Invalidity dossier
US 7249326
Method and system for reducing notification area clutter
Current assignee: Microsoft Technology Licensing LLC
Added 9/24/2026, 3:58:11 AM
Active provider: DeepSeek · deepseek-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for the patent and any related 2026 CAFC docket activity.
US Patent 7,249,326 — Summary
Note on identifier discipline: The searches surfaced look‑alikes that are not this patent — e.g. 8,027,326 ("'326 Patent," a cloud‑computing patent asserted by Intellectual Ventures against airlines), 7,324,469, and JP 7249326 B2 (a 2023 Japanese patent on super‑resolution microscopy). None of those are US 7,249,326; I have excluded them.
Bibliographic data (authoritative, per the full text you supplied)
| Field | Value |
|---|---|
| Title | Method and system for reducing notification area clutter |
| Patent number | US 7,249,326 B2 |
| Application no. | 09/825,717 |
| Filing date | April 4, 2001 |
| Priority | April 6, 2000 (provisional 60/195,625) |
| Pre‑grant publication | US 2001/0035881 A1 (Nov. 1, 2001) |
| Issue/grant date | July 24, 2007 |
| Inventors | Richard W. Stoakley; James B. Kurtz; Todd J. Green; Ramkumar Ramasubramanian; Chris J. Guzak; James F. Springfield |
| Original assignee | Microsoft Corporation |
| Current assignee (listed) | Microsoft Technology Licensing, LLC (assignment recorded Dec. 9, 2014, effective Oct. 14, 2014) |
| Claims | 13 total (2 independent: claims 1 and 7) |
| Status | Expired – Lifetime; adjusted expiration July 3, 2022 |
| Source | https://patents.google.com/patent/US7249326/en |
Abstract
A method and system for organizing and displaying notification items associated with the system, applications or other components within a notification area. The system monitors items placed in the notification area, comparing the period of placement with a predetermined time threshold. If an item has remained inactive longer than the threshold, the item is hidden from the notification area. The system also monitors hidden items for changes in icon appearance and unhides an item upon a change in appearance or specific selection by a user. New and unhidden items are arranged in the order of most recent addition. The system also allows a user to customize the behavior associated with individual notification items.
Plain-language overview of the independent claims
Claim 1 — Method (system-side, "hide when inactive" behavior)
A method for organizing notification icons in a display's notification area, comprising four steps:
- Receiving user inputs that assign one of several user-selectable hiding behaviors to some of the notification items. At least one behavior is an inactivity hiding behavior (hide the icon once a preset inactivity threshold is met), and at least one other behavior displays the icon without regard to that threshold.
- Monitoring a time interval tied to the activity of the notification items.
- For items set to the inactivity behavior, hiding the corresponding notification-area icon once the preset inactivity threshold is met.
- Upon a user input indicating a desire to view the hidden icons, redisplaying them in the notification area and then repeating the monitoring and hiding steps.
Claim 7 — Method (GUI-side, with a chevron affordance)
In a computer system with a GUI and a display, a method of displaying/organizing notification icons in a notification area:
- Displaying each notification item icon in the notification area.
- Providing a set of user-selectable hiding behaviors for at least some of the icons, one of which is an inactivity hiding behavior.
- Hiding the icons associated with that behavior once the preset inactivity threshold is met.
- Retrieving and displaying a chevron icon (the placeholder that represents hidden items).
- Upon a user input indicating a desire to view the hidden icons, repeating the displaying of the notification item icons, repeating the hiding after the threshold is met, and removing the chevron when there are no more hidden items.
Dependent claims (brief): claims 2–4 (ordering by occurrence / revealing on activity / ordering by most-recently-active) depend from claim 1; claims 8–11 (chevron selection signal displays hidden items; selection unhide criterion; re-display in the notification area; placement at the far left) depend from claim 7. Claims 5 and 6 are a computer-readable medium and a computer system (processor/memory/operating environment) respectively for performing claim 1; claims 12 and 13 are the analogous medium/system claims for claim 7.
Observations / uncertainties
- Claim-language anomalies (literal): The claims as published contain apparent drafting errors I will not silently correct — e.g. claim 1 and claim 7 recite "a preset threshold of inactivity with is met"; claim 9 recites "the unhide criteria is met" without an antecedent for "the unhide criteria." These are reproduced verbatim in the authoritative text.
- 2026 CAFC docket activity: I found no Federal Circuit 2026 docket or opinion involving US 7,249,326. My searches returned 2026 CAFC activity for unrelated patents (e.g. Spero v. Mercedes‑Benz, Nos. 2025‑1306/1307/1473, Rule 36 judgment May 14, 2026; Exafer v. Microsoft briefing) — none of which concern 7,249,326. I cannot rule out an untracked district-court or PTAB matter, but I have no authoritative evidence of any 2026 appellate proceeding for this number.
- Enforceability: Per the record, the patent's adjusted expiration is July 3, 2022, and its status is "Expired – Lifetime." Any 2026 dispute would therefore involve past-damages/§286 look-back issues rather than prospective injunctive relief.
- Date discrepancy: Your prompt states the current date is April 26, 2026, while my operating date is October 1, 2026. This does not affect the bibliographic data above, but it may affect any time-sensitive litigation search.
Do you want me to dig into the file history (e.g., the 09/825,717 prosecution) or the citing/cited-by families to assess claim scope and validity exposure?
Generated 10/1/2026, 2:22:35 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 7249326. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US patent 7249326. Let me search multiple sources.
Let me search more targeted litigation databases.
Let me check a few more specialized litigation sources.
Litigation Search: US Patent 7,249,326
Bottom line: I found no evidence of any litigation (district court, ITC, CAFC, or PTAB) involving US Patent 7,249,326.
What the searches covered
I searched for the patent number across general web, patent-litigation aggregators, and litigation-specific sources including the Unified Patents litigation pages, Justia federal district court dockets, and PTAB/CAFC-related materials. No complaint, docket entry, PTAB proceeding, or ITC action asserting or challenging this patent surfaced.
Case list
None identified. Accordingly, there are no plaintiffs, defendants, jurisdictions, case numbers, filing dates, or outcomes to report for US 7,249,326.
Important search caveats (literal-ID matches that are NOT this patent)
The numeric string "7249326" collides with several unrelated identifiers, which I explicitly exclude from the litigation results above:
| Identifier found | What it actually is | Relevance |
|---|---|---|
| JP 7249326 B2 | A Japanese patent (JP Patent No. 7249326), owned by Institut Pasteur, issued 2023-03-30, covering super-resolution microscopy/neural networks | Not the US patent; unrelated |
| Reg. 7249326 | A US trademark registration ("XPRESS," HEXIN HOLDING LIMITED, Class 25 clothing), registered Dec. 19, 2023 | Not a patent; unrelated |
| "Ato n.° 7249326" | A Brazilian municipal administrative act (Santa Catarina) | Unrelated |
| "8,932,278" / other numbers in reexam litigation-search reports | Different patents in reexamination documents | Unrelated |
These are exactly the "similar but different" matches to avoid, and none involve US 7,249,326.
Patent background (for context, not litigation)
- Assignee history: Originally Microsoft Corporation; assigned to Microsoft Technology Licensing, LLC on 2014-12-09 (per Google Patents).
- Status: Expired – Lifetime; adjusted expiration 2022-07-03 (per Google Patents).
- Priority: 2000-04-06; filed 2001-04-04; granted 2007-07-24.
A patent that was enforced would normally show up in docket databases. What the record does show is a large forward-citation family (the "Cited By" lists on Google Patents), which indicates the patent is technically influential — but citation is not litigation, and I am not treating it as such.
Confidence and recommendation
I have moderate-to-high confidence that no litigation is publicly recorded, but I want to be candid about the limits:
- My searches were web-search-tool based. Paywalled/proprietary docket tools (Docket Navigator, Lexis CourtLink, Westlaw KeyCite LitAlert, PACER itself) may hold records not indexed publicly.
- The patent's 2022 expiration makes recent assertion unlikely, but historical suits around 2007–2015 would have had to appear somewhere to be counted.
To confirm definitively, I recommend verifying directly against: PACER, Westlaw KeyCite/LitAlert, Docket Navigator, and the USPTO PTAB proceeding search. If you can grant access to those or want me to run additional targeted searches (e.g., by the named inventors or the "chevron" notification-area feature), I can continue.
Conclusion: No known litigation involving US Patent 7,249,326 is identified in the sources searched.
Generated 10/1/2026, 2:22:34 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.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll verify the structured "no proceedings" default against live sources before drafting.
Let me run a few more targeted checks before concluding.
Proceedings overview
Zero AIA trial proceedings on file. The USPTO Open Data Portal reports no IPR, PGR, or CBM for US 7,249,326, and my independent web checks (Google Patents, uspto.report, PTAB E2E/PTActs, Unified Patents portal, general invalidity-challenge and litigation queries) surfaced no petition, institution decision, Final Written Decision, or Federal Circuit appeal against this patent — so the breakdown is 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denied, and the defensive posture this gives a defendant is unusual: the patent is not "hardened," it is expired. Its term ran out on 2022-07-03 and it is now marked "Expired - Lifetime," so the cleanest defense is the calendar, not the Board.
Proceedings overview (detail)
| Proceeding | Petitioner | Type | Filed | Status | Claims invalidated |
|---|---|---|---|---|---|
| (none) | — | — | — | — | — |
I could not identify a single AIA proceeding. I want to be explicit about the limits of that statement: the structured ODP block is the canonical source and it returns an empty set, and my web verification corroborated it, but an unindexed older case would not appear in a search of this kind. Nothing in the record suggests one exists.
Why there is no PTAB activity (and why that is not surprising)
This is not a case of a well-asserted patent that simply hasn't attracted a petition yet — it is a case where the statutory windows and the patent's own lifecycle explain the silence:
- Filing/priority date: Filed 2001-04-04, priority 2000-04-06 (provisional 60/195,625). Pre-AIA patent.
- IPR availability: IPR petitions became available 2012-09-16. The patent was live and eligible from then until expiration on 2022-07-03 — a ~10-year window in which any party was free to petition.
- CBM availability: CBM review was available for certain pre-AIA financial/business-method patents until 2020-09-16. US 7,249,326 claims a graphical notification-area / taskbar mechanism (claims 1–13 directed to hiding, revealing, and configuring notification icons). It is not a "covered business method" — no financial-product or financial-service claim element — so CBM was never a realistic vehicle.
- Expiration: The "Expired - Lifetime" status and the 2022-07-03 adjusted expiration date mean the patent cannot now be asserted against new conduct, and any late petition would face (a) no live exclusionary right to defend and (b) the Board's settled practice of weighing the patent's expired status. There is no live proceeding to track.
- Ownership: Original assignee [Microsoft Corp.](/litigations/by-plaintiff/Microsoft%20Corp.); reassigned to Microsoft Technology Licensing, LLC on 2014-12-09 (recorded effective 2014-10-14). No defensive aggregator (e.g., Unified Patents) appears anywhere in the chain — those entities petition against patent-owner assertions, and this patent's owner is the original operating company.
Claim-level status map
Because no tribunal has ever construed or canceled anything here, claim status is purely a function of the patent's own file history and term:
- Claims 1–13 — never adjudicated by the PTAB. All thirteen claims stand as issued and as limited only by prosecution. Independent claims: claim 1 (method for organizing/displaying notification items) and claim 7 (method of displaying/organizing notification item icons with the chevron). Dependent claims 2–4 depend from claim 1; claims 8–11 depend from claim 7. Claims 5 and 6 are the computer-readable-medium and computer-system counterparts of claim 1; claims 12 and 13 are the counterparts of claim 7.
- CANCELED: none.
- SUSTAINED: none adjudicated; "sustained" is not a meaningful category absent a proceeding.
- UNTESTED: all of claims 1–13. There is no FWD, no certificate of cancellation, and no court judgment of invalidity.
Estoppel landscape
There is no § 315(e)(2) estoppel against anyone, because estoppel attaches only "after the petitioner obtains a final written decision" from an instituted IPR. With zero proceedings, no petitioner, real party in interest, or privy is estopped from raising any ground — § 102, § 103, or § 112 — in district court or before the Office.
Practically, that means a defendant facing an assertion (if any) retains the full invalidity toolbox: anticipation, obviousness in view of any combination, and § 112 written-description/enablement challenges, with no requirement to avoid art a prior petitioner already used. Note, however, the § 315(b) one-year bar and the § 315(a)(1) civil-action bar are fact-specific to each defendant's own litigation posture and are unaffected by the absence of prior PTAB activity.
Strategic summary
US 7,249,326 is a 2000-priority Microsoft UI patent that escaped the IPR era entirely. It was live for the full ten years of IPR availability and attracted no petition. The most likely explanations are the ones the posture suggests: it is not a financial-business-method patent (so no CBM), it was never held by a non-practicing entity that invited a defensive-aggregator attack, and — critically — it expired on 2022-07-03. There is no cross-proceeding picture to assemble, no narrowing, and no surviving-claim carve-out to map; the claim set is a single, unlitigated unit of thirteen claims.
The absence of any PTAB activity here is not the "well-asserted patents eventually attract IPRs" signal described in the task framing. That heuristic assumes a live patent being asserted against operating companies. This patent is expired and was held continuously by Microsoft/Microsoft Technology Licensing, which largely removes the economic incentive that drives IPRs. So the absence should not be read as "the patent is strong"; it should be read as "the patent is over."
For a defendant today, the analysis collapses to term, not validity. If a demand letter cites US 7,249,326, the threshold question is whether the accused conduct predates 2022-07-03 (the adjusted expiration) — because after that date there is no enforceable right to infringe, and any pre-expiration claim is time-barred by the § 286 six-year damages lookback (from 2026-10-01, roughly conduct after 2020-10-01). If the demand points only at post-2022-07-03 conduct, it is non-actionable on its face, independent of the PTAB record.
Recommended next steps
- If you are a defendant and a demand letter cites US 7,249,326: lead with expiration, not invalidity. The patent's PTAB record is empty, so there is no FWD to quote and no canceled claim to point to. The dispositive facts are the 2022-07-03 adjusted expiration (Google Patents legal status: "Expired - Lifetime") and the pre-AIA § 286 six-year damages window. Demand a damages period with specific dates before engaging on the merits.
- If your exposure is entirely post-expiration: there is no live proceeding to monitor and no trial-stage milestones to track — institution deadlines, oral hearings, and the § 316(a)(11) one-year FWD deadline are all inapplicable because no petition exists. The correct response is a term-based dismissal/non-infringement posture, not an IPR strategy.
- If you nonetheless want a validity fallback (e.g., the letter asserts pre-2022 conduct): you are unconstrained by estoppel and free to run any § 102/§ 103 combination. The prosecution record cites a small set of references — IBM's Locator icon mechanism (US 5,534,887), Microsoft's notification-area (US 5,617,526) and taskbar/start-menu (US 5,757,371) patents, IBM's icon-selection methods (US 5,852,440), and Libera's US 5,790,122 — see the "Patent Citations (10)" list on Google Patents; none was the subject of any post-grant challenge.
- No PTAB activity to monitor: confirm independently via the PTAB E2E / PTActs portal and the Google Patents page for US7249326B2 (legal status and "Cited By" tables). If any proceeding is later identified that the ODP ingest missed, downgrade this memo accordingly and pull the FWD at the USPTO PTAB Decisions site — but I found none, and the structured source agrees.
Caveat on sourcing: I did not find — and did not fabricate — any proceeding number, judge panel, institution date, FWD, settlement, or CAFC docket for this patent. Every "zero / none / not applicable" above reflects the structured ODP block plus my independent searches; if your ODP pull is stale, re-run it before relying on this.
Generated 10/1/2026, 2:22:46 PM
Ownership chain (2)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2001-04-04 · reel 011693/0595 · Assignment
Stoakley, Richard W.; Kurtz, James B.; Green, Todd J.; Ramasubramanian, Ramkumar; Guzak, Chris J.; Springfield, James F.Microsoft Corporation
2014-10-14 · recorded 2014-12-09 · reel 034541/0001 · Assignment
Microsoft CorporationMicrosoft Technology Licensing, LLC
Correspondent: · CPA Global
internal reorg
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll verify the assignment record and check for any post-Microsoft transfers or assertion activity using web sources before reconstructing the chain.
Let me check for any litigation involving this patent and verify the Microsoft-to-MTL transfer record details.
Let me check the recorded assignment pages directly and look for any assertion of this patent.
Ownership Reconstruction — US 7,249,326 B2
"Method and system for reducing notification area clutter"
Application US 09/825,717 · filed 2001‑04‑04 · priority to provisional 60/195,625 (2000‑04‑06) · granted 2007‑07‑24 · status: Expired – Lifetime (adjusted expiration 2022‑07‑03)
Source note: USPTO Assignment Center (https://assignmentcenter.uspto.gov/) was not directly queryable from this session; reel/frame and legal-event data below are taken from the authoritative Google Patents record supplied in the prompt, corroborated against uspto.report, espacenet INPADOC legal-status entries, and a PTAB exhibit reproducing the reel 034541 cover sheet. Where a data point is inferred rather than directly read, it is labeled as such.
Inventors
| Inventor | Employer at filing (determinable) |
|---|---|
| Richard W. Stoakley | Microsoft Corporation (Redmond, WA) |
| James B. Kurtz | Microsoft Corporation |
| Todd J. Green | Microsoft Corporation |
| Ramkumar Ramasubramanian | Microsoft Corporation |
| Chris J. Guzak | Microsoft Corporation |
| James F. Springfield | Microsoft Corporation |
Pattern notes. All six are listed on the original assignment as assignors to Microsoft Corporation — this was an in‑house Microsoft UX/shell team filing (Guzak and Stoakley are known Windows shell/taskbar figures). The six inventors executed between 2001‑02‑15 and 2001‑04‑02, i.e. all within ~7 weeks of the 2001‑04‑04 filing — standard employee‑invention practice, not an anomaly. I found no evidence that any inventor departed Microsoft within 12 months of filing, and I will not infer it: no such data surfaced in the sources checked. Do not treat this as a fire‑sale precursor.
Original assignee
Microsoft Corporation (original assignee; current assignee is its IP subsidiary, see below).
- Product embodying the claims: Yes, decisively. The patent claims the "hide inactive icons / customisable notification‑area behaviour / chevron reveal" mechanism (claims 1 and 7). Microsoft shipped exactly this feature in the Windows notification area — the
chevron 272andballoon notification 270of FIG. 7 are the shipped UI, and the Shell_NotifyIcon behaviour described in the spec is the Windows API. This is a genuine operating‑company product patent, not a paper asset. - Primary line of business: Operating system and software vendor; publicly traded (NASDAQ: MSFT).
- Current status: Operating. Not acquired, not dissolved, not in bankruptcy. The patents were moved internally into a licensing subsidiary in 2014 (see timeline), but the parent remains an active operating company.
Assignment timeline
Assignment Center records for this patent comprise two assignments (per the Google Patents legal‑events record for US 7,249,326 B2). No post‑2014 transfer exists anywhere in the record — the chain terminates inside the Microsoft corporate family.
2001‑04‑04 (executed/recorded 2001‑04‑04; inventors signed 2001‑02‑15 → 2001‑04‑02) — Reel 011693/0595
- Conveyance: Assignment (ASSIGNMENT OF ASSIGNORS' INTEREST)
- Assignor: Stoakley, Richard W.; Kurtz, James B.; Green, Todd J.; Ramasubramanian, Ramkumar; Guzak, Chris J.; Springfield, James F.
- Assignee: Microsoft Corporation, Washington
- Correspondent: not exposed in the sources available to me. Stated plainly rather than guessed. (Microsoft in this era typically used in‑house counsel / a Seattle‑area prosecution firm for inventor assignments; I could not verify a name.)
- Context: Standard employee invention assignment at filing — internal, not a sale.
2014‑10‑14 (executed) / recorded 2014‑12‑09 — Reel 034541/0001
- Conveyance: Assignment (ASSIGNMENT OF ASSIGNOR'S INTEREST; ASSIGNOR: MICROSOFT CORPORATION)
- Assignor: Microsoft Corporation
- Assignee: Microsoft Technology Licensing, LLC, One Microsoft Way, Redmond, Washington 98052
- Correspondent: CPA Global Limited, Liberation House, Castle Street, St Helier, JE1 1BL, Jersey. (Important precision caveat: this correspondent name is read from a PTAB exhibit reproducing the cover sheet of the same mega‑assignment at reel 034541/0477 for a sibling Microsoft patent, application 10/369,006. This patent's own frame is 034541/0001 and I did not independently read its cover sheet. The reel is the same, the assignor/assignee pair is the same, and the recording is a single ~5,000‑property / 451‑page transfer, so the correspondence address is almost certainly identical — but I am flagging the frame‑level inference.)
- Context: Internal reorganisation — Microsoft's 2014 carve‑out of its patent portfolio into its wholly owned licensing subsidiary. CPA Global is an IP‑services/annuity agent, not an assertion lawyer; this is the correspondent pattern of a corporate portfolio migration, not of an NPE recording.
No further assignments. There is no third link, no LLC cascade, no security agreement, no release, and no change‑of‑name filing. Maintenance fees were paid at years 4 (2010‑12‑22), 8 (2014‑12‑29) and 12 (2019‑01‑10) by MTL/Microsoft; the patent then reached adjusted expiration on 2022‑07‑03.
Timeline diagram
timeline
title Ownership of US 7249326
2000 : Provisional application filed Apr 6
2001 : Utility application filed by Microsoft
2007 : Patent US 7249326 issued Jul 24
2014 : Microsoft Technology Licensing takes title
2019 : 12th year maintenance fee paid
2022 : Patent term expires
NPE / troll-pattern signals
Shell-entity transfer — not present. The only post‑issuance transfer (reel 034541/0001, executed 2014‑10‑14) moves the patent from an operating parent to its wholly owned subsidiary, Microsoft Technology Licensing, LLC, at Microsoft's own Redmond campus address (One Microsoft Way). The "LLC + Licensing" suffix is a naming coincidence here: MTL is a disclosed, publicly known Microsoft IP‑holding subsidiary (2014 IP‑group restructuring), not a single‑purpose Delaware/Texas shell at a registered‑agent address. The assignor did not divest the asset outside the corporate family.
Known asserter in the chain — not present. Neither Microsoft Corporation nor Microsoft Technology Licensing, LLC appears on the public NPE lists specified (Acacia, Marathon, Intellectual Ventures, IPNav, Wi‑LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). No entity surfaced by Unified Patents or RPX as a high‑frequency plaintiff appears anywhere in this chain.
Repeat correspondent across the chain — not present. Two links, two different correspondent profiles (2001 in‑house/unverified; 2014 CPA Global Limited, Jersey). CPA Global is a portfolio‑administration/annuity firm used across thousands of ordinary corporate recordals, not an assertion lawyer. A single appearance of a services firm is explicitly not a finding under the stated rule; there is no recurrence to count.
Cascading transfers — not present. One post‑issuance transfer in 2014, i.e. thirteen years after filing and after the patent had been maintained through two fee cycles. No chained LLCs, no shared‑correspondent cluster, no sub‑24‑month sequence.
Pre‑litigation transfer — not present / not applicable. The only transfer (2014) is not followed by any suit naming this patent in the sources I checked. I also found no record of any litigation naming US 7,249,326 in the searches performed — I did not exhaustively query PACER/Docket Navigator, so treat this as "no record found," not as a positive finding of never‑sued.
Bankruptcy fire‑sale — not present. Microsoft Corporation has not filed Chapter 7/11, and no bankruptcy‑sale conveyance appears.
Privateering — not present. The transfer is to a wholly owned licensing subsidiary of the same company that makes the embodying product (Windows). There is no evidence Microsoft handed this patent to a third‑party NPE to assert against competitors, and no Patent Progress/EFF/SEC‑filing coverage surfaced.
Defensive aggregator (anti‑NPE) — not present. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. The patent simply expired in the Microsoft family.
Verdict
Operating-company assertion (licensing-subsidiary variant).
Justification: the chain is only two links — reel 011693/0595 (2001‑04‑04) from the six Microsoft inventors to Microsoft Corporation, then reel 034541/0001 (executed 2014‑10‑14, recorded 2014‑12‑09) from Microsoft Corporation to its wholly owned subsidiary Microsoft Technology Licensing, LLC at One Microsoft Way, Redmond. The current holder sits inside the corporate family of the company whose Windows product embodies claims 1 and 7 (the notification‑area chevron/hide‑when‑inactive mechanism), no third party ever took title, no listed NPE appears, and there is no shell‑LLC cascade, no pre‑litigation transfer, and no attorney‑of‑record recurrence. The only nuance against a pure "operating‑company" label is that MTL itself is a licensing entity rather than the manufacturing entity — but it is Microsoft's own subsidiary and the patent expired 2022‑07‑03, so there is no assertion posture to evaluate.
Caveats I will not paper over: (i) the 2001 correspondent is unverified, and the 2014 correspondent (CPA Global Limited) is read from a sibling patent on the same reel, not this patent's own frame; (ii) "no litigation found" means my search surfaced none — it is not a certified negative.
Verify independently at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (search patent number 7249326, or application 09/825,717), mirrored at https://assignment.uspto.gov/patent/index.html.
Generated 10/1/2026, 2:23:01 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll verify each of the ten references cited on the face of US 7,249,326 (the "Patent Citations" list) against the USPTO/public databases before assessing § 102 anticipation. Let me run those lookups.
I found an important discrepancy on one reference that I'll flag. Let me verify the remaining citations and resolve the title issue.
Prior-Art Analysis — US 7,249,326 B2
Note on scope and a source conflict: I confirmed US 7,249,326 B2 as US App. 09/825,717, "Method and system for reducing notification area clutter," priority 2000‑04‑06 (prov. 60/195,625), filed 2001‑04‑04, granted 2007‑07‑24, Microsoft. The task asks me to analyze "each patent citation for 7249326," which is the 10‑reference "Patent Citations" list printed on the face of the patent (the backward citations). I do not treat the much larger "Cited By" set as prior art — those are forward citations (applicants citing this patent) and post‑date it.
One discrepancy to flag, not auto‑correct (per your strict rule): Google Patents lists the fourth reference as US 5,852,440 A, title "Method and system for facilitating the selection of icons," IBM, priority 1994‑04‑13, published 1998‑12‑22. A Google patent‑sitemap entry separately labels US 5,852,440 as "System for cleaning up a computer display." The EveryPatent/USPTO mirror for 5,852,440 carries the title "Method and system for facilitating the selection of icons" and the Pickover‑et‑al. subject matter (consolidation into a "master icon," clutter cleanup). I therefore adopt the patent's face title and note the variant label rather than "correcting" either.
Bottom line on § 102
No single one of these ten references anticipates independent claim 1 or claim 7 under 35 U.S.C. § 102 as a whole. Neither independent claim's full combination is met by any one reference: each claim requires, together, (i) user‑selectable hiding behaviors, at least one being an inactivity‑hiding behavior and at least one that displays the icon without regard to the threshold; (ii) hiding after the preset inactivity threshold; and (iii) redisplaying on a user input and, for claim 7, a chevron plus its removal. The cited art is best characterized as § 103 obviousness material (closest: US 5,617,526 and US 5,534,887), with individual references mapping strongly to individual limitations as detailed below.
Legend for the mapping column: "Env." = environment/preamble; "Hide" = inactivity hiding limitation; "Chevron" = placeholder/aggregation limitation; "Unhide" = redisplay‑on‑input limitation; "Order" = arrangement/ordering limitation.
Reference‑by‑reference
1. US 5,617,526 A — Operating system provided notification area for displaying visual notifications from application programs
- Full citation: US 5,617,526 A; Oran, Daniel P.; Serrador, Teresa A.; Belfiore, Joseph D.; Pitt, George H., III; assignee Microsoft Corp.; Appl. No. 355,398.
- Dates: filed 1994‑12‑13; granted 1997‑04‑01. (Pre‑dates priority 2000‑04‑06; § 102(b).)
- Description: The foundational "system tray." Discloses a designated notification area on the shell UI, application icons displayed there without interrupting the running application, tool‑tips, click‑to‑open, and the area expanding/shrinking to fit icons and "removing the notification from the notification area when the notification is no longer required" (claim 9). Source: https://patents.google.com/patent/US5617526 and https://uspto.report/patent/grant/[5617526](/patent/5617526).
- § 102 relevance: Env. only — supports the preamble/environment of claims 1 and 7 ("notification area," "notification item icons," "displaying each of the notification item icons in said notification area"). It does not disclose the user‑selectable behavior set, the preset‑inactivity‑threshold hiding, the chevron, or the redisplay‑on‑user‑input. Does not anticipate claims 1 or 7. Note that the patent's own specification invokes this same WINDOWS notification‑area/
Shell_NotifyIconparadigm, so this reference is the acknowledged starting framework, not an anticipating disclosure.
2. US 5,534,887 A — Locator icon mechanism
- Full citation: US 5,534,887 A; Bates, Cary L.; Ryan, Jeffrey M.; Watts, Byron T.; assignee International Business Machines Corp.; Appl. No. 08/198,748.
- Dates: filed 1994‑02‑18; granted 1996‑07‑09. (§ 102(b).)
- Description: On an application "bell tone," the system displays a locator icon; if the user does not select it and no further tone is emitted, the icon is "removed from the display after a time period, which may be set by the user," and "the timer for the locator icon is reset" if another tone arrives. Source: https://patents.google.com/patent/[US5534887A](/patent/US5534887A) and https://www.freepatentsonline.com/[5534887](/patent/5534887).html.
- § 102 relevance: Hide (strong) — a user‑settable time period after which an un‑acted‑upon icon disappears, with timer reset on activity, closely tracks the "preset threshold of inactivity" and the spec's reset‑on‑appearance‑change concept; Unhide (partial) — user selection brings the associated window forward. However, it is a window‑locator mechanism, not a notification‑area with user‑selectable per‑item hiding behaviors (no "display without regard to the threshold" option, no chevron). Does not anticipate claims 1 or 7; strongest single‑reference § 103 teaching on the "hide‑after‑inactivity / reset‑on‑activity" core.
3. US 5,852,440 A — Method and system for facilitating the selection of icons
- Full citation: US 5,852,440 A; inventors incl. McLean, James G.; Pickover, Clifford A.; Schwartz, Michael S.; Winarski, Daniel J.; assignee International Business Machines Corp. (title as printed on the patent; a sitemap source labels it "System for cleaning up a computer display" — see flag above).
- Dates: priority 1994‑04‑13 (division of Ser. No. 08/227,149); granted 1998‑12‑22. (§ 102(b).)
- Description: Reduces display clutter: icons "least likely to be used" are faded/shrunk, and frequently‑unused icons are consolidated into a "master icon," the consolidated icons being "hidden from view," with tabs indicating the consolidated members; an icon can be retrieved when expected to be used. Sources: https://uspto.report/patent/grant/5,852,440, https://www.patentleaderboard.com/ibm/bertrand-m-grossman/[1090597](/patent/1090597).
- § 102 relevance: Hide (mechanism, not trigger) and Chevron (mechanism) — the master‑icon‑with‑tabs is conceptually analogous to the claimed chevron as a placeholder into which hidden icons are aggregated, and the "hidden from view"/re‑retrieval behavior parallels the hide/unhide cycle. But its trigger is a likeliness‑of‑use probability, not an inactivity threshold, and there is no per‑item user‑selectable behavior set. Does not anticipate claims 1 or 7; useful § 103 art for the "aggregate hidden icons behind a placeholder" idea.
4. US 5,790,122 A — Method for providing maximum screen real estate in computer controlled display systems during software application navigation
- Full citation: US 5,790,122 A; assignee Libera, Inc.
- Dates: priority 1994‑11‑15; granted 1998‑08‑04. (§ 102(b).)
- Description: Per the face title, a scheme to maximize usable screen area (auto‑hiding/recovering display chrome) during application navigation. (I was unable to complete a full‑text verification of this reference within the search budget — see caveat below.)
- § 102 relevance: Env./Hide (weak, general) — relevant only as generic background for automatically hiding UI elements to reclaim screen space; does not disclose a notification area, an inactivity threshold, a chevron, or per‑item behaviors. Does not anticipate claims 1 or 7.
5. US 5,757,371 A — Taskbar with start menu
- Full citation: US 5,757,371 A; Oran, Daniel P.; Ellison‑Taylor, Ian M.; Chew, Chee H.; Belfiore, Joseph D.; Malamud, Mark A.; Bogdan, Jeffrey L.; Sullivan, Kent D.; assignee Microsoft Corp.; Appl. No. 572,725.
- Dates: filed 1995‑12‑14 (continuation of 08/478,490, filed 1995‑06‑07); granted 1998‑05‑26. (§ 102(b).)
- Description: The WINDOWS taskbar. Includes auto‑hide of the taskbar when a window is non‑minimized and "unhiding the user interface element in response to the cursor being positioned in a predefined area of the video display" (claims 40, 46–48). Source: https://patents.google.com/patent/[US5757371A](/patent/US5757371A)/en and https://uspto.report/patent/grant/[5,757,371](/patent/5757371).
- § 102 relevance: Unhide (structural analogue) — the hide‑UI‑element / unhide‑on‑cursor‑input pattern is the general form of claim 1's "upon receipt of a user input indicating a desire to view the hidden… redisplaying." But it concerns the taskbar, not notification‑area items, and discloses no inactivity threshold or chevron. Does not anticipate claims 1 or 7.
6. US 5,673,403 A — Method and system for displaying applications of different operating systems on a single system using the user interface of the different operating systems
- Full citation: US 5,673,403 A; assignee International Business Machines Corp.
- Dates: priority 1992‑11‑13; granted 1997‑09‑30. (§ 102(b).)
- Description: Co‑displaying applications from different operating systems within one host UI.
- § 102 relevance: None material to claims 1–13. This is a general windowing/interop reference with no notification area, no inactivity hiding, and no chevron. Does not anticipate any claim.
7. US 6,553,416 B1 — Managing computer system alerts
- Full citation: US 6,553,416 B1; assignee Micron Technology, Inc.
- Dates: filed 1997‑05‑13; granted 2003‑04‑22. (Filed before priority → available as § 102(e) art.)
- Description: System for managing computer‑system alerts/notifications. (Full‑text verification not completed within the search budget — see caveat.)
- § 102 relevance: Env. (possible, on notification/alert handling generally) — as alert management it may touch the "notification item" concept, but I have no basis to attribute the inactivity‑threshold hide, the selectable behavior set, the chevron, or the redisplay‑on‑input to it. Does not anticipate claims 1 or 7 on the record available.
8. US 6,211,858 B1 — Method and apparatus for displaying a rotating meter icon on a portable intelligent communications device
- Full citation: US 6,211,858 B1; assignee Ericsson Inc.
- Dates: filed 1997‑09‑26; granted 2001‑04‑03. (Filed before priority → § 102(e).)
- Description: Displays an animated/rotating meter icon conveying status on a portable communicator. (Full‑text verification not completed — see caveat.)
- § 102 relevance: Env. (weak) — icon/status display only; no notification area, threshold hiding, or chevron. Does not anticipate claims 1 or 7.
9. US 6,385,662 B1 — Method of processing information using a personal communication assistant
- Full citation: US 6,385,662 B1; assignee Ericsson Inc.
- Dates: filed 1997‑10‑03; granted 2002‑05‑07. (Filed before priority → § 102(e).)
- Description: Information handling on a personal communication assistant. (Full‑text verification not completed — see caveat.)
- § 102 relevance: None material to the notification‑area hiding claims as far as the record shows. Does not anticipate any claim.
10. US 6,542,163 B2 — Method and system for providing relevant tips to a user of an application program
- Full citation: US 6,542,163 B2; assignee Microsoft Corp.
- Dates: filed 1999‑05‑05; granted 2003‑04‑01. (Filed before priority → § 102(e).)
- Description: Delivers context‑relevant tips/help to a user of an application. (Full‑text verification not completed — see caveat.)
- § 102 relevance: Env. (weak) — user‑facing notification/help delivery; no threshold‑based hiding, no chevron, no per‑item behavior selection. Does not anticipate claims 1 or 7.
Consolidated § 102 mapping (closest three only)
| Ref | Env. | Hide (inactivity) | User‑selectable behaviors | Chevron | Unhide on input | § 102 verdict |
|---|---|---|---|---|---|---|
| US 5,617,526 | ✔ | ✗ | ✗ | ✗ | ✗ | No (env. only) |
| US 5,534,887 | ~ | ✔ (user‑set timer; reset on activity) | ✗ | ✗ | ~ | No (but strongest § 103) |
| US 5,852,440 | ~ | ~ (likeliness, not inactivity) | ✗ | ~ (master‑icon tabs) | ~ | No |
No reference supplies the "user‑selectable hiding behaviors" limitation (the threshold‑based behavior vs. a behavior that displays "without regard to said preset threshold") that both independent claims make central. That limitation is the principal § 102 gap across the entire cited set.
Caveats and confidence
- Verified in full: US 5,617,526, US 5,757,371, US 5,534,887, and US 5,852,440 (title/description confirmed via Google Patents, USPTO mirrors, and FPO/patent‑leaderboard).
- Not fully verified full‑text within the search budget: US 5,790,122, US 6,553,416 B1, US 6,211,858 B1, US 6,385,662 B1, US 6,542,163 B2. My descriptions for these rest on the titles as printed on the face of US 7,249,326 (authoritative per your rule that the supplied patent text governs) plus general knowledge; I did not independently confirm their disclosures line‑by‑line. Treat those § 102 assessments as provisional. If you want, I can run targeted per‑reference full‑text pulls next.
- Legal standard reminder: § 102 anticipation requires all limitations in a single reference, arranged as claimed. On the record above, none of the ten meets that bar for claims 1 or 7; the realistic posture is that US 5,617,526 + US 5,534,887 (+ US 5,852,440) would be argued under § 103, not § 102.
- Date note: your task specifies the current date as April 26, 2026; my operating notice says October 1, 2026. This does not affect the prior‑art analysis (all references pre‑date the 2000 priority), but I flag the inconsistency as instructed.
Generated 10/1/2026, 2:23:10 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the analysis in the actual cited references before building the §103 combinations.
Now let me ground the remaining cited references.
Obviousness Analysis — US 7,249,326 B2 under 35 U.S.C. § 103
Scope note. This builds on the two prior sections (patent summary; litigation summary) and does not repeat them. It uses the 10 references in the "Patent Citations" section of the Google Patents page (the page's prior-art list), plus two flagged supplementary references noted below. Where I flag a reference as coming from outside that list ("Similar Documents" or a same-family member), I say so explicitly.
1. Legal framework and person of ordinary skill
- Governing law. The application was filed April 4, 2001 (provisional priority April 6, 2000), so pre‑AIA § 102/§ 103 apply. Obviousness is judged as of the April 6, 2000 priority date.
- PHOSITA. A software engineer/UI designer with ~2–3 years' experience in operating-system shell and graphical-user-interface (GUI) development, familiar with Windows taskbar/notification-area APIs (Shell_NotifyIcon), status-bar and toolbar widgets, and standard event-driven display-management techniques (timers, icon-state updates, user preference dialogs).
- Governing test. Graham v. John Deere; KSR Int'l v. Teleflex, 550 U.S. 398 (2007) — the enumerated rationales (combining prior-art elements; simple substitution; "known technique to improve similar devices in the same way"; design incentives/known market demand) are all available here because every reference is in the same field of art (presenting status/notification indicators on a computer display).
- Claim-construction caveat (carried forward from the prior section). The claims contain literal drafting anomalies — claim 1 and claim 7 recite "a preset threshold of inactivity with is met"; claim 9 refers to "the unhide criteria" with no antecedent. I do not silently cure these. For the analysis below I read the claims as a PHOSITA would, but note that these defects create real § 112 and indefiniteness exposure that a challenger could use in addition to § 103.
2. Prior-art inventory (from the page's "Patent Citations" list)
| Ref. | Title / assignee | Filed / Granted | Status as of 4/6/2000 | Relevance core |
|---|---|---|---|---|
| US 5,617,526 ("'526") | Operating system provided notification area for displaying visual notifications from application programs / Microsoft | 12/13/1994 / 4/1/1997 | § 102(b) | The notification area / taskbar tray itself (Oran et al.) — primary reference |
| US 5,534,887 ("'887") | Locator icon mechanism / IBM | 2/18/1994 / 7/9/1996 | § 102(b) | Timer-driven icon removal; user-settable period; timer reset on new event; user selection to invoke |
| US 6,211,858 ("'858") | Rotating meter icon on a portable intelligent communications device / Ericsson | 9/26/1997 / 4/3/2001 | § 102(e) (as of 1997 filing) | User-configurable per-item display behavior (fixed = always shown vs. rotating = shown for a predetermined period); priority on state change; "flash" on new mail |
| US 6,553,416 ("'416") | Managing computer system alerts / Micron | 5/13/1997 / 4/22/2003 | § 102(e) (as of 1997 filing) | Taming alert floods; not every alert need be displayed; alerts disrupt the user's task |
| US 6,542,163 ("'163") | Providing relevant tips to a user of an application program / Microsoft | 5/5/1999 / 4/1/2003 | § 102(e) (as of 1999 filing) | "Unobtrusive," customizable guidance; idle/"user has not used the application for a predetermined period of time" triggers; priority can override the normal gating |
| US 5,757,371 | Taskbar with start menu / Microsoft | 1995 / 5/26/1998 | § 102(b) | Taskbar/Tray antecedent art (co-pending sibling of '526) |
| US 5,790,122 | Maximum screen real estate during software application navigation / Libera | 11/15/1994 / 8/4/1998 | § 102(b) | Conserving screen real estate by altering displayed elements |
| US 5,852,440 | Facilitating the selection of icons / IBM | 4/13/1994 / 12/22/1998 | § 102(b) | Icon selection/organization UI |
| US 5,673,403 | Displaying applications of different OSs on one system / IBM | 11/13/1992 / 9/30/1997 | § 102(b) | Multi-context GUI presentation |
| US 6,385,662 | Processing information using a personal communication assistant / Ericsson | 10/3/1997 / 5/7/2002 | § 102(e) (as of 1997 filing) | Status/information presentation on a limited display |
Confidence caveat (honest): my retrieval tool hit its step limit before I could pull the full texts of US 5,790,122, US 5,852,440, US 5,757,371, US 5,673,403 and US 6,385,662. I therefore rely on their titles/assignees/dates from the patent page and treat them as corroborating art only. The analysis below is driven by the four references whose contents I verified: '526, '887, '858, '416, '163.
Two flagged supplementary references (NOT in the cited list):
- US 6,425,006 B1 ("Alert Configurator and Manager," Chari/Bright, Micron, filed 10/1/1997) — a same-assignee/same-family companion of '416 (it carries a terminal disclaimer). Its abstract expressly states it "allows the user to select which alerts to enable and which alerts to disable from a list of all possible alerts." That is the clearest express teaching of per-item, user-selectable enable/disable behavior. I flag it because it appears in my search results rather than in the patent page's citation list.
- US 6,121,968 A ("Adaptive menus," Microsoft) — appears in the page's "Similar Documents" section, not the citation list. It is the classic disclosure of a chevron/double-arrow that expands a truncated set of items, with user-customizable "show always" vs. "show recently used." Highly material to claim 7.
3. Ground 1 — Claims 1, 2, 3, 4 (and 5, 6): '526 + '887 + '858, optionally + '416/'163
Claim 1 mapped element-by-element
(a) "receiving one or more user inputs associating … user selectable hiding behaviors … at least one … inactivity hiding behavior … at least one … displays … without regard to said preset threshold."
- '858 is the strongest single teaching. FIG. 7 is expressly "used to configure a 'fixed' meter icon and a 'rotating' meter icon." Claim 1 of '858 has a meter area "to depict one of a plurality of meter symbols … for a predetermined time period, whereby the meter symbol … is automatically rotated"; claim 6 adds a second area "having a designated informative meter depicted therein at substantially all times." That is precisely the claim-1 binary: one behavior hides after a period; another is displayed without regard to that period. And it is user-selectable, because '858 lets the user add meters to the "Meter Player" box and choose fixed vs. rotating placement.
- '416/'006 supply the same concept in the alert context: a list of alerts with user selection of which are shown; '416 notes that a "network administrator may not need to be informed of all alerts" and that "displaying every alert disrupts the network administrator's present task."
- '163 supplies "customizable" behavior in which high-priority conditions override the normal display gate ("if the tip condition has a high priority value, then the tip message window may be immediately displayed without the tip icon") — i.e., a behavior that displays without regard to the user's default preference.
(b) "monitoring an interval of time associated with an activity of … the notification items."
- '887 discloses a memory field "Number of seconds 44" = "the length of time remaining for the locator icon … to be displayed," and a countdown "period of time 24." It also expressly resets the countdown: "When a window emits another bell tone while a locator icon is displayed for that window, the timer for the locator icon is reset."
- '163 detects conditions "when the user has not used the application for a predetermined period of time" — i.e., an inactivity interval.
(c) "hiding the corresponding notification area icon … after said preset threshold of inactivity … is met."
- '887: "If the user does not activate the locator icon and no other bell tones are emitted from the same window, then the locator icon will be removed from the display after a time period, which may be set by the user" (and claim 20: "the period of time is set by the user").
- '858: the rotating meter symbol disappears from the meter area after its predetermined time period.
- Applying either to the '526 notification-area icon is the whole of element (c).
(d) "upon receipt of a user input indicating a desire to view the hidden notification area icons, redisplaying the hidden notification area icons … and repeating said monitoring and said hiding."
- '858 teaches that the user can configure the meter area to bring specified meters back into the rotation ("insert the appropriate meter name into the Meter Player box"), and that a meter whose "value … has changed state" takes priority — i.e., previously-suppressed indicators reappear, after which the periodic display cycle re-arms.
- '887 teaches the user-selection half: the user "activates the locator icon by using the pointing device to select it," and the icon reappears/is acted on.
- Combining (c) and (d) yields exactly the claim-1 loop: hide on timeout → user asks to see → re-display → re-start the monitoring/hiding cycle.
Dependent claims 2–4
- Claim 2 (order in which notifications occur). '526: the notification area "grows and shrinks to accommodate the number of icons that are currently displayed"; icons are added/removed via Shell_NotifyIcon. Ordering by occurrence is the '526 baseline; '858's user-ordered "Meter Player" list is an alternative.
- Claim 3 (detect activity on a hidden item → reveal). '887 reset-on-new-bell-tone; '858 state-change priority.
- Claim 4 (monitor most-recently-active; reveal in order of most recent activity). '858's "one of the meters can take a higher priority in situations where the value displayed by the meter has changed state," displayed "so as to be more readily observed."
Claims 5 & 6 (CRM / processor-memory system for the claim-1 method) add no new art; they stand or fall with claim 1.
4. Ground 2 — Claims 7–13: Ground 1 + the chevron (US 6,121,968 flagged)
Claim 7 = claim 1's substance plus: "retrieving a chevron icon; displaying the chevron icon," and "removing the chevron icon when there are no more hidden items." Claim 8 adds "receiving a chevron entry selection signal … displaying each of the hidden notification items."
- The chevron/overflow-expander is the classic GUI truncation affordance. The page's own "Similar Documents" list supplies US 6,121,968 ("Adaptive menus," Microsoft): a menu that shows a subset and a double-arrow chevron that expands to reveal the hidden items, with an option to show all items; the chevron disappears when there is nothing further to expand. That maps onto claim 7's "retrieve/display/remove chevron" and claim 8's "chevron entry selection signal."
- Design-choice / known-technique fallback. Even without '968, the chevron was a pervasive overflow idiom by 2000 (toolbar overflow, menu overflow, "»" expanders). Under KSR, using a conventional overflow affordance as the reveal mechanism for a set of hidden icons is the "predictable use of prior-art elements according to their known functions" — a strong obviousness posture the patent owner would have to rebut with evidence of unexpected results, which the specification does not supply.
- '887 supplies the "selection reveals the represented item" behavior (user activates the suppressed indicator; it "vanishes" and the underlying item is surfaced).
Claims 9–11 (selection-from-hidden-group as the unhide criterion; re-display in the notification area; far-left placement): '887 (user selection of a hidden/overlaid item's indicator), '858 (state-change priority re-display; fixed vs. rotating placement in the status bar), and '526 (placement/ordering within the notification area) collectively cover these. Claim 11's "far left" is a straight design choice on top of '526's grow/shrink ordering. Claims 12–13 rise and fall with claim 7.
5. Articulated motivation to combine (this is the crux)
A PHOSITA in April 2000 would have combined these references, for reasons stated in the references themselves:
Same field, same problem, same solution type. '526 already recognizes the notification area "grows and shrinks" as icons accumulate; '416 expressly identifies the failure mode the patent targets — "Displaying every alert disrupts the network administrator's present task … a major nuisance if the same alert is continuously sent"; '858 expressly identifies the constraint — "the area used for displaying information is at a premium … there may not be enough space to show the user all the information required by various meters"; '163 seeks guidance that is "unobtrusive." Four independent references frame the identical problem (limited display real estate + indicator overload degrading a status display).
Known technique to improve a similar device in the same way (KSR). '887's timer-then-remove mechanism operates on a displayed status icon waiting for user attention — structurally identical to a '526 notification-area icon. Substituting/applying '887's user-settable timeout to '526's icons is the straightforward application of a known technique to a known device, with predictable results.
Design incentive / known market demand. '858's user-configuration screen (fixed vs. rotating) demonstrates that giving users per-item control over whether an indicator persists was already a recognized design goal; '006 (same family as '416) states expressly that the system "allows the user to select which alerts to enable and which alerts to disable." Extending that existing user-preference model to the notification area is an obvious accommodation of user demand.
Combination of familiar elements with no change in their respective functions. Timers (from '887), per-item user preferences (from '858/'416/'163), and the notification area (from '526) each do exactly what they already did; the combination merely co-locates them. KSR treats this as "a combination of familiar elements according to known methods."
Reasonable expectation of success. Implementation required only conventional event-handling: intercept the Shell_NotifyIcon add/modify calls that '526 already describes, start a timer, compare against a user-set threshold, and toggle a visibility flag. Nothing unpredictable or unproven was required.
6. Where the plaintiff/patent-owner would push back (and how strong that is)
The obviousness case is strong on structure but has two genuine soft spots worth stating candidly:
No cited reference discloses a reversible hide for notification-area icons with a restartable cycle. '887 removes the locator icon (the underlying window is then brought forward — a different resolution), and '416 generally suppresses alerts. Neither explicitly teaches "hide → place behind a persistent placeholder → user recalls → re-display → re-arm the timer." That "repeating said monitoring and said hiding" loop in claim 1, and the chevron-as-persistent-placeholder in claim 7, are where a non-obviousness argument would live. My view: that argument is weak because the chevron/expander with re-hide cycling was a well-known idiom (see '968) and '858 already shows the re-displayed indicator re-entering the periodic cycle.
Secondary considerations. There is no record (in the material reviewed) of unexpected results, industry praise, or copying evidence attributable to these specific claims. Absent objective indicia tied to the claim elements, KSR weighs against patentability. Note the large forward-citation family in the record (the "Cited By" lists) — the patent owner might use that as evidence of the significance of the notification-area-clutter problem, but citation counts are not the legally cognizable secondary consideration (nexus would still have to be shown).
Section 112 overlay (carried forward). The "with is met" and missing-antecedent defects flagged in the prior section are independent vulnerabilities: a claim that is indefinite is not saved by a good obviousness defense, and here they cut against the patent owner by making claim scope uncertain.
7. Bottom line
- No single reference anticipates claim 1 or claim 7 — '526 has the notification area but no hiding; '887 has the inactivity timeout but a different object and resolution; '858 has user-configurable persistent-vs-temporary indicators but in a meter area. So a § 102 challenge fails.
- A § 103 challenge is well-supported. The most persuasive grounds are:
- Claim 1 (and 2–4): '526 in view of '887, further in view of '858 and/or '416/'163.
- Claim 7 (and 8–13): those references further in view of US 6,121,968 (chevron/expandable truncated set) — flagged as a "Similar Documents" reference, not a cited one — or, in the alternative, the chevron as a known GUI design choice.
- Motivation: explicit problem statements in the references themselves (display scarcity in '858; alert nuisance in '416; unobtrusiveness in '163) plus the KSR "known technique applied to a similar device" rationale.
- Confidence: moderate-to-high that claims 1 and 7 are prima facie obvious on these combinations; moderate on the dependent claims (they are weaker, being largely design choices/ordering conventions). I could not verify the full text of five cited references (US 5,790,122; 5,852,440; 5,757,371; 5,673,403; 6,385,662) before my search tool hit its step limit, so I have deliberately not rested any essential limitation on them.
Cross-section consistency check: no contradiction with the prior sections. The bibliographic data, the claim anomalies, the 2022 expiration (so any 2026 dispute is a past-damages/§ 286 matter rather than an injunction matter), and the "no known litigation" finding are all carried forward unchanged. The date discrepancy already flagged (prompt date April 26, 2026 vs. my operating date 2026‑10‑01) does not affect this § 103 analysis, which is anchored to the April 6, 2000 priority date.
Generated 10/1/2026, 2:23:31 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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