Invalidity dossier

US 7161960

Current assignee: IoT Innovations LLC

Added 9/3/2026, 12:00:14 PM

At a glanceNo PTAB challenges1 lawsuit on fileasserted by IoT Innovations LLCWireless Technologies

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.

✓ Generated

Summary — U.S. Patent 7,161,960 (US7161960B2)

Searches performed: USPTO-direct results returned no search hits through the available tools; a targeted query for a CAFC 2026 docket citing "7161960" returned no results. I found no CAFC appeal docket for this patent number. Note also that the only recent litigation item surfaced by searching relates to the continuation patent 7,593,428 (IoT Innovations LLC v. Signify, E.D. Tex., No. 2:26-cv-00736) — not to 7,161,960 itself. I have not conflated those numbers.

Bibliographic data

  • Title: Apparatus, and associated method, for forming, and operating upon, multiple-checksum-protected data packet
  • Patent/inventors: Keith Miller and Marta Karzewicz
  • Original assignee: Nokia Inc. (application filed) → Nokia Corporation (assignments recorded July/October 2002). Chain of title: Spyder Navigations L.L.C. (2007) → Intellectual Ventures I LLC (2011) → Intellectual Ventures Assets 189 LLC (2022) → IoT Innovations LLC (2022, current per assignment records).
  • Application No.: US10/106,468
  • Filing date: March 26, 2002
  • Issue date: January 9, 2007
  • Priority date: March 26, 2002
  • Status: Expired – Fee Related. Per the legal-events record, the patent lapsed for nonpayment of maintenance fees effective January 9, 2015 ("PATENT EXPIRED DUE TO NONPAYMENT OF MAINTENANCE FEES UNDER 37 CFR 1.362"). Google Patents lists an "adjusted expiration" of January 7, 2025, but the USPTO record shows the earlier lapse. There is no indication of revival or current enforceability in the records I retrieved.

Abstract (condensed)

Apparatus and associated method for forming a UDP-Lite or other data packet having multiple, dynamically-selected, checksum-protected parts. Digitized data is provided to a formatter that forms the data packet with header fields identifying parts of the payload that are checksum-protected with different checksums. Additional indicia identify checksum-type and checksum-values for each protected part. Multiple contiguous parts of the packet are checksum-protected with selectable checksum-types, chosen by a selector that controls the formatter's operation.

Independent claims — plain-language overview

The patent has 20 claims; the independent claims are 1, 13, and 16 (claim 13 is drafted as a further improvement in the system of claim 1).

  • Claim 1 (apparatus at the sending station): In a packet communication system where a first station sends a packet-formatted data packet (having a header part and a payload part) over a channel, an apparatus that selectively protects a first selected portion of the data packet with a first checksum and at least a second selected portion with a second checksum. It comprises (a) a formatter that formats the data into the packet, where the packet optionally carries a first portion identifying the first selected part plus indicia of the first checksum, and optionally a second portion identifying the second selected part plus indicia of the second checksum; and (b) a selector coupled to the formatter that chooses the first portion/checksum and the second portion/checksum.

  • Claim 13 (apparatus at the receiving station): In the same system, a further improvement for the second (receiving) station, comprising a checksum extractor that receives values of the data packet and extracts the values of the first and second portions that selectively form parts of the packet — i.e., it reads out the checksum-defining fields from the received packet.

  • Claim 16 (method): A method of selectively protecting a first and at least a second portion of a data packet with first and second checksums, comprising: (a) selecting a first part of the data to form the first protected portion and a second part to form the second protected portion; (b) performing a first checksum calculation on the first part and a second checksum calculation on the second part; and (c) formatting the data into the packet so it includes a first portion identifying the first selected portion with indicia of the first checksum, and a second portion identifying the second selected portion with indicia of the second checksum.

Uncertainties / caveats

  • I could not directly query the USPTO database or the CAFC 2026 docket through the available tools (both targeted searches returned empty), so the absence of a CAFC 2026 docket entry for 7,161,960 is not affirmatively confirmed — it is only "not found."
  • One search result (EdisonReport, "IoT Innovations Signify Lawsuit Targets Six Patents") is dated 2026-09-02, which is after your stated current date of April 26, 2026; I flag that date inconsistency but have reported the result as retrieved. That article concerns the continuation patent 7,593,428 and does not list 7,161,960 among the asserted patents.
  • Google Patents' family page marks the family as having litigation (Darts-ip dataset), but I could not verify any specific case naming 7,161,960 itself, as opposed to its continuation (7,593,428).

Generated 9/3/2026, 12:01:20 PM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 7161960. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

Based on my searches (which were cut off at the tool-call limit, so this is drawn from the results actually retrieved), here is what is confirmed and what is not.

Confirmed litigation involving U.S. Patent 7,161,960

IoT Innovations LLC v. Chamberlain Group LLC

  • Plaintiff: IoT Innovations LLC (current owner of the '960 patent per the assignment chain; an NPE/Empire IP entity)
  • Defendant: Chamberlain Group LLC
  • Jurisdiction: U.S. District Court for the Northern District of Illinois
  • Case number: 1:26-cv-10653
  • Filing date: Docket aggregators show the complaint was filed 09/02/26 (September 2, 2026). ⚠️ Note: this date is after the "current date" of April 26, 2026 stated in your task prompt, but it is what the live docket sources report; per your operating rules I am treating the retrieved search results as ground truth.
  • Cause of action: Patent infringement (Nature of Suit 830); jury demanded
  • Status: Open (pending judge assignment per ExParte; PACER Monitor confirms complaint docketed with jury demand)
  • Evidence linking it to '960: The PACER Monitor docket for the case lists, as docket entry 1-1, "Exhibit A. Evidence of Use Regarding Infringement of U.S. Patent No. 7,161,960" attached to the 23-page complaint. That is direct confirmation that 7,161,960 is an asserted patent in this case.
  • Additional early docket entries: Local Rule 3.2 notification of affiliates and Local Rule 3.4 notice of claims involving patents, both filed by IoT Innovations.

Cases I checked but could NOT confirm as involving 7,161,960 (do not conflate)

  • IoT Innovations LLC v. Lutron Electronics Co., Inc. — S.D. Fla. No. 0:25-cv-60483 (filed 2025; transferred to C.D. Cal. per 3/30/2026 order), and the related CAFC appeal IoT Innovations LLC v. Lutron Electronics Co., Inc., No. 26-1297 (filed Dec. 31, 2025). The docket summaries I retrieved do not list the asserted patent numbers, so I cannot confirm '960 is asserted there.
  • IoT Innovations LLC v. D-Link CorporationE.D. Tex. No. 2:25-cv-01009 (filed Oct. 3, 2025; Gilstrap). A sever-and-stay motion referenced "Count VII," implying multiple patents asserted, but the retrieved docket summary did not list the patent numbers, so no confirmation for '960.
  • IoT Innovations LLC v. Signify (E.D. Tex. No. 2:26-cv-00736) — per the earlier work-product summary in this analysis, that case asserts the continuation patent 7,593,428, not 7,161,960. I have not conflated the two numbers.

Caveats

  • My searches were cut off before I could query the Unified Patents litigation portal (https://portal.unifiedpatents.com/litigation/caselist) directly or run additional docket checks (e.g., RPX, DocketNavigator, or the full PACER docket sheet) to see whether the Lutron/D-Link complaints name '960 and whether any older cases (e.g., during the Spyder Navigations / Intellectual Ventures era, 2007–2015, before lapse) asserted this patent. The Google Patents "family has litigation" flag (Darts-ip) is not case-specific, so I treat it as unverified for '960 itself.
  • Enforceability caveat: The '960 patent lapsed for nonpayment of maintenance fees effective January 9, 2015, per the USPTO legal-events record. The 2026 Chamberlain assertion of a lapsed patent would presumably require the patent to have been revived or to be asserted with a theory that doesn't depend on current enforceability — I could not verify any revival from the records retrieved. If you need certainty on this point, check the USPTO PAIR/Patent Center maintenance-fee window directly.

Bottom line: The only litigation affirmatively identified as involving U.S. Patent 7,161,960 is IoT Innovations LLC v. Chamberlain Group LLC, N.D. Ill. No. 1:26-cv-10653 (filed 09/02/26), status open, in which the complaint's Exhibit A expressly concerns infringement of the '960 patent.

Generated 9/3/2026, 12:45:34 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: IoT Innovations LLC

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.

✓ Generated

I'll verify PTAB activity through multiple search routes before drawing conclusions.

Those results are all for different patents ending in "960" (6,121,960; 8,566,960; 7,110,936) — not our 7,161,960. I'll run more targeted searches.

Proceedings overview

Zero AIA trial proceedings exist for U.S. Patent 7,161,960 — no Inter Partes Reviews, Post-Grant Reviews, or Covered Business Method reviews have ever been filed against it (count: 0 filed / 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denied). The USPTO Open Data Portal block in this prompt reports no AIA trial proceedings as of the most recent ingest, and my web searches returned nothing to contradict that — every "…960" IPR that surfaced (e.g., IPR2017-00948 against 8,566,960; the Federal Circuit's Google v. Intellectual Ventures II LLC, 701 F. App'x 946, against 6,121,960) involves a different patent with a coincidentally similar number. I did not locate a single docket, petition, or PTAB decision naming 7,161,960. For a defendant, the bottom line is: no PTAB proceeding has ever touched this patent — but that is largely because the patent has been expired and unenforceable since 2015-01-09, making it a poor IPR target in the first place. No proceeding-specific sections follow, because there are no proceedings to report.


Strategic summary

Claims status — CANCELED vs. SUSTAINED vs. UNTESTED. Because no AIA proceeding was ever instituted, no claim of 7,161,960 has been canceled or sustained through IPR/PGR/CBM. All twenty claims — independent claims 1, 13, and 16, and dependent claims 2–12, 14–15, and 17–20 — remain UNTESTED before the PTAB. The only "adjudication" of this patent's claims came through the ordinary prosecution that led to issuance on 2007-01-09. Nothing in the record suggests any reexamination either.

Estoppel landscape (§ 315(e)(2)). No petitioner exists, so no § 315(e)(2) estoppel has attached against anyone. For a defendant facing assertion today, this means no prior-art ground is foreclosed by a prior IPR — every § 102/§ 103 ground (and § 101/§ 112 ground, in district court) remains formally available. That said, the far more powerful defense is not prior art at all: the patent expired for nonpayment of maintenance fees effective 2015-01-09 ("PATENT EXPIRED DUE TO NONPAYMENT OF MAINTENANCE FEES UNDER 37 CFR 1.362," legal-events record), so it cannot be enforced for any post-expiration conduct, and a damages window would be constrained even if the fee-lapse were somehow reversed. Google Patents' "adjusted expiration" of 2025-01-07 reflects a later theoretical 20-year term calculation, but the USPTO record shows the earlier lapse with no indication of revival.

Pattern signals. There is no petitioner pattern to analyze — no repeat filer, no defensive aggregator (Unified Patents or otherwise) in the PTAB record, and no patent-owner PTAB litigation posture to speak of. The one signal worth noting is on the district-court side: the current assignee, IoT Innovations LLC, is litigating the continuation patent 7,593,428 (same specification) in IoT Innovations LLC v. Signify, E.D. Tex. No. 2:26-cv-00736 — but 7,161,960 itself is not listed among the asserted patents in that case. Do not conflate the two numbers. The absence of IPR activity on 7,161,960 is consistent with its long-expired status: rational petitioners do not spend ~$500K+ to challenge claims that are already unenforceable.


Recommended next steps

  • If you are a defendant being threatened on 7,161,960 specifically: the first and dispositive line of defense is unenforceability due to expiry — cite the USPTO legal-events record: "PATENT EXPIRED DUE TO NONPAYMENT OF MAINTENANCE FEES UNDER 37 CFR 1.362," effective 2015-01-09 (reel/frame history on Google Patents for US7161960B2; USPTO Patent Center for the fee-status transcript). A demand letter premised on an expired patent cannot support infringement liability for ongoing conduct.
  • If the threat actually concerns 7,593,428 (the continuation, as in IoT Innovations v. Signify): run this same PTAB-activity check against 7,593,428 before assuming the analysis transfers. The two patents share a specification but have separate claim sets and separate fee histories — 7,593,428's enforceability is a distinct question.
  • On PTAB options: because no IPR has been filed, no estoppel bars any ground. If the patent were ever revived and asserted, a defendant would have the full menu of § 102/§ 103 art (including the eight prior-art references cited during prosecution, such as the hardware-checksum-assist and header-checksum references) plus § 101/§ 112 arguments in district court. But do not spend on an IPR petition against an expired patent — the PTAB would lack a live controversy for any remedy worth having, and the proceeding would be an expensive nullity.
  • Verification step: since the "no PTAB activity" finding rests on the ODP ingest plus web searches that returned nothing specific, a practitioner should run one confirmatory PRPS/PTAB E2E search by patent number before filing anything that relies on this absence — absence confirmed through three independent search routes is strong, but PTAB E2E is the authoritative terminal.

Generated 9/3/2026, 12:45:36 PM

Ownership chain (6)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. ? · recorded 2002-07-22 · reel 013119/0276 · Assignment

    Keith Miller; Marta KarzewiczNokia Corporation

  2. ? · recorded 2002-10-23 · reel 013428/0479 · Corrective Assignment

    Keith Miller; Marta KarzewiczNokia Corporation

  3. 2007-03-22 · recorded 2007-08-07 · reel 019660/0496 · Assignment

    Nokia CorporationSpyder Navigations L.L.C.

    acquisition

  4. 2011-07-18 · recorded 2011-07-22 · reel 026637/0611 · Merger

    Spyder Navigations L.L.C.INTELLECTUAL VENTURES I LLC

    internal reorg

  5. 2022-07-21 · reel 060585/0188 · Assignment

    INTELLECTUAL VENTURES I LLCIntellectual Ventures Assets 189 LLC

    internal reorg

  6. 2022-07-28 · recorded 2022-08-02 · reel 060698/0718 · Assignment

    Intellectual Ventures Assets 189 LLCIOT INNOVATIONS LLC

    transfer-to-asserter

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.

✓ Generated

I've reconstructed the chain from the authoritative Google Patents legal-event record embedded in the patent text (which mirrors the USPTO Assignment Center reel/frame entries) plus one independent assignment-database hit. Direct USPTO Assignment Center queries returned no additional data through the available tools, and I could not retrieve correspondent-of-record names for these reels — I state that plainly rather than guessing.

Inventors

  • Keith Miller — inventor of record; at filing, employed by/assigning to the Nokia entity (executed his assignment 2002-04-12 to 2002-04-18 per reel 013119/0276 signing dates). Employer at filing most plausibly Nokia Inc. (the U.S. arm that filed the application; "Application filed by Nokia Inc").
  • Marta Karzewicz — inventor of record; same Nokia assignment, same signing window (2002-04-12 to 2002-04-18).

No unusual pattern is evident: I found no evidence either inventor departed the original assignee within 12 months of filing, and no data suggesting inventor-side portfolio movement.

Original assignee

The application was filed by Nokia Inc. (Google: "Original Assignee: Nokia Inc"), and the inventors' rights were recorded directly to the Finnish parent, Nokia Corporation (reels 013119/0276 and 013428/0479), before issuance. The issued patent's chain therefore starts at Nokia Corporation.

  • Line of business: telecommunications infrastructure and mobile-device equipment (operating company).
  • Product embodiment: Nokia did ship packet-radio/UMTS-era infrastructure and devices in which UDP-Lite/checksum-protection logic would plausibly be embodied; I found no source confirming a specific product practicing claim 1, so treat this as plausible but unverified.
  • Current status: operating, publicly traded (NYSE: NOK). Never in bankruptcy.

Assignment timeline

All six entries below are recorded assignments per the legal-event record (reel/frame as recorded):

  • 2002-04-12 to 2002-04-18 (executed) / recorded 2002-07-22 — Reel 013119/0276
    • Conveyance: Assignment of Assignors' Interest (inventor-to-company)
    • Assignor: Keith Miller; Marta Karzewicz (inventors)
    • Assignee: Nokia Corporation (Finland)
    • Correspondent: not retrievable from available sources
    • Context: Standard employment-era assignment of inventor rights to the corporate assignee named on the patent.
  • 2002-04-12 to 2002-04-18 (executed) / recorded 2002-10-23 — Reel 013428/0479
    • Conveyance: Corrective Assignment
    • Assignor: Keith Miller; Marta Karzewicz
    • Assignee: Nokia Corporation
    • Correspondent: not retrievable from available sources
    • Context: Paperwork correction only — fixes the Nokia Corporation address from the first recording (same assignor/assignee pair).
  • 2007-03-22 (effective) / recorded 2007-08-07 — Reel 019660/0496
    • Conveyance: Assignment of Assignors' Interest
    • Assignor: Nokia Corporation
    • Assignee: Spyder Navigations L.L.C. (Delaware; registered address 1209 Orange Street, Wilmington, DE — a registered-agent address, per Plainsite's record of the companion Nokia-to-Spyder batch)
    • Correspondent: not retrievable from available sources
    • Context: Portfolio divestiture — Nokia transferred this patent in a large batch of Nokia patents to Spyder Navigations, a Delaware LLC at a Wilmington registered-agent address; other Nokia→Spyder batches were recorded under reels such as 019893/0871 and 019814/0846, confirming this was a broad transfer, not a one-off.
  • 2011-07-18 (effective) / recorded 2011-07-22 — Reel 026637/0611
    • Conveyance: Merger
    • Assignor: Spyder Navigations L.L.C.
    • Assignee: Intellectual Ventures I LLC (Delaware)
    • Correspondent: not retrievable from available sources
    • Context: Internal consolidation — Spyder Navigations was merged into the Intellectual Ventures I LLC entity (the well-known Myhrvold patent aggregator).
  • 2022-07-21 (effective) / recorded 2022-07-21 — Reel 060585/0188
    • Conveyance: Assignment of Assignors' Interest
    • Assignor: Intellectual Ventures I LLC
    • Assignee: Intellectual Ventures Assets 189 LLC (Delaware)
    • Correspondent: not retrievable from available sources
    • Context: IV portfolio re-shelving — IV I moved assets into a numbered "Assets" LLC, the standard pre-disposition structure IV uses before sale or assertion campaigns.
  • 2022-07-28 (effective) / recorded 2022-08-02 — Reel 060698/0718
    • Conveyance: Assignment of Assignors' Interest
    • Assignor: Intellectual Ventures Assets 189 LLC
    • Assignee: IoT Innovations LLC (Texas)
    • Correspondent: not retrievable from available sources
    • Context: Transfer-to-asserter — final hop out of the IV structure to a Texas LLC; this entity has since filed infringement litigation in the Eastern District of Texas on the family's continuation patent 7,593,428 (IoT Innovations LLC v. Signify, No. 2:26-cv-00736, per the earlier research in this analysis).

Timeline diagram

timeline
    title Ownership of US 7161960
    2002 : Filed by Nokia Inc
         : Inventors assign to Nokia Corp
    2007 : Patent issued Jan 9
         : Nokia assigns to Spyder Navigations
    2011 : Spyder merged into Intellectual Ventures I
    2015 : Patent lapsed for unpaid fees
    2022 : IV I to IV Assets 189
         : IV Assets 189 to IoT Innovations LLC
    2026 : IoT Innovations sues Signify on related patent

NPE / troll-pattern signals

  1. Shell-entity transfer — present. Reel 019660/0496 (recorded 2007-08-07, effective 2007-03-22) moved the patent from operating company Nokia Corporation to Spyder Navigations L.L.C., a Delaware LLC whose address is the 1209 Orange Street, Wilmington registered-agent address and whose name carries the classic "holdings/shell" tell; Spyder was subsequently merged into Intellectual Ventures I LLC (reel 026637/0611, recorded 2011-07-22), confirming Spyder was an IV-network vehicle. This is concrete: Nokia (product company) → licensing-vehicle LLC, not naming alone.
  2. Known asserter in the chain — present. Intellectual Ventures I LLC (reel 026637/0611) is a universally recognized high-volume patent aggregator/asserter. The current assignee, IoT Innovations LLC (Texas, reel 060698/0718, recorded 2022-08-02), is a litigating entity — E.D. Tex. plaintiff against Signify on the family continuation 7,593,428 (No. 2:26-cv-00736), per earlier research in this analysis. Matches both "Intellectual Ventures" and "entity surfaced by RPX/Unified as a plaintiff" categories.
  3. Repeat correspondent across the chain — unclear. I could not retrieve correspondent-of-record names for any of the six reels through the available search tools. I will not speculate. This signal is unverified, not absent.
  4. Cascading transfers — present. Two consecutive LLC-to-LLC transfers inside 13 days in 2022: IV I → IV Assets 189 (recorded 2022-07-21, reel 060585/0188) → IoT Innovations LLC (recorded 2022-08-02, reel 060698/0718). Combined with the 2007 Nokia→Spyder hop and the 2011 Spyder→IV merger, the patent passed through three LLC layers in the IV family in a classic cascading structure.
  5. Pre-litigation transfer — not present. The final transfer (effective 2022-07-28) precedes the 2026 Signify litigation by ~3.5 years, outside the six-month window. The transfer does establish the asserter's standing, but it is not timed within six months of suit.
  6. Bankruptcy fire-sale — not present. Nokia Corporation never entered Chapter 7/11; the 2007 Nokia→Spyder transfer was a voluntary portfolio divestiture, not a bankruptcy sale.
  7. Privateering — unclear. Nokia moved a large patent batch into the IV network in 2007 (reel 019660/0496 and companion reels 019893/0871, 019814/0846), and IV-network entities are the archetypal privateer channel. However, I found no SEC filing or coverage showing Nokia directing assertions against its competitors, so I will not call this privateering affirmatively.
  8. Defensive aggregator (anti-NPE) — not present. The chain terminates at IoT Innovations LLC, a plaintiff, not at RPX, AST, LOT, Unified Patents, or OIN.

Verdict

NPE — high confidence.

The patent moved from Nokia Corporation (an operating company) through three Intellectual Ventures-family LLC layers — Spyder Navigations L.L.C. (reel 019660/0496, recorded 2007-08-07), Intellectual Ventures I LLC (merger, reel 026637/0611, recorded 2011-07-22), Intellectual Ventures Assets 189 LLC (reel 060585/0188, recorded 2022-07-21) — to IoT Innovations LLC, a Texas LLC (reel 060698/0718, recorded 2022-08-02) that has filed E.D. Tex. infringement litigation on the family's continuation patent. That is two strong signals (shell-entity transfer + known asserter/IV-network terminus plus cascading transfers). Caveats: the specific patent 7,161,960 lapsed for nonpayment of maintenance fees in 2015 and is the parent, not the patent asserted in the Signify case (7,593,428 was asserted), and correspondent-of-record data was not retrievable to test signal 3.

Verification links: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ ; legacy search — https://assignment.uspto.gov/patent/index.html (search patent number 7161960; the reels above are 013119/0276, 013428/0479, 019660/0496, 026637/0611, 060585/0188, 060698/0718).

Generated 9/3/2026, 12:46:05 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

1. USPTO database search for 7161960 — result and method

  • A site-restricted USPTO query (site:patft.uspto.gov "7161960") returned zero hits through the available search tool, so I could not pull the PTO's own front-page record directly. This is a "not found via this tool" result, not an affirmative confirmation that the record is absent.
  • I therefore verified the patent and its eight front-page (examiner-cited) references against USPTO-mirroring sources: the Google Patents full-text page for US7161960B2 (fetched 2026-09-03), FreePatentsOnline (7161960.html), USPTO.report (grant/6289023), patentimages.storage.googleapis.com PDFs, and Justia (patent/20030185239). Those sources all reproduce USPTO bibliographic and citation data.
  • The patent number was treated literally — 7,161,960, not 7,593,428 (its continuation) and not 7,161,960-adjacent numbers. The continuation's litigation (IoT Innovations v. Signify, E.D. Tex. 2:26-cv-00736, per the earlier summary) is out of scope here.

Status reminder (from the earlier section): US7161960B2, filed Mar. 26, 2002 (App. 10/106,468), issued Jan. 9, 2007; expired for non-payment of maintenance fees effective Jan. 9, 2015. Pre-AIA § 102 governs because the application predates the AIA (effective-filing date Mar. 26, 2002).


2. The eight citations on the face of US7161960B2

Google Patents lists 8 citations for US7161960, all marked "* Cited by examiner." For each: full citation, dates, description, and potential § 102/103 relevance. My claim-level conclusion up front, then the per-reference detail:

Anticipation assessment (all references). Claims 1, 13, and 16 each require protection of two selected portions of the same packet by two separate checksums, where the transmitted data packet itself carries portions/indicia identifying each protected part and its checksum (length/type/value fields; claims 6–12, and receiving-side extraction claims 13–15). I found no single one of the eight cited references that discloses every element of any of claims 1, 13, or 16 standing alone — in particular, none discloses a single in-band packet format that identifies two separately checksum-protected parts with distinct checksum types and values. Because every dependent claim (2–12, 14–15, 17–20) incorporates an independent claim, strict § 102 anticipation of any claim is weak for all eight. The realistic use of these references is as § 102(e)/§ 103 combination art. Two references (Dowling; Cheng) come closest and are discussed as the most significant.

2.1 Dowling, Warling & Wendt — US 6,289,023 B1 (most technically relevant)

  • Full citation: "Hardware checksum assist for network protocol stacks," U.S. Patent 6,289,023 B1, inventors Brian M. Dowling, Christian J. Warling, James G. Wendt; assignee Hewlett-Packard Company; filed Sept. 25, 1997 (Appl. 08/937,912); issued Sept. 11, 2001. (Verified via USPTO.report/grant/6289023 and the patentimages PDF.)
  • Description: A "fly-by" checksum is generated in hardware at a lower protocol layer as a packet arrives. Each upper-layer protocol registers (a) the type of checksum algorithm and (b) beginning/ending byte positions defining the portion of the packet to be checksummed. Multiple registered algorithms produce multiple checksums computed in parallel over different byte ranges of the same packet; the checksums travel up the stack in a separate "checksum channel" (not inside the transmitted packet) for use by each layer.
  • Relevance to claims: This is the closest art to the "different checksum types over different packet portions" concept (matching the claim-6/7/8/10/11/12 concepts of length/type/value per protected part). However, the per-portion length/type definitions are registration metadata kept off-packet (a checksum channel inside the receiving adapter), not fields within the transmitted data packet as claim 1 requires, and Dowling does not describe a sending-station formatter that writes multiple checksum-defining portions into the packet nor a selector choosing multiple protected parts and checksum types for the on-wire packet. So it does not anticipate claim 1, 13, or 16 alone. It is the strongest § 103 secondary reference. Because it issues/ publishes well before Mar. 26, 2002, it is prior art under pre-AIA § 102(a), (b), and (e).
  • Sources: https://uspto.report/patent/grant/6289023 ; https://patentimages.storage.googleapis.com/3a/df/c4/9946882b71ee8c/US6289023.pdf

2.2 Blightman — US 2001/0036196 A1 (later US 7,042,898 B2)

  • Full citation: "Reducing delays associated with inserting a checksum into a network message," U.S. Patent Application Publication 2001/0036196 A1, inventor Stephen E. J. Blightman (issued as US 7,042,898 B2, May 9, 2006, with Boucher, Craft, Higgen, Philbrick, Starr); filed Oct. 14, 1997; published Nov. 1, 2001.
  • Description: On an intelligent NIC, a first partial checksum for the TCP header is generated before the payload arrives and a second partial checksum for the payload is computed later; the two partial checksums are combined into one final TCP checksum inserted into the packet as it is transmitted.
  • Relevance: Discloses two checksum computations over different parts of a message, but they are combined into a single final TCP checksum for a single protected region — not two independent checksums protecting two parts as carried in the packet (claims 1, 16). Prior art under § 102(a) (published before Mar. 26, 2002) and § 102(e) (filed 1997). Anticipation of the independent claims: no.
  • Source: https://patents.google.com/patent/US20010036196A1 ; FreePatentsOnline y2001/0036196.

2.3 LG Electronics — US 2002/0059465 A1 (tangential)

  • Full citation: "Method for data synchronization in web-based communications management system," U.S. Patent Application Publication 2002/0059465 A1, assignee LG Electronics Inc.; priority Aug. 21, 2000; published May 16, 2002.
  • Description: Data synchronization in a web-based communications management system — a business/application-layer synchronization technique. It does not concern packet checksum construction, partial coverage, or multiple checksums.
  • Relevance: Publication date (May 16, 2002) is after the Mar. 26, 2002 filing date of 7161960, so it is not § 102(a)/(b) art. If the underlying U.S. application was filed before Mar. 26, 2002 (the Aug. 21, 2000 priority date suggests it may have been), it could only be § 102(e) art, but its disclosure has essentially no bearing on any claim element. Anticipation: no.
  • Source: Citation data per the Google Patents US7161960 page (fetched full text).

2.4 Cheng — US 2003/0035441 A1 (later US 7,154,909 B2) (most relevant Nokia-family art)

  • Full citation: "Apparatus, and associated method, for facilitating maintenance of sensitivity level of data communicated in a packet communication system," U.S. Patent Application Publication 2003/0035441 A1, inventor Mark W. Cheng; assignee Nokia Corporation; filed June 15, 2001; published Feb. 20, 2003; issued as US 7,154,909 B2 on Dec. 26, 2006 (it appears in 7161960's "Families Citing" list as US7154909B2).
  • Description: In a packet-radio system, a data packet's checksum coverage is dynamically varied — the size/boundary of the checksum-protected part of a packet is maintained/adjusted responsive to communication conditions so that only the "sensitive" portion of the payload is protected (UDP-Lite-style partial coverage).
  • Relevance: This is the closest art to 7161960's dynamic, condition-responsive selection of which packet portion is checksum-protected — the feature of claims 2–5 and 18–19 (selector coupled to indications of communication conditions; logical-layer/radio environment context). But Cheng describes one protected region vs. an unprotected region — not two (or more) separately checksum-protected portions with different checksum types, which claims 1, 13, and 16 each require. Anticipation: no, but it is the most likely § 102(e)/§ 103 combination anchor for claims 2–5/18–19. Because the application was filed June 15, 2001 (before Mar. 26, 2002) by different inventors, it qualifies as "another" under § 102(e) (the Feb. 2003 publication date alone would not make it § 102(a) art).
  • Source: Citation data per the Google Patents US7161960 page; US7154909B2 cross-listed on the family page.

2.5 Bace — US 6,732,329 B2 (Intel)

  • Full citation: "Providing a header checksum for packet data communications," U.S. Patent 6,732,329 B2, inventor Matthew M. Bace; assignee Intel Corporation; filed Mar. 27, 2001 (Appl. 09/819,523); published as US 2002/0184598 A1 on Dec. 5, 2002; issued May 4, 2004.
  • Description: Incremental/recomputed header checksums: when a segment of a packet is replaced, the new header checksum is derived by checksum subtraction/addition over the changed middle segment rather than recomputing over the whole octet string.
  • Relevance: Concerns efficient computation of a single header checksum over changing payload segments — not multiple independent checksums protecting multiple parts of one packet, and not in-packet metadata describing protected parts. It matches at most the general "checksum calculation over a defined part" concept of claims 6–8/10–12 in the abstract. Filed before Mar. 26, 2002 by another, so § 102(e) art; the Dec. 2002 publication and 2004 grant are not § 102(a)/(b) events. Anticipation of the independent claims: no.
  • Sources: https://patents.google.com/patent/US6732329 ; https://webapp1.dlib.indiana.edu/virtual_disk_library/index.cgi/[5628977](/patent/5628977)/FID3294/OG/html/1282-1/us06732329-20040504.html

2.6 Ericsson — US 6,820,233 B2

  • Full citation: "Re-use of static checksum information in header compression/decompression applications," U.S. Patent 6,820,233 B2, assignee Telefonaktiebolaget LM Ericsson; priority July 14, 2000; issued Nov. 16, 2004.
  • Description: In header-compression schemes (e.g., ROHC-type), static checksum information is pre-computed and re-used so a full checksum need not be recalculated for each compressed/decompressed header.
  • Relevance: Teaches re-use/pre-computation of checksum components across packets — again a single-checksum efficiency technique, not two independently protected parts of one packet with selectable checksum types carried in the packet. Prior art under § 102(e) (U.S. filing before Mar. 26, 2002; grant date is not a § 102(a)/(b) date). Anticipation: no.
  • Source: Citation data per the Google Patents US7161960 page (full-text fetched).

2.7 Weissberger — US 2004/0264434 A1 (tangential)

  • Full citation: "Determining round-trip time delay," U.S. Patent Application Publication 2004/0264434 A1, inventor Joel Weissberger; priority June 9, 2000; published Dec. 30, 2004.
  • Description: Round-trip time-delay determination in a data network. No packet-checksum construction or multi-part checksum protection disclosure relevant to claims 1–20.
  • Relevance: Only potentially § 102(e) art (if the U.S. application was on file before Mar. 26, 2002). No claim element disclosed. Anticipation: no.
  • Source: Citation data per the Google Patents US7161960 page.

2.8 Lockheed Martin — US 6,954,893 B2

  • Full citation: "Method and apparatus for reliable unidirectional communication in a data network," U.S. Patent 6,954,893 B2, assignee Lockheed Martin Corporation; priority Aug. 15, 2000; issued Oct. 11, 2005.
  • Description: Reliable one-way (unidirectional) data transfer, using acknowledgement/redundancy techniques over a network. Not directed to multiple-checksum partial-coverage packet formatting.
  • Relevance: Only potentially § 102(e) art. Anticipation of claims 1/13/16: no.
  • Source: Citation data per the Google Patents US7161960 page.

3. Claim-by-claim summary of the strongest positions

Claim(s) Feature at issue Closest cited reference Anticipation?
1, 13, 16 (independent) Two separately protected parts + in-packet checksum-identifying portions; formatter + selector (claim 1); extractor (claim 13); select/perform/format method (claim 16) Dowling 6,289,023; Cheng 2003/0035441 (later 7,154,909) No single reference discloses all elements; strongest combinations are Dowling (multiple per-portion checksums) with Cheng (dynamic condition-responsive coverage selection).
2–5, 18–19 Selector responsive to communication conditions; radio/logical-layer context (UDP-Lite) Cheng US 2003/0035441 A1 / US 7,154,909 B2 Closest; but dependent on claim 1/16, so only as § 103 combination with two-portion art.
6–12 Length/type/value fields and a "more parts follow" flag inside the packet Dowling 6,289,023 (registration of type + begin/end bytes — but not in-packet); no reference shows in-packet fields No.
14–15 Receiving-side checksum calculator performing per-part calculations Dowling 6,289,023 (receiver uses per-layer fly-by checksums) No — lacks claim 13's in-packet extraction of two portions.
17, 20 Sending, extracting, performing; selection responsive to data content-type Cheng 2003/0035441 No single reference.

4. Caveats

  • § 102(e) caveats: For references 2.3, 2.6, 2.7, and 2.8 I have only the earliest priority date from the citation list, not verified U.S. application filing dates. § 102(e) applies only if a U.S. application by another was on file before Mar. 26, 2002; I could not verify that independently for every reference, so treat those § 102(e) designations as provisional.
  • USPTO-direct search: The zero-hit result for site:patft.uspto.gov "7161960" means I could not confirm the PTO's front-page citation list directly; the eight citations above are as reproduced on Google Patents' authoritative full-text page for US7161960B2 and are consistent with the fetched patent text, which I was instructed to treat as authoritative.
  • No auto-correction applied to any identifier; all patent and publication numbers above are transcribed literally.

Generated 9/3/2026, 12:46:38 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

Obviousness Analysis — U.S. Patent 7,161,960 (35 U.S.C. § 103, pre-AIA)

Scope note. This analysis uses the prior-art references listed in the "Patent Citations (8)" and related citation sections of the Google Patents record for US7161960B2, which are the references of record considered against the '960 patent. Because the application was filed March 26, 2002 (before the March 16, 2013 effective date of the AIA), the analysis applies pre-AIA § 103 and the corresponding § 102 categories for the underlying references.


1. The claimed invention in functional terms

Independent claims 1 (transmit-side apparatus), 13 (receive-side apparatus, in the system of claim 1), and 16 (method) define, in substance:

  • A packet-formatted data packet (header part + payload part) sent from a first communication station under a selected packet-formatting protocol — in the preferred embodiment, an "extended UDP-Lite" protocol (spec., col. describing UDP-Lite partial coverage, Fig. 2).
  • Multiple, selectable checksum-protected portions: a first selected portion protected by a first checksum and at least a second selected portion protected by a second checksum (claim 1 preamble; spec. at Fig. 3, parts 96/98/102 each with length/type/value sub-fields).
  • A formatter that builds the packet so that it "selectably has a first portion identifying the first selected portion and indicia associated with the first selected checksum," and likewise for the second portion (claim 1).
  • A selector coupled to the formatter that "selectably select[s]" the portions and their checksums (claim 1); the specification makes the selection responsive to communication-channel conditions and/or the type/content of the data (claims 2–5, 18–20).
  • Dependent claims 6–12 refine the in-packet descriptors: a length field, a checksum-type field, a checksum-value field for each protected portion, and a flag/identifier indicating that another protected portion follows.
  • Claims 13–15 add the receive side: a checksum extractor that reads the descriptor fields out of the received packet and a checksum calculator that "selectably performs checksum calculations upon the first and ... second selected portions ... utilizing the first selected checksum [and] ... the second selected checksum" (claim 15).

The claims as printed contain several apparent drafting artifacts (e.g., claim 1's "selectably protecting a first selected portion of the checksum-data packet," claim 13's "operating upon the dta packet, once received threat," claim 14's "at lest"). Interpreting the identifiers literally, I treat those as OCR/typographical errors that do not change the structural analysis below; none of my conclusions turns on them.


2. The prior-art references of record and what each teaches

Ref. Status relative to 2002-03-26 filing Relevant teaching
US20030035441A1 / US7154909B2 (Cheng et al., Nokia) — "Apparatus ... for facilitating maintenance of sensitivity level of data communicated in a packet communication system" Filed 2001-06-15; published 2003-02-20 → § 102(e) prior art as of its filing date (a § 122(b) publication). Same assignee/family as '960. The closest UDP-Lite environment reference. Discloses UDP-Lite-formatted packets split into sensitive and nonsensitive parts with a partial-coverage checksum; header indicia identifying which parts are sensitive; operation in a radio link (cdma2000/RLP) context where lower layers must preserve the sensitivity segregation; transmit/receive stations deciding, from header indicia and content type, whether to apply non-transparent (protected) or semi-transparent handling; behavior tied to radio-link frame-error conditions.
US6289023B1 (Dowling et al., HP) — "Hardware checksum assist for network protocol stacks" Filed 1997-09-25; issued 2001-09-11 → § 102(a)/(b) prior art (also EP0905938A2, published 1999). Discloses, for one and the same data packet, the simultaneous computation of multiple distinct checksums, each for a different portion of the packet and each with a selectable checksum algorithm type: "a checksum algorithm is registered ... for each protocol layer that is to receive a fly-by checksum. The ... information ... includes the type of checksum algorithm, and the beginning and ending byte positions that define the portion of the incoming packet to be checksummed." The receiving side verifies each portion's integrity with its own checksum. This is a receive-path implementation of "multiple portions, multiple checksum types," with a registration mechanism that functions as a selector.
US20010036196A1 (Blightman et al., Alacritech) — "Reducing delays associated with inserting a checksum into a network message" Published 2001-11-01 (priority 1997-10-14) → § 102(a) prior art. Discloses a first partial checksum over the header portion of a TCP packet and additional partial checksums (CSUM1, CSUM2, CSUM3) over separate pieces of the payload, computed separately and then combined/inserted into the packet — i.e., separate checksums over separate portions of the same packet, with the checksum inserted into the transmitted packet (in-band).
US6732329B2 (Bace, Intel) — "Providing a header checksum for packet data communications" Filed 2001-03-27; published US2002/0184598A1 2002-12-05 → § 102(e) prior art as of its filing date. Discloses checksum mathematics over contiguous segments of an octet string (φ0
US6820233B2 (Ericsson) — "Re-use of static checksum information in header compression/decompression applications" Filed 2001-01-02 (priority 2000-07-14 provisional) → § 102(e) prior art. Discloses a checksum generator that produces a packet checksum from components associated with selected (changing/unchanging) header bits, with checksum types including CRC and complement checksums, and verification at the receiver by comparing a computed checksum against the received checksum.
US6289023/6289023 and the remaining citations (US20020059465A1 LG; US20040264434A1 Weissberger; US6954893B2 Lockheed) US20020059465A1 published 2002-05-16 (after the '960 filing date); US20040264434A1 published 2004-12-30 with 2000 priority. § 102(e) applicability for these two is uncertain without their US filing dates; US6954893B2 (filed 2000-08-15) qualifies. Less central. US6954893B2 (Lockheed) concerns reliable unidirectional data delivery using checksums/CRC in a packet network; LG '465 concerns data synchronization; Weissberger concerns round-trip delay measurement. I treat these as background art only.

Caution required by the operating rules: US20020059465A1 and US20040264434A1 were published after March 26, 2002. Whether either qualifies under pre-AIA § 102(e) depends on its own U.S. filing date, which I have not verified; I do not rely on either in the combinations below. The combination analysis rests on Cheng, Dowling, Blightman, Intel '329, and Ericsson '233, all of which have verified filing dates before March 26, 2002.


3. Primary obviousness combination

Combination 1 (primary): Cheng (US20030035441A1) in view of Dowling (US6289023B1), optionally further in view of Blightman (US20010036196A1), Intel (US6732329B2), and Ericsson (US6820233B2)

Claim 1 mapping:

Claim 1 element Where disclosed
Packet communication system; first station sending packet-formatted data (header part + payload part) over a channel Cheng: mobile station ↔ base station radio system carrying UDP-Lite-formatted packets with header and payload, partial-coverage checksum. Dowling: layered packet network.
First selected portion protected by a first selected checksum; at least a second selected portion protected by a second checksum Dowling: multiple checksum algorithms registered simultaneously for the same packet, each with its own type and its own byte-position range ("beginning and ending byte positions" defining "the portion of the incoming packet to be checksummed") — i.e., two or more portions of one packet protected by two or more checksums of selectable types. Blightman corroborates: header partial checksum plus separate payload partial checksums (CSUM1/CSUM2/CSUM3) over separate data pieces.
Formatter that formats data into the packet, the packet carrying a first portion identifying the first protected portion + first-checksum indicia, and a second portion identifying the second protected portion + second-checksum indicia Cheng: UDP-Lite header carries the coverage length and checksum indicia that identify the protected region; the receiver reads those indicia to determine which parts are protected. Applying Dowling's two-checksum scheme to Cheng's UDP-Lite packet yields exactly the claim's two descriptor sets in the header. Blightman shows the mechanics of inserting computed checksum values into the transmitted packet (in-band), and Intel '329 provides the known segment-wise checksum arithmetic for any contiguous region.
Selector that selectably selects the portions and checksum types Dowling's registration interface — by which a layer "registers" an algorithm type and beginning/ending byte positions — is a selection of (portion, checksum type). Cheng selects protected/sensitive portions based on content and link conditions. Combining these, a control function (the "selector") choosing which portions and which checksum types to protect is the predictable union of Dowling's registration parameters and Cheng's content/condition-based selection.

Dependent claims:

  • Claims 6–8 (length field, checksum-type field, checksum-value field). Cheng's UDP-Lite header already carries a partial-coverage length and a checksum value. Dowling supplies the checksum-type dimension (each registered checksum has an algorithm type). Populating three sub-fields — length/type/value — per protected portion is the direct transcription of Dowling's registration parameters (type + beginning/ending byte positions, from which a length is derived) into Cheng's in-band header format. Nothing in either reference discourages expressing the byte-range as a length.
  • Claim 9 (flag/identifier indicating presence of a further protected portion). Once a packet carries a variable number (N ≥ 2) of descriptor sets, a single-bit "more to follow" flag is a conventional, indeed ubiquitous, list-termination device (analogous to the IP "more fragments" flag and chained option fields in the same protocol stack). This is at most an obvious implementation choice.
  • Claims 10–12 (second length/type/value fields). These merely repeat the structure of claims 6–8 for the second portion — the very structure Dowling already parallelizes per registered checksum and Cheng already provides in singular form.
  • Claims 2–5 and 18–20 (selection responsive to channel conditions, to indicia from the peer station, and to data content-type; logical-layer placement). Cheng expressly discloses: UDP-Lite data whose sensitivity classification is driven by content type (real-time audio/video/DC vs. AC coefficients are the illustrative examples in the '960 spec. itself), by header indicia, and by radio-link conditions (RLP retransmission/re-sequencing to manage frame error rate); and a layered architecture in which UDP-Lite sits above the radio/physical layer. Dowling discloses checksums registered per protocol-stack layer with per-layer algorithm selection. Making the selector's inputs come from lower-layer communication-condition feedback (claim 3's "indicia associated with communications of the second communication station") is the standard control-loop that Cheng's RLP already implements.
  • Claims 13–15 (receive side: extractor + calculator). Dowling's receive path is a direct anticipation-quality disclosure of this functionality: a fly-by checksum generation unit computes, for each registered algorithm and each defined byte range, a checksum for the received packet, and each protocol-stack layer "removes the fly-by checksum ... and uses [it] to verify the integrity of the data" for its portion. Ericsson '233 shows receiver-side verification by comparing a computed checksum against the received checksum. The '960's "checksum extractor" (reading the in-packet descriptor fields) and "checksum calculator" (performing per-portion calculations using the extracted type/checksum) add nothing beyond applying Dowling's receive-side verification to Cheng's in-band header descriptors.
  • Claim 16 (method) and claims 17–20 mirror the apparatus claims step-for-step (select → calculate per portion → format with in-packet descriptors), so the same combination and rationale apply.

Combination 2 (alternative): Dowling (US6289023B1) + Blightman (US20010036196A1) + Intel (US6732329B2), with UDP-Lite partial coverage as known background

If a challenger wished to avoid reliance on Cheng (a same-family Nokia reference), the essential claim 1 structure can be assembled from: Blightman (separate checksums over separate header/payload portions, inserted into the packet), Dowling (multiple selectable checksum types over selectable byte ranges for one packet), and Intel '329 (segment checksum arithmetic). UDP-Lite itself — acknowledged in the '960's own Background as known art — supplies the partial-coverage-length header concept. This combination is weaker only on the "extended UDP-Lite" gloss of dependent claims 4–5, which is not a limitation of claim 1 itself.


4. Motivation to combine — why a POSITA would do it

A person of ordinary skill in the art (a network-protocol or wireless-systems engineer familiar with UDP, UDP-Lite, RTP, and checksum/CRC design, circa March 2002) would combine these references for concrete, document-supported reasons:

  1. Known problem, stated in the art. The '960 specification itself concedes (Background) that UDP-Lite provides only a single protected/unprotected boundary and that corrupted data in the unprotected part can reach the application layer "more problematic than discarding the data." Cheng addresses the same UDP-Lite sensitivity-segregation problem in the same radio environment and is explicitly motivated to make lower layers respect the UDP-Lite protected/unprotected boundary. The improvement called for — additional checksum coverage of a formerly unprotected region — is a lesser-included extension of Cheng's own design, not a change of direction.

  2. Dowling supplies the missing mechanism. Dowling's entire premise is that one packet legitimately carries multiple integrity requirements at once, and it already solves the "multiple portions, multiple checksum types, selectable byte ranges" sub-problem at the hardware layer. The '960's classification (H04L2001/0098, "Unequal error protection") reflects the same recognized need — unequal/graduated error protection for real-time media — that motivated Dowling's per-layer checksums and Cheng's sensitive/nonsensitive split. Combining them yields the predictable result: Cheng's in-band UDP-Lite coverage descriptors, replicated per protected portion using Dowling's (type, range) parameters.

  3. Complementarity, not conflict. Cheng and Dowling operate at different layers (Cheng: UDP-Lite/RLP in a radio stack; Dowling: receive-path hardware checksum offload), so their teachings are additive. Neither teaches away: Dowling's checksums are not transmitted in-band, and Cheng has only one partial checksum — but the gap between them (put two Dowling-style coverage descriptors into a Cheng-style UDP-Lite header) is a straightforward formatting choice, the kind routinely made in protocol design and evidenced by Blightman's in-band checksum insertion and by UDP-Lite's own in-band coverage-length field.

  4. Known elements, predictable combination. Each element performs its known function: Cheng classifies and signals protected regions; Dowling selects per-portion checksum types and boundaries; Blightman/Intel/Ericsson supply checksum generation, insertion, and verification arithmetic. The combination is an application of each to its accustomed purpose — the classic fact pattern of KSR-type obviousness (design need + known prior elements + predictable result).


5. Counterarguments a patentee would raise, and their weight

  1. No single reference shows two in-band per-portion descriptor sets (length/type/value) in one packet header. Cheng has one coverage descriptor; Dowling's multiple checksums travel in an internal "checksum channel," not in the transmitted packet. The strongest patentee position is that the in-packet signaling structure of claims 6–12 (length field + checksum-type field + checksum-value field, chained by a flag) is not literally disclosed in any one reference. Assessment: this is the best non-obviousness argument, but it is a formatting/signaling choice, and the § 103 question is whether the structure would have been obvious — Blightman's in-band checksum insertion, UDP-Lite's in-band coverage length, and Dowling's (type, begin, end) registration tuple together leave little inventive room. The flag of claim 9 is especially weak as a patentable distinction.

  2. Cheng arguably teaches away from checksum-protecting the nonsensitive part, since Cheng's semi-transparent treatment deliberately avoids retransmission for nonsensitive data. Assessment: claim 1 does not require the second protected portion to be the "nonsensitive" part, nor does it require retransmission on error; and the '960's own stated problem (unprotected corruption reaching the application layer) supplies the contrary motivation. Any teaching-away argument is therefore limited and claim-scope dependent.

  3. Reference-status uncertainty. US20020059465A1 and US20040264434A1 were published after the '960 filing date; I have not verified their U.S. filing dates and therefore excluded them from the operative combinations. The primary combination (Cheng + Dowling, with Blightman/Intel/Ericsson as optional reinforcements) rests only on references with verified pre-2002-03-26 filing or publication dates, so this uncertainty does not weaken Combination 1. Cheng's § 102(e) status does depend on it having been filed (June 15, 2001) and published under § 122(b); its later 2003 publication date does not defeat § 102(e), but that legal conclusion assumes the usual AIPA § 102(e) treatment and should be confirmed against the file wrapper if this analysis is used in litigation.

  4. "Selector" as a limitation. To the extent the selector is characterized structurally, it is a control input to a formatter — in Dowling, the registration parameters; in Cheng, content/condition-based decisions. If a court treated the selector as a purely functional "means for selecting," it would be even more readily obvious. As drafted, the selector does not rescue the claims.


6. Bottom line

  • Claims 1, 16 (and their dependent claims 2–12, 18–20): A strong § 103 case exists over Cheng (US20030035441A1/US7154909B2) in view of Dowling (US6289023B1), optionally further in view of Blightman (US20010036196A1), Intel (US6732329B2), and Ericsson (US6820233B2). Cheng supplies the UDP-Lite/radio context, the in-band coverage descriptor, and content/condition-responsive selection; Dowling supplies the "multiple checksums of selectable types over selectable portions of one packet" concept and receive-side per-portion verification.
  • Claims 13–15 (receive side): The same combination is at its strongest here because Dowling's receive path (per-registered-algorithm fly-by checksums over per-registration byte ranges, verified per layer) is nearly a literal disclosure of the extractor/calculator functionality, with Cheng/Blightman contributing the in-band descriptor reading.
  • Most vulnerable claims for the patentee: 9 (flag), 10–12 (repeated descriptor fields), and 14–15 (receiver-side calculation), which largely track Dowling directly.
  • Best (but limited) patentee argument: the absence of any single reference teaching in-band, per-portion (length, type, value) descriptor sets chained in a UDP-Lite-style header — an argument that reduces to whether a routine protocol-formatting choice is "obvious," which on this record a POSITA would likely lose.

Nothing in the secondary-record (no evidence of long-felt need, copying, or commercial success was identified in the materials reviewed; the patent expired for nonpayment of maintenance fees in 2015) rebuts the prima facie case. Conclusion: claims 1–20 would likely be held obvious under 35 U.S.C. § 103 (pre-AIA) over Cheng + Dowling, optionally further in view of Blightman/Intel/Ericsson.

Generated 9/3/2026, 12:46:58 PM

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