US 7177285

I'll search for authoritative records on this patent and any CAFC 2026 docket activity.

The CAFC 2026 search returned nothing. Let me run more targeted searches on dockets and current owner/appeals.

Summary of U.S. Patent No. 7,177,285 (US7177285B2)

Confirmation note: Searches confirm this patent record (Google Patents, Justia, and federal court complaint exhibits, e.g., CommWorks Solutions LLC v. Adtran Inc., N.D. Ala. 5:23-cv-01327; CommWorks Solutions LLC v. [multiple defendants], C.D. Cal. 8:24-cv-02250, among others). I found no CAFC 2026 docket entries referencing patent 7177285 — the CAFC docket queries returned no results, so I cannot confirm any pending appeal at the Federal Circuit. District-court cases from 2025–2026 exist (Texas Western/Eastern, Virginia Eastern) per the patent record, but none of my searches surfaced a CAFC appeal. This should be treated as unverified rather than definitive.

Core bibliographic data

• Title: Time based wireless access provisioning
• Patent No.: US 7,177,285 B2
• Application No.: 10/961,959 (filed October 8, 2004)
• Priority date: January 13, 2003 (continuation of U.S. Application 10/341,847, issued as U.S. Patent 6,891,807 B2)
• Issue date: February 13, 2007
• Inventors: James A. Roskind (Redwood City, CA); John D. Robinson (South Riding, VA)
• Original assignee: America Online, Incorporated (Dulles, VA) — later AOL LLC, then transferred through Tarquin Consulting Co., LLC → Callahan Cellular L.L.C. → Intellectual Ventures Assets 130 LLC → CommWorks Solutions, LLC → Unwired Broadband, Inc. (Google Patents currently lists Unwired Broadband Inc. as assignee; the chain also includes a terminal disclaimer and a 188-day §154(b) adjustment noted on the face of the patent)
• Status: Expired – Lifetime (adjusted expiration around July 20, 2023; maintenance fees were paid through the 12th year)
• Claims: 62 total; 7 drawing sheets
• Classifications: Int. Cl. H04L 12/26, H04Q 7/34 (as printed on the patent face); USPTO classes 370/255, 370/338; modern CPC: H04W48/02, H04W12/08, H04W8/265, H04B17/10

Abstract (verbatim)

"A method and apparatus is provided for the time-based provisioning of wireless devices. A network access point monitors operation of wireless devices within a service region. When provisioning logic is activated at the network access point, the access point determines if the tracked parameter (such as power on or the onset of signal transmission) of the wireless device occurs within a designated time interval from the time of the provisioning activation. If the tracked device qualifies, the network access point proceeds with provisioning the device. In one system embodiment, the network access point tracks the power on time of wireless devices. When a wireless device to be authorized is powered on, the provisioning logic at the network access point notes the power on time. The user then activates the provisioning access at the network access point, and the network access point provisions the wireless device if it is recently powered on."

Plain-language overview of the independent claims

There are three independent claims (1, 22, and 43); claims 2–21, 23–42, and 44–62 are dependent. (Note: the granted claim language shown in the B2 record is narrower than the earlier published application US20050043021A1, which recited "power on, an activation, and a transmission of an output signal.")

• Claim 1 (method/process): A process for provisioning between a wireless device and a network. It requires (a) tracking an operating parameter of the wireless device within a service area — the tracked parameter being the onset of a signal transmission from the wireless device — and (b) initiating provisioning of the device if that tracked event occurs within a defined time interval. In essence: the access point watches for when a device "shows up" on the airwaves, and only provisions it if that appearance happens inside a qualifying time window.

• Claim 22 (system): A system for the same purpose, expressed in means-plus-function form: means for tracking the operating parameter (again, onset of signal transmission) within a service area, plus logic for initiating provisioning if the tracked parameter occurs within a time interval. This mirrors claim 1 as an apparatus/system counterpart.

• Claim 43 (access point): An access point comprising means for tracking an operating parameter of a wireless device — here broader than claim 1, covering either a power-on or an onset of signal transmission — and logic for initiating an association of the device with a network if the tracked parameter occurs within a time interval. Note the terminology shift from "provisioning" (claims 1/22) to "association" (claim 43).

Technology in context

The invention addresses a usability/security problem in early wireless home LANs: conventional provisioning required manual entry of a device identifier (e.g., a MAC address) into the access point, which was impractical for devices lacking a suitable user interface (e.g., wireless picture frames). The solution lets a user physically push a button or switch on the access point to open a short acceptance window (the specification gives a 5-minute example); any wireless device that powers on or begins transmitting within that window is automatically qualified and provisioned (e.g., added to the access control list and given encryption/setup key material), while devices that were already transmitting earlier — e.g., a neighbor's long-on device — are denied. The figures describe both timing orders: power-on-then-button-press (process 52a) and button-press-then-power-on (process 52b).

Sources

• Google Patents: https://patents.google.com/patent/US7177285/en
• Justia (application publication): https://patents.justia.com/patent/20050043021
• Complaint exhibits confirming bibliographic data, e.g., CommWorks Solutions LLC v. Adtran Inc., 5:23-cv-01327 (N.D. Ala.), and C.D. Cal. 8:24-cv-02250 complaint (both via court documents located through web search).

Uncertainty disclosures: (1) I did not locate any CAFC 2026 docket for this patent — absence of results is not proof none exists; (2) the assignment chain and current entity (Unwired Broadband, Inc. versus CommWorks Solutions, LLC) reflect Google Patents legal-event data and complaint allegations, which I did not independently verify against USPTO Assignment records; (3) the exact "current assignee" for enforcement purposes is a litigation fact I cannot confirm from these searches alone.

I'll search litigation databases and court records for cases involving US 7,177,285.

I have solid initial results. Let me pull more detail on specific cases and the NPE/Unified Patents databases.

Litigation Involving U.S. Patent No. 7,177,285 (US7177285B2)

Bottom line

US 7,177,285 has been asserted extensively — almost entirely by CommWorks Solutions, LLC (an Alpharetta, Georgia LLC; the NPE/assertion entity associated with IP Investments Group) — in a multi-district campaign spanning 2020 through 2026. The patent record itself lists ~37 district-court dockets, and my searches confirmed dozens of them. I found no Federal Circuit (CAFC) appeal naming 7177285. Consistent with the prior section, I could not surface a CAFC 2026 docket; treat "no appeal" as unverified rather than definitive.

⚠️ Important caveat on scope: 7177285 is part of the same family as US 6,891,807, US 7,463,596, and US 7,911,979 (all share the Jan. 13, 2003 priority date). CommWorks pleads these as a bundle. In the cases I could inspect, the complaints attach "Exhibit A — Evidence of Use Regarding U.S. Patent No. 7,177,285," which directly confirms '285 was asserted. Where I could not verify the exhibit list, I mark the entry as family-level / unverified.

⚠️ Contradiction to flag vs. prior section: The prior bibliographic section names Unwired Broadband, Inc. as current assignee. My searches show CommWorks Solutions, LLC as the plaintiff/asserter of 7177285 in every recent case — consistent with the assignment chain (Intellectual Ventures Assets 130 → CommWorks), with Unwired Solutions/Broadband appearing as a licensee rather than the litigant. This is not necessarily a conflict, but the enforcement posture is CommWorks, not Unwired Broadband.

Confirmed cases asserting US 7,177,285 (Exhibit A verified)

Additional dockets listed on the 7177285 record (defendant/status not independently verified)

These appear in the patent's litigation section (Google Patents, sourced from Unified Patents' litigation dataset). Because the family is pleaded together, I list them but cannot confirm '285 was individually asserted in each:

2026 filings (7:26-cv-00043 in W.D. Tex. and 2:26-cv-00088 in E.D. Tex.) are the most recent docket entries on the record; I could not retrieve their defendants or current status within this search.

Notable outcome patterns

• CommWorks is the sole recurring plaintiff; defendants are Wi-Fi/network equipment and semiconductor makers (routers, gateways, Wi-Fi SoCs) and broadband/ISP operators.
• Recurring counsel: Rozier Hardt McDonough PLLC (James F. McDonough III, Jonathan L. Hardt, Carey M. Rozier, Kenneth A. Matuszewski); earlier W.D. Tex. cases used The Stafford Davis Firm / Kheyfits Belenky LLP.
• Most cases terminate early and procedurally — voluntary dismissals (with or without prejudice) or stipulated dismissals, typically before claim construction. No reported merits judgment, Markman ruling, or invalidity holding on 7177285 surfaced in my searches.
• Unified Patents has separately challenged related CommWorks patents via ex parte reexamination (e.g., US 7,760,664), but I did not confirm any reexamination/IPR directed specifically at 7177285.

Confidence and gaps

• High confidence: the confirmed table (verified via CourtListener/PACER, Justia dockets, UniCourt, RPX/Stanford NPE DB, and complaint exhibits bearing "Exhibit A … 7,177,285").
• Lower confidence: the "additional dockets" table — I inferred '285 involvement from family-level pleadings and Google Patents' aggregation; the exact accused-patent list per case should be verified against each PACER docket.
• Not found: (1) any CAFC appeal naming 7177285; (2) any final merits/adverse judgment; (3) defendant identities for the four 2026/newest filings and several 2020–2025 dockets.

Suggested next steps to close gaps: pull PACER dockets for the "additional dockets" table to confirm per-case patent lists, and run a CAFC docket query by party name ("CommWorks Solutions") rather than by patent number, since appeals are docketed by party and not by patent.

Primary sources: Google Patents — https://patents.google.com/patent/US7177285/en; Stanford NPE Litigation Database — https://npe.law.stanford.edu/patent/7177285; Unified Patents Portal — https://portal.unifiedpatents.com/litigation/caselist; CourtListener — https://www.courtlistener.com/docket/71193236/commworks-solutions-llc-v-stmicroelectronics-inc/; Justia Dockets — https://dockets.justia.com/docket/texas/txedce/2:2025cv00433/[237505](/patent/237505); RPX Insight — https://insight.rpxcorp.com/litigation/txedce-[197834](/patent/197834)-commworks-solutions-v-cable-one.

I'll verify the structured block's "no proceedings" result with targeted searches before writing.

Let me run additional targeted searches to be thorough about PTAB coverage and any sibling-patent challenges.

Proceedings overview

Zero AIA trial proceedings. The USPTO Open Data Portal ("PTAB proceedings on file") returns no IPR, PGR, or CBM for U.S. Patent No. 7,177,285, and five independent web searches (Google Patents / Unified Patents litigation data / Docket Alarm / PTAB-trial and petition searches keyed to the patent number, the inventors (Roskind, Robinson), the "time based wireless access provisioning" title, and the current owner CommWorks Solutions) surfaced no petition, institution decision, FWD, or appeal referencing this patent — so the defensive posture is not "hardened by IPR" and not "claims killed at the Board"; it is completely untested at the PTAB, leaving all 62 claims intact and every § 102/§ 103/§ 112 ground presumptively available to a defendant.

Because the canonical structured list is empty, there are no per-proceeding entries to render. What follows is the analysis that would attach to each entry, applied to the "no proceedings" reality.

Proceedings overview (detail)

Structured-source result (canonical): no AIA trial proceedings on file. USPTO ODP ingest, checked as of this analysis.

Corroboration from the patent record itself: the Google Patents page for US7177285B2 enumerates an extensive litigation section (Texas Eastern/Western, Virginia Eastern, Alabama Northern, California Central, Delaware, New York Southern — cases running from 2020 through 2026) but contains no PTAB trial section and no "IPR" entries in its legal-events timeline. A patent this heavily litigated would normally show Board activity in that timeline if it existed.

Absence-of-evidence caveats (stated plainly, not hedged into the findings):

• My verification searches hit a tool step-limit on the final three queries, so this is a five-search sample, not an exhaustive PTAB E2E docket scrape. Treat "zero" as very likely zero, and re-verify at PTAB E2E and the Unified Patents portal before you commit to a litigation position.
• A recently filed petition (e.g., served within the last few weeks) can sit in a pre-institution, non-public window. That would not explain the absence of any older proceeding given a six-year, ~50-defendant campaign, but it is the one scenario worth a second look.

Why there is almost certainly no PTAB activity (structural, not accidental)

1. Statutory vehicle unavailability. PGR requires an effective filing date on or after 2016-03-16 — this patent's priority date is 2003-01-13, so PGR was never available. CBM required a "financial product or service" (this is consumer WLAN provisioning, not a covered business method) and sunset for new petitions on 2020-09-16. That leaves IPR as the only AIA route, and IPR is limited to § 102/§ 103 on patents and printed publications.
2. Expiration removes the classic IPR incentive. The patent record shows expired – lifetime, adjusted expiration 2023-07-20. From that date the claims cannot be asserted for post-expiration conduct, which typically collapses a defendant's ROI on a $400k+ IPR. A suit filed in 2025 or 2026 can only reach pre-expiration damages within the § 286 six-year lookback.
3. The campaign's own conduct. CommWorks sued on 2020-07-29/30 (S.D.N.Y.), then again in 2020–2026 in TX E.D./W.D., VA E.D., N.D. Ala., C.D. Cal., and D. Del.; several defendants exited early (e.g., CommWorks v. AVM, 2:25-cv-00026, dismissed without prejudice 2025-06-19; Altice/CSC v. CommWorks, D. Del. 1:21-cv-01323, voluntary dismissal entered 2022-06-21). A pattern of quick dismissals and licenses reduces the appetite for a Board trial.
4. Sibling patents share the fate. The asserted family — 6,891,807 ('807, the parent), 7,177,285, 7,463,596, 7,911,979, 7,027,465, 7,760,664, 8,116,315, RE44,904 (see the S.D.N.Y. complaints, CommWorks Solutions, LLC v. RCN Telecom Services, LLC, 1:20-cv-07534, and …v. Mediacom) — likewise produced no PTAB trials in my searches. That is the single most important pattern signal below.

Strategic summary

Claim status: all 62 claims are UNTESTED at the PTAB. Nothing has been canceled, nothing has been confirmed, and there is no FWD to quote. Under the grant as printed, independent claims 1, 22, and 43 and all dependents remain live for pre-expiration damages, with claim 1 requiring tracking the onset of a signal transmission (narrower than the published application US20050043021A1) and claim 43 using "association" rather than "provisioning" and covering power-on or onset of transmission. Since the expiration date is 2023-07-20, the practical battleground is historical damages, not injunctions — which changes the math on whether an IPR is worth filing at all.

Estoppel landscape: none exists. With no IPR/PGR, § 315(e)(2) estoppel has not attached to anyone, so a defendant currently being asserted against is free to run any § 102/§ 103/§ 112/§ 101 theory in district court, including art a petitioner could have raised but didn't. Two timing traps to check immediately: (a) § 315(b) — if your client was served with a complaint alleging infringement of '285 more than one year ago, an IPR is now time-barred, so invalidity must be litigated in court; (b) the related-family suits may have created service dates that start that clock. Conversely, because no IPR exists, there is also no petitioner-side art record to mine and no Board claim construction (no Phillips-vs-BRI record) to leverage.

Pattern signals. Single-owner, high-volume campaign (CommWorks Solutions, LLC, with Brainbox Innovations, LLC identified as corporate parent per Rule 7.1 disclosures, e.g., N.D. Ala. 5:23-cv-01327 and E.D. Tex. 2:26-cv-00794); no defensive aggregator appears in the challenge chain — Unified Patents appears in the record only as a litigation-data source, not as a petitioner, and I found no Unified Patents IPR on '285 or its siblings. The asserted theory is consistent across complaints: Wi-Fi Protected Setup (WPS) button-press provisioning read onto the time-based claims, plus Wi-Fi Multimedia (WMM) against the '465/'904 patents (see e.g. the AVM, DrayTek, VTech, STMicroelectronics, and Grandstream complaints, all attaching a claim chart for U.S. 7,177,285). The most consequential fact for you is that this portfolio has been asserted against dozens of networking defendants for ~six years without a single Board challenge reaching institution — either defendants are settling on economic terms, or the family is seen (rightly or wrongly) as a strong-enough-set that coordinated invalidity was never organized.

Recommended next steps

If you are a defendant facing a demand or complaint citing '285:

1. Do not assume the claims are dead — they are not. There is no FWD, no cancellation, no estoppel. Any "the patent was invalidated" position is factually wrong on this record. Confirm the empty state yourself at PTAB E2E (search by patent number and by application 10/961,959) and at Docket Alarm's PTAB index.
2. Check § 315(b) immediately. If service predates 2025-09-13 on a complaint asserting '285, your IPR window is closed. If you were served recently, the window is open, but weigh it against expiration on 2023-07-20 (pre-suit damages only under § 286).
3. Build validity in court, not at the Board, unless economics favor IPR. With no estoppel, your strongest posture is an invalidity case on the WPS/802.11 and Bluetooth prior art already cited on the face of the patent (e.g., US 6,058,106 (Cudak), US 6,275,693 (Lin), WO 01/22661, EP 1081895, and the Bluetooth literature), plus the WPS-standardization art that post-dates or coincides with the 2003 priority date — a § 102/§ 103 attack on claim 1's "onset of a signal transmission within a time interval" is where the claim is most vulnerable.
4. Attack the family, not just this patent. The same complaint charts effectively read WPS onto '807, '285, '596, and '979. A coordinated defense across the family — and a shared invalidity/claim-construction narrative (e.g., "onset of a signal transmission" vs. a mere periodic beacon, and "time interval" activation) — is more efficient than treating each patent serially.
5. Indemnitor/SoC angle. Several charts target router SoC vendors and device makers, so check your supply-chain indemnities and consider coordinating with co-defendants on joint prior-art acquisition.

If you are evaluating the portfolio for licensing: the absence of PTAB activity is itself the signal you should price. The claims are intact and the family has survived six years of district-court assertion without a Board trial being instituted; but the core patent expired on 2023-07-20, so value now lies in historical damages exposure and in the unexpired siblings — verify the expiration dates of '596, '979, and '465 before modeling.

Uncertainty disclosures. (1) The "zero proceedings" finding rests on the structured USPTO ODP block plus a five-search sample; the last three verification queries were cut off by a tool step-limit, so a very recent, pre-institution petition cannot be excluded. (2) I did not locate any Federal Circuit docket tied to this patent, consistent with the earlier section of this analysis. (3) I have not fabricated any proceeding number, panel, FWD, or appeal — none exists in the sources I could reach, and I am not inferring one from the litigation record.

I'll ground this in the recorded assignment reel/frame data and try to surface correspondent-of-record details.

Assignment & Ownership Reconstruction — US 7,177,285 B2

Data-source caveat (read first): I could not open assignmentcenter.uspto.gov or assignment.uspto.gov directly in this session — every query targeting the recorded correspondent of record returned zero results. The reel/frame data below is taken from the Google Patents legal-events table for US7177285B2, which mirrors the USPTO assignment index (same reel/frame numbers). The correspondent attorney/firm for each recording is therefore "not retrieved," not "none" — and I will not guess. Anything I could not verify is flagged as such rather than filled in.

Inventors

Both are named on the face of the patent and both appear as assignors on the recorded inventor→company assignment (Reel 023390/0819), signed 2003-01-09 to 2003-01-14 — i.e., contemporaneous with the 2003-01-13 priority filing of parent application 10/341,847.

Unusual pattern — late recording of the foundational assignment. The inventor→AOL assignment was executed in January 2003 but not recorded until 2009-10-20, roughly 6 years 9 months later — and, critically, five days after AOL had already assigned the patent to Tarquin Consulting Co., LLC (recorded 2009-10-15, Reel 023379/0103). This is the classic signature of a title-cleanup scramble performed to close a portfolio sale: diligence on the Tarquin transaction exposed that the root chain-of-title instrument had never been recorded, and it was filed immediately behind the sale instrument to cure the defect. It is not evidence of inventor flight, but it is evidence the 2009 transaction was a bulk divestiture handled with transactional haste.

No evidence surfaced that either inventor departed AOL within 12 months of filing; I found no support for that pattern and do not assert it.

Original assignee

America Online, Incorporated (Dulles, Virginia), later AOL LLC (a Delaware LLC).

• Primary line of business: consumer online services / ISP (dial-up and then broadband access, client software, content). An operating company, not a patent-holding vehicle.
• Did it ship a product embodying the claims? Unclear, and probably not directly. The '285 claims are directed to an access point that provisions wireless devices (claims 1, 22, 43). AOL was an ISP and portal operator, not a Wi-Fi access-point OEM. The specification's motivation is a home WLAN access point. I found no evidence AOL commercialized an access point practicing the tracked-parameter timing window.
• Current status: The original corporate assignor no longer exists in its 2003 form. AOL converted to AOL LLC effective 2006-04-03 (the 2007 and 2009 recordings at Reels 019711/0316, 022451/0186, and 022835/0613 are all change-of-name / conversion corrections of that same event, not transfers). The AOL brand subsequently passed through Verizon and is now part of Yahoo Inc. Caution: the precise current corporate status of the AOL LLC entity is something I could not verify from primary sources in this session.

Contradiction flagged with the prior section: the earlier summary stated the patent face includes "a terminal disclaimer and a 188-day §154(b) adjustment." I found no support in the patent record for a terminal disclaimer on '285, and I could not verify the 188-day PTA figure. Treat both as unverified.

Assignment timeline

Eleven recorded assignment-family events. All reel/frame values are from the Google Patents legal-events mirror of the USPTO index.

• 2003-01-09 → 2003-01-14 (executed) / recorded 2009-10-20 — Reel 023390/0819

  • Conveyance: Assignment (inventor → company)
  • Assignor: Roskind, James A.; Robinson, John D.
  • Assignee: America Online, Inc.
  • Correspondent: not retrieved (Assignment Center correspondent field not accessible in this session)
  • Context: Original employment/founder assignment; recorded six-plus years late, immediately after the AOL→Tarquin sale, as a chain-of-title cure.

• 2006-04-03 (effective) / recorded 2007-08-17 — Reel 019711/0316

  • Conveyance: recorded as Assignment of assignors' interest, later corrected to Change of Name
  • Assignor: America Online, Inc.
  • Assignee: AOL LLC, a Delaware limited liability company
  • Correspondent: not retrieved
  • Context: Internal reorganization — entity conversion, no change in beneficial ownership.

• 2006-04-03 (effective) / recorded 2009-03-25 — Reel 022451/0186

  • Conveyance: Corrective Assignment (nature of conveyance = Change of Name)
  • Assignor: America Online, Inc. → Assignee: AOL LLC
  • Correspondent: not retrieved
  • Context: Title-desk correction of the 2007 recording; still internal only.

• 2006-04-03 (effective) / recorded 2009-06-17 — Reel 022835/0613

  • Conveyance: Correction to the corrective assignment (actual nature = conversion to a limited liability company)
  • Assignor: America Online, Inc. → Assignee: AOL LLC
  • Correspondent: not retrieved
  • Context: Second-order cleanup. Three recordings to document one conversion is itself a diligence artifact.

• 2009-09-17 (executed) / recorded 2009-10-15 — Reel 023379/0103

  • Conveyance: Assignment
  • Assignor: AOL LLC
  • Assignee: Tarquin Consulting Co., LLC (Delaware)
  • Correspondent: not retrieved
  • Context: Fire-sale / bulk portfolio divestiture — the first transfer out of the operating company into a non-practicing holding vehicle.

• 2015-08-27 (effective) / recorded 2015-12-29 — Reel 037396/0647

  • Conveyance: Merger
  • Assignor: Tarquin Consulting Co., LLC
  • Assignee: Callahan Cellular L.L.C. (Delaware)
  • Correspondent: not retrieved
  • Context: Structural absorption of the holding vehicle into a successor holding vehicle; no arm's-length third-party buyer evident from the record.

• 2019-10-30 (executed) / recorded 2019-10-31 — Reel 050900/0904

  • Conveyance: Assignment
  • Assignor: Callahan Cellular L.L.C.
  • Assignee: Intellectual Ventures Assets 130 LLC (Delaware)
  • Correspondent: not retrieved
  • Context: Transfer into an Intellectual Ventures asset-holding entity — a listed high-volume NPE.

• 2019-11-15 (executed) / recorded 2020-01-03 — Reel 051463/0026

  • Conveyance: Assignment
  • Assignor: Intellectual Ventures Assets 130 LLC
  • Assignee: CommWorks Solutions, LLC (Georgia)
  • Correspondent: not retrieved
  • Context: Transfer-to-asserter, part of the November–December 2019 divestiture of 3,800+ patents from IV to Georgia monetization firm IPInvestments Group LLC (RPX, 10 June 2020).

• 2020-09-18 (executed) / recorded 2020-11-05 — Reel 054443/0958

  • Conveyance: License
  • Assignor: CommWorks Solutions, LLC
  • Assignee: Unwired Solutions, Inc. (California)
  • Correspondent: not retrieved
  • Context: Monetization-side license grant — not a transfer of enforcement title.

• 2020-09-18 (effective) / recorded 2021-02-04 — Reel 056981/0631

  • Conveyance: Corrective Assignment (correct assignee name)
  • Assignor: CommWorks Solutions, LLC
  • Assignee: Unwired Broadband, Inc. (California)
  • Correspondent: not retrieved
  • Context: Name correction only ("Unwired Solutions" → "Unwired Broadband"). Do not conflate with Unwired Planet (the UK SEP litigant) — different entity, different chain.

• 2020-09-18 (effective) / recorded 2022-02-16 — Reel 059907/0563

  • Conveyance: Corrective Assignment — nature of conveyance corrected to "Assignment" (previously recorded as a License)
  • Assignor: CommWorks Solutions, LLC
  • Assignee: Unwired Broadband, Inc.
  • Correspondent: not retrieved
  • Context: Re-characterization of the 2020 instrument from a license into an assignment. Functionally this either perfects a true transfer that was mis-described on first recording, or creates a clean standing record for a monetization counterparty. Either way, a title change was engineered after the assertion campaign began.

Non-assignment recorded events (for completeness, not part of the chain): FPAY 2010-07-02 (4th year), FPAY 2014-07-25 (8th year), MAFP 2018-07-16 (12th year). Maintenance fees paid through the 12th year; the patent expired on the §154(b)-adjusted term (~2023-07-20 per Google Patents).

Timeline diagram

timeline
    title Ownership of US 7177285
    2003 : Inventors assign to America Online
         : Priority application filed Jan 13
    2006 : AOL converts to AOL LLC
    2009 : AOL sells portfolio to Tarquin Consulting
         : Inventor assignment finally recorded
    2015 : Tarquin merges into Callahan Cellular
    2019 : Callahan sells to IV Assets 130
         : IV Assets 130 sells to CommWorks
    2020 : CommWorks licenses to Unwired Broadband
         : First CommWorks suits filed
    2021 : Corrective recording on Unwired deal
    2022 : Conveyance corrected to assignment
    2025 : CommWorks sues Qualcomm and STMicro

NPE / troll-pattern signals

1. Shell-entity transfer — PRESENT. The patent leaves the operating company at Reel 023379/0103 (AOL LLC → Tarquin Consulting Co., LLC, Delaware, executed 2009-09-17) and then passes through Reel 037396/0647 (Merger into Callahan Cellular L.L.C., 2015) and Reel 050900/0904 (→ Intellectual Ventures Assets 130 LLC, 2019). The signal is not the naming alone — it is that three consecutive holders are Delaware non-operating vehicle types ("Consulting," "Cellular," "Assets … LLC") interposed between AOL and the entity that actually litigates. Evidence I do not have: registered-agent addresses or single-member status for Tarquin/Callahan/IV Assets 130; I did not retrieve them and do not assert them.

2. Known asserter in the chain — PRESENT (strong). Two matches:

• Intellectual Ventures Assets 130 LLC (Reel 050900/0904) — IV is on the named-NPE list, and RPX documents the IV→IPInvestments transfer of 3,800+ assets in Nov–Dec 2019.
• CommWorks Solutions, LLC (Reel 051463/0026) — expressly identified by Unified Patents as "an NPE and subsidiary of IP Investments Group LLC," and by Lexology as "an affiliate of Georgia-based NPE IPInvestments Group." CommWorks' portfolio is under a standing Unified Patents ex parte reexamination campaign (e.g., '249 at 90014909; PTAB FWD invalidating claims of 8,923,846 on 2023-02-13). Stanford's NPE litigation database likewise tags CommWorks as "Non Practicing Entity."

3. Repeat correspondent across the chain — UNVERIFIABLE / UNCLEAR. This is the signal the task specifically asks for, and I could not retrieve a single correspondent name. My targeted queries against the Assignment Center mirror returned no correspondent records. I will not name a hypothetical attorney. For what it is worth, the litigation firm of record is a repeat player — Rozier Hardt McDonough PLLC (James F. McDonough, Jonathan L. Hardt) appeared for CommWorks in CommWorks v. STMicroelectronics, W.D. Tex. 7:25-cv-00363 — but litigation counsel is a different role from assignment correspondent and does not satisfy this signal. Marked unclear on the evidence available.

4. Cascading transfers — PRESENT (strong). Reel 050900/0904 (executed 2019-10-30) and Reel 051463/0026 (executed 2019-11-15) move the patent Callahan → IV Assets 130 → CommWorks in 16 days. Two chained LLC hops in a little over two weeks, inside a single bulk IV divestiture, with no operating business on either side. That is the canonical layering pattern used to break visible continuity between originator and asserter.

5. Pre-litigation transfer — PRESENT. The operative transfer to CommWorks was executed 2019-11-15 (recorded 2020-01-03). CommWorks' first litigation wave — including the E.D. Tex. cases 2:20-cv-00158/00159/00160 that appear in the '285 family's related-litigation record — was filed in 2020, roughly six months later; RPX's June 2020 report describes the LLCs as having "filed suit." Note the family is asserted as a group: the 2025 STMicroelectronics case asserts US7177285B2 together with US7463596B2 and US7911979B2 — i.e., the entire continuation family plus US7027465B2 and USRE044904E. Caveat: I could not confirm the exact filing date of the first suit naming '285 specifically; the six-month call rests on the 2020 campaign timing.

6. Bankruptcy fire-sale — NOT PRESENT. No AOL Chapter 7/11 record surfaced. The 2009 exit was a negotiated portfolio divestiture, not a bankruptcy sale.

7. Privateering — UNCLEAR. AOL transferred to Tarquin in 2009 and the patent was asserted against networking/Wi-Fi vendors (Charter, D-Link, Comcast, RCN, Technicolor, Extreme, Qualcomm, STMicroelectronics) beginning roughly a decade later, long after AOL's involvement ended. There is no evidence in the record that the late-2019/2020 assertion campaign was run on AOL's behalf against AOL competitors, which is what privateering requires. Divestiture, not privateering, is the better characterization.

8. Defensive aggregator — NOT PRESENT. No RPX, AST, LOT Network, Unified Patents, or OIN entity appears anywhere in the chain. The inverse conclusion applies: this patent was not neutralized by defensive aggregation — it was the target of defensive challenges instead (Unified's CommWorks campaign).

Verdict

NPE — high confidence.

The chain exits an operating company into non-practicing vehicles at Reel 023379/0103 (AOL LLC → Tarquin Consulting Co., LLC, exec. 2009-09-17), is merged into Callahan Cellular L.L.C. at Reel 037396/0647, passes to Intellectual Ventures Assets 130 LLC at Reel 050900/0904 (exec. 2019-10-30), and reaches CommWorks Solutions, LLC — identified by Unified Patents and Lexology as an NPE affiliate of IPInvestments Group — at Reel 051463/0026 (exec. 2019-11-15, just 16 days after the preceding hop), with the first assertion campaign following about six months later in 2020. Two independent strong signals (known asserter + cascading pre-litigation transfers) are corroborated by a third (shell-entity exit from the operating company), and the 2020–2022 corrective recordings on the Unwired Broadband instrument show ongoing title engineering after assertion began.

Contradiction flagged with the prior section: the earlier summary listed Unwired Broadband, Inc. as current assignee per Google Patents. That reflects Reels 054443/0958, 056981/0631, and 059907/0563 — but the litigation record is unambiguous that CommWorks Solutions, LLC is the plaintiff asserting US7177285B2 as recently as 2025 (CommWorks v. STMicroelectronics, W.D. Tex. 7:25-cv-00363, which was voluntarily dismissed with prejudice 2025-10-31; CommWorks v. Qualcomm, E.D. Tex. 2:25-cv-00154, filed 2025-02-06). The Unwired instrument was originally recorded as a license, then corrected twice, ultimately re-characterized as an assignment — so the enforcement-title question (CommWorks vs. Unwired Broadband) is genuinely ambiguous on the face of the recording sequence and deserves a direct Assignment Center pull.

Verification: search patent number 7177285 at https://assignmentcenter.uspto.gov/ (or the legacy index at https://assignment.uspto.gov/patent/index.html) and confirm Reels 023379/0103, 037396/0647, 050900/0904, 051463/0026, 054443/0958, 056981/0631, and 059907/0563 — and, in particular, capture the correspondent of record on each, which is the one field I could not retrieve and the most probative remaining evidence for the repeat-correspondent signal.

I'll verify the key prior-art references via search, then analyze them against the claims.

Let me verify a few more key references cited on the face of the patent.

Prior-art analysis — U.S. Patent No. 7,177,285 (US7177285B2)

Step 1 — Confirming the number (exact match, not a neighbor)

The USPTO record sought is exactly US 7,177,285 B2, "Time based wireless access provisioning," application 10/961,959, filed 2004-10-08, priority 2003-01-13, granted 2007-02-13, inventors Roskind & Robinson, original assignee America Online. This is the record matching the number you specified; I have not substituted any similar number (e.g., 7,177,284 / 7,177,286 or the sibling family members 6,891,807 / 7,463,596 / 7,911,979).

Per the operating rules, I treat the fetched patent text and its printed front page as authoritative for the citation list, and I verified the highest-value references by live search where the tool allowed.

Step 2 — How I am reading "each patent citation"

The front page of US7177285B2 lists 22 patent documents and 17 non-patent items. These are the references cited during prosecution (a mix of examiner-cited and applicant-submitted), which is what "date of citation" means here. Important structural point up front:

US 6,891,807 B2 is the parent of '285 (same family, same priority, same inventors). It is therefore NOT prior art under § 102 — it is listed only because it is the parent application. I exclude it from any § 102 attack.

Step 3 — The 22 cited patent references, with § 102 relevance

Dates are as printed on the '285 front page (priority date / publication-or-grant date). "§ 102 read" states whether the reference plausibly anticipates the independent claims (1, 22, 43) standing alone, or is really § 103/element material.

Step 4 — Detailed § 102 read on the closest four

Independent claim 1 requires exactly two things: (a) tracking an operating parameter of the wireless device within a service area, the parameter being the onset of a signal transmission; and (b) initiating provisioning if that tracked event occurs within a time interval. Claim 22 mirrors this in means-plus-function form; claim 43 broadens the parameter to power-on or onset of transmission and calls the outcome an "association."

• US 6,317,594 (Openwave/Helferich) — discloses element (a) almost verbatim ("detection of activity of the device on a wireless network," including registration/origination triggers). It fails (b): the network's response is to push data to the device, not to provision access, and there is no user-opened acceptance window. Anticipates nothing; supports § 103.
• WO 01/22661 (Thomson) — discloses the provisioning outcome (registration + authentication-key download to a new device in a home WLAN). It fails both (a)'s trigger (it is PIN-entry driven, not signal-onset driven) and (b)'s time interval. Anticipates nothing; supports § 103 for the key-material/identifier dependent claims.
• US 6,282,183 (Motorola/Harris) — discloses unsolicited-signal detection + an authorization/bond + a timer. Because its timer is not a provisioning acceptance window, it fails (b). Anticipates nothing; best § 103 reference against claim 43's "association."
• US 5,461,627 (Rypinski) — registration "upon activation" (signal onset) but no time interval. Anticipates nothing; § 103 element.

Step 5 — Non-patent literature cited (for completeness)

The '285 front page also cites 17 NPL items. Thematically relevant ones: Candolin, Security Issues for Wearable Computing and Bluetooth Technology, 23 Oct. 2000 (Bluetooth security too weak for more than personal use); Aziz & Diffie, Privacy and Authentication for Wireless Local Area Networks, Jul. 26, 1993; and IEEE papers on wireless home networks (Fujieda 2000; Gummalla & Limb 1999; Shepard 2001; Saito 2001; Lilakiatsakun & Seneviratne 2001). None of these, on its face, discloses a user-activated time-window qualification of a device's transmission onset; they are § 103 context.

Step 6 — Bottom line on § 102

None of the 22 cited references, taken alone, appears to anticipate independent claims 1, 22, or 43. The references collectively supply every element — activity/signal detection (US 6,317,594; US 6,282,183; US 5,461,627), access-point authentication (EP 1 081 895; US 2001/0048744), device registration with key material (WO 01/22661), and AP-based provisioning generally (US 6,058,106; US 6,275,693) — but not the combination of (i) tracking the onset of transmission/power-on and (ii) gating provisioning on that event falling inside a user-opened acceptance interval. That gap is the novelty core of '285.

Two points worth flagging explicitly:

1. The true "time-window" reference is NOT prior art to '285. EP 1 615 381 A1 (Thomson Multimedia Broadband Belgium, Device and process for wireless local area network association, priority 2004-07-06) describes precisely the "push one button → opens a time window during which a station may be associated" concept (the commercialized Speed Touch 570 behavior). Its 2004 priority post-dates '285's 2003-01-13 priority, so it is citing/follow-on art (it appears in the "Families Citing this Family" table), not § 102 art. If you were expecting a § 102 "button-opens-a-window" knockout reference on the front page, there isn't one — and the on-point document is on the wrong side of the priority date.

2. § 102 vs. § 103 framing. Given the "within a time interval" limitation, the realistic validity attack on '285 is § 103, combining an activity/onset-detection reference (US 6,317,594 or US 6,282,183) with a registration/key-provisioning reference (WO 01/22661) and, optionally, the Rypinski activation-registration teaching. A pure single-reference § 102 anticipation is not supported by the cited art as printed.

Caveats / verification notes

• I verified the bibliographic and content details of US 5,461,627, US 6,317,594, WO 01/22661, EP 1 615 381, and US 6,282,183 by live search (Google Patents, FreePatentsOnline, EPO publication server, Unified Patents portal). The remaining entries' dates/titles are taken from the authoritative '285 front-page citation list in the fetched patent text.
• My final three verification searches were cut off by a tool step-limit, so the descriptions of EP 1 081 895, US 2001/0048744, and US 6,058,106 rest on the patent's own citation data plus my prior knowledge, not a fresh source check — flagged as such rather than presented as freshly verified.
• The § 102 subsection designations (pre-AIA § 102(a)/(b)/(e)) are stated only where the date math is unambiguous; I have avoided asserting a precise subsection for every item where the continuation filing date (2004-10-08) vs. priority date (2003-01-13) could shift the one-year window.
• I did not fabricate any reference; every citation above is one actually printed on US7177285B2 or returned by search.

Primary sources: https://patents.google.com/patent/US7177285/en (authoritative patent text); https://patents.google.com/patent/US6317594 ; https://patents.google.com/patent/[US5461627A](/patent/US5461627A) ; https://patents.google.com/patent/WO2001022661A2 ; https://patents.google.com/patent/EP1615381 ; https://patents.google.com/patent/[US6282183B1](/patent/US6282183B1) .

I'll ground the obviousness analysis in the actual cited-art corpus. Let me pull details on the key references from the patent's Prior Art section.

The search results are highly informative — one cited reference (Kimura) appears to disclose the core time-window mechanism. Let me verify two more cited references before writing the analysis.

Obviousness Analysis — U.S. Patent No. 7,177,285 under 35 U.S.C. § 103

Scope note: This analysis uses the prior-art corpus identified in the "Prior Art" section of the US7177285B2 record — i.e., the references cited on the face of the patent (22 patent documents) and the background-of-invention citations and NPL list (17 non-patent references). Where I rely on the content of a reference, I say so with a pin cite; where I could not verify a reference's content, I say so rather than assume it. This builds on, and does not repeat, the bibliographic, litigation, and PTAB sections already generated.

1. Framework

Priority date / critical date: January 13, 2003 (continuation of US 10/341,847, filed the same day; '285 itself filed Oct. 8, 2004). Every reference in the cited corpus except four NPL items predates the critical date and is available as § 102(a)/(b)/(e) art.

Not prior art (flag): The following cited NPL post-dates 2003-01-13 and therefore cannot be prior art on this record: Microsoft Announces Wireless Provisioning Services (GeekZone, Dec. 10, 2003); Wireless Provisioning Services Overview (The Cable Guy, Dec. 2003); HP Spotlights Mobile Gear (CNET, Oct. 13, 2003); Sony Ericsson HBH-65 Manual (Aug. 2003). Do not build a ground on these. (One caveat: each could theoretically evidence earlier public use, but no such foundation appears in the record.)

Level of ordinary skill (POSITA): a B.S. in electrical engineering or computer science plus 2–3 years of experience in wireless LAN/WPAN networking (IEEE 802.11 or Bluetooth), or equivalent. This is a low-to-moderate skill level for a claim set that recites architecture and control logic but no algorithm, no key-exchange protocol, and no numeric interval.

Governing law posture: KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) — predictable variation, known design incentives, and "obvious to try" with a finite number of identified solutions. Any obviousness case here should be framed under KSR, because the patent's asserted contribution is a choice of which event anchors a timing window, and the specification itself treats both orderings as interchangeable (FIG. 5 / process 52a: power-on then button; FIG. 6 / process 52b: button then power-on). A patentee's own treatment of two alternatives as equivalents is powerful evidence that choosing between them is within ordinary skill.

Key admitted art (from the patent's own background): the specification concedes that wireless home LAN devices are provisioned through an access point using "device identification information, such as a MAC address," and that MAC entry is problematic for devices lacking user interfaces. That is a binding admission of the known problem — and it supplies the "motivation" half of the obviousness case for free.

2. Claim construction of the dispositive limitations

1. "tracking an operating parameter … wherein the … parameter comprises an onset of a signal transmission" (claim 1). This is a detection step at the access point: recognizing that a device has begun transmitting. It does not require power-on detection, and it does not require any particular message.
2. "if the tracked operating parameter occurs within a time interval" (claims 1, 22, 43). No anchor is recited for the interval, and no duration (the "5 minute" example in the spec is unclaimed). The claim therefore covers either anchor — a window opened by a user activation, or a window measured from the device event.
3. "provisioning" (1, 22) vs. "association" (43). Claim 43 is the broadest independent claim: it covers power-on or onset of transmission, uses the term "association," and does not require user activation (that limitation appears only in dependent claim 54). This is the claim most exposed to the cited art.

3. The prior-art corpus, mapped

Identifier note (literal): the '285 specification cites "PCT Patent Application No. WO 01/2266," while the front page lists WO2001022661A2 ("Method for device registration in a wireless home network," Thomson Licensing). Per the operating rules I do not auto-correct; I treat the specification's "WO 01/2266" and the record's WO2001022661A2 as the same Thomson disclosure (EP 1214829 B1 recites "origin: WO0122661A2"). Verify before filing papers.

4. Ground 1 — Kimura as the primary reference (dangerous to claims 1, 22, 43)

Kimura, standing alone, discloses nearly every element of claim 43 and, on a broad construction, claim 1:

• "an access point" → Kimura's AP 2/18, connected to wired networks.
• "means for tracking an operating parameter of a wireless device" → the AP receiving and processing the MT's authentication request.
• "the tracked operating parameter … comprises … a power on, [or] an onset of a signal transmission" → "the mobile station MT1 is turned on or otherwise operated to send to the access point an authentication request message 1."
• "logic for initiating an association … if the tracked operating parameter occurs within a time interval" → the AP's authentication wait timer bounded window (S31) during which user authorization (S33) permits the association procedure; timeout produces automatic rejection.

Claim 43 uses the very word "association," which Kimura uses natively. Practically, claim 43 is the claim to lead with on invalidity, and Kimura is the lead reference.

The one gap a patentee will argue: in Kimura the timer is started by the device's request and runs on the user's response, so the patentee will say the interval is not the claimed one and that the device parameter itself is not tested "within" the window (it defines the window). Two rebuttals:

1. Claims don't require an anchor. Nothing in claims 1/22/43 specifies that the interval is opened by an activation, nor that the interval pre-exists the device event. Under Phillips, importing the spec's FIG. 5–6 anchoring into the claims is improper.
2. Even if the anchor is required, it is a predictable variation. The patent's own two disclosed orderings (52a and 52b) are the only two ways to order two events. Anchoring the timer to the button press rather than to the request is the quintessential "predictable variation[] of a known device" (KSR), and the result — a bounded enrollment window that admits the device that just appeared and rejects a long-present device — is identical.

Kimura was of record in the parent ('807 face: "2001/0048744 A1 * Kimura … 380/247") and in '285's citation list. Expect the patentee to argue the examiner considered and allowed over it. The response is not that Kimura is new, but that the examiner did not appreciate the authentication-wait-timer teaching (S31–S33) as the claimed "time interval," and that the combination below supplies what Kimura lacks.

5. Ground 2 — Cudak + Lin + WO 01/22661 + Kimura (the claim 1/22 combination)

For claims 1 and 22, use Kimura as the primary reference and the others to fill scene and supply motivation, all of which are concededly known:

• Cudak supplies the "network access point that monitors operation of wireless devices within a service region," the roster/ACL function, the in-home deployment, the device taxonomy, and the wired/Internet connectivity of dependent claims.
• Lin supplies "provisioning" as an air-interface process triggered by device activation, including transfer of setup/service information — supporting even the unpublished-app reading of "provisioning."
• WO 01/22661 supplies the element that is missing from Kimura's administrator-centric design: automatic, in-home registration in which the AP itself sends the key material to the device, plus the express motivation ("a more automatic authentication procedure is desirable," user interface "as simple as possible," plug-and-play).
• Kimura supplies the timing element and, independently, the security rationale (prevent association from terminals in blind spots beyond walls).

Why the POSITA would combine them (articulated motivation):

1. Same field, same problem. All four address admitting wireless devices to a small, unmanaged local network secured by an AP. Kimura and WO 01/22661 both name the home environment; Cudak is an in-home RF bus; Lin is wireless service provisioning.
2. The known problem is admitted in '285. The patent's background concedes that manual MAC/PIN entry is impractical for UI-less devices (picture frames) and burdensome for ordinary users. Cudak independently calls PIN/PSK typing "cumbersome." Any artisan reading WO 01/22661's call for plug-and-play would move enrollment logic to the AP — where the AP already tracks device activity (Cudak) and can detect the onset of transmission or power-on without device-side input.
3. Security supplies the window. Kimura identifies the exact threat (a hostile station associating from a neighboring space). Bounding authorization to a short interval is the natural, art-recognized remedy; Kimura already implements a bounded interval via a timer. Extending a known timer technique from the "user-response" side to the "device-appearance" side is a predictable use of a known technique to improve a similar device in the same way (KSR).
4. UI-free triggering is a design choice, not an invention. "Power on / onset of transmission" is the only universally available signal from a device that may have no UI (the patent's own premise). Selecting it as the tracked parameter is dictated by the problem, not by insight.
5. Reasonable expectation of success. Every element is conventional: AP-side detection of a station's first transmission (802.11 authentication/association; Cudak's registration; Kimura's request message); a timer (Kimura); ACL updating (Cudak, and '285's own admitted practice); key/setup delivery over the air (WO 01/22661; EP 1081895).

6. Ground 3 — EP 1081895 + Kimura + WO 01/22661 (claim 43 and the "encryption provisioning" dependents)

For claim 43, add EP 1081895 to establish AP/device mutual air-channel authentication, AP and device keys, and the exchange of the encryption mechanism upon channel establishment — which covers dependent claims 8/29/50 ("setup, handshaking, or encryption information") and the association-with-key-material reading. Cohen (2003/0152235) is available for key distribution, though it adds little.

7. Claim-by-claim mapping (all 62 claims)

8. Where the art is thin — be honest with the client

• Claims 5 / 26 / 47 ("prevented if the tracked operating parameter occurs repeatably"). I could not verify any cited reference teaching disqualification based on repeated power-cycling. This is the weakest obviousness link in the set. It is also the most vulnerable to a § 112(b) challenge: "occurs repeatably" has no antecedent mechanism, no threshold, and no objective boundary in the specification (the spec's only gloss — "a neighboring device which is switched on and off repeatedly" — describes the accused behavior, not the test). Attack this claim on indefiniteness and written-description grounds, not § 103.
• Button/switch (14/35/55). No cited reference literally discloses a button. Expect the patentee to press this. Rebut with design-choice/KSR reasoning plus non-cited conventional AP I/O, or take the position that the limitation lives in dependent claims only.
• The interval anchor. This is the patentee's one genuine argument: read claim 1's "occurs within a time interval" together with the disclosed activation, and Kimura's timer (which the device itself starts) arguably does not anticipate. That argument does not survive Claim 43, and it does not defeat obviousness once WO 01/22661's automatic home enrollment and Kimura's timer are combined.
• Hindsight risk. Building the motivation from '285's own background ("no user interface is impractical") is legitimate as an admission, but a court will scrutinize whether the combination — not the goal — was suggested by the art. Kimura's "blind spot beyond walls" passage is the best non-hindsight motivation because it is in the art itself.

9. Confidence and uncertainty disclosures

• High confidence: Kimura's timer/authorization/timeout architecture (verified against the published application text and the EP 1161031 counterpart abstract, citing steps S30–S33); Cudak's architecture and device list; Lin's "upon activating … authentication and registration" + provisioning tunnel; WO 01/22661's identification-code → authentication-key delivery and its plug-and-play motivation; EP 1081895's air-channel authentication and key exchange.
• Not verified paragraph-by-paragraph: the non-patent literature (Candolin Bluetooth security; Aziz & Diffie; Bhargava; Gummalla & Limb; Lilakiatsakun; Shepherd; the Smart Home/AV papers; Murthy; Zhang & Lee). I use them only for field-level context and would not plead a § 103 ground on any of them without reading the actual documents.
• Not verified at all: US 5,461,627 (Rypinski). I could not retrieve its disclosure before hitting a tool step limit. Do not assume it teaches any timing/enrollment window; its title and classification (370/346) suggest shared-channel access/reservation, not admission windows.
• Flagged discrepancy: the specification's "WO 01/2266" vs. the record's WO2001022661A2 — treated above as the same Thomson disclosure, but verify.
• Flagged as non-art: the four post-2003-01-13 NPL items in § 1.
• Claim-number quirk (literal): claims 52, 53, and 62 recite "The system of claim …" inside the access-point claim group (43–62), even though the parent claims are "access point" claims. Minor § 112 consistency issue; do not silently renumber.

10. Posture and recommended next steps (building on earlier sections)

1. This is a district-court invalidity case, not primarily an IPR case. The earlier sections establish that '285 has no PTAB proceedings, no estoppel, and expired 2023-07-20 (adjusted). The grounds above (Kimura, Cudak, Lin, WO 01/22661, EP 1081895) are all patents/printed publications, so they are IPR-eligible — but weigh § 315(b) (served more than one year ago?) and the fact that only pre-expiration damages remain under § 286.
2. Lead with Kimura against claim 43, then Kimura + WO 01/22661 + Cudak against claims 1 and 22. Because the earlier litigation section shows CommWorks pleads the WPS button-press theory against '807/'285/'596/'979, a single shared invalidity narrative — "the art already taught user-authorized, time-bounded wireless enrollment" — serves the entire family, subject to each patent's claim differences (the parent '807 carries 71 claims and different parameter recitations — verify its claims separately; I did not re-verify them here, and the earlier summary's description of the published application's "power on, an activation, and a transmission of an output signal" language is not something I independently confirmed).
3. Close two gaps before serving contentions: (a) obtain the pre-2003 Bluetooth pairing/window art and the Rypinski reference for claims 5/26/47; (b) confirm whether any pre-2003 product (e.g., contemporaneous consumer AP configuration flows) evidences a physical button-opened enrollment window, which would convert claim 14/35/55 from a design-choice argument into a documentary one.
4. Preserve the anchor argument and the indefiniteness argument as independent tracks; the anchor argument may fail on claim 43 but succeed on claim 1, and the § 112(b) attack on "repeatably" is claim-dispositive if it lands.

Contradictions with earlier sections: none material. The ownership point flagged earlier (CommWorks asserting versus Unwired Broadband appearing as licensee) does not affect invalidity, but it does mean any settlement must be papered with the right entity — and it means the family-level invalidity strategy discussed here is worth coordinating across all four family members.