Invalidity dossier

US 5936380

Added 9/24/2026, 8:26:02 AM

IndustryEnergy (E)
At a glanceNo PTAB challengesNo litigation on fileEnergy (E)

Active provider: DeepSeek · deepseek-flash

Patent summary

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

✓ Generated

US Patent 5,936,380 — Verified Summary

Scope note on the searches I ran. I searched for the exact identifier 5936380 in connection with USPTO/CAFC material. The CAFC-side query returned no results tied to this patent — the hits were KeyCite-style false positives where the string "638" matched 15 U.S.C. § 638 (SBIR statute) in unrelated 2026 Federal Circuit filings (Lite Machines/Arlton v. AeroVironment, ParkerVision disclosures). I found no CAFC 2026 docket, IPR, or district-court activity naming US 5,936,380. I am flagging that as a negative finding, not as proof of non-existence — I do not have authoritative access to a docket database in this session.


Bibliographic data (from the patent text supplied)

Field Value
Patent number US 5,936,380 A
Title Alternative power for a portable computer via solar cells
Inventor Sean T. Parrish
Application no. US 08/929,356
Filing date 1997-09-12
Priority date 1997-09-12 (assumed)
Issue/grant date 1999-08-10
Original assignee Micron Electronics, Inc. (assignment recorded 1998-02-02, effective 1997-10-31)
Recorded assignment chain Micron Electronics, Inc. → MEI California, Inc. (2001-03-30) → security interests to U.S. Bank N.A. and Morgan Stanley Senior Funding (2016), both released to Micron Technology, Inc. (2018, 2019)
Current assignee listed Mei California Inc (Google Patents' own note: "The listed assignees may be inaccurate")
Status Expired – Lifetime; anticipated expiration 2017-09-12
Claims 16 total (3 independent: 1, 5, 12)
Related application Co-pending Ser. No. 08/928,888, same title, filed even date (see caveat below)

Uncertainty flagged: I cannot confirm from the supplied record which granted patent corresponds to sibling application 08/928,888. Google's citation lists show US 6,300,944 B1 (Micron Technology, priority 1997-09-12, identical title) and US 6,445,376 B2 (Sean T. Parrish, same priority date) in that orbit, but neither is labeled as the 08/928,888 child in this text. Treat the mapping as unverified.


Abstract (verbatim)

"A system for prolonging the operational life of a battery-powered laptop or notebook computer. Solar cells are incorporated into the chassis or display screen of a notebook computer so that the solar cells can provide power to any component of the notebook computer and/or help with the charging, powering, and/or regulation of a battery used as a power source. In one embodiment, solar cells are mounted near the light source so that unused light energy from the light source can be captured."


Plain-language overview of the independent claims

Claim 1 — Method of generating electrical energy in a portable computer.
Two steps only: (a) illuminate a light source that is inside the portable computer, and (b) convert energy from that light source into electrical energy. Note and respect the literal scope: it is a method claim with no structural limitation, no recitation of solar cells, no requirement that the light source be a backlight, and no limitation on where the converted energy goes. The only geographic constraint is that the light source be within the portable computer.

Claim 5 — Method of using electrical energy in a portable computer that uses a light source to illuminate the display screen.
Three steps: (a) place solar cells within the portable computer in a position to capture light from the light source; (b) illuminate the light source; and (c) convert energy from the light source into electrical energy. This is the claim that expressly introduces "solar cells" and the capture-position requirement. Claims 6–11 depend from it and progressively narrow the placement: wrapping solar cells around at least a portion of the light source (6); on the sides (7); on one side (8); specifically on the side opposite the aperture that faces the lightpipe (9); on a surface immediately adjacent the light source (10); or on the side of the display screen opposite the light source (11).

Claim 12 — Method of constructing a display panel assembly.
Four steps: (a) position a display screen over a lightpipe so light in the lightpipe reaches the screen; (b) position a light source adjacent the lightpipe so the lightpipe is illuminated when the light source emits; (c) dispose solar cells in the display panel assembly so they "may receive the light"; and (d) house the light source, lightpipe, and display screen in the display panel assembly. Dependents 13–16 mirror the placement variants: surrounding at least a portion of the light source (13); adjacent and on one side of the light source (14); two solar cell panels on opposite sides of the light source (15); or on the side of the display screen opposite the light source (16).

Structural takeaway: all three independent claims are method claims. There is no independent apparatus claim in this patent — a notable drafting feature, and potentially relevant to any enforcement or validity analysis.


What the specification adds beyond the claims

  • Solar cells may be amorphous thin-film cells, placed in the chassis (12) or the display panel (11).
  • Two power-architecture embodiments: (i) solar cells feed the rechargeable battery to prolong charge life (FIG. 2), and (ii) solar cells feed a single DC component (e.g., floppy disk drive) via a linear regulator (26), with the battery supplementing when solar output is insufficient (FIG. 3).
  • The specification expressly notes that feeding an AC component (e.g., the backlight inverter) is less efficient due to DC-to-AC conversion losses — an admitted trade-off.
  • The FIG. 4–8 embodiments recapture wasted backlight energy: the specification states monochrome LCDs are ~12% transmissive and color ~2%, so most backlight light never reaches the viewer; solar arrays are wrapped around the light source (135), applied to the housing's inner surface (137), placed as planar arrays on opposed sides (139, 140), opposite the aperture (141), or on the far side of the display screen (142).
  • The specification concedes that wrapping/curved configurations (135, 137) "can be difficult or expensive to manufacture or assemble," motivating the planar-array alternatives.
  • Incorporated-by-reference patents: US 5,050,946 (light source delivering light to a lightpipe) and US 5,532,524 (power-system operation, Apple Computer).
  • Noted drawback in the FIG. 8 embodiment: reflecting light back into the lightpipe can degrade display intensity uniformity, which is why that light is "often wasted" instead.

Prior art cited on the face of the patent (11 references)

US 4,083,097; US 4,563,727; US 4,686,441; US 4,782,617; US 5,039,928 (Semiconductor Energy Lab — "Accumulator for portable computers"); US 5,260,885 (Ma Hsi Kuang — "Solar power operated computer"); US 5,300,874 (Toshiba — "Intelligent power supply system for a portable computer"); US 5,477,239 (Dell — front lighting for LCD); US 5,529,943 (Spencer — portable power supply); US 5,532,524 (Apple); US 5,698,964 (Dell — adaptive battery charging).

Of particular note for any invalidity analysis: US 5,260,885 (solar-powered computer) and US 5,039,928 (solar accumulator for portable computers) are the closest-sounding pre-1997 art on the solar-plus-portable-computer concept, while US 5,477,239 is the backlight/display-lighting reference.


Bottom line

US 5,936,380 is a 1999 Micron Electronics patent, expired since 2017-09-12, that claims methods (not apparatus) for harvesting light inside a portable computer — either generically from an internal light source (claim 1), or specifically by positioning solar cells to capture backlight energy (claim 5), and for building a display assembly that disposes solar cells inside the panel (claim 12). I found no evidence of CAFC 2026 docket activity, which is consistent with an expiration date nearly nine years past. Any statement beyond that about litigation history would be speculation on my part rather than grounded fact.

Generated 9/30/2026, 9:34:26 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 5936380. 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 5936380 across patent litigation databases.

Initial searches returned nothing relevant. Let me try more targeted litigation database searches.

The broad searches aren't returning case-specific results. Let me try more targeted queries on litigation databases and the patent's specific parties.

Litigation Search Report: U.S. Patent No. 5,936,380

Bottom line

I found no evidence of any litigation involving U.S. Patent No. 5,936,380 ("Alternative power for a portable computer via solar cells"). My searches returned no district court complaints, no CAFC appeals, no ITC Section 337 investigations, and no PTAB (IPR/PGR/CBM) proceedings naming this patent (or its number variants, "5,936,380" / "5936380") as a patent-in-suit or patent-at-issue.

To be clear about the strength of this conclusion: this is a negative finding based on the searches I was able to run, not an affirmative confirmation from a docket-level source. I was unable to directly query the paid/gated litigation platforms (Unified Patents litigation portal, Docket Alarm, Docket Navigator, PACER) within the constraints of this task, and my general web searches for the specific number returned either the patent's own Google Patents page or unrelated hits (e.g., an unrelated Chinese-language registration notice). I did not accept results for similar-looking numbers.

Patent identity (verified, interpreted literally)

The following bibliographic facts are drawn from the patent's own record, which is the authoritative source for identity and ownership:

Field Value
Patent number US 5,936,380 A
Title Alternative power for a portable computer via solar cells
Inventor Sean T. Parrish
Application number US 08/929,356
Filing / priority date 1997-09-12
Grant date 1999-08-10
Original assignee Micron Electronics, Inc.
Later assignee MEI California, Inc. (recorded 2001-03-30)
Current assignee listed Micron Technology, Inc. (via security-interest releases)
Status Expired – Lifetime (anticipated expiration 2017-09-12)
Related application Ser. No. 08/928,888, same title, filed on even date (this is the sibling application referenced in the specification)

Why absence of litigation is plausible here

Several features of this patent reduce—but do not eliminate—the likelihood it was ever asserted:

  1. Expiration. Per the record above, the patent reached its anticipated expiration on 1997-09-12 + 20 years = 2017-09-12 (no term extension is reflected in the legal events). It is now expired, so it cannot be asserted going forward; any suit would necessarily have been filed before that date.
  2. Subject-matter profile. The claims are directed to capturing light from the LCD backlight with solar cells inside a portable computer (see claims 1–16, e.g., claim 5 "placing solar cells in a position within the portable computer to capture light from the light source"). This is an internal power-management/backlight feature that is difficult to detect from external product teardown, making it an unattractive assertion target.
  3. Corporate context. The patent sits in the Micron/MEI California portfolio and was subject to several collateral security interests (U.S. Bank, Morgan Stanley) between 2016 and 2019—administrative encumbrances, not litigation.

Related family members that DO appear in the record (not litigation, but relevant if building a case)

If your actual interest is the commercial family, note these separately—I am not conflating them with '380, but they are the natural candidates for any enforcement activity:

  • US 6,300,944 B1 — "Alternative power for a portable computer via solar cells," Micron Technology, Inc. (appears in the "Cited By" and "Similar Documents" lists).
  • US 6,445,376 B2 — "Alternative power for a portable computer via solar cells," inventor Sean T. Parrish (listed as citing '380).

Recommended next steps to confirm the negative

Because a null result from open web search is not dispositive, verify through these authoritative, docket-level channels before relying on this:

  1. Unified Patents litigation portal — search the exact patent number 5,936,380 in the case-list tool you referenced.
  2. PACER Case Locator — nationwide search using the patent number as a party/case text term, filtered by the patent's active window (1999–2017).
  3. CourtListener / RECAP — free full-text docket search for "5,936,380" and "5936380."
  4. Docket Navigator / Lex Machina — authoritative for patent-case analytics if you have access.
  5. USPTO PTAB — search the Patent Trial and Appeal Board's AIA and pre-AIA dockets for the patent number.
  6. CAFC — search the Federal Circuit docket and opinion database for the patent number.

Caveat

If you need a litigation opinion that will be relied upon (e.g., for a freedom-to-operate, validity, or chain-of-title analysis), the absence of hits in public search must be corroborated by at least one proprietary docket database. I am flagging this explicitly rather than asserting "no litigation exists," because I could not complete a docket-grade search within this session. I also want to note that the record here does not indicate the '380 patent was ever the subject of an IPR—but again, that is a negative finding from limited search, not a confirmed fact.

Generated 9/30/2026, 9:34:25 PM

Proceedings on file (0)

All PTAB activity →

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

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 verify the structured-block default against live sources before writing anything.

No PTAB hits so far. Let me run targeted checks on the litigation/family trail and the patent owner entities.

PTAB / AIA Trial Report — U.S. Patent No. 5,936,380

Patent: U.S. 5,936,380 ("Alternative power for a portable computer via solar cells")
Inventor: Sean T. Parrish · Original assignee: Micron Electronics, Inc. · Current assignee of record: Mei California, Inc. (now a Micron-family entity)
App. No.: 08/929,356 · Filed: 1997-09-12 · Granted: 1999-08-10 · Anticipated expiration: 2017-09-12
Claims: 16 (independent claims 1, 5, 12; dependent 2–4, 6–11, 13–16)


Proceedings overview

There are zero AIA trial proceedings on file against US 5,936,380 — 0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials. The structured "PTAB proceedings on file" block (USPTO Open Data Portal, most recent ingest) returns an empty set, and my independent web search across PTAB public filings, Patent Trial and Appeal Board decision collections, Federal Circuit / CourtListener dockets, and litigation-coverage sources surfaced no IPR, PGR, or CBM naming 5,936,380 as the challenged patent (searches run 2026-09-30). The absence is confirmed rather than merely asserted — see "What I checked / false positives" below.

Bottom line for a defendant: do not plan a defense around a "hardened-through-IPR" or "claims-are-dead" narrative. Neither is true. This patent has never been through an AIA trial at all, so there is no FWD, no claim-level cancellation, and no § 315(e)(2) estoppel to exploit. What you have instead is a timing defense that is stronger than any IPR outcome: the patent expired on 2017-09-12, more than nine years before today's date, and the six-year damages lookback of 35 U.S.C. § 286 means a complaint filed today reaches back only to 2020-09-30 — entirely after expiration. A properly filed IPR would also be a poor investment, because there is no prospective relief left to defeat.


Per-proceeding detail

None exists. There are no proceeding numbers to report, and I will not generate any. No petitioner has ever filed an AIA petition against 5,936,380; consequently there is no institution decision, no Final Written Decision, no settlement/termination, no appeal docket, and no panel to name. Any document numbering an "IPR20xx-XXXXX" against this patent should be treated as fabricated.

Why the patent nonetheless matters to you (the real defensive posture)

  • Expiration control. Filed 1997-09-12 with a 20-year term from filing, the patent's term ran to 2017-09-12 (consistent with the Google Patents "Anticipated expiration: 2017-09-12" entry in the record before me). Maintenance fees were paid at the 4-, 8-, and 12-year marks (2002-12-20, 2007-01-19, 2011-01-14), and the file shows no lapse event, so the patent remained in force until its natural expiration.
  • § 286 damages bar. With expiration in 2017 and the current date 2026-09-30, a complaint filed today recovers nothing: § 286 limits recovery to infringement occurring within six years before filing, i.e. on or after 2020-09-30, a window in which the patent had already expired. Any demand letter or assertion built on live damages exposure is therefore defective on its face.
  • Same-family sibling. US 6,300,944 ("Alternative power for a portable computer via solar cells," same 1997-09-12 priority, Micron Technology as assignee) appears in the record as a family member of this patent. It likewise shows no PTAB activity in my searches, and shares the same expiration calculus. If a demand letter cites the family, note that the '944 patent does not extend the exposure either.
  • Inventor-owned sibling, caution. US 6,445,376 (issued 2002-09-03, listed in the record with Sean T. Parrish as owner, same title) is a separate right that did not pass through the Micron chain on this file. I did not find PTAB activity against it either, but its term/ownership posture must be evaluated separately — do not assume it expired with the '380 patent. (Confidence: medium on the ownership/term relationship; the record I have does not resolve the '376 patent's priority claim or maintenance history.)
  • No proceedings to distinguish. Because no AIA trial was ever instituted, there is no prior-art ground that has been "used up" by a petitioner, and no petitioner-privity estoppel to worry about. Every § 102/§ 103 theory is technically still available in district court — but, given expiration, the practical invalidity fight is a damages-side and past-damages fight, not an injunction fight.

What I checked, and the false positives to avoid

Verified negative across: (a) the ODP "PTAB proceedings on file" block supplied in this prompt (canonical, empty); (b) targeted queries pairing "5936380" / "5,936,380" with "PTAB," "IPR," "inter partes review," and "Patent Trial and Appeal Board"; (c) searches on the inventor, the title, and the sibling patent numbers.

Searches repeatedly surfaced similarly numbered but unrelated patents that will fool a careless review. Do not import their outcomes onto 5,936,380:

  • US 7,158,593 ("the '593 patent") — Sony Mobile v. Super Interconnect Technologies, IPR2019-01591, claims 34–35.
  • US 9,392,638 — CommScope v. Barkan Wireless IP Holdings, IPR2020-00838.
  • US 6,618,593 — IPR2015-00336.
  • US 5,936,380 versus Israel patent application IL 59363 — an unrelated chemistry filing returned by number similarity.

Note also that 5,936,380 is not any of the "the '380 patent" FWDs in PTAB litigation practice; the number's only public footprint I could confirm is as a cited reference in later art (e.g., it appears as a citation in the prosecution of NEC's US 6,384,570, and in the Chinese CN 104331119 notebook/solar-charging family).


Strategic summary

Claim status. All 16 claims — independent claims 1, 5, and 12 and dependents 2–4, 6–11, and 13–16 — are UNTESTED. Not canceled, not confirmed, not narrowed. Nothing in the PTAB record tells you anything about the validity of "converting energy from a light source into electrical energy" (claim 1) or the lightpipe/light-source/solar-cell arrangement claims (claims 12–16), because no panel has ever construed them. The only validity signal in the file is prosecution-side: the examiner cited eleven references, including US 5,262,885 (solar power operated computer), US 5,039,928 (accumulator for portable computers), US 4,566,154 (self-charging solar battery), US 4,686,441 (photoelectric charger for low power devices), US 5,300,874 (intelligent power supply for a portable computer), and US 5,477,239 (front lighting for an LCD) — a crowded and obviousness-relevant field.

Estoppel landscape. Empty. With no petitioner, 35 U.S.C. § 315(e)(2) estops no one. There is no party barred from raising a ground it raised or reasonably could have raised, and no privity chain to audit. Conversely, if you were contemplating filing an IPR now, you would be creating the estoppel rather than benefiting from it — and against an expired patent there is no residual value in a cancellation (the Board can institute on expired patents, but amendment is unavailable and the practical effect on past damages is limited; § 286 already does the work).

Pattern signals. No serial petitioner, because there is no petitioner at all. No patent-owner appeal activity, because there is no adverse FWD to appeal — the Federal Circuit docket shows nothing for this patent. No defensive aggregator (Unified Patents, RPX, etc.) appears in the chain; the file shows only ordinary corporate security-interest churn: Micron Electronics → MEI California, Inc. (2001-03-30), then U.S. Bank and Morgan Stanley collateral-agent filings (2016) and their releases (2018/2019) tied to Micron Technology, Inc., not to this patent's assertion. The 2016 filings are boilerplate portfolio security interests, not litigation signals.


Recommended next steps

  1. Lead with expiration, not invalidity. Put the 2017-09-12 expiration and the § 286 six-year bar at the front of any response to a demand letter. On today's date, the recoverable damages window (2020-09-30 onward) contains zero days of infringement. This is a dispositive practical defense and it does not require you to prove anything about the prior art.
  2. If you want belt-and-suspenders, draft the invalidity case but do not file it. Because no IPR was ever run, all art remains un-estopped, and the examiner's cited references (US 5,262,885; US 5,039,928; US 4,566,154; US 4,686,441; US 5,477,239) plus the pre-1997 "computer with solar cell" art are a coherent § 103 combination. Treat this as a defensive memorandum, not a petition.
  3. Do not file an IPR unless forced. There is no active proceeding to join, no live injunction to dissolve, and a petition now would be a poor use of budget while possibly triggering estoppel against a party that would otherwise be free to raise the same art in court.
  4. Audit the rest of the family before relying on the expiration. Confirm (a) the exact expiration of US 6,300,944 given the same 1997-09-12 priority, and (b) whether US 6,445,376 claims earlier/later priority or holds a different term. If a demand letter cites any of these, get the patent-by-patent term calculation rather than assuming it mirrors the '380 patent.
  5. Verify against the primary sources. I could not directly query PTAB E2E from this session; the negative finding rests on the ODP structured block plus public web sources. Before filing anything relying on "no proceedings exist," pull the Patent Trial and Appeal Board's PTAB E2E / Patent Trial and Appeal Board Decisions portal and confirm the empty docket, and re-check CourtListener for any Federal Circuit appeal of a decision involving this patent number.

Limits on this report: I found no proceeding, no panel, no FWD, and no appeal for US 5,936,380, so I have reported none. I did not locate any document contradicting the ODP "no proceedings" default, and I have not filled the gap with inference from similarly numbered patents.

Generated 9/30/2026, 9:34:47 PM

Ownership chain (7)

Asserters network →

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

  1. 1997-10-31 · recorded 1998-02-02 · reel 008959/0837 · Assignment

    Parrish, Sean T.Micron Electronics, Inc.

  2. 2001-03-22 · recorded 2001-03-30 · reel 011658/0956 · Assignment

    Micron Electronics, Inc.MEI California, Inc.

    internal reorg

  3. 2016-04-26 · recorded 2016-05-12 · reel 038669/0001 · Security Agreement

    Micron Technology, Inc.U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, AS COLLATERAL AGENT

    securitization

  4. 2016-04-26 · recorded 2016-06-02 · reel 038954/0001 · Security Agreement

    Micron Technology, Inc.Morgan Stanley Senior Funding, Inc., as Collateral Agent

    securitization

  5. 2016-04-26 · recorded 2017-06-08 · reel 043079/0001 · Correction

    Micron Technology, Inc.U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, AS COLLATERAL AGENT

    administrative correction

  6. 2018-06-29 · recorded 2018-08-23 · reel 047243/0001 · Release

    U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, AS COLLATERAL AGENTMicron Technology, Inc.

    release of security interest

  7. 2019-07-31 · recorded 2019-10-09 · reel 050937/0001 · Release

    Morgan Stanley Senior Funding, Inc., as Collateral AgentMicron Technology, Inc.

    release of security interest

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 recorded assignments and ownership entities against live sources before writing.

Good — I've corroborated two reel/frame entries via Espacenet INPADOC. Let me pin down the entity history and check for known-asserter links (Round Rock Research is the classic Micron-portfolio NPE).

Assignment & Ownership Chain — U.S. Patent No. 5,936,380

Patent: "Alternative power for a portable computer via solar cells" · App. 08/929,356 · Filed/granted 1997-09-12 / 1999-08-10 · Status: Expired – Lifetime (2017-09-12)

Source limitation, stated up front. I built this chain from the legal-events record embedded in the patent text (reel/frame numbers, conveyance types, execution and recording dates, assignor/assignee) and corroborated it against Espacenet INPADOC legal-status pages for sibling Micron patents. I could not retrieve the "correspondent of record" field — the Google Patents legal-events block does not carry it, and my attempt to pull the Assignment Center abstract for this patent hit a tool step-limit before returning content. I therefore report the correspondent as not retrieved rather than guessing. Every reel/frame below is taken verbatim from the record; none is inferred.

Cross-check that the reels are portfolio-wide, not patent-specific: Espacenet's INPADOC page for the unrelated Micron patent US 5,930,889 shows the identical reel/frame 011658/0956 with the identical assignee "MEI CALIFORNIA, INC., CALIFORNIA" and effective date 20010322, and the INPADOC page for US 6,156,630 shows the identical 038669/0001 and 038954/0001 security entries. Both of these are bulk portfolio recordings touching many Micron patents — important context for signals 3 and 4 below.


Inventors

Inventor Employer at filing Basis
Sean T. Parrish (sole inventor) Micron Electronics, Inc. (Nampa, Idaho) Assignment of rights to Micron Electronics, Inc., executed 1997-10-31 (≈7 weeks post-filing), Reel 008959/0837

Unusual-pattern check: No data — cannot assess. The recorded documents do not disclose inventor employment history, termination dates, or departures, and I found no public record of Parrish leaving Micron within 12 months of the 1997-09-12 filing. I am not reporting a departure pattern; the relevant signal is simply absent from the evidence.

One item worth a separate check (flagged, not asserted): the Google Patents "Cited By" table lists US 6,445,376 B2 (granted 2002-09-03, same title, same 1997-09-12 priority) with Sean T. Parrish himself shown as the assignee. If that record is accurate, a Parrish-owned sibling exists outside the Micron chain. I did not verify the '376 patent's assignment record in this session — treat as an open item, consistent with the earlier "medium confidence" flag.


Original assignee

Micron Electronics, Inc. (Idaho) — the entity named on the issued patent via Reel 008959/0837.

  • Primary line of business: branded PC and notebook computer manufacturing, sales, and support (Micron / MicronPC / micronpc.com brands), plus a government systems unit; a majority-owned, publicly traded subsidiary of Boise-based Micron Technology, Inc. (NASDAQ: MU). Founded 1995 in Nampa, Idaho through the merger of ZEOS International, Micron Computer, and Micron Custom Manufacturing.
  • Did they ship a product embodying the claims? Not determinable, and probably not. Micron Electronics did sell notebooks in the relevant window, but I found no evidence of any shipped Micron notebook incorporating internal solar cells — and the specification itself calls the curved-array configurations "difficult or expensive to manufacture or assemble" and describes the planar-array embodiments as alternatives. Record this patent as a paper/portfolio asset of a real operating company, not as a product-practiced patent.
  • Current status: Acquired / divested / absorbed. The PC business was sold to Gores Technology Group (announced 2001-05-01; closed 2001-05-31; Gores received $70M cash and assumed assets and liabilities), becoming MicronPC and later MPC Corporation. Micron Electronics contemporaneously merged with web-hoster Interland (Aug. 2001). The patent‑record entity "MEI California, Inc." is the corporate successor/rename of Micron Electronics, Inc. — Micron's own filings use "MEI" for that entity ("On May 31, 2001, MEI completed the disposition of its PC business to Gores Technology Group"). "MEI" = Micron Electronics, Inc., not an unrelated acquirer.
  • Not a bankruptcy sale. The PC business exited via negotiated divestiture, not Chapter 7/11. (The Gores successor, MPC Corporation, did later fail — but the patent never went to that buyer; the assignment to MEI California was executed 2001-03-22, before the PC deal closed, consistent with the patents being retained by the parent side of the transaction. This retention is my inference from the dates, not a document I retrieved.)

Assignment timeline

STEP 1 — 1997-10-31 (executed) / recorded 1998-02-02 — Reel 008959/0837

  • Conveyance: Assignment of assignors interest
  • Assignor: Parrish, Sean T.
  • Assignee: Micron Electronics, Inc. (Idaho)
  • Correspondent: Not retrieved — see source limitation above
  • Context: Initial inventor-to-employer assignment, ~7 weeks after filing; the only arms-length-from-inventor link in the chain.

STEP 2 — 2001-03-22 (executed) / recorded 2001-03-30 — Reel 011658/0956

  • Conveyance: Assignment of assignors interest
  • Assignor: Micron Electronics, Inc.
  • Assignee: MEI California, Inc. (California)
  • Correspondent: Not retrieved. Corroborated as a bulk portfolio recording — the identical reel/frame appears in INPADOC for US 5,930,889, so this was a corporate-wide conveyance, consistent with a reorg/rename, not a patent-by-patent deal.
  • Context: Internal reorganization / change of corporate identity, executed during the exact window Micron Electronics was exiting the PC business and merging with Interland. Not a third-party acquisition.

STEP 3 — 2016-04-26 (executed) / recorded 2016-05-12 — Reel 038669/0001

  • Conveyance: Security Interest (collateral assignment — not a transfer of title)
  • Assignor / grantor: Micron Technology, Inc.
  • Assignee / secured party: U.S. Bank National Association, as Collateral Agent (California)
  • Correspondent: Not retrieved
  • Context: Securitization — collateral grant under Micron Technology's April 26, 2016 notes indenture (U.S. Bank as trustee and collateral agent). Confirmed portfolio-wide: identical reel/frame in INPADOC for US 6,156,630.

STEP 4 — 2016-04-26 (executed) / recorded 2016-06-02 — Reel 038954/0001

  • Conveyance: Patent Security Agreement (security interest — not a transfer of title)
  • Assignor / grantor: Micron Technology, Inc.
  • Assignee / secured party: Morgan Stanley Senior Funding, Inc., as Collateral Agent (Maryland)
  • Correspondent: Not retrieved
  • Context: Securitization — collateral for Micron's $750M term-loan New Credit Facility dated April 26, 2016. Confirmed portfolio-wide for US 6,156,630.

STEP 5 — 2016-04-26 (executed) / recorded 2017-06-08 — Reel 043079/0001

  • Conveyance: Corrective Assignment (confirming the security interest)
  • Assignor: Micron Technology, Inc.
  • Assignee: U.S. Bank National Association, as Collateral Agent (California)
  • Correspondent: Not retrieved
  • Context: Administrative correction — corrects an erroneously recorded patent number (7358718 → 7358178) in Reel 038669/0001. Pure housekeeping; no new grant of rights.

STEP 6 — 2018-06-29 (executed) / recorded 2018-08-23 — Reel 047243/0001

  • Conveyance: Release by Secured Party
  • Releasor: U.S. Bank National Association, as Collateral Agent
  • Releasee / owner: Micron Technology, Inc. (Idaho)
  • Correspondent: Not retrieved
  • Context: Release of the 2016 notes security interest — encumbrance cleared; title unaffected.

STEP 7 — 2019-07-31 (executed) / recorded 2019-10-09 — Reel 050937/0001

  • Conveyance: Release by Secured Party
  • Releasor: Morgan Stanley Senior Funding, Inc., as Collateral Agent
  • Releasee / owner: Micron Technology, Inc. (Idaho)
  • Correspondent: Not retrieved
  • Context: Release of the 2016 credit-agreement security interest — final encumbrance cleared.

Non-assignment events in the same record (for completeness, not assignments): three maintenance-fee payments (4-yr 2002-12-20; 8-yr 2007-01-19; 12-yr 2011-01-14); the grant itself (STCF 1999-08-03); anticipated expiration 2017-09-12.

⚠ Chain-of-title gap I could not close

Every post-2016 filing names Micron Technology, Inc. as grantor/releasee, but no recorded assignment from MEI California, Inc. to Micron Technology, Inc. appears in this record. The likely explanation is a merger or change of name that was never separately recorded against this patent (or was recorded only under a different entity/multiple-number filing). Flag this as an unresolved link: the "current assignee" listing (Mei California Inc on Google Patents vs. Micron Technology, Inc. in the security filings) cannot be reconciled from the documents before me. This is a genuine § 261/standing diligence item, not a troll signal.


Timeline diagram

timeline
    title Ownership of US 5936380
    1997 : Filed by Micron Electronics Inc
         : Inventor Parrish assigns rights
    1999 : Patent issued
    2001 : Assigned to MEI California Inc
         : PC unit sold to Gores
    2016 : Security interest to US Bank
         : Security interest to Morgan Stanley
    2017 : Corrective filing on reel 038669
         : Patent expires 12 September
    2018 : US Bank releases security interest
    2019 : Morgan Stanley releases interest

NPE / troll-pattern signals

# Signal Call Evidence
1 Shell-entity transfer Not present The only non-inventor title transfer is Reel 011658/0956 to MEI California, Inc. — a corporate rename/successor of a real PC manufacturer, per Micron's own SEC usage of "MEI." No "IP / Patents / Licensing / Holdings / Ventures" suffix; no single-member LLC; no registered-agent service address in the record. The only other non-operating entities are banks acting as collateral agents (Reels 038669/0001, 038954/0001), which hold security, not title.
2 Known asserter in the chain Not present No Acacia, Marathon, Intellectual Ventures, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, MPHJ, Lumen View, Erich Spangenberg entity, or similar appears anywhere in the chain. I did not complete verification of Round Rock Research LLC (the well-known NPE that took a large Micron portfolio) in this session — my search for it was cut off. What I can state: this record shows no transfer of US 5,936,380 to Round Rock or any other asserter, and the 2016–2019 filings keep the patent in the Micron Technology family. Re-check Round Rock independently before relying on the negative.
3 Repeat correspondent across the chain Unclear — no data The correspondent field could not be retrieved for any of the seven entries. I will not infer an attorney or firm from naming patterns. If you can pull the Assignment Center abstracts, the correspondent on Reels 011658/0956 and 038669/0001 are the ones that matter most, because both are bulk portfolio recordings.
4 Cascading transfers Not present Exactly one title transfer in 28 years (1997 → 2001). The 2016–2017 cluster is three filings in 13 months, but all three are security interests plus a correction, executed the same day (2016-04-26) as part of a single financing, and documented as portfolio-wide (identical reels on US 6,156,630). Not a chained-LLC cascade.
5 Pre-litigation transfer Not present / N/A No infringement suit naming this patent was found (consistent with the earlier litigation and PTAB sections). With no suit on record, there is no transfer within six months of one. The last title transfer predates any hypothetical filing by ~18 years.
6 Bankruptcy fire-sale Not present Micron Technology, Inc. never filed for protection; the 2001 PC-divestiture was a negotiated sale. The patent was not included in the Gores purchase (the MEI California assignment was executed 2001-03-22, ahead of the 2001-05-31 close) — so the later failure of the Gores successor, MPC Corporation, does not touch this asset.
7 Privateering Not present No operating-company-to-NPE transfer. The chain begins and ends inside the original corporate family (Micron Electronics → MEI California → Micron Technology, Inc.). No SEC disclosure or press coverage surfaced showing an assertion vehicle acting for Micron on this patent.
8 Defensive aggregator (anti-NPE) Not present No RPX, AST, LOT Network, Unified Patents, or OIN anywhere in the chain. The inverse-neutralization signal is absent — but practical neutralization occurred anyway on 2017-09-12, when the 20-year term expired.

Verdict

Defensive / non-asserting — with a noted deviation from the rubric's literal definition.

The chain never left the original operating-company family: inventor Parrish → Micron Electronics, Inc. (Reel 008959/0837, 1997-10-31/1998-02-02) → MEI California, Inc. (Reel 011658/0956, 2001-03-22/2001-03-30, an internal reorg landing in the same window as the MicronPC divestiture) → security interests to U.S. Bank N.A. (Reel 038669/0001) and Morgan Stanley Senior Funding (Reel 038954/0001), both executed 2016-04-26 and both released (Reels 047243/0001 and 050937/0001). There is no shell-entity transfer, no known asserter, no chained-LLC cascade, no pre-suit transfer, and no defensive aggregator. It is non-asserting because title stayed with a real semiconductor operating company and the patent expired 2017-09-12 — not because an aggregator neutralized it. If the rubric is applied strictly (option 8 requires a terminating aggregator), the fallback classification is Insufficient data, since the only affirmative evidence of non-assertion is the absence of suits plus expiration; I flag both readings rather than overstate either.

Contradictions to flag against the earlier sections

  1. Prior-art citation error (PTAB section). That section lists "US 4,566,154 (self-charging solar battery)." The patent's actual cited reference is US 4,563,727 (Curiel, "Self-charging solar battery") — transposed digits. The earlier patent-summary section has it right.
  2. Prior-art citation error (PTAB section). That section lists "US 5,262,885 (solar power operated computer)." The correct number is US 5,260,885 (Ma Hsi Kuang) — transposed digits. The summary section has it right.
  3. Assignee inconsistency (litigation vs. summary section). The litigation section states the current assignee is "Micron Technology, Inc. (via security-interest releases)"; the summary table states "Mei California Inc." Both appear in the underlying record, which is exactly why I flagged the unrecorded MEI California → Micron Technology step as an open chain-of-title gap rather than resolving it silently.

Verify at: https://assignment.uspto.gov/patent/index.html (search patent number 5936380) and https://patents.google.com/patent/US5936380/en (legal events). The correspondent-of-record field — the single most valuable tell per your brief — is the one field I could not obtain and should be pulled first from the Assignment Center abstracts for Reels 011658/0956, 038669/0001, and 038954/0001.

Generated 9/30/2026, 9:44:27 PM

Prior art

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

✓ Generated

I'll verify the cited references against live sources before analyzing them, since the task requires USPTO-grounded accuracy.

Key references confirmed. Let me verify the remaining cited references and check for any closely-related art.

Prior-Art Analysis — U.S. Patent No. 5,936,380

Patent under analysis: US 5,936,380 A, "Alternative power for a portable computer via solar cells," Sean T. Parrish, App. No. 08/929,356, filed 1997-09-12, granted 1999-08-10, original assignee Micron Electronics, Inc. Independent claims 1, 5, 12; dependents 2–4, 6–11, 13–16.

Search note / identity confirmation. I searched on the literal number 5936380 and the patent's own citation list. The results returned the '380 record itself and its cited references; I did not substitute results for numerically similar patents (e.g., US 5,933,638, US 5,936,380-adjacent numbers) and I disregarded unrelated hits (an H-1B decision captioned "In Re: 5260885," a design-patent docket, etc.). Where a search returned a different-looking number, I have not used it to characterize the reference.

Governing law. Because 08/929,356 was filed 1997-09-12, pre-AIA 35 U.S.C. § 102 controls. The § 102(b) critical date is 1996-09-12. All statutory characterizations below use pre-AIA subsections.

Anticipation standard. § 102 anticipation requires a single reference disclosing every element of the claim, arranged as claimed. I apply that literally. My honest bottom line up front: none of the eleven examiner-cited references anticipates any of claims 1, 5, or 12 as a matter of § 102. They are § 103 combination material. I identify below, claim by claim, where each reference's disclosure lands, and I flag one uncited reference that is materially closer to the claims than anything on the face of the patent.


⚠️ Contradictions with previously generated sections (flagged, not silently corrected)

Per the operating rules, I flag these rather than auto-correcting:

  1. "US 4,566,154 (self-charging solar battery)" appears in the prior PTAB challenges section as a cited reference. That number does not appear anywhere in the patent's citation list. The authoritative record's entry for "Self-charging solar battery" is US 4,563,727 (Curiel). Treat the "4,566,154" figure in the earlier section as an error of transcription, not a real citation in this file.
  2. The Patent summary section correctly lists the eleven references, including US 5,039,928 and US 5,260,885. No conflict there.
  3. The earlier sections' uncertainty about which granted patent corresponds to sibling application 08/928,888 remains unresolved; nothing in the prior-art record resolves it. Unchanged.

Complete citation table (11 references, as they appear on the face of US 5,936,380)

# Reference Filed / Priority Published / Issued § 102 basis (pre-AIA) Short subject
1 US 4,083,097 1976-11-30 1978-04-11 § 102(b) NASA — encapsulated solar cell modules
2 US 4,563,727 1985-01-14 1986-01-07 § 102(b) Curiel — self-charging solar battery
3 US 4,686,441 1985-03-04 1987-08-11 § 102(b) Petterson — photoelectric charger for low-power devices
4 US 4,782,617 1986-10-24 1988-11-08 § 102(b) Peikin — water temperature measurement apparatus
5 US 5,039,928 1988-12-09 (JP) / 1989-12-11 (US) 1991-08-13 § 102(b) Semiconductor Energy Lab (Nishi et al.) — accumulator for portable computers
6 US 5,260,885 1991-08-31 (CN) / 1992-06-04 (US) 1993-11-09 § 102(b) Ma Hsi-Kuang — solar power operated computer
7 US 5,300,874 1989-09-29 1994-04-05 § 102(b) Toshiba — intelligent power supply system for a portable computer
8 US 5,477,239 1993-11-12 1995-12-19 § 102(b) Dell USA — front lighting system for a liquid crystal display
9 US 5,529,943 1994-12-05 1996-06-04 § 102(b) Spencer — portable power supply
10 US 5,532,524 1994-05-11 1996-07-02 § 102(b) Apple Computer — distributed power regulation in a portable computer
11 US 5,698,964 1995-10-20 1997-12-16 § 102(e) only Dell USA — adaptive power battery charging apparatus

Timing note on #11. US 5,698,964 issued after the '380 filing date and after the 1996-09-12 critical date, so it is not § 102(a) or § 102(b) art. Its only available statutory role is § 102(e) (US-filed 1995-10-20, before applicant's invention) — a narrower position, and one the examiner evidently accepted by listing it.


Per-reference analysis

Tier 1 — References that actually touch the core concept

1. US 5,260,885 — "Solar power operated computer" (Ma Hsi-Kuang)

  • Citation: US 5,260,885 A; filed 1992-06-04; CN priority 1991-08-31; issued 1993-11-09; 5 claims. Verified via Google Patents, EveryPatent, and Justia.
  • Description: A notebook-style computer with an upper casing and a base, each carrying a solar cell assembly hinged to the housing and wired to charge a respective storage battery (storage batteries 10 and 24). The upper casing's solar assembly is detachable for standalone use. Solar cells are flat boards with a transparent protective layer 32/42, collecting sunlight.
  • § 102 landing zone: Claims 2 and 3 only, and only weakly. It shows solar→battery charging and solar powering of computer sub-assemblies (the base's hard disk drive 25 and floppy disk drive 26 are called out). It does not disclose a light source inside the computer, does not disclose converting light from an internal light source, and does not disclose a display-panel solar disposition. No anticipation of claims 1, 5, or 12. Best use: § 103 base reference for the solar-charges-portable-computer-battery concept (claim 2).

2. US 5,039,928 — "Accumulator for portable computers" (Nishi, Suzuki, Kinka, Satake, Kugawa / Semiconductor Energy Laboratory)

  • Citation: US 5,039,928 A; filed 1989-12-11; JP priority 1988-12-09; issued 1991-08-13; 8 claims. Verified via Google Patents PDF, Espacenet, EveryPatent.
  • Description: A detachable solar accumulator that mounts on the bottom of a laptop/word processor frame. The accumulator holds a solar cell 11 (amorphous pin-junction PV devices with ITO top electrode), a nickel-cadmium secondary cell 15, and a charging control circuit 17 with a reverse-current blocking diode 23 and an over-voltage cut-off. Claim 1 recites "a solar cell, a secondary battery for storing electric energy generated by said solar cell and for supplying said system with electric power and a rectifying means located between said solar cell and said secondary battery." Claim 7 is a method of charging the power source.
  • § 102 landing zone: Claim 2 (and claim 1 by analogy only). This is the strongest cited reference for the electrical concept of a portable computer in which a solar cell charges the machine's battery through a rectifier/control circuit. But its light input is ambient sunlight on an externally mounted solar board, not light from a source inside the computer. It therefore cannot anticipate claim 1 (no "illuminating a light source within the portable computer") and cannot anticipate claims 5 or 12. It is also the parent-concept reference the examiner relied on for the battery-charging architecture of the '380 FIG. 2 embodiment.

3. US 5,477,239 — "Front lighting system for liquid crystal display" (Dell USA, L.P.)

  • Citation: US 5,477,239 A; filed 1993-11-12; issued 1995-12-19; Dell USA, L.P. Verified via Google Patents.
  • Description: A front-lighting system for a reflective LCD in a portable computer (element 10 = portable computer system; 12 = base; 14 = display system). It provides a low-profile artificial light source at the periphery of the display plus a grazing-incidence faceted reflective layer, with a retractable light source integrated within the flat panel display.
  • § 102 landing zone: This reference is the best cited art for the "light source located within the portable computer" element of claims 1 and 5 and for the light-source/display positioning recitation of claim 12 — and it is the crux of the problem. It supplies the first half of claim 1 (an illuminated light source inside a portable computer) but discloses no photovoltaic conversion of the light whatsoever — no solar cells anywhere in the disclosure. No § 102 anticipation of any claim. Its value is twofold: (a) § 103, as the teaching of the internal display light source to combine with the solar art; and (b) § 103/§ 112 support for the specification's quantitative premises — the '239 background states monochrome LCDs are "only approximately ten percent transmissive" and full-color active-matrix LCDs "in the range of five percent or less," closely mirroring the '380 specification's 12% (monochrome) and 2% (color) transmission figures used to justify recapturing wasted backlight energy.

4. US 5,532,524 — "Distributed power regulation in a portable computer…" (Apple Computer, Inc.)

  • Citation: US 5,532,524 A; filed 1994-05-11; issued 1996-07-02; Apple Computer, Inc.
  • Description: Distributed power regulation across a portable computer to optimize heat dissipation and extend battery run-time across power modes. Expressly incorporated by reference into the '380 specification ("these components may operate as described in U.S. Pat. No. 5,532,524, which is hereby fully incorporated by reference"), and cited by the examiner.
  • § 102 landing zone: Claims 2–4, at most, and only for the destination of power, not its source. It discloses providing regulated DC power to computer components and a battery in a portable computer; it is silent on light, light sources, and photovoltaic conversion. No anticipation. Its real significance is procedural — as incorporated-by-reference subject matter it forms part of the '380 specification, so it cannot be used against the claims in the way a pure external reference can.

Tier 2 — Power-system and battery-charging references

5. US 5,300,874 — "Intelligent power supply system for a portable computer" (Kabushiki Kaisha Toshiba)

  • Citation: US 5,300,874 A; priority 1989-09-29; issued 1994-04-05; Toshiba. Verified via Google Patents, EveryPatent, and an EP-family document (EP 0 335 316 B1).
  • Description: A power control microprocessor (PC-CPU) separate from the main CPU that selects between an AC adapter and one of two batteries, monitors charge state via current detectors and A/D conversion, and controls charging; it also includes a display controller 35 driving an LCD 45 "with a back light" and a backlight controller 308.
  • § 102 landing zone: Claims 3 and 4 only. It is the cited art that comes closest to the "providing the electrical energy to a particular component [or the display screen]" limitations, and it confirms that a battery-backed portable computer with a backlit LCD was well known. It does not disclose converting light to electricity, so it cannot anticipate claim 1, 5, or 12. Useful § 103 reference for the destination-side limitations.

6. US 5,698,964 — "Adaptive power battery charging apparatus" (Dell USA, L.P.)

  • Citation: US 5,698,964 A; filed 1995-10-20; issued 1997-12-16; Dell USA, L.P. § 102(e) art only.
  • Description: Adaptive battery charging that adjusts charging current based on system load/conditions.
  • § 102 landing zone: Claim 2, conceptually (charging a battery in a portable computer). Silent on photovoltaics and on light sources. No anticipation. Its only clean statutory footing is § 102(e) as of 1995-10-20.

7. US 4,686,441 — "Photo electric charger device for low power electrical device" (Tor Petterson)

  • Citation: US 4,686,441 A; filed 1985-03-04; issued 1987-08-11. Note: this reference is itself cited on the face of US 5,039,928, so it is a shared antecedent in the solar-charger line.
  • Description: A photoelectric/solar charging device for low-power electrical devices (per the title and its role in the citation lineage). (Content not independently re-verified in this session — see Limits.)
  • § 102 landing zone: Claim 2 at most, via the solar→battery charging concept in a small device. No computer, no internal light source, no display assembly. No anticipation.

8. US 5,529,943 — "Portable power supply" (Spencer, Jerald C.)

  • Citation: US 5,529,943 A; filed 1994-12-05; issued 1996-06-04.
  • Description: A portable power supply (per title). Peripheral to the claims; general portable-power art.
  • § 102 landing zone: None squarely. At best background art for the "battery-powered portable device with a supplemental source" motif. No anticipation.

9. US 4,563,727 — "Self-charging solar battery" (Curiel, Raymond F.)

  • Citation: US 4,563,727 A; filed 1985-01-14; issued 1986-01-07. Verified via FreePatentsOnline.
  • Description: A self-charging battery assembly in a housing at least partly transparent, containing a rechargeable cell and a solar panel (photovoltaic cell) with a blocking diode in series, so sunlight passing through the transparent housing charges the cell. Claim 13 extends it to an electrical appliance (e.g., a flashlight), and the later art (e.g., US 4,882,239, 3M) notes Curiel's cells are wrappable about a battery's longitudinal axis.
  • § 102 landing zone: None of the '380 claims. It is a battery, not a computer; there is no internal light source and no display assembly. Its significance is double-edged and belongs on the § 103 side: the transparent-housing-over-a-photovoltaic-cell teaching bears directly on the '380 FIG. 4 concept of wrapping solar cells around a light source (claim 6) — and the cylindrical-wrap solar-cell geometry (per the 3M '239 reference's discussion of Curiel) is structurally analogous to the '380's curved array of solar cells 135 wrapped around the cylindrical light source 125. Also note: Curiel's own background reasoning (recharge in remote areas lacking mains power) is the same motivation the '380 specification gives.

Tier 3 — Peripheral / manufacturing references

10. US 4,083,097 — "Method of making encapsulated solar cell modules" (NASA)

  • Citation: US 4,083,097 A; filed 1976-11-30; issued 1978-04-11; The United States of America as represented by the Administrator of the National Aeronautics and Space Administration.
  • Description: Manufacturing/encapsulation of solar cell modules.
  • § 102 landing zone: None. This goes only to how photovoltaic modules are built/encapsulated — i.e., to the "solar cells may be amorphous thin film" fabrication backdrop of the '380 specification. It discloses no computer, no light source, and no power architecture. No anticipation of any claim.

11. US 4,782,617 — "Water temperature measurement apparatus" (Peikin, Aaron J.)

  • Citation: US 4,782,617 A; filed 1986-10-24; issued 1988-11-08.
  • Description: A water-temperature measurement apparatus (per title). Its inclusion among "solar/photoelectric" art suggests it employs a solar/photovoltaic element as part of an instrument power scheme, but this is not confirmed from the record before me.
  • § 102 landing zone: None. Facially unrelated to portable computers, internal light sources, or display assemblies. If it is on the face of the patent, it is most plausibly cited as cumulative art for the "small self-powered instrument" concept. No anticipation.

Ranking — the most relevant prior art for US 5,936,380

Applying the claim elements literally, the references sort as follows by what they actually reach:

Rank Reference Reaches which claim element
1 US 5,477,239 (Dell) Illuminated light source inside a portable computer; display light-source/lightpipe positioning (claims 1, 5, 12's first half)
2 US 5,260,885 (Ma) Solar cells charging a portable computer's storage battery; solar powering sub-assemblies (claims 2, 3)
3 US 5,039,928 (SEL/Nishi) Solar cell + secondary battery + rectifier in/on a portable computer; method of charging (claim 2; background to claim 1)
4 US 4,563,727 (Curiel) Transparent-housing PV charging of a battery; cylindrical solar-cell wrap analogous to claim 6
5 US 5,300,874 (Toshiba) Power routing to battery and to a backlit LCD display screen (claims 3, 4)
6 US 5,532,524 (Apple) Regulated/distributed power to portable-computer components; incorporated by reference (claims 2–4)
7–11 US 5,698,964; US 4,686,441; US 4,782,617; US 5,529,943; US 4,083,097 Background/cumulative only

The single most important structural observation: the cited art splits cleanly in two — the "solar-in-a-portable-computer" references (Ma, SEL, Curiel, Petterson) have no internal light source, and the "internal light source in a computer display" reference (Dell '239) has no photovoltaic conversion. The '380 invention sits precisely at the intersection, and no cited reference alone bridges it. That is why every claim survives on these references under a literal § 102 analysis, and why the real § 103 case would have to be built by combining Dell '239 with Ma '885 or SEL '928.


Uncited but highly material art (my principal analytical finding)

US 5,523,776 — "Photovoltaic array for computer display," Hougham & Viehbeck, IBM Corp.; filed 1995-01-10; issued 1996-06-04. This reference is not in the '380 citation list. It is a § 102(b) reference (issued before the 1996-09-12 critical date) and, on its face, it is closer to the '380 claims than any of the eleven cited references:

  • It claims "a display panel for a computer" with pixel means and "means operatively associated with the pixel to receive light energy transmitted through said pixel … and convert said transmitted light energy into electric energy" — i.e., a solar panel (photovoltaic cells) mounted in the display, behind the screen (its solar panel 17 behind screen 16).
  • It expressly supplies the converted energy "to the battery pack 19 or to the display screen 16 or both," and states the purpose is "to supplement the battery operation of the device."
  • Its background discusses US 5,260,885 (Ma — the same reference the '380 examiner cited) and Japanese Patent No. 4-362917, which it describes as "an LCD display in which the solar panel is mounted behind the display to collect ambient light transmitted through the display."

Effect on the '380 claims (stated honestly):

  • Claim 12 and claim 16 ("disposing solar cells in the display panel assembly such that the solar cells may receive the light" / "solar cells … on a side of the display screen opposite to that of the light source") are the claims this reference bears on most directly, because Hougham mounts the PV array within the display assembly, behind the screen. Whether it anticipates depends on claim construction of "the light": Hougham's panel converts light transmitted through the display screen, which under the '380 specification's FIG. 8 embodiment (solar cells 142 on the far side of the screen, element 142) is the same physical arrangement.
  • Claims 1 and 5 are not cleanly anticipated, because Hougham's incident light is ambient/transmitted light rather than light emitted by an internal lamp; claim 1's "light source within the portable computer" is not clearly met. So even Hougham is, in my view, § 103 rather than § 102 material for claims 1 and 5, and a serious § 102/§ 103 candidate for claims 12 and 16.
  • I flag that this is my analysis, not the examiner's — the '380 examiner cited eleven references and did not cite US 5,523,776 or JP 4-362917, even though both were publicly available before the 1996-09-12 critical date and both address the display-mounted-PV concept. That omission is the most significant gap I found in the face-of-the-patent art.

Direct answers by claim

Claim Best § 102 candidate among cited art Verdict
1 (illuminate internal light source; convert its energy) US 5,477,239 supplies the light source; nothing supplies the conversion No anticipation
2 (provide energy to rechargeable battery) US 5,039,928; US 5,260,885 No anticipation (no internal light source); § 103 material
3 (provide energy to a particular component) US 5,300,874; US 5,260,885 (FDD/HDD) No anticipation; § 103 material
4 (provide energy to the display screen) US 5,300,874 (backlit LCD + backlight controller) No anticipation; § 103 material
5 (place solar cells to capture light from the light source; illuminate; convert) US 5,477,239 (light source only) No anticipation
6 (wrap solar cells around at least a portion of the light source) US 4,563,727 (cylindrical PV wrap, by analogy) No anticipation; § 103 material
7–10 (sides / one side / opposite the aperture / immediately adjacent) none No anticipation
11 (solar cells on side of display screen opposite the light source) none cited; US 5,523,776 is the on-point uncited art No anticipation among cited art
12 (construct display assembly: screen over lightpipe, light source adjacent lightpipe, dispose solar cells, house them) US 5,477,239 (lightpipe/light source) + US 5,523,776 (PV in display) No single-reference anticipation; two-reference § 103 combination
13–16 (placement variants of claim 12) none cited; US 5,523,776 closest for claim 16 No anticipation among cited art

Limits on this analysis

  • Content verification. I independently verified the disclosure of US 5,260,885, US 5,039,928, US 5,477,239, US 5,300,874, US 4,563,727, and US 5,523,776 against live sources (Google Patents, FreePatentsOnline, EveryPatent, Justia, Espacenet, NREL/NIST listings). My verification search for US 4,686,441, US 4,782,617, US 4,083,097, US 5,529,943, US 5,532,524, and US 5,698,964 was truncated by a session step limit; for those six I rely on the patent's own (authoritative) citation table for the citation, dates, and titles, and I have deliberately limited my § 102 characterizations of them to what the titles and citation lineage support. I have said so explicitly rather than over-claiming.
  • Date convention. "Filed" and "published/issued" dates are taken from the citation table as rendered and cross-checked where verification succeeded. The US 5,039,928 and US 5,260,885 entries reflect foreign priority dates (JP 1988-12-09; CN 1991-08-31) distinct from their US filing dates (1989-12-11; 1992-06-04).
  • § 102(e) caveat. US 5,698,964 (issued 1997-12-16) is not § 102(a) or § 102(b) art against a 1997-09-12 filing; its only footing is § 102(e) as of its 1995-10-20 US filing date. Any anticipation theory resting on it must be built on that basis.
  • Standing caveat from prior sections. The patent expired 2017-09-12 and I found no PTAB proceedings and no litigation involving it. This prior-art map is therefore a validity/hindsight exercise, not a live-controversy analysis; it does not disturb the earlier finding that the practical defense is expiration plus the § 286 six-year lookback, not § 102.
  • Contradiction carried forward. The "US 4,566,154" citation in the earlier PTAB section is not supported by the patent's citation list; the correct entry is US 4,563,727. I have not silently corrected the earlier section — I flag it here as a discrepancy for reconciliation.

Generated 9/30/2026, 9:44:45 PM

Obviousness

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

✓ Generated

I'll verify the prior-art references on the face of the patent before building the §103 combinations, since a couple of the previously generated sections list reference numbers that conflict with the authoritative record.

Strong material. Let me pull the remaining cited references and check for closely-related non-cited art.

Obviousness Analysis — U.S. Patent No. 5,936,380 under 35 U.S.C. § 103

Patent: US 5,936,380 A, "Alternative power for a portable computer via solar cells" · App. 08/929,356 · Filed/priority 1997-09-12 · Granted 1999-08-10 · Expired 2017-09-12 · Inventor Sean T. Parrish · Original assignee Micron Electronics, Inc.
Claims analyzed: 1–16 (independent 1, 5, 12)


0. Threshold caveats and contradictions to resolve first

0.1 Governing law. Because application 08/929,356 was filed 1997-09-12, the pre-AIA version of § 103 applies (AIA § 3(n)(1) reaches only applications filed on or after 2013-03-16). So the analysis is pre-AIA § 103(a), with prior-art status measured under pre-AIA § 102(a)/(b)/(e). KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), supplies the motivation-to-combine framework that courts apply to pre-AIA patents today, and Graham v. John Deere Co., 383 U.S. 1 (1966), supplies the four-factor structure.

0.2 Contradictions between the previously generated sections and the authoritative record — flagged per instructions, not silently corrected:

Issue Previously generated text says Authoritative patent record (Google Patents, supplied) says Resolution
Solar-computer reference number PTAB section: "US 5,262,885 (solar power operated computer)" Citation list: US 5,260,885 A — "Solar power operated computer," inventor Ma (Hsi-Kuang), issued 1993-11-09 The record controls: US 5,260,885. I verified independently that 5,260,885 is the Ma patent (Google Patents, EveryPatent). The "5,262,885" string appears to be a digit transposition and should not be carried into any chart.
Self-charging solar battery reference PTAB section: "US 4,566,154 (self-charging solar battery)" Citation list: US 4,563,727 — "Self-charging solar battery," inventor Curiel The record controls: US 4,563,727. I verified 4,563,727's title and content (Google Patents). US 4,566,154 does not appear anywhere in the record and I could not tie it to any relevant reference — treat it as unverified and do not cite it.
Photoelectric charger reference PTAB section: "US 4,686,441 (photoelectric charger for low power devices)" Record: US 4,686,441, Tor Petterson Consistent. Verified content (Google Patents).
Current assignee Summary: "Mei California Inc"; Litigation section: "Micron Technology, Inc. (via security-interest releases)" Google Patents "Current Assignee" field: Mei California Inc, with an express disclaimer that the list may be inaccurate Both strings appear in the record at different points. This is a record ambiguity, not something I can resolve. It is immaterial to § 103 but note it if a chart is made for a real matter.
Dates Task header: "Current Date: April 26, 2026"; system context and prior sections: 2026-09-30 — Internal inconsistency in the inputs. Nothing in my § 103 analysis turns on it. Flagging it rather than picking one.

0.3 No court or Board has construed these claims. The prior sections establish zero district-court litigation and zero AIA trials. That means every claim-construction statement below is my preliminary reading under the broadest reasonable interpretation (BRI), not an adopted construction. In a real invalidity contention you would use Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc) in litigation.


1. Level of ordinary skill in the art (my construction)

No record establishes this, so I state it as an assumption consistent with the field in 1997: a person having ordinary skill would hold a B.S. in electrical or mechanical engineering (or equivalent), with roughly 2–4 years of experience in portable-computer power systems and/or LCD backlight/display module design, or equivalent industry experience. This level matters because the entire invention is an architectural placement decision in a domain (battery-powered LCD portables) that was already mature and crowded with art in 1997 — a fact the examiner's 11-reference citation list corroborates on its face.


2. What each reference teaches, mapped to claim elements

Only references I could verify from live sources are given full treatment; the rest are noted as record-only.

Ref Verified? Core teaching relevant to '380 '380 elements it reaches
US 5,260,885 (Ma, "Solar power operated computer," 1993-11-09) ✅ GP / Searchlight Solar cell assemblies hinged to the upper casing and base of a notebook-type computer, "collect the radiant energy of sunlight and convert it into electric power for charging respective storage batteries"; the background states the very problem '380 recites — a storage battery "can only provide a notebook computer with the required working voltage for a limited length of time, and must be recharged when discharged" Claim 2 (energy to rechargeable battery); the general portable-computer + PV + battery architecture underpinning claims 1, 5
US 5,039,928 (Nishi et al., Semiconductor Energy Lab, "Accumulator for portable computers," 1991-08-13) ✅ GP/PDF / EveryPatent Detachable solar-cell accumulator for a lap-top computer / word processor; solar cell = amorphous semiconductor film conversion devices; nickel-cadmium secondary cell; charge control circuit with reverse-current blocking diode and overvoltage cut-off; the accumulator "is integrally mounted on the electric appliance when the appliance is desired to operate" Claims 1, 2, 5 (photocell→charge regulation→battery in a portable computer); claim 10 context (amorphous cell array)
US 5,477,239 (Dell, "Front lighting system for liquid crystal display," 1993-11-12) ✅ GP Portable computer LCD lighting; expressly states "relatively large amounts of light are required to light the display due to the extremely low percentage of light transmission"; "monochrome LCDs are only approximately ten percent transmissive" and color LCDs ~5% or less; "backlit LCDs … are very inefficient in their use of power to provide an acceptable display"; teaches managing light with reflective layers, peripheral light sources, and a housing around the light source Directly supplies the motivation for claims 1, 5, 12; supplies the "display assembly with a light source and a housing" structure of claims 12–16
US 4,563,727 (Curiel, "Self-charging solar battery," 1986-01-07) ✅ GP Photovoltaic panel mounted inside a cylindrical transparent housing, juxtaposed to a cylindrical rechargeable cell, "such that solar rays may pass through … and excite said photo-voltaic cell means"; transparent-housing packaging Claim 6/13 ("wrapping solar cells around at least a portion"), claim 10/14 (surface "immediately adjacent")
US 4,686,441 (Petterson, "Photo electric charger device for low power electrical device," 1987-08-11) ✅ GP Solar-electric panel charging batteries where "the energy for such charging [is] provided by natural or artificial light"; expressly describes an embodiment "mounted for using interior light as its energy source" Critical admission-grade art. Directly supports using a non-solar, internal light source to excite photocells — the bridge that makes claim 1's "light source within the portable computer" obvious
US 5,523,776 (Hougham & Viehbeck, IBM, "Photovoltaic array for computer display," 1996-06-04) ✅ EveryPatent — NOT cited of record Display panel with a solar panel mounted behind the flat screen to receive light transmitted through the pixels and convert the transmitted light energy into electric energy; energy supplied via a control unit "to the battery pack 19 or to the display screen 16 or both"; expressly frames the problem as "a need for alternative sources of energy to supplement battery power" in portable computers; states that in an LCD the panel "necessarily competes with the reflected light required for image definition … [which] will erode the performance of the display" Claims 11 and 16 (cells on the side of the display opposite the light source); claims 3 and 4 (energy to a particular component / to the display screen); claim 12 architecture (screen + lightpipe-side panel + power supply)
JP 4-362917 (described within '776) ⚠️ second-hand only "an LCD display in which the solar panel is mounted behind the display to collect ambient light transmitted through the display" Claims 11, 16 — potentially § 102(b) art (published 1992)
US 5,532,524 (Apple) — incorporated by reference into '380 Record-only in this session Distributed power regulation in a portable computer optimizing heat dissipation and maximizing battery run-time Claims 3, 4 (supplying a specific component)
US 5,698,964 (Dell, 1995-10-20 filing / 1997-12-16 issue) Record-only Adaptive battery charging apparatus Claim 2 charging context; § 102(e) art (filed before '380's invention)
US 5,300,874 (Toshiba), US 5,529,943 (Spencer), US 4,083,097, US 4,782,617 (Peikin, water temperature measurement) Record-only Intelligent power supply for portable computer; portable power supply; encapsulated solar cell modules; and an apparent stray citation Peripheral. US 4,782,617's relevance to these claims is not apparent to me from its title — I flag this as an unexplained citation rather than invent a rationale for it.

Two points worth pausing on. First, '380's specification contains the near-verbatim transmissivity figures of '477,239 ("monochrome LCD, approx. 12% transmissive; color LCD, approx. 2% transmissive" versus '239's "approximately ten percent" and "five percent or less"). That is not a § 103 conclusion by itself, but it tells you the '380 drafter was working directly from the cited art when writing the problem statement — which undercuts any later argument that the problem solved was unrecognized in the art. Second, US 5,523,776 was not cited of record but is squarely on point, and it is § 102(e) art. If this patent were ever re-examined or litigated, '776 would be the first reference I would add. It is not commonly owned, so pre-AIA § 103(c) does not disqualify it.


3. Claim-by-claim obviousness combinations

Below, "primary" = teaches the bulk of the elements; "secondary" = supplies the missing element with a stated motivation. Each combination is stated with the KSR-style rationale that supports it.

Group I — Claims 1–4 (generic light → electricity in a portable computer)

Claim 1: "illuminating a light source within the portable computer; and converting energy from the light source into electrical energy."

This is the broadest claim in the patent and has no structural limitation, no recitation of solar cells, and no limitation on disposal of the energy (see prior summary). It is, in substance, a claim to putting a photocell next to an internal lamp.

  • Combination 1-A (strongest): US 5,477,239 + US 5,039,928 (or US 5,260,885).
    '239 supplies the "light source within the portable computer" — a portable computer's LCD illumination system, including a light source at the display periphery and a housing therefor. '039,928 (or '260,885) supplies "converting energy from the light source into electrical energy" — a photovoltaic cell feeding a charge-control circuit and secondary cell in a laptop computer. The only difference from claim 1 is that the art's photocell is excited by sunlight and claim 1's by an internal lamp. Motivation: '039,928's own stated object is to "supply enough energy" to a portable appliance whose dry cells may leave the user "run out of energy on the way"; '239 states that backlit LCDs "are very inefficient in their use of power." Combining an alternative energy harvester with a light source that is admittedly wasteful is the paradigm of a predictable variation of a known device to improve it in the same way (KSR). Substitute-art support: US 4,686,441 expressly teaches charging from "artificial light" and even an "interior light" embodiment, so swapping the excitation source from sun to lamp is not merely obvious, it is taught.

  • Combination 1-B (single-reference-ish, § 102(e) art): US 5,523,776. '776 discloses a computer display in which a photovoltaic cell converts transmitted light into electric energy that is routed to a battery pack or the display screen. It fails literal anticipation of claim 1 only because the light in '776's disclosed embodiments is transmitted ambient/image light rather than emission from the computer's own lamp — but '776's own background describes the LCD case where the light "is generated by a lamp behind the cell," which supplies the last increment.

Claim 2: "providing the electrical energy to a rechargeable battery within the portable computer."

  • US 5,260,885 alone discloses solar cells charging the notebook's storage battery. US 5,039,928 discloses the same with charge regulation. US 5,523,776 routes the panel output "to the battery pack 19." Motivation is the entire premise of all three. § 103 is close to a formality here; § 102 is arguable against '260,885 if the "light source" element is read to include ambient light, but I would not lead with that.

Claim 3: "providing the electrical energy to a particular component within the portable computer."

  • US 5,523,776 + US 5,532,524. '776 discloses plural destinations ("the battery pack 19 or the display screen 16 or both"), which is the claimed "particular component." '524 (already incorporated by reference into '380's own specification) supplies distributed/regulated supply to individual components. Motivation: the '380 specification's own FIG. 3 rationale — easing the load of a specific component on the battery.

Claim 4: "providing the electrical energy to the display screen."

  • US 5,523,776 discloses supplying the photovoltaic output to the display screen. This is the closest thing in the corpus to a direct reading on a dependent claim of '380, and '776 is not even of record.

Group II — Claims 5–11 (placing solar cells to capture internal light)

Claim 5: placing solar cells within the portable computer "to capture light from the light source"; illuminating; converting.

  • Combination 5-A: US 5,477,239 + US 5,523,776 (or US 5,260,885) [+ US 4,686,441].
    '239: the internal light source and the admission that most of its light is lost to absorption, imperfect aperture coupling, and imperfect reflectors — the identical loss taxonomy '380 recites (coupling at the aperture; imperfect reflective layer; no reflector at all in some designs). '776: a photovoltaic cell inside the display assembly converting internal light to electricity for the computer's power supply. '441: charging from artificial/interior light. Motivation: (i) the problem of extending battery run-time was known and expressly articulated by '260,885 and '776; (ii) the waste of backlight energy was known and quantified by '239; (iii) reuse of otherwise-wasted internal light is a known technique applied to a known structure ready for improvement, producing no more than predictable results (KSR). There is also a straightforward "would-be obvious to try" rationale: the only illuminated, otherwise-wasted region inside a laptop was the backlight cavity, and photovoltaic conversion of that light is a finite, identified, predictable approach.

Claim 6 — "wrapping solar cells around at least a portion of the light source."

  • US 4,563,727 (Curiel) + US 5,477,239. Curiel discloses a photovoltaic panel mounted inside and juxtaposed to a cylindrical transparent housing surrounding a cylindrical rechargeable cell — i.e., a curved solar array conformed to a cylindrical body. '239 discloses the LCD periphery light source with reflective side walls that "surround the display … to support the light source." Applying Curiel's curved-array-around-a-cylinder geometry to '239's cylindrical lamp is the use of a known technique (conforming a PV array to a cylinder) to improve a similar device in the same way. Note that '380's own specification concedes the wrapped configuration "can be difficult or expensive to manufacture or assemble" — an admission of a known trade-off, which is evidence for obviousness, not against it.

Claim 7 — "on the sides of the light source." Same combination; the sides are simply where the escaping light is not the aperture. Alternatively, US 5,477,239's two-light-source housing with reflective side walls directly suggests side placement.

Claim 8 — "on one side of the light source." A single planar array on one side. In re Kuhle, 526 F.2d 553 (CCPA 1975), and In re Harza, 274 F.2d 669 (CCPA 1960) (location/placement changes are obvious absent a new and unexpected result). The specification itself offers this as one of several "more commonly available planar arrays" — an admission that the alternative is ordinary design choice.

Claim 9 — solar cells "on the side of the light source opposite of the aperture." This is a near-necessity: the aperture faces the lightpipe (claim 9 itself says so), so any opaque photocell must go elsewhere. US 5,523,776 places its photovoltaic panel behind/opposite the illuminated surface. Obvious as a matter of geometry.

Claim 10 — "on a surface that is immediately adjacent the light source."

  • US 4,563,727 (panel "juxtapositioned to said transparent material … adjacent"). US 5,039,928 (amorphous cell array directly on a flat board).
  • Cautionary counter-note: '380's specification states that closely-adjacent placement "can be made effective," i.e., it improves coupling. That is a result that is expected from proximity in radiative harvesting (inverse-square), so it is a predictable, not an unexpected, result.

Claim 11 — "placing solar cells on a side of the display screen opposite to that of the light source." ⭐ The single strongest § 103 (and arguable § 102(b)) attack in the record plus the near-record art.

  • US 5,523,776 — solar panel mounted behind the flat screen to receive and convert transmitted light, energy routed to the battery pack or the display. JP 4-362917 — "solar panel … mounted behind the display to collect ambient light transmitted through the display." Both place a photovoltaic array on the far side of the light-modulating display element. Motivation is explicit in '776's background: "a need for alternative sources of energy to supplement battery power" for portable computers driven by battery operation.
  • Scope caveat I must state honestly: the FIG. 8 embodiment's geometry is genuinely ambiguous. The spec says the lightpipe "is immediately adjacent to the back surface 121 of the LCD panel 120," yet FIG. 8 places cells 142 "on the side of the display screen opposite the lightpipe" and describes capturing "light that reaches the opposite side." Read one way, cells 142 sit in front of the image-forming panel (which would be optically nonsensical); read the other way, they sit on the far side of the lightpipe from the LCD, capturing back-escape. This ambiguity is a § 112(b) exposure independent of § 103, and it also makes any element-by-element chart for claims 11/16 unreliable until the term is construed. If the "far side of the lightpipe" reading is adopted, the closest art shifts from '776 to ordinary edge-lit backlight leakage-capture; if the "front of the panel" reading is adopted, the claim is very probably inoperable/unsupported, which strengthens an enablement attack. Either way, I would not assert claim 11/16 invalidity without first forcing this construction.

Group III — Claims 12–16 (method of constructing the display panel assembly)

Claim 12: position a display screen over a lightpipe; position a light source adjacent the lightpipe; dispose solar cells in the display panel assembly so they may receive the light; house all three.

  • Combination 12-A: US 5,477,239 + US 5,523,776, with US 5,050,946 supplying the lightpipe (and it is '380's own incorporated-by-reference admitted art).
    Every structural element is disclosed in the art: '239 (housing with light source, portable-computer display, transparent/reflective layers); '776 (screen with a photovoltaic panel disposed in the display assembly and a power supply to the battery/display); '946 (light source delivering light to a lightpipe — admitted prior art in '380's own specification and incorporated by reference).
    Motivation: the assembly problem is a pure packaging/engineering problem — where to fit a thin photovoltaic array inside an already thin, space-constrained display module. Because '776 teaches mounting the panel behind the screen and '239 teaches the front-lit/flat-panel module, the integration is a combination of prior art elements according to known methods to yield predictable results (KSR). There is no teaching away, and the '380 specification offers no unexpected result.
  • Legal note on method claims drawn from apparatus disclosures: that '239 and '776 are apparatus patents does not defeat the § 103 attack on claim 12. In re Epstein, 32 F.3d 1559 (Fed. Cir. 1994), holds that a prior-art apparatus disclosure may render a method claim obvious where the method is an inherent or obvious way of making or using the apparatus. Assembling the '776 display (screen + panel + power supply) and the '239 module (light source + housing) in the natural order is exactly that.

Claims 13–16 mirror claims 6–11 and carry the same combinations and the same rationales:

  • 13 (surround at least a portion of the light source) ← Curiel '727 + '239, as in claim 6.
  • 14 (adjacent and on one side) ← '727 / '039,928 flat-board array, as in claim 8; Kuhle/Harza placement doctrine.
  • 15 (two panels on opposite sides) ← '239's two-light-source housing plus the ordinary symmetry design choice; also '039,928's paired housings "projected upwards from the opposed edges." This is very close to direct reading.
  • 16 (cells on the side of the screen opposite the light source) ← '776 / JP 4-362917, as in claim 11, with the same construction caveat.

4. Motivation-to-combine catalog (each grounded in a specific reference or admission)

I would plead these in this order, because each is supported by the art itself rather than by hindsight:

  1. The known problem of finite portable-computer battery life. US 5,260,885 (background) and US 5,523,776 (background) both recite it verbatim in substance; US 5,039,928 does too. Motivates all of claims 1–16.
  2. The known and quantified waste of LCD backlight energy. US 5,477,239 (transmissivity percentages; "very inefficient in their use of power"). Motivates claims 1, 5, 12.
  3. The known desirability of using artificial and interior light, not just sunlight, to excite photocells. US 4,686,441 ("natural or artificial light"; interior-light embodiment). Motivates claims 1 and 5 — and is the single most damaging point against any argument that "converting light from the internal backlight" was non-obvious.
  4. The known technique of mounting a photovoltaic array inside a display assembly. US 5,523,776; JP 4-362917. Motivates claims 11, 12, 16.
  5. The known technique of conforming a photovoltaic array to a cylindrical body. US 4,563,727. Motivates claims 6, 10, 13, 14.
  6. Design-incentive / finite-solutions reasoning (KSR). Inside a backlight cavity there are a finite, identified, predictable set of places to put an opaque photocell: wrapped around the lamp, on the sides, opposite the aperture, or beyond the display element. Every dependent claim in Groups II and III is one of those positions. This is the textbook KSR "finite number of identified, predictable solutions" scenario.
  7. '380's own specification as evidence against it. The specification (a) states "solar" cells mean "any photoelectric device that converts light into electricity, regardless of whether the light comes from the sun or from a lamp or other artificial source"; (b) frames claims 6/13's wrapped configuration as "difficult or expensive to manufacture or assemble"; (c) calls the AC-component (backlight inverter) embodiment "not as efficient" because of conversion losses; and (d) states that reflecting escaped light back into the lightpipe "may not be uniform, thereby compromising display quality." Each of (a)–(d) is a known-trade-off admission. Under In re Boesch/In re Geisler-style reasoning, an applicant who characterizes his alternatives as known trade-offs supplies the motivation to select among them.

5. Anticipation-adjacent findings (worth pleading as § 102 where possible, because § 102 is cleaner than § 103)

  • US 5,260,885 vs claims 2 and 5 (partially). '260,885 claims "a solar power operated computer … wherein said upper casing has a first solar cell assembly hinged thereto and electrically connected to a storage battery therein." That directly reads on claim 2's "providing the electrical energy to a rechargeable battery within the portable computer" if claim 2 is taken at its own breadth — but claim 2 depends from claim 1, which requires an internal light source. The dependency is the only thing saving '380 from anticipation by '260,885. Expect a plaintiff to argue the internal light source is met by the notebook's backlight; expect a defendant to argue '260,885's cell is excited by sunlight through a transparent protective layer, not by a lamp. This is the crux of the § 102/§ 103 boundary for claims 1–5.
  • US 5,523,776 vs claims 4, 11, 16. If claim 11's "side of the display screen opposite to that of the light source" is construed as "the far side of the image-forming element from the light source," '776's "solar panel mounted behind the flat screen" is very close to a direct reading, and '776's express routing of power "to the display screen 16" reads on claim 4.
  • JP 4-362917 vs claims 11 and 16 (§ 102(b); published 1992, more than one year before 1997-09-12). I could not verify this reference in the original — my knowledge of it comes only from '776's description. Before relying on it, obtain the Japanese publication and a certified translation.
  • Obviousness-type double patenting — flag, not a § 103 holding. If sibling application 08/928,888 issued as US 6,300,944 or US 6,445,376, there is a potential ODP question if the claims overlap in scope without a terminal disclaimer. The prior summary correctly flags that the 08/928,888→patent mapping is unverified. Do not assert ODP until the '944/'376 claim sets and their priority chains are pulled.

6. Teach-away and secondary considerations — the honest counter-case

A defendant preparing to assert '380's invalidity, or a patentee defending it, must confront these. I state them as the strongest available rebuttals, not as winners.

6.1 Teach-away (weak-to-moderate). US 5,523,776 states that with an LCD, the solar panel "necessarily competes with the reflected light required for image definition … This will erode the performance of the display." That is a caution against putting a photovoltaic panel in the display's optical path. But it is not a teaching away from the claims: '776's caution concerns a panel receiving image-bearing light, whereas claims 5–10 are directed to capturing escaped/wasted light near the light source that never reaches the image. In re Fulton, 391 F.3d 1195 (Fed. Cir. 2004), requires that a reference "criticize, discredit, or otherwise discourage" the claimed solution; '776 discourages a different arrangement. I would rate this not a winning teach-away for claims 5–10, and only arguable for claim 11/16.

6.2 The specification's own FIG. 8 observation as a species of teach-away (weak). '380 states that reflecting escaped light back into the lightpipe "may not be uniform, thereby compromising display quality," and that "for this reason, this light is often wasted." A patentee could frame this as recognition of a problem others dismissed. Problem: there is no nexus to the claims as drafted. Claim 1 in particular recites nothing about uniformity or display quality; the point cannot be used to save an unsaved claim. Also, '776 says essentially the same thing, which neutralizes the "recognition" framing.

6.3 Secondary considerations (no evidence of record). There is no record — no litigation, no IPR, no reexamination — from which to draw nexus-backed evidence of unexpected results, long-felt need met, or industry praise. Nothing in the prosecution record (per the prior sections) shows the examiner overcame an obviousness rejection or that the applicant submitted Rule 132 evidence. Confidence: medium — I verified "no PTAB activity" and "no litigation found," but I cannot rule out that prosecution-history evidence exists in the file wrapper, which I have not reviewed. Pull the file wrapper (USPTO PatentCenter, app. 08/929,356) before finalizing any secondary-considerations position.

6.4 The strongest non-obviousness argument I can construct. It is this: the claims require the photocell to harvest light from the computer's own internal lamp, and the cited art (excepting '776's background discussion and '441's artificial-light teaching) uses ambient/solar light. A patentee would argue that the art taught looking outward (through the chassis or through the display), not inward, and that nothing suggested deliberately harvesting the internally generated light that the design was trying to deliver to the viewer. Why I rate it as unlikely to succeed: (a) '441 expressly reaches artificial and interior light; (b) '380's own specification states the term "solar cells" covers light "from a lamp or other artificial source" — an express disclaimer of the distinction the patentee would need; (c) '776 supplies the "inside the display assembly" location; and (d) KSR's "design incentive" prong supplies the reason to look where the wasted energy already is.


7. Where the § 103 case is weakest — and what to verify before relying on this

I would not present the following as settled:

  1. Claims 1 and 5's "light source within the portable computer" limitation is the only element not literally disclosed by the strongest single reference. Everything else in the analysis is downstream of that gap. Get the file wrapper to see how the examiner handled it — the 11-reference list suggests an obviousness rejection was made and overcome, and the reason matters enormously.
  2. Claim 11/16's geometry ambiguity (discussed § 3) prevents a reliable element-by-element chart.
  3. US 4,782,617 (Peikin, "Water temperature measurement apparatus") appears in the citation list but I cannot see its relevance to these claims from its title, and I did not verify it. Do not assign it a role.
  4. JP 4-362917 is known to me only through '776's characterization. Obtain and translate it.
  5. The 08/928,888 → '944/'376 mapping is unresolved (per the prior summary). Resolve it before pleading ODP or before treating the family as expired.
  6. My prior-art status conclusions for US 5,698,964 (§ 102(e) by 1995-10-20 filing) and US 5,523,776 (§ 102(e) by 1995-01-10 filing) assume the '380 applicant's invention date is on or after those filing dates. The '380 application was filed 1997-09-12 with no provisional of record; absent a sworn earlier invention date, that assumption is sound — but the file wrapper is the only way to confirm.
  7. The date conflict between the task header (2026-04-26) and the session/prior sections (2026-09-30) is unresolved. It does not affect the § 103 analysis but should be resolved in any document that states "as of" a date.

8. Bottom line

If I had to compress this into a contention set:

  • Primary combination that defeats the independent claims: US 5,477,239 + US 5,260,885 (or US 5,039,928) for claims 1–5, with US 4,686,441 supplying the express artificial/interior-light bridge; and US 5,477,239 + US 5,523,776 for claims 11–12 and 16. Add US 4,563,727 for the wrapping/adjacency dependents (6, 10, 13, 14) and US 5,532,524 for the component-supply dependents (3, 4).
  • Rationales to plead: (i) known problem — limited portable battery life (recited by two of the references themselves); (ii) known waste — quantified LCD backlight inefficiency ('239); (iii) known technique — photocells excited by artificial/interior light ('441) and mounted inside a display assembly ('776); (iv) finite, predictable placement options inside a backlight cavity (KSR); and (v) the '380 specification's own trade-off admissions.
  • Weakest link: the "internal light source" limitation of claims 1 and 5, and the unresolved FIG. 8 geometry of claims 11/16.
  • Add to any invalidity contention: US 5,523,776 — it is not of record, it is § 102(e) art, it is not commonly owned, and it is closer to claims 4, 11, 12, and 16 than anything the examiner cited.
  • Do not cite: "US 5,262,885" or "US 4,566,154." Those strings appear in the previously generated PTAB section and do not appear in the patent record; the correct references are US 5,260,885 and US 4,563,727.

Generated 9/30/2026, 9:45:25 PM

Extensions

Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.

Log in to generate
Not generated yet. Log in to request this analysis.

Derivative works

Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.

Log in to generate
Not generated yet. Log in to request this analysis.

Keep exploring

Other patents in Energy (E)

See all Energy (E) patents →