US 6745229

I'll search for authoritative information on this patent, including any 2026 litigation activity.

Let me run additional targeted searches on the claims and any litigation activity.

Let me look specifically for the complete claim set of US 6,745,229 to identify all independent claims.

Summary of US Patent 6,745,229 (US 6,745,229 B1)

Important scope note on my search results: I searched for this specific number and found no CAFC 2026 docket, no Federal Circuit appeal, no PTAB/IPR proceeding, and no active district-court litigation involving U.S. Patent No. 6,745,229. The only hits for the bare string "6745229" outside the U.S. patent were coincidental other patents (e.g., Japanese Patent No. JP6745229B2, a can-printing apparatus by Showa Aluminum Can Corp., and U.S. Application No. 6745229 from 1991, a Nokia connection block). Those are different documents and I am not conflating them. A negative result is not proof of no litigation; my tooling does not cover every docket system comprehensively, so treat "no 2026 CAFC activity found" as an absence of evidence rather than verified certitude.

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Bibliographic data (from the granted patent front page and Google Patents)

Note: the granted-PDF OCR renders the primary examiner's name as "Bunjob Jarosenkonwami"; secondary databases list it as Bunjob Jaroenchonwanit. I flag this rather than silently normalizing it.

Abstract (verbatim): "A Web-based invoice viewing system and method for enabling a customer to generate invoices relating to various network services provided to the customer by an enterprise. A Web enabled invoice viewing system provides billing and invoice information to remote customers having a workstation with a Web browser and an Internet access. A graphical user interface system at the customer workstation presents a list of invoice documents organized into products and date ranges applicable to the customer for the customer to select and view. Various displays presented at the customer workstation may be printed, faxed, or queued for batch printing at the enterprise remotely. The customer is enabled to view dynamically summed results of numerical figures displayed on the invoice documents by highlighting the numbers in the document directly on the display."

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Plain-language overview of the independent claim(s)

Claim 1 (confirmed independent — system claim). It covers a Web-based invoice viewing system that lets a customer retrieve an invoice over the Internet using a browser client at the customer's workstation. The system has three cooperating parts:

1. At least one secure server that manages customer sessions over the Internet and supports a secure socket connection (i.e., encrypted, SSL/HTTPS-style) between the client browser application and the server.
2. An "invoice presentation device" that (a) lets the customer select and be shown invoice documents in accordance with customer entitlements, and (b) generates an invoice request message when the customer picks a specific invoice option and forwards it through the secure server.
3. An "invoice server device" that receives the request, accesses the database in response, and builds a response message sent back through the secure server; the response is assembled in a display-ready form, and the presentation device displays the selected invoice at the workstation.

The final limitation is the notable structural hook: the presentation device includes a presentation applet downloaded from the secure server and launched within a Web browser window (i.e., the thin-client/Java-applet delivery model, rather than a locally installed Windows client).

Because claim 1 is a system claim, its "devices" are the functional components of the three-tier Web architecture described in the specification (client tier / secure Web-server middle tier / back-end invoice server).

Other independent claims — uncertainty. I could not authoritatively confirm the full claim set of the '229 patent. The only claim text I could verify is claim 1 (above) plus dependent claims 2 and 3 (claim 2 = "dynamic accumulator(s)" for highlighting and summing figures; claim 3 = automatic population of product and date-range fields for a customer identifier). I therefore cannot state with confidence whether claims 4–22 include any additional independent claims (e.g., a method or computer-readable-medium claim). Do not treat claims 2–22 as conclusively all-dependent on the evidence I gathered.

Related family note (do not confuse): The continuation application 10/822,509 (published as US 2004/0193512 A1, filed April 12, 2004) is a separate application in this family. Its file history shows independent claims 21, 26, 31, and 36 (system, computer-implemented method, computer-readable medium, and method for accessing telecommunication invoices, respectively) plus a § 101 rejection that was argued in prosecution. Those claim numbers belong to the continuation, not to US 6,745,229, and should not be attributed to the '229 patent.

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Sources

• Granted patent (Google Patents): https://patents.google.com/patent/US6745229/en
• Granted-patent PDF (front page, abstract, bibliographic data): https://patentimages.storage.googleapis.com/ca/bc/2a/364d8a5d596370/US6745229.pdf
• Justia patent page (bibliographic data, assignee, examiners): https://patents.justia.com/patent/6745229
• uspto.report transaction/prior-art listing: https://uspto.report/patent/grant/6,745,229
• Claim 1 / claims 2–3 text (mirror): https://radaris.com/f/Jia/Swei/Inventor
• Continuation 10/822,509 file-wrapper documents (separate application): https://ia800500.us.archive.org/20/items/gov.uspto.patents.application.[10822509](/patent/10822509)/

Explicit uncertainty flags

1. No CAFC 2026 (or other) litigation found for this patent; treat as a negative search result, not a verified absence.
2. Full claim set unverified — only claim 1 (independent) and claims 2–3 (dependent) were confirmed from primary/mirrored text.
3. The patent's term ran to September 24, 2018; it is expired, which limits (though does not entirely eliminate) current enforcement significance.

I'll search litigation-specific sources for this patent number.

Let me try more targeted litigation databases and specific search formulations.

Let me try additional litigation-specific databases and variants.

Litigation Search Results — U.S. Patent No. 6,745,229

Bottom line

I found no known litigation involving U.S. Patent No. 6,745,229. I could not identify a single district-court case, ITC investigation, PTAB/IPR proceeding, or Federal Circuit appeal in which the '229 patent was asserted, challenged, or named as a patent-in-suit.

Because there is no case to report, the requested per-case fields cannot be populated with real data. Stating them with invented values would be fabrication, so I have left them expressly empty below.

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Search coverage and what I actually ran

Important limitation: My tooling is a general web search, not a credentialed docket query. I could not directly query PACER, the CAFC docket, Docket Alarm, or the Unified Patents litigation portal (https://portal.unifiedpatents.com/litigation/caselist) as logged-in sources; I can only reach what those systems surface to open search. A negative result here is an absence of evidence, not verified proof of no litigation.

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Near-misses / false positives — explicitly distinguished

These are the most likely sources of a wrong answer, and I flag them so they are not attributed to the '229 patent:

1. A different '229 patent in Lambda Optical Solutions v. Alcatel-Lucent (D. Del., No. 10-487). A Delaware opinion discusses "the ’229 patent," which issued December 6, 2005 and was practiced by Lambda Optical Systems from 2001. U.S. 6,745,229 issued June 1, 2004 and is a WorldCom/Verizon invoice-reporting patent. Different patent, different owner, different technology. Do not conflate.
   Source: https://www-ded.qa.uscourts.gov/sites/ded/files/opinions/10-487_1_1.pdf

2. "6745229" appearing in an IPR2022-00413 (Apple v. RFCyber) exhibit. This is the file history of U.S. 9,240,009, in which "6745229" appears inside a PTO reference listing (a prior-art citation string). That is a citation of the '229 patent as prior art against a third party's application — not a proceeding against the '229 patent.
   Source: https://www.docketalarm.com/cases/PTAB/IPR2022-00413/

3. JP6745229B2 (Showa Aluminum Can Corp.). A Japanese can-printing apparatus patent. Same digits, unrelated document and jurisdiction. Explicitly flagged in the prior section as well — I confirm no conflation.
   Source: https://patentimages.storage.googleapis.com/7e/69/97/2085ba1f9b6a6f/JP6745229B2.pdf

4. Verizon's other patent litigation. Verizon/Verizon Wireless is a frequent patent litigant (e.g., Adaptix v. Cellco, Cellular Communications Equipment v. Verizon, the 2026 E.D. Tex. jury verdict re: Wi-Fi/cellular handover). None of those identify U.S. 6,745,229 as an asserted or challenged patent.

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Consistency check against the prior section

No contradiction. The previously generated summary also concluded that no CAFC 2026 docket, no Federal Circuit appeal, no PTAB/IPR, and no active district-court litigation involving U.S. Patent No. 6,745,229 could be found. My independent queries reach the same result. The earlier section's caution — that "no 2026 CAFC activity found" is an absence of evidence rather than verified certitude — remains the correct characterization.

One factual correction to note for accuracy: the prior section referred to a "CAFC 2026 docket." The task at hand is district-court and PTAB litigation generally, not just 2026 appellate activity; my searches were not limited to 2026 or to the Federal Circuit, and still returned nothing.

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Why a negative result is unsurprising here (context, not proof)

• U.S. 6,745,229 is a WorldCom/MCI-origin, now-Verizon-owned patent on a Web-based invoice-viewing client interface (claim 1 covers a secure server + invoice presentation device + invoice server device with a downloadable browser applet).
• It expired on its anticipated date of September 24, 2018 (per Google Patents). Expired patents are rarely asserted in new suits, which is consistent with finding no modern campaign.
• The prior section noted the separate continuation 10/822,509 (US 2004/0193512 A1) carried independent claims 21, 26, 31, 36 and a § 101 rejection. Any litigation or prosecution activity tied to that continuation must not be reported as litigation on the '229 patent.

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Sources consulted

• Google Patents (bibliographic/legal status, assignee chain, expiration): https://patents.google.com/patent/[US6745229](/patent/US6745229)/en
• Granted-patent front page and abstract: https://patentimages.storage.googleapis.com/ca/bc/2a/364d8a5d596370/US6745229.pdf
• Justia patent page: https://patents.justia.com/patent/6745229
• Lambda Optical v. Alcatel (different '229 patent): https://www-ded.qa.uscourts.gov/sites/ded/files/opinions/10-487_1_1.pdf
• Apple v. RFCyber IPR2022-00413 exhibit (prior-art citation only): https://www.docketalarm.com/cases/PTAB/IPR2022-00413/
• JP6745229B2 (unrelated Japanese document): https://patentimages.storage.googleapis.com/7e/69/97/2085ba1f9b6a6f/JP6745229B2.pdf

Recommendation for a definitive answer: if a verified litigation history is required (e.g., for a clearance or validity opinion), run the number directly against PACER (all district courts), the CAFC docket, the USPTO PTAB Endpoint/PTAB Center API, and the ITC EDIS. My open-web result is strong evidence of no known litigation but should not be treated as a certified clearance search.

I'll verify the structured block's "no PTAB activity" result with targeted web searches before writing the analysis.

Let me run a few more targeted checks, including the Unified Patents portal and PTAB-specific queries.

Let me check the Unified Patents portal entry and whether any related family patents saw PTAB activity, plus confirm no reexamination.

Proceedings overview

Total AIA trial proceedings on file for US 6,745,229: zero (0 active, 0 with claims invalidated, 0 with claims sustained, 0 settled, 0 institution-denied). The canonical USPTO Open Data Portal block lists no IPR, PGR, or CBM proceeding for this patent, and three independent web-search checks returned no petition, institution decision, final written decision, or termination referencing 6,745,229 as the challenged patent — so the bottom-line defensive posture for a defendant is not "hardened by surviving IPR" but rather "unlitigated at the Board," which cuts both ways: there is no PTAB cancellation to hand you a free win, but also no IPR estoppel, no claim-construction record, and no FWD you can borrow from.

No proceedings to itemize

Because the requested per-proceeding template (petitioner, panel, grounds, institution, FWD, settlement, appeal) presupposes at least one docket entry, there is nothing to populate. What I can document instead is the scope of the negative finding and the things that were not PTAB proceedings, so a reader doesn't mistake them for hits:

Coincidental matches — explicitly flagged so they are not miscounted as PTAB activity:

1. JP 6745229 B2 — a Japanese patent to Showa Aluminum Can Corp. (a can-printing apparatus, Japanese Appl. No. 2017-14603). The digit string matches; the document does not.
2. Lithuanian bankruptcy-notice number 6745229 (UAB "Finansų studija") — a registry publication number, not a patent.
3. U.S. Patent No. 6,745,229 cited as prior art by others — it appears in the prior-art citation lists of IPR2022-00413 (Apple Inc. v. RFCyber Corp., Ex. 1042) and in a PCT search report (WO 2013/121410 A1). Being cited against someone else is the opposite of being challenged.
4. Verizon-hosted IPRs (IPR2020-01143, IPR2022-01350, etc.) — Verizon entities appear as petitioners attacking other companies' patents. None targets 6,745,229, and Verizon Patent and Licensing Inc. is the current assignee here, not a petitioner.

Confidence and limits. The negative is corroborated by the ODP block plus independent web verification, and it is consistent with the other sections already generated (which likewise found no CAFC 2026 docket or district-court litigation). AIA trials did not exist before 2012-09-16, so there is no "pre-AIA IPR" that could be hiding. Caveats: (a) I did not page PTAB E2E directly, so this is an absence of evidence, not a certified null; (b) pre-AIA ex parte/inter partes reexamination is outside the AIA-trial scope and I found no evidence of either — but a reexam would not appear in a PTAB-proceedings block, so treat that specific sub-question as unverified; (c) do not infer that related family members (e.g., 6,636,402, 6,714,979, 6,115,040) were challenged — I did not verify that either way.

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Strategic summary

Claim status: nothing canceled, nothing sustained, everything UNTESTED at the Board. Because no AIA trial was ever instituted, claims 1–22 stand exactly as issued. To restate the claim landscape from the prior section without re-litigating it: claim 1 is the confirmed independent system claim (secure server + "invoice presentation device" + "invoice server device," with the hook being a presentation applet downloaded from the secure server and launched in a browser window); claims 2–3 are dependent (dynamic accumulator; auto-population of product/date fields). The prior section explicitly flagged that the full claim set is unverified — I could not confirm whether claims 4–22 contain further independents. That gap matters more here than it normally would: with no FWD to work from, the only claim-level record a defendant can cite is the patent's own text, so pull the full 22-claim set from the granted PDF before drafting anything.

Estoppel landscape — effectively empty, which is a two-edged sword. Because there is no petitioner, § 315(e)(2) estoppel has never attached to anyone. No party is barred from raising § 102/§ 103 grounds, and no prior art was "raised or reasonably could have been raised." Practically: a defendant can file an IPR without an estoppel overhang, construct an invalidity case from scratch, and pick its own art. The flip side is that there is no free win — no claim has been canceled, so a demand letter built on claim 1 is not defeated by a prior FWD, and every invalidity argument must be proved the first time. Note also that IPR is limited to § 102/§ 103 (and a narrow § 112(b) carve-out added in 2018); the most natural attack on this patent is § 101, which IPR cannot reach at all.

The procedural clock has largely run out — and that is the real story for a defendant today. Three independent bars matter:

• The patent is expired. Per the front-page data in the prior section, the term ran to 2018-09-24 ("Anticipated expiration," status "Expired – Lifetime"). No post-expiration infringement is possible; only past damages within the § 286 six-year lookback, which is now also closed. The practical value of invalidating an expired patent through an IPR is low, which is very likely why no IPR was ever filed — the absence of PTAB activity here is a rational-response signal, not a validity signal.
• CBM review is unavailable. The patent's own CPC classifications (G06Q20/102 — bill distribution or payments; G06Q30/06 — buying, selling or leasing transactions; G06Q30/02) place it squarely in covered-business-method territory, making CBM the natural vehicle. But the AIA § 18 CBM program sunset on 2020-09-16; no new CBM petition could be filed after that date. CBM was the one AIA vehicle that could have reached § 101 — and it is gone.
• The IPR/PGR windows for anyone actually sued are long past. Any § 315(b) one-year clock keyed to service of a complaint on this patent expired years ago, and the PGR nine-month window closed roughly nine months after issue in 2004.

Pattern signals. No repeat-petitioner pattern (there is no petitioner at all). No patent-owner appeal activity — there is no FWD to appeal, consistent with the prior section's finding of no CAFC docket. No defensive aggregator (Unified Patents or similar) appears in the chain; the Unified Patents portal carries only a passive patent-profile page for US-6745229-B1, not a proceeding. The assignee trail (WorldCom → MCI → Verizon Business Global → Verizon Patent and Licensing Inc.) shows a well-resourced owner, which makes the 25-year absence of any Board challenge more noteworthy, not less.

Contradiction check. No contradiction between the structured block, the web results, and the previously generated sections. All sources agree: no PTAB activity, no CAFC appeal, no district-court litigation found. Treat the whole cluster as mutually reinforcing but still as absence of evidence.

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Recommended next steps

If you are a defendant facing assertion of 6,745,229:

1. Do not build a defense on a canceled claim — none exists. There is no FWD to cite and no canceled claim to quote, so the "the troll has no case" shortcut is unavailable. Your only claim-level weapons are the patent text itself and district-court invalidity.
2. Attack on § 101 and § 112 in court, not at the Board. IPR cannot reach either. The prior section already noted that the continuation 10/822,509 (now US 2004/0193512 A1) drew a § 101 rejection that was argued in prosecution — a useful file-history foothold for an Alice argument, and a signal that examiners have questioned eligibility in this family. Pair that with the specification's own framing (a Web front-end over pre-existing billing back-ends, organized into "products and date ranges") to argue the claims recite a generic computer implementing a commercial/informational practice.
3. Lead with expiry as a threshold dispositive point. Confirm the expiration date on the face of the patent and in PAIR/ODP (prior section: 2018-09-24). If assertion postdates that, there can be no direct infringement, and the § 286 damages window is closed.
4. If you nonetheless want an IPR (e.g., a declaratory posture or a licensing leverage play): the § 315(b) bar only applies to parties served with a complaint more than one year earlier. Note the Board's practice on expired patents — an IPR may still be instituted, but the patent owner cannot amend, and the Board has discretion to weigh the mootness of the relief. Budget accordingly; the cost/benefit is usually poor against an expired patent.
5. Preserve the full claim set and specification now. Because claims 4–22 are unverified in this analysis, obtain the granted PDF (https://patentimages.storage.googleapis.com/ca/bc/2a/364d8a5d596370/US6745229.pdf) and the file history, and confirm whether any additional independent (including any method or CRM) claim exists. A defense built on the assumption that claims 4–22 are all dependent is unsupported.

If you are looking for the formal records to cite in a brief or opinion: confirm the null directly at PTAB E2E (https://ptacts.uspto.gov/) and the USPTO Patent Trial and Appeal Board decisions page (https://www.uspto.gov/patents/ptab), and cross-check appellate history at CourtListener (https://www.courtlistener.com/). Filing a short declaration or records request memorializing the null result is cheap insurance if a counterparty asserts that a proceeding exists.

Plain statement, per the constraints requested: there is no PTAB activity on US 6,745,229. The absence is itself informative here — this was a broadly classified, Web-era business-method-classified patent from a well-funded assignee, exactly the profile that attracts IPRs and CBMs when asserted. The likeliest explanation is that the patent expired in 2018 before any assertion worth challenging, and/or was never asserted against a party with both the incentive and an open § 315(b) window. I am flagging that as inference, not fact.

I'll build on the prior summary and focus on the assignment record. Let me search for the correspondence and reel/frame details.

Let me look for the recorded assignment reel/frame data and correspondents.

Let me try to pin down the recorded correspondence and the WorldCom bankruptcy context.

I hit the step ceiling while probing the Assignment Center mirrors for reel/frame and correspondent data. Below is what the record supports, with the gaps called out explicitly rather than filled in.

Inventors

Employer evidence: All seven executed the December 1998 "ASSIGNMENT OF ASSIGNORS INTEREST" in favor of MCI WorldCom, Inc. (Google Patents reassignment event, recorded 1998-12-02). The resolver addresses (Rye Brook, NY and the CT/NY cluster) are MCI/WorldCom corporate locations, and the invention is the "networkMCI Interact" online-invoicing platform. Employer attribution is therefore a strong inference from the assignment itself, not a separately documented payroll record — flagging that.

Unusual-pattern check: I found no evidence of inventors departing the assignee of record within 12 months of filing, and no evidence of a parallel inventor-side assignment to a third party. I cannot affirmatively state departures did not occur; the data to test that (employment histories) was not retrieved. Nothing here resembles the "all-inventors-out-the-door pre-fire-sale" pattern.

Original assignee

• Entity named on the issued patent: Worldcom, Inc. (Google Patents front page). By the time of issuance (2004-06-01) the original April-1998 assignee MCI WorldCom, Inc. had already been shortened to WorldCom, Inc. — the patent issued under the later name.
• Primary line of business: Tier-1 long-distance/telecom carrier; this patent covers the online invoicing component of its networkMCI Interact customer self-service platform (the product embodying the claims — MCI's Service View / Interact reporting suite).
• Current status: WorldCom filed Chapter 11 on 2002-07-21 (then the largest U.S. bankruptcy), emerged 2004-04-20 as MCI, Inc., and was acquired by Verizon Communications in January 2006. The brand was retired into Verizon Business. The issuing entity no longer exists as an independent company.

Assignment timeline

Critical sourcing caveat up front: the entries below are the reassignment events as indexed by Google Patents, which mirror the USPTO assignment records. I was able to confirm exactly one reel/frame from a primary cross-reference: Reel 032734 / Frame 0502 (cited verbatim in the 2017 corrective-assignment text as the prior recording). I could not retrieve the reel/frame numbers or the correspondent of record for the remaining links, and I will not invent them. This materially weakens the "repeat correspondent" analysis in the next section.

• 1998-12-02 (recorded; execution date not retrieved) — Reel not retrieved

  • Conveyance: Assignment ("Assignment of Assignors' Interest")
  • Assignor: Gobin, Hall, Hauryluck, Kanze, Liburd, Van Sandt, Swei (the inventors)
  • Assignee: MCI WorldCom, Inc.
  • Correspondent: not retrieved
  • Context: Original employment/inventor assignment; utility filing (App. 09/159,405, filed 1998-09-24) claiming priority to Provisional 60/060,655 (1997-09-26).

• 2002-04-22 (recorded) — Reel not retrieved

  • Conveyance: Change of Name
  • Assignor: MCI WorldCom, Inc.
  • Assignee: WorldCom, Inc.
  • Correspondent: not retrieved
  • Context: Internal renaming only — Corporate name change (the "MCI" prefix dropped in 2000), recorded after the patent's allowance.

• 2006-05-12 (recorded) — Reel not retrieved

  • Conveyance: Change of Name
  • Assignor: WorldCom, Inc.
  • Assignee: MCI, Inc.
  • Correspondent: not retrieved
  • Context: Internal renaming only — successor-name change following WorldCom's 2002 Chapter 11 and its 2004-04-20 emergence as MCI, Inc.

• 2006-05-12 (recorded) — Reel not retrieved

  • Conveyance: Change of Name
  • Assignor: MCI, Inc.
  • Assignee: MCI, LLC
  • Correspondent: not retrieved
  • Context: Internal renaming/conversion only — corporate-form conversion to an LLC within the same family, recorded same day as the prior event.

• 2007-03-21 (recorded) — Reel not retrieved

  • Conveyance: Change of Name
  • Assignor: MCI, LLC
  • Assignee: Verizon Business Global LLC
  • Correspondent: not retrieved
  • Context: Internal renaming only — rebranding after Verizon's January 2006 acquisition of MCI.

• 2014-04-22 (recorded) — Reel 032734 / Frame 0502

  • Conveyance: Assignment ("Assignment of Assignors' Interest")
  • Assignor: Verizon Business Global LLC
  • Assignee: Verizon Patent and Licensing Inc.
  • Correspondent: not retrieved
  • Context: Intra-group portfolio consolidation — transfer into Verizon's central IP-holding subsidiary. This is the one recording whose reel/frame I can cite with confidence, because the 2017 corrective assignment identifies it by number.

• 2017-11-28 (recorded) — Reel not retrieved

  • Conveyance: Corrective Assignment
  • Assignor: Verizon Business Global LLC
  • Assignee: Verizon Patent and Licensing Inc.
  • Correspondent: not retrieved
  • Context: Correction of record only — "CORRECTIVE ASSIGNMENT TO CORRECT THE ASSIGNEE PREVIOUSLY RECORDED AT REEL: 032734 FRAME: 0502." Corrects the assignee identity on the 2014-04-22 recording; conveys no new interest.

Timeline diagram

timeline
    title Ownership of US 6745229
    1997 : Provisional filed Sep 26
    1998 : Utility application filed Sep 24
         : Inventors assign to MCI WorldCom
    2002 : Renamed WorldCom Inc
         : WorldCom files Chapter 11
    2004 : Patent issues Jun 1
         : WorldCom emerges as MCI Inc
    2006 : Renamed MCI Inc
         : Converted to MCI LLC
    2007 : Renamed Verizon Business Global LLC
    2014 : Assigned to Verizon Patent and Licensing
    2017 : Corrective assignment recorded
    2018 : Patent expires Sep 24

NPE / troll-pattern signals

1. Shell-entity transfer — not present. Every post-1998 link is a change-of-name or intra-group assignment, not a sale out of the operating family. The only entity with an "IP/Licensing" suffix in the chain is Verizon Patent and Licensing Inc., reached at Reel 032734 / Frame 0502 (2014-04-22). That entity is a wholly-owned subsidiary of an operating carrier (Verizon), not a single-purpose Delaware/Texas LLC parked at a registered-agent address. No single-purpose LLC appears anywhere in the chain.

2. Known asserter in the chain — not present. No assignee in the chain (MCI WorldCom, WorldCom, MCI, MCI LLC, Verizon Business Global, Verizon Patent and Licensing) matches any public NPE list (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, etc.). Verizon Patent and Licensing is a defendant-side/portfolio entity, not a tracked high-frequency NPE plaintiff for this asset. No litigation, ITC action, or PTAB proceeding naming this patent was found (consistent with the prior section's negative result — absence of evidence, not verified absence).

3. Repeat correspondent across the chain — unclear / not assessable. This is the signal the task most wanted, and it is precisely the one I cannot report: the correspondent of record was not retrieved for any link. I will not infer a repeat player from the entity names. If the Assignment Center shows one firm handling every recording from 1998 through 2017, that would be ordinary in-house/corporate-secretary practice for a serial acquirer like WorldCom/Verizon and would not by itself indicate a shell network — recurrence only becomes probative when paired with shell LLCs, which are absent here.

4. Cascading transfers — present as a factual pattern, benign in substance. There are three recordings within roughly 10 months (2006-05-12 ×2 and 2007-03-21) and a further transfer in 2014 (Reel 032734/0502). Read literally this is "multiple consecutive assignments." Read substantively, they are name changes and an intra-group re-issue, not transfers to unrelated parties — so as an NPE signal this is not present. Flagging the cluster explicitly so the reader can see the raw data that could superficially resemble chaining.

5. Pre-litigation transfer — not present. No infringement suit naming the patent was located, so there is no litigation anchor date against which to measure a suspicious transfer. The last real transfer (2014-04-22, Reel 032734/0502) is followed by no identified enforcement.

6. Bankruptcy fire-sale — trigger present, transfer absent. WorldCom filed Chapter 11 on 2002-07-21 — a genuine bankruptcy trigger. However, the record shows the patents did not leave the corporate family: WorldCom emerged as MCI, Inc. and the chain continues internally. There is no recorded sale to a third party/asset purchaser, so the classic fire-sale signature is not present. (Note: a general Chapter 11 case does not scope the estate for intellectual property; absent a §363 sale order naming these assets, I cannot assert the patents were even in a disposition process, and I make no such claim.) Corroborating corporate context: FCC transfer-of-control and merger filings (WorldCom→MCI 2003; MCI→Verizon 2005–2006).

7. Privateering — not present. Verizon did not transfer this patent to an NPE to assert on its behalf; the asset stayed in Verizon's own IP subsidiary.

8. Defensive aggregator (anti-NPE) — not present in the strict sense. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at Verizon Patent and Licensing Inc., an operating company's in-house IP holding arm. The practical effect — the asset is retained and unasserted, and the patent expired 2018-09-24 (20-year term from the 1998-09-24 filing) — is neutralization, but the mechanism is corporate retention, not acquisition by a defensive aggregator.

Verdict

Defensive / non-asserting — with an explicit taxonomy caveat.

Justification: The chain is a pure corporate-succession line — inventors → MCI WorldCom (1998) → WorldCom (2002 change of name) → MCI, Inc. (2006) → MCI, LLC (2006) → Verizon Business Global LLC (2007) → Verizon Patent and Licensing Inc. (Reel 032734 / Frame 0502, 2014-04-22), clarified by the 2017-11-28 corrective assignment. There is no shell LLC, no known NPE, no third-party intellectual-property purchaser, and no identified litigation; the patent simply remained inside the operating-company family and expired on 2018-09-24. The category's stated trigger (termination at a defensive aggregator like RPX/AST/LOT) is technically unmet — Verizon Patent and Licensing is an operating-company IP subsidiary — so I am applying the "non-asserting" substance of the category rather than its aggregator trigger, and flagging that the taxonomy has no clean bucket for "benign corporate-succession chain ending in an operating-company IP holder."

Verification link: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent number 6,745,229). Note the caveat at the top of the timeline: I confirmed only Reel 032734 / Frame 0502 and no correspondents; retrieving the full reel/frame set and correspondent column from the live Assignment Center is required before treating signal 3 as resolved.

I'll search the USPTO and related databases for the prior-art citations appearing on the face of US 6,745,229.

Let me retrieve the complete "References Cited" list from the front page and the transitional list.

The reference list is long and partially truncated. Let me pull the middle and end segments of the front-page "References Cited" list.

I hit the tool-call limit before I could pull the complete front-page citation list, so below is what I retrieved and verified, followed by the § 102 relevance analysis. I flag every gap explicitly rather than filling it in.

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1. What the search returned for the exact number 6745229

The number resolves to one U.S. patent — it is not to be conflated with unrelated documents that share the string (e.g., Japanese Patent No. JP 6745229 B2, a printing apparatus / can-body manufacturing system by Showa Aluminum Can Corp., published 2020 — a different document with a coincidentally identical number). Consistent with the earlier-generated summary, I found no CAFC/Federal Circuit 2026 docket, no IPR, and no active district-court assertion for US 6,745,229; treat that as a negative search result, not verified absence.

The relevant vehicle is US 6,745,229 B1 (Google Patents / Justia / uspto.report all agree), and its prior-art-of-record is its front-page "(56) References Cited" list.

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2. Scoping rules I applied (read before using the tables)

1. Only backward citations count as prior art. Patents that cite '229 (the "Referenced By" lists, e.g., DE 69526652 T2, WO 2009/009442 A3, and the numerous later MCI/WorldCom siblings) are forward citations and are not prior art to '229. I excluded them.
2. '229 is pre-AIA. Application 09/159,405 was filed 1998-09-24 with provisional priority to 1997-09-26. Therefore §§ 102(a), 102(b) and 102(e) apply. The § 102(b) critical date is ~1997-09-24 (one year before the U.S. filing date).
3. The list is incomplete in this session. The full "(56)" list on the '229 front page runs to roughly 100+ U.S. references plus 8 foreign documents and 2 "Other Publications." I verified the segments reproduced below; the middle of the list (roughly the 5,491,xxx → 5,781,xxx gap) was truncated in every snippet I could retrieve. Do not treat the tables below as the complete citation list.
4. § 102 anticipation requires all limitations. A front-page citation is not a § 102 rejection. These references were before the examiner who allowed the 22 claims, so on their face they did not anticipate the claims as issued. Every mapping below is a hypothesis to be tested against the reference text, not a conclusion. I have not read the full disclosure of each reference in this session.

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3. Verified prior-art citations of record for US 6,745,229

3.1 U.S. Patent Documents (verified segment A — earliest, 1979–1996)

3.2 U.S. Patent Documents (verified segment B — 1997–1999 cluster)

(The list continues past US 5,930,764; I could not retrieve its tail.)

3.3 Foreign Patent Documents (complete — 8 documents)

3.4 Other Publications (complete — 2 documents)

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4. § 102 relevance analysis — the most material references

Because I did not read the full text of every reference in this session, I have separated high-confidence mappings (I know the reference's subject matter) from unverified candidates. Treat the confidence column literally.

A. High-confidence candidates

(i) US 5,694,546 — Reisman, "System for automatic unattended electronic information transport between a server and a client by a vendor provided transport software with a manifest list," issued 1997-12-02.
Subject matter confirmed: an independent docket entry describes it verbatim as "SYSTEM FOR AUTOMATIC UNATTENDED ELECTRONIC INFORMATION TRANSPORT BETWEEN A SERVER AND A CLIENT BY A VENDOR PROVIDED TRANSPORT SOFTWARE WITH A MANIFEST LIST." It is the U.S. national-phase counterpart of WO 95/33236 (Reisman, published 1995-12-07), which shares the family with US 6,769,009 / US 6,594,692 / US 6,125,388.

• § 102(b) (WO 95/33236 published 1995-12-07) and § 102(e) (US 5,694,546, filed pre-1998).
• Claims potentially affected: Claim 1 — specifically the final limitation "the invoice presentation device includes a presentation applet downloaded from the secure server, the presentation applet launched within a Web browser window." Reisman teaches vendor-supplied transport software downloaded from a server to a client and executed there. This is the single most structurally on-point reference for the "downloaded software" hook of claim 1. However, Reisman is not an invoicing system, so it cannot alone anticipate a claim that also requires an "invoice presentation device" and "invoice server device." Its realistic role is as the primary § 102(e) reference combined with an invoicing/billing reference, or as § 103 art.
• Confidence: High on subject matter; Moderate on whether it discloses "applet launched within a Web browser window" specifically (it predates the applet paradigm — it likely teaches native downloaded client software, not a browser-hosted applet). This is a genuine § 102 gap.

(ii) US 5,774,670 — Montulli, "Persistent client state in a hypertext transfer protocol based client-server system," issued 1998-06-30.
Subject matter confirmed (title and the cookie/session-state subject matter; the "cited by" linkage to '229 is confirmed).

• § 102(e) (filed before 1998-09-24) — it is not § 102(b) because it issued after 1997-09-24.
• Claims potentially affected: the claim 1 element "at least one secure server for managing customer sessions over the Internet." Montulli teaches HTTP session state management (the cookie-jar mechanism the '229 specification itself describes). It does not teach a "secure socket connection" limitation or invoicing — so it is only a partial § 102(a)/(e) reference for the session-management sub-element.
• Confidence: High on subject matter; explicit gap on the invoicing and secure-socket limitations.

(iii) US 5,892,900 — Ginter et al., "Systems and methods for secure transaction management and electronic rights protection," issued 1999-04-06.
Subject matter confirmed.

• § 102(e) only (issued after the critical date). Filed 1995-02-13 (per family).
• Claims potentially affected: peripherally, the claim 1 secure-communication/entitlement elements ("in accordance with customer entitlements," "secure socket connection"). Ginter is an electronic-rights/secure-delivery reference, not an invoice-presentation reference.
• Confidence: High that it is cited and is § 102(e)-qualified; Low that it anticipates claim 1 (wrong field — rights management, not Web invoicing).

(iv) US 5,826,269 — Hussey, issued 1998-10-20.
(Title not verified in this session.) The metadata places it in the electronic-commerce / bill-handling cluster that the examiner cited alongside Hussey-family art.

• § 102(e) (issued after the critical date).
• Confidence: Low — I could not verify the disclosure. Do not rely on this entry.

(v) Microsoft Access User's Guide (1994).

• § 102(b) (printed publication, well before 1997-09-24).
• Claims potentially affected: Claim 2 — "one or more dynamic accumulator(s) for enabling the customer to add numerical figures presented in the invoice document by highlighting the figures directly on the invoice document." A spreadsheet/database user guide teaches selecting cells/values and obtaining running totals — i.e., the arithmetic-aggregation half of claim 2. It does not teach highlighting figures directly on a displayed invoice document within a Web-delivered invoice viewer.
• Confidence: High it is a § 102(b) printed publication; Moderate-to-High that it anticipates only the arithmetic sub-element, not claim 2 in full.

B. Unverified candidates worth pulling first (ranked by likely relevance)

C. Segment-A references (1979–1996, items 1–27 above)

On the face of the record these read as general background art in data processing, telephony and document handling. They are all § 102(b)-qualified (every one issued well before 1997-09-24). Individually, none of them plausibly contains the Internet + secure socket + downloaded applet + invoice presentation combination of claim 1 — they predate the commercial Web. Their realistic citation purpose is to show the state of the art in billing/document presentation and to support § 103 combinations. I did not verify the subject matter of any of items 1–27, so I am not asserting they are irrelevant — only that their dates preclude them from teaching the Internet-specific limitations.

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5. Important contextual fact for the § 102 analysis

The separate continuation application in this family, 10/822,509 (published as US 2004/0193512 A1, filed 2004-04-12), was rejected in prosecution for anticipation under 35 U.S.C. § 102(e) based on Barry et al., US 6,615,258 — with claims 21–39 rejected. That rejection, and the accompanying § 101 rejection of claims 26–30 and 36–39, are documented in the appeal brief in the 10/822,509 file wrapper.

Two cautions:

• US 6,615,258 (Barry et al.) is not a front-page citation of US 6,745,229. It is an examiner-cited reference in the continuation's prosecution and must not be attributed to the '229 record. It is, however, the most probative known § 102 reference against the family's claim set, and any validity analysis of the '229 disclosure should pull it.
• The '229 patent is expired (anticipated expiration 2018-09-24, per the bibliographic record). That does not affect the § 102 analysis, but it does affect the practical significance of any invalidity position.

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6. What I could not verify (read this as the limitations of the above)

1. The complete "(56)" list. Roughly the US 5,491,xxx → US 5,781,xxx span is missing from my retrieval. The tables in § 3 are a verified subset, not the whole record. The authoritative source for the complete list is the '229 front page (USPTO PatentCenter / the granted-PDF at patentimages.storage.googleapis.com/ca/bc/2a/364d8a5d596370/US6745229.pdf).
2. Subject matter of ~70 of the ~85 U.S. references. I gave inventor, number and date for each but could not confirm what most of them disclose. The "not verified in-session" and "Low" confidence entries must be researched individually before any § 102 assertion is made.
3. Claim set. Confirmed: claim 1 (independent, system), claims 2–3 (dependent). I still cannot confirm whether claims 4–22 contain further independent claims (e.g., method or CRM claims). The independent claims 21, 26, 31, 36, 40 belong to the continuation US 2004/0193512 A1, not to US 6,745,229. Do not carry them across.
4. Original rule preserved: the granted-PDF OCR renders the primary examiner as "Bunjob Jarosenkonwami"; secondary databases give Bunjob Jaroenchonwanit. I am flagging the discrepancy, not normalizing it.

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7. Bottom line

• The exact patent 6745229 = US 6,745,229 B1, WorldCom, "Web based integrated customer interface for invoice reporting" — and it is not JP 6745229 B2 (Showa Aluminum Can) or any other coincidentally-numbered document.
• The most technically germane item on the '229 front page is US 5,694,546 (Reisman), whose family includes WO 95/33236, because it teaches vendor-supplied software downloaded from a server to a client — the closest prior teaching to claim 1's final "presentation applet downloaded from the secure server… launched within a Web browser window" limitation. It is § 102(b)/(e)-qualified but does not itself disclose invoicing or a browser applet.
• US 5,774,670 (Montulli) is the best on-point citation for claim 1's session-management element; US 5,892,900 (Ginter) for the secure-delivery element; the Microsoft Access User's Guide (1994, examiner-asterisked) for claim 2's arithmetic-aggregation element. None of these three, alone, covers a full claim.
• No single front-page reference appears to anticipate claim 1 in its entirety on the evidence I could verify — which is expected, since these references were before the examiner who allowed all 22 claims. A credible § 102 position on claim 1 would require either (a) a reference I could not retrieve from the truncated middle of the list, or (b) a reference outside the '229 record — most notably US 6,615,258 (Barry et al.), which the USPTO did use to reject the sibling continuation's claims 21–39 under § 102(e).

Sources

• Granted patent (Google Patents): https://patents.google.com/patent/US6745229/en
• Granted-PDF front page, "(56) References Cited": https://patentimages.storage.googleapis.com/ca/bc/2a/364d8a5d596370/US6745229.pdf
• Justia citation list: https://patents.justia.com/patent/6745229
• uspto.report citation list: https://uspto.report/patent/grant/6,745,229
• Continuation 10/822,509 appeal brief (Barry et al., US 6,615,258 § 102(e) rejection; claims 21–39): https://ia600500.us.archive.org/20/items/gov.uspto.patents.application.[10822509](/patent/10822509)/10822509-image_file_wrapper/10822509-2010-05-28-00003-AP.B_text.pdf
• Reisman US 5,694,546 subject-matter confirmation (IPR exhibit): https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2016-00472/.../Exhibit-1003.pdf
• Reisman WO 95/33236 / US 5,694,546 family (EPO search report, EP 1 531 602 A3): https://patentimages.storage.googleapis.com/ca/b5/55/032ddb618eb00d/EP1531602A3.pdf
• JP 6745229 B2 (unrelated document — printing apparatus / can body manufacturing system, Showa Aluminum Can Corp.): https://patentimages.storage.googleapis.com/7e/69/97/2085ba1f9b6a6f/JP6745229B2.pdf

I'll ground this analysis in the actual references cited on the '229 patent and adjacent art, rather than general knowledge alone.

Let me pull the actual cited references from the patent's front page and any related proceedings.

I need the actual front-page citations. Let me try to retrieve the citation table.

Obviousness Analysis — U.S. Patent No. 6,745,229 B1

"Web based integrated customer interface for invoice reporting"
§ 103 analysis prepared April 26, 2026

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0. Scope, sources, and an important caveat about the "Prior Art" section

What the fetched page's Prior Art section actually contains. The Google Patents page for US6745229 (https://patents.google.com/patent/US6745229/en) does not display an enumerated reference list in the portion fetched. Its "Prior Art" content is limited to:

• Prior art keywords: invoice, customer, server, document, client — five tokens that map almost one-to-one onto the five functional elements of claim 1.
• CPC classes, most pointedly H04L12/1428 — "Invoice generation, e.g. customization, lay-out, database processing, algorithms for calculating the bill or formatting invoices as WWW pages" and H04M15/44 — "Augmented, consolidated or itemized billing statement or bill presentation."

That classification assignment is itself analytically significant: the patent office classification scheme documents as a known field of art the formatting of invoices as WWW pages. I treat that as the page's own characterization of the prior-art field.

What I could and could not retrieve. I located a partial front-page "References Cited" listing via uspto.report (https://uspto.report/patent/grant/6,745,229), running from US 5,710,882 (Svennevik, Jan. 1998) through US 5,844,896 and truncated mid-list. That excerpt is the only primary citation data I obtained this session; I did not retrieve the complete U.S. reference list, the foreign-reference list, or the "Other Publications" list. Accordingly:

Grounds below are constructed from (a) the verified claim text, (b) the patent's own specification admissions, (c) the verified-as-cited subset of references in the excerpt, and (d) art I know to be in the field, expressly labeled as not verified as cited. I have not fabricated reference titles or numbers.

Verified as cited on the '229 front page (partial list): 5,710,882 Svennevik; 5,721,908 Lagarde; 5,721,913 Ackroff; 5,727,129 Barrett; 5,734,709 DeWitt; 5,734,831 Sanders; 5,742,762 Scholl; 5,742,763 Jones; 5,742,768 Gennaro; 5,742,905 Pepe; 5,745,754 Lagarde; 5,754,830 Butts; 5,757,900 Nagel; 5,764,756 Onweller; 5,768,501 Lewis; 5,774,660 Brendel; 5,774,670 Montulli; 5,778,178 Arunachalam; 5,781,550 Templin; 5,781,632 Odom; 5,787,160 Chaney; 5,787,412 Bosch; 5,790,780 Brichta; 5,790,789 Suarez; 5,790,797 Shimada; 5,790,809 Holmes; 5,793,694 Akiba; 5,793,762 Penners; 5,793,964 Rogers; 5,796,393 MacNaughton; 5,799,154 Kuriyan; 5,802,320 Baehr; 5,805,803 Birrell; 5,812,533 Cox; 5,812,654 Anderson; 5,812,750 Dev; 5,815,080 Taguchi; 5,815,665 Teper; 5,819,225 Eastwood; 5,819,271 Mahoney; 5,825,769 O'Reilly; 5,825,890 Elgamal; 5,826,029 Gore; 5,826,269 Hussey; 5,832,519 Bowen; 5,835,084 Bailey; 5,844,896 …

Date discrepancy flag: the task states April 26, 2026; the system header states 2026-10-01. I make no substantive use of either date beyond noting that the patent expired September 24, 2018, so any § 103 finding here is of historical/validity-defense significance, not current-enforcement significance.

Inherited uncertainty (unresolved): the prior summary could confirm only claim 1 (independent) and claims 2–3 (dependent). I still cannot verify whether claims 4–22 include further independent claims. No claim-level obviousness conclusion for claims 4–22 is offered.

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1. Governing law and critical date

• Pre-AIA § 103(a) applies (application filed Sept. 24, 1998; AIA first-inventor-to-file took effect March 16, 2013). The analysis therefore proceeds under Graham v. John Deere, 383 U.S. 1 (1966), as refined by KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
• Earliest priority: Sept. 26, 1997 (Prov. 60/060,655). Actual filing: Sept. 24, 1998. Prior art must therefore predate Sept. 26, 1997 for § 102(a)/(e) purposes, or Sept. 24, 1997 for § 102(b) purposes.
• § 103(c) common-ownership caveat: the patent's specification expressly incorporates U.S. Pat. No. 6,115,040 and co-pending applications 09/159,512 and 09/159,409. Those are sibling WorldCom/MCI networkMCI Interact filings. Any of them qualifying only under § 102(e)/(f)/(g) and commonly owned cannot be used in a § 103 combination (pre-AIA § 103(c)). Any ground built on the networkMCI Interact sibling patents is therefore legally fragile and must be pleaded carefully. US 6,470,386 B1 (WorldCom, Oct. 22, 2002) surfaced in a later WO search as a category "A" background citation alongside US 6,745,229 and is likewise a family-adjacent document — handle with the same caution.

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2. Level of ordinary skill (PHOSITA)

A person having ordinary skill in the art as of Sept. 1997 would be a software engineer with roughly 2–4 years' experience building Internet client-server applications, conversant with: HTML/HTTP; Netscape Navigator 3/4 and Internet Explorer 3/4; Java 1.0/1.1 applets (released Jan. 23, 1996); SSL 3.0 (1996) and HTTPS; Netscape-style cookies; CGI/server-side scripting; relational and legacy mainframe databases (CICS/DB2-type back ends); and the enterprise customer-network-management platforms of the day (MCI Service View, AT&T and Sprint equivalents). This is a low skill level relative to a specialized field — which cuts against non-obviousness.

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3. The patent's own admissions (the most useful § 103 ammunition)

Under In re Fout / MPEP 2129, applicant statements in the specification are admissions usable as prior art. The '229 specification states:

1. MCI, AT&T and Sprint "presently provide[] for the presentation and dissemination of customer invoice account and network management information to their customers through a Windows-based graphical user interface resident on a personal computer."
2. Customers "directly dial-up… or… via dedicated communication lines … to the entity's application and database servers," and initiate reports "through the reporting graphical user interface (GUI)."
3. "The report requests … are processed by the entity's application server, which retrieves the requested customer information from one or more databases, processes and formats the information for downloading to the client's reporting GUI."
4. MCI's Service View platform already delivered Toll Free Network Manager, Perspective (priced call detail) and TrafficView (unpriced call detail) reports to customers.

Admissions (1)–(3) together describe a client-server invoice/account reporting system with (i) a customer workstation GUI, (ii) remote transport to entity servers, (iii) an application server that retrieves data from databases and formats it for client display. What is left for claim 1 is: the transport becomes the public Internet, the client becomes a browser-launched applet, the server is a secure server managing sessions over a secure socket connection, and access is gated on customer entitlements. Elements (i)–(iii) are admitted; only the delivery mechanism differs.

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4. Claim 1 element-by-element mapping

Observation: every limitation is either admitted in the specification, or is a named, dated, off-the-shelf technology (cookies, SSL, Java applets, browser-launched thin clients). No claim 1 element required a new discovery.

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5. Grounds of rejection under § 103

Ground 1 — Admitted prior art + Montulli + SSL/HTTPS + Java applet delivery

• Primary reference: the admitted MCI/AT&T/Sprint client-server invoice and network-management reporting architecture (spec. ¶¶ 1–3) — a § 102(a)/(b) "known or used" reference via admission.
• Secondary references: Montulli '670 (HTTP session state via cookies — verified as cited); SSL 3.0/HTTPS secure socket transport (well-known standard, 1996); Java 1.0 applet model (well-known, 1996).
• Motivation to combine: the specification itself supplies it — the stated desire for "customer connectivity over the public Internet, as the Internet provides access connectivity world wide via the TCP/IP standard, obviating a need to cater programs to specific native vendor-supplied listener programs." A PHOSITA seeking to eliminate per-customer Windows client installation, versioning and dedicated-line provisioning would predictably substitute a browser-delivered thin client. KSR, 550 U.S. at 416–417 ("combination of familiar elements according to known methods … does no more than yield predictable results"); MPEP 2143 rationales (a) and (b).
• Result: claim 1 rendered obvious.

Ground 2 — Bill-presentment art + WWW-invoice-classification art + secure/entitlement web delivery

• Primary references: electronic bill delivery/payment art in the field, e.g., Lawlor et al., US 5,220,501 ("Method and system for remote delivery of retail banking services," 1993) and Hilt et al., US 5,465,206 ("Electronic bill pay system," 1995) — both confirmed to exist as of the relevant period from the docket records I retrieved, but I have not verified either as cited in '229; plus the field's own recognition of "formatting invoices as WWW pages" as codified at CPC H04L12/1428.
• Secondary references: Montulli '670; an entitlement/access-control reference (Levergood '780); Java applet delivery.
• Motivation to combine: Lawlor/Hilt teach delivering itemized billing data to a remote subscriber over a communication network for on-demand viewing; the art recognized moving that presentation onto the WWW. A PHOSITA would combine them to give the customer browser-based self-service invoice viewing with authenticated access — a predictable aggregation of known functions (KSR; In re Rouffet — references from the same field combine readily).

Ground 3 — Platform-level delivery of legacy back-end reports to a browser (family-adjacent; § 103(c) risk)

The networkMCI Interact platform patents (US 6,115,040, incorporated by reference; the 09/159,512 and 09/159,409 siblings; US 6,470,386) describe the three-tier browser/applet → firewalled secure web server → dispatcher → legacy application server architecture. Combined with the admitted invoice-reporting function, this yields claim 1 almost verbatim. However, because they share a common assignee/inventive origin, pre-AIA § 103(c) bars their use if they qualify only as § 102(e)/(f)/(g) art. Any petitioner would need § 102(a)/(b) qualification (e.g., publication or public use predating Sept. 26, 1997).

Ground 4 — The applet limitation standing alone does not save the claim

The specification's asserted novelty hook — an applet "downloaded from the secure server" and "launched within a Web browser window" — reads on the ordinary, documented operation of Java applets as of January 1996. Using a known technique (server-delivered executable thin client) to improve a similar system (remote invoice reporting) in the same way is the paradigm KSR obviousness case. There is no teaching away in the specification.

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6. Dependent claims

• Claim 2 — "dynamic accumulator(s) … by highlighting the figures directly on the invoice document." Selecting numeric cells in a grid and having the application display an automatic sum was standard spreadsheet behavior (Microsoft Excel's selection-based status-bar "AutoCalculate," present by Excel 97) and was used in call-detail/usage analysis tools. Applying a known selection-summation UI to a newly displayed invoice document is a predictable application of a known technique to a known element (KSR). Obvious.
• Claim 3 — "automatically populates products and date range fields associated with a customer identifier." Database-driven form population and dependent (drilldown) list boxes were conventional client-server UI patterns; the '229 specification itself attributes the underlying entitlement/identifier data to StarOE. Obvious over the admitted prior art in view of any conventional database-form UI reference.

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7. Anticipated counterarguments and responses

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8. Secondary considerations

No objective evidence of non-obviousness (unexpected results, licensing due to the merits, industry praise, copying) is of record in the materials I retrieved. Commercial success of the networkMCI Interact suite, even if demonstrated, would face a nexus problem: the suite's success flows from the platform as a whole (US 6,115,040 and siblings) and from many applications, not from the features distinguishing claim 1. The patent is expired (Sept. 24, 2018), further reducing the practical stakes of any § 103 finding.

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9. Adjacent invalidity avenues worth noting

1. § 102(b) public use / on-sale. The non-provisional was filed Sept. 24, 1998 — essentially one year after the Sept. 26, 1997 provisional. If networkMCI Interact (including online invoicing) was publicly demonstrated or offered for sale before Sept. 24, 1997, a § 102(b) bar may attach. I have no evidence either way and flag this strictly as an investigative lead.
2. § 112 support for "entitlements." The term appears in claim 1 with limited antecedent structure in the specification; a written-description/enablement challenge is plausible.
3. The continuation US 2004/0193512 A1 (App. 10/822,509) drew a § 101 rejection argued during prosecution (per the earlier section). That is a different application's issue and does not bear on the '229 claims; noted only to avoid conflation.

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10. Confidence and uncertainty flags

1. Full prior-art list not retrieved. I hold only a truncated front-page citation excerpt. Any conclusion here could be materially strengthened (or a specific Ground confirmed) by the complete IDS/1449 and the "Other Publications" list.
2. Reference titles/authors. Beyond Montulli '670 and the admitted prior art, I have not independently verified titles for the cited numbers, and I have expressly labeled Lawlor '501 and Hilt '206 as field art not verified as cited in '229.
3. Claim set incomplete. Claims 4–22 remain unverified; some may be independent, and this analysis does not extend to them.
4. No litigation/PTAB proceeding found for US 6,745,229 (carried forward from the earlier section) — an absence of evidence, not verified absence.
5. Sources: https://patents.google.com/patent/US6745229/en (claim 1 and claims 2–3 text; CPC and prior-art-keyword sections); https://uspto.report/patent/grant/6,745,229 (partial cited-reference list); https://radaris.com/f/Jia/Swei/Inventor (mirrored claim text, cross-checked against the Google Patents version).

Bottom line: Claim 1 appears obvious under § 103 as the predictable migration of the specification's own admitted client-server invoice/account reporting system to the 1997 Internet paradigm (browser + downloadable Java applet + SSL/HTTPS secure server with cookie-based sessions + entitlement-gated access), and dependent claims 2 and 3 appear obvious as routine UI applications — subject to the verification gaps flagged above.