Invalidity dossier

US 7941541

Wireless data output method for rendering digital content accessed from a mobile information apparatus

Current assignee: Flexiworld Technologies, Inc.

Added 9/24/2026, 3:33:07 AM

At a glanceNo PTAB challenges7 lawsuits on fileasserted by Flexiworld Technologies, Inc.Wireless Technologies

Active provider: DeepSeek · deepseek-flash

Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

✓ Generated

I'll ground this in both the provided full text and live searches for litigation/docket information.

Let me retrieve the actual claim text and check for any recent (2026) appellate activity.

I have independent claims 27 and 54 partially. Let me retrieve claim 1 and the full claim set, plus check for recent appellate activity.

US 7,941,541 B2 — Analyst Summary

Bottom line up front: I was able to verify the bibliographic data and the statute/ownership history for US 7,941,541 ("the '541 patent"), and I retrieved partial claim text for its later independent claims (27 and 54). I could not retrieve the full claim set (in particular claim 1) or the official abstract text from the fetched Google Patents record, and I found no authoritative evidence of any 2026 CAFC docket involving this patent. Those gaps are flagged below rather than filled in.


1. Bibliographic data (verified against the full patent text provided)

Field Value
Patent number US 7,941,541 B2 (granted as such; publication US 2002/0083121 A1 on 2002‑06‑27)
Title Wireless data output method for rendering digital content accessed from a mobile information apparatus
Application no. 10/016,223 (filed 2001‑11‑01)
Priority date 2000‑11‑01 (assumed priority date; provisional 60/245,101 filed 2000‑11‑01)
Issue / publication date 2011‑05‑10
Inventors William Ho Chang; Christina Ying Liu
Original assignee Flexiworld Technologies, Inc. (assignment recorded 2001‑11‑01, assignors Chang and Liu)
Later assignee of record Samsung Electronics Co., Ltd. (assignment recorded 2013‑03‑13)
Status Expired – Lifetime; adjusted expiration 2023‑02‑15 (i.e., lapsed more than three years before today's date)
Family Large continuation family (e.g., US 8,332,521; US 8,285,802; US 9,164,718; US 9,797,516; US 10,846,031; US 10,592,201/10,592,202), all claiming back to this application
Litigation flag Google Patents shows "Family has litigation"

Spelling caveat under your strict‑interpretation rule: the Google Patents record renders the assignee name inconsistently — the original‑assignee field reads "Flexiworld Technologies Inc," while the reassignment entries read "FLEXIWORD TECHNOLOGIES, INC." I am reporting each spelling as it literally appears and am not correcting either one.

2. Abstract

The text I fetched did not render the official Abstract field. A third‑party aggregator (wiki.golden.com) reports the abstract as:

"An electronic system and method of pervasive output allow an information apparatus to output data content conveniently to virtually any output device. One method includes establishing a communication channel between the information apparatus and an output device and receiving at the information apparatus over the communication channel an attributes corresponding to the output device. The output device may then be selected at the information apparatus based at least in part on the attributes. The data content is delivered to the output device for rendering."

Uncertainty flag: this is a secondary source, not the face of the patent. Treat it as probable but unverified. The specification's own opening definitional statement — which I did verify — frames the invention as relating "to device synchronization and digital output and, in particular, to providing pervasive output for information apparatuses."

3. Independent claims — plain language

What I verified: the claim set runs to at least claim 54. I retrieved full text for claims 32–53 (dependents of claim 27) and the opening of claim 54. I did not obtain text for claims 1–26, so I cannot state how many independent claims exist or describe claim 1. The overviews below cover only the two independent claims I could partially confirm.

Claim 27 — method in a wireless mobile information apparatus (independent).
A method carried out by a wireless mobile information apparatus that outputs digital content to an output device. Based on its dependents, the claim covers:

  • Radio‑wireless discovery of the selected output device — either the apparatus broadcasts a discovery request and awaits a response, or the output device broadcasts its availability; discovery may involve checking whether the device satisfies output, service, or compatibility requirements (price, quality of service, availability) (claims 32–37).
  • Receiving, over a direct wireless connection, one or more components or information from the selected output device — stored either in the output device itself or in an output controller associated with it (claims 38–39). The components may be software code or a software application (claim 41).
  • Installing and executing those received components at the mobile apparatus to drive the output device over the direct connection (claims 43–45).
  • Conforming the data content into output data, which may include raster image processing performed at the apparatus, with raster image processing optionally also performed at the selected output device (claims 46–47).
  • Delivering output data over the direct wireless link for rendering, where the output data may be compressed, may be converted into a form compatible with an output engine / display engine / audio engine / printer engine / output controller / display controller / printer controller, and may be further processed in an output controller before reaching the device (claims 48–49, 52).
  • The output device may be a printing, display, projection, or audio output device (claim 51), and the radio link is Bluetooth or IEEE 802.11‑compatible (claim 53).

Claim 54 — non‑transitory computer‑readable storage unit (independent).
A storage medium holding a software program executable on a wireless mobile information apparatus for outputting digital content "without requiring a device‑dependent output device driver specific to each output device." The program includes software for:

  1. searching over a radio frequency channel for output devices;
  2. receiving device‑dependent attributes of those devices over that channel;
  3. selecting an output device based at least partly on those attributes;
  4. establishing an RF wireless connection directly between the apparatus and the selected device, expressly "not including an external output server" between them;
  5. receiving, over that direct connection, information or components from the selected output device needed to generate at the apparatus output data suitable for sending to that device; and
  6. generating the output data at the apparatus from the digital content based at least in part on … (text truncated in the source I retrieved) — the sentence continues beyond what I could verify.

The technical through‑line of both claims is the 2000‑era Flexiworld premise: the mobile device pulls the device‑dependent pieces from the nearby output device itself, over a direct short‑range wireless link, instead of requiring a pre‑installed driver.

4. Ownership, litigation, and PTAB history

  • Assignment to Samsung (2013): an assignment from Flexiworld Technologies, Inc. to Samsung Electronics Co., Ltd. was recorded 2013‑03‑13 — so the '541 patent's recorded owner of record is Samsung, even though later Flexiworld enforcement activity involved other family members.
  • PTAB: the '541 patent appears as Exhibit 2007 in PGR2021‑00112 (Roku, Inc. v. Flexiworld Technologies, Inc.), a post‑grant review of US 11,029,903 — one of the many continuations in this family. The '541 patent is relied on by Flexiworld as an incorporated‑by‑reference priority document; the petitioner argued it was improper to use the '541 and '257 written descriptions to supply support for the '413 application. Parallel proceedings included PGR2021‑00111 ('031 patent), IPR2022‑01267 ('257 patent), IPR2022‑01268 ('822 patent), IPR2022‑01269 ('577 patent), and IPR2022‑00775 (Unified v. Flexiworld) — the Roku matters terminated in October 2022 by settlement/license.
  • District court: Flexiworld asserted family patents against Roku in Flexiworld Technologies, Inc. v. Roku, Inc., No. 6:21‑cv‑00767‑ADA (W.D. Tex.) and No. 6:20‑cv‑00819‑ADA, and there is a 2025‑docketed case at 2:25‑cv‑00960 (E.D. Tex.) in which Flexiworld recites the '541 patent among the priority chain of asserted continuation patents.

5. CAFC 2026 docket search — result

I searched for Federal Circuit activity tied to the '541 patent, including any 2026 docket entries. I found no authoritative docket, opinion, or order for 2026 involving the '541 patent. I therefore cannot confirm that any 2026 CAFC proceeding exists. Given that the patent's adjusted expiration was 2023‑02‑15, any 2026 appellate activity would most plausibly relate to family continuations (e.g., the '903, '257, '031, or '096 patents) rather than to the '541 patent itself. I am stating this as an inference from the expiration record, not as a verified fact.

6. Number‑confusion cautions (per your strict‑identification instruction)

Several results surfaced numbers that must not be treated as US 7,941,541:

  • US 7,941,541 vs. "7908401‑$.DID. OR US‑7941541‑$.DID." — the latter is an exhibit‑index string in a PTAB filing, not a separate patent number.
  • "US‑7941541‑$" also appeared as a documented‑ID suffix in a PTAB exhibit list; same patent, different notation.
  • The Garmin/Supreme Court petition appendix discussing "the '794 Patent" concerns a different, unrelated patent (Cellspin‑style data‑capture/Bluetooth subject matter); it is not US 7,941,541.
  • Related but distinct family members frequently co‑appearing: US 7,944,577, US 8,184,324, US 9,836,257, US 10,846,031, US 11,029,903, US 9,389,822.

Open items / explicit uncertainty

  1. Claim 1 and claims 2–26 of the '541 patent were not retrieved — I cannot give a complete list of independent claims or a claim‑1 overview.
  2. The abstract is from a secondary aggregator, not the patent face.
  3. No 2026 CAFC docket was located; absence of a result here reflects the limits of my search, not proof of absence.
  4. The assignee spelling discrepancy ("Flexiworld" vs. "FLEXIWORD") is reproduced as it appears and not corrected.

If you want a claim‑chart‑grade version, the next step would be to pull the granted patent's claim sheet directly from the USPTO PatentCenter/Patent Public Search record for application 10/016,223 (or the patentimages PDF of the grant), which would give authoritative claim 1 text and the official abstract.

Generated 10/1/2026, 3:24:29 PM

Cases on file (7)

Group view →

Specific litigation cases in our database that name US patent 7941541. The free-form analysis below may also discuss cases beyond this list.

Lawsuits filed per year

2020: 1 case'202021: 1 case'212022: 3 cases3'222023: 1 case'23
Cases asserting US 7941541, by filing year.

Litigation summary

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

✓ Generated

I'll research litigation involving US patent 7941541 across patent litigation databases and court sources.

Let me search more targeted sources for the specific '541 patent in litigation databases.

Let me dig deeper into whether the '541 patent itself was asserted or was the subject of PTAB proceedings.

Litigation Involving U.S. Patent No. 7,941,541 ("the '541 patent")

Bottom line up front: Based on the sources I could retrieve, I did not find any case in which U.S. Patent No. 7,941,541 was itself pleaded as an asserted patent‑in‑suit (i.e., no infringement complaint I located charges a defendant with infringing the '541 patent). However, the '541 patent is directly involved in one federal litigation — Flexiworld Technologies, Inc. v. Roku, Inc. (W.D. Tex.) — where its ownership/assignment was the central disputed issue in a standing fight. I explain that below, plus the important caveat about coverage limits.

A key fact that explains the absence of '541 infringement counts: the '541 patent was assigned out of Flexiworld to Samsung Electronics Co., Ltd. The Google Patents record lists the current assignees as "Flexiworld Technologies Inc" and "[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.) Ltd," with a 2013‑03‑13 reassignment to Samsung (assignor: Flexiworld Technologies, Inc.). A court order I retrieved quotes the assignment language transferring "the sole and entire right, title, and interest … in and to U.S. Patent No. 7,941,541 and U.S. patent application Serial No. 13/103,958" to Samsung. Flexiworld's later assertion campaigns therefore targeted continuation patents in the family (e.g., the '064, '066, '257, '233, '402, '178, '846, '096, '576, '031, '725 patents), not the '541 patent itself.


1. Case directly involving the '541 patent (ownership/standing dispute)

Flexiworld Technologies, Inc. v. Roku, Inc.

  • Plaintiff / Defendant: Flexiworld Technologies, Inc. (plaintiff) v. Roku, Inc. (defendant)
  • Jurisdiction / Court: [U.S. District Court for the Western District of Texas, Waco Division](/courts/western-district-of-texas-waco) (Judge Alan D. Albright)
  • Case No.: 6:20‑cv‑00819‑ADA
  • Filing date: 2020 (Roku matter; the Amazon companion case 6:20‑cv‑00553‑ADA was filed 06/22/2020)
  • Role of the '541 patent: Not asserted for infringement. Instead, the '541 patent was the pivot of Roku's standing/ownership challenge. Roku argued that Flexiworld's 2013 assignment of the '541 patent (and application 13/103,958) to Samsung was drafted broadly enough ("all inventions described in any of the foregoing") to also assign the later continuation Patents‑in‑Suit ('064 and '066) to Samsung, which would strip Flexiworld of standing.
  • Outcome / current status: The court rejected Roku's argument. In its order filed June 6, 2022 (Doc. 198), the court held that the agreement § 1.1.1 assigned only four specific items — "the '541 Patent, the '958 Application, a continuation application, and a second continuation application" — and that the "rights related thereto or arising thereunder" language is limited to inventions "included in a claim" of those items. The court concluded the '064 and '066 patents were not assigned to Samsung and that Flexiworld retained standing. (This order also appears on CourtListener, opinion ID 10214095.)
  • Sources: https://storage.courtlistener.com/recap/gov.uscourts.txwd.[1107258](/patent/1107258)/gov.uscourts.txwd.1107258.198.0.pdf ; https://www.courtlistener.com/opinion/10214095/flexiworld-technologies-inc-v-roku-inc/ ; Google Patents reassignment/current‑assignee data at https://patents.google.com/patent/[US7941541](/patent/US7941541)/en

2. Related Flexiworld family litigation (for context — these asserted OTHER patents, not the '541 patent)

Flexiworld ran a broad multi‑front assertion campaign. The '541 patent is the common parent/priority patent for many patents asserted in these cases, but I found no complaint asserting '541 itself. Representative cases (from the retrieved pleadings/PTAB papers):

Case Defendant(s) Court / No. Filed Status noted
Flexiworld v. Roku, Inc. Roku W.D. Tex. 6:21‑cv‑00680‑ADA 2021‑06‑28 Settled/voluntarily dismissed 2022‑10‑28
Flexiworld v. Amazon.com, Inc. et al. Amazon.com, Amazon.com Services, AWS W.D. Tex. 6:20‑cv‑00553‑ADA 2020‑06‑22 Terminated 2021‑08‑02
Flexiworld v. Lexmark Int'l, Inc. Lexmark E.D. Ky. 5:22‑cv‑00097 / ‑00110 (lead 5:22‑cv‑00097‑KKC) 2022‑04‑29 Consolidated; §287 notice dispute
Flexiworld v. Brother Industries (USA), Inc. Brother W.D. Tenn. 2:22‑cv‑02251 2022‑04‑21 Settled/voluntary dismissal 2023‑03‑13
Flexiworld v. Hisense Co., Ltd., et al. Hisense E.D. Tex. 2:22‑cv‑00225 → N.D. Ga. 1:22‑cv‑04337 2022‑06‑24 Settled/voluntary dismissal 2023‑04‑07
Flexiworld v. Roku, Inc. Roku W.D. Tex. 6:20‑cv‑00819‑ADA 2020 Infringement action (see §1)
Flexiworld v. Xerox Corp Xerox W.D.N.Y. 6:23‑cv‑06371 2023‑06‑28 Per Unified Patents portal
Flexiworld v. TCL Electronics Holdings Ltd. et al. TCL entities E.D. Tex. 2:26‑cv‑00229 ~2026 Active (docket retrieved 2026‑04‑16)

(There are also complaints in other venues, e.g., a Central District of California action SACV 21‑008xx, and a Sony action described in an RPX litigation document citing notice letters dated October 14, 2021. The patents asserted in those pleadings are family continuations such as the '903, '871, '811, '259, '596, '178, '072, '402, '073, '846, '233, '257 — not '541.)


3. PTAB / post‑grant proceedings

  • I found no IPR, PGR, or reexam instituted on U.S. Patent 7,941,541 itself. The Flexiworld IPRs I located challenged other family members, e.g.:
    • Roku, Inc. v. Flexiworld Technologies, Inc., IPR2021‑00713 (U.S. Pat. 10,740,066) and IPR2021‑00714 (U.S. Pat. 8,989,064).
    • Unified Patents, LLC v. Flexiworld Technologies, Inc., IPR2022‑00775 (U.S. Pat. 9,836,257).
    • IPR2022‑01114 (U.S. Pat. 9,965,233) — settled/voluntarily dismissed prior to institution.
    • IPR2023‑00845 (U.S. Pat. 7,609,402).
  • In these papers, the '541 patent appears only as a priority/incorporation‑by‑reference citation (e.g., parties arguing whether Flexiworld could rely on the '541 and '257 written descriptions), not as the challenged patent.

4. Important caveats (please read)

  1. Coverage limits: I could not complete exhaustive PACER/Unified Patents/RPX/Darts‑IP queries within the available search budget, and I could not directly browse the Unified Patents caselist or Darts‑IP family litigation page linked on the Google Patents record (family 22925285). My conclusion that the '541 patent was never itself asserted is based on the documents I retrieved, not a guaranteed‑complete docket sweep.
  2. Pre‑2013 window unverified: Flexiworld owned the '541 patent from issuance (2011‑05‑10) until the 2013‑03‑13 Samsung assignment (about two years). I found no litigation on '541 in that window, but I cannot rule it out.
  3. Litigation vs. "involvement": If by "litigation involving" you mean the '541 patent appearing in the record at all, then the answer is yes — in Flexiworld v. Roku, No. 6:20‑cv‑00819‑ADA (W.D. Tex.), where its scope of assignment to Samsung was litigated and decided in Flexiworld's favor (Doc. 198, June 6, 2022). If you mean "asserted as an infringed patent," I found no such case.
  4. Assignee status: Because the '541 patent was assigned to Samsung Electronics Co., Ltd., any assertion of the '541 patent today would be brought by Samsung or its successors, not Flexiworld. Readers should treat the assignee information as reported by the sources and not as a legal conclusion.

Recommended verification steps: (a) run the '541 patent through PACER's nationwide patent docket search and through the Unified Patents litigation portal and Darts‑IP family 22925285; (b) confirm the Samsung assignment recordation at USPTO Reel/Frame (the Roku order references the Agreement at ECF 56‑3); and (c) check whether Samsung or its assigns ever asserted '541 (a search for "7,941,541" as a patent‑in‑suit returned no hits in my queries).

Generated 10/1/2026, 3:24:22 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: Flexiworld Technologies, Inc.

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

I'll verify the structured block's "no proceedings" default against live sources before finalizing.

Initial results show Flexiworld PTAB activity — but mostly on other Flexiworld patents. Let me pin down whether any proceeding names the '541 patent itself.

No CBM surfaced either. Two more targeted checks: whether any IPR names the '541 patent directly, and who currently owns it.

I hit my search-step budget, so I'll report what the structured data and the searches I completed establish, and flag what I could not verify.

Proceedings overview

Total AIA trial proceedings on US 7,941,541: zero. The USPTO Open Data Portal block is canonical and returns no IPR, PGR, or CBM naming this patent, and the web searches I ran (PTAB petition documents, Docket Alarm PTAB records, litigation filings, CBM queries) surfaced no petition that challenges the '541 — Flexiworld's PTAB docket involves other patents in this family (the '257, '064, '066, '073, '114, '233, '811, '903), with the '541 appearing only as a recited priority/related patent. Status breakdown is therefore 0 active / 0 invalidated / 0 sustained / 0 settled / 0 institution-denied. Bottom-line defensive posture: unusual but favorable — there is no PTAB estoppel wall and no canceled claims, but the patent carries a 2023-02-15 adjusted expiration (Google Patents lists it "Expired – Lifetime"), so the practical defense is expiration plus a chain-of-title/standing attack on the Samsung assignment, not IPR.

No proceeding entries to itemize

The per-proceeding template (type / filed / status / panel / grounds / institution / FWD / settlement / appeal / defensive value) produces nothing here, because the canonical list is empty and I found no unindexed proceeding to add. I will not manufacture proceeding numbers or outcomes.

Neighborhood proceedings (context only — these are NOT on the '541)

Labeling these clearly as not on this patent, because they are the most useful intelligence for a defendant and several appear to share the '541's specification:

  • PGR2021-00111 and PGR2021-00112 — Roku, Inc. v. Flexiworld Technologies, Inc., on U.S. Pat. No. 11,029,903. Petitioner's briefing argued the claims are invalid for lack of written description (crowding out the information apparatus from the claimed "output system," citing Rivera) and under § 101. Docket: https://www.docketalarm.com/cases/PTAB/PGR2021-00112/Roku_Inc._v._Flexiworld_Technologies_Inc/ — I did not retrieve the FWDs on these and will not state an outcome.
  • IPR2021-00713, IPR2021-00714, IPR2021-00715 — Roku v. Flexiworld, on the '066, '064, and '114 patents. Patent Owner's 2022-07-19 demonstratives show a partial institution: Grounds 1 and 3 denied (Yamaguchi held not prior art; Ikonen's inquiry response not a "broadcast or advertisement of availability"), Ground 2 (Ikonen + Gu) instituted on claims 7, 8, 10. FWD outcomes not verified.
  • IPR2022-01112, IPR2022-01113, IPR2022-01114 — Roku v. Flexiworld, on the '073, '811, and '233 patents.
  • IPR2022-00775 — Unified Patents, LLC v. Flexiworld, on the '257 patent. Institution decision dated 2022-11-08 (Panel: Ogden, joined by McMillen and Dougal), rejecting Flexiworld's § 314(a) discretionary-denial arguments about Unified not practicing the patent. This confirms a defensive aggregator (Unified Patents) is in the chain — but against a family member, not the '541.

Two things worth flagging about that pattern: (1) Petitioners consistently attacked the later-issued continuations, not the '541, and (2) the '541 is the expired parent, which removes most of the incentive to spend IPR fees on it.

Strategic summary

Claim status. No claim of the '541 has been canceled, narrowed, or sustained through any AIA trial — the entire claim set is untested at the PTAB. But that is not a "hardened patent" story: per the front page, the patent is Expired – Lifetime with an adjusted expiration of 2023-02-15, and it issued 2011-05-10 from an application filed 2001-11-01. For a defendant facing assertion today, the live question is not validity but whether any infringing acts fall inside the damages window (pre-expiration, subject to the six-year lookback of 35 U.S.C. § 286), and whether the patent was even Flexiworld's to assert.

Estoppel landscape. Because there is no IPR/PGR on the '541, § 315(e)(2) estoppel does not exist for this patent against anyone. No petitioner is barred from raising any § 102/§ 103 ground, and there is no adverse FWD record to work around. Full freedom of action on the prior-art side — an unusual luxury in a family this heavily litigated.

Ownership / standing — the real defensive lever. In Flexiworld Technologies, Inc. v. Roku Inc., No. 6:20-cv-00819-ADA (W.D. Tex.), the court construed the 2013 Samsung agreement and held that § 1.1.1 "specifically assigns four items (the '541 Patent, the '958 Application, a continuation application, and a second continuation application)," while concluding the '064 and '066 were not assigned. Google Patents separately lists Samsung Electronics Co., Ltd. among the current assignees. If a demand letter asserts the '541 against you, the threshold question is whether Flexiworld owns it at all, and Roku's standing challenge gives you a template. Full opinion: https://www.courtlistener.com/opinion/[10214095](/patent/10214095)/flexiworld-technologies-inc-v-roku-inc/. I did not have search budget left to independently verify the current USPTO reel/frame chain of title, so treat this as a lead to confirm, not a settled conclusion.

Recommended next steps

  1. If you have a demand letter citing US 7,941,541, open with expiration. Expiration date 2023-02-15; identify the last date of any accused conduct and the pre-expiration damages window. This is likely dispositive of nuisance value.
  2. Demand the chain of title. Ask for the assignment from Flexiworld for the '541 and for any documents reflecting the 2013 Samsung transaction. The W.D. Tex. standing order (linked above) treated the '541 as among the four items assigned to Samsung — press that point.
  3. Do not budget for an IPR defense unless the patent is reasserted. There is no PTAB prior art to leverage, but also no estoppel; if a real dispute materializes, you have a clean slate. Note that a patent expired 2023-02-15 is generally not IPR-eligible in any practical sense.
  4. Mine the family IPRs for invalidity theories on any unexpired sibling. The written-description attack on the '903 in PGR2021-00112 (the "output system" improperly eliminating the information apparatus) and the mixed institution results in IPR2021-00713/-00714 are transferable reasoning if the demand letter cites a live continuation instead.
  5. Verify against primary sources before relying on this. The absence of proceedings is the USPTO ODP default plus my negative search results; I did not exhaustively query PTAB E2E by patent number. Confirm at PTAB E2E (https://ptacts.uspto.gov/ptabweb/) and https://patents.google.com/patent/US7941541/en.

Limits on this analysis: I could not retrieve the final written decisions for the family proceedings (IPR2021-00713/-00714/-00715, PGR2021-00111/-00112, IPR2022-01112/-01113/-01114, IPR2022-00775), any Federal Circuit appeals from them, or the current USPTO assignment record for the '541. I have not stated outcomes I could not verify.

Generated 10/1/2026, 3:24:43 PM

Ownership chain (2)

Asserters network →

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

  1. 2001-11-01 · Assignment

    William Ho Chang and Christina Ying LiuFlexiworld Technologies, Inc.

    founder/IP-vesting transfer

  2. ? · recorded 2013-03-13 · Assignment

    Flexiworld Technologies, Inc.Samsung Electronics Co., Ltd.

    acquisition

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll reconstruct the assignment record for US 7,941,541. Let me pull the recorded assignments and cross-reference ownership sources.

Let me pin down the specific reel/frame records and the correspondent of record.

I hit the search-step limit before I could pull the Assignment Center record page itself. Here is the reconstruction from everything assembled across the prior sections and the additional sources retrieved in this pass, with every gap flagged rather than filled.

Note on primary source. I was not able to load the USPTO Assignment Center record for application 10/016,223 / patent 7,941,541 directly — the searches that returned usable content surfaced assignment data through Google Patents' legal-events block and through litigation pleadings, not the Assignment Center's own reel/frame list. Reel/frame numbers and correspondent-of-record names for the '541's two assignments are therefore NOT VERIFIED. Family-member pleadings do recite reel/frames for sibling patents (see Assignment Timeline notes), which shows the format but does not establish the '541's own numbers.


Inventors

Inventor Employer at time of filing (2000–2001) Basis
William Ho Chang Flexiworld Technologies (founder & president). Immediately prior employer: Sharp Laboratories (Sharp's color copier/printer/digital-imaging programs; "Inventor of the Year," Sharp, 1999). Earlier: Amiable Technologies (NASDAQ: SVECF) as Chief Architect; Intergraph Corp. Corporate bio filed in PTAB papers (ptacts.uspto.gov petition doc, petitioner bio exhibit); Crunchbase person profile
Christina Ying Liu Not determinable — no retrieved source states her employer. Most likely Flexiworld (co-inventor and co-assignor on the original assignment), but I will not state that as fact. Google Patents inventorship field

Unusual-pattern check: The "all inventors leave the assignee within 12 months of filing, presaging a fire-sale" tell is not present on the evidence I have. Chang remained Flexiworld's president/CTO for years and is still publicly identified as founder; the original assignment was executed at filing (2001-11-01), not after a departure. No departure dates for Liu were found. Unclear/absent.


Original assignee

Flexiworld Technologies, Inc. — named on the issued patent. The Google Patents reassignment block renders the name "FLEXIWORD TECHNOLOGIES, INC." while the original-assignee field reads "Flexiworld Technologies Inc"; I reproduce both spellings and correct neither (per the strict-interpretation rule carried over from the earlier sections).

  • Primary line of business (as described pre-assertion): wireless application software for mobile devices / printers — marketed products were FlexiCore™ software and FlexiJet™ wireless products (flexiworld.com "About Us"). Also pursued Chinese-government and Taiwan chip-supplier partnerships.
  • Did it ship a product embodying the claims? No evidence of commercialization found. Flexiworld's own later complaints state it "has not made, offered for sale, sold, or imported a product that practices any of the Patents-in-Suit" and that it complied with §287 marking for its licensees — i.e., by litigation time it presented itself as a non-manufacturing licensor. Its website carried a 2005–2006 copyright with news entries ending Oct 2005 (Voicebot.ai report).
  • Current status: Not operating as a product company on the available evidence. Third-party reporting notes no current employees listed on LinkedIn and an unmaintained website, while the "Patents" tab continued to list patents through 2019. I found no bankruptcy or dissolution filing. Treat as "patent-monetization / licensing entity," status otherwise unconfirmed.

Assignment timeline

Two links are recorded against the '541. Reel/frame and correspondent for both are unretrieved — flagged inline.

2001-11-01 (executed) / recorded 2001-11-01 — Reel/Frame: NOT RETRIEVED

  • Conveyance: Assignment
  • Assignor: William Ho Chang and Christina Ying Liu (joint inventors)
  • Assignee: Flexiworld Technologies, Inc. (reassignment entry spelling: "FLEXIWORD TECHNOLOGIES, INC.")
  • Correspondent: NOT RETRIEVED. No recurrence conclusion possible.
  • Context: Original inventor-to-company assignment, executed the same day the application was filed — standard founder/IP-vesting transfer, not a fire-sale or NPE transfer.
  • Cross-check: For sibling patent '402 (US 7,609,402), the parallel inventor→Flexiworld assignment is pleaded as Reel/Frame 028733/0064; other siblings at 039816/0200 ('596) and 042385/0202 ('178). These corroborate that Flexiworld recorded inventor assignments around Reel 028733 and later, but do not supply the '541's number.

2013-03-13 (recorded) — execution date NOT RETRIEVED — Reel/Frame: NOT RETRIEVED

  • Conveyance: Assignment
  • Assignor: Flexiworld Technologies, Inc.
  • Assignee: Samsung Electronics Co., Ltd.
  • Correspondent: NOT RETRIEVED. No recurrence conclusion possible.
  • Context: Divestiture of the parent patent to a large operating company. The W.D. Tex. standing order construes the Samsung agreement §1.1.1 as assigning exactly four items — "the '541 Patent, the '958 Application, a continuation application, and a second continuation application." Under the sale, Samsung got the '541 and the '958 application; Flexiworld kept the later continuations it later asserted. This is a portfolio sale / license-and-settle-style transfer to an operating company, not a transfer to an asserter.
  • Cross-check: The same order quotes the agreement's assignment language conveying "the sole and entire right, title, and interest … in and to U.S. Patent No. 7,941,541 and U.S. patent application Serial No. 13/103,958" to Samsung (ECF 56-3; opinion at CourtListener ID 10214095).

No further assignments to the '541 appear in any source I retrieved. Google Patents still lists both "Flexiworld Technologies Inc" and "Samsung Electronics Co. Ltd" as current assignees — an inconsistency I report as-is. The court held the '541 was Samsung's and the continuations were not, which means the dual listing likely reflects a data artifact rather than a post-2013 reconveyance back to Flexiworld. I did not verify a Samsung→Flexiworld assignment and found none.


Timeline diagram

timeline
    title Ownership of US 7941541
    2000 : Provisional priority date Nov 1
    2001 : Application filed Nov 1
         : Assigned to Flexiworld
    2011 : Patent issued May 10
    2013 : Divested to Samsung Electronics
    2020 : Flexiworld sues Roku on siblings
    2022 : Court rules 541 went to Samsung
    2023 : Patent expired Feb 15

NPE / troll-pattern signals

# Signal Call Basis
1 Shell-entity transfer Not present Both recorded links go to a named operating company (Flexiworld → Samsung Electronics). No "IP/Holdings/Ventures" suffix LLC appears anywhere in the '541 chain. No registered-agent address or single-member LLC evidence retrieved.
2 Known asserter in the chain Present (prior assignee) Flexiworld Technologies is the original assignee and is a high-frequency plaintiff on this family (Unified Patents tracks IPRs against it; RPX tracks its suits). It is a non-practicing enforcer: its own complaints state it makes/sells no practicing product, and third-party reporting found no current employees. Caveat: Flexiworld is the prior, not current, owner of the '541; the current record owner is Samsung (not on any NPE list).
3 Repeat correspondent across the chain Unclear — not verifiable Correspondent-of-record names for both '541 recordings could not be retrieved. With only two links and no correspondent data, no recurrence finding is possible. Do not infer.
4 Cascading transfers (<24 mo through chained LLCs) Not present Only two transfers, 12 years apart (2001 → 2013), with no common-principal or common-address clustering.
5 Pre-litigation transfer (within 6 mo of first suit on this patent) Not present The Samsung transfer (recorded 2013) predates Flexiworld's 2020–2022 campaign by ~7 years, and the '541 was never asserted. No transfer timed to a '541 suit exists.
6 Bankruptcy fire-sale Not present No Chapter 7/11 proceeding for Flexiworld or Samsung found.
7 Privateering Not present Running the opposite direction: the NPE-style entity (Flexiworld) sold the parent patent to an operating company (Samsung). No operating company → NPE assertion-on-behalf-of transfer appears for the '541.
8 Defensive aggregator (anti-NPE) Not present Chain terminates at Samsung Electronics, a commercial operating company — not RPX, AST, LOT, Unified, or OIN.

Verdict

NPE — moderate confidence.

Justification: the '541 sits inside a family controlled by a proven non-practicing enforcer (signal #2, one strong signal). Flexiworld Technologies — the original assignee per the 2001-11-01 recording — is a high-frequency plaintiff that makes and sells no practicing product and admits non-marking, and it is the entity asserting the family against Sony, Roku, Amazon, Hisense, and others. That single verified strong signal supports moderate, not high, confidence, because this specific patent does not follow the classic NPE arc: the '541 was divested to Samsung Electronics in 2013 (per the W.D. Tex. standing order and Google Patents' reassignment record), never asserted, and expired 2023-02-15. So the honest reading is that the NPE/monetization pattern attaches to the family and its asserter, while the '541 itself is a divested, expired parent — a defendant should not expect the '541 to be asserted, but should expect the Flexiworld-controlled continuations to be.

Reel/frame and correspondent citations that would normally drive this verdict are missing — I could not retrieve them for either '541 recording, so this verdict rests on the asserter identity and the court-verified 2013 Samsung transfer, not on recording-level metadata.

Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search application 10/016,223 or patent 7,941,541); mirror index at https://assignment.uspto.gov/patent/index.html. Also confirm the Samsung assignment agreement language at Flexiworld Technologies, Inc. v. Roku Inc., No. 6:20-cv-00819-ADA (W.D. Tex.), ECF 56-3 and the standing order at ECF 198 (06/06/2022) — https://www.courtlistener.com/opinion/10214095/flexiworld-technologies-inc-v-roku-inc/.


Explicit gaps in this report

  1. No reel/frame numbers for either '541 assignment — not fabricated.
  2. No correspondent-of-record names — signal #3 therefore stays "unclear," not "present."
  3. Execution date of the Samsung assignment not retrieved (only the 2013-03-13 recording date from Google Patents).
  4. Christina Ying Liu's employer at filing unconfirmed.
  5. Current ownership end-state is internally inconsistent across sources (Google lists both Flexiworld and Samsung); the court found the '541 was Samsung's, which I treat as the better evidence but do not present as a settled current chain of title.
  6. The earlier "Patent summary"/"PTAB challenges" sections correctly found zero AIA proceedings on the '541 and a 2023-02-15 adjusted expiration — both consistent with this ownership reconstruction and reused, not re-derived, here.

Generated 10/1/2026, 3:44:21 PM

Prior art

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

✓ Generated

I'll research the prior art citations for US 7,941,541. Let me run targeted searches against the patent record and USPTO sources.

Let me target the patent's front-page citation list specifically.

Let me try to retrieve the front-page citation list directly.

Prior-Art Analysis — US 7,941,541 B2

Bottom line up front: I was not able to retrieve the patent's own front-page "References Cited" block (the examiner-cited U.S. patent documents / foreign documents / other publications) from either the authoritative full text provided in this task or from live searches. That block was not included in the fetched Google Patents text (which begins at the classification/description level), and my targeted searches for it returned either (a) the family-member citations that Google Patents lists for the '541, or (b) cited-reference tables belonging to other applications. I will not reconstruct an examiner's citation list from memory, because doing so would risk fabricating reference numbers and § 102 mappings. Below I give exactly what the record does establish, flag the uncertainty, and lay out the references that are genuinely part of the '541's prior-art neighborhood from the related adversarial record.


1. What the record does and does not show

Item Status
Front-page examiner citations for the '541 Not retrieved — cannot be verified from available sources
Google Patents "Patent Citations" for the '541 The citations that surface are Flexiworld's own family/co-pending applications (same inventors, same priority chain) — these are not § 102 prior art
Prior art actually litigated against this family (PTAB) Identified: Yamaguchi, Ikonen, Gu (see § 3)
§ 102 critical date 2000-11-01 (assumed priority; provisional 60/245,101). Any anticipating reference must predate this date

Why the "Patent Citations" list is not prior art here: Google Patents renders, on the '541 page, a "Patent Citations"/related-family table populated largely with Flexiworld's own co-pending applications (e.g., 10/003,594 "Controller for device-to-device pervasive digital output"; 10/000,732 "Manager for device-to-device pervasive digital output"; 10/016,630 "Method for device-to-device pervasive digital output") and its own continuations ('577, '524, '521, '802, '718, '516…). Those share the same inventors and priority date and are not available as § 102 prior art against the '541. If a claim chart treats them as "cited prior art," that is an error.


2. The subject matter a § 102 reference would have to disclose

To be relevant against the '541's claims, a reference must predate 2000-11-01 and disclose, at minimum:

  • a mobile/wireless information apparatus that discovers a nearby output device over a radio-frequency link (Bluetooth or IEEE 802.11);
  • receiving, over a direct wireless connection from the output device itself, device-dependent information/components (e.g., a driver / software component) — expressly without an external output server interposed (claim 54);
  • installing/executing the received component at the apparatus to generate output data; and
  • conforming the content into output data (optionally raster image processing) and delivering it over the direct link for rendering by the printer/display/audio engine.

The 2000-era novelty is the combination of driver-pull-from-device + direct short-range RF link + no pre-installed device-dependent driver. Any § 102 reference must attack those elements individually or in combination.


3. References actually on the adversarial record for this family

These are the prior-art references that Roku and Unified Patents relied on in the PTAB proceedings against sibling patents (the '064, '066, '114, '903). They were not asserted against the '541 itself, but they are the closest verified technical art for this disclosure:

Ref. (short name) Citation as it appears in the record Nature / date Prior-art role in the family Potential § 102 relevance to '541
Ikonen Referenced in Roku, Inc. v. Flexiworld Techs., IPR2021-00713/-00714/-00715 Pre-2000-11-01 reference Panel held its inquiry response is not a "broadcast or advertisement of availability"; Ground 2 (Ikonen + Gu) was instituted on claims 7, 8, 10 Would map to the '541's discovery limitations (claims 32–37 in the dependent set) — but only if the '541 claim language reads on an "announcement" model; the panel's construction cuts against that
Gu Same IPRs; combined with Ikonen in the instituted ground Pre-2000-11-01 reference Used as secondary reference in the instituted combination Would map to the receiving/installing a component or generating output data limitations
Yamaguchi IPR2021-00713/-00714/-00715 Pre-2000-11-01 reference Held not prior art (Ground 1 and 3 denied) Of limited anticipatory value given the denial

Caveat (important): I could not confirm the full citations, publication dates, or assignees for Yamaguchi, Ikonen, and Gu, and I could not confirm that any of them was examined against — or cited on the face of — the '541. Treat the "potential § 102 relevance" column as analytical inference, not a verified mapping. These references were mapped by petitioners to the sibling claims, and the '541 has a different claim set (independent claims 27 and 54, with claim 54 expressly requiring "not including an external output server").


4. Search-report references that surfaced — but belong to DIFFERENT applications (do not attribute to the '541)

Several "DOCUMENTS CONSIDERED TO BE RELEVANT" tables appeared in my searches. None of them is the '541's own search report. For completeness and to prevent number-confusion:

  • US 5,878,774 A (Tiedemann Jr. et al., 1999-02-16) and US 6,208,871 B1 (Krzystyniak et al., 2001-03-27) — from the ISR of WO 2003/010554 A1 / PCT/IB02/02817, a different application.
  • US 6,234,171 B1 (Springett et al., 2001-05-22), US 2010/0154805 A1 (Duffy et al., 2010-06-24), US 6,394,090 B1 (Chen et al., 2002-05-28) — from the ISR of WO 2017/066284 A1 / PCT/US2016/056586, a different application.
  • US 2003/0115095 A1 ("YAMUCHI" / Yamaguchi, 2003-06-19) — a "Y"-category reference in the ISR of WO 2015/109032 A1 (PCT/US2015/011482). The name similarity to the PTAB "Yamaguchi" is coincidental until confirmed; do not assume they are the same reference.

These are listed only to show what I found and to warn against importing them into a '541 chart.


5. Why the citation list is likely empty of strong § 102 art (context, not a finding)

The '541 issued in 2011 from an application filed 2001-11-01 with a 2000-11-01 priority. The family's clearance strategy was defensive: Flexiworld's later campaigns asserted continuations, and every PTAB challenge I located was filed against a sibling ('064, '066, '114, '903, '257, '073, '811, '233), never against the '541. Combined with the 2023-02-15 adjusted expiration, there was little incentive for anyone to litigate or IPR the '541. That is consistent with — but does not prove — a thin, non-dispositive prior-art record on the '541 itself.


6. Explicit uncertainties and required verification

  1. I did not obtain the '541's front-page "References Cited" list. Any list of "each patent citation for 7941541" I produced would be reconstructed, not verified. I decline to do that.
  2. No § 102 anticipation mapping is asserted here as established. The Yamaguchi/Ikonen/Gu relevance above is inferred from sibling-patent PTAB papers and is caveated accordingly.
  3. Reference numbers for Yamaguchi, Ikonen, and Gu were not confirmed. The prior analysis noted the Yamaguchi "not prior art" holding and the Ikonen + Gu institution; I could not pull the underlying exhibit numbers.
  4. Number-confusion caution (carried forward): "7908401-$.DID. OR US-7941541-$" is a PTAB exhibit/document-ID string, not a separate patent; US 7,944,577 and US 9,839,822 are unrelated family members, not the '541.

Recommended next step to close the gap: pull the granted patent's front page directly — from the USPTO Patent Public Search / PatentCenter record for application 10/016,223, or the patentimages PDF of the US 7,941,541 B2 grant. The "References Cited" block on that face page is the only authoritative source for the examiner citations and the "Primary Examiner" field, and it is where a claim-chart-grade § 102 analysis must start. I could not reach that document within this session's search budget, so I am reporting the limitation rather than filling it in.

Generated 10/1/2026, 3:44:06 PM

Obviousness

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

✓ Generated

I'll build on the prior sections, but first I need to pin down what prior art actually appears on this patent's face — the fetched full text includes only the "Prior art keywords" field, not a cited-references list. Let me search.

The front-page reference list still isn't surfacing. Let me try the Justia record and the patentimages front page directly.

Some family-level signal is coming through. Let me try to pull the '541's own cited references and the art applied against sibling patents in the PTAB, which is the most useful benchmark for an obviousness analysis.

Obviousness Analysis — U.S. Patent No. 7,941,541 ("the '541 patent") under 35 U.S.C. § 103

Prepared: 2026-04-26. Builds on the prior sections; does not repeat them.


0. Threshold caveats up front (these drive how much of this analysis is grade-A vs. provisional)

  1. The "Prior Art" list on the face of the '541 patent was not in the material I was given or could retrieve. The full text I was supplied contains only the Prior art keywords field ("output; wireless; information apparatus; output device; mobile information") and the specification's Background. It does not contain the front-page "(56) References Cited" list, the "Cited By" list, or the "Similar Documents" list. I ran searches aimed at the '541's own cited-reference list and did not recover it. Everything below therefore rests on prior art that I can document as being in this patent family's actual prior-art record — not on the '541's own face.
  2. Claim 1 text was never retrieved (flagged in the earlier claim section and still true). I therefore cannot give a complete § 103 analysis. The element mapping below is built on independent claims 27 and 54 and the dependents 32–53 recovered earlier. A grade-A opinion requires claim 1 and claims 2–26.
  3. Most reference descriptions below come from PTAB party filings (petitions and patent-owner responses), not from the references themselves. Party characterizations of a reference are not authoritative. Where I do not have a patent/publication number for a reference, I have not invented one.
  4. § 103 here is pre-AIA. Application 10/016,223 was filed 2001-11-01, priority 2000-11-01. The controlling art date is therefore ~2000-11-01 (with the pre-AIA § 102(a)/(b)/(e) framework). This matters because the art I can document was applied by third parties as pre-AIA § 103 art against other members of this same family claiming the same 2000-11-01 priority — which is strong circumstantial evidence it predates the '541's priority date.
  5. Practical posture: the '541 is "Expired – Lifetime" with adjusted expiration 2023-02-15 (per the record). An obviousness challenge today is only relevant to pre-expiration damages exposure or to the surviving/sibling continuations. I flag that rather than pretend this is a live-validity question.

1. Legal framework applied

  • Graham v. John Deere factors: scope/content of the prior art, differences between prior art and claims, PHOSITA level, secondary considerations.
  • KSR Int'l v. Teleflex (2007): a combination is obvious where the elements were known, the combination is of a "finite number of identified, predictable solutions," there is a design incentive or market demand, and there is a reasonable expectation of success. Motivation need not be in the references — it can come from the problem to be solved, from common sense, or from the nature of the problem.
  • MPEP § 2143 rationales I lean on here: (A) combining prior art elements according to known methods to yield predictable results; (B) simple substitution of one known element for another; (C) use of a known technique to improve a similar device in the same way; (D) applying a known technique to a known device ready for improvement; (F) obvious to try from a finite set of identified, predictable solutions.
  • Critical admissions rule: the '541 specification's own Background is prior art and an admission against interest (MPEP § 2129). This is the single most powerful tool available against these claims and I use it heavily below.

2. The prior-art record I can actually document

Each of these appears by name in PTAB papers involving this family (same 2000-11-01 priority chain). I give the record location, and flag where I lack a bibliographic number.

Reference (as named in the record) What the record says it discloses Where I found it Number verified?
Yamaguchi "System and method for printing electronic documents from a wireless device (e.g., a mobile phone)"; a wireless "interface box" that wirelessly communicates with users' wireless devices to receive electronic document information, and communicates with a printer over a wired interface; coin-operated, random-number handshake, browser UI. Express example: "a traveler at an airport who wishes to print a hard copy of a rental car confirmation web page." Used in Grounds 2/3 against the '064 patent. https://www.docketalarm.com/cases/PTAB/IPR2021-00714/ (POR and Ex. 1028 reply) No — name only
Kammer "Managing a wireless device … operating in discovery mode in a wireless network of devices, such as a Bluetooth network"; broadcast inquiry, inquiry response, discoverable/non-discoverable modes; discusses discovery power/message overhead. https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1553925](/patent/1553925)/... No — name only
Gu UPnP-based discovery/advertisement art ("Yamaguchi‑Gu grounds"; UPnP as a standard interoperability platform). Note the '064 specification itself names UPnP as a usable discovery protocol at 30:31-34. Same PTAB papers (Ex. 1028 reply declaration) No — name only
Ikonen Mobile station + link module communicating wirelessly; discovery/interaction between mobile station and link module; SDP/Bluetooth context. Best-fit art for the "mobile device pulls functionality from the nearby device" premise. https://www.docketalarm.com/cases/PTAB/IPR2021-00714/ (POR §B.i; Ex. 1028 ¶¶26-29) No — name only
Beck A service platform/framework: services advertised by multicasting service descriptors; "network 103 can be embodied, for example, by Bluetooth; the communication protocol is HTTP and TCP/IP with support for multicast messages" (3:52-54); "lazy loading of service software" where the software needed to use a service (interface, adapter, implementation proxy) is downloaded at runtime; security policies restricting access to services. Ex. 1028 (Roku reply declaration), IPR2021-00714 No — name only (column cite 3:52-54 only)
Saulpaugh "device discovery mechanisms that enable remote service calls, e.g., a cell phone detecting and using a remote printer"; discovery of networked devices and authentication of clients, then providing remote services (Ground 1a, IPR2022-01112, pre-AIA § 103). https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1549802](/patent/1549802)/ No — name only
Castell Combined with Saulpaugh (Ground 1b). Same No — name only
Putzolu Combined with Beck (Grounds 2b/2c). Same No — name only
Larsson Combined with Beck + Putzolu for claims 5, 13. Same No — name only
Bisdikian, "An Overview of the Bluetooth Wireless Technology" (2001) Bluetooth overview; "The SDP only provides information about services, it does not provide access to them." Ex. 1002 App. D, IPR2021-00714 reply Publication year given; no volume/page verified
The '541's own Background (admissions) Admitted state of the art: wired and wireless (radio/IR) links to output devices; IrDA, HomeRF, Bluetooth, IEEE 802.11, HiperLan2; network printing with print servers doing spool/queue/priority management; printer drivers downloadable from the network ("the driver of each networked printer may be stored in the network (for example, in an application server) and available for clients to download"); computing devices "having limited memory and storage capacity"; RIP executed in the information apparatus's driver/application for printers lacking a printer controller; device-dependent vs. device-independent driver split. The '541 specification itself (supplied full text) N/A — intrinsic

Name-confusion caution (in the spirit of the strict-identifier rule): "Chang, Intelligent Delivery and Acquisition of Digital Assets" (Ex. 1004 in a separate IPR on U.S. Pat. 8,554,196) is not William Ho Chang and is not this patent. Do not treat that Chang as the '541 inventor. Likewise the earlier caution that US 7,944,577 is not this patent still applies — it is a sibling that cites 7941541 on its face (per patents.justia.com/patent/11662918).


3. What the asserted independent claims require (condensed, from claims 27–54)

# Element Label
E1 RF/wireless discovery of output devices — either the apparatus broadcasts a request and devices respond, or devices advertise availability; output device may be a printer, display, projector, or audio device (claims 32–37; claim 27/54) Discovery
E2 Selecting an output device based at least partly on device-dependent attributes received over the RF channel (claim 54) Selection
E3 Establishing a direct RF wireless connection between mobile apparatus and selected device, expressly "not including an external output server" (claim 54) Direct link
E4 Receiving, over that direct connection, one or more components/information from the selected output device (or an output controller associated with it), including software code or a software application (claims 38–41) Component pull
E5 Installing and executing those received components at the mobile apparatus to drive the output device over the direct connection Install/execute
E6 Conforming the digital content into output data at the apparatus (RIP at the apparatus; optionally also at the output device) (claims 46–47) Local RIP
E7 Sending output data over the direct RF link for rendering; output data may be compressed; may require further processing in an output controller before reaching the device (claims 48–49, 52) Delivery
E8 Output data generated "without requiring a device-dependent output device driver specific to each output device" (claim 54 preamble) No-pre-installed-driver
E9 Radio link is Bluetooth and/or IEEE 802.11 (claim 53) Protocol

4. Element-by-element obviousness mapping

Element Primary reference(s) Secondary reference / rationale source
E1 Discovery over RF Kammer (Bluetooth inquiry/inquiry-response, discoverable modes) — expressly a "discovery mode" reference; Gu (UPnP advertisement/discovery); Saulpaugh (device discovery) '541 Background admission: Bluetooth, HomeRF, IEEE 802.11, IrDA, and discovery protocols "Bluetooth, HAVi, Jini, Salutation, Service Location Protocol, and Universal Plug-and-play" are all named in the spec. This is an admission that service discovery was a standardized, known solution space → MPEP 2143(F), "finite number of identified, predictable solutions."
E2 Select on device-dependent attributes Gu (device/service descriptors advertised before selection); Beck (multicast service descriptors) Saulpaugh (discovery of networked devices + client authentication before service call)
E3 Direct RF link, no external output server Kammer (direct Bluetooth device-to-device inquiry/page); Ikonen (mobile station ↔ link module direct wireless) '541 Background admission that a printer may be linked "directly" by radio/IR without any network; KSR rationale (B)/(C): eliminating an intermediary where the intermediary's function is unchanged is obvious. This is the element where Yamaguchi is weakest, because Yamaguchi's interface box is a separate box with a wired link to the printer.
E4 Pull component/information from the output device Beck — the reference that matters most: "the software necessary to use a service (e.g., an interface, adapter, and implementation proxy) may be downloaded at runtime"; service software is fetched from the service side Ikonen (mobile station/services on the link module); '541 Background admission that drivers can be downloaded from the network rather than pre-installed — the only remaining difference is the location of the download source (local device vs. network server), which is a predictable substitution.
E5 Install & execute at the apparatus Beck ("lazy loading"; downloaded interface/adapter/implementation proxy used by the requesting device) Motivation: the '541's own admission that mobile information devices "usually ha[ve] limited memory and storage capacity" — exactly the rationale Roku's declarant gave for why Beck's runtime loading suit mobile stations.
E6 RIP at the apparatus The '541's own Background: "RIP can be integrated within the output manager 308 or application software 302 in the information apparatus 100"; "the rasterization process may occur in the information apparatus 100 that outputs to such a printer" This element is an admission of prior art from the applicant's own mouth. Combined with Saulpaugh/Yamaguchi driver-side processing.
E7 Send to engine / via output controller Yamaguchi (device sends document data to the print device/interface box, which delivers to the printer); Saulpaugh (remote service call to a printer) Putzolu (job/service management) for the output-controller buffering/queue aspect of claim 49
E8 No device-specific pre-installed driver Beck (runtime download replaces pre-installation) + '541 Background admission (drivers are device-dependent and cumbersome to install/configure per printer, a stated problem) Motivation: the '541's stated "undesirable and discouraging process" of installing a driver at every location is simultaneously the problem statement and the reason a POSITA would adopt Beck's runtime-loading solution.
E9 Bluetooth / IEEE 802.11 Bisdikian (Bluetooth overview); '541 Background admission listing Bluetooth and IEEE 802.11 by name Gu/UPnP and Kammer both operate over these links

5. Proposed § 103 grounds, with explicit motivations

Ground A — Yamaguchi in view of Kammer (and optionally Gu)

Covers: E1, E2, E6, E7; the general "wireless mobile device → nearby printer" framework.
Why a POSITA would combine: Yamaguchi's stated problem is verbatim the '541's stated problem — a mobile traveler needing a hard copy of a document at a location with no printer, and no easy way to generate one. The '541's Background repeats the same airport/email scenario as its motivating use case. Kammer supplies the standardized mechanism (Bluetooth inquiry/inquiry-response, discoverable mode) by which Yamaguchi's mobile device would locate the interface box; Gu supplies UPnP-style advertisement of devices/services with attributes. KSR: this is use of a known technique (standard RF discovery) to improve a similar device in the same way, with predictable results. Note the '541 specification itself lists Bluetooth and UPnP as the known usable protocols.
Weak point: claim 54's "not including an external output server." Yamaguchi's interface box is an intermediary, so Ground A alone does not reach E3 as literally recited; it must be combined with Ground B/C art or with the KSR "eliminate the intermediary" rationale plus the '541's own admission that direct radio/IR links to output devices were known.

Ground B — Ikonen in view of Beck, further in view of Kammer/Bisdikian (the strongest combination)

Covers: E1, E3, E4, E5, E8, E9.
Why a POSITA would combine:

  • Ikonen supplies the architecture the claims assume: a mobile station that discovers and interacts directly over RF with a local module that fronts the device — i.e., the local device, not a network server, is the source of capability.
  • Beck supplies the exact missing step of the claims: rather than pre-installing software, the requesting device downloads the service software it needs (interface, adapter, implementation proxy) at runtime from the service side, over a Bluetooth network with HTTP/TCP-IP multicast.
  • Kammer/Bisdikian supply the enabling Bluetooth discovery and service-discovery details, and Beck's own multicasting of service descriptors is confined to devices on the Bluetooth network — which the record shows is why the discovery is, in substance, physical-proximity/RF-based.
    Motivation that is unusually well grounded: both Beck's own stated advantages and the '541's express admission that mobile information devices "usually ha[ve] limited memory and storage capacity" point the same way — download-on-demand instead of pre-install. That is a textbook KSR design incentive, and it is sourced from the patent-in-suit, which blunts any hindsight objection.
    Weak point: the claims add "without requiring a device-dependent output device driver specific to each output device." Expect the patent owner to argue Beck teaches software for a service, not a printer driver, and Ikonen's link module is not a printer. Given claim 54 recites "information or component" broadly (not "printer driver"), this looks like a surmountable argument, but it is the place to expect a fight.

Ground C — Saulpaugh (optionally with Castell, and with Putzolu)

Covers: E1, E2, E3, E7 — and it is the cleanest single-reference art for the "cell phone detecting and using a remote printer" fact pattern, with client authentication.
Why combine: Saulpaugh's device discovery + remote service call + client authentication is the generic distributed-computing solution to "let a client use a device it has never seen." KSR rationale (C)/(D): applying this known discovery-and-remote-service-call technique to printers and other output devices (the '541's own list: printers, fax, copiers, displays, projectors, audio) is the use of a known technique on a known device ready for improvement. Castell and Putzolu add authentication/security and job-serving for the dependent claims.
Value: Saulpaugh is a strong § 102/§ 103 reference against any surviving sibling claim that emphasizes "discovering networked devices and authenticating clients, then providing remote services."

Ground D — Beck in view of Putzolu, further in view of Larsson

Covers: the dependent-claim layer — job/service management, queue/spooling, and the claim-49 "output data further processed in an output controller" element. Putzolu and Larsson were specifically applied to the '073 patent's dependent claims as pre-AIA § 103 art, so their status as pre-2000-11-01 art is at least as well-supported as the primary references.

Ground E — Yamaguchi in view of Beck

Covers: E1–E2, E4–E8 in one combination.
Why combine: Yamaguchi supplies the wireless mobile printing with payment scenario; Beck supplies the mechanism by which a mobile device that lacks the necessary software obtains it on the spot from the local service provider. The motivation is the '541's own stated pain point — the "multi-step process for each printer," the "degree of complexity and work to end-users," and the admission that a mobile user "may not want to be bothered with looking for a driver or downloading it and installing it just to print out one page." That sentence is, functionally, a motivation statement for Ground E written by the patentee.


6. Non-obviousness counterarguments (and how they fare)

Patent owner's likely argument Assessment
"No motivation to remove the server/interface box." Yamaguchi's interface box and Beck's platform are intermediaries; claim 54 excludes an external output server. Partially effective. KSR's "eliminating a step" and "substitution of known element" rationales apply where function is unchanged, and the '541 Background admits direct radio/IR links to printers were known. But this is the strongest non-obviousness argument available.
"Beck teaches service software, not printer drivers." Weak-to-moderate. Claim 54 recites "information or component," not "printer driver"; claim 41 recites "software code or software application," not "driver." The preamble's "without requiring a device-dependent driver" is a capability statement, and Beck's runtime-loading of device-specific proxies maps onto it.
"Hindsight combination." Blunted. Almost all of the motivation can be drawn from the '541's own Background admissions (limited memory, per-printer driver installation burden, network download of drivers, RIP in the device driver, Bluetooth/802.11/UPnP/HAVi/Jini/Salutation/SLP as known). Motivation from the patent's own admission is the cleanest answer to hindsight.
"Unexpected results / secondary considerations." I have no evidence of secondary considerations in the record I reviewed — no licensing-due-to-validity, no Nexus evidence, no commercial-success evidence tied to the claims. The 2013 Samsung assignment and the family licensing activity were treated in the W.D. Tex. standing order as title transactions, not as validity indicia. I cannot support a secondary-considerations argument on this record, and I won't manufacture one.
"The '541's claims are broader/different from the siblings attacked at the PTAB." True and material. The PTAB art was aimed at the '064, '066, '073, '811, '233, '257, '903 claims. No proceeding has ever construed a '541 claim. Whether these grounds land on the '541 depends entirely on claim 1 and claims 2–26, which I never retrieved.

7. Bottom line

  • There is a strong, documentable § 103 case against the verified independent claims 27 and 54, built on combinations that third parties already asserted, as pre-AIA § 103 grounds, against same-priority family members: principally Ikonen + Beck (+ Kammer/Bisdikian) for the wireless-discovery / direct-link / runtime-download / no-pre-installed-driver core, and Yamaguchi + Kammer (+ Gu) for the mobile-device-prints-at-nearby-printer framework. Saulpaugh (+ Castell, + Putzolu) is a clean alternative primary reference for the discovery-and-remote-service-call elements.
  • The motivation analysis is unusually clean because the '541 specification itself supplies most of it: limited mobile memory, the burden of per-printer driver installation, network-based driver download, RIP in the device driver, and Bluetooth/802.11/UPnP/Jini/SLP/HAVi as known protocols. That is admissible prior art and an admission.
  • The weakest element for the challenger is claim 54's "not including an external output server" (and, secondarily, the "without requiring a device-dependent driver" preamble). Everything else maps well.
  • This is a provisional opinion, not a claim chart. I lacked (a) the '541's own cited-reference list, (b) claim 1 and claims 2–26, (c) the reference documents themselves, and (d) patent/publication numbers for most references. I have deliberately not assigned numbers to Yamaguchi, Ikonen, Beck, Kammer, Gu, Saulpaugh, Castell, Putzolu, or Larsson because I could not verify them; any numbers produced for those references should be treated as unverified until pulled from the exhibit lists.
  • Practical note: the '541's 2023-02-15 adjusted expiration means an invalidity theory has little forward-looking value. The higher-value use of this art set is against the unexpired siblings — where, per the prior sections, the Roku IPRs produced mixed results on the same specification.

Verification steps to convert this into a claim chart: (1) pull the granted '541 claim sheet (all claims 1–54) and the front-page "(56) References Cited" list from the patentimages PDF of the grant or USPTO Patent Public Search for application 10/016,223; (2) pull the exhibit lists from IPR2021-00713/-00714/-00715, IPR2022-01112/-01113/-01114, IPR2022-00775, and PGR2021-00111/-00112 on PTAB E2E (https://ptacts.uspto.gov/ptabweb/) to get the certified bibliographic data for Yamaguchi, Ikonen, Beck, Kammer, Gu, Saulpaugh, Castell, Putzolu, and Larsson; (3) confirm each reference's actual publication/filing date against a 2000-11-01 critical date under pre-AIA § 102.

Generated 10/1/2026, 3:44:40 PM

Extensions

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