US 8024752

I'll search for this specific patent number and any related litigation.

US 8,024,752 B2 — Summary

Search note: I searched for this exact patent number and for any 2026 Federal Circuit activity tied to it. The patent-number searches returned only the patent's own records (Google Patents / Justia). I found no CAFC appeal, IPR, or district-court litigation naming US 8,024,752. I cannot rule out an unrelated docket I couldn't surface — public web search is not a substitute for PACER/Docket Navigator — so treat the "no litigation" statement as absence of found evidence, not an authoritative negative. (Also note: a UK application number "8024752" and other 7-digit numbers appear in results but are unrelated; I excluded them.)

Bibliographic data

Chain of title: Thomson Licensing S.A. → (change of name) Thomson Licensing → Thomson Licensing DTV (eff. 2016‑01‑04) → InterDigital Madison Patent Holdings (eff. 2018‑07‑23, recorded 2018‑08‑10).

Status nuance / uncertainty: Google's front-page shows both "Expired – Fee Related, expires 2024‑11‑30" and a lapse event: maintenance-fee reminder mailed 2023‑05‑08, "Lapsed for failure to pay maintenance fees" 2023‑10‑23 with effective date 2023‑09‑20. Those two dates are internally inconsistent, so I'd treat the precise expiration date as uncertain; what is clear is that the patent lapsed for non-payment of the 12th-year maintenance fee in 2023. (The 8th-year fee was paid 2019‑02‑22.)

Filing-date nuance: US 10/482,085 is the U.S. national-stage entry of the PCT, but Google lists the filing date as 2001‑06‑29, i.e., the international filing date. The actual §371 national-stage date is not stated in the fetched record (one assignment entry is dated 2003‑12‑22). Treat the true U.S. filing date as uncertain.

Abstract (verbatim)

A method for managing access to a signal representative of an event of a service provider by permitting a subscriber of the service provider to view an event for which the subscriber is not authorized for a specified time period; and transmitting at least one authorization code for the event to the subscriber during the specified time period.

Technical gist

The patent addresses the problem of "homing" in pay-TV conditional-access systems — set-top boxes/DTVs must sit powered-up, tuned to a channel, to receive their Entitlement Management Messages (EMMs) via a repeating data carousel. Long carousel cycles (the spec gives a ~25-minute carousel for ~187,500 users in a hypothetical Indianapolis area) mean a subscriber who paid but didn't watch may not have received their EMM for the new authorization period, and the always-on homing costs standby power (~10–15 W → ~$5.84/yr). The disclosed approach: when a paid subscriber tunes to a channel for which their device currently lacks a valid authorization code, the device is allowed a limited "unconfirmed viewing time" (an authorization acquisition period) long enough to catch the EMM off the carousel — with the authorization transmitted automatically, not in response to a device request.

Independent claims — plain-language overview

Claim 1 — method (device side + headend). Allow an access device to process the signal and view an event even though it lacks the event's authorization code, for an "authorization acquisition period" that is independent of the signal's content, giving a set amount of unconfirmed viewing time in which to acquire the code. The content must have been purchased before this enabling. At least one authorization code for the current authorization period is transmitted to the device during that period, letting it keep accessing beyond the period. The transmission is automatic and not in response to a device request.

Claim 6 — system. Same core idea, framed as: a device with a smart card, plus "means for transmitting," where the device is enabled to view a channel it lacks the code for during an authorization acquisition period independent of content; the transmitting means sends codes for content purchased before the acquisition period; and the transmission is automatic, not request-driven.

Claim 7 — system. A service provider plus a digital device whose software enables it to access a channel it lacks a code for, for an authorization acquisition period independent of content, giving unconfirmed viewing time; access to the channel has been purchased before the device accesses the signal; and the device does not send a request for authorization during the period.

Claim 10 — method (with boundary condition). Set an authorization acquisition period; enable access to the uncoded channel for that period independent of content (purchase predates enabling), giving the subscriber unconfirmed viewing time; inhibit access if the code isn't received during the period; continue access if it is received; device sends no authorization request during the period.

Claim 12 — digital device. A conditional-access digital device receiving a channel signal from a program service provider, with software enabling access to a channel whose code it lacks, for an authorization acquisition period independent of content, providing unconfirmed viewing time; access was pre-purchased; device sends no authorization request during the period.

Claim 14 — system (with scrambling emphasis). A transmitter sends scrambled signal(s) plus authorization code(s), including codes for content purchased before the acquisition period; a receiver descrambles and is enabled to output the signal in the clear for an authorization acquisition period independent of content before the code arrives, giving unconfirmed viewing time; receiver sends no authorization request during the period.

Claim 15 — method (receive-side mirror of claim 1). Enable access to the uncoded channel for an authorization acquisition period independent of content (pre-purchased), giving unconfirmed viewing time; receive at least one code for the current authorization period during that period so access continues beyond it; device sends no authorization request during the period.

Notable dependent claims

• 2 — the authorization code is an Entitlement Management Message (EMM).
• 3 — code is transmitted to a smart card in the access device.
• 4 / 9 / 11 — the authorization acquisition period is ≥ the carousel rate of the data carousel carrying the code.
• 5 — at least two codes on separate channels, both authorizing the same event.
• 8 / 13 — access is discontinued after the period expires unless the current code is received.
• 16 — the enabling step applies where the device had previously received a previous authorization code for a previous authorization period.

Key limitations worth flagging

The apparent points of novelty (relevant to any validity/scope analysis) are: (1) the acquisition period being independent of the signal's content (i.e., not content-driven); (2) purchase already made prior to the grace window; (3) no request from the device — the authorization is delivered automatically; and (4) the grace period sized to the carousel rate.

Sources

• Google Patents: https://patents.google.com/patent/US8024752/en
• Justia (claims text): https://patents.justia.com/patent/8024752
• Family/publication US 2004/0210924 A1: https://patents.google.com/patent/US20040210924

No CAFC 2026 docket or PTAB/litigation record for US 8,024,752 was located in the searches performed.

I'll research litigation involving US Patent 8,024,752. Let me search multiple sources.

Let me search more targeted litigation databases.

Litigation Search Results — US Patent 8,024,752

Bottom line: No litigation involving US Patent 8,024,752 was found.

I searched for the specific number 8,024,752 (and the string "8024752") across patent‑litigation‑oriented sources, including CourtListener/RECAP dockets, PACER‑derived dockets (Justia, PacerMonitor), Unified Patents' litigation portal, and general web sources covering InterDigital–Thomson patent disputes. I could not identify any case — district court, ITC, PTAB, or appellate — in which US 8,024,752 was asserted, challenged, or otherwise at issue.

Because the strict rule requires literal interpretation of the identifier, I want to flag what the searches did return so nothing is mistaken for a hit:

None of these involves the subject patent.

Important context on the patent itself

Google Patents (the authoritative text provided) shows the following, which is consistent with the absence of litigation:

• Title: "Method and apparatus for permitting unconfirmed viewing time with addressable pay TV"
• Owner chain: Thomson Licensing S.A. → Thomson Licensing → Thomson Licensing DTV → InterDigital Madison Patent Holdings SAS (current assignee per the record)
• Status: Expired – Fee Related — the record states the patent "expired 2024‑11‑30," with a lapse‑for‑failure‑to‑pay entry dated 2023‑10‑23 and an effective expiration of 2023‑09‑20 for nonpayment of maintenance fees.
• No "Litigation" entries appear in the Google Patents record; only "Cited By" and "Families Citing" references (mostly unrelated later patents).

A patent that lapsed for nonpayment of maintenance fees in 2023 and whose asserted‑patent history is not reflected in any of the major docket databases is consistent with the patent never having been asserted in litigation.

Caveat on confidence

I could not run an exhaustive subscription‑database query (e.g., full Docket Navigator, Lex Machina, or a complete PACER sweep) within the searches performed. My conclusion is based on:

1. No matching docket found in CourtListener/RECAP, Justia, PacerMonitor, or Unified Patents' portal for the literal number 8,024,752; and
2. No litigation reference on the Google Patents page for US 8,024,752.

On that basis, the most accurate answer is: no known litigation involving US Patent 8,024,752. If a definitive negative is required for a legal opinion or freedom‑to‑operate analysis, I would recommend a confirmatory search of a comprehensive litigation database (Docket Navigator, Lex Machina) using the exact patent number, plus a PACER docket‑text search, since those tools index the full text of every complaint and would catch any assertion I may not have surfaced here.

Nothing in this response should be treated as a legal conclusion. It reflects the search results available as of the date of the query.

I'll verify the ODP's "no proceedings" result against the public record before drafting.

Let me run a couple more targeted checks before concluding.

PTAB Proceedings — U.S. Patent No. 8,024,752 B2

Patent: Method and apparatus for permitting unconfirmed viewing time with addressable pay TV
Inventor: David Jay Duffield · App. No. 10/482,085 · PCT PCT/US01/20844
Filed / Priority: 2001-06-29 · Granted: 2011-09-20 · Claims: 16
Assignee chain: Thomson Licensing S.A. → Thomson Licensing → Thomson Licensing DTV → InterDigital Madison Patent Holdings SAS
Current legal status (per source of record): Expired – Fee Related

Canonical source note: This analysis is built on the structured "PTAB proceedings on file" block (USPTO Open Data Portal). That block reports: "The USPTO ODP API returns no AIA trial proceedings for this patent as of the most recent ingest." I treated that as the default and then attempted to falsify it with independent web searches. I found no PTAB proceeding of any type — no IPR, PGR, CBM, or derivation — naming U.S. Patent No. 8,024,752. No proceeding numbers appear below because none exist to report. I have not invented any.

Proceedings overview

Total proceedings: 0. Breakdown: 0 active · 0 with claims invalidated · 0 with claims sustained · 0 settled · 0 institutions denied.

Bottom-line defensive posture: this is not a "no PTAB activity — proceed with caution" situation, and it is not a "the patent is hardened" situation either. It is a "the patent is dead" situation. Separately from the absence of PTAB activity, the maintenance record shows the patent expired on 2023-09-20 for failure to pay the 12-year maintenance fee (lapse entered 2023-10-23; "FP – Lapsed due to failure to pay maintenance fee," effective 20230920). A defendant receiving an assertion letter citing US 8,024,752 today is, on this record, facing a lapsed patent — a threshold defense that dwarfs any art-based attack. The absence of IPRs is consistent with that: nobody files a $40k+ IPR petition against a patent no one is credibly enforcing.

Proceedings

(none)

There are no AIA trial proceedings to itemize. For completeness, the template fields resolve as follows:

Why the null result is legally coherent, not just an indexing gap:

• PGR was statutorily unavailable. Post-Grant Review under 35 U.S.C. § 321 applies only to patents with an effective filing date on or after 2012-03-16. The '752 patent's effective filing date is 2001-06-29 (PCT filing, no earlier priority claimed). PGR could never have been filed against it — its absence is a matter of law, not of petitioner choice.
• CBM had a window (2012-09-16 → 2020-09-16) and was never invoked. The '752 claims (billing/authorization for pay-TV events) sit at least arguably within the "financial product or service" prong of the transitional covered-business-method definition, though the "technological invention" exception is a real and probably winning counter for a conditional-access/smart-card architecture of this type. Either way, no CBM petition was ever filed, and the CBM program sunset on 2020-09-16, so that door is closed permanently.
• IPR was always available and was never used. The '752 patent issued 2011-09-20, so IPR under § 311 was available from issuance onward. Nothing was filed.

Independent verification attempted (2026-10-01): targeted searches for the patent number against IPR/PGR/CBM docketing, for the assignee (InterDigital Madison Patent Holdings) PTAB activity, and for a Unified Patents–style defensive challenge. Results:

• A PTAB-tracker profile for InterDigital Madison lists only two PTAB matters, both filed 2026 and both on unrelated patents — IPR2026-00252 (Dolby v. InterDigital Madison, filed 2026-02-09) and IPR2026-00195 (Amazon.com v. InterDigital Madison, filed 2026-01-09). Neither is directed to the '752 patent.
• No Unified Patents (or other defensive aggregator) petition naming the '752 patent surfaced.
• No Federal Circuit appeal stemming from a '752 PTAB proceeding surfaced.

Caveat, stated plainly: a negative search result is weaker evidence than a positive one. My searches are not a substitute for a PTAB E2E / USPTO PatentCenter party-and-patent query run against the live system, and a very recently filed petition could be absent from third-party indexes. Nothing I found contradicts the ODP's "no proceedings" answer, so the ODP answer stands.

Strategic summary

Claim status: 16 of 16 claims UNTESTED — for the trivial reason that no tribunal has ever tested them. No claim of the '752 patent has been canceled, confirmed, or construed in any AIA trial. There is no narrowing to report, no surviving-claim list to assemble, and no FWD to characterize. The claims are exactly as they issued on 2011-09-20, subject only to whatever the file history and any district-court construction may say. The practical point for a defendant is that the patent's claims were never the battleground — the patent's term was. It lapsed on 2023-09-20 before any invalidity challenge was ever mounted.

Estoppel landscape: there is nothing to estop and nothing estopped. Section 315(e)(2) estoppel attaches only after a final written decision under § 318(a). With zero FWDs, no petitioner, real party in interest, or privy is barred from raising anything — and correspondingly, no defendant enjoys any estoppel-derived advantage from a prior petitioner's work product. Every prior-art ground, whether or not it was ever considered by the Examiner, remains fully available in district court or at the ITC. The complete list of references cited on the face of the patent (15 entries) is the natural starting point: US 4,947,244 (On Command Video); WO 96/006504 (Thomson Consumer Electronics); US 6,157,719 (Scientific-Atlanta); WO 98/043425 and WO 98/043428 (Canal+); US 6,177,930 (IBM); WO 99/007150 (Scientific-Atlanta); JP 2000-101984 (Hitachi); US 7,310,810 (Sony); US 6,973,662 (Starz Entertainment); US 2002/0120928 / WO 01/30082 (Irdeto Access); US 2007/0124753 (Yamaguchi); US 2002/0112234 (Bacon); US 7,069,579 (OpenTV); and US 2003/0005435 (Nelger). Note that the Nelger application (US 2003/0005435 A1) shares the same 2001-06-29 priority date as the '752 patent and was itself cited — worth a § 102(e)/§ 102(g)-style look if you are litigating priority.

Pattern signals: none of the usual ones. No serial petitioner (no one filed a second or third petition against this patent because no one filed a first). No Patent Owner appeal activity — there is no adverse PTAB decision for InterDigital Madison to appeal, so its aggressive PTAB appellate posture in other matters (the '877, '268, and '244 families) tells you nothing about this patent. No defensive aggregator in the chain. The relevant pattern signal is the opposite one: this patent was never worth attacking. Its closest EP family member, EP 1 415 471 B1, granted 2005-09-07 and appears in the '752 patent's "similar documents" set; I did not locate a European opposition outcome for it and will not speculate.

One flag on the record itself: the source page carries both "Expired – Fee Related" (lapse 2023-10-23, effective 2023-09-20) and an "Adjusted expiration" entry of 2024-11-30. Those are not reconcilable as a single expiration date. The 2024-11-30 figure reads as the nominal patent-term-adjusted date, while the 2023-09-20 date is the actual termination for nonpayment. Treat 2023-09-20 as the operative expiration unless and until you confirm in USPTO PatentCenter that the 12-year fee was reinstated. I did not find evidence of reinstatement.

Recommended next steps

If you are a defendant and a demand letter cites US 8,024,752:

1. Lead with the lapse, not with invalidity. The maintenance record shows expiration on 2023-09-20 for failure to pay the 12-year maintenance fee, with the lapse docketed 2023-10-23 ("PATENT EXPIRED FOR FAILURE TO PAY MAINTENANCE FEES," 37 C.F.R. § 1.362). Verify the current fee status at USPTO PatentCenter for application 10/482,085 — a petition to accept an unintentionally delayed payment under § 1.378 is theoretically possible but no evidence of one surfaced. If the patent is confirmed lapsed, any infringement theory covering post-2023-09-20 conduct fails at the threshold, and damages are confined at most to the pre-expiration window.
2. There is no FWD to quote. The instructions ask that a defendant with invalidated claims "link explicitly to the FWD and quote the disposition." No such document exists for this patent, and I will not synthesize one. The claims are intact and untested. If you need an invalidity position, you are building it from scratch — and the 15 cited references plus the co-priority Nelger application are the place to start.
3. Check the priority date before you brief validity. The '752 patent claims benefit of PCT/US01/20844 filed 2001-06-29, and cites US 2003/0005435 (Nelger) — same filing date, same technical space, different owner lineage. Confirm whether Nelger is § 102(e) art and whether it discloses the "authorization acquisition period independent of the signal's content" limitation that does the heavy lifting in claims 1, 6, 7, 10, 12, 14, and 15.
4. Do not spend money distinguishing the pre-AIA vs. AIA regime. Effective filing date 2001-06-29 means pre-AIA §§ 102/103 govern throughout, and PGR was never available. Frame all invalidity contentions accordingly.
5. If the patent is somehow still live, decide on an IPR immediately. There is no estoppel to worry about, no FWD clock running, and no prior petitioner's art to reuse — a clean slate. But note the filing-date math: for an IPR petition, § 315(b)'s one-year bar runs from service of a complaint alleging infringement, so calendar the complaint-service date the moment one lands.

If no proceeding has been filed and you are monitoring rather than defending: confirm the null result directly rather than relying on this memo. Run the patent number through PTAB E2E / the USPTO PTAB Center (https://ptacts.uspto.gov/ptabweb/) and the CourtListener docket search (https://www.courtlistener.com/?q=%228%2C024%2C752%22) to capture anything filed after the ODP ingest. A null result on a patent that lapsed in 2023 is expected; a new petition on a lapsed patent would be extraordinary and worth understanding before you react to it.

Source links

• US 8,024,752 B2 on Google Patents — full text, claim set (16 claims), 15 cited references, assignment and legal-events history used above
• USPTO PTAB Center / E2E — canonical docket for AIA trials
• USPTO PatentCenter — maintenance-fee and expiration status for App. No. 10/482,085
• CourtListener — Federal Circuit and district-court docket search

Nothing in this memo rests on a proceeding number, judge panel, FWD, or appeal that I could not locate in the record. Where the record is silent — which is everywhere in the PTAB docket for this patent — I have said so rather than filling the gap.

I'll research this patent's ownership chain using the available tools, then build the report.

Let me search for the specific assignment records and correspondent details.

I could not reach the USPTO Assignment Center directly in this session (web-fetch/step limits), so the reconstruction below is grounded in the Google Patents legal-events feed for US8024752 (which mirrors the Assignment Center reel/frame entries), cross-checked against InterDigital's SEC-filed 10-Ks and press releases, IPqwery/onscope/INPI ownership records, and Dutch (RVO) and Vietnamese (IP Vietnam) register entries that show the same chain transferring in other jurisdictions. Where a field was not retrievable, I say so rather than guess.

Inventors

• David Jay Duffield — sole named inventor. The application was filed by Thomson Licensing S.A. and the inventor's rights were assigned to Thomson Licensing S.A. under an assignment executed 2001-07-17 (recorded 2003-12-22), which is the ordinary "employee inventor → employer patent-holding arm" pattern. His specific job title/employer unit at filing is not determinable from the sources consulted, but the 2001-07-17 assignment dates 18 days after the 2001-06-29 PCT filing, so he was working for the Thomson (Thomson Multimedia) group at the time.
• No inventor-departure pattern can be assessed: this is a single-inventor patent, so the "all inventors left within 12 months" tell is not applicable. I found no evidence of Duffield's tenure or departure.

Priority/family: PCT/US2001/020844 filed 2001-06-29, published as WO2003003740A1; US national-phase app. 10/482,085; EP family member EP1415471B1 ("Method and apparatus for permitting unconfirmed viewing time with addressable pay TV").

Original assignee

Thomson Licensing S.A. (France) — the patent-holding/licensing subsidiary of Thomson Multimedia (renamed Thomson in 2002, then Technicolor in 2010). This was an operating consumer-electronics and media-technology group (television sets, set-top boxes, the RCA/GE consumer-electronics business, plus a large licensing arm).

• Did they ship a product embodying the claims? Not confirmed. The group's STB/DTV and conditional-access business is squarely in the same domain as the claims (addressable pay-TV / unconfirmed viewing window), but I found no specific product evidence showing a Thomson/Technicolor implementation of the '752 claims. Treat this as domain-aligned but unverified.
• Primary line of business: consumer electronics + technology licensing.
• Current status: the group substantially exited patent licensing via the July 2018 sale of its patent licensing business to InterDigital; Technicolor SA later underwent significant corporate restructuring. I cannot confirm the current legal status with high confidence and flag that a status check is warranted (press reports of French insolvency/restructuring proceedings exist, but I did not verify this to a citable primary record; do not rely on it).

Assignment timeline

Four assignments are recorded (all surfaced on the Google Patents legal-events feed; the same transfers are corroborated in the NL and VN registers). Correspondent of record could not be retrieved for any reel/frame — the Google Patents events expose the Reel/Frame and the free-format text but not the recording attorney/agent, and I could not open the Assignment Center records in this session. I did not fabricate correspondent names.

1. 2001-07-17 (executed) / recorded 2003-12-22 — Reel 015431/0707

   • Conveyance: Assignment
   • Assignor: Duffield, David Jay
   • Assignee: Thomson Licensing, S.A. (France)
   • Correspondent: not retrievable from source (manual Assignment Center lookup required)
   • Context: first assignment — inventor's rights to his employer's patent-holding arm (ordinary employment assignment).

2. 2010-05-05 (effective) / recorded 2017-04-21 — Reel 042303/0268

   • Conveyance: Change of Name
   • Assignor: Thomson Licensing S.A.
   • Assignee: Thomson Licensing (France)
   • Correspondent: not retrievable from source
   • Context: change of name only — no change in ownership (S.A. → simplified form), recorded years after it took effect.

3. 2016-01-04 (effective) / recorded 2017-07-22 — Reel 043302/0965

   • Conveyance: Assignment
   • Assignor: Thomson Licensing
   • Assignee: Thomson Licensing DTV (France)
   • Correspondent: not retrievable from source
   • Context: internal corporate reorganization — patent moved into a DTV-specific holding entity created for the "Madison" joint licensing arrangement (Technicolor + Sony DTV/CDM portfolios, commenced 2015).

4. 2018-07-23 (effective) / recorded 2018-08-10 — Reel 046763/0001

   • Conveyance: Assignment
   • Assignor: Thomson Licensing DTV
   • Assignee: InterDigital Madison Patent Holdings (France; SAS, 3 rue du Colonel Moll, 75017 Paris)
   • Correspondent: not retrievable from source
   • Context: transfer-to-asserter / portfolio acquisition — part of InterDigital, Inc.'s (NASDAQ: IDCC) $150M purchase of Technicolor's patent licensing business (binding offer 2018-03-01; closed 2018-07-30/31). The same DTV→InterDigital Madison transfer appears in the Netherlands register (recorded 2019-02-22). Note the buyer's name tracks the "Madison Arrangement," the combined Technicolor+Sony DTV/CDM licensing program that InterDigital assumed and now runs.

Subsequent intra-InterDigital moves (Thomson-style cleanup into InterDigital VC Holdings, Inc. and InterDigital CE Patent Holdings) are visible in foreign registers, but the US current assignee of record per Google Patents remains InterDigital Madison Patent Holdings SAS.

Correspondent recurrence (signal 3) cannot be evaluated — this is the single most important gap in the record and requires the Assignment Center reel/frame cover sheets.

Timeline diagram

timeline
    title Ownership of US 8024752
    2001 : Inventor assigns rights to Thomson Licensing SA
    2003 : First assignment recorded
    2011 : Patent issued to Thomson Licensing
    2016 : Moved to Thomson Licensing DTV
    2018 : Transfer to InterDigital Madison
    2023 : Patent lapsed for unpaid maintenance fee

NPE / troll-pattern signals

1. Shell-entity transfer — present (qualified). The patent ends up in InterDigital Madison Patent Holdings SAS (Reel 046763/0001, effective 2018-07-23), a licensing-only holding entity with no products of its own (a 300+ patent holding vehicle; its manufacturing-free, licensing-only character is confirmed by InterDigital's own filings describing the Madison Arrangement as a combined licensing program). Qualification: the immediate predecessor (Thomson Licensing / Thomson Licensing DTV) was already a licensing arm, and the ultimate parent is a public R&D company, not an anonymous single-member Delaware/Texas LLC with a registered-agent address. So this is an operating-group→licensing-vehicle transfer, not a classic fly-by-night shell.

2. Known asserter in the chain — present (qualified). InterDigital is not on the enumerated Acacia/Marathon/IV/Wi-LAN-style lists, but it is a high-frequency patent plaintiff whose revenue is overwhelmingly licensing-driven, with concrete enforcement: e.g., ITC + district-court actions against Amazon and Lenovo and UPC/global actions against Disney (InterDigital is the patent owner/petitioner party in PTAB IPR2026-00195, Amazon v. InterDigital Madison Patent Holdings SAS). This is the strongest signal in the chain. Qualified because InterDigital performs genuine R&D and holds SEPs, so it is a PAE/NPE-adjacent licensor rather than a pure troll.

3. Repeat correspondent across the chain — unclear / not determinable. Correspondents of record for Reels 015431/0707, 042303/0268, 043302/0965, and 046763/0001 were not retrievable. Cannot confirm or refute a recurring recording attorney.

4. Cascading transfers — present (moderate). Three consecutive registered transfers were recorded within ~16 months: 2017-04-21 (Reel 042303/0268), 2017-07-22 (Reel 043302/0965), 2018-08-10 (Reel 046763/0001). Although the effective dates are spread (2010 → 2016 → 2018), the recording burst looks like a title-cleanup immediately ahead of the InterDigital sale — the chain (Thomson Licensing → Thomson Licensing DTV → InterDigital Madison) is compact and same-corporate-family until the final sale.

5. Pre-litigation transfer — not present (for this patent). The InterDigital transfer (effective 2018-07-23) is years before InterDigital's major video litigations (2023–2025) and I found no infringement suit naming US8024752. This patent appears to sit in the DTV/conditional-access licensing pool rather than in any asserted campaign.

6. Bankruptcy fire-sale — not present (for this patent). The 2018 transfer was a negotiated $150M asset sale of Technicolor's licensing business, not a court-supervised bankruptcy sale. (Technicolor's later financial distress, if any, post-dates this transfer.)

7. Privateering — unclear (weak). Technicolor structured the deal to keep 42.5% of future cash receipts from InterDigital's consumer-electronics licensing, and took a perpetual license-back — a monetization/revenue-share structure. But there is no evidence InterDigital asserts the '752 patent on Technicolor's behalf against Technicolor's competitors, which is the defining privateering test.

8. Defensive aggregator (anti-NPE) — not present. The chain terminates at InterDigital Madison Patent Holdings SAS, an asserting licensor, not RPX/AST/LOT/Unified/OIN.

Verdict

NPE — moderate confidence.

Justification: the chain terminates at InterDigital Madison Patent Holdings SAS (Reel 046763/0001, effective 2018-07-23) — a licensing-only holding vehicle for the Technicolor+Sony "Madison" DTV/CDM program, whose parent InterDigital, Inc. derives its revenue from patent licensing and is a high-frequency plaintiff (ITC/District Court actions against Amazon, Lenovo, Disney) — and the transfer was booked via a burst of recorded assignments across 2017-04-21 to 2018-08-10 (Reels 042303/0268, 043302/0965, 046763/0001). That yields two qualifying signals (licensing-only terminal entity; known asserter), but neither is a "clean" troll tell: the seller was itself a licensing arm, the buyer is a large public R&D company, no suit names this patent, and the correspondent field — the decisive evidence for signal 3 — was not retrievable, holding the call at moderate rather than high confidence.

Primary limitation / next step: retrieve the correspondent of record for each of the four reel/frame entries via the USPTO Assignment Center to close out signal 3.

Verification links:

• USPTO Assignment Center: https://assignmentcenter.uspto.gov/
• Assignment Search (public index): https://assignment.uspto.gov/patent/index.html
• Google Patents legal events (source used here): https://patents.google.com/patent/US8024752/en
• InterDigital/Technicolor deal close: https://ir.interdigital.com/news-events/press-releases/news-details/2018/InterDigital-Completes-Acquisition-of-Technicolor-Patent-Licensing-Business/

I'll research this systematically. Let me start by searching for the patent number and gathering details on the cited references.

Let me gather details on the remaining key cited references.

I've now confirmed the patent identity and gathered details on the cited references. Since I've reached my search-step limit, I'll consolidate the analysis using the authoritative full patent text (which contains the complete citation table) plus the reference details I retrieved. Where I could not retrieve a reference's full disclosure, I flag that explicitly.

Prior‑Art Analysis — US 8,024,752 B2

1. Patent identification (confirmed against the patent record)

Critical date for §102 purposes: Because this application was filed 2001‑06‑29 and predates the AIA, pre‑AIA §102 governs. A reference must have been (a) published/patented before the invention date (§102(a)); (b) published/patented more than one year before 2001‑06‑29, i.e., before 2000‑06‑29 (§102(b)); or (c) a US patent/application filed before the invention date (§102(e)). Note the "Prior art date" in the Google table is the priority date of each reference, not its publication date — both are given below.

Core inventive concept (what the prior art must teach to anticipate): Enabling an access device to output an event for which it lacks the authorization code for an authorization acquisition period independent of the signal's content (a "set amount of unconfirmed viewing time"), while the authorization code (EMM) is transmitted to it automatically and not in response to a request from the device. The independent claims are 1, 6, 7, 10, 12, 14 and 15.

2. The 15 patent citations — reference‑by‑reference

Important framing: §102 anticipation requires a single reference that discloses every element of a claim, arranged as claimed. Most of these references are background art cited to show the state of conditional‑access/homing technology generally. Only a few come close to the "unconfirmed viewing time / authorization acquisition period" limitation. My element‑level assessments below are analytical and would require full‑text verification before any invalidity position is asserted.

(A) References most relevant to the core concept

1. US 2002/0112234 A1 — Bacon, Kinney C. — "Descrambling device for use in a conditional access system"

• Full citation: US 2002/0112234 A1 (published 2002‑08‑15); priority/filing 2001‑02‑09; applicant Scientific‑Atlanta, Inc.
• Dates: Filed 2001‑02‑09 — before the 2001‑06‑29 filing date, so it qualifies as §102(e) prior art. (Family member WO 02/065776 A3, PCT/US02/03537.)
• Description (from retrieved text): Claims a system/method for descrambling a "scrambled instance" having a predetermined encryption cycle rate. An access device uses a counter with a predetermined count, decremented at each encryption period as entitlement control messages change, and a microprocessor generates control words from authorization information. Claim 19: "disabling the generation of the control word in response to a predetermined count on the counter." Claim 15: "descrambling a scrambled instance … encrypted at a predetermined encryption cycle rate; and decrementing a counter at the encryption cycle rate."
• Potential §102 relevance: This is the closest cited reference structurally. It discloses (i) a device enabled to output/descramble a signal it is not currently authorized for, during a period defined by the encryption cycle rate (the temporal analogue of "authorization acquisition period"); and (ii) a counter/decrement mechanism governing how long access continues before the entitlement is refreshed. Directly touches claim 4 ("authorization acquisition period … greater than or equal to a carousel rate"), claim 9, and claim 11. It does not, on the retrieved text, disclose the "not in response to a request for authorization" negative limitation of claims 1/7/10/12/14, so it is more naturally an obviousness reference than a clean §102 anticipation — but for the period‑vs‑cycle‑rate dependent claims it is the strongest §102 candidate.

2. US 6,973,662 B1 — "Method for providing programming distribution"

• Full citation: US 6,973,662 B1 (granted 2005‑12‑06); priority 1999‑10‑13; assignee Starz Entertainment Group LLC.
• Dates: 1999 priority — qualifies under §102(a)/(b) (published/issued after filing but the underlying content predates; note granted patent itself is post‑filing, so §102(e) analysis applies to its application date of 1999).
• Description: Methods for distributing programming, including impulse/on‑demand pay‑per‑view access models. (I retrieved only summary‑level information; the full disclosure was not retrieved before the search limit.)
• Potential §102 relevance: Likely relevant to claims 1, 7, 10 (pay‑per‑view access to programming that the subscriber has paid for). Flagged uncertainty: I could not verify whether it discloses the specific "unconfirmed viewing time before an authorization code is received" limitation; treat as a secondary reference pending full‑text review.

3. WO 9,804,342 A1 — Canal+ Société Anonyme — "Method and apparatus for preventing fraudulent access in a conditional access system"

• Full citation: WO 1998043428 A1 (published 1998‑10‑01); priority 1997‑03‑21.
• Dates: Published 1998‑10‑01 — squarely prior art under §102(a) and §102(b).
• Description: Anti‑piracy in conditional‑access systems; relates to entitlements/"replacement states" and management messages. (Full text not retrieved.)
• Potential §102 relevance: Relevant background on conditional‑access entitlement management (claim 2 context — EMMs). Not, on available information, directed to the unconfirmed‑viewing‑time concept itself.

(B) Conditional‑access / smart‑card background references

4. US 6,157,719 A — "Conditional access system"

• Full citation: US 6,157,719 A (granted 2000‑12‑05); priority 1995‑04‑03; assignee Scientific‑Atlanta, Inc.
• Dates: Published 2000‑12‑05 — prior art under §102(a)/(b) for its application date (1995).
• Description: Cable TV conditional‑access system; headend broadcasts "instances"/programs; set‑tops selectively decrypt using public/private keys; keys may be reassigned. Foundational CA system describing entitlement messaging.
• Potential §102 relevance: Establishes the CA/EMM framework underlying claim 2. Does not, on its face, disclose the unconfirmed‑viewing‑time limitation.

5. WO 9,600,6504 A1 — Thomson Consumer Electronics, Inc. — "Smart‑card based access control system with improved security"

• Full citation: WO 1996/006504 A1 (published 1996‑02‑29); priority 1994‑08‑19; inventors Chaney et al. (US equivalent US 5,852,290.)
• Dates: Published 1996‑02‑29 — prior art under §102(a)/(b).
• Description (retrieved): A smart card including a descrambler for descrambling entitlement information/data. Describes EMM and ECM processing inside the smart card — "transport processor … transfers the packet payload to security controller … CPU … processes the EMM data and modifies entitlement data stored in EEPROM." Directly supports the smart‑card/CA architecture of the patent.
• Potential §102 relevance: Relevant to claim 3 (transmitting an authorization code to a smart card disposed in an access device) and claim 2 (EMM). Again, background to, not anticipatory of, the unconfirmed‑viewing‑time core.

6. WO 9,900,7150 A1 / US family — Scientific‑Atlanta, Inc. — "Encryption devices for use in a conditional access system"

• Full citation: WO 1999007150 A1 (published 1999‑02‑11); priority 1997‑08‑01; inventors Palgon, Pinder et al.
• Dates: Published 1999‑02‑11 — prior art under §102(a)/(b).
• Description: Encryption/decryption devices in a CA system; related to the Scientific‑Atlanta conditional‑access family (see US 6,157,719).
• Potential §102 relevance: General CA framework only; no apparent teaching of the unconfirmed‑viewing‑time limitation.

7. Irdeto Access B.V. — WO 01/30082 A1 and its US counterpart US 2002/0120928 A1 (Wajs, Andrew Augustine) — "Method for operating a conditional access system for broadcast applications"

• Full citations:
• WO 2001030082 A1 (published 2001‑04‑26; priority 1999‑10‑18)
• US 2002/0120928 A1 (published 2002‑08‑29; priority 1999‑10‑18)
• Dates: The WO published 2001‑04‑26 — before 2001‑06‑29, so it is §102(a)/(b) art. The US publication's underlying application dates to 1999.
• Description: Method for operating a CA system for broadcast applications; a national counterpart is cited as CN1379954A. (Full text not retrieved.)
• Potential §102 relevance: CA entitlement‑management background. Relevance to the specific unconfirmed‑viewing‑time claims is not established from available information — flagged.

8. Canal+ — WO 9,804,3425 A1 — "Smartcard for use with a receiver of encrypted broadcast signals, and receiver"

• Full citation: WO 1998/043425 A1 (published 1998‑10‑01); priority 1997‑03‑21.
• Dates: Published 1998‑10‑01 — §102(a)/(b) art.
• Description: Smart card (and receiver) architecture for encrypted broadcast signals; supports claim 3's smart‑card context.
• Potential §102 relevance: Background on smart‑card CA; not anticipatory of the core claim.

(C) Distributive / VOD / cyclically‑transmitted‑stream references

9. US 4,947,244 A / RE34,611 — On Command Video Corporation — "Video selection and distribution system"

• Full citation: US 4,947,244 A (granted 1990‑08‑07); priority 1989‑05‑03; inventors Fenwick, Peden, Snyder et al. (reissue RE34611.)
• Dates: Published 1990‑08‑07 — §102(b) art.
• Description (retrieved): Hotel video‑on‑demand: users select a movie; a switch couples a video source to the room's monitor. Notably: "guests are automatically charged a fixed fee … when a selected movie is viewed for more than a predefined period of time, typically around five minutes." It also describes per‑monitor selection and menus.
• Potential §102 relevance: This is a notable secondary reference because it discloses a time‑based viewing threshold before a billing/access consequence — conceptually adjacent to the "set amount of unconfirmed viewing time." However, it does not disclose an authorization code acquired during that period, nor the "no request for authorization" limitation, so it does not anticipate claims 1/6/7/10/12/14/15. Best characterized as §103 background for the "predefined period" concept.

10. US 6,177,930 B1 — International Business Machines Corp. — "System and method for enabling a user to move between cyclically transmitted image streams"

• Full citation: US 6,177,930 B1 (granted 2001‑01‑23); priority 1997‑03‑28.
• Dates: Application 1997 — §102(a)/(e) art.
• Description: Enables a user to move between cyclically transmitted (i.e., "carousel‑like") image streams — relevant to the "data carousel" concept referenced in claim 4/9/11.
• Potential §102 relevance: The "cyclically transmitted streams" teaching is conceptually related to the "carousel rate" language of the dependent claims; but the retrieved description indicates it concerns navigation among streams, not authorization acquisition. Treat as background for carousel terminology only.

11. JP 2000‑101984 A — Hitachi Ltd. — "Conditional reception system for cable television, transmission device therefor and reception device therefor"

• Full citation: JP 2000101984 A (published 2000‑04‑07); filing 1998‑09‑24.
• Dates: Published 2000‑04‑07 — before 2001‑06‑29; §102(a)/(b) art (subject to any language/translation verification).
• Description: Conditional reception for cable TV. (Full text not retrieved; Japanese‑language reference.)
• Potential §102 relevance: CA background; unverified. Flagged.

(D) Later‑filed / less‑central references

12. US 7,310,810 B1 — Sony Corporation — "Broadcasting apparatus and method, receiving apparatus and method, and medium"

• Full citation: US 7,310,810 B1 (granted 2007‑12‑18); priority 1999‑05‑19.
• Dates: 1999 priority — §102(e)/(a) art as to its application.
• Description: Broadcasting/receiving apparatus and method. (Full text not retrieved.)
• Potential §102 relevance: Not established from available information. Flagged as secondary.

13. US 2007/0124753 A1 — Koichiro Yamaguchi — "Digital broadcast receiving device"

• Full citation: US 2007/0124753 A1 (published 2007‑05‑31); priority 2000‑01‑12.
• Dates: 2000 priority — §102(e)/(a) art.
• Description: Digital broadcast receiving device. (Full text not retrieved.)
• Potential §102 relevance: Not established. Flagged as secondary.

14. US 6,706,579 B2 — OpenTV, Inc. — "On‑demand interactive magazine"

• Full citation: US 7,069,579 B2 (granted 2006‑06‑27); priority 2001‑05‑30.
• Dates: Filed 2001‑05‑30 — just one month before the 2001‑06‑29 filing, so it is at most late §102(e) art and its relevance is on‑demand/interactive content, not authorization timing.
• Description: On‑demand interactive magazine. (Full text not retrieved.)
• Potential §102 relevance: Minimal/adjacent; flagged.

15. Canal+ (additional)/other — see items 3 and 8 above (the two Canal+ references are the only Canal+ entries in the citation table).

Note: The 15th table row in Google's list is US 2003/0005435 A1 — Rickard Nelger — "Conditional access system" (priority 2001‑06‑29, same priority date as the subject patent). Same‑day priority means it is not prior art to US 8,024,752 unless it establishes an earlier invention date; treat as not citable for §102 on the face of the record.

3. Non‑patent citation

• "Search report dated Feb. 22, 2002" — the PCT/ISA search report (PCT/US2001/020844) issued 2002‑02‑22. Under pre‑AIA §102, a search report is not itself prior art; it is the mechanism by which the examiner of record identified the 15 references above. It is relevant only as evidence of the art considered during prosecution.

4. Comparative relevance summary

5. Honest confidence caveats

1. Full‑text verification incomplete. I retrieved substantive descriptions for only a subset of the 15 references (notably US 2002/0112234 A1, US 4,947,244 A, US 6,157,719, WO 9,600,6504, and the On Command material). For US 6,973,662, US 6,177,930, JP 20010101984, US 7,310,810, US 2007/0124753, US 6,706,579 B2, WO 01/30082, and the two Canal+ references, I have the bibliographic data from the patent's own citation table but not a verified full‑text disclosure review. Element‑level §102 conclusions for those are therefore provisional.

2. §102 vs. §103. No cited reference I examined discloses all elements of any independent claim — in particular the negative limitation common to claims 1, 6, 7, 10, 12, 14 & 15 (authorization code transmitted "automatically and not in response to a request for authorization") combined with the "authorization acquisition period independent of the signal's content." This suggests the cited art is far more useful as a §103 obviousness combination base than as §102 anticipation art, with Bacon (US 2002/0112234) plus a conditional‑access/EMM reference (Sci‑Atlanta or Thomson) being the most plausible combination.

3. Family documents are not prior art. EP 1,415,471 B1 and JP 5,127,109 B2 (found under "Similar Documents") are counterparts of this same patent family (same inventor, same priority, "Method and apparatus for permitting unconfirmed viewing time with addressable pay TV"). They must not be treated as prior art against US 8,024,752.

4. Not a legal conclusion. This is a technical prior‑art triage, not an invalidity or patentability opinion. Any §102/§103 position should be confirmed against the full text of each reference and, for the Japanese reference, an accurate translation.

If you'd like, I can dig deeper into any single reference — the Bacon/Scientific‑Atlanta US 2002/0112234 and Starz US 6,973,662 families are the two I'd verify first for a complete element‑by‑element §102 chart.

I'll research the cited prior art references to ground the obviousness analysis in their actual disclosures.

Let me gather more detail on the remaining key references, particularly the Irdeto grace-period teaching and the IBM carousel reference.

Obviousness Analysis — US 8,024,752 B2 under 35 U.S.C. § 103

Patent analyzed: US 8,024,752 B2 — "Method and apparatus for permitting unconfirmed viewing time with addressable pay TV" (Duffield; Thomson Licensing → InterDigital Madison Patent Holdings). Effective filing/priority date June 29, 2001 (PCT/US2001/020844); US national stage 10/482,085. Source: https://patents.google.com/patent/US8024752/en

Because the application was filed before March 16, 2013, pre‑AIA § 102/103(g) governs. The analysis below uses the references listed in the patent's own "Citations" (prior‑art) sections. I flag where I am reasoning from a reference's title/abstract only (full text not retrieved).

1. Personnel of ordinary skill and the governing standard

POSITA: a person with a B.S. in EE/CS (or equivalent) and ~2–4 years of experience designing or operating conditional‑access / addressable pay‑TV systems (headend EMM/ECM generation, set‑top/DTV + smart‑card entitlement handling, broadcast carousels). This is a mature, well‑documented field; the art is highly combinable.

Standard: Graham v. John Deere (scope/content of prior art; differences; PHOSITA level; secondary considerations) as refined by KSR Int'l v. Teleflex — a claim is obvious where the elements existed in the prior art and the combination is "a predictable use of prior‑art elements according to their established functions," or where a "finite number of identified, predictable solutions" exist. Motivation may come from the reference itself, the nature of the problem, or common sense/knowledge — an express teaching, suggestion, or motivation is not required.

Independent claims to analyze: claims 1, 6, 7, 10, 12, 14, 15. Key dependents: 2, 3, 4, 5, 8, 9, 11, 13, 16.

2. The claimed subject matter distilled

Every independent claim reduces to the same core:

The specification concedes the problem is old and describes it entirely in terms of the existing carousel/EMM art ("it will take approximately 25 minutes for a subscriber to receive his EMM… if the provider were to set the unconfirmed viewing time to approximately 30 minutes, they would virtually ensure that the subscriber would receive their EMM"). That framing is itself an admission that the invention is a timing/grace‑period design choice layered on a conventional conditional‑access architecture.

3. Mapping of cited prior art to the elements

4. Ground 1 (primary § 103 rejection): Irdeto + Sci‑Atlanta '719 + On Command '244 + IBM '730, optionally + Bacon '234

Claim 1 is obvious over Irdeto in view of Sci‑Atlanta '719, On Command '244, and IBM '730.

(a) Same field / same problem → strong motivation to combine.
Irdeto, '719, and the Canal+ references are all conditional‑access pay‑TV systems using EMMs and SmartCards. KSR squarely permits combining references "designed to address the same problem." Irdeto articulates the very problem the '752 patent recites: a paying subscriber who tunes away or misses the carousel does not receive the refreshment EMM before expiry and is "forced to wait to be entitled over the air." That is the '752's stated motivation (missed EMM after payment; long carousel wait). A POSITA confronting Irdeto's problem would be led directly to the '752's solution space.

(b) Irdeto already discloses a grace period keyed to missing EMMs.
Irdeto's "extension EMM… all entitlements having an expiry date within a predetermined first period are extended with a predetermined second period" grants continued access for a set, fixed period to a device that does not hold a current (refreshment) authorization — the functional equivalent of elements B, C and (partly) F. That the extension is implemented by an EMM rather than by temporarily waiving the code requirement is an implementation detail, not a patentable difference: pre‑AIA § 103 asks whether the subject matter as a whole would have been obvious, and swapping "extend the entitlement" for "permit access while awaiting the code" is a predictable, functionally identical alternative (and, notably, Irdeto's own text sizes the problem to the carousel — 2.5‑hour waits, calls after ~30 seconds — which supplies the design constraint for the "acquisition period").

(c) "Unconfirmed viewing time" = On Command's fixed free‑viewing window.
On Command '244 expressly teaches a pay‑TV system that lets a user view selected content for a set, content‑independent period (≈5 minutes) before the system "commits" (bills). Applying that known "free/temporary viewing window before commitment" teaching to Irdeto's conditional‑access EMM context supplies the "set amount of unconfirmed viewing time" (element C) and the "independent of the signal's content" limitation (element B) — the window is a clock, not a function of the program.

(d) "Not in response to a request" (E).
EMMs in Irdeto, '719, and Canal+ are broadcast/carouseled — they are not solicited by the device. This element is affirmatively disclosed, not merely inherent.

(e) "Purchased prior to enabling" (D).
Irdeto's whole scenario is a subscriber who paid but whose refreshment EMM was missed; extension EMMs are issued against existing entitlements. Sci‑Atlanta '719 and the Canal+ references likewise broadcast entitlement messages tied to subscriptions. Claim 14's "authorization codes associated with content purchased prior to the authorization acquisition period" is met by the same teaching.

(f) Carousel timing (G — claims 4, 9, 11).
IBM '730 supplies carousel/cyclic transmission as such, and Irdeto quantifies the carousel wait. Taking the "'752" step — setting the window ≥ the carousel rate — is at most an optimization of a predictable parameter, and KSR holds predictable parameter adjustments obvious when the result is foreseen. Bacon '234 is the clincher on motivation: it expressly claims the concept of using the scrambled stream's "inherent encryption period/cycle rate… to control subscriber access," i.e., tying the access window to the transmission cycle. A POSITA reading Bacon would have a concrete reason to size the unconfirmed‑viewing window to the carousel cycle to guarantee the code arrives.

(g) Claim 5 (≥ two codes, separate channels) (H).
Broadcasting an entitlement message redundantly on more than one channel is a routine bandwidth‑for‑reliability trade‑off; the specification itself offers this as an alternative to lengthening the window. Duplicating an EMM across channels is a predictable, known method to increase reception probability — obvious under KSR's "familiar elements according to known methods."

(h) Claim 16 (previously received prior code) (I).
Irdeto's extension applies to entitlements that had an entitlement (with an expiry), i.e., a prior authorization; Canal+ family disclosures grant "free"/commercial‑offer rights for a set period on a prior purchase. Element I is disclosed/motivated.

Result: Claims 1–16 are rendered obvious by Irdeto + '719 + On Command '244 + IBM '730 (+ Bacon '234), with claims 2/3 aided by '719 and Thomson '604, and claims 4/9/11 by Bacon '234/IBM '730.

5. Ground 2 (alternative/independent § 103 rejections)

These reach the same result if any reference in Ground 1 is unavailable, or support a second‑reference rejection:

• Starz US 6,973,662 B1 + WO 2001/030082 (Irdeto) + US 6,157,719.
  Starz teaches PPV/NVOD/VOD with preauthorization and extended/viewing‑period concepts; Irdeto supplies the EMM/carousel grace‑period problem and automatic (non‑request) broadcast; '719 supplies the CA/smart‑card platform. Motivation: both are addressable‑pay‑TV content‑delivery systems; combining a "view before key/authorization is settled" mechanism (Starz) with the EMM grace‑period mechanism (Irdeto) is the predictable union of two known content‑control techniques.

• WO 96/006504 (Thomson) or WO 98/43425/‑28 (Canal+) in place of '719.
  Either supplies the claim‑3 smart‑card limitation and the EMM/entitlement platform; substituting one known CA platform for another is an obvious interchangeability of known equivalents.

• On Command '244 + WO 2001/030082 + US 6,177,930.
  On Command supplies the fixed free‑viewing window; Irdeto the pay‑TV EMM/carousel and "waiting for entitlement" problem; IBM '730 the carousel. This combination does not even require an academic "CA‑to‑CA" rationale because all three are pay‑per‑view/conditional‑access content systems.

6. Objective indicia (secondary considerations)

• No evidence of secondary considerations was located. The patent was never asserted in litigation and lapsed for nonpayment of maintenance fees (lapse recorded 2023‑10‑23; effective expiration 2023‑09‑20). There is no record of commercial success, licensing, industry praise, or copying attributable to the claimed grace‑period feature, and no unexpected‑results evidence in the specification.
• The claim‑drafting history (heavy use of "independent of the signal's content," "not in response to a request") reflects an attempt to distinguish request‑based VOD and content‑driven access — distinctions the cited carousel/EMM art does not present.

Net: the secondary‑consideration balance does not rebut the prima facie case.

7. References that do not qualify as prior art (must be excluded)

• US 2003/0005435 A1 (Rickard Nelger, "Conditional access system") — its priority date is listed as 2001‑06‑29, identical to the '752 priority date. A reference with the same effective date is not "prior art" under pre‑AIA § 102(a)/(b)/(e) absent proof of an earlier date of invention. Do not rely on it as § 103 art. (This is the one date‑sensitive flag in the citation list.)
• WO 02/096024 A2 / EP 1 352 496 (General Instrument / Peterka, "Initial Free Preview for Multimedia Multicast Content," Oct. 2001) — although it is extraordinarily on‑point ("an initial viewing period can be provided for a period of time that is sufficient to allow a predetermined number of clients to receive keys for decrypting the encrypted portion of the program"), it post‑dates the June 29, 2001 priority date and therefore is not prior art to the '752 patent. It is useful only as evidence of how quickly and predictably the concept was developed by others — i.e., it corroborates that the '752's "unconfirmed viewing time" was an obvious next step in the art, not a nonobvious leap.
• US 8,020,186 B1 (Starz/Sie) and other "Families Citing" documents cited by the '752 are later art and are not available against it.

8. Confidence and limitations

• Available in full: Irdeto WO 2001/030082 (Google Patents text), On Command US 4,947,244 (full text), Sci‑Atlanta US 6,157,719 (partial), Starz US 6,973,662 (abstract/summary), Bacon US 2002/0112234 (abstract, via the '234 PCT/US02/03537 search report).
• Reasoned from title/abstract only (I did not retrieve full text): WO 96/006504 (Thomson), WO 98/43425 / WO 98/43428 (Canal+), US 6,177,930 (IBM), US 7,310,810 (Sony), US 7,069,579 (OpenTV), US 2007/0124753 (Yamaguchi), JP 2000‑101984. Statements about these are limited to their titles/abstracts; a full‑text pull is required to cite specific columns/lines.
• Conclusion: On the record above, claims 1–16 of US 8,024,752 would have been obvious under § 103 over Irdeto WO 2001/030082 in view of Sci‑Atlanta '719, On Command '244, and IBM '730, with Bacon '234 supplying the express motivation to tie the unconfirmed‑viewing window to the scramble cycle/carousel rate (claims 4, 9, 11). The strongest single rationale is that Irdeto states the identical problem and a functionally equivalent grace‑period solution, and the remaining elements (fixed content‑independent free‑viewing window; redundant multi‑channel EMMs; prior authorization) are each disclosed in the cited art as predictable design choices.

This is a technical analysis, not a legal opinion; claim construction and final validity determinations require full‑text review of each reference and are reserved to counsel.