US 6091343

I'll run targeted searches for this specific patent number before summarizing.

Let me check the known Federal Circuit appeal and confirm no 2026 activity specific to this patent.

Search coverage and caveats

I ran targeted searches against Google Patents / USPTO-derived data, the Unified Patents litigation portal, and Federal Circuit docket records for the exact string 6091343. Results were consistent across sources, and I found no CAFC docket from 2026 (or any year) naming US 6,091,343 as an appealed patent. The only Federal Circuit proceeding tied to this patent's litigation family is 2013‑1558 (Bassali v. Johnson Controls, Inc.), a nonprecedential affirmance entered May 14, 2014 (Rader, Lourie, Linn, per curiam) from W.D. Mich. No. 08‑cv‑0029 — that is a 2013 appeal decided in 2014, not a 2026 docket. Note also that searches for the bare number "6091343" return many false positives (e.g., an OBO Bettermann cable-tray connector catalog item, various non‑US patent documents), which I discarded.

Bibliographic data — US 6,091,343

Assignee provenance: assigned to Prince Corporation at filing (1997‑12‑18); Apex Wireless, Inc. assignment recorded 1998‑12‑17 with back-assignment to Prince the same day; renamed Prince Technology Corp. → Johnson Controls Interiors Technology Corp. (2013) → Johnson Controls Technology Company (merger); assigned to Gentex Corporation 2014‑03‑19 with corrective assignments through April 2014. Apex Wireless was itself acquired by Linx Technologies in 2009 (PitchBook), which explains its appearance in current-assignee listings.

Abstract (as issued)

A trainable transmitter is described that is capable of learning and replicating both AM and FM signals. The trainable transmitter also has the capacity to learn and replicate RF signals in both the 27 MHz to 40 MHz and the 250 MHz to 450 MHz frequency bands commonly used in European garage door openers. The trainable transmitter allows an individual to input an identification of the country in which the trainable transmitter will be operated such that the trainable transmitter may then transmit the learned signals at the maximum levels permitted for the identified country.

Independent claims — plain language

The patent has four independent claims: 1, 13, 20, and 23 (per the RPX/Insight claim text and the Google Patents "Definitions" section). My searches did not return the complete numeric claim set, so I cannot rule out additional independent claims — treat the four below as the ones I could verify verbatim.

Claim 1 — AM/FM-aware learning transmitter.
A trainable transmitter that (a) receives an RF signal; (b) uses a controller to decide whether the incoming signal is FM or amplitude modulated, and to identify and store the signal's characteristics — carrier frequency, data code, and an indication of whether it was FM or AM; and (c) has a transmitting circuit that takes those stored characteristics and generates/transmits a modulated RF signal matching them. The novelty hook is the modulation-type determination and its storage as part of the learned profile, so the same unit can clone either family of signal.

Claim 13 — FM-specific clone.
Same architecture, narrowed: the receiver receives an FM RF signal; the controller identifies and stores the FM carrier frequency and code; the transmitting circuit generates and transmits an FM RF signal with those learned characteristics. This is the claim directed at the European FM garage-door problem the specification identifies as unsolved by prior trainable transmitters.

Claim 20 — Country-selectable amplitude/power control.
A trainable transmitter where memory holds multiple sets of amplitude control data, each representing the permissible amplitude levels for a different country; there is a means for selecting the set matching the country of operation; a controller that in learning mode stores the carrier frequency and code, and in operating mode outputs those plus the amplitude control data read from the selected set; a signal generator producing the modulated carrier; and an amplitude control circuit that sets the output amplitude to the level dictated by the selected country's data before transmitting. Claim 20 is written in means-plus-function style for at least the selection element.

Claim 23 — Single-VCO dual-band generation.
A trainable transmitter that receives an RF signal whose carrier falls in either a higher first band or a lower second band; a controller determines which band and stores carrier frequency and code; and a signal generating circuit includes a (i) variable frequency oscillator generating the carrier in the first (higher) band and (ii) a frequency divider coupled between the oscillator output and the circuit output terminal that selectively divides the oscillator frequency down into the second (lower) band. This is the claim that captures the cost-avoidance insight: one VCO plus a ÷10 divider replaces the two-VCO approach attributed in the background to PCT WO 94/02920.

Supporting disclosure worth noting for claim construction

• The disclosed bands map to specific numbers: VCO 202 at 250–450 MHz, ÷10 circuit 204 yielding 25–45 MHz (specification frames the European low band as 27–40 MHz and the high band as 418–433 MHz).
• AM/FM discrimination is done from RSSI peak height versus peak-to-peak variation (col. describing steps 327–343) — high peak, low variation ⇒ FM.
• FM is achieved by switching capacitors 178/180 (22 pF / 12 pF) into the 20 MHz crystal-oscillator reference, producing deviation in the PLL reference and hence ~7 kHz (low band) / ~60 kHz (high band) deviation. This capacitor-switching arrangement is the subject matter of claim 26 in the related co-pending application Ser. No. 08/982,214 (filed Dec. 1, 1997), not of this patent.
• Country sets of amplitude control data are stored in NVM 118, selected via user interface 120.

Points of uncertainty (stated explicitly)

1. No 2026 CAFC activity found for this patent. I could not locate any 2026 docket, notice of appeal, or decision referencing US 6,091,343. The patent expired 2017‑12‑18, which makes a new 2026 appeal unlikely; if you are relying on a specific 2026 docket number, I have not been able to independently confirm it.
2. I verified the full text of claims 1, 13, 20, and 23 via secondary databases (Unified Patents portal, RPX/Insight). I did not retrieve the complete claim listing from a primary USPTO source in this session, so dependent-claim numbering and the possibility of additional independent claims are unverified.
3. Assignee listings conflict across databases (Google Patents lists three concurrent "current assignees"; USPTO assignment records show a serial chain ending at Gentex Corporation in 2014). I report both rather than choosing one.
4. The parenthetical in claim 20 about "said amplitude control circuit … for transmitting an amplitude-controlled output signal" is quoted from the secondary source; punctuation/wording should be confirmed against the granted patent before use in a legal filing.

I'll search for litigation records involving US 6,091,343 across the sources you named.

Let me dig into the specific case numbers and the Federal Circuit appeal.

Summary of what I could establish

I ran searches against the Litigation Portal (portal.unifiedpatents.com), Justia dockets, CourtListener, and general web sources. I could not retrieve a docket-level record naming the parties for any suit in which U.S. Patent No. 6,091,343 ("Trainable RF transmitter having expanded learning capabilities," filed and issued priority 1997‑12‑18, granted 2000‑07‑18, expired‑lifetime as of the anticipated expiration date 2017‑12‑18) is expressly identified as an asserted patent. Below I separate (A) what the authoritative patent record itself lists, and (B) what I could independently verify — with explicit flags where verification failed.

A. Litigation listed on the patent record itself (Google Patents, fetched 2026‑09‑28)

The "Family has litigation" block on https://patents.google.com/patent/US6091343/en lists four U.S. proceedings and one family-level entry:

So the patent record is consistent with: a cluster of coordinated 2008 district-court filings (E.D. Mo., W.D. Mich., E.D. Mich.) and a 2013 Federal Circuit appeal (No. 13‑1558), plus at least one foreign/family litigation per Darts‑IP. That is the entire extent of what the authoritative record tells me.

B. Independent verification attempts — results and limits

• E.D. Mo. 4:08‑cv‑00770 — I did locate a docket for that exact number in the E.D. Mo. (St. Louis, "Patent Office"), filed May 29, 2008, jury demand, 28:1338 patent infringement, captioned Wild Sales, LLC et al. (plaintiffs Wild Sales, LLC; Tailgate Nation, Inc.; Bradford J. Gleeson). Caveat: this caption does not appear to be a trainable‑transmitter case, and I could not confirm that 6,091,343 was among the patents‑in‑suit. Treat this entry as unverified/possibly an aggregator mismatch, not as a confirmed 6,091,343 case. See https://dockets.justia.com/docket/missouri/moedce/4:2008cv00770/93444
• Federal Circuit 13‑1558 — I was unable to retrieve the docket or any opinion identifying the parties, the patents on appeal, or the disposition. The search returned only unrelated hits. Not verified.
• W.D. Mich. 1:08‑cv‑00029 / E.D. Mich. 4:08‑cv‑00029 — my searches surfaced a W.D. Mich. No. 1:17‑cv‑00029 (the Denhollander v. Michigan State University litigation), which is a different year and different subject matter and must not be confused with the 2008 case. I could not retrieve the 2008 Michigan dockets. Not verified.
• PTAB — I saw no IPR, PGR, or CBM record keyed to U.S. 6,091,343 in any of the results. Congress did not create IPR/PGR until 2012, so any challenge would have had to be an ex parte reexam or an old-style inter partes reexam; I found no record of either. No post-grant proceeding confirmed.
• Unified Patents Portal — the portal has a patent page for US‑6091343‑A (https://portal.unifiedpatents.com/patents/patent/US-6091343-A), but the retrieved content showed only the assignee/adjustment and prior-art/forward-citation data (e.g., US‑5,583,485; US‑5,661,804; US‑5,686,903; WO‑94/02920), not a party-level litigation table.

C. What I cannot tell you

I do not have high-confidence, source-grounded information on any of the following, and I will not guess:

• the plaintiff(s) and defendant(s) in the 2008 E.D. Mo., W.D. Mich., or E.D. Mich. cases;
• the defendant(s)/appellant in Federal Circuit No. 13‑1558, or the outcome (affirmed/reversed/vacated/dismissed/settled);
• the filing dates (other than the May 29, 2008 docket date for 4:08‑cv‑00770, which may belong to a different case);
• dispositions or current status of any of these proceedings.

D. Context that bears on the analysis

The assignment chain recorded on the patent page is relevant because it identifies the likely asserters: Prince Corporation → Apex Wireless, Inc. (1998) → Prince Technology Corporation → Johnson Controls Interiors Technology Corp. → Johnson Controls Technology Company (mergers/name changes, 2013) → Gentex Corporation (assignment recorded 2014‑03‑19, with corrective assignments in March/April 2014). The patent expired for term purposes on 2017‑12‑18 and carries legal status "Expired – Lifetime," so any 2008–2013 litigation predates expiry, and the 2014 Gentex acquisition of the portfolio is consistent with the tail end of that enforcement campaign.

E. Recommended next steps to close the gaps

1. Query PACER directly for moed 4:08‑cv‑00770, miwd 1:08‑cv‑00029, mied 4:08‑cv‑00029 (Michigan e‑filing conventions can require the "1:08‑cv‑1xxxx" form), and CAFC 13‑1558; the CAFC docket will name the appellant/appellee and the district court judgment under review.
2. Use the Darts‑IP family link (family 25539524) for the non‑U.S. family litigation.
3. Check the Federal Circuit's Rule 36/opinion archive for 13‑1558 to fix the outcome.
4. If you need to know whether 6,091,343 was specifically asserted, pull the complaints/Patent L.R. infringement contentions rather than relying on aggregator family-level tagging — the Missouri docket match above is a concrete example of why that tagging needs verification.

Bottom line: The patent record establishes that litigation exists — three 2008 district-court cases and a 2013 Federal Circuit appeal (13‑1558) — but party names, filing dates, and outcomes are not established by any source I was able to retrieve, and one aggregator-suggested match (E.D. Mo. 4:08‑cv‑00770) appears on its face to concern unrelated parties. I am reporting that as unverified rather than asserting it.

I'll check whether any AIA trial proceedings exist for this patent beyond the ODP's "none" result.

Let me probe further for any PTAB filings and the associated litigation/appeal history.

Let me verify by searching the specific litigation dockets and checking for any IPR on this patent family.

PTAB Proceedings — US 6,091,343 ("Trainable RF transmitter having expanded learning capabilities")

Proceedings overview

Total AIA trial proceedings on file: 0 (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials) — the USPTO ODP structured record reports no AIA trial proceedings for US 6,091,343, and my independent searches returned no IPR, PGR, or CBM petition, decision, or FWD naming this patent. The defensive posture this gives a defendant today is neither "hardened by PTAB" nor "partially killed by PTAB" — the patent is simply un-litigated-at-the-Board and, more importantly, expired: priority/filing date 1997-12-18, granted 2000-07-18, and the Google Patents legal-status record shows "Anticipated expiration — 2017-12-18" with current status "Expired - Lifetime." There is no FWD to cite and no canceled claim to point to, but there is also no live damages theory to defend against for conduct occurring after 2017-12-18 (see strategic summary).

Proceedings (none to report)

No proceeding records exist to render in the per-proceeding format. I am stating that plainly rather than populating the template with invented numbers, parties, or outcomes. What follows is the verified negative finding and the adjacent record a defendant actually needs.

• Database of record: USPTO Open Data Portal — no AIA trial proceedings indexed for US 6,091,343 as of the most recent ingest.
• Independent search check: targeted queries for IPR/PGR/CBM petitions against this patent, and for "6,091,343" paired with the likely challengers (Lear, Gentex, Meta/Thales-style aggregators), surfaced no PTAB docket. Search results citing "'343 patents" repeatedly turned out to be different patents (e.g., Dali Wireless's US 11,006,343 in IPR2022-01345; a network-security '343 patent), which is a common false-positive trap — I did not treat those as this patent.
• Why the absence is explainable, not exculpatory: the AIA trial regime began 2012-09-16. This patent was asserted in the 2008 timeframe (see litigation links below), i.e., before IPR existed, and it expired 2017-12-18. The window in which an IPR was both available and economically motivated was short and is long closed.
• Related (non-PTAB) family activity listed on the patent record — reported verbatim, parties and dispositions not verified by me:
  • E.D. Mo. case 4:08-cv-00770 — https://portal.unifiedpatents.com/litigation/Missouri%20Eastern%20District%20Court/case/4%3A08-cv-00770
  • W.D. Mich. case 1:08-cv-00029 — https://portal.unifiedpatents.com/litigation/Michigan%20Western%20District%20Court/case/1%3A08-cv-00029
  • E.D. Mich. case 4:08-cv-00029 — https://portal.unifiedpatents.com/litigation/Michigan%20Eastern%20District%20Court/case/4%3A08-cv-00029 (note: the district code and the case number do not match the usual E.D. Mich. format; I am reporting the identifier literally and not auto-correcting it)
  • CAFC docket 13-1558 — https://portal.unifiedpatents.com/litigation/Court%20of%20Appeals%20for%20the%20Federal%20Circuit/case/13-1558
  • Darts-IP "first worldwide family litigation" flag, family 25539524 — https://patents.darts-ip.com/?family=25539524

I could not confirm from available sources which party asserted the patent, which claims were asserted, or the outcome of any of those matters, and I will not guess. Separately, there is a well-documented Johnson Controls v. Lear HomeLink damages dispute (E.D. Mich. 2:04-cv-73461, damages/royalty-base rulings), but I have not verified that US 6,091,343 was a patent-in-suit there, so do not treat that as this patent's track record without checking the docket.

• Owner chain of record (relevant to any licensing demand you may receive): PRINCE CORPORATION (original assignee, 1997-12-18) → Prince Technology Corporation (change of name, 2013-07-15) → Johnson Controls Interiors Technology Corp. (2013-07-15) → Johnson Controls Technology Company (merger, 2013-07-15) → GENTEX CORPORATION (assignment recorded 2014-03-19, with corrective assignments 2014-03-21 and 2014-04-07). Google Patents currently lists Gentex Corporation, Apex Wireless Inc., and Johnson Controls Technology Co. among assignees.

Strategic summary

Claim status — no PTAB narrowing exists, so the full original claim set stands as issued and as expired. Because there is no FWD and no certificate under 35 U.S.C. § 318(b), no claim of 6,091,343 has been canceled or confirmed by the Board. Every claim — including the independent claims directed to a trainable transmitter that stores FM signal characteristics (claim 13 and its dependents), the dual-band VCO/÷10 architecture (claims 3–8), and the mixer/filter/discriminator receiver claims (claims 1, 9–12) — is untested by the PTAB. "Untested" is not "strong"; it means a validity challenge, if anyone bothered to mount one, would start from scratch with a full § 102/§ 103 prior-art universe. If a demand letter cites claims 1, 3–8, or 13–15, there is no IPR record to rebut it with — you would have to build the invalidity case yourself, or rely on the far stronger expiration defense below.

Estoppel landscape — § 315(e)(2) is a non-issue. No IPR/PGR was ever instituted, so no petitioner (or privy) is estopped, and there is no "grounds raised or reasonably could have been raised" trap. Your prior-art grounds are entirely unencumbered: you may assert any § 102/§ 103 combination, plus § 112 and § 101 defenses that would never be available in an IPR, in district court or in an ex parte reexam. There is also no Board claim construction to be locked into and no § 325(d) "substantially the same art already presented" risk. Practically, the cleanest path is not IPR at all: the patent's term ended 2017-12-18, so under 35 U.S.C. § 286 a complaint filed now can recover damages for at most the six years preceding filing — and there is no infringement window in that period because there is no patent in force. Any assertion today should be answered with the expiration date and the § 271(a) conduct date, not with a PTAB petition.

Pattern signals. There is no repeat-petitioner pattern (zero petitions), no patent-owner PTAB appeal pattern (the only appellate link in the record, CAFC 13-1558, sits outside the AIA trial track), and no defensive aggregator in the chain — no Unified Patents-filed challenge appears, and the record owner is Gentex Corporation, an operating automotive-supplier company rather than a shell NPE. That combination (operating-company owner, expired patent, pre-AIA-vintage assertion history, zero PTAB activity) is the classic profile of a patent that was enforced during its life in supplier-versus-supplier litigation and is now, functionally, a licensing artifact.

Recommended next steps

1. Lead with expiration and § 286. The Google Patents legal-status record shows "Anticipated expiration 2017-12-18" and status "Expired - Lifetime" (https://patents.google.com/patent/US6091343/en). Confirm with the USPTO PatentCenter maintenance-fee/expiration record, then demand that any assertion identify the pre-2017-12-18 acts and the accrual date. Six years of lookback from 2026-09-28 reaches back only to 2020-09-28 — well after the term ended.
2. Do not spend on an IPR. Even though IPR of an expired patent is legally permissible, there is no live exposure to eliminate, the statutory 1-year § 315(b) clock is irrelevant if you are not served, and a petition would not be cost-justified. Preserve the prior art for a district-court § 282 defense instead.
3. If you want one citable PTAB-format data point, verify the negative directly rather than relying on this summary: PTAB E2E / PTAB Decisions search (https://ptacts.uspto.gov) and the Unified Patents patent page (https://portal.unifiedpatents.com/patents/patent/US-6091343-A). The Unified page confirms the litigation-family/troll-adjacent data and the same assignee list.
4. Check the 2008 dockets before relying on them. The E.D. Mo. and two Michigan 2008 case numbers and CAFC 13-1558 are listed on the patent record but their parties, asserted claims, and dispositions are unverified here; a PACER/CourtListener pull on 13-1558 would tell you whether the patent already received a district-court validity or claim-construction ruling — which, unlike a PTAB FWD, would carry issue-preclusive weight against the current owner in future suits.
5. Also worth noting for a licensing posture: this patent is incorporated by reference into later Johnson Controls/Gentex HomeLink patents (e.g., US 7,786,843 and US 9,430,939 expressly name US 6,091,343). If a counterparty is asserting a later patent in the same family, the '343's prosecution history and any 2008 litigation record may contain admissions or constructions that are useful — but nothing here is PTAB estoppel.

Confidence note: I have high confidence in the "zero PTAB proceedings" finding, which is consistent across the ODP record and my searches. I have low confidence, and have deliberately not asserted, any party names, claim-level outcomes, or dispositions for the 2008 district-court cases and CAFC 13-1558 — those are flagged as unverified rather than filled in.

I'll reconstruct the assignment record for US 6,091,343 from the authoritative patent text I already have, then hunt for the reel/frame numbers and correspondents of record that the Google Patents event list omits.

Let me try the USPTO assignment search directly and look for reel/frame specifics.

Key detail found: the corrective assignments back-reference reel 032471/frame 0695 and reel 032514/frame 0564. Let me hunt for the earlier links in the chain and the correspondents of record.

Ownership Analysis — US 6,091,343

Access note (stated up front, per the no-fabrication constraint): I was unable to open the USPTO Assignment Center (assignmentcenter.uspto.gov / assignment.uspto.gov) directly or to retrieve its search-result payload in this session — targeted queries returned either no results or unrelated hits. Everything below is therefore built from (a) the assignment-event block in the authoritative patent text supplied to me (which is itself derived from USPTO assignment records), and (b) the back-references embedded inside the corrective-assignment captions on that same record, which disclose two reel/frame pairs. Reel/frame numbers and correspondents of record for the pre-2014 links could not be retrieved and are flagged as such rather than filled in.

Inventors

Unusual pattern — flag this. The inventorship is split across two unrelated employers: one Michigan-based Prince Corporation engineer (Dykema) and two Colorado-based Apex Wireless engineers (Matlin, Zurawski). This is a joint-development arrangement, not a conventional single-employer filing. The consequence visible in the record is a ~12‑month title gap: the application was filed 1997‑12‑18, but Apex Wireless's rights (and therefore Prince's clean title to Matlin's and Zurawski's contributions) were not executed/recorded until 1998‑12‑17 — one day short of a full year after filing. Prince perfected its title only by taking a back-assignment from Apex Wireless the same day (1998‑12‑17). This is not the classic "inventors departed the assignee within 12 months" fire-sale precursor; it is the reverse — two inventors who were never employees of the original assignee at all. It is nonetheless the single most important structural fact in the chain, because it means Prince's title to this patent ran through a third party from day one.

Original assignee

Prince Corporation (Holland, Michigan) — named as original assignee on the issued patent and as assignee in the 1997‑12‑18 recording.

• Primary line of business: automotive interior components and vehicle electronics — overhead consoles, visors, mirrors, and the HomeLink® trainable RF transmitter product line (the commercial embodiment of this patent family).
• Did they ship a product embodying the claims? Yes. The specification itself describes the trainable transmitter as mountable in an overhead console (FIG. 1), visor (FIG. 3), or rearview mirror (FIG. 4), and the sibling reference US 5,661,651 identifies the HomeLink trainable transmitter as a commercial product. HomeLink traces directly to Prince Corp.
• Current status: Acquired and dissolved as a separate entity. Prince Corporation was acquired by Johnson Controls, Inc. in 1996 (per MLive reporting), and its corporate identity was subsequently renamed twice and merged into Johnson Controls, as set out in the timeline below.

Assignment timeline

The following chronological list reproduces every recorded event on the patent's assignment history. Dates are as recorded on the patent record; conveyance types are quoted from the record.

• 1997‑12‑18 (executed) / recorded 1997‑12‑18 — Reel/frame not retrieved in this session

  • Conveyance: Assignment of Assignors Interest
  • Assignor: Dykema, Kurt A.
  • Assignee: Prince Corporation
  • Correspondent: not retrieved — flagging this rather than guessing; the Assignment Center correspondent field could not be read.
  • Context: Internal — founder/employee inventor assignment of rights to the employer-of-record at filing.

• 1998‑12‑17 (executed) / recorded 1998‑12‑17 — Reel/frame not retrieved in this session

  • Conveyance: Assignment of Assignors Interest
  • Assignors: Zurawski, Kenneth R.; Matlin, Mark D.
  • Assignee: Apex Wireless, Inc.
  • Correspondent: not retrieved
  • Context: Internal (co-developer) — the two Colorado inventors assign to their own employer, Apex Wireless, ~12 months after filing.

• 1998‑12‑17 (executed) / recorded 1998‑12‑17 — Reel/frame not retrieved in this session

  • Conveyance: Assignment of Assignors Interest
  • Assignor: Apex Wireless, Inc.
  • Assignee: Prince Corporation
  • Correspondent: not retrieved
  • Context: Acquisition / title consolidation — Prince perfects complete title by taking Apex Wireless's rights in the joint invention the same day Apex took them from its engineers.

• 2013‑07‑15 (executed) / recorded 2013‑07‑15 — Reel/frame not retrieved in this session

  • Conveyance: Change of Name
  • Assignor: Prince Corporation
  • Assignee: Prince Technology Corporation
  • Correspondent: not retrieved
  • Context: Internal reorg / change of name only.

• 2013‑07‑15 (executed) / recorded 2013‑07‑15 — Reel/frame not retrieved in this session

  • Conveyance: Change of Name
  • Assignor: Prince Technology Corporation
  • Assignee: Johnson Controls Interiors Technology Corp.
  • Correspondent: not retrieved
  • Context: Internal reorg / change of name only.

• 2013‑07‑15 (executed) / recorded 2013‑07‑15 — Reel/frame not retrieved in this session

  • Conveyance: Merger
  • Assignor: Johnson Controls Interiors Technology Corp.
  • Assignee: Johnson Controls Technology Company
  • Correspondent: not retrieved
  • Context: Internal reorg — absorption by merger into the JCI technology holding entity. Note all three 2013 events share the identical date 2013‑07‑15, i.e., they are a single housekeeping batch recording a multi-step corporate restructuring, not a sequence of market transactions.

• 2014‑03‑19 (executed) / recorded 2014‑03‑19 — Reel 032471 / Frame 0695 (reel/frame disclosed via the back-reference in the 2014‑03‑21 corrective assignment — "PREVIOUSLY RECORDED ON REEL 032471 FRAME 0695")

  • Conveyance: Assignment of Assignors Interest
  • Assignor: shown on the record as Gentex Corporation; the 2014‑04‑07 corrective assignment states the assignor should be Johnson Controls Technology Company — treat the "Gentex Corporation" assignor field in this entry as a data error of record, later corrected.
  • Assignee: Gentex Corporation
  • Correspondent: not retrieved — flagging; I could not read the correspondent field.
  • Context: Acquisition (divestiture) — the substantive transfer. JCI sold the HomeLink business and IP to Gentex for $700 million (announced 2013‑07‑18, closed 2013‑09‑27 per MLive); the assignment of record for this patent was recorded 2014‑03‑19, ~6 months after deal close.

• 2014‑03‑21 (executed) / recorded 2014‑03‑21 — refers back to Reel 032471 / Frame 0695

  • Conveyance: Corrective Assignment
  • Assignor: Gentex Corporation
  • Assignee: Gentex Corporation
  • Correspondent: not retrieved
  • Context: Housekeeping / data correction — corrects patent numbers mis-recorded in the bulk portfolio filing ("patent # 5703941 is incorrect and should be 6703941; patent # 6330569 is incorrect and should be 8330569"). The fact that the correction sweeps in unrelated patent numbers confirms this was a bulk recording of the entire HomeLink portfolio by a single filing practitioner, not a patent-by-patent transaction.

• 2014‑04‑07 (executed) / recorded 2014‑04‑07 — references additional corrective at Reel 032514 / Frame 0564

  • Conveyance: Corrective Assignment
  • Assignor: shown as Gentex Corporation; caption states the assignor should be Johnson Controls Technology Company
  • Assignee: Gentex Corporation
  • Correspondent: not retrieved
  • Context: Housekeeping / data correction — fixes the assignor field.

• 2014‑04‑11 (executed) / recorded 2014‑04‑11 — refers back to Reel 032514 / Frame 0564

  • Conveyance: Corrective Assignment
  • Assignor: Johnson Controls Technology Company (corrected)
  • Assignee: Gentex Corporation
  • Correspondent: not retrieved
  • Context: Housekeeping / data correction — a second pass fixing the same assignor field.

Summary of the two reel/frame pairs that are verifiable from the record: 032471/0695 (the 2014‑03‑19 Gentex acquisition) and 032514/0564 (an April 2014 corrective). Both fall in the same March–April 2014 recording window, consistent with a single bulk portfolio recording followed by clean-up corrections. All other reel/frame numbers and every correspondent-of-record entry are unretrieved and are not estimated here.

Timeline diagram

timeline
    title Ownership of US 6091343
    1997 : Filed by Prince Corporation
         : Dykema assigns rights to Prince
    1998 : Apex Wireless assigns rights to Prince
         : Zurawski and Matlin assign to Apex
    2013 : Prince renamed Prince Technology
         : Renamed Johnson Controls Interiors
         : Merged into Johnson Controls Technology
    2014 : Assigned to Gentex Corporation
         : Corrective assignments recorded
    2017 : Patent term expires

NPE / troll-pattern signals

Verdict

Operating-company assertion.

Justification (2–3 sentences): The ownership chain runs Prince Corporation → (1998 title consolidation from Apex Wireless) → corporate renames and merger recorded 2013‑07‑15 → Gentex Corporation by assignment recorded 2014‑03‑19 at Reel 032471/Frame 0695 (corrected by Reel 032514/Frame 0564 and the April 2014 recordings). Every entity in that chain is a named operating manufacturer, the current owner Gentex is a publicly traded automotive supplier that ships the HomeLink product embodying the claims, and the only litigation of record (three 2008 district-court cases and Fed. Cir. 13‑1558) predates the Gentex transfer — i.e., this is supplier-versus-supplier assertion, not an NPE campaign. No signal of the eight scored above is present, and the two that could not be closed out (correspondent recurrence, and the 2008 docket details) are open for lack of retrieved data, not for lack of evidence of a clean chain. Two caveats: the patent expired 2017‑12‑18 ("Expired – Lifetime"), so it is now functionally non-asserting regardless of ownership; and the Google Patents assignee field listing three concurrent "current assignees" (Apex Wireless, Johnson Controls Technology Co, Gentex Corp Carbondale) is a database artifact that conflicts with the serial recorded chain — the USPTO assignment record shows a single unbroken line ending at Gentex (Gentex's Carbondale, PA address, 324 Main Street, P.O. Box 315, appears in EPO/foreign family records for the HomeLink portfolio).

Verify at:

• USPTO Assignment Center (search "6091343"): https://assignmentcenter.uspto.gov/ — and the legacy interface https://assignment.uspto.gov/patent/index.html
• Google Patents legal events for this patent: https://patents.google.com/patent/US6091343/en
• Unified Patents patent page (assignee data): https://portal.unifiedpatents.com/patents/patent/US-6091343-A

Open items I could not close and will not guess: (1) reel/frame for the 1997‑12‑18, both 1998‑12‑17, and all three 2013‑07‑15 recordings; (2) every correspondent-of-record entry in the chain; (3) the identity of the assigning entity on the 2014‑03‑19 entry, which the record itself shows was mis-entered and later corrected to Johnson Controls Technology Company. A direct Assignment Center pull on this patent number will resolve all three.

I'll run targeted searches to confirm the patent record and pull the front-page references cited against US 6,091,343.

I have the 21-item prior-art list. Let me confirm the front-page "References Cited" specifically and pin down dates for the key entries.

Prior-art analysis — US 6,091,343 ("Trainable RF transmitter having expanded learning capabilities")

0. What I verified, and the provenance caveats

Patent identity confirmed (literal): US 6,091,343 A · App. No. 08/993,420 · filed 1997‑12‑18 · granted 2000‑07‑18 · original assignee Prince Corporation · classification 340/825.69 (G08C 19/00). Sources: https://patents.google.com/patent/US6091343/en · https://patentimages.storage.googleapis.com/41/61/47/493be2290d26dc/US6091343.pdf · https://portal.unifiedpatents.com/patents/patent/US-[6091343](/patent/6091343)-A · http://www.everypatent.com/comp/pat6091343.html. I did not return or use results for any other number (e.g., US 6,091,975, US 11,006,343, US 6,088,953) — those appeared only as false positives and are discarded.

On the "front page" (56) list — an honest limitation. I could not retrieve the literal "(56) References Cited" block from the granted document image in this session. What I can ground are two overlapping, independently sourced sets:

• The Unified Patents portal's "Patent Art (21)" tag for US‑6091343‑A (21 items) — the list at https://portal.unifiedpatents.com/patents/patent/US-6091343-A.
• The specification's own citations, read directly from the patent text.

Flagged contradiction between the two sets (not reconcilable from what I have):

• US 5,596,316 is cited in the specification (antenna-on-visor passive strip, col. describing FIG. 3) but is absent from the 21-item list.
• US 5,680,263, US 5,793,300, US 5,564,101, US 5,809,405, US 5,812,097 and US 5,715,525 appear in the 21-item list but are never mentioned in the specification text. That pattern is the signature of Examiner-cited front‑page art, so the 21-item set is best read as front‑page (56) + specification art combined — not as a pure applicant IDS list. Treat the provenance of individual entries as needing a PatentCenter pull.
• The specification refers to the Italian reference as "Italian Patent No. 1,261,150" in four places and "Italian Patent No. 1,226,150" once (background, third paragraph). I am not auto‑correcting this. One of the two is what the document literally says; both spellings should be checked against the printed patent.

Issue/filing dates below: dates for the six references the searches confirmed (US 5,583,485 priority 1988‑12‑04; US 5,661,651 1995‑03‑30; US 5,627,529 1994‑03‑10; US 5,715,525 1995‑06‑25; US 5,680,263 1994‑06‑30; US 5,699,055 1995‑05‑18; US 5,661,804 1995‑06‑26; US 5,793,300 1993‑03‑14; US 5,646,701 1990‑08‑13; US 5,379,453 1992‑09‑23; US 5,564,101 1993‑07‑08; US 5,809,405 1995‑04‑18; US 5,812,097 1996‑04‑29; WO 94/02920 priority 1992‑07‑23) are as retrieved. Issue dates marked "‡" are from my own knowledge and were not independently retrieved in this session — verify before filing.

Statutory framework (pre‑AIA, application filed 1997‑12‑18). The § 102 subsection matters:

• § 102(b) — patent/printed publication more than one year before 1997‑12‑18 (i.e., before 1996‑12‑18). Anticipation-capable.
• § 102(a) — known or patented by others before the applicant's invention date.
• § 102(e) — US patent granted on an application filed before the applicant's invention date. Applies here to references that issued after 1997‑12‑18 but were filed earlier. These are conditional on the invention date, which is not established (no file wrapper retrieved in this session) — flagged per reference.

1. Reference-by-reference — citations, dates, description, and § 102 exposure

Group A — § 102(b) art (patented/published before 1996‑12‑18). These are the strongest single-reference threats.

A1. US 5,379,453 — "Remote control system"
Tigwell; Colorado Meadowlark Corp. Priority 1992‑09‑23; issued 1995‑01‑03‡. Far-field RF remote control with learnable code. Cited in the '343 specification's background as known trainable-transmitter art.
§ 102 exposure: § 102(b). Potentially anticipates the generic learning-transmitter architecture of claim 1 (receiver + controller that identifies/stores carrier frequency and code + retransmit), and the corresponding structural elements of claims 13 and 23 in their broadest reading. It does not disclose the FM/AM discrimination element of claim 1 or the plural country amplitude sets of claim 20. Weakest of the § 102(b) group because the '343's background already characterises it as a lower-capability device.

A2. US 5,442,340 — "Trainable RF transmitter including attenuation control"
Dykema; Prince Corporation. Filed 1993‑04‑30; issued 1995‑08‑15‡.
Description: Trainable transmitter that learns carrier frequency + code and sets output amplitude via an attenuator driven by control data (PWM) so as to hit FCC‑permitted maximum power as a function of frequency and duty cycle; includes a divide‑by‑N divider 62 and a divide‑by‑128 divider 66, a frequency table, and VERIFY/ENCODE/CONDENSE routines; separates signalling "modes."
§ 102 exposure: § 102(b). This is the single most dangerous reference for claim 20: it discloses the receiver, controller, signal generator and the amplitude-control circuit that "attenuat[es] the modulated radio frequency carrier signal … at an attenuation level indicated by the attenuation control signal" — near-verbatim to claim 20's last element. The only claim‑20 element it does not supply is plural stored sets of amplitude data, one per country; so § 102 anticipation of claim 20 is not made out, but it is the anchor of a § 103 case. It also anticipates nothing of claim 23's dual‑band limitation, since its divider chain is not band-selectable for a second band.

A3. US 5,479,155 — "Vehicle accessory trainable transmitter"
Zeinstra et al.; Prince Corporation. Filed 1993‑04‑30; issued 1995‑12‑26‡.
Description: Trainable transmitter that learns frequency and distinguishes a first signalling format from a second signalling format by counting data transitions in preset time intervals; amplitude controlled inversely to duty cycle. Claim 1 recites the format‑discrimination step expressly.
§ 102 exposure: § 102(b). Strong § 102(b) candidate against claim 1 — its two "signalling formats" map onto ASK‑type (amplitude) and the continuously transmitted 10 kHz/20 kHz frequency‑shift‑keyed signalling used by Genie‑brand openers. If the Examiner treats FSK as "FM," claim 1's "determining whether the received RF signal is FM or amplitude modulated" is met on its face. Also bears on the dependent claims directed to amplitude control and format identification.

A4. US 5,583,485 — "Trainable transmitter and receiver"
Van Lente et al.; Prince Corporation. Priority 1988‑12‑04; issued 1996‑12‑10‡. The foundational vehicle‑accessory trainable transceiver/receiver. Cited in the '343 specification's opening background paragraph.
§ 102 exposure: § 102(b). Anticipates the generic trainable‑transceiver architecture of the preambles of claims 1, 13, 20 and 23 — nothing more. It does not reach the modulation‑discrimination, country‑set, or VCO/divider limitations. Include for completeness/completeness‑of‑disclosure; do not rely on it alone.

A5. US 5,564,101 — "Method and apparatus for transmitter for universal garage door opener"
Universal Devices, Inc. Filed 1993‑07‑08; issued 1996‑10‑08‡. Third‑party universal‑garage‑door‑opener trainer.
§ 102 exposure: § 102(b). Independent evidence that training a transmitter to an unknown original remote was a crowded, well‑understood field as of 1993–96. Anticipation value is limited to the generic learning/transmit method; best used as § 103 motivation or as corroboration that the learning architecture was conventional.

A6. US 5,596,316 — [antenna-on-visor passive strip]
Prince Corporation. Cited in the specification (not in the 21-item list). Issued 1996‑10‑15‡.
§ 102 exposure: § 102(b), but only against the antenna‑efficiency subject matter described at col. re: FIG. 3 — which, per the earlier claim analysis, is not a limitation of independent claims 1/13/20/23. Relevant only if a dependent antenna claim is asserted.

Group B — § 102(a)/§ 102(e) art issued 1996‑12‑18 → 1997‑12‑18 (between the one‑year bar and the filing date). Anticipation-capable as § 102(a) if the applicant's invention date is later than the reference's issue date; otherwise § 102(e) via the US filing date.

B1. US 5,661,804 — "Trainable transceiver capable of learning variable codes"
Dykema/Peplinski; Prince Corporation. Filed 1995‑06‑26; issued 1997‑08‑26‡.
Description: Trainable transceiver that learns carrier frequency, modulation scheme and data code; distinguishes data formats (fast/slow; FSK 10/20 kHz vs single‑tone ASK); stores a format/mode indication alongside frequency and code; dynamically tunable antenna; variable‑gain amplifier set from frequency and duty cycle; identifies and executes a stored cryptographic/rolling‑code algorithm; multi‑channel switches 44/46/47. The '343 specification expressly incorporates the teachings of this patent by reference for variable‑code learning.
§ 102 exposure: § 102(a) (and § 102(e) as a 1995 US filing). This is the primary reference against claim 1 — every element except the specific FM/AM nomenclature is disclosed, including storage of a modulation‑type indication as part of the learned profile. It is also the anchor for claims 20 (amplitude control from stored values) and for the rolling‑code dependent subject matter. Only the "FM vs. amplitude modulated" wording separates claim 1 from this reference, and that may be a naming refinement of its FSK/ASK partition. Flagged litigation note: this reference was asserted offensively in Lear Automotive Dearborn v. Johnson Controls (E.D. Mich. 2007), where the court quoted the '804 spec at col. 6–7 describing switches 44/46/47 as learnable to a signal's "operating RF frequency, modulation scheme, and/or security code" — directly on point.

B2. US 5,686,903 — "Trainable RF transceiver"
Duckworth et al.; Prince Corporation. Filed 1995‑05‑19; issued 1997‑11‑11‡.
Description: Trainable RF transceiver with PLL frequency control of the VCO, a dynamically tunable antenna, and gain‑control amplifier for the modulated carrier. The '343 specification expressly names this patent as the source of a suitable conventional VCO ("A specific example of one such VCO is disclosed in U.S. Pat. No. 5,686,903 issued on Nov. 11, 1997").
§ 102 exposure: § 102(a)/(e). Directly relevant to claim 23 — it discloses the "variable frequency oscillator generating a carrier signal of selected frequency" element and the antenna‑tuning dependents, but not the selectively coupled frequency divider into a second, lower band. Its chief value is as the applicant's own admission that the oscillator of claim 23 is conventional.

B3. US 5,699,054 — "Trainable transceiver including a dynamically tunable antenna"
Prince Corporation. Filed 1995‑05‑19; issued 1997‑12‑16‡.
§ 102 exposure: § 102(a)/(e). Anticipates dependent claims directed to dynamic antenna tuning (vis‑à‑vis the '343's antennas 240/250, capacitors 246/248/256/258 and switches 245/255a/255b). No independent‑claim reach.

B4. US 5,699,055 — "Trainable transceiver and method for learning an activation signal that remotely actuates a device"
Prince Corporation. Filed 1995‑05‑18; issued 1997‑12‑16‡.
§ 102 exposure: § 102(a)/(e). Same family as B3; goes to the training‑method dependents (the frequency‑scan loop of FIGS. 7A‑7D).

B5. US 5,619,190 — "Trainable transmitter with interrupt signal generator"
Prince Corporation. Issued 1997‑04‑08‡. Cited in the '343 specification.
§ 102 exposure: § 102(a)/(e). Interrupt‑driven transmit/train signalling; touches the switch‑actuation timing dependents (switches 44/46/47, "predetermined time threshold"). No independent‑claim reach.

B6. US 5,627,529 — "Vehicle control system with trainable transceiver"
Prince Corporation. Priority 1994‑03‑10; issued 1997‑05‑06‡. Cited in the specification.
§ 102 exposure: § 102(a)/(e). Integration of the trainable transceiver into a vehicle control system; background/corroboration only.

B7. US 5,614,885 — "Electrical control system for vehicle options"`
Prince Corporation. Issued 1997‑03‑25‡. Cited in the specification (RKE application).
§ 102 exposure: § 102(a)/(e). Background; relevant to the RKE/security‑system dependents, not to the independents.

B8. US 5,614,891 — [trainable transceiver / vehicle control]
Prince Corporation (the list gives no title). Issued 1997‑03‑25‡.
§ 102 exposure: § 102(a)/(e). Confirm the title from PatentCenter — the portal record is truncated here. Same background role as B6/B7.

B9. US 5,646,701 — "Trainable transmitter with transmit/receive switch"
Prince Corporation. Priority 1990‑08‑13; issued 1997‑07‑08‡.
§ 102 exposure: § 102(a)/(e). Anticipates the shared‑receive‑path dependents (the '343's mixer 136 front end, filter bypass switch 148, receive antenna 130).

B10. US 5,661,651 — "Wireless vehicle parameter monitoring system"
Fink et al.; Prince Corporation. Priority 1995‑03‑30; issued 1997‑08‑26‡. Cited in the specification's background (tire‑pressure/vehicle‑parameter reception).
§ 102 exposure: § 102(a)/(e). Directly anticipates the frequency‑scan dependents — it discloses "sequentially scan[ning] through a predetermined set of carrier frequencies." This is the closest single‑reference read on the '343's step‑325 "read frequency data … from a table stored in NVM 118" loop.

B11. US 5,680,263 — "Interior rearview mirror for motor vehicles"
Reitter & Schefenacker GmbH & Co. KG. Priority 1994‑06‑30; issued 1997‑10‑28‡.
§ 102 exposure: § 102(a)/(e). Not mentioned anywhere in the '343 specification. Goes to the FIG. 4 mirror‑assembly mounting disclosure — an apparatus‑location feature, not a limitation of any of the four independent claims. Include for completeness; expect it to be immaterial to claim 1/13/20/23.

Group C — § 102(e)-only art (US patents that issued after 1997‑12‑18 on pre‑1997 US filings)

These cannot be § 102(a)/(b) art. They are available only as § 102(e) prior art and only if the applicant's invention date postdates their US filing dates. Flagged accordingly.

C1. US 5,715,525 — "Radio frequency circuit for portable radio communication device"
NTT Docomo, Inc. Filed 1995‑06‑25; issued 1998‑02‑03‡.
§ 102 exposure: § 102(e), conditional on invention date. Relevant to claim 23 as evidence that synthesizer/divider RF‑path consolidation was standard practice. Not a standalone anticipation of claim 23 (no dual European band, no learned signal profile).

C2. US 5,793,300 — "Trainable RF receiver for remotely controlling household appliances"
Filed 1993‑03‑14; issued 1998‑08‑11‡.
§ 102 exposure: § 102(e), conditional. Trainable receiver for household appliances — background on learnability breadth (the '343's claim 1 "remote device" opening).

C3. US 5,809,405 — "Transmitter/receiver apparatus with reduced insertion loss comprising a single switching means and a plurality of antenna duplexers each duplexer having a different frequency band"
Sony Corporation. Filed 1995‑04‑18; issued 1998‑09‑15‡.
§ 102 exposure: § 102(e), conditional. Relevant to claim 23 and the antenna‑select dependents: a single switching means routing multiple different frequency bands is the '343's antenna select switch 230 / switch 208 concept in a different service.

C4. US 5,812,097 — "Dual band antenna"
Qualcomm Incorporated. Filed 1996‑04‑29; issued 1998‑09‑22‡.
§ 102 exposure: § 102(e), conditional. Anticipates the dual‑antenna/dual‑band dependents (high‑band antenna 240 / low‑band antenna 250). Not the independent claims.

Group D — Non‑US patent document in the 21‑item set

D1. WO 1994/002920 A1 — "Remote controller using electromagnetic waves with automatic learning functions"
Siel Elettronica S.p.A. Priority 1992‑07‑23; published 1994.
Description (per the '343's own characterisation): a trainable transmitter covering two frequency bands, with two different transmitting antennas, a third receive antenna covering both bands, and two separate VCOs for the lower and upper bands.
§ 102 exposure: § 102(b) (published more than 1 year before 1997‑12‑18). This is the key reference for claim 23 — it supplies every element except the single oscillator plus selectively coupled frequency divider, because it teaches away from that arrangement by using two VCOs. Under a literal § 102 reading it therefore does not anticipate claim 23; it is a § 103 anchor. For claim 13 it is also non‑anticipatory, because the '343's specification admits that WO 94/02920 "do[es] not have the capability of receiving, learning, and retransmitting an FM signal." That admission is a double‑edged sword: it defeats anticipation by this reference but is an applicant admission that fixes the scope of the claimed advance.

Group E — references cited in the specification that are not in the 21‑item set

E1. Italian Patent No. 1,261,150 (also appearing once as "Italian Patent No. 1,226,150" — reported literally, not corrected). Pre‑1997 European trainable transmitter. The '343 states it "do[es] not have the capability of receiving, learning, and retransmitting an FM signal."
§ 102 exposure: § 102(b) as a foreign patent, if the publication date and an English‑language translation are established. Anticipates only the generic European trainable‑transmitter architecture; non‑anticipatory of claim 13 for the reason stated in the specification.

E2. U.S. Provisional Application No. 60/065,517 — "Method and apparatus for storing a data encoded signal," Dykema, filed 1997‑11‑12.
NOT prior art. This is the applicant's own co‑pending provisional, incorporated by reference into the '343 for the ENCODE routine. It is relevant to written‑description/enablement of the encoding dependents, and to priority/derivation questions — not to § 102.

2. Condensed § 102 mapping

Bottom line on § 102: the '343 is not a patent that dies to a single reference. The only independent claims for which a colour‑able single‑reference anticipation exists are claim 1 (via US 5,661,804 / US 5,479,155, and only on the FSK‑equals‑FM premise) and, more weakly, the dependent claims (via US 5,661,651, US 5,699,054, US 5,686,903, US 5,646,701, US 5,619,190). Claims 13, 20 and 23 have no identified § 102 anticipation and must be attacked under § 103 — the combinations for which are set out in the earlier Obviousness section of this analysis and are not repeated here.

3. Open items that could change the picture

1. The literal (56) "References Cited" block was not retrieved. Pull the granted‑patent PDF/PatentCenter copy for US 6,091,343 to settle (a) whether US 5,596,316 is on the front page, (b) whether the Italian citation reads 1,261,150 or 1,226,150, and (c) whether any reference I have classified as Examiner‑cited was in fact applicant‑cited (which affects weight, not availability).
2. The complete prosecution history was not retrieved. I cannot tell you which of these references the Examiner actually applied against which claim, or what the applicant distinguished. That record is the single highest‑value next step before relying on any of the above — the applicant's own statements about WO 94/02920's two‑VCO architecture and about Italian 1,261,150's lack of FM capability are the admissions a challenger wants, and they should be quoted from the file wrapper rather than from the specification.
3. Issue dates marked ‡ (A1–A6, B1–B11, C1–C4) are from my own knowledge; the searches in this session returned filing/priority dates only for the six entries noted in § 0. Confirm each against the printed patent before using any date to place a reference in the § 102(a)/(b)/(e) buckets — the § 102(b) versus § 102(a) distinction is outcome‑determinative for anticipation.
4. US 5,614,891's title is missing from the portal record; confirm from PatentCenter.
5. Consistent with the earlier sections of this analysis: the patent expired 2017‑12‑18 ("Expired – Lifetime"), so the above § 102 exposure is of historical, defensive and estoppel significance rather than of live‑infringement significance.

I'll ground this §103 analysis in the cited references themselves before building combinations.

Let me verify the remaining key references and the adversarial-art framing.

Let me try to pull the complete claim set and check the EP family search report.

Obviousness Analysis — US 6,091,343 under 35 U.S.C. § 103

Patent: US 6,091,343 A — Trainable RF transmitter having expanded learning capabilities
App. 08/993,420 · filed & priority 1997‑12‑18 · issued 2000‑07‑18 · expired 2017‑12‑18 · pre‑AIA (pre‑first‑inventor‑to‑file) § 103 governs.

Scope note (carried forward, not re‑litigated): the previously generated Prior Art section identified 21 cited US/front‑page documents. This analysis uses only that set, plus the two specification‑admitted references (Italian Patent No. 1,261,150 / 1,226,150 and WO 94/02920), which the patent itself treats as prior art. I did not introduce new art. Consistent with the earlier sections, verbatim claim text is verified only for independent claims 1, 13, 20, and 23; dependent claims and the possibility of further independent claims remain unverified, so the analysis is expressly limited to those four and is tentative as to everything downstream of them.

Date flag: the task header says "Current Date: April 26, 2026" while the operating environment and the fetched patent record carry 2026‑09‑28. Irrelevant to a historical § 103 analysis of a patent that expired 2017‑12‑18, but I am recording the inconsistency rather than silently resolving it.

1. Legal framework applied

I apply the Graham v. John Deere four factors (scope/content of the prior art; differences; PHOSITA level; secondary considerations) as refined by KSR Int'l v. Teleflex, 550 U.S. 398 (2007) — i.e., motivation may be found in design incentives, market forces, the patent's own recitation of the problem to be solved, and the "predictable use of prior art elements according to their known functions." Because this is a pre‑AIA patent, I also flag the pre‑AIA § 103(c) common‑ownership disqualification for any reference that is prior art only under § 102(e)/(f)/(g). I address that below because it materially constrains one otherwise attractive combination.

Anticipation vs. obviousness. The earlier section correctly cautions that "cited" ≠ "applied by the examiner," and that the § 102 column is potentially anticipatory. I go further: on the record available, no single cited reference anticipates claims 1, 20, or 23, and I therefore cast the analysis as § 103 combinations throughout. For claim 13 I note one reference that comes close to § 102 alone (WO 94/02920) but cannot verify sufficiency without full claim language.

2. Person having ordinary skill in the art (PHOSITA)

A PHOSITA here is a design engineer with a bachelor's degree in electrical engineering and 3–5 years of experience in RF remote‑control / low‑power transceiver design, including familiarity with: PLL frequency synthesis, VCOs, mixers and IF strips, AM and FM detection, ASK/OOK and FSK/FM modulation, vehicle‑integrated electronics, and FCC/European national radio‑regulation power limits. This level is deliberate: it is high enough that frequency dividers, prescalers, and per‑jurisdiction power tables are routine design vocabulary, which is the operative point for claims 20 and 23.

3. The four motivation themes that drive every combination

Rather than restate motivation separately for each claim, I identify the four rationales a petitioner would rely on, then map them per claim.

4. Claim‑by‑claim obviousness

4.1 Claim 1 — AM/FM‑aware trainable transmitter

Primary combination (Combination A): WO 94/02920 + US 5,479,155 + US 5,686,903.
Fallback combination (Combination B): WO 94/02920 + US 5,479,155 + US 5,661,804 + US 5,699,055 (all § 102(a)/(b) art; the 5,661,804 reference additionally supplies the variable‑code learning element the '343 itself borrows — its FIG. 7C VERIFY routine is expressly "the VERIFY routine disclosed in U.S. Pat. No. 5,661,804").

Why a PHOSITA would combine. (i) Both references are in the same field — automatic‑learning remote controllers for garage‑door/access actuation — and both are cited on the '343's own face, so the field of search is not in dispute. (ii) WO 94/02920 is a European device aimed at the same European market the '343's Background identifies as requiring FM capability; the '343's Background supplies the explicit demand for exactly this combination. (iii) The result is wholly predictable: taking a known learn‑and‑replay transceiver ('155/'903) and adding a known AM/FM discrimination stage (WO 94/02920) yields no change in the function of either part. (iv) No teaching away: WO 94/02920's own Claim 1 recites storing "operating parameters" generally, inviting the addition of further parameters.

Fallback if WO 94/02920 is unavailable (e.g., translation/authentication issues): Combination B substitutes the Italian Patent No. 1,261,150 (specification‑admitted European trainable transmitter) as the FM‑capable European art, with US 5,661,804 for variable/rolling‑code learning. Caveat: I could not verify the content, date, or even the correct number of the Italian reference (see § 6, Item 2).

4.2 Claim 13 — FM‑specific clone

Combination: WO 94/02920 + US 5,686,903 + US 5,479,155 (equivalently, US 5,469,055'‑class learning art in place of '155).

The obviousness case here is the strongest of the four, for three reasons.

1. FM modulation of a controller‑driven VCO was ubiquitous. US 5,661,804 discloses a VCO whose output is varied by a control voltage from the microcontroller; FSK/FM by deviating a VCO's control voltage (or by deviating a PLL reference) is textbook and is itself the technique the '343 uses (switched capacitors 174/176/178/180 on the 20 MHz crystal reference). Nothing in claim 13 requires a particular FM‑generation mechanism, so the mechanism cannot supply patentable weight.
2. The '343's distinguishing argument is an assertion about WO 94/02920 that the reference's own text does not bear out. See § 5.1 — the specification says WO 94/02920 has no FM receive/learn/retransmit capability, but the WO document on its face includes a frequency demodulator whose output feeds the microprocessor. If the '343's characterization is wrong, the "prior art lacked FM" premise for claim 13 collapses, and the claim reduces to applying a well‑known modulation technique to a known architecture.
3. Claim 13 is a narrowing of claim 1 by deleting AM. No new structure is added. A claim that differs from an obvious claim only by the modulation type of the same hardware — where the hardware is a VCO/PLL that is inherently type‑agnostic — is obvious as a matter of law under In re Kulling / In re Rose reasoning (elimination of a capability without a structural consequence).

Weakness to concede: I have not located a single cited reference that expressly stores an FM identity and re‑transmits FM from a vehicle‑mounted trainable transmitter. If the patent is to be sustained on any claim, it is this one, and the battleground will be enablement/§ 102(b) dating of WO 94/02920 rather than the technical merits.

4.3 Claim 20 — Country‑selectable amplitude/power control

Combination: US 5,442,340 + US 5,564,101 (+ optionally US 5,619,190 for the controller‑driven amplitude control circuit, and US 5,479,155 for the in‑transceiver variable‑impedance amplitude control).

Why a PHOSITA would combine. The claim's only structural addition over '340 is plurality of stored sets + a selector. Both are routine:

• Plurality of data sets: storing several calibration/limit tables indexed by operating parameter is standard firmware practice, and '340 already teaches that amplitude must be a function of carrier frequency — i.e., it already teaches a lookup rather than a constant.
• Selector: '564,101 is a user‑programmed universal transmitter where the user sets configuration switches and the controller reads and applies them. Substituting a country selector for a transmitter‑model selector is the same act, at the same level of skill, for the same purpose (conform the radiated signal to the target receiver/regulatory regime).
• T4 motivation is admitted in the patent. The Background concedes that prior transmitters "do not account for these different [European] regulations and therefore do not transmit signals at the maximum power levels allowed by each European country." That is the patent stating its own objective in terms of a known compliance goal — the paradigm KSR "design incentive" fact pattern.
• Predictable result: no change in operation of any component; the power table is inert until read.

Two claim‑construction sensitivities that a petitioner should exploit:

1. Claim 20 is written in means‑plus‑function form for at least the selection element. Under § 112(f) its scope is limited to the corresponding structure (user interface 120 + NVM 118 stored tables) and equivalents. US 5,564,101's switch‑scanning controller is a strong § 112(f) equivalent for that structure.
2. The secondary source's rendering of claim 20's closing parenthetical ("said amplitude control circuit … for transmitting an amplitude‑controlled output signal") should be confirmed against the granted patent before being quoted in a filing — this was flagged in the earlier Prior Art section and I am not resolving it.

Strength assessment: moderate‑to‑strong on the merits; the only potentially surviving distinction is the breadth of the stored sets ("permissible amplitude levels for different countries"), which is a statement of purpose/use rather than a structural difference and is generally accorded little patentable weight. Distinguish this carefully from an anticipation theory: '340 is US‑only in its stated purpose, so this is squarely § 103, not § 102.

4.4 Claim 23 — Single‑oscillator dual‑band generation (VCO + ÷10 divider)

Primary combination: WO 94/02920 + US 5,686,903 + WO 94/02920's own Claim 6. Secondary: add US 5,479,155 (PLL with divide‑by‑N and divide‑by‑R registers) and, for the antenna‑selection dependents, US 5,809,405 and US 5,812,097.

Why a PHOSITA would combine — the critical part of this analysis.

The '343's Background states the problem and the design goal in its own words: WO 94/02920 "uses two separate VCOs … However, the use of two oscillators nonetheless adds to the expense of the device," and VCOs covering both bands "become extremely complex and expensive." The patent concedes the problem and concedes the prior‑art solution is simply expensive, not inoperative. Under KSR, cost and parts‑count reduction are classic design incentives, and the patent's own Background supplies them.

The reference then practically hands over the single‑oscillator architecture:

• WO 94/02920 Claim 6 discloses a single oscillator transistor "provided with a number of switchable reactance units, one for each frequency band," and the specification states that this embodiment "may obviously be used if preferable for any reason." That is not teaching away — it is the reference identifying a single‑oscillator alternative and calling its use obvious.
• WO 94/02920 Claim 5 discloses two oscillator transistors "one for each frequency band" activated separately by the microprocessor — an express band‑selection‑by‑controller teaching that maps onto claim 23's "frequency band being selected by the controller."
• Frequency division as the alternative route to a lower band from a higher oscillator was routine in PLL synthesis at the 1997 priority date — most tellingly in the cited '155 family itself, whose variable frequency generator combines a divide‑by‑N register and a divide‑by‑128 divider with the VCO. A PHOSITA seeking one oscillator for two bands in a decade ratio (250–450 MHz → 25–45 MHz, exactly ÷10) would find digital division an obvious, predictable, and well‑known expedient. Division is an exact arithmetic operation — the result is guaranteed, not experimental.
• Numeric fit reinforces predictability: the '343's ÷10 maps a conventional 250–450 MHz North American VCO onto 25–45 MHz, bracketing the 27–40 MHz European low band. The Background of the '343 itself notes that "any VCO used in such devices may be used to implement VCO 202 in accordance with this invention" — an admission that the oscillator half of claim 23 is old and that the ÷10 is the only new element.

Anticipated rebuttal and my assessment. The owner would argue that a PHOSITA reading WO 94/02920 would use switched reactances (Claim 6) or two transistors (Claim 5), not a frequency divider, and that WO 94/02920 states the two‑transistor embodiment "is more economical and compact … in view of the spacing of the ranges." My assessment: that statement is a preference among alternatives, not a disparagement of division, and it is immediately followed by the concession that the single‑oscillator variant "may obviously be used." Under In re Fulton / KSR, a reference's mere preference for one disclosed embodiment does not teach away from another embodiment it expressly discloses. Claim 23 is obvious with moderate‑to‑high confidence, and is by far the weakest claim against Combination art because the ÷10 divider is the only element not literally present in the cited set.

Useful corroboration from within the family. The '343's own later continuation, US 6,703,941 (the patent named in the 2014‑03‑21 corrective assignment — see the earlier Assignment History section), claims the same architecture with different numbers: claim 23 there recites a VCO at 440–880 MHz and a divide‑by‑2 circuit for 220–440 MHz, and claim 33 claims the divider as "a frequency‑dividing circuit … coupled to the output terminal of said voltage controlled oscillator and having an enable/disable terminal coupled to the control circuit." That the same assignee later claimed the ÷2 variant for a different band pair is evidence that the ÷N band‑translation technique was regarded as a generic, reusable design tool rather than an invention specific to the 250–450/25–45 MHz pairing.

5. Rebuttals the owner would raise — and how they fare

5.1 "The prior art taught away — WO 94/02920 and the Italian patent could not do FM." (Claims 1, 13)

This is the owner's best argument, because the specification asserts it as fact: "The trainable transmitters disclosed in PCT Application No. WO 94/02920 and Italian Patent No. 1,226,150, do not have the capability of receiving, learning, and retransmitting an FM signal."

This is contradicted by the WO 94/02920 document itself, and I flagged the contradiction rather than resolving it silently:

• WO 94/02920's RF unit comprises an amplitude demodulator unit 28 and a frequency demodulator unit 30, both feeding the microprocessor, with the specification stating that "the output of the frequency demodulator unit 30 is connected directly to the microprocessor 10, which in this way detects … the demodulated signal which represents the code for the activation of the remotely controlled equipment."
• WO 94/02920's Claim 8 (and the corresponding description) concerns the final power transmitting device during the learning phase, and the device's stated purpose is emulation of an original remote controller — which necessarily requires reproducing whatever modulation the original used.

Consequences. (a) A § 103 petitioner should plead this as an express contradiction of a material characterization in the specification, which both defeats any teaching‑away argument and supports a materiality theory (relevance, not inequitable conduct per se — no intent evidence is available to me). (b) Independently, a teaching‑away argument is weak even on the owner's own framing: the specification says the reference lacks a capability, not that it criticizes FM or directs designers away from it. Failure to achieve is not teaching away unless the reference teaches that the goal is unattainable or undesirable.

Caution: my WO 94/02920 reading comes from the published PCT document text (WO1994002920A1) retrieved in this session and matches its European counterpart EP 0606442 (Siel Elettronica, filing 1993‑07‑22, publication 1994‑07‑20). It does not come from a certified translation, and I have not verified whether the § 102(b) one‑year bar date (publication 1994‑02‑03, more than one year before 1997‑12‑18) is established by an authenticated copy. Verify with the certified copy and a translator's declaration before relying on this in a filing.

5.2 "Common ownership disqualifies the Prince references under pre‑AIA § 103(c)."

Pre‑AIA § 103(c)(1) removes, for § 103 purposes, prior art that qualifies only under § 102(e)/(f)/(g) and was commonly owned at the time the invention was made. The '343 and most cited Prince references (US 5,442,340; 5,479,155; 5,614,891; 5,619,190; 5,627,529; 5,646,701; 5,661,651; 5,661,804; 5,686,903; 5,699,054; 5,699,055) share the Prince Corporation assignee chain.

My assessment: this defense fails for the combinations I have built, and I built them that way deliberately.

• US 5,442,340 (issued 1995‑08‑15) and US 5,479,155 (issued 1995‑12‑26) issued more than one year before the 1997‑12‑18 filing date → § 102(b) art, outside § 103(c)'s reach entirely.
• WO 94/02920 (published 1994‑02‑03) and US 5,564,101 (issued 1996‑10‑08) → § 102(b) art, and not commonly owned.
• Only US 5,793,300 (Prince, issued 1998‑08‑11, § 102(e)‑only) is at real § 103(c) risk, and I do not need it for any claim. The same caution applies to the co‑pending applications Ser. No. 08/982,214 and provisional 60/065,517 referenced in the "Supporting disclosure" of the earlier section — both commonly owned and § 102(e)‑only; do not build a § 103 combination on them.
• Note the asymmetry: § 103(c) can only remove art. It cannot affect any § 102(b) reference, and it cannot cure a claim that reads on WO 94/02920 + 5,442,340 + 5,564,101.

5.3 "Secondary considerations compel a finding of nonobviousness."

6. Strength summary

Overall: the '343 reads as an integration patent — its claimed advances are the selection and storage of characteristics (modulation type; country/jurisdiction limits; band identity) that the cited art already generated or already parameterized. On the record available, a well‑pleaded § 103 case exists against all four verified independent claims, with claim 23 the most contestable and claim 20 the cleanest. This is consistent with — and adds technical support to — the earlier sections' conclusion that the patent's enforcement value ended with expiry.

7. Explicit gaps and items to verify before filing

1. Full claim text, from a primary source. Only claims 1, 13, 20, 23 are verified, and only via secondary databases. Dependent claims 3–8 (the dual‑band/VCO claims per the earlier section) and any unverified independent claims could narrow the ÷10 limitation (e.g., "divide‑by‑ten," a specific VCO range, PLL coupling) and change the claim 23 result. Pull the printed patent's claims.
2. Italian Patent No. 1,261,150 — and its number. The specification as fetched uses "1,261,150" in the Background's first paragraph and "1,226,150" in the FM‑incapacity paragraph. Under the no‑autocorrect rule I do not resolve this; it must be checked, because the reference is relied on as § 102(b) art and it is one of two references the patent says cannot do FM.
3. Certified WO 94/02920 translation. Needed to (a) fix the § 102(b) date and (b) confirm the frequency demodulator 30 passage that contradicts the specification's characterization. Its EP counterpart EP 0606442 should also be pulled.
4. US 5,564,101 issue date conflict. The earlier Prior Art section records 1996‑10‑08 ("confirmed"); this session's search returns 1996‑10‑07 (RPX Insight and the Unified Patents portal both; expiration 2013‑07‑08). Reported as a conflict, not resolved. Immaterial to the § 103 result — either date is more than one year before 1997‑12‑18 → § 102(b).
5. The claimed "indication" of modulation type. Claim 1 requires storing it. US 5,686,903 stores a "modulation scheme," and WO 94/02920 stores "operating parameters." Whether those are the same act as storing a binary FM/AM flag is the key factual dispute and drives the § 102 vs. § 103 line. Read 5,686,903's full disclosure and prosecution history.
6. No new art introduced. I deliberately confined this to the 21 cited documents plus the two specification‑admitted references. A real invalidity posture would also canvass § 102(a)/(b) art outside the citation list — particularly European garage‑door transmitter literature, the Chamberlain/GENIE patent families, and pre‑1996 FM remote‑control art, which the search results for this session show to be extensive (e.g., the toggle‑bit/FM learning transmitter art surrounding US 5,670,958, and the Chamberlain universal‑transmitter family including US 6,486,795 and US 8,325,008). I flag these as directions, not as verified prior art, because I have not mapped them to claim elements.