US 8151345

I'll run targeted searches for this specific patent number, its litigation, and any appellate activity.

Let me check the litigation dockets and any PTAB/appellate activity specific to this patent.

Let me pull the full independent claim set (including the cellular-adapter claims asserted in the 2026 suits) and check for any PTAB petition.

US Patent 8,151,345 — verification summary

Searches performed: Google Patents (US8151345B1), Justia Patents, FreePatentsOnline, SumoBrain, USPTO.report, Golden, Docket Alarm / Justia dockets (W.D. Tex. and E.D. Tex.), and a Federal Circuit / CAFC-docket search. I interpreted the number literally as US 8,151,345 B1 and did not substitute any similar number.

1. Bibliographic data

2. Ownership chain (per USPTO assignment records reflected on Google Patents)

• Original assignee: Individual (i.e., inventor‑held at grant).
• 2016‑10‑14: assigned to U.S. ENCODECORPORATION, YEAGER, DOUG.
• 2016‑10‑19: assigned to NEOLOGY, INC. (from U.S. Encode Corporation and Doug Yeager).
• 2026‑02‑11: assigned to MOBILITY IP HOLDINGS, INC. (from Neology, Inc.).

The patent page also lists "Mobility Ip Holdings Inc" and "Us Encodecorporation" as current/listed assignees. Consistent with the most recent reassignment, Mobility IP Holdings, Inc. is the apparent current owner, and it is the plaintiff in the 2026 suits described below.

3. Abstract (as issued)

Self-authorizing cards and cellular network adapters for authorization of financially payments and other secure transactions. In some embodiments a smart card is provided with a connector for a USB port on a computer terminal such as a personal computer (PC). Embodiments are also provided for mobile phones, personal digital assistants (PDAs), and similar devices. The self-authorizing devices typically include a secure element that has been previously provisioned with information about a particular card holder account. A secure element reader interrogates the smart element and derives information needed to authorize the transaction. A communications controller transmits the information to a host device, such as a PC, PDA, or a mobile phone.

4. Plain‑language overview of the independent claims

Note on claim numbering: The patent's independent claims are a "token" group and a "cellular network adapter" group. Justia's text displays independent claims 1, 9, and 11; the March 2026 Apple complaint charts also rely on independent claim 23 (cellular network adapter). I could not retrieve a clean, complete official claim set for every independent claim number, so claim 23 below is reconstructed from the complaint analysis and flagged as such.

• Claim 1 (self-authorizing token, USB/HID): A device ("token") with a body and a connector to plug into a computer. Affixed to that body are (a) a secure element with a data file, (b) a secure element reader that interrogates the chip by executing ISO 7816-4 file‑system functions (expressly including a command to select a payment card application) to produce file information, and (c) a communications controller that converts that file information into transaction information and sends it to the computer. The claim requires the connector to be USB, the controller to present itself as a USB Human Interface Device (HID) class device, and the output to be in a format that auto‑populates a form field in an application on the computer.

• Claim 9 (token, encrypted financial data + auto‑populate): Same general token architecture, but the secure element's data file contains financial authorization data; the controller extracts and encrypts at least part of that financial data and transmits the encrypted data as transaction information, again auto‑populating a form field.

• Claim 11 (token, USB HID keyboard emulation): A token with a USB connector and a secure element, where the communications controller is configured as an HID‑class USB device, extracts information from the secure element data file, converts part of it to transaction information, and transmits it through the USB connector as keyboard emulation, auto‑populating a form field.

• Claim 23 (cellular network adapter — per the 2026 complaint chart, not a verbatim official source): A cellular network adapter for a cellular device having a cellular network application interface, comprising a secure element with a data file; a secure element reader that interrogates the secure element using ISO 7816‑4 file‑system functions; a near field communications (NFC) controller bridge chip that converts the file information to an RF data signal for an external reader; and a communications controller that converts the file information into transaction authorization information and transmits it over a wireless network. A further limitation recites that the reader is configured to await a startup instruction comprising an unpredictable number originating over the cellular wireless network before interrogating the secure element.

Representative dependent claims (as listed): prescribed cadence of data delivery to the host (claims 2, 5, 10, 12); encryption of extracted financial data (claims 3, 4, 13); transaction information comprising an encrypted unpredictable number constructed as a hash of a timestamp (claim 6); encryption constructed from a timestamp and a transaction counter (claim 7); and awaiting a startup instruction containing an unpredictable number from the host before interrogation (claim 8).

5. 2026 litigation status (and CAFC status)

The Google Patents record and docket searches identify two 2026 district‑court actions asserting this patent; both are cited on the patent page itself:

• Mobility IP Holdings, Inc. v. Apple Inc., No. 7:26‑cv‑00075 (W.D. Tex., Midland Division; filed March 4, 2026; Judge Alan Albright; §1338 patent infringement). Accused products: Apple mobile devices (iPhone XR onward, Apple Watch Series 5+, various iPads) running Apple Pay, including secure‑element/NFC functionality. The complaint also asserts US 8,548,924.
• Mobility IP et al. v. [[[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.), No. 2:26‑cv‑00157 (E.D. Tex., Marshall Division; filed February 27, 2026; Judge Rodney Gilstrap). Docket activity includes answers filed June 23, 2026 and scheduling orders in June 2026.

CAFC 2026 dockets: I found no Federal Circuit appeal in 2026 involving US 8,151,345. My searches surfaced only unrelated 2026 CAFC decisions (e.g., FedEx, Netlist v. Micron, Constellation Designs) and no appellate docket for this patent. If an appeal exists, it does not appear in the sources I could reach.

6. Uncertainty / caveats

• Claim 23 wording is taken from a third‑party complaint‑analysis table quoting the patent; it may be paraphrased and should be confirmed against the official USPTO claim text. I did not independently verify whether the patent contains additional independent claims in the cellular‑adapter group beyond claim 23.
• Timeline anomaly: the priority (2007), grant (2012), and reassignment events are internally consistent, but note that the "current assignee" listing shows both Mobility IP Holdings and U.S. Encode Corp.; the latest recorded assignment (2026‑02‑11) is from Neology to Mobility IP Holdings.
• I could not authoritatively confirm the primary examiner, exact claim count, or whether any PTAB/IPR petition has been filed against this patent; my CAFC/PTAB searches returned no such proceeding. These should be verified directly in USPTO PatentCenter and the PTAB docket if precision is required.
• The "2030‑12‑17" adjusted expiration reflects the granted PTA/terminal disclaimer per the patent page; it is a listed value, not an independently recomputed term.

I'll search litigation-focused sources for this specific patent number.

Let me check for earlier litigation (Neology-era) and any additional cases, plus the litigation portal.

Litigation involving U.S. Patent No. 8,151,345

Bottom line: Based on the litigation-focused sources I could reach, two known lawsuits assert U.S. Patent No. 8,151,345 — both filed in 2026 by Mobility IP Holdings, Inc. (the apparent current owner), one against Apple and one against Samsung. Both are pending; no outcome has been reached in either. I found no earlier (Neology-era) assertion of the '345 patent and no appellate (CAFC) or PTAB activity specific to it.

Case 1 — Mobility IP Holdings, Inc. v. Apple Inc.

Source: Docket Alarm docket 7:26-cv-00075 (Texas W.D.); Ex Parte docket summary ("Status: Open," filed 03/04/26); Justia dockets.

Case 2 — Mobility IP Holdings, Inc. v. [[Samsung Electronics Co., Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.)

Source: Docket summary for 2:26-cv-00157 (E.D. Tex., Marshall); Ex Parte docket ("Status: Open," filed 02/27/26); Korean-press coverage (SeoulWire, 2026-03-01) confirming the '345 patent among the seven asserted; complaint-analysis tables.

Cases that do NOT involve the '345 patent (for the record)

My searches surfaced several Neology cases, but these concern RFID/tolling patents (e.g., 6,229,443; 6,690,264; 8,237,568; 8,325,044; 8,587,436; 7,119,664) and are not assertions of the '345 patent:

• Neology, Inc. v. Kapsch TrafficCom IVHS, Inc., et al., No. 1:13-cv-02052 (D. Del.) — RFID/tolling patents.
• Neology, Inc. v. Federal Signal Corp. / Sirit (6C RFID tag patents).
• TransCore v. Neology (RFID).
• Hot Systems, LLC v. San Diego Association of Governments et al., No. 3:26-cv-00738 (S.D. Cal.) — Neology is a defendant; patents are 10,810,578 and 11,270,182.

None of these is an assertion of US 8,151,345.

Caveats and contradictions to flag

1. Date discrepancy: The task states the current date is April 26, 2026, but the docket for the Samsung case contains entries dated June 2026 (answer and scheduling order), and the system environment date is September 19, 2026. I report the docket entries as retrieved rather than suppressing them, but the "current status" for Samsung should be treated as extending at least through late June 2026.

2. Claim 23 wording: The "cellular network adapter / claim 23" emphasis in both 2026 complaints comes from third-party complaint-analysis tables quoting the patent (Ex Parte AI analysis). Independent claims 1, 9, and 11 appear in Justia's text; I could not retrieve a clean, complete official independent-claim set for every number. Confirm claim 23 verbatim in USPTO PatentCenter before relying on it.

3. Completeness: Mobility IP Holdings is an active NPE filer; it may have filed suits against other defendants in the same 2026 campaign asserting the '345 patent that I could not surface within my search budget. A full PACER/Unified Patents docket sweep on "Mobility IP Holdings" (and on Neology, Inc. as prior plaintiff) is warranted to rule out additional cases.

4. No CAFC / PTAB activity found: No Federal Circuit appeal and no IPR/PGR petition directed to the '345 patent appeared in my searches. This is a negative finding from limited sources, not an affirmative confirmation of absence.

Primary sources:

• https://www.docketalarm.com/search/FederalCourts/?q=party:(Apple) — 7:26-cv-00075
• https://ai-lab.exparte.com/case/dct/txwd/7:26-cv-00075/mobility-ip-holdings-inc-v-apple-inc
• https://gaeflexstaging-dot-docketupdate.appspot.com/cases/Texas_Eastern_District_Court/2--26-cv-00157/
• https://ai-lab.exparte.com/case/dct/txed/2:26-cv-00157/mobility-ip-v-samsung-electronics-co-ltd
• https://patents.google.com/patent/[US8151345B1](/patent/US8151345B1) (family litigation links to both 2026 cases)

I'll verify the single proceeding listed and look for any institutional activity, related filings, or parallel proceedings on this patent.

Let me try a couple more targeted searches for the specific proceeding and petitioner.

I ran targeted searches on IPR2026-00500, on the patent number, and on the Mobility IP / Apple dispute. The structured PTAB list is the only authoritative source of proceeding numbers, and it contains exactly one entry — filed today (2026-09-19), before any PTAB paper is public. I flag below where the record is simply silent rather than guess at grounds, panels, or outcomes.

Proceedings overview

Total AIA proceedings on US 8,151,345: 1. Breakdown: 1 active/pending at the pre‑institution stage; 0 claims invalidated; 0 claims sustained; 0 settled; 0 institution denials. Bottom line defensive posture: the patent is neither hardened nor narrowed — it is untested at the Board. Because the single petition was filed on 2026‑09‑19 (the same day as this analysis), there is no institution decision, no Final Written Decision, and no claim‑level outcome to rely on. A defendant today gets zero benefit from IPR claim cancellation or § 315(e)(2) estoppel, but should track IPR2026-00500 closely because it is the first‑ever AIA challenge to a patent that issued in 2012 and is now being asserted in two 2026 district‑court suits.

IPR2026-00500 — Apple Inc. et al. v. Mobility IP Holdings, Inc. (apparent patent owner)

• Type: Inter Partes Review (IPR)
• Filed: 2026-09-19
• Status: Pending (verbatim from the structured PTAB data). Gloss: petition received; proceeding is pre‑institution — no patent‑owner preliminary response (POPR), no institution decision, and no trial has begun.
• Judge panel: Not public. No panel is assigned until institution; PTAB does not publish a merits panel for a pending, non‑instituted petition.
• Petition grounds: Not public / not in the structured data. The claims challenged, the prior art relied upon, and the statutory basis (§ 102 / § 103 / § 112) are not available in the record I can reach. I will not infer them from the patent's claim set. Anyone needing this must pull the petition itself from PTAB E2E (below).
• Institution decision: None issued. Statutory deadline is 6 months from filing → on or about 2027-03-19, extendable up to 6 additional months for good cause (~2027-09-19).
• Final Written Decision: None. If instituted, the FWD is due within 12 months of institution (~2028-03-19 if instituted at the 6‑month mark), extendable up to 6 months.
• Settlement / termination: None reported. No joint motion to terminate, no § 317 termination.
• Appeal: None. No Federal Circuit appeal — nothing is appealable yet. (Consistent with the prior section, which found no CAFC 2026 activity involving this patent.)
• Defensive value: Minimal as of today — no claim is canceled and no estoppel has attached, so a defendant cannot yet say "the troll has no case." The strategic value is that a major petitioner group ("Apple Inc. et al.") has now committed to an invalidity track at the Board, and the outcome of the institution decision will determine whether § 315(e)(2) estoppel and potential claim cancellation become available to the defense.

Note on the "et al.": the petitioner line reads "Apple Inc. et al.," indicating one or more additional petitioners/real parties‑in‑interest beyond Apple. The exact RPI list matters because § 315(e)(2) estoppel runs to the petitioner and its privies — co‑defendants not named as petitioners or RPIs would not be bound. Do not assume Samsung or any other defendant is covered until you confirm the RPI section of the petition.

Strategic summary

Claim status. Canceled: none. Sustained: none. Untested: essentially the entire patent — the Board has not touched a single claim. That includes the token‑group independent claims (1, 9, 11 as previously identified) and the cellular‑network‑adapter claims asserted in the 2026 suits (claim 23 per the earlier section's complaint‑derived reconstruction, which should still be verified against official text). No claim of 8,151,345 has been narrowed or invalidated by any IPR.

Estoppel landscape. No estoppel has attached. § 315(e)(2) estoppel only arises after a Final Written Decision; a mere petition confers nothing. This cuts both ways today:

• If IPR2026-00500 is instituted and reaches an FWD, Apple and any named RPIs/privies will be barred from asserting in the district court case any ground they raised or reasonably could have raised (§ 102/§ 103 on patents and printed publications) — a meaningful constraint given the parallel W.D. Tex. (7:26-cv-00075, Judge Albright) and E.D. Tex. (2:26-cv-00157, Judge Gilstrap) suits.
• Until then, all prior‑art grounds remain available to parties who are not petitioners/RPIs, and even to Apple pre‑FWD.
• Watch for a Sotera‑type stipulation from Apple (as it has filed in other 2026 IPRs). Such a stipulation removes much of the discretionary‑denial risk under Fintiv/Magnolia but, per Ingenico v. IOENGINE (Fed. Cir. 2025), does not necessarily sweep in system‑art grounds.

Pattern signals. This is the first AIA petition ever filed against 8,151,345, roughly 14 years after issuance and within months of the 2026 assertion wave — a classic "assertion first, IPR response second" sequence. There is a single petitioner group (Apple et al.); no serial/duplicative petitions on this patent are evident; no defensive aggregator (Unified Patents, RPX) appears as petitioner in the PTAB record — Unified Patents appears only as the source of the litigation‑portal links on the patent page, which is a data feed, not a filing. The patent's owner is a monetization entity (Mobility IP Holdings, Inc., recorded assignee as of 2026‑02‑11), which historically litigates rather than pivots to PTAB appeals — but no appeal exists yet.

Recommended next steps

1. Pull the actual petition and its mandatory notices from PTAB E2E: https://ptacts.uspto.gov/ptabweb/ — confirm (a) the challenged claims, (b) the grounds/statutory basis, (c) the complete RPI list behind "Apple Inc. et al.," and (d) any Sotera stipulation. The petition text is the only way to know what is actually being challenged; the structured data does not contain it.
2. Calendar the day‑zero milestones (PTAB's statutory clocks, 35 U.S.C. §§ 314, 316):
   • POPR due ~3 months from filing → on or about 2026-12-19 (waivable by patent owner).
   • Institution decision due ~2027-03-19 (6 months from filing; extendable to ~2027-09-19 for good cause).
   • If instituted, FWD due ~12 months from institution (~2028-03-19), extendable up to 6 months.
3. Monitor for Director discretionary denial. With parallel litigation in two Texas districts, Fintiv/Magnolia and the Tesla/Revvo line of decisions are live risk factors. A broad Apple stipulation materially reduces that risk; the absence of one raises it.
4. Check for companion IPRs on the patent family. The prior section notes US 8,548,924 was asserted alongside 8,151,345 in the 2026 suits; a coordinated petitioner group would likely file parallel petitions. The structured list covers only 8,151,345, so companions — if any — are outside this record.
5. CAFC tracker. No appeal exists today; the first possible appeal would follow an adverse FWD, i.e., no earlier than ~2028. There is nothing to link on CourtListener yet.

Caveats and contradictions flagged: (a) The only proceeding in the canonical list was filed on the same day as this analysis, so every merits‑level field (panel, grounds, institution, FWD, settlement, appeal) is genuinely "not yet public" — I have not inferred any of them. (b) I could not independently confirm the petitioner's full RPI list or the challenged claims via web search; searches for "IPR2026-00500" returned no substantive PTAB papers. (c) The earlier section's caution that claim 23's wording comes from a complaint‑derived table still stands — do not treat it as verified official text. (d) The earlier "Mobility IP Holdings + U.S. Encode" dual‑assignee listing remains an unresolved annotation on the patent page; the latest recorded assignment (2026‑02‑11, Neology → Mobility IP Holdings) is the best evidence of current ownership.

I'll research the assignment chain, the entities involved, and any NPE/asserter signals.

Let me dig into the entities in the chain and the assignment records.

Assignment & Ownership Analysis — US 8,151,345 B1 (Self-authorizing devices)

Source note before the detail: the four assignment events below are taken from the recorded-assignment entries surfaced on Google Patents' legal-events tab (which mirrors USPTO assignment data), cross-checked against the litigation record. I was not able to retrieve the underlying reel/frame numbers or the recorded correspondent-of-record for the 2016 and 2026 recordings from the sources reachable in this session. I am flagging that gap explicitly rather than inventing reel/frame citations. Everything else below is grounded in cited dates, dockets, and corporate records.

Verification entry points: USPTO Assignment Center · Assignment Search · Google Patents legal events for US8151345B1

Inventors

Findings and unusual patterns:

• The patent issued with the assignee listed literally as "Individual" on the Google Patents record. There is no employer/company on the face of the patent. For a payment-card/secure-element invention filed in January 2008, that is a notable pattern: it indicates the application was filed outside an employment-assignment chain, or that no assignment was recorded before grant.
• Yeager is a serial inventor-entrepreneur in the RFID/payments space, not a one-off inventor. His longitudinal portfolio (per USPTO.report/Justia inventor listings) shows Knoxville TN and later Austin, TX, and later filings under SimplyTapp, Inc. (HCE/digital-wallet pioneer) and OV Loop, Inc. (same "unexpected cryptogram" family, EP3996019A1 / US 20130054474). That profile matters: the 2016 assignment to "U.S. ENCODECORPORATION, YEAGER, DOUG" looks like the inventor moving his personal portfolio into his own vehicle, not an employer taking title.
• No inventor-departure pattern is present in the ordinary sense (there is only one inventor and he was never a corporate assignor of record until 2016). The relevant anomaly is the inverse: an inventor-held asset sat unassigned from 2008 until 2016, then changed hands three times in ten years.

Original assignee

• Entity on the issued patent: the individual inventor, C. Douglas Yeager (Google Patents lists original assignee as Individual).
• Primary line of business / product: the specification is a product-centric disclosure (a USB "self-swiping" smart token that presents as an HID keyboard device and auto-populates a web form). Yeager's later vehicle for the concept appears to have been U.S. Encode Corporation, the entity he assigned into in October 2016. I could not confirm whether U.S. Encode Corporation ever shipped a commercial product embodying the claims, and I could not retrieve its corporate status (operating / dissolved / acquired).
• Current status of the original assignee entity: not applicable in the corporate sense — the "original assignee" was a natural person. Yeager subsequently appears in connection with SimplyTapp, Inc. and OV Loop, Inc. (both operating fintech companies).

Assignment timeline

Three post-issuance recorded assignments. Reel/frame not retrieved — do not treat the frame numbers as verified.

• 2016-10-14 (executed) / recorded 2016-10-14 — Reel/Frame not retrieved

  • Conveyance: Assignment of Assignors' Interest
  • Assignor: C. Douglas Yeager (individually)
  • Assignee: U.S. Encode Corporation (recorded jointly with "Yeager, Doug")
  • Correspondent: not retrieved from the record. The prosecution attorney of record on the issued patent is Luedeka Neely Group, P.C. (Knoxville, TN), per the Justia patent-history block; whether that firm acted as assignment correspondent is unverified.
  • Context: Internal consolidation — the individual inventor moving his personally held portfolio into his own corporation (first link of a two-hop conduit).

• 2016-10-19 (executed) / recorded 2016-10-19 — Reel/Frame not retrieved

  • Conveyance: Assignment of Assignors' Interest
  • Assignor: U.S. Encode Corporation and Doug Yeager
  • Assignee: Neology, Inc. (Delaware corporation, San Diego, CA)
  • Correspondent: not retrieved. Same-recording-week pair with the 2016-10-14 entry — the two recordings almost certainly share a correspondent, but I cannot cite a name; this is the single most valuable unverified field for the repeat-correspondent test.
  • Context: Sale/transfer to an operating company. Five days after taking title, U.S. Encode Corporation flipped the asset to Neology. This makes U.S. Encode a transient conduit entity, not a real acquirer.

• 2026-02-11 (recorded) — Reel/Frame not retrieved (execution date not retrieved)

  • Conveyance: Assignment of Assignor's Interest
  • Assignor: Neology, Inc.
  • Assignee: Mobility IP Holdings, Inc.
  • Correspondent: not retrieved. Diagnostic note: Mobility IP Holdings' litigation counsel of record in E.D. Tex. include Howard Neil Wisnia (appearance 4/2/2026), Jason McManis, Weining Bai, Justin Cale Kenney, Warren Joseph McCarty III, and Abanoub Henry (docket entries 9–12, 17 of 2:26-cv-00157). These are litigation appearances, not assignment correspondents — do not conflate them. Wisnia and McManis-based filings recur in plaintiff-side patent dockets and are worth running against a Unified Patents / RPX high-frequency-plaintiff list.
  • Context: Transfer-to-asserter / monetization carve-out, executed and recorded 16 days before the first infringement suit.

Reconciliation of the earlier "both assignees" oddity: Google Patents' Current Assignee field lists both Mobility IP Holdings Inc and US Encodecorporation. That is an aggregation artifact of all recorded assignees ever appearing in the chain, not a competing live ownership claim. The 2026-02-11 record from Neology to Mobility IP Holdings is the operative one.

Chain of title by ownership, in plain sequence:
Yeager (individual) → U.S. Encode Corporation (5 days) → Neology, Inc. (2016–2026) → Mobility IP Holdings, Inc. (2026–present)

Timeline diagram

timeline
    title Ownership of US 8151345
    2007 : Provisional filed by Yeager
    2008 : Nonprovisional application filed
    2012 : Patent issues to Yeager
    2016 : Yeager assigns to US Encode Corp
         : US Encode assigns to Neology Inc
    2026 : Neology assigns to Mobility IP Holdings
         : Suit filed vs Samsung
         : Suit filed vs Apple

NPE / troll-pattern signals

1. Shell-entity transfer — PRESENT (qualification noted).
The patent moved from an operating company (Neology, Inc., a Delaware RFID/tolling company) to Mobility IP Holdings, Inc., recorded 2026-02-11. The concrete, non-name-based evidence is behavioral: Mobility IP Holdings' only visible activity is filing suit on the acquired asset within three weeks — Mobility IP v. Samsung, No. 2:26-cv-00157 (E.D. Tex., filed 2026-02-27) and Mobility IP Holdings v. Apple, No. 7:26-cv-00075 (W.D. Tex., filed 2026-03-04). Korean trade press covering the Samsung filing describes the plaintiff flatly as an NPE ("미국 특허관리형법인") that acquired the former Neology patents (Seoul Wire, 2026-03-01). Qualification: the "holdings/IP suffix + registered-agent address + single-member DE/TX LLC" particulars were not verified — I could not retrieve Mobility IP Holdings' incorporation state, formation date, or address.

2. Known asserter in the chain — NOT PRESENT (as to the enumerated lists) / UNCLEAR (as to current Unified–RPX listings).
No link in the chain matches the enumerated roster (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). Neology, Inc. is itself an operating company that has asserted patents — but against actual competitors, e.g. Neology, Inc. v. Federal Signal Corp., No. 11-672-LPS (D. Del., preliminary-injunction and § 101/obviousness rulings), ITC Inv. No. 337-TA-971 against Kapsch TrafficCom / Star Systems (filed 2015), and Neology v. Kapsch, CAFC No. 18-1338 (2019, nonprecedential, affirmance). That is competitor litigation, not NPE conduct. Mobility IP Holdings is too new (2026) to appear on most published high-frequency-plaintiff lists.

3. Repeat correspondent across the chain — UNCLEAR (unverified; priority item).
The recorded correspondents for the 2016-10-14, 2016-10-19, and 2026-02-11 recordings were not retrievable here. Two of the three recordings occurred five days apart and involve the same principals, so a single recurring correspondent on those two reels is highly likely — but likelihood is not evidence, and I will not state a firm or attorney name as a finding. This is the single highest-value field to pull from Assignment Center. Prosecution counsel of record was Luedeka Neely Group, P.C. (Knoxville, TN); Mobility IP's litigation counsel (Wisnia, McManis, Bai, Kenney, McCarty, Henry) should be run separately against NPE plaintiff rosters.

4. Cascading transfers — PRESENT.
Two consecutive assignments in five days: 2016-10-14 (Yeager → U.S. Encode Corporation) immediately followed by 2016-10-19 (U.S. Encode Corporation + Yeager → Neology, Inc.). A conduit entity that holds title for less than a work-week is a classic clean-up/sale conduit. A longer-gap cascade also exists across the record (2016 → 2026, a ten-year hold).

5. Pre-litigation transfer — PRESENT (strongest signal).
Assignment recorded 2026-02-11 (Neology → Mobility IP Holdings); first infringement suit filed 2026-02-27 (v. Samsung, E.D. Tex.); second filed 2026-03-04 (v. Apple, W.D. Tex.). 16 days from recording to first complaint — comfortably inside the six-month window, and consistent with arranging standing and filing venue in Marshall and Midland. The asserted set is a portfolio-wide campaign, not a single-patent dispute: per the Seoul Wire report and the complaints, Mobility IP asserted US 8,151,345, 8,548,924, 8,766,772, 8,933,807, 10,235,513, 10,706,412, and 10,762,187 — seven patents, reportedly all originating from Neology. Note that US 8,548,924 (Self-authorizing token) is the direct continuations-family sibling of the patent at issue (filed 2012-02-23, granted 2013-10-01, same inventor), also acquired by Mobility IP.

6. Bankruptcy fire-sale — NOT PRESENT / UNCLEAR.
No evidence that Neology, Inc. or its parent SMARTRAC N.V. filed Chapter 7/11, or that these patents were sold in insolvency proceedings. The verified corporate events are ordinary M&A: SMARTRAC N.V. agreed to acquire a majority of Neology in December 2011 (SMARTRAC press release, 2011-12-08), and One Equity Partners acquired Neology in September 2017 (Tracxn acquisition record, 2017-09-21). Because the 2026 transfer is a sale out of a private-equity-owned operating company rather than a bankruptcy estate, this signal stays not present — but "PE-owned seller divesting non-core mobile-payments patents" is a plausible commercial motive and should be checked against Neology/OEP disclosure if available.

7. Privateering — UNCLEAR.
The pattern (operating company → litigating entity → suits against Apple and Samsung) superficially fits privateering. It is weakened by business logic: Neology's operating business is RFID tolling, electronic vehicle registration, and ALPR, so it is not an operating competitor of Apple or Samsung in mobile payments, and it has no obvious product rivalry advanced by these suits. A straight portfolio monetization/carve-out is at least as likely as privateering. No SEC filing or Patent Progress/EFF coverage was found tying Neology to Mobility IP's enforcement.

8. Defensive aggregator — NOT PRESENT.
The chain terminates at Mobility IP Holdings, Inc., an active plaintiff. There is no RPX, AST, LOT Network, Unified Patents, or OIN entity anywhere in the chain. The asset is the opposite of neutralized — it is in active assertion.

Verdict

NPE — high confidence.

Two strong, date-specific signals drive the call. First, pre-litigation transfer: the assignment from operating company Neology, Inc. to Mobility IP Holdings, Inc. was recorded 2026-02-11, and Mobility IP filed on the acquired portfolio against Samsung (2026-02-27, E.D. Tex.) and Apple (2026-03-04, W.D. Tex.) — 16 days later, with the plaintiff described as an NPE in trade press. Second, shell/assertion-entity transfer: an entity with no visible product or operating business took a multi-patent mobile-payments portfolio out of an RFID-tolling operating company and immediately began asserting it, backed by a five-day conduit transfer (2016-10-14 → 2016-10-19) that shows deliberate ownership-chain engineering. Confidence is capped short of absolute only because the reel/frame numbers, correspondent-of-record identity, and Mobility IP Holdings' corporate particulars could not be retrieved here — pulling those three fields from USPTO Assignment Center would confirm or break the repeat-correspondent signal (item 3), which is currently unresolved.

Caveats: no reel/frame, correspondent, or execution-date data for the 2016 and 2026 recordings was retrievable in this session; the assignee names, dates, and conveyance types are as indexed by Google Patents' legal-events tab and should be confirmed on the Assignment Center record. I have not verified Mobility IP Holdings' state of incorporation, formation date, or registered agent, and I have not verified whether U.S. Encode Corporation still exists.

I'll research the prior-art citations for US 8,151,345 B1. Let me pull the patent's reference lists from several sources.

Let me try to retrieve the actual front page / "References Cited" list for this patent.

I have the claim set. Now let me locate the patent's front-page "References Cited" (the examiner/applicant citations).

Sourcing status for this task (read first)

The instruction was to pull the USPTO "References Cited" (front-page (56)) list for US 8,151,345 B1 and analyze each cited reference under § 102. I attempted this across Google Patents, Justia, FreePatentsOnline, SumoBrain, Golden, USPTO.report, and targeted Google/Bing queries for the patent's front-page citation block, plus a search for the patent's PDF on patentimages.

Result: I could not obtain the authoritative (56) "References Cited" list for this patent. The full text supplied to me for US8151345B1 (Google Patents render) does not include the bibliographic "References Cited" block — it begins at the Classifications/Definitions, then the abstract and description. Live search returned (a) other patents' IDs lists, (b) the patent's own "Cited By"/family-equivalent tables, and (c) the full claim text — but not the list of U.S. patent documents the examiner/applicant cited against 8151345 during prosecution.

Per my operating rules I am not going to reconstruct that list from memory or infer it — that would be fabrication. Below I give (1) what I could verify, (2) the prior art the patent itself identifies, (3) a § 102 framework, and (4) exactly where to get the authoritative citations.

I also flag a metadata inconsistency with the previously generated section: the prior section used "current date 2026-09-19" (fetched), while this task states April 26, 2026. No substantive impact, but noted.

1. Confirmed claim set (needed to map any § 102 reference)

Retrieved verbatim from Justia (patents.justia.com/patent/8151345), confirming the independent-claim structure flagged in the prior section:

• Claim 1 (independent, token): mounting structure + communication connector; secure element with a data file; secure element reader that interrogates the SE "by executing file system functions comprising a command to select a payment card application according to ISO 7816-4"; communications controller converting file information to transaction information; wherein the connector is USB, the controller is an HID-class USB device, and it provides the transaction information "in a format that auto-populates a form field."
• Claim 9 (independent, token): same token architecture; SE data file contains financial authorization data; controller extracts and encrypts at least a portion and transmits the encrypted data as transaction information; auto-populates a form field.
• Claim 11 (independent, token): USB connector; SE data file; controller configured as HID-class USB device, converts part of the data file to transaction information and transmits it "through the USB connector as keyboard emulation," auto-populating a form field.
• Dependent claims 2–8 (pendant to 1): prescribed cadence (2, 5); encryption of financial authorization data (3, 4); encrypted unpredictable number constructed as a hash of a timestamp (6); encryption from a timestamp and transaction counter (7); reader awaits a startup instruction comprising an unpredictable number from the computer terminal (8). Claims 10, 12–14 pend from 9/11 analogously.
• The cellular-network-adapter independent claim (the prior section identified it as claim 23, reconstructed from a 2026 complaint chart — still unverified against official text) covers SE + ISO 7816-4 reader + NFC controller bridge chip converting file information to an RF signal for an external reader + communications controller transmitting over a wireless network, with an "await a startup instruction comprising an unpredictable number" limitation.

Consistency check with prior section: the confirmed claims 1/9/11 track the prior section's description. The claim-23 caveat in the prior section stands — I still could not verify it from an official source.

2. Prior art the patent itself identifies (intrinsic, verifiable from the specification)

These are the references the applicant expressly names as the relevant art. They are the substantive § 102 candidates. Full citation / date / description / mapped claims:

Key analytical point: the specifications above are standards and data formats, i.e., § 102(b) printed publications. Each supplies one claimed element (protocol, connector type, format). None alone contains the full combination of a card-resident reader + HID-keyboard-class emitter + auto-populating form field, which is the actual point of novelty in claims 1/11. So on the intrinsic record, these references are strong § 103 material and element-level § 102 material, but not standalone full-claim § 102 anticipation — except to the extent an un-identified examiner-cited patent/application discloses the whole combination.

3. Documents that cite US 8,151,345 (forward citations) — NOT § 102 art against it

Search surfaced tables (on Google Patents pages for documents such as DE60107106D1 and US20160342560) listing documents alongside US8151345B1. These appear to be "Cited By"/similar-document rows, i.e., later documents that cite 8151345 — not the references 8151345 cited. I list them only to document the field and to be explicit that they cannot anticipate 8151345 under § 102 because they postdate its Jan. 25, 2007 priority:

• US20100131414A1 — Personal identification device for secure transactions (Gavin Randall Tame), priority 2007-03-14, pub. 2010-05-27.
• US7726568B2 — Smart card session optimization (Research In Motion), 2007-03-21.
• US20090190277A1 — ESD Protection For USB Memory Devices (Super Talent Electronics), 2007-09-28.
• US8213902B2 — Smart card accessible over a personal area network (Red Hat), 2007-08-02.
• EP2026240A1 — Method for booting portable objects with multiple communication interface (Axalto), 2007-08-03.
• US8364989B2 — Power supply input selection circuit (Infineon), 2007-09-26.
• CN101276319B (2008-02-05, Beijing Feitian), JP2009207090A (2008-02-29, Seiko Epson), DE102008026785A1 (2008-06-04, Giesecke & Devrient), EP2180410A1 (2008-10-27, Gemalto), KR101555637B1 (2009-03-27, Samsung), FR2949011B1 (2009-08-07), DE102010009492A1 (2010-02-26, Austria Card), CN101840387B (2010-04-07, Beijing Tian Di Rong), US8631284B2 (2010-04-30), US8762682B1 (2010-07-02).
• Also surfaced as citing/similar: JP4347350B2 (2007-02-15), US20080270596A1 (2007-04-25), US7865351B2 (2007-12-30), US8402552B2 (2008-01-07), EP2508987A1 (2008-04-04), CN101382904B (2008-09-28), US8370532B1 (2009-10-27).

Caveat on this table: I could not confirm from the page context whether these rows are the "Cited By" list for 8151345 or a mixed "similar documents" table. Treat the list as indicative of the citing field, not as an authoritative citation report. Two entries (Tame 2007-03-14 and RIM 2007-03-21) fall between the Jan. 25, 2007 priority date and the Jan. 24, 2008 filing date — if any of these was a U.S. application published/filed before 8151345's filing, it could be § 102(e) art, which is the only way any of them could matter against 8151345. That determination requires the actual citation and priority records.

4. Bottom line on "which claims each reference anticipates"

I cannot responsibly assign specific § 102 anticipatory claim mappings to the examiner-cited patent references, because I was unable to retrieve that citation list. What I can state with confidence:

1. No single one of the references identified in the patent's own specification appears to anticipate claims 1, 9, 11, or the cellular-adapter claim in full. Each supplies only an element (ISO 7816-4 protocol; USB connection; HID class; Track 1/2 format; DES-OFB; Luhn; EMV app selection). The claimed combination — a card/token-resident SE reader that drives a USB-HID keyboard emitter to auto-populate a web form — is not disclosed by any standard cited.
2. The HID-class/keyboard-emulation + auto-populate limitation (claims 1 and 11) and the on-card PAN encryption that preserves bank routing code and recomputes the Luhn check digit limitation (claims 9/13, with FIGs. 13–13.4) are the two limitations most likely to withstand minimal § 102 art — and the two most likely to be attacked with § 103 combinations in the pending litigation (Mobility IP Holdings v. Apple, 7:26-cv-00075; and the E.D. Tex. Samsung case, 2:26-cv-00157, per the prior section).
3. The cellular-adapter claim's "await a startup instruction comprising an unpredictable number" limitation (claim 8 analog; claim 23) is the most vulnerable to prior art describing host-initiated/unpredictable-number card interrogation (2-way HID class interfaces; EMV dynamic CVC/DCVC flows), which the spec itself describes at FIG. 14.

5. How to obtain the authoritative (56) list (recommended next step)

To complete this task rigorously, the citation list must be pulled directly:

• USPTO Patent Public Search (ppubs.uspto.gov) — search 8151345; open "US Patents" full document → "Front Page" / "References Cited."
• USPTO PatentCenter — Application 12/019,318, "Documents & Transactions" → the issued patent front page and any PTO-892 "Notice of References Cited" in the file wrapper (this gives the examiner-applied citations, which are the § 102/§ 103 references).
• Google Patents → US8151345B1 → "Citations" tab (the render supplied to me omitted it) — separates "Patent Citations" (cited by) from "Cited By."
• Patent PDF (patentimages.storage.googleapis.com) — page 1 columns 1–2.

Once I have that list, I can produce the requested table (full citation, pub/filing date, description, § 102 mapping to claims 1/9/11/23) with grounded precision.

6. Caveats (explicit)

• I did not obtain the (56) "References Cited" list. Any claim-by-claim § 102 mapping against the examiner's cited references is therefore unavailable and I have not fabricated one.
• The forward-citation table in § 3 is drawn from search snippets whose page context (Cited By vs. Similar Documents vs. family list) I could not confirm; treat it as indicative only. Those documents postdate 8151345 and are not § 102 art against it.
• The cellular-adapter independent claim is still identified as claim 23 on the strength of the prior section's complaint-chart reconstruction; the Justia text I retrieved covers dependent claims through at least claim 14, so the cellular-adapter claims sit later in the set and their exact numbering is unverified.
• All § 102 characterizations above are analytical, based on the patent's own text and the identified standards; none is a substitute for a citation-by-citation validity analysis against the actual prosecution record.

I'll ground this analysis in the actual prior-art record for this patent before reasoning about combinations.

Let me pull the specific citation lists and the claim text for the full independent claim set.

Obviousness Analysis — U.S. Patent No. 8,151,345 B1 (“Self-authorizing devices”)

Analyst note on sourcing (read first). My searches did not return a clean, page-level “Prior Art” / “Patent Citations” block for the '345 itself. The citation data I did retrieve is from the Google Patents page for sibling case US 8,548,924 B1 (“Self-authorizing token”), which shares the '345 specification, priority, and family (US8548924 on Google Patents). I therefore treat that list as the best available proxy for the family’s prior-art record and label each item as to whether it is verified, inferred, or flagged. Anything I could not verify is called out rather than asserted. I also flag one hard contradiction with the earlier section and one date inconsistency in the task framing.

1. Legal framework and priority date

Two consequences matter for every ground below:

1. Only references with a pre-Jan-25-2007 date or a pre-2007 U.S. filing date can be § 102/§ 103 art. Several documents appearing in the family’s citation list fail this test and cannot be used by a petitioner (see § 4).
2. The '345 specification contains substantial applicant-admitted prior art (AAPA) — that readers were needed for SEs, that ISO 7816/14443 define the interfaces, that ISO 7816-4 defines file-system and security-service APIs and APDU message structures, that HID is a standard USB class, and that MasterCard/VISA/AMEX applications are provisioned onto SEs by entities like First Data. Under the PTO’s September 2025 memo this AAPA generally cannot supply a missing claim limitation in an IPR, but it remains strong evidence of the level of ordinary skill and of motivation to combine — precisely the permitted uses.

2. Person of ordinary skill in the art (POSA)

Working definition (should be confirmed against the parties’ proposals in the 2026 suits): a person with a bachelor’s degree in electrical engineering or computer science and 2–4 years’ experience in smart-card / secure-element systems and USB device design, or equivalent. The POSA would know:

• ISO 7816-3/7816-4 (contact) and ISO 14443 (contactless) APDU exchanges, including the ISO 7816-4 SELECT by AID command used to select an EMV payment application;
• USB device classes, including the HID keyboard class and the fact that HID keyboards require no host drivers;
• The commercial availability of dual-mode smart-card interface controllers that bridge ISO 7816 and USB.

3. Claim scope restated (element-level), with verified text

Claims 1, 9, 11 and (per Justia) 17 are independent; claim 1’s full text is verified from Justia’s copy:

• Claim 1: mounting structure + integral USB connector; SE affixed with a data file; SE reader affixed to the mounting structure configured to interrogate the SE by “executing file system functions comprising a command to select a payment card application according to ISO 7816-4”; communications controller affixed, converting file information → transaction information, transmitting via the USB connector, configured as an HID-class USB device, and “configured to provide the transaction information in a format that auto-populates a form field defined by an application running on the computer terminal.”
• Claims 2, 5, 10, 12: prescribed cadence of delivery.
• Claims 3, 4, 13: SE data file = financial authorization data; controller extracts and encrypts it (claim 4 recites the USB connector variant).
• Claims 6, 14: transaction information = encrypted unpredictable number constructed as a hash of a timestamp.
• Claims 7, 15: encryption constructed from a timestamp and a transaction counter.
• Claims 8, 16: reader awaits a startup instruction comprising an unpredictable number originating from the computer terminal before interrogating.
• Claim 11: USB connector + SE + HID-class controller transmitting “as keyboard emulation,” auto-populating a form field.
• Claim 17: token variant (verified only in part).

⚠ Contradiction to flag. The earlier section describes claim 23 as an independent cellular-network-adapter claim with an NFC bridge chip and an “await an unpredictable number over the cellular wireless network” limitation, reconstructed from a 2026 complaint chart. Justia’s retrieved text shows independent claims at 1, 9, 11 and 17. I could not verify the existence, numbering, or wording of claim 23 in this session, and I cannot exclude that the complaint chart conflated claim 17 (or a later claim) with claim 23. Treat all claim-23 analysis below as provisional and dependent on confirming the official claim text in PatentCenter.

⚠ Date inconsistency to flag. The task states the current date is April 26, 2026, while the system date is 2026-09-19, and the earlier section cites E.D. Tex. docket activity from June 2026. I have proceeded without reconciling these.

4. The available prior art, sorted for pre-AIA usability

Retrieved from the US 8,548,924 citation block (family-level; the '345’s own list was not fully retrievable — verify against the '345’s “References Cited” face page before relying on any of this):

Why this matters: the family’s citation list mixes genuine art with post-dating references that are legally unusable against the '345 (EP 1 804 220 A1, US 2010/0207742 A1) and one date-sensitive item (US 2007/0084925 A1). A petitioner who lifts the family citation list wholesale will hand the patent owner an easy rebuttal. This sorting is the single most useful contribution I can make from the available data.

Also note: none of the retrieved citations is a dynamic-CVV / dCVV reference. The '345’s encryption claims (3–7, 13–15) are best attacked with art outside this list — e.g., the Visa/Inovant Brown family (US 6,631,849; US 2005/0082360 A1) — which I could not verify on this page’s prior-art record and therefore flag as unconfirmed.

5. Proposed § 103 grounds

Ground A — Claims 1–8 and 11–16 (USB/HID token claims)

Combination: Aladdin '399 + Aladdin '266 + O2Micro '397 + STMicroelectronics '464/'715, optionally + Axalto '247 and Feitian CN 1808973 A.

Motivation to combine (KSR “design incentive / market force”):

1. The problem was stated in the field: harden card-not-present internet transactions to approach card-present security (the '345 admits the interchange-fee differential). That is an explicit market incentive to move the reader onto the card.
2. Avoid driver installation: HID class is natively supported, so the token works “without requiring any special drivers or operating system updates” — the specification’s own stated benefit, and the reason to select HID over mass-storage.
3. The building blocks were off-the-shelf at the critical date: dual-mode ISO 7816/USB controller ICs (O2Micro '397; STM '464/'715) existed precisely to combine smart-card and USB functionality.
4. Auto-populating a form field is the predictable result of presenting a keyboard-interface device to a host with focus in a form — a “predictable use of prior art elements according to their established functions” (KSR).

Anticipated patent-owner rebuttal: the references are said to be in different fields (USB memory keys vs. smart cards vs. form-fill), so no motivation; and no single reference teaches both on-card interrogation and keyboard-emulation form-fill. A petitioner should meet this with (a) Feitian CN 1808973 A, which bridges that gap pre-priority, and (b) the '345’s own admissions as evidence of the POSA’s knowledge.

Ground B — Claims 3–7, 9, 10, 13–15 (encryption, dCVV, timestamp, transaction counter)

Combination: Ground A + a dynamic-CVV / cryptogram reference (Visa/Inovant Brown family — UNCONFIRMED against this page’s prior-art section) + US 7,527,208 (Visa) + AAPA (the spec’s own FIG. 13 / 13.1–13.4 discussion of DES-OFB with an XORed transaction counter, retaining the bank routing code, and recomputing the Luhn check digit).

• Claims 7, 15 (timestamp + transaction counter): A transaction counter combined with a time value as the input to a cryptogram is standard dCVV practice that the specification itself presents as known (“the algorithm to create a DCVV typically uses a UN, a transaction counter, and DES key”).
• Claims 6, 14 (UN = hash of a timestamp): hashing a timestamp to obtain an unpredictable number is a routine substitution of a known nonce source; both a timestamp and a random UN are disclosed in the art as UN sources, and the specification acknowledges predictable trade-offs (“It may not be possible to use a timestamp in all embodiments if the interrogator does not have access to an accurate clock”).
• Claims 3, 4, 13: encrypting extracted financial data before transmission over an untrusted network is the entire purpose of the ROC concept and is squarely obvious in view of dCVV art + the network-security incentive.

Caveat: because the retrieved citation list contains no verified cryptogram reference, Ground B is the least supported ground here and depends on art I could not confirm on the page.

Ground C — Claim 8 / claim 16 (await a startup instruction with a UN from the host)

Combination: Ground A + two-way HID (interrupt OUT endpoint) art + dCVV art.

• The specification itself concedes the alternative: a generic HID class supporting both an “in” and an “out” endpoint, and the observation that the standard HID keyboard class is “typically a 1-way device… ‘in’ endpoint only,” such that “the interrogation most likely starts at the time the USB device is plugged into the computer and cannot be initialized by the PC.”
• Once a two-way HID channel is selected, host-initiated interrogation with a supplied nonce is the obvious next step and is expressly described in the admitted art (VISA/MASTERCARD dynamic-CVC flows).
• Risk to petitioner: claim 8’s “await a startup instruction… prior to interrogating” is a temporal/ordering limitation. Expect the patent owner to argue the art discloses host-initiated commands but not a reader that withholds interrogation pending a nonce-bearing startup instruction.

Ground D — Cellular-network-adapter claims (provisional; contingent on verifying claim numbering)

Combination: US 7,527,208 (Visa) (contactless bank-issued payment card; §102(e) art) + US 8,081,060 B1 (Nokia) (communications establishment; §102(e) art) + US 8,059,835 B2 (Thibaudeau) + Ground A’s on-card reader teachings.

• Do not use EP 1 804 220 A1 (AXSionics) or US 2010/0207742 A1 (Motorola) — both post-date the '345’s priority date and are legally unavailable (see § 4). Any chart built on the family citation list that includes them is legally defective.
• NFC bridge chip limitation: if present as alleged, US 7,527,208 supplies a contactless/dual-interface payment card, and POSA knowledge supplies the RF bridge from ISO 14443 to an external reader.
• UN “originating over the cellular wireless network”: this is the most defensible limitation for the patent owner. Support would have to come from Nokia '060 plus standard challenge-response/nonce practice.

6. Obviousness weaknesses and counter-considerations

1. Claim 1’s “command to select a payment card application according to ISO 7816-4.” If the art teaches only generic ISO 7816-4 file-system access (read/select files) without payment-application selection by AID, the petitioner must prove that EMV SELECT-by-AID was routine and conventional before 2007. The '345’s own admission that MasterCard/VISA/AMEX applications are provisioned onto SEs is helpful but, under the September 2025 PTO memo, AAPA alone cannot fill the gap in an IPR.
2. “Affixed to the mounting structure” for the reader. The specification deliberately broadens this to cover the reader/interrogator/controller being integrated into a single chip or into a phone’s baseband processor. A petitioner should not concede a narrow construction; conversely, under the broadest reasonable/Phillips construction, the limitation is easy to meet but so is the prior art.
3. Secondary considerations. Expect the patent owner to assert: (a) commercial success of SE-based mobile wallets reading on this patent’s disclosure chain; (b) the card-present interchange benefit; (c) licensing to Neology/U.S. Encode; and (d) the 2026 assertions against Apple and Samsung. The nexus argument is the battleground — In re Kao; ClassCo v. Apple; and the PTAB’s repeated holding that secondary considerations “cannot overcome a strong prima facie case” (Wyers v. Master Lock). A patent owner will struggle to show nexus where the claimed elements (USB token + HID + reader) were individually known; the counter-argument is that the combination drove adoption.
4. § 325(d) / Advanced Bionics risk. The family citations (Aladdin, Axalto, STMicro, O2Micro) appear to have been of record in the '924 prosecution. If they were also before the examiner in the '345, a petitioner must show material examiner error, not merely re-argue them. Verify whether each reference appears on the '345’s own face page before filing.
5. Un-retrieved independent claims. Claim 17 (verified partially) and any cellular-adapter independent claims were not fully retrieved. The grounds above are incomplete for those claims until the official claim text is confirmed.

7. Bottom line

• Strongest § 103 ground: Aladdin '399 + Aladdin '266 + O2Micro '397 (with STMicro '464/'715 and Axalto '247)** + Feitian CN 1808973 A** against claims 1 and 11 and their dependents. The motivation is supplied by the specification’s own stated design incentive (adapt smart-card security to internet transactions), the driver-free advantage of HID, and the commercial availability of dual-mode ISO 7816/USB controllers. The most vulnerable claim element is the HID-keyboard-emulation auto-population of a form field, which the specification itself treats as a known technique, and Feitian CN 1808973 A supplies pre-priority published support.
• Weaker grounds: the encryption/dCVV claims (need art not present in the retrieved family citation list) and the host-supplied-UN / two-way interrogation claims (ordering limitation).
• Legally unusable on the retrieved dates: EP 1 804 220 A1 (published 2007-07-04) and US 2010/0207742 A1 (priority 2009-01-26). US 2007/0084925 A1 and GB 0600207.0 require date verification before use.
• Highest-value, lowest-cost next step for a real petition: obtain the '345’s official face-page reference list and full claim set from USPTO PatentCenter, confirm whether claim 23 exists and reads as reconstructed, and confirm the priority-chain dates for US 2007/0084925 A1. Everything above is conditioned on those confirmations.

Confidence statement: the bibliographic, priority, and verified claim-1/claim-11 text is high confidence (patent text and Justia). The reference-by-reference disclosure characterizations are medium-to-low confidence — I have described each reference by its title/assignee/date and by what its subject matter necessarily entails, and I have explicitly marked the elements for which I am relying on domain knowledge rather than a retrieved passage. No column/line citations are offered because I could not retrieve them, and I have not fabricated any.