holdings" entity that appears — Maxell Holdings, Ltd., on the 2021‑11‑29 merger record — is a Japanese holding company with the same Kyoto address as Maxell, Ltd. (1 Koizumi, Oyamazaki), created by an internal reorganization and unwound 12 days later by the 2021‑12‑03 change‑of‑name recording. It is not an assertion vehicle. Note the rule I'm applying: "Holdings" in the name is not a finding by itself.

2. Known asserter in the chain — NOT PRESENT as an assignee, but UNCLEAR as a party. No assignee in this chain (Hitachi Maxell, Maxell Holdings, Maxell Ltd.) matches the reference NPE lists (Acacia, Marathon, IV, IPNav, Wi‑LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). Maxell, Ltd. is not one of those entities and is a listed operating manufacturer. Separately, Maxell is a high‑frequency patent plaintiff in its own right — it has sued Apple (No. 5:19‑cv‑00036), Samsung (E.D. Tex. 5:23‑cv‑00092; 5:25‑cv‑00052; ITC 337‑TA‑1432; UPC Germany; Tokyo District Court), and TCL (ITC 337‑TA‑1420, asserting this patent's claims 7–11). Whether RPX/Unified currently list Maxell on a high‑frequency‑plaintiff roster is something I could not confirm in this session, so I mark this unclear rather than assert it.

3. Repeat correspondent across the chain — UNCLEAR / NOT RETRIEVABLE. This is the single most diagnostic field the task asks for and it is the field I could not obtain. I will not name an attorney without a record. Independently: even if the two recordings share a correspondent, that would be expected and weak — a two‑link internal restructuring filed by the same company's patent department over four days proves little. The recurrence signal is meaningful for multi‑LLC chains; this chain has one corporate family and no LLCs.

4. Cascading transfers through chained LLCs in <24 months — NOT PRESENT. There are exactly two recorded transfers, occurring 4 days apart (recorded 2021‑11‑29 and 2021‑12‑03), both internal to the same corporate family and both executing a single 2021 reorganization. Two steps, same address, no LLCs, no common‑principal shell structure — this is the opposite of a cascade.

5. Pre‑litigation transfer — NOT PRESENT. The last recorded assignment is 2021‑12‑03; the first infringement action naming this patent (ITC 337‑TA‑1420) was filed 2024‑08‑22 — roughly 32 months later, far outside any 6‑month window. There was no title clean‑up before the ITC filing because none was needed.

6. Bankruptcy fire‑sale — NOT PRESENT. No assignor or assignee in the chain filed Chapter 7/11. Maxell, Ltd. remains an operating, listed company (TSE Prime 6810). The 2013–2014 Hitachi→HMX portfolio transfer was a business divestiture, not a distress sale.

7. Privateering — UNCLEAR, leaning NOT PRESENT on the record available. This is the closest fit of any signal, and it deserves an honest treatment. The pattern that would make it a finding is: an operating company transfers patents to an NPE that asserts against the operating company's competitors. Here, the actual inventive entity appears to be Hitachi/its CE subsidiary, and the patents ended up with Maxell — an entity that had bought Hitachi's consumer‑electronics business and, after Hitachi's stake fell to ~3%, operates independently of and adverse to Hitachi. Maxell then asserted the portfolio against Apple, Samsung, and TCL. There is a documented origin‑and‑separation story but no documented transfer to a third‑party assertion vehicle — Maxell asserts in its own name, for its own account. I mark this unclear because I have not seen the 2014 assignment instrument or SEC disclosure that would let me say whether Hitachi retained any economic interest.

8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at Maxell, Ltd., an asserting operating company. The patent has not been neutralized.

Verdict

Operating-company assertion.

Justification: The entire recorded chain is two internal corporate‑housekeeping recordings inside one corporate family — Maxell, Ltd. → MAXELL HOLDINGS, LTD. (merger, recorded 2021‑11‑29) and MAXELL HOLDINGS, LTD. → MAXELL, LTD. (change of name, recorded 2021‑12‑03) — with no third‑party assignee, no shell LLC, no pre‑litigation transfer, no bankruptcy, and no defensive aggregator anywhere in the chain. The assignee is a Tokyo‑listed, product‑shipping manufacturer (Maxell, Ltd., TSE Prime 6810) that asserts its own patent rights directly, and the patent is still owned by the same corporate family that has held it since the 2014 Hitachi CE portfolio transfer.

Two candor caveats the reader should carry forward:

1. Fields the task depends on most are unresolved. Reel/frame numbers, execution dates, and — critically — the correspondent of record were not retrievable in this session. Signal #3 is therefore answered unclear, not "not present," because "not present" would require evidence I do not have. Verify at https://assignmentcenter.usitc.gov is not the right door — verify at https://assignmentcenter.uspto.gov/ (search patent 11451860, and separately search the parent 12/260,410 to reconstruct the Hitachi→Maxell links).
2. Substance‑over‑form note, offered as context rather than as a second verdict: Maxell does not appear to practice the claimed display‑apparatus technology, having exited the consumer‑electronics business from which these patents came, and it monetizes this family through litigation and licensing. A diligence reviewer comparing Maxell's assertion behavior to its product line would reasonably describe it as an operating company acting like a non‑practicing licensor for this specific portfolio. That is a characterization of Maxell's conduct, not an ownership finding, and the assignment record itself contains zero NPE transfer signals.

Verification link: https://assignmentcenter.uspto.gov/ (patent number search: 11451860); secondary mirror https://assignment.uspto.gov/patent/index.html; family‑level corroboration at https://portal.unifiedpatents.com/patents/patent/US-11451860-B2 and the ITC docket https://edis.usitc.gov (Inv. No. 337‑TA‑1420).

Nothing above is a legal conclusion as to ownership, validity, or enforceability; it is a reconstruction of recorded and reported public data, with gaps identified rather than filled.

I'll search for the authoritative patent record and its cited prior art.

Let me try to retrieve the actual front-page citations for the '860 patent.

Let me try alternate patent databases that reproduce the full front-page reference lists.

Prior-Art Analysis — U.S. Patent No. 11,451,860 ("the '860 patent")

Method note / explicit limitation up front: You asked me to pull every patent citation on the face of U.S. 11,451,860 and map each to a § 102 anticipation theory. I was able to confirm the identity of the '860 patent and the count of its cited prior art, but I was NOT able to retrieve the enumerated "References Cited" list itself in this session. The front-page citation list is not reproduced verbatim in the sources my searches returned, and I did not have direct access to USPTO Patent Public Search / PatentCenter or the granted-claims text (a limitation already flagged in the earlier sections of this analysis). I will not invent reference numbers or dates to fill that gap. Below I give (a) what is verified, (b) the one prior-art reference the '860 specification itself identifies, (c) family-documented references, (d) third-party art used against the family, with verification status labeled for each, and (e) the correct § 102 framework and the retrieval path that will produce the complete list.

1. Identity confirmation — this is U.S. 11,451,860, not a similar number

Searching the specific number 11451860 returns exactly one granted patent:

Distinct patents that appeared in my search results and are NOT the '860 patent (listed only to show I did not return similar numbers in place of the target): US 11,470,379 B2 (Machida et al., Maxell); US 11,541,286 B2; US 10,339,893 B2 (Kurita et al., "Display apparatus" — a different Maxell family, JP 2007-269651 priority); US 11,509,953 B2; US 11,445,241 B2; US 12,143,665 B2; US 12,418,692 B2. Several of the latter four are same-family continuations of the '860 (see § 4) and are therefore not prior art against it, for the reasons in § 5.

Newly verified detail: the Unified Patents record for US 11,451,860 indexes "Patent Art (109)" and "Non-Patent Literature (13)" — i.e., on the order of ~109 patent references and 13 NPL items are associated with this record (front-page citations + family). I could not enumerate those 109/13 in this session; the aggregator exposes the count but my searches did not surface the listing itself.

2. The one reference the '860 specification itself cites

The '860 description contains exactly one express prior-art citation (it appears in the "Background" section, verbatim from the supplied patent text):

"A conventional technique in which digitized video and audio signals are multiplexed for transmission as above is described in, for example, JP-A-2007-202115."

3. Front-page "References Cited" — status

I could not retrieve the enumerated list. Everything below is either (a) family-documented art or (b) third-party art asserted against the family, and each row is labeled. I am deliberately not presenting any reference as a front-page citation of the '860 unless a source confirms it.

4. Family-documented and third-party references (labeled)

4.1 The '860's own continuation chain (NOT prior art — see § 5)

Verified from the '860 "Incorporation by Reference" paragraph (authoritative supplied text):

Also verified as claiming priority from the '860 (children): US 16/738,059 → US 11,509,953; US 17/568,166 → US 11,445,241; US 17/967,092 → US 12,143,665; US 18/905,664 → US 12,418,692.

4.2 Third-party prior art asserted against the parent '590 in IPR (highly relevant to the '860's claims)

4.3 Same-inventor Maxell "Display apparatus" family (different family — flagged to prevent conflation)

These appeared prominently in my searches but belong to a different Maxell family (JP 2007-269651, filed Oct. 17, 2007) and are therefore not the '860's front-page references:

Don't use these as the '860's cited references — different family, different priority. I include them only because they surfaced in number-adjacent searches, and the strict rule here is not to substitute one number/family for another.

4.4 EP counterpart lead (unverified — flagged, not endorsed)

An EPO search report I retrieved (EP 2 034 547 A1) cites JP 2006-032163 A (Hitachi Maxell, Ltd., Feb. 2, 2006) and JP 2006-100194 A (Matsushita Electric Industrial Co., Ltd., Apr. 13, 2006). I could NOT confirm that EP 2 034 547 is a member of the '860's family, so I do not represent these as the '860's cited art. If the family link is confirmed, both are pre-Nov. 28, 2007 publications and would be pre-AIA § 102(a)/(b) art of potential § 103 relevance (multiplexing/display background), again with no evident disclosure of the prioritized dual-radio architecture.

5. § 102 framework and why the continuation chain is not prior art

Governing statute: The '860 has an effective filing date of Nov. 28, 2007 (JP 2007-306750), so pre-AIA 35 U.S.C. § 102 applies (AIAA first-inventor-to-file regime, effective Mar. 16, 2013, does not govern). The critical dates:

• § 102(a)/(e): art dated before Nov. 28, 2007 (priority date).
• § 102(b): printed publications/patents dated more than one year before the earliest U.S. filing to which benefit is claimed under § 120 — i.e., before Oct. 29, 2007.

Why the family is not prior art: US 9,420,212, US 10,129,590, US 11,509,953, US 11,445,241, US 12,143,665 and US 12,418,692 all claim the same 2007 priority as the '860. Under pre-AIA § 102(e), a reference must have an earlier effective filing date, and it must be "by another." Same-family members sharing the '860's priority date (and the same inventors, Kurita & Owashi) are therefore neither § 102(e) nor § 102(a)/(b) art. Note the same logic applies to the separately numbered same-inventor "Display apparatus" family (§ 4.3).

Claim mapping caveat: As flagged in the earlier sections of this analysis, I could not retrieve the granted claim text, so the mapping above is stated at the level of the two independent apparatus claims (the display-apparatus claim and the mirror-image video-processing-apparatus claim) and their dependents. The ITC record (Inv. No. 337-TA-1420) independently confirms that claims 7–11 were asserted — consistent with independent claim 7 being the video-processing-apparatus claim.

6. Contradictions / discrepancies flagged (no new material conflict found)

• My new searches re-confirm the one-day Google-vs-Unified discrepancies already flagged (priority 2007-11-28 vs. 2007-11-27; filing 2019-02-07 vs. 2019-02-06; grant 2022-09-20 vs. 2022-09-19). No new contradiction with the earlier sections.
• New, non-conflicting information: Unified Patents supplies the primary examiner (Dagnew, Mekonnen D) and the prior-art counts (109 patent art / 13 NPL) that were not in the earlier sections.
• Date note: the task header states "Current Date: April 26, 2026," while my operating context is 2026-09-28. I flag this rather than silently reconciling it; it does not affect any dated prior art here.

7. What you should run to get the complete, authoritative citation list

I am not able to complete the "each patent citation" enumeration with verified data from this session. The authoritative retrieval paths are:

1. USPTO Patent Public Search (https://ppubs.uspto.gov) or PatentCenter — open application 16/269,662 / patent 11,451,860 and export the "References Cited" (front page) and "Patent Family" tabs. This is the only source that gives the exact 109-reference list with examiner-vs-applicant attribution.
2. USPTO Patent Trial & Appeal Board (https://ptacts.uspto.gov) — retrieve IPR2024-00906 / IPR2024-00907 exhibits for the full Nokia N93 manual and the '590 reexamination record; the '860 shares the '590's specification, so this art is directly transferable.
3. USPTO PAIR/file wrapper for the parent 15/891,085 and grandparent 15/208,886 — a continuation's cited references are typically the parent's, so the parent's "References Cited" is the fastest proxy for the '860's.
4. Google Patents "Citations" and "Cited By" tabs (https://patents.google.com/patent/[US11451860B2](/patent/US11451860B2)/en) and Unified Patents portal (https://portal.unifiedpatents.com/patents/patent/US-11451860-B2) — for the 109/13 listing.

Bottom line: The only prior-art reference I can verify is recited inside the '860 patent itself — JP-A-2007-202115 (multiplexed digital video/audio transmission; likely § 102(b) art as background, no anticipation of claims 1–11). The most technically relevant known prior art to the '860's claim scope is the Nokia N93 User Manual asserted in the Samsung IPRs against the family's '590 patent, and it too is best characterized as § 103 material rather than a standalone § 102 anticipation reference. The full front-page citation list (~109 patent references, 13 NPL) must be pulled from USPTO PatentCenter/Patent Public Search to complete your request, and I recommend treating any pre-Oct. 29, 2007 publication in that list as the § 102(b) priority for your validity analysis.

I'll start by gathering the prior-art references of record for the '860 patent, since the supplied page text does not include its "References Cited" list.

The page's "References Cited" list didn't come through in the supplied text. Let me try to recover it and any invalidity contentions from the litigation record.

Excellent — I found a highly relevant sibling-patent IPR. Let me pin down that record and check for any IPR aimed at the '860 itself.

Obviousness Analysis — U.S. Patent No. 11,451,860 ("the '860 patent") under 35 U.S.C. § 103

Prepared: for the continuation of this matter's technical analysis. This section builds on, and does not repeat, the Patent Summary (§§1–5) and Litigation Report already generated.

0. Threshold matter: the "Prior Art section" — and one date conflict

The page text supplied to me does not contain a Prior Art / "References Cited" listing. The Google Patents page as retrieved contains only these prior-art-adjacent fields:

There is no "Cited By," "References Cited," "Similar Documents," or examiner-citation table in the material furnished. I therefore cannot do what the task literally asks in its narrowest reading ("use the results from the Prior Art section of this page"). I flag this rather than silently substituting a different corpus.

What I can ground in the authoritative text is one express prior-art citation made by the patentee itself, in the Background section:

"A conventional technique in which digitized video and audio signals are multiplexed for transmission as above is described in, for example, JP-A-2007-202115."

I have supplemented that single citation with references recovered from (a) the prosecution/search-report records of this patent family and (b) a co-pending PTAB petition against a same-specification sibling patent (U.S. 10,244,284). Every supplementary reference below is flagged by source and confidence, and none has been auto-corrected.

Date conflict flagged: the task header states "Current Date: April 26, 2026," while my operating environment states today is 2026-09-28. I note this rather than reconcile it. It matters only for the "most recent development" framing, not for the § 103 analysis, which is date-anchored to 2007.

1. The § 103 legal frame and the critical date

Because the '860 patent's earliest effective filing date is November 28, 2007 (JP 2007-306750, via the US 12/260,410 → 15/208,886 → 15/891,085 → 16/269,662 chain recited in the patent's own "Incorporation by Reference"), the pre-AIA § 103(a) framework governs. That produces two hard gates:

1. § 102(b) statutory-bar art — printed publications or public uses more than one year before the US filing date of the earliest application in the chain (US 12/260,410, filed Oct. 29, 2008). The § 102(b) cutoff is therefore ~October 29, 2007.
2. § 102(a)/(e) art — material published before November 28, 2007 or earlier-filed US applications published afterward.

All candidate references below fall on the correct side of at least the § 102(a) gate; most clear § 102(b).

There is also a live second-order question the Patent Owner will press: whether the '860 claims are actually entitled to the 2007 priority date, or whether the chain lacks § 112 support for particular limitations (which would move the critical date to 2018/2019 and expand the art universe — a worse outcome for the patentee). That cuts against the patentee either way.

Claim scope. I adopt the reconstructed limitations from § 3 of the Patent Summary and label them explicitly as reconstructions, not verbatim claim text. The ITC record independently confirms claims 7–11 were asserted (89 FR 79307). The four limitations I test:

2. Candidate prior art — inventory with source and confidence

⚠️ References (B)–(E) were not retrieved from their own primary documents in this session. They come from a third-party petition-summary page for IPR2025-00520 ([LG Electronics Inc.](/litigations/by-plaintiff/LG%20Electronics%20Inc.) v. Maxell Ltd.), which challenged U.S. 10,244,284 — a patent bearing the same title, "Display Apparatus and Video Processing Apparatus," and drawn from the same specification family. The application numbers are reproduced literally, uncorrected. Anyone relying on this analysis should pull the primary documents before filing anything.

3. Combination 1 — Honkanen + Dua (+ Barnes): the strongest § 103 case

This is, in substance, the theory already on file against a same-specification sibling in IPR2025-00520, and it maps almost cleanly onto limitations (I)–(IV).

Motivation to combine (KSR)

1. Same field, same problem, same solution space. Honkanen, Dua, Barnes, the N95 guide, and the '860 patent all concern portable/handheld devices carrying more than one co-located radio. KSR: "the combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results." KSR Int'l Co. v. Teleflex Inc., 127 S. Ct. 1727, 1739 (2007).
2. The problem was known, and the solution was the obvious one. Honkanen expressly frames the problem as managing two simultaneously active radios and adjusting connection parameters. Dua supplies the two-radio hardware and the video-to-local-TV use case but is thin on how to arbitrate. Barnes supplies precisely the missing piece: allocate the high-bandwidth path to the video task, because video buffers and stutters while background data does not.
3. Predictable, not inventive, result. The claimed result is a comparative-rate relationship between two links sharing a constrained radio resource. Prioritizing a latency/bandwidth-sensitive stream over a non-real-time data connection is the ordinary engineering response; KSR: "if a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious unless its actual application is beyond his or her skill." 127 S. Ct. at 1740.
4. The patentee's own specification concedes the trade-off is trivial. The '860 specification states: "The band of radio signals from the terminal 101 and that of radio signals from the terminal 134 are fixed. Therefore, if the band of signals from the terminal 101 is expanded, that of signals from the terminal 134 narrows to slightly lower the communication speed of the network. However, this rarely influences the system operation since information regarding the network is less frequently exchanged as compared with video information…" This is an admission that the negative consequence of reprioritization is known and acceptable — i.e., the "predictable result" of the very reallocation the claims recite.
5. Design incentive / market force. By 2006–2007, consumer devices were being pushed to simultaneously stream HD video locally and remain Internet-connected (Dua's Internet-to-TV relay; the N95's connectivity suite). That marketplace pressure is a recognized KSR motivating factor ("design incentives and other market forces can prompt variations").

Anticipation note

If Dua is read to disclose the prioritization (its Internet-to-TV relay necessarily favors the local video link), a § 102 anticipation argument on the independent claims is arguable; I would not lead with it, as the explicit comparative-rate limitation is better attacked via Barnes under § 103.

4. Combination 2 — Dua + Barnes (clean two-reference case)

Should a tribunal reject Honkanen on some technicality, Dua + Barnes alone supports obviousness of (I)–(IV):

• Dua supplies (I) the local video/link transceiver, (II) the network transceiver, and the architecture for concurrent operation, plus (III) a processor that must decide how to route/partition traffic across the two radios.
• Barnes supplies (III)+(IV) directly: selection of the best connection for the task, choosing a higher-speed/higher-bandwidth link for video to prevent buffering.
• Motivation: both address the same device class (portable multi-radio media devices); Barnes solves the exact deficiency in Dua (no stated arbitration policy); combination yields no new field of endeavor and no unexpected result — only smoother video and uninterrupted background data, which is the stated goal of both.

5. Combination 3 — EP 1 747 616 A1 / US 2005/0255878 A1 + Dua or Barnes

This line supplies the coexistence motivation that Combination 1 relies on:

• G/H teach a mobile terminal with two co-located radios of different character (UWB vs. narrowband cellular) and — critically — a mechanism for detecting interference between them and switching the data connection to an alternative path. That is an express reason for a POSITA to deliberately arbitrate and reprioritize between a high-rate local link and a network link.
• Combined with Dua (two-transceiver media device) and Barnes (bandwidth-priority for video), the resulting system meets (I)–(IV) with an explicit, articulated motivation to combine: coexistence management.

This combination is also the best answer to a patentee argument that a POSITA would not have thought to coordinate two radios at all — the art was already coordinating them for interference reasons, and the '860 patent merely applies the same coordination to a throughput-priority policy.

6. Combination 4 — the family's own cited Japanese art (candidate only)

If the search report I recovered does in fact belong to this family (unconfirmed), then JP 2006-032163 A and JP 2006-100194 A (both 2006, both cited as "Y" references) plus JP 11-287620 A / JP 2001-202662 A would form a substantially earlier, single-jurisdiction combination teaching radio-linked portable-apparatus/display communications. Their value here is not as the primary obviousness theory (I cannot read their disclosures in this session) but as corroboration that the field was crowded and the elementary radio-link architecture was old by 2007. Corresponding US family members, if any, would need to be run down.

7. Dependent claims / specific embodiments — obviousness posture

The dependent-claim and disclosure-level features are, on these references, weak:

None of these features, on the art identified, presents a nonobviousness anchor in the nature of an unexpected result or a teaching away.

8. What the Patent Owner will argue, and the counter

9. Sibling-patent record as evidentiary cross-check

The fact that the identical specification has already drawn this art is the single most probative signal in this analysis:

• IPR2025-00520 — LG Electronics Inc. v. Maxell Ltd., filed January 21, 2025, challenging U.S. 10,244,284, "Display Apparatus and Video Processing Apparatus," claims 18–20, on Ground 1: Honkanen + Nokia N95-1 User Guide and Ground 2: Dua + Barnes — i.e., exactly the combinations analyzed in § 3 and § 4 above, aimed at the same two-radio rate-assignment subject matter.
• IPR2024-00906 / IPR2024-00907 — Samsung Electronics v. Maxell, challenging U.S. 10,129,590 (the '860 patent's parent) using the Nokia N93 User Manual.

I could not determine whether IPR2025-00520 was instituted — I exhausted my search budget before retrieving the Board's institution or final written decision. That is a material unknown and should be checked. A written decision in IPR2025-00520 would be the closest thing to an adjudicated obviousness holding on this claimed subject matter.

No IPR petition against U.S. 11,451,860 itself was located. (Consistent with the Litigation Report §3.)

10. Conclusion

On the art identified, the independent claims of U.S. 11,451,860 (claims 1 and 7) would have been obvious under pre-AIA 35 U.S.C. § 103(a).

• Primary combination: Dua (US 2006/0258289 A1) + Barnes (US 2005/0136949 A1) — two references, same field, complementary teachings, explicit motivation (bandwidth-priority for video to avoid buffering), predictable result.
• Reinforced combination: Honkanen (US 2006/0135076 A1) + Dua + Barnes — adds an express control unit for multiple simultaneous radio interfaces, closing limitation (III) squarely.
• Alternative/coexistence combination: EP 1 747 616 A1 and/or US 2005/0255878 A1 + Dua and/or Barnes — supplies the interference-based rationale for arbitrating between co-located radios.
• Secondary reference: Nokia N95-1 User Guide — user-initiated connection selection (dependent-claim hook).
• Corroborating art: Nokia N93 User Manual (already deployed against the '860 patent's parent in IPR2024-00906/907).

Dependent claims 8–11 (OFDM; modulation/frequency-band/carrier-count variation; user-triggered reprioritization; resolution-tracking rate change; MIMO; pooled band-A–D modems) add only routine link-adaptation and radio-resource-management techniques that were standard by 2007 and are not, on this record, anchored by any unexpected result.

Confidence: moderate-to-high on the legal trajectory; low-to-moderate on any single reference's exact disclosure, because the key references (B)–(E) reached me second-hand via an IPR petition summary rather than primary documents.

11. Explicitly unverified / do not rely without checking

1. The '860 patent's actual claim text — still not retrieved (carried forward from § 3 of the Patent Summary). All limitation mapping above is to reconstructed limitations.
2. Primary documents for Honkanen, Dua, Barnes, and the N95-1 guide — application numbers reproduced literally from a third-party summary; disclosures, publication dates, and even the mapping of "Honkanen" to US 2006/0135076 need primary confirmation.
3. Institution/outcome of IPR2025-00520 — unknown; search budget exhausted.
4. Whether the EP/PCT search reports citing JP 2006-032163 A, JP 2006-100194 A, JP 11-287620 A, and JP 2001-202662 A belong to this family — unconfirmed.
5. Publication date of EP 1 747 616 A1 — unverified.
6. ITC Inv. No. 337-TA-3769 — still unverified (see Litigation Report §2); not relied on here.
7. The date conflict between the task header (April 26, 2026) and my operating environment (September 28, 2026) is noted, not resolved.

Authoritative next checks: USPTO PTAB (https://ptacts.uspto.gov) for IPR2025-00520's institution/FWD and for any petition naming U.S. 11,451,860; USPTO PatentCenter/public PAIR for the '860 file history and its actual "References Cited" list; ITC EDIS (https://edis.usitc.gov) for any '860-related second investigation; and Google Patents' "References Cited" table for US11451860B2 (https://patents.google.com/patent/[US11451860](/patent/US11451860)/en) — the very table that was absent from the material furnished to me.

Nothing in this section is legal advice or a legal conclusion as to validity, infringement, or enforceability.