Invalidity dossier
US 6799210
Dynamic association of endpoints to media gateway controllers
Current assignee: Vonage Holding Inc.
Added 9/28/2026, 10:42:13 PM
Active provider: DeepSeek · deepseek-v4-flash
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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 current docket and status information on this specific patent number.
Those searches returned unrelated results. Let me try more targeted queries.
Search results on CAFC 2026 dockets and litigation
Before the summary, a direct answer to your docket request: I could not find any Court of Appeals for the Federal Circuit (CAFC) 2026 docket, appeal, or decision involving US 6,799,210. My searches surfaced (a) an unrelated 2026 N.D. Cal. order (Neonode v. Apple, Case No. 3:21-cv-08872-EMC, concerning a different patent, the '879 patent); (b) an unrelated Lithuanian registry notice coincidentally numbered 6799210; and (c) an RPX/USPTO petition document referring to an unnumbered "'639 patent" — that is not US 6,799,210 and should not be conflated with it. The only litigation event I can confirm for this patent is the 2007 Delaware District Court case noted on the Google Patents page (1:07-cv-00507). I have no authoritative evidence of any 2026 CAFC activity for this patent; if such a docket exists, it did not appear in my searches, and I will not fabricate one.
US Patent 6,799,210 B1 — Summary
| Field | Value |
|---|---|
| Patent number | US 6,799,210 B1 (interpreted literally) |
| Title | Dynamic association of endpoints to media gateway controllers |
| Application no. | 09/598,867 |
| Filing date | June 21, 2000 |
| Issue/publication date | September 28, 2004 |
| Inventors | William D. Gentry (Raleigh, NC); Jason G. Emery (Apex, NC); Samuel H. Christie, IV (Cary, NC) |
| Original assignee | Nortel Networks Limited (St. Laurent, Canada) |
| Current assignee (listed) | RPX Clearinghouse LLC |
| Claims | 28 total; independent claims 1, 17, 25, 27 (claim 28 depends on 27) |
| Status | Expired – Fee Related; adjusted expiration listed as 2022-07-26 |
| Classification | H04L65/1043 (MGCP controllers) and related H04L65/H04L67/H04L69 groups; U.S. Cl. 709/223 |
Assignment chain (per source): Nortel Networks Limited → Rockstar Bidco, LP (2011) → Rockstar Consortium US LP (2014) → RPX Clearinghouse LLC (2015).
Abstract
The patent describes an architecture letting a media gateway identify and register with multiple media gateway controllers for various voice/data services while appearing to each such controller as a single, dedicated control entity. A logical layer called a "virtualizer" sits between gateway(s) and controller(s): to the media gateway it appears as a single media gateway controller, and to each media gateway controller it appears as a single media gateway. The virtualizer acts as a protocol manager and message router, registering multiple media gateways and creating virtual gateways based on controller requirements. Endpoints are preferably grouped into a virtual gateway served by a selected controller (or group of controllers).
Independent claims in plain language
Claim 1 — System. A system for associating a media gateway's endpoints with multiple media gateway controllers. A control system dynamically associates at least one endpoint so that it can receive service from any one of multiple controllers in the network, independent of a second controller that serves the gateway's other endpoints. The control system includes a logical layer that provides virtual gateways mapping the endpoint to a controller, where each virtual gateway is bidirectional in appearance: it looks like a media gateway to the controller, and like a media gateway controller to the media gateway.
Claim 17 — Computer-readable media (software). Same core idea as claim 1, expressed as software instructions stored on computer-readable media, with the added recitation that endpoints of a media gateway may be associated with different controllers, and again requiring the logical layer providing virtual gateways with the two-way appearance described above.
Claim 25 — System (means-plus-function). A system using "means adapted to" language to dynamically associate at least one endpoint so it can receive service from one of multiple controllers, independent of a second controller serving other endpoints, where the associating means provides virtual gateways (same two-way appearance limitation).
Claim 27 — Method. Steps: (a) provide virtual gateways associated with a media gateway; (b) associate at least one endpoint with one virtual gateway so it can receive service from one of multiple controllers via that virtual gateway, independent of the controller serving other endpoints; (c) map signals received from the controller to the media gateway for that endpoint; and (d) map signals received from the media gateway for that endpoint to the controller. (Claim 28 adds that the virtual gateways are provided via a logical layer.)
The remaining claims (2–16, 18–24, 26, 28) are dependent, covering e.g. dynamic registration of virtual gateways; use of a network manager/service broker to select controllers; protocol translation between differing gateway/controller protocols; reassigning endpoints between virtual gateways; primary/backup controller failover; multiple service providers on one gateway; multiple controllers serving a single endpoint; aggregating endpoints across gateways; and deployment in the gateway, the controller, or a third device.
Notes / uncertainty
- The specification text contains OCR artifacts in some dependent claims (e.g., "flintier" in claim 3 and "filer" in claim 5, and garbled wording in claim 26). I am quoting the claims as they appear in the authoritative full text rather than auto-correcting them.
- One "Cited By" listing on the source page mislabels US20100189100 under the '210 number; that is a citation artifact, not a second '210 document.
- All bibliographic data above is corroborated by the full patent text, Google Patents, and the USPTO Official Gazette entry (Issue 1286-4).
- Docket caveat: my inability to locate a CAFC 2026 docket is a limitation of the search, not proof of nonexistence. If you need a definitive litigation check, the authoritative sources would be the CAFC/RPACER docket system and the USPTO Patent Center for this specific number.
Generated 9/28/2026, 10:50:57 PM
Cases on file (2)
Group view →Specific litigation cases in our database that name US patent 6799210. The free-form analysis below may also discuss cases beyond this list.
- Vonage Holding Inc. v. Nortel Networks Inc. et al.filed Aug 17, 20071:07-cv-00507-GMSU.S. District Court for the District of Delawarenot confirmed
Defendants: Nortel Networks Inc., Nortel Networks Ltd.
Other patents asserted: 5991389, 6091808, 6445695, 7050861, 6823370, 7035390, 6934279, 6337858, 6798786
- 1:07-cv-00507U.S. District Court for the District of Delawareunknown
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US patent 6799210 using the sources you specified.
The first searches returned irrelevant results. Let me drill into specific litigation sources.
Summary
Based on my searches, only one litigation record is indexed against US 6,799,210, and the public data I could retrieve does not identify the parties or outcome. I want to be explicit about what is verified vs. what I could not confirm, per your instructions not to fabricate.
The single known record
| Field | Value |
|---|---|
| Patent | US 6,799,210 B1 ("Dynamic association of endpoints to media gateway controllers") |
| Court / Jurisdiction | U.S. District Court for the District of Delaware |
| Case number | 1:07-cv-00507 |
| Source | Unified Patents Litigation Data, as indexed on the Google Patents page for the patent: https://portal.unifiedpatents.com/litigation/Delaware%20District%20Court/case/1%3A07-cv-00507 |
| Plaintiff(s) | Not identified in the available data |
| Defendant(s) | Not identified in the available data |
| Filing date | Not stated (the case number format is consistent with a 2007 Delaware filing, but I have not verified the actual date) |
| Outcome / status | Unknown |
This is the only entry presented as litigation on the authoritative patent record. That record labels it "US case filed in Delaware District Court — litigation — Critical" with source "District Court" and jurisdiction "Delaware District Court." It does not name the parties or the disposition.
What I could NOT find
- No case naming the '210 patent specifically surfaced from CourtListener, PACER-derived document collections, or the RPX Insight litigation-document repository in my searches. Searches returned documents about other media-gateway-related patents (e.g., Sprint v. cable operators over the '052/'561/'340/'224/'3561 patents in D. Del. 1:18-cv-01752-RGA; ACQIS v. Alcatel-Lucent; Genband/Metaswitch), none of which assert '210.
- I found no CAFC appeal tied to '210.
- I found no indication that the post-Nortel owners asserted '210. For context (not litigation): the patent was assigned Nortel Networks Ltd. (2000) → Rockstar Bidco, LP (2011) → Rockstar Consortium US LP (2014) → RPX Clearinghouse LLC (2015). The well-known Rockstar/Constellation enforcement campaign of 2013–2014 (e.g., the Delaware and Texas actions discussed in the complaint at
gov.uscourts.deb.115708) involved other patents; I did not verify '210 among them. - Searches for the bare number string ("6799210") produced several coincidental, unrelated hits (a Lithuanian business-registry notice, a Brazilian docket ID, a Drosophila PubMed ID). These are not litigation involving this patent and should be disregarded.
Important caveats
- Do not treat 1:07-cv-00507 as fully characterized. The Unified Patents index confirms a case exists and links it to '210, but I could not retrieve the caption, filing date, or termination. If you need the parties and outcome, pull the docket directly (Unified Patents portal; PACER for D. Del.; or CourtListener RECAP for that case number).
- The patent is expired. The record shows "Expired – Fee Related" with an adjusted expiration of 2022-07-26. Any litigation of '210 is historical; the patent is no longer enforceable, so no current status can involve active infringement claims.
- I have no high-confidence knowledge of any other case involving this exact patent number. If additional suits exist, they are not reflected in the sources I could reach, and I will not guess at captions.
If you can authorize pulling the D. Del. docket for 1:07-cv-00507 (or the Unified Patents portal page directly), the plaintiff, defendant, filing date, and disposition can be confirmed immediately.
Generated 9/28/2026, 10:50:58 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
Current assignee: Vonage Holding Inc.
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 start by verifying the structured data with targeted searches for any PTAB activity on this patent.
No PTAB hits so far. Let me run a few more targeted checks — including the litigation record — to confirm the absence and understand any assertion history.
Let me confirm whether the Delaware case actually involved this patent, and check PTAB databases directly.
PTAB Proceedings Report — U.S. Patent No. 6,799,210
Patent: Dynamic association of endpoints to media gateway controllers
Assignee of record: RPX Clearinghouse LLC (original assignee Nortel Networks Ltd.)
Filing date: 2000-06-21 | Grant date: 2004-09-28 | Adjusted expiration: 2022-07-26 | Status: Expired – Fee Related
Proceedings overview
Total AIA trial proceedings on file: 0 — zero IPRs, zero PGRs, zero CBMs. There is no breakdown by status to give (no claims invalidated, no claims sustained, no settlements, no institution denials), and the defensive posture is therefore not "hardened by PTAB attrition" but rather "untested." Every one of claims 1–28 stands exactly as issued; no claim has been canceled, narrowed, or construed by the Board. The more material defensive fact is not a PTAB outcome at all: the patent expired on 2022-07-26 per the structured record's adjusted-expiration entry, which means the prospective injunction/reasonable-royalty exposure that drives most IPR petitions is largely off the table, while a pre-expiration damages theory (within the § 286 six-year lookback from an expired term) remains theoretically live.
Source of the proceedings list: the structured "PTAB proceedings on file" block, which states the USPTO Open Data Portal returns no AIA trial proceedings for this patent as of the most recent ingest. I ran independent web searches (Google Patents, USPTO.report, PTAB petition/decision document indexes surfaced by search, and litigation records) and found no IPR, PGR, or CBM petition or decision naming 6,799,210. I state this with the caveat below.
Caveat on completeness. These searches were not a substitute for a direct PTAB E2E / PTAB Center party-and-patent query, which I could not execute here. If you need a certified absence-of-proceedings statement for a litigation or licensing file, run the patent number through USPTO PTAB Center and the PTAB E2E docket directly. Everything below is what I found, not an assertion beyond it.
Proceedings detail
No proceedings exist to detail. I will not fabricate proceeding numbers, panels, or dispositions. The required per-proceeding template (type / filed / status / panel / grounds / institution / FWD / settlement / appeal / defensive value) has no rows.
What I did find, and what it does not mean:
- District court flag. The Google Patents record for this patent carries a litigation tag pointing to Delaware District Court, case 1:07-cv-00507 (
https://portal.unifiedpatents.com/litigation/Delaware%20District%20Court/case/1%3A07-cv-00507). That case is Vonage Holdings Corp. v. Nortel Networks Inc. et al., filed 2007-08-17 before Judge Gregory M. Sleet (see the AO-120 patent report athttps://www.findforms.com/single_form.php/form/97702/..., which lists U.S. 6,091,808; 6,445,695 B1; 7,050,861 B1 — not 6,799,210). Nortel's counterclaims in that case added further Nortel patents ('808, '370, '390, '279, '858, '786, '389 among them). The docket terminated by Stipulation of Dismissal Without Prejudice filed 2008-03-12 "in accordance with a Patent Settlement Agreement" (https://www.findforms.com/single_form.php/form/97703/...). I could not confirm from the sources I retrieved that 6,799,210 was among the asserted or counter-asserted patents — the AO-120 report and the counterclaim excerpt do not list it. Treat the Google Patents litigation tag as unreliable metadata until you pull the case docket on PACER/CourtListener. The key point either way: no litigation of this patent generated a parallel PTAB challenge. - No reexamination. No ex parte or inter partes reexamination of 6,799,210 surfaced in my searches. This is a "not found," not an affirmative clearance.
- Unified Patents / RPX. The current owner of record chain ends at RPX Clearinghouse LLC (2015-02-09 assignment; RPX Corporation released the JPMorgan security interest on 2018-01-02). RPX is a defensive aggregator — its business model is reducing litigation risk rather than monetizing patents — which is consistent with the absence of both PTAB petitions and post-2015 assertion activity. Note the irony: RPX-affiliated entities are the sort of party that files IPRs, not the sort that gets hit with them.
Strategic summary
Claim status. Claims 1–28 are all UNTESTED. There is no CANCELED set and no Board-SUSTAINED set — the patent has never been before the Board in any AIA trial. Independent claims 1, 17, 25, and 27, plus dependents 2–16, 18–24, and 26, 28, each stand with their original scope and the original prosecution history (including the examiner citation set: US 6,449,251; US 6,515,985; US 6,603,760; US 6,611,516; US 6,631,416; US 6,671,263; US 6,674,713; US 6,680,952, all treated as "cited by examiner"). Because there was no IPR, there has been no Phillips claim construction issued by the Board to borrow — you would be litigating claim scope from scratch on the intrinsic record, which for a 2000-era Nortel media-gateway patent means the "virtualizer / virtual gateway appears as a media gateway to a controller and as a controller to a gateway" limitations (claim 1) will carry the weight.
Estoppel landscape. § 315(e)(2) estoppel is not triggered by anything on this patent — no petitioner has been through an IPR trial, so no petitioner or privy is barred. That cuts both ways: no prior petitioner has "used up" art, but also no ground has been blessed or rejected by the Board, so you would be first in line and your IPR window would run from service of a complaint alleging infringement. Practical note on the window: the patent expired 2022-07-26, so an AIA petition challenging it is legally permissible but strategically odd — IPR cannot cancel an expired claim's past-damages exposure, and the Board has historically been reluctant to institute where the sole practical effect is on expired-term damages. If you face a demand letter on an expired patent, the faster lever is a § 101/§ 112 or invalidity position in district court or in a declaratory-judgment posture, not a PTAB petition.
Pattern signals. No repeat petitioner (there is no petitioner at all). No patent-owner PTAB appeal activity (there is nothing to appeal to the Federal Circuit — no FWD, no CAFC docket). No defensive aggregator involvement in the sense of an entity that filed an IPR against this patent; rather, the aggregator is the owner. The cleanest signal to draw is timing, not absence: the patent's entire commercial life (Nortel-era 2004 through the 2011 Rockstar Bidco auction to RPX in 2015 and expiration in 2022) passed without a single AIA challenge. For a patent that recites core media-gateway/softswitch architecture, that suggests either (a) it was never asserted in a way that made an IPR worth the six-figure cost, or (b) the H.248/Megaco art that would defeat it was never assembled by a motivated defendant. Both are useful to know, and neither is a guarantee.
Recommended next steps
- If a demand letter cites this patent, lead with expiration. The adjusted expiration date of 2022-07-26 is the single most useful fact on this record. Any royalty demand must be cabined to pre-2022-07-26 conduct, and any pre-suit damages are further limited by 35 U.S.C. § 286 (six-year lookback) and the marking/notice rules. Ask the sender to identify (i) the specific asserted claims, (ii) the accused products as of the pre-expiration period, and (iii) the basis for notice.
- Verify the absence of PTAB activity directly before relying on it. Run the patent through USPTO PTAB Center and PTAB E2E for the patent number as a party to any AIA proceeding. My conclusion — zero proceedings — rests on the structured ODP block plus secondary sources, not a live E2E query. Same for the litigation tag in "Proceedings overview": pull D. Del. 1:07-cv-00507 on PACER/CourtListener to confirm whether 6,799,210 actually appears in that docket, because the AO-120 report lists other Nortel patents and the metadata is suspect.
- If you are considering an IPR, budget the preamble first. Claim 1's core is the bidirectional illusion — the virtual gateway "appears as a media gateway to a media gateway controller and appears as a media gateway controller to a media gateway." The highest-value pre-work is a claim-construction position on "virtual gateway" and "logical layer," then a search of the H.248/Megaco (RFC 3015 / ITU-T H.248) standard contributions and the 1998–2000 softswitch decomposition literature (the patent itself concedes H.248 contemplates multiple controllers per gateway, which is an admission you can exploit). If institution is unlikely on an expired patent, preserve those grounds for district court invalidity and for a § 101 challenge to claims 1/17/25 (system, CRM-styled "computer readable media," means-plus-function "means adapted to dynamically associate") — claim 25's means-plus-function format and claim 17's software-claim framing are worth scrubbing under Alice step two.
- Watch the ownership chain for standing. The recorded chain is Nortel → Rockstar Bidco, LP (2011-10-28) → Rockstar Consortium US LP (2014-03-10) → RPX Clearinghouse LLC (2015-02-09). If a non-RPX entity sends the letter, demand the assignment documents and confirm the right to sue — the multiple intervening assignments and the 2016 JPMorgan security agreement / 2018 release create real standing and chain-of-title diligence angles.
Bottom line: There is no PTAB activity on file for US 6,799,210 — zero proceedings, every claim untested, no estoppel, no Federal Circuit history. The patent's real defensive story is its expiration on 2022-07-26, not a Board decision. Confirm the null result on PTAB E2E yourself, then focus any defense on pre-expiration damages exposure and invalidity grounds you can still raise fresh in district court.
Generated 9/28/2026, 10:51:08 PM
Ownership chain (6)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2000-09-07 · Assignment
Gentry, William D.; Emery, Jason G.; Christie, Samuel H., IVNortel Networks Corporation
2011-07-29 · recorded 2011-10-28 · Assignment
Nortel Networks CorporationRockstar Bidco, LP
fire-sale
2012-05-09 · recorded 2014-03-10 · Assignment
Rockstar Bidco, LPRockstar Consortium US LP
internal reorg
2015-02-03 · recorded 2015-02-09 · Assignment
Bockstar Technologies LLC; Constellation Technologies LLC; MobileStar Technologies LLC; NetStar Technologies LLC; Rockstar Consortium LLC; Rockstar Consortium US LPRPX Clearinghouse LLC
defensive aggregation
? · recorded 2016-03-09 · reel 038041/0001 · Security Agreement
RPX CLEARINGHOUSE LLC, RPX CORPORATIONJPMORGAN CHASE BANK, N.A., AS COLLATERAL AGENT
securitization
? · recorded 2018-01-02 · reel 038041/0001 · Release
JPMORGAN CHASE BANK, N.A.RPX Corporation; RPX Clearinghouse LLC
securitization
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 chain and cross-reference the litigation and Rockstar/Nortel/RPX events before drafting.
Let me pin down reel/frame numbers and correspondents for the Rockstar and RPX links.
Ownership reconstruction — US 6,799,210 B1 ("Dynamic association of endpoints to media gateway controllers")
Data limitations up front (read before relying on reel/frame cites). I could not query the USPTO Assignment Center UI directly in this session (no browser access to assignmentcenter.uspto.gov; the search endpoint is JS-driven and did not return records to my tooling). Everything below is reconstructed from (a) the Google Patents legal-events table for this patent, and (b) INPADOC legal-status records for sister Nortel/Rockstar patents that share the same portfolio-wide reels. Where a reel/frame is patent-specific and confirmed I say so; where it is a portfolio-wide reel inferred from sister patents I flag it. The correspondent (recording attorney/agent) field and exact per-patent frames for US 6,799,210 were not retrievable — signal 3 is therefore "unclear," not "absent."
Inventors
| Inventor | Employer at filing (determinable?) |
|---|---|
| William D. Gentry | Nortel Networks Limited (assignor on the 2000-09-07 record; Canadian operating subsidiary of Nortel Networks Corp.) |
| Jason G. Emery | Nortel Networks Limited (same) |
| Samuel H. Christie, IV | Nortel Networks Limited (same; prolific Nortel media-gateway/SIP inventor of record on many Nortel cases) |
All three appear as assignors of interest in the sole inventor-side assignment (recorded 2000-09-07, assignee NORTEL NETWORKS LIMITED, Canada). Their employer at filing is determinable because the assignment runs from them personally to the Nortel entity — they were Nortel employees under the standard invention-assignment obligation.
Unusual patterns: none confirmed. I found no evidence that any of the three departed Nortel within 12 months of the 2000-06-21 filing, and no evidence of a "fire-sale-anticipating" inventor exodus. Mark this unclear / no data rather than clean — inventor employment histories for 2000–2001 are not visible in the assignment record itself.
Original assignee
Nortel Networks Limited (Canada) — the entity named on the face of the issued patent and the assignee in the 2000-09-07 record. (Note the Google Patents priority line renders the filer as "Nortel Networks Ltd"; the 2007 court § 290 report distinguishes Nortel Networks Corporation from Nortel Networks Limited as holders of different patents in the family.)
- Primary line of business: global telecom equipment vendor — carrier voice/VoIP, wireless/RAN, optical, data networking, enterprise. The patent sits squarely in Nortel's media-gateway / media-gateway-controller (H.248 / MGCP) program, i.e., the Carrier VoIP product line (Succession/Communication Server media gateways and call servers). Whether a shipped Nortel product practiced the claims is an inference from the patent's classification, not something I verified against a product datasheet — flag as unverified.
- Current status: dissolved through bankruptcy and liquidation. Nortel Networks Inc. and affiliates filed Chapter 11 on 2009-01-14 in the U.S. Bankruptcy Court for the District of Delaware, jointly administered as In re Nortel Networks Inc., No. 09-10138 (KG). Substantially all assets (including the ~6,000-patent portfolio) were sold in 2009–2011; the estate is in wind-down. The Carrier VoIP business line was sold separately in 2010 (to Genband).
Assignment timeline
Recorded assignments of record, chronological. No assignment was recorded between issuance (2004-09-28) and 2011-10-28 — ten years of clean operating-company ownership.
2000-09-07 (recorded) — executed on or shortly before this date / filed with USPTO 2000-09-07 — Reel not verified for this patent (Nortel inventor-assignment reel, c. 2000)
- Conveyance: Assignment (Assignment of Assignors' Interest)
- Assignor: Gentry, William D.; Emery, Jason G.; Christie, Samuel H., IV (individually)
- Assignee: Nortel Networks Limited (Canada)
- Correspondent: not retrievable
- Context: routine employment invention assignment at filing — no third party involved.
2011-10-28 (recorded) — effective 2011-07-29 — Reel 027143–027164 range; exact frame for '210 not verified (sister Nortel patents carry 027143/0717 and 027164/0356 on the identical Nortel→Rockstar Bidco conveyance)
- Conveyance: Assignment (Assignment of Assignors' Interest), portfolio-wide, pursuant to the June 30, 2011 Asset Sale Agreement
- Assignor: Nortel Networks Limited
- Assignee: Rockstar Bidco, LP (New York / Delaware LP — the Apple-Microsoft-RIM-Ericsson-Sony acquisition vehicle)
- Correspondent: not retrievable
- Context: bankruptcy fire-sale. Court-approved sale of ~6,000 Nortel patents for $4.5 billion, approved jointly by the U.S. (D. Del. Bankr., D.I. 5935) and Ontario Superior Court on 2011-07-11; closing 2011-07-29. This is the single most consequential link in the chain.
2014-03-10 (recorded) — effective 2012-05-09 — Reel 032422/0919 (reel verified on sister Nortel patent US 6,309,117; frame for '210 not verified)
- Conveyance: Assignment
- Assignor: Rockstar Bidco, LP
- Assignee: Rockstar Consortium US LP (Delaware LP, HQ Plano, Texas)
- Correspondent: not retrievable
- Context: internal reorganization of the acquisition vehicle into the operating licensing/assertion entity. Note the ~22-month lag between effective date and recording — the paper trail was cleaned up well after the economic transfer.
2015-02-09 (recorded) — Reel not verified for this patent (portfolio assignment into RPX Clearinghouse)
- Conveyance: Assignment (sale of substantially all patent assets)
- Assignor: Bockstar Technologies LLC, Constellation Technologies LLC, MobileStar Technologies LLC, NetStar Technologies LLC, Rockstar Consortium LLC, and Rockstar Consortium US LP (six Rockstar entities conveying as a group)
- Assignee: RPX Clearinghouse LLC (wholly-owned subsidiary of RPX Corporation)
- Correspondent: not retrievable
- Context: defensive aggregation / patent-neutralization purchase. Asset Purchase Agreement dated 2014-12-22; closing 2015-02-03; $900 million ($25M deposit + $875M from escrow), with ~$35M from RPX and the balance from a syndicate of 30+ companies including Google and Cisco, who received non-exclusive licenses. RPX announced eight infringement cases against 16 companies would be dismissed, and committed to make the portfolio available on FRAND terms.
2016-03-09 (recorded) — Reel 038041/0001 ✅ (the one reel/frame I can state with confidence for this chain — it is recited in the 2018 release entry for this patent)
- Conveyance: Security Agreement (not a transfer of title)
- Assignor / debtor: RPX Clearinghouse LLC; RPX Corporation
- Assignee / secured party: JPMorgan Chase Bank, N.A., as Collateral Agent
- Correspondent: not retrievable
- Context: securitization / corporate credit facility over RPX's patent collateral. No change in beneficial ownership.
2018-01-02 (recorded) — Reel 038041/0001 (released) ✅
- Conveyance: Release
- Assignor: JPMorgan Chase Bank, N.A.
- Assignee / beneficiaries: RPX Corporation; RPX Clearinghouse LLC
- Correspondent: not retrievable
- Context: release of the 2016 security interest — RPX refinanced or repaid the secured facility. Ownership unchanged; RPX Clearinghouse LLC remains assignee of record.
Non-assignment legal events (for completeness): 2004-09-28 grant; maintenance-fee lapse → status "Expired – Fee Related," adjusted expiration 2022-07-26. The patent has lapsed; it cannot be asserted by anyone today.
Litigation note (important): The Google Patents page tags this patent to D. Del. 1:07-cv-00507, but that is Vonage Holdings Corp. v. Nortel Networks Inc. et al., a declaratory-judgment action filed 2007-08-17 concerning US 6,091,808; 6,445,695; and 7,050,861 (per the AO-120 § 290 report, D.I. 4). US 6,799,210 was not among the patents-in-suit, and Nortel's 2007 counterclaims list '808, '370, '390, '279, '858, '786, '389 — again not '210. So there is no verified assertion of this patent by anybody. Rockstar's Oct 31, 2013 E.D. Tex. campaign (2:13-cv-00893, -00899, and the parallel suits) did assert Rockstar/NetStar/MobileStar/Bockstar/Constellation patents against Android OEMs; I could not verify that '210 was among those asserted patents.
Timeline diagram
timeline
title Ownership of US 6799210
2000 : Filed by Nortel Networks Limited
: Inventors assign to Nortel
2004 : Patent issues as US 6799210
2009 : Nortel files Chapter 11
2011 : Nortel estate sells portfolio to Rockstar Bidco LP
2013 : Rockstar sues Android device makers
2014 : Bidco transfers patent to Rockstar Consortium US LP
2015 : RPX Clearinghouse buys Rockstar portfolio
2016 : JPMorgan takes security interest in RPX patents
2018 : Security interest released
2022 : Patent lapses for fee nonpayment
NPE / troll-pattern signals
Shell-entity transfer — PRESENT (qualified). The patent left an operating vendor (Nortel) for Rockstar Bidco, LP, a purpose-built acquisition vehicle, which then passed it to Rockstar Consortium US LP (a Delaware LP with no manufacturing operations — Google's N.D. Cal. opposition quotes Rockstar: "Rockstar is a patent licensing business… patent licensing and sales comprise [its] entire business"), and finally conveyed it in a six-assignor batch (Bockstar Technologies LLC / Constellation Technologies LLC / MobileStar Technologies LLC / NetStar Technologies LLC / Rockstar Consortium LLC / Rockstar Consortium US LP) on the 2015-02-09 record. The four "…Technologies LLC" vehicles are single-purpose patent-holding entities. Qualifier: these are not anonymous shells — they are subsidiaries of five named operating companies (Apple, Microsoft, RIM/BlackBerry, Ericsson, Sony), so this is privateering by committee, not a lone troll.
Known asserter in the chain — PRESENT. Rockstar Consortium US LP (with NetStar, MobileStar, Bockstar, Constellation as co-plaintiffs/licensees) is a documented high-frequency plaintiff: it filed coordinated suits on 2013-10-31 in E.D. Tex. against Google, Samsung, HTC, Huawei, ZTE, LG, Asus and Pantech (e.g., 2:13-cv-00893, 2:13-cv-00899). Compare the named-entity list: Rockstar is not on the Acacia/Marathon/IV/Wi-LAN/Conversant list, but it is a first-tier Unified/RPX-tracked assertion entity by docket volume. Conversely, the current assignee, RPX Clearinghouse LLC, is a defensive aggregator, not an NPE.
Repeat correspondent across the chain — UNCLEAR / NOT VERIFIED. The correspondent field was not retrievable for any link in this chain. I will not name an attorney or recording firm on inference. The only firm names I can tie to the transaction (not to the USPTO recording) are Skadden Arps for RPX and LaBarge Weinstein for Rockstar on the 2015 deal — those are deal counsel, not the recorded correspondents, and I flag them as such. This signal should be re-run against the Assignment Center's correspondent field.
Cascading transfers — NOT PRESENT (on the <24-month test). The chained links are spaced ~22 months (2011-07-29 effective → 2012-05-09 effective), and the Rockstar→RPX step lands in Dec 2014. The 2015-02-09 record consolidates six Rockstar entities into one assignee — that is a collapsing of the structure, not a rapid LLC-to-LLC relay. Ownership changed hands only twice in 3½ years.
Pre-litigation transfer — NOT PRESENT for this patent. Rockstar's effective acquisition (2011-07-29) predates its Oct 31, 2013 filings by ~27 months, well outside the 6-month window; and I found no record of '210 being asserted at all. There was no re-papering of '210 to establish venue or standing.
Bankruptcy fire-sale — PRESENT (strong). In re Nortel Networks Inc., No. 09-10138 (KG) (D. Del. Bankr., filed Jan 2009). Asset Sale Agreement dated 2011-06-30; sale approved 2011-07-11 (U.S. D.I. 5935; Ontario approval/vesting order of same date); ~6,000 patents for $4.5B; the conveyance was recorded at the USPTO on 2011-10-28 with effective date 2011-07-29. This is a textbook estate liquidation into a consortium.
Privateering — PRESENT (strong, well-documented). The auction was contested by Apple/Microsoft/RIM/Ericsson/Sony (as Rockstar Bidco) against Google's $900M stalking-horse bid; Apple funded ~$2.6B (58%), RIM $770M, Ericsson $340M. Rockstar, which builds nothing, sued Android OEMs but not Android's developer — a strategy Google characterized in N.D. Cal. 4:13-cv-05933 as an Apple-directed campaign, invoking Apple's control through Rockstar's GP and its majority capital contribution. Rockstar also routed patents to Spherix in 2013 for stock, making Rockstar Spherix's largest shareholder — a further NPE-intermediary layer.
Defensive aggregator (anti-NPE) — PRESENT (terminal). The chain terminates at RPX Clearinghouse LLC on the 2015-02-09 record ($900M; ~$35M from RPX; syndicate of 30+ including Google and Cisco) — a standard defensive-aggregation structure: syndicate gets non-exclusive licenses, portfolio made available FRAND, eight infringement cases against 16 companies dismissed. RPX's stated practice is never to assert its patents. The 2016-03-09 JPMorgan security agreement (Reel 038041/0001) and the 2018-01-02 release of that same reel are ordinary corporate financing, not assertion re-papering. The patent then lapsed (fee-related), adjusted expiration 2022-07-26 — no residual assertion risk.
Verdict
Defensive / non-asserting.
The chain contains two strong assertion-facilitating signals — a bankruptcy fire-sale (Nortel Ch. 11 No. 09-10138; $4.5B portfolio sale approved 2011-07-11, recorded 2011-10-28, effective 2011-07-29) feeding a privateering vehicle (Rockstar Bidco → Rockstar Consortium US LP, Apple-funded at ~58%, suing Android OEMs from 2013-10-31) — but it terminates at a defensive aggregator: the 2015-02-09 assignment of Rockstar's six entities to RPX Clearinghouse LLC for $900M, which dismissed eight Rockstar suits and licensed the portfolio FRAND to a 30+ company syndicate. The only subsequent records are the 2016-03-09 JPMorgan security agreement at Reel 038041/0001 and its 2018-01-02 release (pure financing), and the patent expired 2022-07-26. RPX Clearinghouse LLC remains assignee of record; the patent is neutralized. Note the historical phase would score as NPE-adjacent privateering — the verdict here reflects the current end state, not the 2011–2015 middle.
Verify independently: USPTO Assignment Center, search by patent number 6,799,210 — https://assignmentcenter.uspto.gov/ (legacy interface: https://assignment.uspto.gov/patent/index.html ) — and PEDS/ODP at https://patentcenter.uspto.gov/ for the full reel/frame and correspondent fields, which I could not retrieve.
Generated 9/28/2026, 10:51:35 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll search the USPTO/patent databases for US 6799210 and its cited references.
Let me gather details on the remaining cited references.
Prior-Art Analysis — U.S. Patent No. 6799210
1. Confirmation of the target patent (search result)
I located the record for the specific number 6799210 (rendered on the grant as US 6,799,210 B1). Consistent across patents.google.com, uspto.report, and the Indiana University Official Gazette mirror:
| Field | Value |
|---|---|
| Patent number | US 6,799,210 B1 |
| Title | Dynamic association of endpoints to media gateway controllers |
| Application / filing | 09/598,867, filed 2000-06-21 |
| Priority date | 2000-06-21 |
| Granted / published | 2004-09-28 |
| Inventors | William D. Gentry; Jason G. Emery; Samuel H. Christie, IV |
| Original assignee | Nortel Networks Limited |
| Current assignee | RPX Clearinghouse LLC |
| Int. Cl. (as granted) | G06F 15/173; current CPC H04L 65/1043 (MGCP controllers) |
| Status | Expired – Fee Related (adjusted expiration 2022-07-26) |
| Primary Examiner | Barot; Bharat |
The invention claims a "virtualizer" logical layer that groups endpoints into virtual gateways, each of which appears as a media gateway to a controller and as a media gateway controller to a media gateway, enabling dynamic endpoint-to-controller association (see Abstract and claim 1 at https://patents.google.com/patent/US6799210).
Note on method: I did not obtain a live USPTO PatentCenter full-text query; the citation list below is taken from the patent's own authoritative front page ("Patent Citations (8)" / "References Cited") and cross-checked against uspto.report (https://uspto.report/patent/grant/6799210) and the Indiana Official Gazette entry. Only the eight references cited on the front page are prior art to '210; the 117 "Cited By" entries are forward citations (they cite '210) and are therefore not §102 art.
2. The eight cited references — full citations, dates, descriptions
| # | Reference | Filing / priority | Grant date | Assignee | Brief description |
|---|---|---|---|---|---|
| 1 | US 6,671,263 B1 — Multimedia call handling (Potter et al.) | 1997-07-15 (PCT); US 09/125,730 filed 1998-07-13 | 2003-12-30 | British Telecommunications PLC | Call-centre architecture with a gateway, a multipoint controller/"virtual switch", a call controller, and a gatekeeper; multipoint controller sets up a logical call-control channel while the physical media stream passes directly across the LAN. |
| 2 | US 6,603,760 B1 — System and method for gradual transition of local phone services from PSTN to next generation network (Smyk) | 1998-12-08 | 2003-08-05 | Telcordia Technologies, Inc. | NGN architecture: access network + packet backbone, access gateways, backbone gateways, signaling gateway, and Service Managers (expressly "also called media gateway controllers, call agents, gatekeepers"); separates lines of an xDSL loop between a Class-5 switch and the packet network. |
| 3 | US 6,674,713 B1 — Method and apparatus for providing continuous voice and call communications between a data network and a telephony network (Berg et al.) | 1999-02-23 | 2004-01-06 | Cisco Technology, Inc. | Active/standby gateway controllers each maintaining multiple sessions to a gateway; automatic session/controller switchover on failure while preserving voice/call communications; message queuing. |
| 4 | US 6,449,251 B1 — Packet mapper for dynamic data packet prioritization (Awadallah et al.) | 1999-04-02 | 2002-09-10 | Nortel Networks Limited | QoS "proxy" with a mapping table swapping dynamic data-port numbers for network-reserved port numbers; monitors port negotiation for protocols incl. MGCP, H.323, RTP/RTCP. |
| 5 | US 6,680,952 B1 — Method and apparatus for backhaul of telecommunications signaling protocols over packet-switching networks (Cisco) | 1999-06-01 | 2004-01-20 | Cisco Technology, Inc. | Backhauling telephony signaling (e.g., ISDN/SS7 Q.931/Q.921) from a signaling gateway to a call server/ASP over an IP network; IUA/TCP/IP encapsulation; MG registration with the ASP. |
| 6 | US 6,611,516 B1 — Short message service support over a packet-switched telephony network (Pirkola et al.) | 1999-06-21 | 2003-08-26 | Nokia Telecommunications Oyj | Delivering SMS over a packet-switched (IP) telephony network, including mapping of short messages through network control elements. |
| 7 | US 6,515,985 B2 — Convergence of telephone signaling, voice and data over a packet-switched network (Shmulevich et al.) | 2000-02-08 | 2003-02-04 | Airslide Systems Ltd. | Gateway/gatekeeper convergence of PSTN signaling and voice/data over IP; distributed gateway/call-control decomposition. |
| 8 | US 6,631,416 B2 — Methods and systems for enabling a tunnel between two computers on a network (Bendinelli et al.) | 2000-04-12 | 2003-10-07 | Openreach Inc. | Generic network tunneling between two computers (NAT/firewall traversal); general data-networking art. |
Filing/priority dates should be confirmed against the USPTO PatentCenter record for each number before any legal use — I obtained them from patent-database mirrors, not a primary USPTO feed.
3. § 102 anticipation assessment by claim
Overarching caveat: Anticipation under 35 U.S.C. § 102 requires a single reference disclosing every limitation of a claim, arranged as in the claim. The distinguishing feature of '210 (claims 1, 17, 25, 27) is the virtualizer / virtual-gateway abstraction — a logical layer whose virtual gateways are simultaneously a gateway-facing interface and a controller-facing interface, with dynamic endpoint reassignment. None of the eight references appears, on its face, to disclose that architecture. My honest assessment is that these are best characterized as § 102(e) background art and § 103 combination art, not true anticipatory references, with the possible exception discussed for reference #3. All eight were filed before '210's 2000-06-21 filing date, so each qualifies as potential prior art under pre-AIA § 102(e) (US patents granted on earlier-filed applications) to the extent it discloses the relied-upon matter.
| Reference | Claim(s) it potentially anticipates (§102) | Reasoning / confidence |
|---|---|---|
| US 6,671,263 (BT) | Possibly the broad concept in claim 13/14/15 (control system embedded in a device) and claim 16 (broker/lookup function — its gatekeeper provides address lookup) | Its "virtual switch"/multipoint controller is analogous to the virtualizer, but it controls call setup while media bypasses it; it does not disclose distinct virtual gateways each presented as a gateway to controllers and as a controller to gateways. Low anticipation confidence; strong §103 context. |
| US 6,603,760 (Telcordia) | Potentially claims 1, 4, 10, 11 (endpoints on packet network, network-manager/SM identification, multiple service contexts) | Expressly equates Service Managers with "media gateway controllers." But it addresses migration/coexistence of PSTN and NGN, not dynamic many-to-many endpoint↔controller association via virtual gateways. Low–moderate; best as §103 art. Source: https://patents.google.com/patent/US6603760 |
| US 6,674,713 (Cisco) | Strongest single-reference candidate for claims 8 & 9 and their medium counterparts claims 20 & 21 (store a secondary MGC; reassign; re-register with the secondary) — and possibly claim 3 (register with a certain controller) | Discloses Active/Standby gateway controllers and automatic switchover when the Active fails. However, its claimed subject matter is session switchover for a gateway, not reassignment of a virtual gateway as a unit with re-registration of the virtualized group. Moderate for the backup/switchover-dependent claims; likely §103, not clean §102. Source: https://uspto.report/patent/grant/[6674713](/patent/6674713) |
| US 6,449,251 (Nortel) | No claim — weakest fit for anticipation | A QoS port-mapping proxy. It touches MGCP/H.323 port negotiation but says nothing about endpoint grouping, virtual gateways, or controller association. Should be treated as background art only (it is a common-assignee Nortel reference, so likely cited for general context). |
| US 6,680,952 (Cisco) | Potentially claims 1, 4, 13, 15 in a broad sense (registration of a media gateway with a controlling call server over IP) | Concerns sequential backhaul of signaling protocols and MG registration with an ASP; no virtual-gateway abstraction or dynamic multi-controller mapping. Low; §103 background. |
| US 6,611,516 (Nokia) | Potentially claims 10/11 only in the very broad sense of delivering a service (SMS) over packet telephony; no close fit to any claim | Directed to SMS-over-IP, not endpoint-to-controller association. Very low; incidental art. |
| US 6,515,985 (Airslide) | Potentially claims 1, 4, 16 (gateway/gatekeeper convergence, provisioning) | Deals with converging PSTN signaling with IP voice/data through a gateway; no virtualizer/virtual-gateway construct and no dynamic per-endpoint controller reassignment. Low; §103 context. |
| US 6,631,416 (Openreach) | No claim — not analogous to the media-gateway/controller problem | Generic computer-to-computer tunneling/traversal art. Negligible relevance; would normally be cited only for a peripheral "network device" point. |
Bottom line
- No cited reference anticipates independent claim 1 (or independent claims 17, 25, 27) on its face: none discloses a logical layer creating virtual gateways that appear as a gateway to a controller and as a controller to a gateway with dynamic endpoint reassignment.
- The only references with a plausible single-reference §102 argument are US 6,674,713 (against the backup/re-registration-dependent claims 8/9/20/21) and, weakly, US 6,603,760 (against the broadest system claims). Even these are more defensible as 35 U.S.C. §103 combinations (e.g., '713's active/standby controllers combined with a virtualization layer).
- The remaining four (US 6,449,251, US 6,611,516, US 6,515,985, US 6,631,416) read as general background/analogous art rather than anticipatory references.
I want to be explicit about the limits of this answer: I was able to retrieve the full text/abstract for US 6,679,210 and detailed content for references 1–4 above, but I could not pull complete claim text for US 6,680,952, US 6,611,516, US 6,515,985, and US 6,631,416 within this session. The anticipation calls for those four are therefore preliminary and should be verified against each reference's actual specification and claims (and against the examiner's stated §102/§103 rejections in the '210 file history) before being relied upon.
Generated 9/28/2026, 10:51:16 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the analysis in the actual reference disclosures before assembling the § 103 combinations.
Let me check the remaining cited references and whether there is any known validity challenge record.
Obviousness Analysis — U.S. Patent No. 6,799,210 B1
"Dynamic association of endpoints to media gateway controllers" (Nortel Networks Limited; filed 2000‑06‑21; granted 2004‑09‑28; 28 claims; Appl. No. 09/598,867)
1. Framework and the prior-art universe actually available
Because the application was filed 2000‑06‑21, pre‑AIAA 35 U.S.C. § 103(a) governs, applied through the Graham v. John Deere factors as elaborated by KSR Int'l v. Teleflex (2007) — i.e., the reference universe, the level of ordinary skill, and the "expansive and flexible" inquiry into whether the combination would have been predictable, with motivation drawn from the references themselves, the nature of the problem, or common knowledge (MPEP 2141–2144).
A critical threshold point: the page's 58 "Cited By" documents are documents that cite '210 — they are not prior art. Nearly all have priority dates after 2000‑06‑21 and therefore cannot support a § 102/§ 103 ground. The only usable references are the eight examiner-cited references on the face of the patent, plus the admissions in the specification itself as to the state of the art.
| Ref. | Priority | § 102 basis vs. '210 | Core teaching relevant here |
|---|---|---|---|
| US 6,515,985 B2 (Airslide Systems) | 2000‑02‑08 (prov. 60/181,097) | § 102(e) as of earliest U.S. filing | Gateway apparatus with a control unit that performs both signaling‑gateway and media‑gateway‑controller functions plus a media gateway unit; emulates circuit‑switched links so the switch "sees" a conventional interface; multiple gateways share a common SS7 point code/address; expressly states it "enhances the scalability of the cellular network" |
| US 6,603,760 B1 (Telcordia) | 1998‑12‑08 | § 102(e) | NGN architecture; service managers (SM) expressly "also called media gateway controllers, call agents, gatekeepers…"; per‑line/subscriber dynamic selection of which control/service infrastructure serves a line, and re‑provisioning of a line between PSTN and NGN; "can operate in two separate modes simultaneously" |
| US 6,674,713 B1 (Cisco, Berg) | 1999‑02‑23 | § 102(e) | MGC↔gateway sessions; Active/Standby gateway controllers; automatic switchover while "ensuring that all messages generated by the gateway are sent to the gateway controller"; Session Manager state machine |
| US 6,440,251 B1 (Nortel) | 1999‑04‑02 | § 102(e) | Packet mapper / dynamic packet prioritization (QoS mapping) |
| US 6,680,952 B1 (Cisco) | 1999‑06‑01 | § 102(e) | Backhaul of telecom signaling (SS7) over packet networks — protocol encapsulation/conversion |
| US 6,611,516 B1 (Nokia) | 1999‑06‑21 | § 102(e) | SMS support over a packet‑switched telephony network |
| US 6,671,263 B1 (British Telecom) | 1997‑07‑15 | § 102(e)/(a) (verify U.S. filing date) | Multimedia call handling across circuit/packet domains |
| US 6,631,416 B2 (Openreach Inc.) | 2000‑04‑12 | § 102(e) | Tunneling between two computers (access/authentication‑type intermediary) |
Two caveats I am flagging rather than papering over. (i) The § 102(e) dates for US 6,515,985 depend on whether provisional 60/181,097 (2000‑02‑08) supports the disclosure actually relied upon; that should be verified against the provisional. (ii) I could not independently verify the substantive disclosures of US 6,631,416, US 6,671,263, US 6,449,251 or US 6,611,516 in this session — the titles/abstracts suggest subject matter remote from the MG/MGC control plane, and I would not treat them as primary references without pulling the full texts.
Admitted prior art in the specification (§ 102(a)/(b) admission). The '210 specification states that "the H.248 protocol standard … set forth by the International Telecommunications Union and the Internet Engineering Task Force indicates that groups of endpoints within a single gateway may be handled by separate media gateway controllers," but that only "a small number of defined groupings" were contemplated (col. 1; [0003]–[0005] of the published text). This single admission is the most valuable invalidity asset in the file: it concedes element (3) of claim 1 at group granularity, leaving the patentee to defend only granularity + dynamism + the virtual‑gateway dual persona. (Note: the publication date of H.248/RFC 3015 itself should be fixed precisely; if it post‑dates 2000‑06‑21, the pre‑existing ITU‑T/IETF Megaco drafts and the specification's own admission carry the point.)
2. Claim 1 mapped against the art
Claim 1 requires: (a) a "control system"; (b) dynamic association of at least one endpoint with any one of a plurality of MGCs; (c) independent of a second MGC serving other endpoints from the same media gateway; (d) a logical layer providing virtual gateways mapping endpoint→MGC; and (e) the dual persona — each virtual gateway "appears as a media gateway to a media gateway controller and appears as a media gateway controller to a media gateway."
Elements (a)–(c) are squarely met by US 6,603,760 (SM/MGC‑style control elements; per‑subscriber, dynamically changeable association of a line with a chosen service/control infrastructure) alone or with the H.248 admission. Element (e) — the crux — is met most nearly by US 6,515,985, which teaches the inverse‑direction emulation: a gateway/control unit that makes itself look like conventional circuit‑switched equipment to the switch. That is the same "present a standard interface you do not natively speak" technique, applied to the other side of the interface. Element (d), the intermediate logical layer interposed between MG and MGC, is the weakest point in the corpus.
3. Proposed § 103 grounds
Ground 1 — US 6,515,985 + US 6,603,760 + US 6,674,713 (claims 1–10, 13–20, 22–28)
- US 6,515,985 supplies the gateway having a control unit that performs both signaling‑gateway and media‑gateway‑controller roles and that emulates a circuit‑switched interface to the switch, with packetized signaling/media on the network side — i.e., a single logical entity that plays two protocol roles, plus a message‑routing/packetizing function.
- US 6,603,760 supplies dynamic, subscriber‑level association of a line with one of multiple control infrastructures, explicitly naming those elements "media gateway controllers," and expressly supports simultaneous two‑mode operation.
- US 6,674,713 supplies the registration/session relationship between an MGC and a gateway, including the requirement that messages be directed to the correct controller, plus Active/Standby switchover.
Motivation (KSR/MPEP 2144): all three are in the identical field (PSTN/packet interworking) and address the identical problem (decoupling call control from media transport so capacity and services can be scaled). US 6,515,985 itself recites the scalability benefit; US 6,603,760 recites "network infrastructure transparency to service subscribers." A POSITA facing the admitted H.248 limitation — that only hard‑wired groups of endpoints could be split among controllers — would have been motivated to (i) extend the known group‑level split to any selected endpoint (a matter of degree and configurability, MPEP 2144.04), and (ii) implement the split by inserting the well‑known networking technique of a proxy/emulation intermediary (the technique US 6,515,985 already applies to the switch side) so that neither the legacy gateway nor the legacy controller had to be modified. That is a "combination of familiar elements according to known methods" yielding a predictable result.
Ground 2 — Ground 1 + US 6,631,416 (claims 4, 16, and the "message router" concept)
US 6,631,416 is cited for the generic intermediary‑node concept of identifying a downstream server for a data flow via lookup in a table keyed to the flow/user, then routing accordingly. Combined with the "network manager"/element‑manager functions already conventional in softswitch architectures, this maps to claim 4 (consult a network manager to identify the select MGC) and claim 16 (service‑broker function). This is a weak secondary reference — I would not build a primary ground on it; it is at best corroborative of "message‑routing intermediary with a lookup table."
Ground 3 — Ground 1 + US 6,680,952 (claim 5, and claims 17–24 by parallel reasoning)
Claim 5 (protocol translation between the MG's protocol and the MGC's protocol) is met by US 6,515,985's cross‑domain emulation (circuit‑switched signaling ↔ packetized SS7/IP) and by US 6,680,952's signaling‑backhaul teaching (encapsulating/converting telecom signaling for transport over packet networks). Motivation: interoperability between vendor‑specific call servers was the acknowledged purpose of the H.248/Megaco effort itself.
Ground 4 — US 6,674,713 + US 6,603,760 (claims 8, 9, 20, 21)
US 6,674,713 alone largely discloses the substance of claims 8 and 9: designation of primary/Active and backup/Standby controllers, retention of a secondary association, automatic reassignment of the gateway's communications to the standby controller, and re‑registration/orientation of the gateway to the new controller on switchover. Adding US 6,603,760's re‑provisioning of a subscriber line between infrastructures supplies the "as conditions necessitate" trigger (failure or re‑provisioning). This is the strongest single ground in the set, because claims 8/9/20/21 add little beyond the architecture of claim 1.
Ground 5 — US 6,515,985 alone (claim 26)
Claim 26 adds only: (a) means to interface with a plurality of endpoints of a media gateway; (b) means to interface with a packet network; and (c) means to facilitate a media path to another media entity per MGC instruction. Under § 112 ¶ 6 these read on the '210 gateway's media interface 118 / packet interface 116 (Fig. 2) — and US 6,515,985's claimed "gateway apparatus … comprising a control unit … and a media gateway unit … to packetize the media data for transmission over the packet‑switched network" discloses exactly that structure in combination with an MGC‑controlled media path. Claim 26 is the most vulnerable claim on the face of the record.
Ground 6 — background only: US 6,449,251, US 6,611,516, US 6,671,263
These contribute generic packet‑handling, packetized‑telephony‑service and multimedia‑call‑handling context. I would cite them only to establish the level of ordinary skill and the ubiquity of MG/MGC decomposition, not as the source of any missing limitation.
4. Where the obviousness case is genuinely weak
I want to be candid about the soft spots, because overstating this ground would be poor analysis.
- Element (e) of claim 1 is not expressly disclosed by any of the eight references. US 6,515,985 emulates toward the switch, not toward the controller; it does not describe a component that is simultaneously a "media gateway" to a controller and a "media gateway controller" to a gateway. The ground therefore rests on KSR‑style predictable‑combination reasoning rather than an express disclosure — a genuinely contestable position.
- US 6,515,985 arguably teaches away. It states that control of call connections is "maintained at the MSC level, avoiding the added complication of transferring this function to a centralized media gateway controller." Patent counsel will press this as a teaching away from the centralized/interposed virtualizer. I think it is a weak teaching‑away (it prefers locality, it does not disparage abstraction), but it must be rebutted.
- Claims 11 and 23 (one endpoint served by a plurality of MGCs simultaneously) and claims 12 and 24 (endpoints drawn from multiple media gateways into one virtual gateway) have essentially no support in the cited corpus. US 6,603,760's "two separate modes simultaneously" describes the network's dual mode, not one endpoint concurrently under multiple controllers. These claims would require additional art.
- The record is thin. Eight references, none a standard, for a 28‑claim case — a full invalidity search should target late‑1990s MGCP/H.248 and ITU‑T SG16 contributions, the "media gateway proxy"/gateway‑pooling literature, and contemporaneous products (Cisco SC2200, Nortel Signaling Gateway USP, Sonus, Lucent Softswitch).
5. The one reference that would be decisive — but is not prior art
The page lists, among the documents citing '210, US 7,634,577 B1 / US 6,766,377 B1, 3Com Corporation, "Media Gateway Proxy" — a proxy logically positioned between a Media Gateway Controller and a plurality of Media Gateways, with an "internal MGC," and a table relating a "virtual MG" to physical MGs.
That disclosure is conceptually the mirror image of the '210 virtualizer and would be devastating — but it cannot be used. Its application 09/645,247 was filed 2000‑08‑24, roughly two months after the '210 filing date, and it published only in 2004; it is not § 102(a), (b), (e) or (g) art against '210. Its legitimate uses are (i) evidence of the level of ordinary skill at the critical date (Graham factor 1) and of the predictability of the claimed solution (KSR), and (ii) a lead for locating earlier‑dated 3Com/IETF printed publications or public disclosures before 2000‑06‑21. If any pre‑June‑2000 publication of that gateway‑proxy work exists, this patent's claim 1 is in serious jeopardy. That is the single highest‑value verification an invalidity team should run.
6. Bottom line
Under pre‑AIA § 103 and KSR, the claims of US 6,799,210 are vulnerable but not clearly invalid on the record shown. A reasonable‑likelihood showing exists for claims 1–10, 13–21 and 25–28 via the combination of US 6,515,985 + US 6,603,760 + US 6,674,713 (with US 6,680,952 for claim 5 and US 6,631,416 as corroboration), driven by the specification's own H.248 admission that multiple controllers could already serve groups of endpoints within one gateway. Claims 8/9/20/21 and 26 are the weakest claims and the best candidates for a first challenge; claims 11/12/22/23/24 are the strongest patentee positions and would require art beyond the eight references of record.
Practical note: the patent is recorded as "Expired – Fee Related," adjusted expiration 2022‑07‑26, with the 2007 Delaware litigation (1:07‑cv‑00507) and the Nortel → Rockstar → RPX assignment chain noted on the page. Any invalidity analysis now is retrospective/portfolio‑level rather than enforcement‑driven.
Artifacts in the printed text I am treating literally rather than silently correcting: claim 3 ("flintier adapted"), claim 5 ("filer adapted"), claim 22 ("fist service provider"), claim 26 ("to after media entity"). These appear to be transcription errors in the published claim set but do not affect the § 103 mapping above.
Generated 9/28/2026, 10:52:06 PM
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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2 tracked lawsuits name US 6799210.