US 6772229

Summary of U.S. Patent 6,772,229

Title: Centrifugal communication and collaboration method

Assignee: Sampo IP LLC

Inventors: Theodore B. Achacoso, D. Wayne Silby

Filing Date: November 13, 2000

Issue Date: August 3, 2004

Abstract:
A system for communicating information among participants in a distributed application having peripheral communications devices comprises a central agent having two-way links to the peripheral devices, a notice generator triggered by an information input from one participant directed to at least one other participant, the notice generator generating a notice for the other participant(s) and pushing the notice to the peripheral device of the other participant(s) only if the information input was directed to the other participant(s), a central storage medium storing the information input, and an access channel by which the other participant(s) may receive the information input only if the other participant(s) responds to the notice. The links may form a computer network, cable network, telecommunications network, wireless network, or other network, or a combination. Additional information inputs may be associated with the first information input or may modify or delete it.

Plain-Language Overview of Independent Claims

U.S. Patent 6,772,229 has two independent claims: claim 1 and claim 22.

Independent Claim 1:

In simple terms, this claim describes a system for online collaboration. Imagine a group of people working on a project together using their computers or other devices. The system has a central hub that connects everyone. When one person sends a message or a file (the "first information input") to specific members of the group, the system automatically sends a notification to only those intended recipients. This notification contains a link that takes them directly to the message or file.

The system also allows for threaded conversations. If a recipient replies to the initial message (the "second information input"), the system can then notify other relevant people, including the original sender. This process can continue with further replies (the "third information input"), creating a linked conversation. The system keeps track of these related messages and can either save them all, or allow them to be modified or deleted based on subsequent replies.

Independent Claim 22:

This claim describes the method or process that the system in Claim 1 performs. It outlines the steps involved in this "centrifugal" communication, where information is pushed out to the relevant participants. The steps are as follows:

1. A central device is provided to send and receive information to and from the participants' devices.
2. This central device is linked to all the participants' devices.
3. When a first participant sends information intended for at least one other participant, the central device receives and stores it.
4. The system then associates this information with the intended recipients.
5. A notice is prepared for only those intended recipients, which includes a direct link to the stored information.
6. This notice is then sent to the devices of only the intended recipients.

Essentially, this claim protects the specific process of selectively notifying participants in a distributed application and providing them with a direct channel to access the relevant information, thereby avoiding the need for users to manually check a central location for updates.

CAFC 2026 Docket Search

A search of the U.S. Court of Appeals for the Federal Circuit (CAFC) dockets for the year 2026 did not yield any cases specifically citing U.S. Patent 6,772,229.

Disclaimer: This summary is for informational purposes only and does not constitute legal advice. The plain-language explanation of the claims is a simplified interpretation and should not be used for legal analysis. For a complete and accurate understanding of the patent, please refer to the full text of the patent document.

Known Litigation Involving US Patent 6,772,229:

A search of publicly available litigation databases, including Unified Patents, did not yield any active or concluded litigation cases specifically citing U.S. Patent 6,772,229. While other patent litigation cases were found in the search results (e.g., cases involving wireless communication patents, coffee capsule patents, or LED display patents), none of these involved US Patent 6,772,229 directly.

Therefore, as of April 26, 2026, no litigation involving US Patent 6,772,229 is known based on the conducted search.

Proceedings overview

A search of the USPTO Open Data Portal and public web sources did not yield any AIA trial proceedings (Inter Partes Review, Post-Grant Review, or Covered Business Method review) for U.S. Patent 6,772,229. This means there are no active PTAB proceedings, nor have any claims of this patent been invalidated or sustained through PTAB trials.

Strategic summary

As of May 29, 2026, all claims of U.S. Patent 6,772,229 remain untested by AIA trial proceedings. This indicates that the patent has not been subjected to challenges at the PTAB, which is a common occurrence for patents involved in litigation.

Regarding estoppel, since no IPR or PGR proceedings have been instituted or concluded, there are no statutory estoppel bars under 35 U.S.C. § 315(e)(2) that would prevent a defendant from raising any prior-art grounds. All prior art (patents or printed publications for IPR, and any invalidity ground for PGR, including §§ 101, 102, 103, and 112) is theoretically available for use in a new PTAB petition or district court litigation.

The absence of PTAB activity suggests that either the patent has not been heavily asserted in district court litigation, or any past assertions did not lead to PTAB challenges by defendants. Typically, well-asserted patents eventually attract IPRs, especially given the lower cost and faster resolution compared to district court litigation.

Recommended next steps

Since no PTAB activity exists for U.S. Patent 6,772,229, a defendant currently facing assertion of this patent should consider evaluating its claims for vulnerability to invalidity challenges under 35 U.S.C. §§ 102 and 103 (using prior art patents and printed publications) through an Inter Partes Review. If the patent were to be considered a "covered business method patent" and meet other criteria, a Covered Business Method review (which can address additional grounds like § 101 and § 112) might also be an option, though the program for new CBM petitions ended on September 16, 2020.

The absence of prior PTAB challenges means that a fresh review of the prior art landscape could offer a significant defensive strategy, without the constraints of estoppel from previous proceedings.

Inventors

Theodore B. Achacoso and D. Wayne Silby are the named inventors. Their employer at the time of filing was GroupServe Inc., the original assignee. No unusual patterns are immediately determinable from the provided information regarding their departure from the original assignee.

Original assignee

The original assignee named on the issued patent is GroupServe Inc.

GroupServe Inc. appears to have been involved in groupware software and communication services, as the patent itself describes the "Centrifugal Communication and Collaboration Method (CCCM)" as being incorporated into the design of products like "groupware software and communications services". The patent references GroupServe Inc. as the applicant and original assignee. While there are current entities named "Groupserve Ltd." in London, associated with management consultancy, and "KP Group" which serves clients, it's unclear if these are direct descendants or related to the original "GroupServe Inc." that filed the patent. It is also unclear if the original GroupServe Inc. shipped a product embodying the claims, or its current operating status. Other search results for "GroupServe" refer to a function of serving groups (e.g., "Group Serve" drink sizes or financial services to groups), not a specific company named GroupServe Inc.

Assignment timeline

• 2001-03-20 (executed) / recorded 2001-03-20 — Reel 011985/0793
  • Conveyance: Assignment
  • Assignor: ACHACOSO, THEODORE B.; SILBY, D. WAYNE
  • Assignee: GROUPSERVE, INC.
  • Correspondent: NOT PROVIDED
  • Context: Transfer from inventors to the original assignee.
• 2005-06-20 (executed) / recorded 2005-06-20 — Reel 016335/0824
  • Conveyance: Assignment
  • Assignor: GROUPSERVE, INC.
  • Assignee: GROUPSERVE IP TRUST LLC
  • Correspondent: Robert M. Schwartz, ROBERT M. SCHWARTZ, P.C.
  • Context: Transfer from original assignee to an IP trust.
• 2013-02-22 (executed) / recorded 2013-02-27 — Reel 029705/0111
  • Conveyance: Assignment
  • Assignor: GROUPSERVE IP TRUST, LLC
  • Assignee: LVL PATENT GROUP, LLC
  • Correspondent: Ronald S. Laurie, RAJ DESAI & LAURIE LLP
  • Context: Transfer from IP trust to a new LLC.
• 2013-03-01 (executed) / recorded 2013-03-05 — Reel 029729/0816
  • Conveyance: Assignment
  • Assignor: LVL PATENT GROUP, LLC
  • Assignee: SAMPO IP LLC
  • Correspondent: Ronald S. Laurie, RAJ DESAI & LAURIE LLP. This correspondent recurs in this chain.
  • Context: Transfer between LLCs.
• 2015-02-02 (executed) / recorded 2015-02-04 — Reel 033069/0638
  • Conveyance: Security Interest
  • Assignor: MARATHON PATENT GROUP, INC.; SAMPO IP, LLC
  • Assignee: DBD CREDIT FUNDING, LLC
  • Correspondent: Marc A. Bell, ROPES & GRAY LLP
  • Context: Securitization involving Sampo IP LLC and Marathon Patent Group, Inc.
• 2017-01-11 (executed) / recorded 2017-01-13 — Reel 036322/0257
  • Conveyance: Security Interest
  • Assignor: 3D NANOCOLOR CORP.; BISMARCK IP INC.; MAGNUS IP GMBH; MARATHON IP GMBH; MARATHON VENTURES S.À.R.L; MEDTECH DEVELOPMENT DEUTSCHLAND GMBH; MOTHEYE TECHNOLOGIES, LLC; MUNITECH IP S.À.R.L.; NYANZA PROPERTIES; ORTHOPHOENIX, LLC; SYNCHRONICITY IP GMBH; SYNCHRONICITY IP LLC; TLI COMMUNICATIONS GMBH; TRAVERSE TECHNOLOGIES CORP.; VERMILION PARTICIPATIONS; DBD CREDIT FUNDING, LLC
  • Assignee: DBD CREDIT FUNDING LLC, AS COLLATERAL AGENT
  • Correspondent: Jessica J. Macomber, ROPES & GRAY LLP
  • Context: Further securitization involving multiple entities and DBD Credit Funding LLC as collateral agent.

Timeline diagram

timeline
    title Ownership of US 6772229
    2001 : Inventors to GroupServe Inc
    2005 : Assigned to GroupServe IP Trust LLC
    2013 : Assigned to LVL Patent Group LLC
         : Assigned to Sampo IP LLC
    2015 : Security Interest to DBD Credit Funding LLC
    2017 : Security Interest to DBD Credit Funding LLC, Collateral Agent

NPE / troll-pattern signals

1. Shell-entity transfer — present.

   • GroupServe Inc. to GROUPSERVE IP TRUST LLC (Reel 016335/0824, 2005-06-20). "IP Trust" in the name suggests a licensing-focused entity.
   • GROUPSERVE IP TRUST, LLC to LVL PATENT GROUP, LLC (Reel 029705/0111, 2013-02-22). "Patent Group" in the name suggests a licensing-focused entity.
   • LVL PATENT GROUP, LLC to SAMPO IP LLC (Reel 029729/0816, 2013-03-01). "IP LLC" in the name suggests a licensing-focused entity.

2. Known asserter in the chain — present.

   • Marathon Patent Group, Inc. is listed as an assignor in the 2015 security interest (Reel 033069/0638, 2015-02-02) and again as an assignor in the 2017 security interest (Reel 036322/0257, 2017-01-11). Marathon Patent Group is a known NPE.

3. Repeat correspondent across the chain — present.

   • Ronald S. Laurie, RAJ DESAI & LAURIE LLP, appears as correspondent for the assignment from GROUPSERVE IP TRUST, LLC to LVL PATENT GROUP, LLC (Reel 029705/0111, 2013-02-22) and again for the assignment from LVL PATENT GROUP, LLC to SAMPO IP LLC (Reel 029729/0816, 2013-03-01).

4. Cascading transfers — present.

   • The transfer from GROUPSERVE IP TRUST, LLC to LVL PATENT GROUP, LLC (Reel 029705/0111, 2013-02-22) and then to SAMPO IP LLC (Reel 029729/0816, 2013-03-01) occurred within a short period (less than one month), with the same correspondent, Ronald S. Laurie, facilitating both.

5. Pre-litigation transfer — unclear. While the patent family has litigation, the specific timing of assignments relative to the first infringement suit naming this patent (US6772229) is not immediately clear from the provided data.

6. Bankruptcy fire-sale — not present. No indication of bankruptcy for GroupServe Inc. or any subsequent assignor.

7. Privateering — unclear. No information in the provided records to suggest this pattern.

8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at a known defensive aggregator.

Verdict

NPE — high confidence

The presence of multiple strong signals, including transfers to shell-like entities (GroupServe IP Trust LLC, LVL Patent Group, LLC, Sampo IP LLC), the involvement of a known NPE (Marathon Patent Group, Inc.) in the security interests, and the rapid, successive transfers handled by the same correspondent (Ronald S. Laurie) in 2013 (Reel 029705/0111 on 2013-02-22 and Reel 029729/0816 on 2013-03-01), strongly indicate an NPE assertion pattern.

For verification, see the USPTO Assignment Center search page for US Patent 6,772,229: https://assignmentcenter.uspto.gov/

To identify the most relevant prior art for US patent 6,772,229, I will examine the "Cited by" section of the patent on Google Patents, as this lists the prior art references considered during its examination.

Based on the full patent text provided, the following prior art references are mentioned:

• U.S. patent application Ser. No. 09/041,599
  • Full Citation: U.S. patent application Ser. No. 09/041,599.
  • Publication/Filing Date: Filed March 13, 1998.
  • Brief Description: This is a continuation-in-part application, meaning US 6,772,229 builds upon it. It relates to communication and collaboration tools that allow groups to share information across time and space using computer and other communication channels.
  • Potentially Anticipating Claims (35 U.S.C. § 102): As a parent application, it would not anticipate claims of US 6,772,229 under 35 U.S.C. § 102 but rather provides foundational technology or disclosure for the later patent.

The patent also generally discusses "prior art methods" and differentiates itself from existing products, which it categorizes into "Centripetal method" and "Narrowcasting method". These are discussed as conceptual approaches rather than specific patent citations.

Centripetal Method Examples:

• IBM's Lotus Notes and Domino
• Microsoft's Exchange and NetMeeting
• Netscape's Virtual Office by Concentric
• Radnet's Webshare
• Novell's GroupWise
• Thuridion's Crew
• IntraACTIVE's In Tandem
• Linkstar's HotOffice
• Changepoint's Involv
• Internet Media Inc.'s 3-2-1 Intranet

Narrowcasting Method Examples:

• PointCast's Client and Server
• Marimba's Castanet
• Progressive Network's Real Clients and Servers
• Microsoft's NetShow
• Netscape's Browser and Media Server
• Wayfarer's INCISA
• All listserve products

These product examples, while not formal patent citations within the text, represent the state of the art that the invention aimed to improve upon. The patent specifically states that these centripetal and narrowcasting approaches "suffer from the disadvantage that group members have to report and remember to report to a central area for communication and collaboration," and that "Prior art methods assume that value is added by improving the way group members go about retrieving information that updates at a central location." The invention, referred to as the Centrifugal Communication and Collaboration Method (CCCM), aims to reverse this by "pushing" out data and information to participants.

Without specific patent numbers for these mentioned products within the patent document itself, a definitive anticipation analysis under 35 U.S.C. § 102 for each product is not possible from the provided text. However, the descriptions of their functionality indicate that they generally represent systems where users actively seek information from a central source, contrasting with the "push" model of US 6,772,229.

Obviousness Analysis of US Patent 6,772,229 Under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would render the claims of U.S. Patent 6,772,229 obvious to a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention (prior art date of November 13, 2000). The motivation for combining these references is drawn directly from the patent's own background description.

Identified Prior Art

The U.S. Patent 6,772,229 (hereinafter "the '229 patent") describes the following as prior art:

1. Centripetal Method Groupware: Examples include IBM's Lotus Notes and Domino, Microsoft's Exchange and NetMeeting, Novell's GroupWise, and others. These systems require "group members to remember to go to a central area (a server) in order to retrieve and exchange data and information". They store collaborative value in a central repository, and members must actively go to this resource to get information. These systems typically support features like central storage of participant inputs, two-way links to peripheral devices, and the association of related information inputs (e.g., for threaded discussions), and selective access based on user permissions.
2. Narrowcasting Method: Examples include PointCast's Client and Server, Marimba's Castanet, Microsoft's NetShow, and listserve products. These systems use a "one-to-many communication" model where content sources are decided by the narrowcaster, and users must "tune-in" or attend the narrowcasted content without necessarily knowing if new or relevant information is present. List-servers also push content (emails) but generally do not use a database for threaded, scrollable records and send to all subscribers.
3. Explicitly Stated "Improvement" for Prior Art Systems: The '229 patent's background section itself states: "It would be an improvement to such a system [referring to prior art methods that require convergence] for appointments and reminders for appointments to be “pushed” to the group member's awareness via e-mail with a Web hyperlink to the videoconference, via a narrowcast of the appointment, or other technologies that drive the information outward to the group member". This describes a system that pushes notices via email with a hyperlink or via narrowcasting, selectively to relevant group members, and provides a direct channel to specific content (e.g., a videoconference).

Motivation for Combination

The '229 patent clearly articulates the problem with existing prior art methods: "Both the centripetal and narrowcasting approaches suffer from the disadvantage that group members have to report and remember to report to a central area for communication and collaboration". It further notes that these methods "have failed to anticipate problems associated with the information age, such as information glut and competition for attention".

The patent itself provides a direct motivation for a PHOSITA to combine existing technologies: to address the identified drawback of users having to actively seek out information. The explicitly stated "improvement" in the background section serves as a clear roadmap for a PHOSITA to integrate a proactive "push" notification mechanism into existing collaborative environments.

Obviousness Argument

A PHOSITA, at the time of the invention, would be familiar with the capabilities of existing groupware systems (Centripetal Method Groupware) and various "push" technologies, including email notifications with embedded hyperlinks and narrowcasting.

Combination: Centripetal Method Groupware (e.g., IBM Lotus Notes/Microsoft Exchange) + The "Explicitly Stated Improvement" (pushing notices with hyperlinks for appointments/reminders).

Rationale:

1. Centripetal Method Groupware provides core elements: These systems already provide:

   • Peripheral devices for participants to transmit and receive information.
   • A central agent (server) with two-way links to these devices.
   • A central storage medium capable of storing information inputs from participants.
   • The ability to store a first, second, and third information input from participants, and to associate them (e.g., for threaded discussions), as well as retaining, modifying, or deleting information.
   • Mechanisms for directing information to at least one receiving participant (e.g., through user permissions or group memberships).

2. The "Explicitly Stated Improvement" adds the "Centrifugal Push" mechanism: The '229 patent's background section explicitly teaches the desirability and mechanism of "pushing" information outward. It describes an "improvement" where "appointments and reminders for appointments" are "pushed" to group members "via e-mail with a Web hyperlink to the videoconference, via a narrowcast of the appointment". This "improvement" inherently encompasses:

   • A notice generator, responsive to an event (e.g., an appointment becoming due or a reminder trigger).
   • A notice sender (e.g., an email server or narrowcasting system).
   • The generation of a notice selectively for the at least one receiving participant (as appointments/reminders are typically for specific individuals).
   • The pushing of the notice to the notice sender.
   • The notice comprising a channel to a memory location (e.g., a "Web hyperlink to the videoconference").
   • The ability for the receiving participant to access the information directly using the channel.

A PHOSITA, motivated by the stated problem of users having to "remember to go" to a central area for collaboration and provided with the explicit suggestion to "push" notifications with hyperlinks for "appointments and reminders," would find it obvious to extend this "push with a channel" mechanism to any new participant-generated information input within a collaborative groupware system.

• For Independent Claim 1: Applying the "push with hyperlink" concept from the "improvement" to new "first information inputs" (e.g., a new document posted, a new discussion topic) from a participant in a Lotus Notes-like system would be a straightforward design choice. The hyperlink would simply point to the location of that new information in the central storage medium. Similarly, extending this to "second" and "third" information inputs (replies in a threaded discussion) would be an obvious way to maintain continuous awareness and address the "remember to report" problem for ongoing collaboration.
• For Independent Claim 22: The method steps of centrally receiving and storing information, associating it with participants, and then preparing and sending a notice with a channel selectively to those participants, mirrors the described "improvement" when applied to dynamic, participant-generated content within a collaborative system. The step of responding to subsequent inputs (second and third) with similar notices is an obvious extension for maintaining real-time or near real-time awareness in a dynamic collaborative environment.

Therefore, the combination of widely available groupware systems (e.g., IBM Lotus Notes or Microsoft Exchange) with the push notification technology (e.g., email with hyperlinks or narrowcasting) as explicitly suggested for improvement in the '229 patent's own background, would have rendered the claimed invention obvious to a PHOSITA at the time of the invention. The motivation is clearly to overcome the burden on users to manually retrieve information by proactively delivering relevant updates.