Invalidity dossier
US 6651000
Current assignee: Global Locate, Inc., Broadcom Corporation
Added 9/29/2026, 4:51:50 AM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for the specific patent number and any related litigation/docket information.
Let me check specifically for any recent (2026) CAFC activity and confirm current ownership status.
US Patent 6,651,000 — Analyst Summary
Note on the identifier (literal interpretation): The number in your query is 6651000, which is US Patent 6,651,000 B2 (application US 09/915,219). I did not auto-correct or re-derive this; the patent record itself renders it "US 6,651,000 B2," and litigation documents consistently refer to it as "the '000 patent." All figures below are drawn from the authoritative patent text you supplied, supplemented by the ITC/CAFC records surfaced in search.
1. Bibliographic data
| Field | Value |
|---|---|
| Patent number | US 6,651,000 B2 (US6651000B2) |
| Title | Method and apparatus for generating and distributing satellite tracking information in a compact format |
| Inventors | Frank van Diggelen (San Jose, CA); Charles Abraham (San Jose, CA); James W. LaMance (San Jose, CA) |
| Original assignee | Global Locate, Inc. (San Jose, CA) |
| Current assignee (as listed) | Avago Technologies International Sales Pte Ltd (Singapore) |
| Application number | US 09/915,219 |
| Priority date | 2001-07-25 |
| Filing date | 2001-07-25 |
| Issue / publication date | 2003-11-18 (pre-grant pub. US20030023379A1 on 2003-01-30) |
| Legal status | Ceased; adjusted expiration 2021-10-14 |
| Classification | G01S19/27, G01S19/258, G01S19/05 |
| Family | Continuation US 6,829,535 B2 (app. 10/655,884); Reissue US RE48176 E1 (app. 13/237,550); EP1417798B1; WO2003010912A2; AU2002326433A1; ATE510230T1 |
Post-grant events (important):
- 2010-06-08 / filed 2010-08-31: Request for ex parte reexamination filed.
- 2011-11-15: Reexamination certificate issued — claims 1, 2 and 5 cancelled; claims 3, 4 and 6–33 not reexamined. (Notably, these are the very claims the ITC found infringed — see §4.)
- 2011-09-20: Reissue application 13/237,550 filed; US RE48176 E1 granted 2020-08-25 (currently Avago; also shown "Expired – Lifetime").
2. Abstract (verbatim)
"A method and apparatus for creating and distributing satellite tracking data in a compact format to a remote receiver. At least a portion of the satellite tracking data is extracted from memory and is formatted into a compact format. The compact formatted data is transmitted to the remote receiver via a distribution network. Once this data is received at the remote receiver it is reformatted into a format prescribed by the remote receiver."
3. Plain-language overview of the independent claims
The patent has four independent claims as originally granted — claims 1, 16, 26 and 29. Claim 1 (and its dependents) was cancelled in reexamination; claims 16, 26 and 29 survive (and are materially rewritten in the reissue, RE48176).
Claim 1 — "Distribute in a compact format, expand at the receiver" (CANCELLED in reexam).
A method for creating and distributing compact satellite orbit models, comprising four steps: (a) receive satellite signals at one or more satellites/a receiving station; (b) extract at least part of the satellite tracking data from the signal and represent it in a first (compact) format; (c) transmit that formatted data to a remote receiver; and (d) at the remote receiver, represent the data in a second format that the receiver supports. In plain terms: shrink the orbit/clock data on the server side, send it, then re-inflate it into a receiver-native format on the device.
Claim 16 — "Fewer orbit terms sent, receiver expands back to the full term count."
A method where the extracted tracking data includes a first number of orbit terms defining a first orbit model; the data is formatted down to a second, smaller number of orbit terms defining a second (compact) orbit model; the compact data is transmitted; and the remote receiver expands the data back to the first number of terms. In plain terms: the server drops orbit terms to save bandwidth, and the receiver puts the missing terms back.
- Reissue (RE48176) version of claim 16 adds significant limitations: the source is "measurement data"; the orbit terms "comprise harmonic and non-harmonic parameters"; the second (transmitted) number of terms excludes the harmonic parameters; and the receiver must expand the data and use the expanded data to determine the receiver's location.
Claim 26 — "Create a compact orbit model by reducing the term set."
A method (as granted, framed generically) of providing a satellite orbit model having a first set of terms and adjusting that first set to produce a compact orbit model having a second, smaller set of terms. Dependent claims 27–28 specify the mechanism: zeroing a plurality of terms, then adjusting the non-zero terms to compensate for the zeroed terms.
- Reissue version of claim 26 is recast as a system interaction: a GPS receiver receives satellite tracking information, forms a set of satellite ephemeris parameters (comprising harmonic and non-harmonic parameters), transmits that to a server, which adjusts it into a compact model excluding the harmonic parameters, and transmits the compact model to a remote receiver configured to expand it and determine its location.
Claim 29 — Apparatus counterpart.
An apparatus with (a) at least one satellite-signal receiver; (b) "means for extracting" at least a portion of the satellite tracking data and representing it in a first format; (c) a transmitter to send the formatted data to a remote receiver; and (d) at the remote receiver, representing the data in a second format supported by the receiver.
- Reissue version of claim 29 again adds: the first format includes first-set terms comprising harmonic and non-harmonic parameters; a "means for reformatting" generates a second format excluding the harmonic parameters; the receiver represents the data back into the first format and uses it to determine its location.
New independent claims added in the reissue (RE48176), not present in the original '000 grant: claims 34 and 47 (method/apparatus that expressly recite "compact satellite orbit model is a subset of satellite ephemeris parameters… excluding the harmonic parameters," plus dependent claims 35–46 and 48–49 reciting, e.g., replacing excluded harmonic parameters with zero or with a value from GPS almanac data).
Underlying technical gist (from the specification): GPS broadcast ephemeris is ~900 bits and takes up to 18 seconds to receive; the invention compacts it. The preferred embodiment starts from the 15-term standard ephemeris (ICD-GPS-200c) parameter set, zeroes the 6 harmonic correction terms, and re-fits the remaining 9 non-harmonic terms (e.g., via least-squares) so the compact model stays accurate — the patent states a receiver using the compact model should compute a position no more than 2 meters less accurate than with a full orbit model over the interval.
4. Litigation / docket findings (searched)
- ITC Inv. No. 337-TA-602, Certain GPS Devices and Products Containing Same — instituted 2007-05-07 on a complaint by Global Locate, Inc. (later joined by Broadcom Corp.). The '000 patent was one of six asserted patents. The original institution notice listed, for the '000 patent, claims 1–5, 9, 10, 11–14, 29–31 and 33; the ALJ's final determination found infringement of claims 1, 2 and 5 (Initial Determination, Aug. 8, 2008). Respondents included SiRF Technology, Mio, MiTAC, Pharos and E-TEN.
- Commission Final Determination, Jan. 15, 2009 — violation found as to all six patents; limited exclusion order and cease-and-desist orders issued.
- *Federal Circuit: SiRF Technology, Inc. v. International Trade Commission, No. 2009-1262 — decided April 12, 2010* (precedential). The court affirmed the Commission's final determination in all respects. The opinion describes the '000 patent as teaching "the compaction of satellite ephemeris data in order for it to be received more quickly by GPS receivers than uncompacted data."
- District court: California Central District Court case 8:06-cv-01216 (per the litigation links on the patent page).
- 2010–2011 aftermath: Commission modification/enforcement proceedings (Federal Register notice, Dec. 7, 2010), and the ex parte reexamination that cancelled claims 1, 2 and 5 — i.e., the exact claims the ITC found infringed.
5. Explicit uncertainty / caveats
- No 2026 CAFC docket activity for this patent was found. I searched for Federal Circuit 2026 dockets tied to 6,651,000 and found none. The only 2026 Broadcom/CAFC matter that surfaced was TexasLDPC Inc. v. Broadcom Inc., No. 25-1074 — unrelated to the '000 patent and not evidence of any '000-patent appeal. If you have a specific 2026 CAFC docket number, please supply it and I will search that identifier directly.
- Enforcement is effectively historical. The '000 patent shows "Ceased," with adjusted expiration 2021-10-14, and the reissue RE48176 E1 shows "Expired – Lifetime." This makes new CAFC appellate activity on the patent number itself unlikely, which is consistent with the absence of 2026 docket results.
- Claim numbering changes across instruments. Original-grant claims, the reexamination certificate (claims 1, 2, 5 cancelled), and the reissue RE48176 (claims rewritten; new claims 34–49 added) differ. If you need claim-text-exact analysis for a particular date of alleged conduct, the operative version must be matched to that date (original grant vs. post-reexam vs. post-reissue). I have flagged which claim sets derive from which instrument above.
- I could not independently verify the current on-the-record ownership beyond the assignments listed (Global Locate → Broadcom, 2015 → Avago Technologies General IP (Singapore) → Avago Technologies International Sales Pte. Limited); the Google Patents page's "current assignee" field is itself disclaimed as possibly inaccurate.
Generated 9/29/2026, 5:11:07 AM
Cases on file (1)
Group view →Specific litigation cases in our database that name US patent 6651000. The free-form analysis below may also discuss cases beyond this list.
- 337-TA-602U.S. International Trade Commission, Washington, D.C.terminated Jan 15, 2009Complainants prevailed; violation found; limited exclusion order and cease-and-desist orders; investigation terminated.
Defendants: SiRF Technology, Inc., Pharos Science & Applications, Inc., MiTAC International Corp., and 2 others
Other patents asserted: 6606346, 6417801, 6704651, 6937187, 7158080
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research the litigation history for US patent 6651000. Let me search multiple sources.
Let me search for the district court cases and other litigation.
Let me search for the specific district court case numbers and outcomes.
I now have sufficient information. Here is my consolidated report on known litigation involving US Patent 6,651,000 ("Method and Apparatus for Generating and Distributing Satellite Tracking Information in a Compact Format").
Important scope note
US 6,651,000 ("the '000 patent") was asserted alongside several sibling GPS/Assisted-GPS patents owned by Global Locate, Inc. (acquired by Broadcom Corp. in July 2007). Litigation on this patent family unfolded concurrently before the U.S. International Trade Commission (ITC) and the U.S. District Court for the Central District of California (Santa Ana), and then on appeal to the Court of Appeals for the Federal Circuit (CAFC). The '000 patent was expressly found infringed and not invalid in the ITC action. The record does not show the '000 patent being asserted in any separate later action (e.g., against Qualcomm, u-blox, or others).
1. ITC Investigation — Certain GPS Devices and Products Containing Same
- Investigation No.: 337-TA-602
- Complainant(s): Global Locate, Inc. (later joined by Broadcom Corporation, added as complainant Feb. 5, 2008 after acquiring Global Locate)
- Respondent(s): SiRF Technology, Inc.; Pharos Science & Applications, Inc.; MiTAC International Corp.; Mio Technology Ltd., USA; E-TEN Information Systems Co., Ltd.
- Jurisdiction: U.S. International Trade Commission, Washington, D.C.
- Filing/Institution: Complaint filed April 2, 2007; investigation instituted April 30/May 7, 2007
- Patents asserted: U.S. 6,417,801; 6,606,346; 6,651,000; 6,704,651; 6,937,187; 7,158,080
- Key holding on the '000 patent: ALJ Carl C. Charneski (Initial Determination, Aug. 8, 2008) found infringement of claims 1, 2 and 5 of the '000 patent and that all six patents were not invalid or unenforceable. On Jan. 15, 2009, the full Commission issued its Final Determination, modifying certain findings and holding that SiRF directly infringes the '000 patent through its commercial activities.
- Outcome / Status: Violation of 19 U.S.C. § 1337 found. Commission issued a Limited Exclusion Order and Cease and Desist Orders. The orders took effect after the 60-day Presidential review period expired March 16, 2009. Investigation terminated. (The ITC found infringement of the '000 patent by SiRF's SiRFstarIII chips and its InstantFix/InstantGPS products.)
- Source: ITC Notice of Investigation, 72 Fed. Reg. 25,777 (May 7, 2007); ITC Final Determination notice, 74 Fed. Reg. (Jan. 23, 2009); ITC Pub. 4137.
2. CAFC Appeal — SiRF Technology, Inc. v. International Trade Commission
- Case No.: 2009-1262
- Court: U.S. Court of Appeals for the Federal Circuit
- Appellants: SiRF Technology, Inc. (joined by E-TEN, Pharos, MiTAC, Mio)
- Appellee: International Trade Commission
- Intervenor: Broadcom Corp. / Global Locate, Inc.
- Filing date: 2009 (appeal docketed from the Jan. 15, 2009 ITC Final Determination)
- Decision date: April 12, 2010 — 601 F.3d 1319
- Outcome / Status: Affirmed the ITC. The Federal Circuit held: (1) Global Locate had standing to assert the '346 patent; (2) SiRF directly infringed the '000 patent (claims 1, 2, 5) and the '651 patent — rejecting SiRF's "divided infringement" defense because the claim steps of "transmitting" (in the '000 patent) do not require direct transmission; and (3) the asserted method claims ('801/'187) were patent-eligible under the then-controlling Bilski machine-or-transformation test.
- Source: SiRF Tech., Inc. v. Int'l Trade Comm'n, 601 F.3d 1319 (Fed. Cir. 2010); CAFC opinion PDF at cafc.uscourts.gov/opinions-orders/09-1262.pdf.
3. District Court — SiRF Technology, Inc. v. Global Locate, Inc. (and SBCG, Inc.)
- Case No.: 8:06-cv-01216 (C.D. Cal.)
- Court: U.S. District Court for the Central District of California (Santa Ana)
- Plaintiff: SiRF Technology, Inc. (suit initiated Dec. 15, 2006)
- Defendant/Counterclaimant: Global Locate, Inc. and its U.S. distributor SBCG, Inc. (counterclaims filed Jan. 8, 2007)
- Filing date: December 15, 2006 (SiRF complaint); Global Locate answer/counterclaims Jan. 8, 2007
- Patents at issue: On Global Locate's counterclaims — U.S. 6,542,820; 6,560,534; 6,704,651; 6,606,346 (and related patents referenced in the litigation listing, including the '000 family)
- Outcome / Status: The action was stayed in its entirety pending the final results of the ITC investigations (337-TA-602 and the SiRF-filed 337-TA-596). Ultimately, by stipulation, all claims by each side were dismissed without prejudice, each party bearing its own costs and attorneys' fees, after the disputes were resolved through the broader Broadcom–SiRF settlement (see below).
- Source: Unified Patents litigation record for case 8:06-cv-01216 (portal.unifiedpatents.com/litigation/California%20Central%20District%20Court/case/8:06-cv-01216).
4. District Court — Broadcom Corp. v. SiRF Technology, Inc.
- Case No.: 8:08-cv-00546 (C.D. Cal.)
- Court: U.S. District Court for the Central District of California (Santa Ana) — Judge James V. Selna
- Filing date: 2008 (one of two Santa Ana filings; the earlier January 2007 filing asserted four patents, the May 2008 filing added four more)
- Parties: Broadcom Corp. / Global Locate, Inc. v. SiRF Technology, Inc. (later including CSR plc)
- Outcome / Status: This case (with related 8:07-cv-00198) proceeded with reexamination stays, summary-judgment motions, etc., and was resolved as part of the global settlement of all Broadcom–SiRF patent litigation (2009).
- Source: CourtListener docket 4144104 (Broadcom Corp. v. SiRF Technology Inc, 8:08-cv-00546).
5. Related ITC Investigation — Certain GPS Chips (SiRF as complainant)
- Investigation No.: 337-TA-596
- Parties: SiRF Technology, Inc. (complainant) v. Global Locate/Broadcom (respondent)
- Institution: March 13, 2007
- Patents: Primarily SiRF patents U.S. 7,043,363 and 7,091,904
- Outcome: ALJ found SiRF's U.S. 7,043,363 invalid and not infringed (June 13, 2008). This was the companion "counter" ITC action to 337-TA-602.
- Note: I did not find this case on the appended patent page's litigation listings; it is corroborated by expert-witness records referencing it.
Summary table
| Case | Parties | Forum | Number | Filed | Outcome/Status |
|---|---|---|---|---|---|
| ITC Inv. 337-TA-602 | Global Locate/Broadcom v. SiRF, Pharos, MiTAC, Mio, E-TEN | ITC | 337-TA-602 | Apr. 2, 2007 | Violation found; '000 patent infringed; LEO + CDOs; effective Mar. 16, 2009 |
| CAFC appeal | SiRF v. ITC (Broadcom/Global Locate intervening) | CAFC | 2009-1262 | 2009 | Affirmed Apr. 12, 2010, 601 F.3d 1319 |
| SiRF v. Global Locate | SiRF v. Global Locate & SBCG | C.D. Cal. | 8:06-cv-01216 | Dec. 15, 2006 | Stayed; later dismissed without prejudice by stipulation |
| Broadcom v. SiRF | Broadcom/Global Locate v. SiRF | C.D. Cal. | 8:08-cv-00546 | 2008 | Resolved in global 2009 settlement |
| ITC Inv. 337-TA-596 | SiRF v. Global Locate/Broadcom | ITC | 337-TA-596 | Mar. 13, 2007 | SiRF patent 7,043,363 held invalid/not infringed |
Caveats and confidence levels
- High confidence: The ITC 337-TA-602 action, the CAFC 2009-1262 affirmance (which specifically addressed claims of the '000 patent), and the general existence of the C.D. Cal. cases (8:06-cv-01216; 8:08-cv-00546). These are grounded in the ITC Federal Register notices, the CAFC opinion, and the Unified Patents/CourtListener dockets.
- Medium confidence: The exact filing date of 8:08-cv-00546 (2008) and the precise allocation of which patents were asserted in each of the two Santa Ana district-court filings. Press reports indicate fililngs in January 2007 and May 2008, but I could not confirm the specific case number assigned to the January 2007 filing from a primary source; the '000 patent was part of the asserted family in the ITC action and, per the appended patent page, is also linked to the 8:06-cv-01216 matter.
- Lower confidence / not confirmed: Whether the '000 patent itself (as opposed to the family) was separately asserted in the district-court filings versus only at the ITC. The clearest adjudicated finding on the '000 patent is the ITC determination (claims 1, 2, 5 infringed) affirmed by the CAFC.
- Not found: Any subsequent or unrelated litigation asserting the '000 patent (e.g., post-2010 actions), or any action in other U.S. districts. If such exist, they were not surfaced in these searches.
If you need PACER-level docket confirmations (e.g., the exact filing dates and Docket Numbers for the two Santa Ana complaints, or proof of the settlement's dismissal terms), those would require a PACER pull, which these public sources do not fully replicate.
Generated 9/29/2026, 5:11:01 AM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
Current assignee: Global Locate, Inc., Broadcom Corporation
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.
I'll verify the structured data against public sources before drafting.
Structured data says no AIA trials. Let me confirm the reexamination and reissue history, which is where the real claim-level damage lives.
Proceedings overview
AIA trial proceedings on file for US 6,651,000: zero. The USPTO Open Data Portal structured block returns no IPR, PGR, or CBM for this patent, and targeted web searches surfaced none — no IPRxxxx-xxxxx naming 6,651,000 as the challenged patent, from any petitioner, at any time. This is not an oversight: the patent issued 2003-11-18 and its meaningful validity challenge was filed in 2010 as an ex parte reexamination, at a time when IPR/PGR did not exist and CBM review was unavailable for a GPS ephemeris patent. Breakdown by status: active 0 / claims invalidated 0 (via AIA trial) / claims sustained 0 / settled 0 / institution denied 0. The closest analogue to an AIA "claims invalidated" outcome is the ex parte reexamination certificate of 2011-11-15, which cancelled claims 1, 2 and 5 — the same three claims the ITC had found infringed. Combined with the patent's adjusted expiration of 2021-10-14, the defensive posture is stark: there is no live claim of 6,651,000 to assert against a defendant today, and the three claims that ever mattered were cancelled before expiry.
Because the requested per-proceeding template presupposes AIA trials, I apply it below to the two proceedings that actually shaped this patent — the ex parte reexamination and the § 337 / CAFC track — and label each clearly as not an AIA trial.
Reexamination Certificate issued 2011-11-15 — Ex parte reexamination of US 6,651,000 (claims 1, 2, 5 cancelled)
- Type: Ex parte reexamination under 35 U.S.C. §§ 301–307 (not an AIA trial — no PTAB jurisdiction, no APJ panel, no FWD)
- Filed: ODP records the reexamination request with an effective date of 2010-06-08 (event logged 2010-08-31). Caveat: SiRF publicly announced on 2008-08-06 that it had "completed filing" four ex parte reexamination requests against four Broadcom/Global Locate patents asserted in the Santa Ana district court action (https://www.design-reuse.com/news/202515381-sirf-requests-reexamination-of-broadcom-patents-asserted-against-sirf). The ODP record does not name the requester of the '000 reexamination, and the 2008-08-06 request set may or may not have included the '000 patent. I cannot confirm the requester from the structured data.
- Status: Concluded — Reexamination Certificate, first reexamination, mailed 2011-11-15. Verbatim disposition: "CLAIMS 1, 2 AND 5 ARE CANCELLED. CLAIMS 3, 4 AND 6-33 WERE NOT REEXAMINED."
- Judge panel: Not applicable (examiner/CRU, not PTAB). No APJ names exist for this proceeding.
- Petition grounds: Not applied. From the SiRF 10-K disclosure of the parallel 2008 reexamination set, one of the four requests drew a preliminary Office Action dated 2009-03-05 rejecting all 33 claims of a patent, after which the patent owner added 50 proposed new claims on 2009-05-06 (https://www.sec.gov/Archives/edgar/data/[1368358](/patent/1368358)/000119312509121673/df4.htm). The '000 patent has exactly 33 claims, which matches — but the disclosure does not name the patent, so treat this attribution as likely, not confirmed. If it is the '000 patent, the requester's art was § 102/§ 103 prior art "not previously considered by the Patent Office."
- Institution decision: N/A — reexamination is ordered by the CRU on a substantial-new-question-of-patentability finding, not instituted by a panel. I did not locate the order granting reexamination (Reexam Control No. not shown in the ODP block or in my searches), so I will not state a date or an SNQ rationale.
- Final Written Decision: N/A. The equivalent is the certificate: claims 1, 2 and 5 cancelled; claims 3, 4 and 6-33 not reexamined. Note the internal tension worth verifying in the file wrapper: a certificate that lists claims 6–33 as "not reexamined" is unusual if all 33 claims had earlier been rejected. Do not assume claims 6–33 were substantively tested — the certificate says they were not.
- Settlement / termination: No settlement mechanism applies. The proceeding ran to a certificate.
- Appeal: No appeal of the reexamination certificate is recorded in the ODP data. The separate reissue application Ser. No. 13/237,550, filed 2011-09-20, which matured into US RE48176 E1 (granted 2020-08-25, now held by Avago Technologies International Sales Pte. Ltd.), is the follow-on vehicle — filed less than two months after the certificate. Because it was filed more than two years after the 2003-11-18 grant of the original patent, 35 U.S.C. § 251(d) barred any enlarging reissue; the reissue could only narrow or correct. The RE48176 claims are a separate patent document and require their own review; do not assume they mirror the '000 claims.
- Defensive value: Claims 1, 2 and 5 are dead. Any infringement theory, demand letter, or damages model built on them after 2011-11-15 is untenable. Claims 6–33 were never reexamined — but that point is academic given the 2021-10-14 expiry.
ITC Inv. No. 337-TA-602 — Global Locate, Inc. v. SiRF Technology, Inc. et al. (the litigation that drove the '000 patent's invalidation)
- Type: Section 337 investigation, U.S. International Trade Commission (not an AIA trial)
- Filed: Complaint filed 2007-04-02; investigation instituted 2007-05-07, 72 FR 25777
- Status: Concluded. Commission Final Determination 2009-01-15 finding a violation as to all six asserted patents; limited exclusion order and cease-and-desist orders issued the same day; Federal Circuit affirmed in all respects on 2010-04-12; a formal enforcement proceeding was instituted 2010-12-07
- Judge panel: ALJ evidentiary hearing and a 216-page Initial Determination issued 2008-08-08. The notice of investigation designates ALJ Robert L. Barton, Jr. as presiding (https://regulations.justia.com/regulations/fedreg/2007/05/07/E7-8624.html), while Broadcom's contemporaneous press release credits ALJ Carl C. Charneski (https://semiiphub.com/pulse/news/gps-patents). The case appears to have been reassigned; I cannot resolve the discrepancy from the sources reviewed.
- Petition grounds (asserted claims): The '000 patent was asserted as to claims 1–5, 9, 10, 11–14, 29–31, and 33. The ALJ found infringement of claims 1, 2, and 5 of the '000 patent only, and found all six patents not invalid and not unenforceable. Invalidity was adjudicated on § 102/§ 103 prior art and § 112-type defenses raised by respondents, and the Commission also addressed § 101 subject matter under In re Bilski for method claims of the '801 and '187 patents.
- Institution decision: Instituted 2007-05-07. Complaint amended 2008-02-05 to terminate claims 1, 3, 8, 9, 10, and 23 of the '346 patent and add Broadcom as a co-complainant (https://www.federalregister.gov/documents/full_text/xml/2008/03/03/E8-3979.xml).
- Final Written Decision equivalent: Commission opinion of 2009-01-15 — modified the ALJ by finding direct infringement and that SiRF "exercises control over end users of the GPS receivers so as to cause infringement of the '651 and the '000 patents." Claims found infringed: '801 claims 1, 2, 11; '346 claims 4, 11; '000 claims 1, 2, 5; '651 claims 1, 2; '187 claims 1, 9; '080 claims 1, 2, 22 (ITC Pub. 4137, https://www.usitc.gov/intellectual_property/documents/pub4137.pdf).
- Settlement / termination: No settlement. The remedial orders were enforced, and SiRF redesigned its software to exit the exclusion order's scope (Customs determination letter dated 2009-05-21, received 2009-05-29, per SiRF's F-4).
- Appeal: SiRF Technology, Inc. v. International Trade Commission, No. 2009-1262 (Fed. Cir. Apr. 12, 2010) — precedential opinion reported at 601 F.3d 1319. Issues: (i) Global Locate's standing to assert the '346 patent without co-owner Magellan, given inventor employment agreements; (ii) whether SiRF was a direct infringer given that customers/end users performed the "transmitting"/"communicating" steps of '000 claim 1 and '651 claim 1; and (iii) § 101 patentability of certain method claims under Bilski. Disposition: affirmed in all respects. The court construed "communicating"/"transmitting" as not limited to direct communication, preserving the single-actor infringement theory. Link: https://www.courtlistener.com/opinion/[1320748](/patent/1320748)/sirf-technology-inc-v-international-trade-commission/ and http://cafc.uscourts.gov/opinions-orders/09-1262.pdf
- Related district court track: ODP litigation data lists California Central District Court, 8:06-cv-01216; Broadcom/Global Locate also filed in the Santa Ana division in January 2007 and again on 2008-05-14 (the complaint that triggered SiRF's August 2008 reexamination requests). SiRF's first stay motion was denied by Judge James V. Selna on 2008-09-15 without prejudice; a renewed motion was pending as of mid-2009.
- Defensive value: The ITC is the reason the '000 patent is now worth little. It generated the exclusion order Broadcom wanted — and it produced the invalidity record that led to the cancellation of claims 1, 2 and 5 in reexamination eighteen months after the Commission's Final Determination. A defendant today inherits a patent whose only adjudicated claims were found infringed and then cancelled — the worst possible posture for an asserted patent.
Strategic summary
Claim status. CANCELLED: claims 1, 2 and 5 (reexamination certificate, 2011-11-15). NOT REEXAMINED / NEVER ADJUDICATED: claims 3, 4 and 6–33 — these were, per the certificate, outside the scope of the reexamination, and the ITC found no infringement of them (it found infringement only of claims 1, 2 and 5). Critically, there are no surviving independent claims: claim 1 is cancelled; claim 16 (the second independent method claim) and claim 26 (the independent "creating a compact orbit model" claim) were never tested but are expired. Separately, US RE48176 E1 issued 2020-08-25 out of reissue application Ser. No. 13/237,550; because it was filed in 2011, more than two years after the 2003 original grant, § 251(d) forecloses any claim of broadened scope. Its claims are a distinct document that a defendant must review on its own terms, but its term is coextensive with the original — both expired on the adjusted date of 2021-10-14.
Estoppel landscape. There is no § 315(e)(2) estoppel against anyone, because no IPR/PGR was ever instituted. The estoppel that matters here is different and older: the ITC Final Determination of 2009-01-15, affirmed at 601 F.3d 1319, established that SiRF's products read on '000 claims 1, 2 and 5 — findings that the reexamination then mooted by cancelling those claims. For a defendant today, the practical question is not which prior-art grounds remain available but whether any enforceable claim remains: none does as of 2021-10-14. Any prior-art ground already "raised or reasonably could have been raised" is irrelevant when the asserted claims are cancelled and the patent has expired. If a demand is nonetheless made on the reissue patent RE48176, the reexamination file, the ITC record, and the CAFC opinion are all fair game as § 282 defenses.
Pattern signals. (1) No repeat-petitioner pattern exists because no AIA petitions exist; the early-2010s challenge was channelled into ex parte reexamination, a forum with no petitioner estoppel and no petitioner participation after filing — which is exactly why the cancellation of claims 1, 2 and 5 caught the patent owner by surprise relative to the ITC win. (2) The patent owner did not pursue PTAB appeals (none exist); the only appellate activity is SiRF's appeal of the ITC determination at No. 2009-1262, which Global Locate/Broadcom won. (3) No defensive aggregator (e.g., Unified Patents) appears in the chain. Unified Patents appears in the Google Patents record only as the publisher of the litigation-data hyperlink, not as a petitioner or party — do not mistake that citation for a Unified Patents IPR. (4) The ownership chain (Global Locate → Broadcom → Avago/Broadcom International Sales) and the reissue filing in 2011 are the hallmarks of a portfolio being repositioned after a reexamination loss, not of an aggressive assertion campaign against the '000 patent itself.
Recommended next steps
- If you are a defendant and a demand letter cites US 6,651,000: the answer is that claims 1, 2 and 5 were cancelled by the reexamination certificate of 2011-11-15 (verbatim: "CLAIMS 1, 2 AND 5 ARE CANCELLED"), and that the patent's adjusted expiration was 2021-10-14. A cancelled claim cannot be infringed and an expired patent cannot support injunctive relief or ongoing royalties. Pull the reexamination certificate from USPTO PatentCenter and the file wrapper (Reexam Control No. unknown to me — obtain it from the '000 file history) as your primary exhibits.
- Do not build any defense on § 315(e)(2). There is nothing to estop. Build instead on (a) the cancellation certificate, (b) the 2021-10-14 expiry, and (c) if the reissue is asserted, § 251(d) and the reissue file wrapper.
- If a demand cites US RE48176 E1: that is a different document. Verify its claim set, its expiration date, and whether any claim term maps onto your product. Because broadening was statutorily barred, expect narrow claims — but confirm rather than assume.
- Verify two open items in the file wrapper before relying on them: (i) the identity of the reexamination requester and the reexamination control number for the '000 patent, and (ii) whether the "all 33 claims rejected" Office Action of 2009-03-05 and the addition of 50 proposed claims on 2009-05-06 belong to the '000 patent or to one of the other three patents in the 2008 SiRF reexamination set. I flagged both as unconfirmed above and will not assert them as fact.
- If you were looking for PTAB activity: there is none, and its absence is itself the signal. This patent never attracted an AIA petition — but only because reexamination got there first and cancelled the asserted claims in 2011, and the term expired in 2021. A patent with no PTAB history and no live claims is not "hardened"; it is spent.
Generated 9/29/2026, 5:11:27 AM
Ownership chain (7)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2002-01-23 · reel 012512/0789 · Assignment
Frank van Diggelen; Charles Abraham; James W. LaManceGlobal Locate, Inc.
2015-09-08 · recorded 2015-09-16 · reel 036617/0654 · Assignment
Global Locate, Inc.Broadcom Corporation
acquisition
2016-02-01 · recorded 2016-02-11 · reel 037806/0001 · Security Agreement
Broadcom CorporationBank of America, N.A., as Collateral Agent
securitization
2017-01-19 · recorded 2017-02-03 · reel 041712/0001 · Release
Bank of America, N.A., as Collateral AgentBroadcom Corporation
securitization
2017-01-20 · recorded 2017-02-01 · reel 041706/0001 · Assignment
Broadcom CorporationAvago Technologies General IP (Singapore) Pte. Ltd.
internal reorg
2018-09-05 · recorded 2018-10-04 · reel 047195/0026 · Merger
Avago Technologies General IP (Singapore) Pte. Ltd.Avago Technologies International Sales Pte. Limited
Correspondent: · Foley & Lardner
internal reorg
? · recorded 2018-11-05 · Correction
Avago Technologies General IP (Singapore) Pte. Ltd.Avago Technologies International Sales Pte. Limited
Correspondent: · Foley & Lardner
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.
I'll research the assignment record and related ownership details before assembling the analysis.
Let me dig into the specific assignment records, correspondents, and the reissue/reel details.
Assignment & Ownership Analysis — US Patent 6,651,000 B2
Scope note: The Google Patents legal-events record for US 6,651,000 supplies the reel/frame numbers and execution/recording dates quoted below; those are treated as the authoritative recording data. Correspondent-of-record fields are only partially retrievable from public mirrors and are flagged where confidence is low. USPTO Assignment Center search: https://assignmentcenter.uspto.gov/ (mirror: https://assignment.uspto.gov/patent/index.html → search "6651000").
Inventors
| Inventor | Employer at time of filing (2001-07-25) | Notes |
|---|---|---|
| Frank van Diggelen | Global Locate, Inc. (San Jose, CA) | Co-founder / chief technologist of Global Locate. Signed assignment 2001-11-29→12-01. |
| Charles Abraham | Global Locate, Inc. (San Jose, CA) | Signed assignment 2001-11-29→12-01. |
| James W. LaMance | Global Locate, Inc. (San Jose, CA) | Signed assignment 2001-11-29→12-01. |
Pattern check — inventors departing the original assignee within 12 months of filing (fire-sale precursor): Not present. All three inventors were Global Locate employees and executed the confirmatory assignment to Global Locate in late 2001, only ~4 months after filing — the ordinary startup employment-assignment step, not a departure. All three remained with Global Locate through Broadcom's July 2007 acquisition of the company. There is no signal of inventors bailing out shortly after filing. (Lower confidence, not verified this session: van Diggelen is publicly associated with Google in more recent years; that is a post-acquisition career move and irrelevant to the fire-sale test.)
Original assignee
Global Locate, Inc. (San Jose, CA; founded 1999; ~61 employees; fabless).
- Primary line of business: GPS and Assisted-GPS (A-GPS) semiconductors and software — the "Hammerhead" single-chip CMOS GPS product line, plus a worldwide reference network and Long-Term Orbit (LTO) assistance service. This is squarely the commercial embodiment of the "compact ephemeris distributed over a network, expanded at the receiver" concept claimed here.
- Did they ship a product embodying the claims? Yes. Global Locate's A-GPS chips/LTO service were shipping in commercial devices (e.g., the TomTom One PND; HP and Sharp smartphones), and its reference network distributed orbit/clock assistance data to receivers — the claimed architecture.
- Current status: Acquired, no longer independent. Broadcom Corporation announced the acquisition on 2007-07-12 and closed it 2007-07-16 for ~$143–146M cash plus up to $80M contingent (widely reported at up to ~$226M). Broadcom stated the deal added "more than 175 issued and pending U.S. and foreign patents" — the '000 patent's family among them. No bankruptcy or Chapter 7/11 proceeding was found for Global Locate (it was acquired as a solvent going concern). The brand was absorbed into Broadcom's Wireless Connectivity Group and the assets now sit inside the Broadcom/Avago group described below.
Assignment timeline
All entries below are recorded USPTO assignment events for US 09/915,219 → US 6,651,000. Order is chronological by execution/effective date, with recording date noted.
2001-11-29 → 2001-12-01 (executed) / recorded 2002-01-23 — Reel 012512/0789
- Conveyance: Assignment (Assignment of Assignors' Interest)
- Assignor: Frank van Diggelen; Charles Abraham; James W. LaMance
- Assignee: GLOBAL LOCATE INC., California
- Correspondent: Not retrievable from the public record surfaced; no recurring correspondent determinable. (Unclear.)
- Context: Founders'/employees' confirmatory assignment perfecting title in the original assignee — standard startup patent-assignment step, not a transfer.
2015-09-08 (effective) / recorded 2015-09-16 — Reel 036617/0654
- Conveyance: Assignment (Assignment of Assignor's Interest)
- Assignor: GLOBAL LOCATE, INC.
- Assignee: BROADCOM CORPORATION, California
- Correspondent: Broadcom's IP counsel of record (firm name not confirmed on this record; the same reel 036617/0654 appears as the Global Locate→Broadcom mass assignment on sibling GPS patents in this family). (Low confidence on the individual attorney/firm.)
- Context: Acquisition. This is the recording of the 2007 Broadcom purchase of Global Locate — note it was recorded ~8 years after the deal closed, evidently as part of a bulk portfolio re-recording (the same reel covers many Global Locate/Broadcom GPS patents). This is a housekeeping recording, not a contemporaneous transfer.
2016-02-01 (effective) / recorded 2016-02-11 — Reel 037806/0001
- Conveyance: Security Agreement (Patent Security Agreement)
- Assignor: BROADCOM CORPORATION
- Assignee: BANK OF AMERICA, N.A., as Collateral Agent, North Carolina
- Correspondent: Broadcom's IP counsel of record (firm not confirmed). (Low confidence.)
- Context: Securitization. Broadcom pledged this patent (among a large portfolio) as collateral under its credit facilities — a financing lien, not a change in beneficial ownership.
2017-01-20 (effective) / recorded 2017-02-01 — Reel 041706/0001
- Conveyance: Assignment (Assignment of Assignor's Interest)
- Assignor: BROADCOM CORPORATION
- Assignee: AVAGO TECHNOLOGIES GENERAL IP (SINGAPORE) PTE. LTD., Singapore
- Correspondent: Broadcom/Avago IP counsel of record (firm not confirmed). (Low confidence.)
- Context: Internal reorganization implementing the 2016 Avago Technologies/Broadcom combination — operating-company patent assets were consolidated into the Singapore IP-holding subsidiary.
2017-01-19 (effective) / recorded 2017-02-03 — Reel 041712/0001
- Conveyance: Release (Termination and Release of Security Interest in Patents)
- Assignor: BANK OF AMERICA, N.A., as Collateral Agent
- Assignee: BROADCOM CORPORATION
- Correspondent: Broadcom's IP counsel of record (firm not confirmed). (Low confidence.)
- Context: Lien release clearing the 2016 Bank of America security interest in connection with the reorg (note the release is recorded after the assignment it follows).
2018-10-04 (recorded) — Reel 047195/0026
- Conveyance: Merger
- Assignor: AVAGO TECHNOLOGIES GENERAL IP (SINGAPORE) PTE. LTD.
- Assignee: AVAGO TECHNOLOGIES INTERNATIONAL SALES PTE. LIMITED, 1 Yishun Avenue 7, Singapore 768923
- Correspondent: A public assignment mirror recording this same Avago General IP → Avago International Sales merger lists the correspondent as Foley & Lardner LLP, 3000 K Street N.W., Suite 600, Washington, D.C. 20007 (flag: I could not confirm that the Foley & Lardner correspondent attaches specifically to reel 047195/0026 versus a companion mass-merger recording; treat as moderate-to-low confidence for the '000 patent).
- Context: Internal reorganization / universal-succession merger — the Singapore IP-holder was merged into the group's international sales entity; no arm's-length sale.
2018-11-05 (recorded) — Corrective Assignment (corrects Reel 047195/Frame 0026)
- Conveyance: Corrective Assignment
- Assignor/Assignee: Same parties as 047195/0026
- Correspondent: As above (Foley & Lardner LLP, per the merger recording). (Moderate-to-low confidence.)
- Context: Correction only — fixes the effective date of the 2018 merger previously recorded at 047195/0026 to 2018-09-05. No change in ownership.
Post-grant prosecution instrument (not an assignment):
- 2011-09-20 — Reissue application 13/237,550 filed (→ US RE48176 E1, granted 2020-08-25, currently shown as Avago). Filed roughly contemporaneously with the 2011-11-15 ex parte reexamination certificate that cancelled claims 1, 2 and 5 — i.e., immediately after the asserted claims were killed in reexam, the owner rebuilt a parallel instrument (new claims 34–49 reciting exclusion of the harmonic parameters).
Data caveat / flagged discrepancy: The '000 patent's Google record shows the Avago merger at 047195/0026, whereas a sibling Global Locate/Broadcom patent (US 7,945,387) shows the same merger at 047196/0687 (corrected at ~04763x). These near-identical reel numbers suggest the merger was recorded across multiple reels/segments; I could not reconcile the exact segment covering the '000 patent beyond what the '000 record itself states.
Timeline diagram
timeline
title Ownership of US 6651000
2001 : Inventors assign to Global Locate
2003 : Patent issued to Global Locate
2007 : Broadcom acquires Global Locate
2010 : Ex parte reexamination requested
2011 : Claims 1 2 5 cancelled in reexam
: Reissue application filed
2015 : Recorded assignment to Broadcom
2016 : Security interest to Bank of America
2017 : Assigned to Avago General IP Singapore
: Bank of America releases security interest
2018 : Merger into Avago International Sales
2020 : Reissue RE48176 granted
2021 : Patent expires
NPE / troll-pattern signals
1. Shell-entity transfer — NOT PRESENT.
The chain never leaves operating semiconductor companies. Every assignee — Global Locate (GPS chip/software maker shipping the Hammerhead line), Broadcom Corporation, Avago Technologies General IP (Singapore) Pte. Ltd., and Avago Technologies International Sales Pte. Limited — is part of a single publicly listed, product-shipping semiconductor group (Broadcom/Avago). Although "Avago Technologies General IP (Singapore) Pte. Ltd." carries an "IP" name and a registered-office address at 1 Yishun Avenue 7, Singapore, the evidence shows a wholly-owned holding subsidiary of an operating parent used for internal portfolio consolidation (Reels 041706/0001 and 047195/0026), not a single-purpose Delaware/Texas licensing shell parked at a registered-agent service. No product-less NPE LLC appears.
2. Known asserter in the chain — NOT PRESENT.
Neither the current assignee nor any prior assignee matches the named NPE lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Spangenberg entities, etc.). The asserting parties here — Global Locate/Broadcom against SiRF (ITC 337-TA-602) — are operating competitors in the GPS chip market, not an NPE asserting a purchased patent. The transfer history (Reels 036617/0654, 041706/0001, 047195/0026) reflects acquisition and corporate reorganization, not transfer to an assertion vehicle.
3. Repeat correspondent across the chain — UNCLEAR / insufficient data.
Correspondent fields were not retrievable for Reels 012512/0789, 036617/0654, 037806/0001, 041706/0001, or 041712/0001 from the sources available in this session. The only correspondent surfaced anywhere in this chain is Foley & Lardner LLP (Washington, D.C.) on a Broadcom/Avago merger assignment, with moderate-to-low confidence that it attaches to the '000 patent's 047195/0026 recording specifically. Because the signal requires recurrence by the same attorney/firm, and I can confirm at most a single (uncertain) appearance, I cannot score this as present. Recommended follow-up: pull each reel/frame at Assignment Center and record the correspondent attorney for 036617/0654, 037806/0001, 041706/0001, 041712/0001, and 047195/0026.
4. Cascading transfers — NOT PRESENT.
Although there is a 2015→2016→2017→2018 cluster of four recordings, they are (i) a late mass-recording of a 2007 acquisition, (ii) a financing lien, (iii) a lien release, and (iv) an internal merger — all between affiliates of one listed company, spanning 17 years end-to-end. This is not the hallmark pattern of multiple chained LLCs in <24 months sharing a correspondent address or common principals.
5. Pre-litigation transfer — NOT PRESENT (nuance noted).
The offensive assertion (ITC complaint, filed April 2007) predates the recorded Broadcom assignment (effective 2015, Deal closed July 2007). The ownership movement to the eventual asserter (Broadcom, via Global Locate) happened during/after the litigation started, and it was a corporate acquisition of the whole company — not a fresh transfer of this patent to enable assertion. There is no assignment dated within 6 months before a first suit naming the '000 patent.
6. Bankruptcy fire-sale — NOT PRESENT.
Global Locate was acquired as a going concern for ~$143–146M cash plus an earn-out; no Chapter 7/11, liquidation, or §363 sale was found for any assignee in this chain.
7. Privateering — NOT PRESENT.
Broadcom asserted the '000 patent (through its acquired Global Locate subsidiary) directly against a competitor, SiRF Technology, with Broadcom itself joining the ITC complaint (Feb. 2008). This is classic operating-company-versus-competitor assertion, not an operating company funneling patents to a proxy NPE. The later Avago-entity campaigns (e.g., Avago v. Realtek in the UPC/German courts, per the D. Del. filings) likewise show the operating group litigating its own patents and products.
8. Defensive aggregator — NOT PRESENT.
The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. Ownership stays inside the Broadcom/Avago group through the reissue RE48176 and to expiration.
Verdict
Operating-company assertion.
The ownership chain runs inventor → Global Locate, Inc. (Reel 012512/0789, 2002) → Broadcom Corporation (Reel 036617/0654, eff. 2015-09-08) → Avago Technologies General IP (Singapore) Pte. Ltd. (Reel 041706/0001, eff. 2017-01-20, recorded 2017-02-01) → Avago Technologies International Sales Pte. Limited (Reel 047195/0026, 2018-10-04 merger, corrected 2018-11-05). Every assignee is a product-shipping semiconductor operating company — Global Locate shipped the Hammerhead A-GPS chips and LTO service embodying these claims, and its acquirer used the patent to sue a direct market competitor (SiRF) at the ITC. No shell LLC, no named NPE, no chained-LLC cascade, no bankruptcy sale, and no defensive-aggregator terminus appears; the only non-ownership events are a 2016 Bank of America collateral lien (Reel 037806/0001) released in 2017 (Reel 041712/0001). This is a straightforward legacy operating-company portfolio, not an NPE chain.
Verification link: https://assignment.uspto.gov/patent/index.html#/patent/search?q=6651000 (and https://assignmentcenter.uspto.gov/ → search patent number 6651000).
Confidence summary
- High confidence: The 2001 inventor→Global Locate assignment (Reel 012512/0789); the Broadcom, Bank of America, Avago General IP, and release reels/dates; Global Locate's product business and the ~$143M Broadcom acquisition; the absence of any NPE, bankruptcy, or defensive-aggregator link.
- Moderate confidence: The characterization of Reel 041706/0001 as internal reorg incident to the 2016 Avago/Broadcom combination; the merger reel mapping (047195/0026).
- Low confidence / unresolved: All correspondent-of-record fields (only Foley & Lardner LLP surfaced, on an Avago merger recording, and I could not confirm it attaches to the '000 patent's specific reel/frame); the exact reel segment for the Avago merger given the sibling-patent discrepancy (047195/0026 vs 047196/0687). These should be confirmed by pulling each reel/frame directly at Assignment Center, since a same-correspondent recurrence across 036617/0654, 041706/0001, and 047195/0026 would be the only way this chain could ever move toward an "NPE — moderate" call — and nothing in the evidence so far suggests it would.
Generated 9/29/2026, 5:11:57 AM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research the prior art citations for US 6,651,000, verifying against the authoritative patent text and the USPTO record.
Let me verify the key references' content to assess § 102 relevance.
Prior-Art Analysis — US 6,651,000 B2
"Method and apparatus for generating and distributing satellite tracking information in a compact format"
Application US 09/915,219 · Filed 2001‑07‑25 · Issued 2003‑11‑18 · Inventors van Diggelen, Abraham, LaMance · Original assignee Global Locate, Inc.
Litigation note carried forward from prior sections: Claims 1, 2 and 5 were cancelled in ex parte reexamination (reexam certificate 2011‑11‑15); claims 3–4 and 6–33 were not reexamined. Any § 102 mapping below must be read against the operative claim version for the relevant date (original grant vs. post-reexam vs. RE48176). Claims 1/2/5 no longer exist as granted claims.
Sourcing note (per operating rules): The reference list below is taken verbatim from the authoritative full patent text (Google Patents "Patent Citations (17)" / "Citations (17)" section) — https://patents.google.com/patent/US6651000/en. I did not substitute or "correct" any number. Descriptive content for key references was verified against the references' own primary documents.
0. Analytical framework
Pre‑AIA § 102 applies (application filed 2001‑07‑25). For each reference I give:
- § 102(b) — US patent issued more than one year before 2001‑07‑25 (i.e., on or before 2000‑07‑25);
- § 102(e) — US patent granted on an application filed before the applicant's invention date (here, conservatively, before 2001‑07‑25);
- § 102(a) — where pertinent.
Critical caution: None of these seventeen references appears to have been applied as an anticipatory (single‑reference) rejection that survived to issuance. They function in the file primarily as background and § 103 combination art for the general Assisted‑GPS architecture, and — for the compaction‑specific teaching — chiefly as § 103 references. A reference "potentially anticipates" a claim only if it discloses every element; several below come close on the broad architecture claims (1/16/29) but none discloses the core compaction step (zeroing/removing the 6 harmonic terms and re‑fitting the remaining 9, or its equivalents) that the patent treats as inventive.
1. The seventeen examiner-cited references
A. Highest relevance — "compact/partial ephemeris over a communication link"
1. US 6,134,483 A — Vayanos (Qualcomm)
- Title: Method and apparatus for efficient GPS assistance in a communication system
- Filed: 1999‑02‑12 · Issued: 2000‑10‑17 · § 102(e)
- Description: Transmits "efficient" GPS assistance from a network to a mobile — i.e., a reduced/format‑tailored assistance message, distinguishing itself from retransmitting the full ephemeris.
- Potential § 102 mapping: Claim 1 (extract STD, represent in a first format, transmit to remote receiver) and its dependents 9 (fewer bits to encode) and 16/22 (fewer orbit terms / fewer bits). This is the strongest single candidate for the "compact first format" limitation.
2. US 6,313,787 B1 — King, Geier, Zhao, Hart (Motorola)
- Title: Method and apparatus for assisted GPS protocol
- Filed: 1999‑11‑12 · Issued: 2001‑11‑06 · § 102(e)
- Description (verified): Explicitly reduces "the number of bits required to be transferred to each handset," including "compression of the differential correction broadcast message," delta/differential correction values representing a difference from a prior ephemeris value, and compression "based upon RTCM standard" (claims 16–20, 26).
- Potential § 102 mapping: Claims 9, 16, 22 (data requiring fewer bits / fewer orbit terms); claim 8 (a term "defined as a number with lower resolution") is closely approached by the "delta correction values" teaching; claims 26–28 (adjusting a term set) by analogy to delta‑adjustment of ephemeris values. A very strong § 103 anchor.
3. US 6,115,977 A — Vannucci (Lucent Technologies)
- Title: Telecommunications-assisted satellite positioning system
- Filed: 1997‑09‑11 · Issued: 2000‑09‑12 · § 102(e) (issued ~7 weeks after the 2000‑07‑25 § 102(b) cutoff, so NOT § 102(b))
- Description (verified): An auxiliary system acquires ephemeris information, "partially process[es]" it, and transmits the partially processed information to the wireless terminal "in a form that is useful to the wireless terminal," which then uses it to acquire ranging signals.
- Potential § 102 mapping: Closest structural analogue to claim 1 (steps a–d) and claim 16 (transmitted subset expanded/used at the receiver), plus claims 4, 10, 11, 13. The "partially processed … useful form" language is the best match to "first format (compact) → second format (receiver‑native)" among the cited art.
4. US 6,215,441 B1 — Moeglein, Sheynblat, Krasner (SnapTrack)
- Title: Satellite positioning reference system and method
- Filed: 1997‑04‑15 · Issued: 2001‑04‑10 · § 102(e)
- Description (verified): Reference receivers transmit "a representation of at least a portion of a satellite navigation message"; the spec expressly notes that "only certain segments of the satellite navigation message may be sent … in order to lower the bandwidth requirements."
- Potential § 102 mapping: Claims 16–19 (portion → fewer terms → expand) and claim 26 (reduce the term set). Strong § 103 combination with refs 1–2.
5. US 6,064,336 A — Krasner (SnapTrack)
- Title: GPS receiver utilizing a communication link
- Filed: 1995‑10‑09 · Issued: 2000‑05‑16 · § 102(b) (examiner‑marked *)
- Description: A GPS receiver that obtains satellite information (including a subset of ephemeris) over a wireless communication link rather than from the satellite.
- Potential § 102 mapping: Claims 1, 10, 13, 14 and apparatus claim 29 (remote GPS receiver receiving formatted orbit data over a link). Undermines novelty of the broad architecture claim but not the compaction step.
6. US 6,411,899 B2 — Kao, Helms, Gudat et al. (Trimble Navigation)
- Title: Position based personal digital assistant
- Filed: 1996‑10‑24 · Issued: 2002‑06‑25 · § 102(e) (examiner‑marked *)
- Description: Position‑based PDA (the Tendler-type architecture) — relevant because the '000 specification expressly contemplates loading orbit data via "the cradle for a personal digital assistant (PDA)" and Bluetooth.
- Potential § 102 mapping: Claim 13 (wireless link) and the loading/transfer aspects underpinning claim 1; background for claim 11.
7. US 6,212,543 B1 — Ericsson
- Title: Location system combining ranging measurements from GPS and cellular networks
- Filed: 1998‑05‑28 · Issued: 2001‑06‑26 · § 102(e)
- Potential § 102 mapping: Claims 1, 10, 11, 13 (Assisted‑GPS architecture).
8. US 6,067,045 A — Hughes Electronics
- Title: Communication network initialization apparatus and method for fast GPS‑based positioning
- Filed: 1998‑09‑01 · Issued: 2000‑05‑23 · § 102(b)
- Potential § 102 mapping: Claims 1, 10, 13 (ephemeris delivered via communication network for fast fix).
9. US 6,188,354 B1 — Qualcomm
- Title: Method and apparatus for determining the location of a remote station in a CDMA communication network
- Filed: 1999‑03‑29 · Issued: 2001‑02‑13 · § 102(e)
- Potential § 102 mapping: Claims 1, 10, 13, 14 (position of a remote receiver via network‑supplied data, no receiver‑position feedback required).
10. US 6,211,819 B1 — Motorola
- Title: Mobile station location determination in a radio communication system
- Filed: 1999‑08‑27 · Issued: 2001‑04‑03 · § 102(e)
- Potential § 102 mapping: Claims 1, 10, 11 (mobile station uses network‑provided satellite data).
11. US 6,433,735 B1 — Ericsson
- Title: Position detection system integrated into mobile terminal
- Filed: 2000‑09‑07 · Issued: 2002‑08‑20 · § 102(e)
- Potential § 102 mapping: Claims 1, 10, 11, 29 (integrated mobile terminal / remote receiver architecture). Note: later‑issued than the '000 patent, so only § 102(e)/(a) status, never § 102(b).
12. US 6,204,804 B1 — Telefonaktiebolaget LM Ericsson
- Title: Method for determining object movement data
- Filed: 1998‑10‑30 · Issued: 2001‑03‑20 · § 102(e)
- Potential § 102 mapping: Claim 1 generally (satellite‑derived motion/position in a radio system).
13. US 5,812,087 A — Krasner (SnapTrack)
- Title: Method and apparatus for satellite positioning system based time measurement
- Filed: 1997‑02‑03 · Issued: 1998‑09‑22 · § 102(b)
- Potential § 102 mapping: Claim 11 (SPS receiver context); background for Assisted‑GPS acquisition.
14. US 6,078,284 A — Qualcomm
- Title: Passive position determination using two low‑earth orbit satellites
- Filed: 1996‑09‑30 · Issued: 2000‑06‑20 · § 102(b)
- Potential § 102 mapping: Broad claim 1 architecture; the '000 spec itself says the invention applies to GLONASS/GALILEO "or other satellite systems," so LEO‑based teaching is background, not anticipating.
15. US 5,920,278 A — Gregory D. Gibbons
- Title: Method and apparatus for identifying, locating, tracking, or communicating with remote objects
- Filed: 1997‑05‑28 · Issued: 1999‑07‑06 · § 102(b)
- Potential § 102 mapping: Background re remote‑object tracking; weak on any specific '000 claim.
16. US 5,444,450 A — Motorola
- Title: Radio telecommunications system and method with adaptive location determination convergence
- Filed: 1993‑08‑11 · Issued: 1995‑08‑22 · § 102(b)
- Potential § 102 mapping: Background only (radio‑based location convergence).
17. US 5,613,193 A — Kokusai Denshin Denwa Co. Ltd.
- Title: Compensation of frequency offset
- Filed: 1993‑07‑05 · Issued: 1997‑03‑18 · § 102(b)
- Potential § 102 mapping: Peripheral — wireless‑link frequency‑offset compensation; no '000 claim element is disclosed. Cited for general wireless‑communication context.
2. Non-patent citation (NPL)
- "Copy of International Search Report dated May 29, 2003 for corresponding PCT application PCT/US02/23282."
- This is the ISR for the PCT sibling of the '000 patent (published as WO 03/010912 A2). The EPO search‑report record for the family (EP 1417798 A4) states "No further relevant documents disclosed" and points back to the WO 03/010912 references — indicating the examiner‑cited art came largely from the US IDS rather than adding new anticipatory material. No § 102 anticipatory teaching is supplied by the ISR itself.
3. Additional prior art cited in the family / background (not in the 17, but relevant)
These appear in the patent's "Family Cites Families (135)" list and/or are explicitly discussed/incorporated by reference in the '000 specification. They are the true conceptual starting point and should not be ignored in any invalidity/validity study:
| Reference | Filed / Issued | Role |
|---|---|---|
| US 4,445,118 A (NASA) | 1981‑05‑22 / 1984‑04‑24 | The foundational Assisted‑GPS patent, expressly discussed in the '000 Background ("collects satellite orbit information at a GPS reference station, and transmits the information to the remote GPS receiver via a wireless transmission"). Best § 102(b) art for the broad claim 1 architecture. |
| US 5,365,450 A (Stanford Telecommunications) | 1992‑12‑17 / 1994‑11‑15 | Expressly incorporated by reference in the '000 spec as the source of "standard ephemeris message data" and for producing STD. § 102(b) — directly bears on the "second format = standard ephemeris" concept (claims 5, 12, 21). |
| U.S. App. Ser. No. 09/875,809 (filed 2001‑06‑06) | priority 2001‑06‑06 | Expressly cross‑referenced/incorporated: the source of the long‑term STD that the '000 compacts. Now US 6,542,820 / US 6,560,534 (Global Locate). Not "prior art" to the '000 if same inventive entity — but highly relevant to any double‑patenting / § 102‑in‑view‑of‑§ 103 analysis. |
| US 6,411,892 B1 (van Diggelen, Global Locate) | 2000‑07‑13 / 2002‑06‑25 | Wide‑area reference network for propagating ephemeris; cited as X‑art against later Motorola applications. |
4. Ranking — "most relevant prior art for US 6,651,000"
- US 6,411,899 B2 / US 4,445,118 A / US 6,064,336 A — establish the entire "get orbit data at a station → send to remote receiver over a link" architecture (broad claims 1, 29).
- US 6,115,977 A (Lucent) — partially processed ephemeris sent in a "useful form" to the terminal: closest to the first‑format → second‑format recitation of claim 1.
- US 6,215,441 B1 (SnapTrack) — transmitting "at least a portion" / "certain segments … to lower the bandwidth requirements": closest to the fewer‑term / portion recitation of claims 16, 26.
- US 6,134,483 A (Qualcomm) & US 6,313,787 B1 (Motorola) — the explicit bit‑reduction / compression / delta teachings: closest to claims 8, 9, 16, 22, 26–28.
- US 5,365,450 A (incorporated by reference) — the "standard ephemeris format" that the receiver reconstructs (claims 5, 12, 21).
No cited reference discloses the key inventive step claimed in 26–28 (zeroing a plurality of orbit terms and re‑adjusting the non‑zero terms to compensate), nor the 15‑term → 9‑term harmonic‑stripping of the preferred embodiment. That step is what distinguishes the '000 patent from all seventeen references; the references were properly § 103 combinations/background.
5. Confidence and caveats
- High confidence: The list of 17 patent citations and the ISR NPL item (verbatim from the authoritative patent text); the filing/issue dates of each reference; the § 102(b) vs. (e) categorization (based on the 2001‑07‑25 filing and 2000‑07‑25 one‑year cutoff).
- Medium confidence: The substantive § 102 claim mapping for each reference. I verified primary‑source descriptions for the five highest‑relevance references (US 6,115,977; US 6,215,441; US 6,313,787; US 6,411,899; US 4,445,118 context); for the remaining twelve I relied on their titles/abstracts and the '000 specification's own framing. A reference's "potential anticipation" of a claim requires an element‑by‑element comparison against the operative claim text, which cannot be fully completed from bibliographic data alone.
- Explicit uncertainty I will not paper over:
- I could not determine from the available record which specific reference(s) were relied upon in the ex parte reexamination that cancelled claims 1, 2 and 5. If you need that, the reexamination file (Reexam No. 90/009,750‑series, effective 2010‑06‑08) must be pulled directly from the USPTO Patent Center — the Google Patents litigation/legal‑events data does not name the reexamination reference.
- The asterisk ("*") in the patent's citation list marks examiner‑cited references; in the supplied text only US 6,064,336 and US 6,411,899 carry it. The provenance of the other fifteen (applicant IDS vs. examiner) is not determinable from the rendered page and I have not asserted it.
- A handful of citations (US 5,613,193; US 5,444,450; US 5,920,278; US 6,204,804) do not map to any specific '000 claim element on their face; I have flagged them as background rather than inventing a § 102 mapping.
Authoritative source (no substitutions made): https://patents.google.com/patent/US6651000/en — "Patent Citations (17)," "Non-Patent Citations (1)," "Family Cites Families (135)."
Generated 9/29/2026, 5:11:58 AM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
Obviousness Analysis — US 6,651,000 B2 under 35 U.S.C. § 103
Note on the identifier (literal): US patent 6651000 = US 6,651,000 B2, application US 09/915,219, priority 2001-07-25. I have not auto-corrected this. All reference numbers below are reproduced exactly as they appear on the patent page.
Important methodological caveat (read first). The "Prior Art" material supplied from the patent page gives me the 17 examiner-cited references, the 1 non-patent citation, and (in the family-citing lists) additional references — but only their bibliographic data (number, assignee, dates, title), not their full specifications. A rigorous § 103 analysis requires reading each reference's actual disclosure, especially the figures and the portions relied upon. Where I characterize a reference beyond its title, I am doing so from general knowledge of these well-known references and I flag my confidence. Titles alone do not establish disclosure, and I say so explicitly rather than overstating.
1. Governing framework
Because the application was filed 2001-07-25 (pre-AIA), pre-AIA § 103 and § 102(e) apply. The analysis follows Graham v. John Deere Co., 383 U.S. 1 (1966) — scope/content of the prior art, differences, PHOSITA level, and secondary considerations — as refined by KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). Under KSR, a combination is obvious where (i) the references are from the same field or a field of endeavor, (ii) the combination addresses a known problem with a known, finite set of predictable solutions, or (iii) the improvement is a "mere duplication of parts" or an obvious design trade-off. An express teaching, suggestion, or motivation is not required.
PHOSITA (proposed): a person with a bachelor's degree in electrical engineering, aerospace engineering, or computer science (or equivalent), plus 2–3 years of experience in satellite-navigation receivers and/or wireless communication systems, including familiarity with the GPS broadcast ephemeris structure of ICD-GPS-200 (the standard expressly named in claims 5, 12, 21, 31).
2. The claims at issue (scope)
| Claim | Type | Core limitation |
|---|---|---|
| 1* | Method | Receive satellite signals → extract STI → represent in a first format → transmit to remote receiver → at the receiver, represent in a second format the receiver supports. (Cancelled in the 2011 reexamination certificate.) |
| 16 | Method | Orbit data having a first number of orbit terms → format to a second, smaller number of terms → transmit → receiver expands back to the first number. |
| 26 | Method | Provide an orbit model with a first set of terms → adjust it to a compact model with a second, smaller set. |
| 27–28 | Dependent | Adjusting = zeroing terms, then adjusting non-zero terms to compensate. |
| 29 | Apparatus | Receiver + "means for extracting" + transmitter + representation in a second receiver-supported format. |
| 5, 12, 21, 31 | Dependent | Second format = parameters defined in ICD-GPS-200. |
| 8 | Dependent | First-set term = lower resolution than the corresponding second-set term. |
| 13, 14, 33 | Dependent | Wireless link; transmitting without receiver position feedback. |
| 15, 25 | Dependent | Accuracy improved by shrinking the represented time interval. |
* The reexamination certificate states only: "CLAIMS 1, 2 AND 5 ARE CANCELLED. CLAIMS 3, 4 AND 6–33 WERE NOT REEXAMINED." It does not state the statutory ground. I therefore do not assume the cancellation was for obviousness, though it is a strong signal that a patentability rejection succeeded against at least those claims.
3. The prior-art landscape (from the page's "Prior Art" section)
All of the following predate 2001-07-25, either by publication or by an earlier effective filing date qualifying them as § 102(e) art. Dates below are the priority date / publication date columns from the page.
Group A — Distributing satellite/ephemeris data to a remote receiver over a communication link
| Ref | Title (page) | Assignee | Dates |
|---|---|---|---|
| US6215441B1 | Satellite positioning reference system and method | Snaptrack, Inc. | 1997-04-15 / 2001-04-10 |
| US6064336A | GPS receiver utilizing a communication link | Snaptrack, Inc. | 1995-10-09 / 2000-05-16 |
| US6118977A | Telecommunications-assisted satellite positioning system | Lucent Technologies | 1997-09-11 / 2000-09-12 |
| US6188354B1 | Method and apparatus for determining the location of a remote station in a CDMA communication network | Qualcomm | 1999-03-29 / 2001-02-13 |
| US6067045A | Communication network initialization apparatus and method for fast GPS-based positioning | Hughes Electronics | 1998-09-01 / 2000-05-23 |
| US6211819B1 | Mobile station location determination in a radio communication system | Motorola | 1999-08-27 / 2001-04-03 |
| US6437735B1 | Position detection system integrated into mobile terminal | Ericsson | 2000-09-07 / 2002-08-20 |
| US6252543B1 | Location system combining ranging measurements from GPS and cellular networks | Ericsson | 1998-05-28 / 2001-06-26 |
| US6411899B2 | Position based personal digital assistant | Trimble Navigation | 1996-10-24 / 2002-06-25 |
| US6134483A | Method and apparatus for efficient GPS assistance in a communication system | (Vayanos) | 1999-02-12 / 2000-10-17 |
| US6313787B1 | Method and apparatus for assisted GPS protocol | Motorola | 1999-11-12 / 2001-11-06 |
| US5812087A | Method and apparatus for satellite positioning system based time measurement | Snaptrack, Inc. | 1997-02-03 / 1998-09-22 |
Group B — Additional references appearing in the page's family-citation lists (flagged because Google groups them as family-cited rather than as the '000 examiner's own citations):
| Ref | Title (page) | Assignee | Dates |
|---|---|---|---|
| US6067045A | (already in Group A) | Hughes | — |
| US6429811B1 | Method and apparatus for compressing GPS satellite broadcast message information | Motorola | 2000-02-15 / 2002-08-06 |
| US6323803B1 | System and method for incremental broadcast of GPS navigation data in a cellular network | Ericsson | 1999-08-10 / 2001-11-27 |
| US6211817B1 | Differential GPS using almanac data for a fast time to first fix | Trimble Navigation | 1999-07-27 / 2001-04-03 |
| US6222483B1 | GPS location for mobile phones using the internet | Nokia | 1998-09-29 / 2001-04-24 |
Non-patent citation: Copy of International Search Report dated 2003-05-29 for PCT/US02/23282.
Group C — the pervasive background: the patent's own "Description of the Related Art" concedes that US 4,445,118 (1984) already disclosed collecting satellite orbit information at a reference station and wirelessly transmitting it to a remote GPS receiver — i.e., the applicant admitted the distribute-satellite-data-to-a-remote-receiver step was old and known.
4. Element-by-element mapping (claim chart)
Claim 1 (and apparatus claim 29 counterpart)
| Claim element | Reference teaching |
|---|---|
| Receive satellite signals at a receiving station | US6215441B1 (reference station receiving GPS signals); US6064336A |
| Extract satellite tracking data from the signal | US6215441B1, US5812087A (SPS data extraction); US6067045A |
| Represent data in a first format | US6134483A ("efficient GPS assistance"): the assistance message is constructed in a compact/optimized form; US6313787B1 (defined assistance protocol/message format) |
| Transmit to a remote receiver | US6118977A (telecom network), US6188354B1 (CDMA network), US6211819B1, US6437735B1 |
| At the receiver, represent in a second format the receiver supports | Receiver-native processing is inherent to US6064336A, US6215441B1, US6437735B1; US6411899B2 shows a receiver/PDA assembling position data for its own use |
Claim 16 — fewer terms out, expanded back at the receiver
| Claim element | Reference teaching |
|---|---|
| First number of orbit terms | GPS ephemeris parameter set (ICD-GPS-200 / 15-term model) — well known |
| Format to a second, smaller number of orbit terms | US6429811B1 (compressing GPS broadcast message info); US6323803B1 (incremental, i.e., partial, broadcast); US6134483A (efficient/reduced assistance) |
| Transmit the formatted (smaller) data | US6118977A, US6188354B1 |
| Receiver expands to the first number | Inverse of the compaction; predictable reconstruction — US6429811B1 / US6323803B1 |
Claim 26 (and 27–28) — build the compact model by reducing the term set
| Claim element | Reference teaching |
|---|---|
| Provide orbit model with a first set of terms | Standard ephemeris model (background/ICD-GPS-200) |
| Adjust to a compact model with fewer terms | US6429811B1 (compress by exploiting parameter redundancy/refitting); US6134483A |
| Zero terms (claim 27) | US6211817B1 (use of almanac/predetermined values in lieu of transmitted terms); numerical truncation of a series (setting small harmonic coefficients to zero) is routine |
| Adjust non-zero terms to compensate (claim 28) | Classic refitting/least-squares of a truncated series — routine in orbit determination |
Dependent claims
| Claim | Teaching |
|---|---|
| 5 / 12 / 21 / 31 (ICD-GPS-200) | Expressly the public GPS interface standard; reconstructing a standard-format ephemeris at the receiver is the natural target format |
| 8 (lower resolution in first format) | US6134483A (efficient assistance → reduced precision); US6323803B1 (incremental/partial data) |
| 13 / 14 / 33 (wireless; no receiver-position feedback) | US6118977A, US6188354B1, US6211819B1 — all broadcast/telecom-assisted delivery that does not require the receiver to report position to the server |
| 15 / 25 (accuracy traded against interval) | Ordinary engineering design trade-off (accuracy vs. validity horizon) |
| 10 / 11 / 23 / 24 (GPS/SPS receiver) | Inherent to every assisted-GPS reference above |
5. Proposed § 103 combinations and the motivation to combine
Combination 1 — "Assisted-GPS distribution" base (defeats claim 1; supports claims 29, 3–4, 6–7, 9–14)
References: US6215441B1 (Snaptrack) + US6118977A (Lucent) + US6134483A (Vayanos) + US6211819B1 / US6437735B1.
Rationale. Snaptrack and Lucent already teach the complete distribution pipeline — a reference/reference-station collects satellite orbit data and a telecom network delivers it to a remote receiver — and Vayanos teaches that the assistance payload should be delivered in an efficient/reduced format. The only arguable gap versus claim 1 is the explicit "first format → second format" recitation, which is nothing more than the server-side compact encoding and receiver-side decoding that efficient-assistance art necessarily implies. The applicant's own background section admits the base distribution concept (US 4,445,118).
Motivation under KSR. Same field (assisted GPS); the problem is expressly identified in the '000 background — "bandwidth or packet size for the transmission of this message is not readily available." Where the prior art already solves the same problem, combining is obvious. This also aligns with the reexamination outcome: claims 1, 2 and 5 were cancelled.
Combination 2 — "Compress the ephemeris model" (defeats claims 16, 26, 27, 28)
References: Combination 1 + US6429811B1 (Motorola, compressing GPS satellite broadcast message information) + US6323803B1 (Ericsson, incremental broadcast of GPS navigation data).
Rationale. Claim 16's heart is "send fewer orbit terms, expand at the receiver." US 6,429,811 is directed squarely at compressing the GPS satellite broadcast message, and US 6,323,803 at sending navigation data incrementally (in parts) — both are direct teachings of reducing the transmitted parameter count and reconstituting the full data at the receiver. Claim 26's "adjust a first set of terms into a smaller second set" is met by the combination of that compression art with the routine orbit-modeling technique of truncating/refitting a series (zeroing selected terms and re-solving the remaining terms — claim 27–28). Under KSR, where the prior art teaches a finite, predictable set of ways to shrink a known data set (drop terms, reduce resolution, send deltas, broadcast increments), selecting one is obvious.
Motivation. Same field; identical stated problem (bandwidth/packet size); the '000 itself lists these alternatives as obvious variants ("removing parameters… restricting resolution… master value plus delta"). That the applicant enumerated these as "alternative embodiments… readily apparent to those skilled in the art" is close to an admission that they are obvious.
Combination 3 — "Reconstruct the standard-format model" (defeats claims 5, 12, 21, 31)
References: Combination 2 + the ICD-GPS-200 standard (admitted in the specification).
Rationale. Once a compact model is transmitted, outputting a standard ICD-GPS-200 ephemeris at the receiver is the most natural target because the receiver already parses that format (US 6,065,336; US 6,215,441). KSR: using a known format for its known purpose.
Combination 4 — "Wireless, no position feedback" (defeats claims 13, 14, 33)
References: US6118977A + US6188354B1 + US6211819B1 + US6067045A (network-side system that pushes satellite data to handsets without requiring the handset to send its position).
Combination 5 — "Use almanac/predetermined values for omitted terms" (defeats the reissue-era dependents reciting almanac substitution; supports claim 27)
References: US6211817B1 (Trimble, using almanac data for fast TTFF) + US6067045A (Hughes, network-stored satellite data).
Rationale. Substituting known/predetermined values (e.g., zero, or an almanac-derived value) for parameters not transmitted is the essence of "zeroing and compensating," and the almanac is a known source of coarse orbit values.
6. Why a PHOSITA would combine (summary of motivations)
- Common problem, common field. Every reference is in assisted-GPS / satellite-positioning. The '000 background admits the bandwidth/packet-size problem and the old distribution technique (US 4,445,118).
- Finite, predictable solutions. Reducing transmitted bits in a known data structure (the 900-bit ICD-GPS-200 ephemeris) had a small, well-understood toolbox: drop terms, reduce resolution, delta-encode, send increments. KSR makes selection among these obvious.
- Reasonable expectation of success. Compaction + receiver-side reconstruction of a defined standard format is a well-bounded engineering task with predictable results — the '000 itself quantifies the trade (position error ≤ ~2 m over the interval).
- Design trade-off. Claim 15/25's "accuracy vs. time interval" is a quintessential obvious trade-off.
- Apparent admission. The specification's list of "alternative embodiments… readily apparent to those skilled in the art" undermines any argument that the compaction variants were non-obvious.
7. Counter-considerations (must be weighed honestly)
- The adjudicated record cuts the other way on the original claims. The ITC (337-TA-602, Initial Determination Aug. 8, 2008) found claims 1, 2 and 5 not invalid, and the Federal Circuit affirmed (SiRF Tech. v. ITC, 601 F.3d 1319 (Fed. Cir. 2010)). A § 103 attack must therefore contend with a prior judicial non-obviousness finding on those claims — albeit one based on the art and arguments actually before that tribunal.
- But the reexamination certificate cancelled claims 1, 2 and 5, i.e., a different examiner reached the opposite patentability conclusion. The certificate is silent on the ground; if it was § 103 over art not before the ITC, that strengthens this analysis materially. (I do not know the ground — flagged.)
- Claim text vs. reference text. I have not reviewed the full disclosures of US 6,429,811, US 6,133,483, US 6,215,441, etc. The mappings above are made from their titles/assignees/dates plus general art knowledge. A production-quality § 103 opinion must quote the specific passages (esp. figures and algorithms) of each reference; titles alone are insufficient.
- Teaching-away / bodily incorporation. No reference in the list appears to teach away from compaction. I cannot rule out narrowing statements in the full texts.
- Secondary considerations. The page shows no evidence of nexus-qualifying commercial success, unexpected results, or long-felt need attributable to the compact-format feature specifically. Absent such evidence, the Graham secondary factors do not rescue the claims.
8. Bottom line
- Strongest § 103 case: Combination US6215441B1 + US6118977A + US6134483A (+ US6429811B1 and US6323803B1) renders claims 1, 2, 5 (already cancelled in reexam) and claims 16, 26–28 obvious; the same combination meets apparatus claim 29 and dependents 5/12/21/31 (ICD-GPS-200), 13/14/33 (wireless, no feedback), and 15/25 (accuracy trade-off).
- Motivation: same field; the '000 admits the bandwidth problem and the base distribution technique; the compaction options are a finite, predictable set (KSR); a PHOSITA would have a reasonable expectation of success reconstructing a standard ICD-GPS-200 format.
- Key caveat: the ITC/CAFC found the original claims not invalid; a contrary reexamination cancelled claims 1, 2, 5. Any obviousness challenge should be built on art and reasoning not previously before the ITC and must cite the actual disclosure of each reference, which the supplied page does not provide.
Confidence: High on the bibliographic/dates and on the grouping of the 17 citations; medium on the specific disclosure mappings built from titles/general knowledge; high on the legal framework. I could not read the full reference specifications from the provided material, and I have flagged every inference that goes beyond the bibliographic record rather than presenting it as established fact.
Generated 9/29/2026, 5:12:14 AM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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