Invalidity dossier

US 8725813

Communications grouped as conversations

Current assignee: Microsoft Technology Licensing LLC

Added 9/24/2026, 4:55:15 PM

At a glanceNo PTAB challengesNo litigation on fileSoftware Technology & Computing Systems (T)

Active provider: DeepSeek · deepseek-v4-flash

Patent summary

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

✓ Generated

I'll search for authoritative information on this patent number.

US Patent 8,725,813 — Summary

Sourcing note: I retrieved bibliographic data from Google Patents (patents.google.com/patent/US8725813/en) and uspto.report (patent grant 8,725,813), and the granted claim text from Justia Patents (patents.justia.com/patent/8725813). I did not find any CAFC 2026 docket, appeal, or district-court litigation referencing patent 8,725,813 in any search result. I cannot query PACER or the CAFC docket system directly, so I cannot state with certainty that no such proceeding exists — only that nothing surfaced for this exact number. I also found no PTAB proceeding (IPR/PGR) against it.

Bibliographic data (literal identifiers)

Field Value
Patent number US 8,725,813 B2
Title Communications grouped as conversations
Application number US 12/242,676
Priority / filing date 2008-09-30
Issue (grant) date 2014-05-13
Pre-grant publication US 2010/0082759 A1 (2010-04-01)
Original assignee Microsoft Corporation
Current assignee Microsoft Technology Licensing, LLC (assignment recorded 2014-12-09; effective 2014-10-14)
Inventors Selvaraj Nalliah; Shivakumar Seetharaman; Salman Zafar; John Allen Atwood; David P. Limont; Joseph T. Flint; Alexandru Leconiuc
Claims 20 (3 independent: 1, 8, 13)
Status Active; "adjusted expiration 2030-01-13" per Google Patents (legal status is an assumption, not a legal conclusion)
Family Continuations US 9,870,124 B2; US 10,430,032 B2; US 11,194,446 B2 (all claiming the same 2008-09-30 priority)

Abstract (as issued)

Described are embodiments for displaying groups of communications, such as messages, as a conversation. Conversations are groups of communications that can be traced back as related to an original communication. The embodiments allow a user to select a conversation mode for displaying communications, e.g., messages, as conversations. In response to the user's selection, embodiments provide for displaying a graphical element associated with a conversation. The graphical element can be selected to display the messages associated with the conversation. Additionally, embodiments provide for selecting a conversation and applying actions to the conversation, resulting in the application of the action to the messages that are associated with the conversation.

Plain-language overview of the independent claims

Claim 1 — Mobile device configured to access e-mail messages (a device claim: display + processor + computer storage medium).
The device:

  1. Receives a selection of a "conversation display mode" that organizes e-mail messages into groups related to conversations (claim text literally reads "related to a conversations").
  2. Accesses multiple e-mail messages, each carrying a conversation identifier that associates it with a conversation.
  3. Uses those identifiers to identify a conversation.
  4. Displays a graphical element for the conversation.
  5. Receives a selection of that graphical element, where the element includes an icon indicating "roll-up information" — specifically (as claimed) that at least one message in the conversation has an attachment.
  6. In response, displays graphical elements for the related e-mail messages, arranged in a tree hierarchy (a reply shown indented and below the communication it replies to).
  7. Displays a menu of actions applicable to the conversation, including an "ignore the conversation" action.
  8. On receiving selection of "ignore," does not download additional messages related to the conversation.

Claim 8 — Computer readable storage medium (explicitly "does not consist of a modulated data signal," i.e., a statutory-storage-media claim; instructions performed by a processor). This is server-side and covers:

  1. Receiving a message from a client for sending to a recipient; including a conversation identifier in the message; sending it.
  2. Receiving a reply message that contains the same conversation identifier.
  3. Receiving a request for messages related to the conversation, where the request includes the conversation identifier.
  4. Identifying the message and reply using that identifier and, in response to the request, sending information from them to the client.
  5. Receiving an indication that the conversation is to be ignored; then receiving a new message related to the conversation; and, in response, not sending information from the new message to the client.

Claim 13 — Method with the same sequence of steps as claim 8 (server-side conversation-ID assignment, threaded retrieval, and suppressing delivery of new messages for an ignored conversation).

Notable observations and uncertainties

  • The granted claims differ from the pre-grant publication. The published application (US 2010/0082759 A1) had as its claim 1 a "computer implemented method of displaying communications grouped into conversations"; after prosecution the granted independent claim 1 was rewritten as a mobile-device claim incorporating the attachment roll-up icon, the tree hierarchy, and the ignore/do-not-download limitation, with the method content recast in claim 13. This means search results that quote the application's claims (e.g., the Justia page for publication 20100082759) are not the granted claim set.
  • The claims use "conversation identifier" supporting both GUID-type and keyword/subject-matter identification in the specification (see ¶¶ describing GUIDs, UUIDs, incrementing IDs, and keyword matching), but the claims themselves recite "conversation identifier" generically.
  • The "ignore" limitation appears in all three independent claims — it is the distinguishing subject matter of the granted claims relative to the earlier application.
  • The patent's remaining life depends on terminal disclaimer / PTA adjustments; the "2030-01-13" adjusted-expiration date from Google Patents is an assumption, not an official determination.
  • I could not verify current ownership beyond the recorded Microsoft Technology Licensing, LLC assignment, and I found no evidence of litigation, IPR, or a CAFC 2026 appeal involving this patent number.

If you need a PACER/CAFC docket check specifically, that would require a direct docket query, which my available search tool could not perform.

Generated 9/29/2026, 5:21:06 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 8725813. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

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

✓ Generated

I'll research litigation involving US patent 8725813 across patent litigation databases.

Let me search more targeted litigation databases for this specific patent.

Let me query more specialized patent litigation sources.

Summary finding

I was unable to identify any litigation involving U.S. Patent No. 8,725,813. Based on the sources searched, no district court case, ITC action, PTAB proceeding, or CAFC appeal asserting or challenging this specific patent was located. I should be candid that this is a negative finding from a limited search rather than an exhaustive litigation clearance, and I have flagged the specific verification limits below.

What I searched and what came back

I ran searches targeting patent-litigation aggregators (Unified Patents litigation portal, RPX/insight.rpxcorp.com, Docket Alarm, CourtListener/RECAP, Justia, USPTO/PTAB) for the exact strings "8,725,813" and "8725813" together with the patent title ("Communications grouped as conversations"). The results fell into three buckets, none of which tie to this patent:

1. Same-number-short-form false positives (the dominant problem). Numerous search hits used the shorthand "'872" to refer to entirely different patents:

  • Eco Fiber, Inc. v. Yukon Packaging (W.D.N.C., Case No. 2024CVS20983-590 related state action; federal action in W.D.N.C.) — the "'872 Patent" there is a thermally insulated container / packaging patent (claim 1 recites "loading" steps for cold packs), not a messaging patent.
  • A N.D. Cal. case (4:2010cv05254, Judge Claudia Wilken) referencing an "'872 patent" in an invalidity/collateral-estoppel dispute involving "USBI."
  • Caltech's matter referencing an "'833 patent" and other unrelated patents.
  • MPH v. Apple (N.D. Cal.) involving a "'302 patent."

Under the strict rule in force, I have not collapsed these into your patent; a three-digit shorthand is not the same identifier as 8,725,813. None of these cases involve the "conversations" patent.

2. Patent-identification pages (not litigation). Google Patents, USPTO Report (uspto.report/patent/grant/8,725,813), and Justia confirm bibliographic facts only:

  • Title: Communications grouped as conversations
  • Inventors: Nalliah, Seetharaman, Zafar, Atwood, Limont, Flint, Leconiuc
  • Original assignee: Microsoft Corporation; current assignee: Microsoft Technology Licensing, LLC
  • Application No. 12/242,676; filed 2008-09-30; granted 2014-05-13; adjusted expiration 2030-01-13
  • Family/continuations: US 9,870,124 (from 14/226,491); US 10,430,032 (from 15/793,556); US 11,194,446 (from 16/587,540)
  • Litigation front-page data ("Cited By," "Families Citing this Family") shows only patent-to-patent citations, not court cases.

3. Microsoft-involved patent suits that do not name this patent. Searches surfaced many Microsoft patent matters (e.g., QOMPLX LLC v. Microsoft (W.D. Tex. 1:25-cv-01383, filed 2025), Corent Technology v. Microsoft (C.D. Cal. 8:25-cv-02182), Uniloc v. Microsoft, Koninklijke Philips v. Microsoft/HTC, etc.), but 8,725,813 does not appear in any of them.

I also found no PTAB record (IPR/PGR/reexam) for 8,725,813 in the search returns.

Important caveats and limitations

  • Negative ≠ conclusive. I could not directly load the Unified Patents litigation caselist (portal.unifiedpatents.com/litigation/caselist) or query PACER/RPX by patent number in this session; my searches hit search-engine indexes and document caches. A case could exist that simply isn't indexed or indexed under the application number (12/242,676) or a party name.
  • Shorthand hazard. As shown above, "'872" is heavily overloaded across unrelated patents. Any claim of litigation must be verified against the full number 8,725,813 and the '813 / 12/242,676 identifiers — not a truncated form. If prior analysis (or a search engine) reported an "'872" case for this patent, that is very likely a false positive.
  • Assignee context. This is a Microsoft-owned patent. Microsoft patents are asserted defensively far more often than they are used offensively by Microsoft; the absence of litigation is therefore not surprising, and the absence of NPE assertion is consistent with a patent that has remained within the Microsoft portfolio rather than being sold into a monetization campaign. This is inference, not a verified fact.

Recommended next verification steps

To close this out, I would confirm against native identifiers in authoritative sources:

  1. Unified Patents litigation portal — search the caselist by patent number 8725813 (and by 12/242,676).
  2. PACER / CourtListener-RECAP — full-text query for "8,725,813" and "8725813" across all districts, plus Docket Alarm's patent page for 8725813.
  3. USPTO Patent Center / PTAB — PTAB API/Patent Center "litigation" and "post-grant" records for the '813 patent and its application number.
  4. RPX Insight — the patent's litigation tab (patent-specific, not title-based).

Bottom line

At present I found no known litigation, PTAB proceeding, or ITC action involving U.S. Patent No. 8,725,813. All apparent "hits" were either unrelated patents sharing a truncated "'872" shorthand or non-litigation bibliographic records. If you have a specific case name or docket number you believe asserts this patent, provide it and I can verify whether it maps to 8,725,813 rather than one of the many other "'872" patents.

Generated 9/29/2026, 5:21:16 PM

Proceedings on file (0)

All PTAB activity →

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

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

PTAB challenges

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

✓ Generated

I'll start by verifying the canonical list against what web search surfaces, since the structured block reports no proceedings.

The initial results are noisy — several hits reference different patents that happen to end in "872" (e.g., US 9,954,872 in IPR2025-00070, and a separate '872 patent about "association"). Let me run targeted confirmatory searches on the exact patent number.

Let me run two final confirmatory searches — one on the patent's own Google Patents "litigation/PTAB" footprint and one on possible NPE assertion, since an asserted patent tends to attract IPRs.

PTAB proceedings on US 8,725,813 — "Communications grouped as conversations"

Bottom line up front: The structured "PTAB proceedings on file" block (sourced from the USPTO Open Data Portal) reports no AIA trial proceedings. My independent web checks did not contradict that. Everything below is therefore framed around the absence of PTAB activity — which I state plainly rather than dress up.


Proceedings overview

Total AIA trial proceedings on file: 0 (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials) — no IPR, PGR, or CBM petition has ever been filed against US 8,725,813 as of 2026-09-29. Defensive posture: the patent is untested at the PTAB, not "hardened" and not "dead." No claim has been canceled, so nothing about this patent is foreclosed; but no claim has been sustained either, so there is no PTAB outcome, no FWD, and no estoppel for a defendant to leverage. A challenger must build its invalidity case from scratch (district court and/or a new IPR petition).


Per-proceeding detail

No AIA trial proceeding on file

  • Type: N/A — no Inter Partes Review, Post-Grant Review, or Covered Business Method review has been identified.
  • Filed: N/A
  • Status: The canonical block's verbatim position is that the ODP API returns no AIA trial proceedings for this patent as of the most recent ingest. Plain-English gloss: zero petitions, zero institutions, zero FWDs.
  • Judge panel: N/A — no panel has ever been assigned.
  • Petition grounds: N/A
  • Institution decision: N/A
  • Final Written Decision: N/A — no FWD exists, so no claim-level verdict to report. I will not attribute any claim outcome to this patent.
  • Settlement / termination: N/A
  • Appeal: N/A — no PTAB proceeding means no PTAB appeal to the Federal Circuit. I found no CAFC appeal docketed from a PTAB decision on this patent.
  • Defensive value: No help and no harm. Because there is no FWD, § 315(e)(2) estoppel has not attached to anyone, and all prior-art grounds — including art that would have been raised in a hypothetical IPR — remain fully available in litigation.

Note on false-positive hits I screened out (do not cite these as this patent): Web searches for "872" surfaced several unrelated matters that are different patents, and they should not be conflated with US 8,725,813:

  • IPR2025-00070 (Patent 9,954,872 B2) — a different patent number ending in "872."
  • A PTAB petition referring to an "'872 patent" about "association" / "unauthorized action" — a different '872 patent.
  • A petition referring to an "'872 patent" involving call-center "quality task"/KPI evaluation — likewise a different '872 patent.
  • Various Microsoft-as-petitioner IPRs (e.g., IPR2019-00810/811/812/813/814 against IPA Technologies; IPR2021-00277; IPR2021-01325) — none involve US 8,725,813.

None of these is US 8,725,813.


Strategic summary

Claim status of US 8,725,813. All 20 issued claims are UNTESTED at the PTAB. Claims 1–7 (the mobile-device/conversation-display claims) and claims 8–20 (the server-side conversation-identifier and "ignore the conversation" claims) stand exactly as issued. There is no canceled-claim list and no sustained-claim carve-out, because no trial ever reached a Final Written Decision. Any representation that a given claim of this patent has been "upheld" or "invalidated" by the Board would be false.

Estoppel landscape. § 315(e)(2) estoppel only attaches after a final written decision, and it binds the petitioner, its real parties in interest, and privies. With no FWD, no estoppel exists against anyone on this patent. For a defendant currently facing assertion, that cuts both ways: nothing is foreclosed, but nothing is pre-litigated either — you have to fund and win your own challenge. Practically, that also means there is no petitioner-side record to borrow from, no Board claim construction to cite, and no expert testimony already on the record for you to adopt.

Pattern signals.

  • Repeat petitioners: None — there is no petitioner to repeat.
  • Patent-owner aggression at the PTAB: None observed. Microsoft Technology Licensing, LLC (current assignee; [Microsoft Corp.](/litigations/by-plaintiff/Microsoft%20Corp.) was the original assignee) has not had to defend this patent at the Board.
  • Defensive aggregator (Unified Patents, RPX, etc.): No Unified Patents or similar entity challenge surfaced in the family's citing/cited-by records.
  • Family signal worth flagging: This patent sits in an active Microsoft family with later continuations/related grants — US 9,870,124, US 10,430,032, and US 11,194,446 — all sharing the 2008-09-30 priority date. Even a successful IPR against the '813 parent would not clear the family, so any clearance strategy should scope the continuation claims too.

Recommended next steps

  1. Independently re-confirm the zero count before relying on it. I checked PTAB E2E-reproduced content and general web sources and found nothing; but my search tools cannot exhaustively query PTAB E2E dockets. Verify directly at USPTO PTAB E2E / PTAB API and Docket Alarm, and check the "Litigation/PTAB" tabs on the patent's Google Patents page (https://patents.google.com/patent/US8725813/en) and on Unified Patents' patent portal.
  2. Treat the absence as an untested patent, not a safe one. This is not an NPE patent that has been litigated to death — it is an operating-company patent (Microsoft) that appears not to have been asserted widely enough to attract an IPR. That generally means the claims have not been stress-tested, and its continued maintenance-fee-active status (adjusted expiration 2030-01-13 per the record) means it remains live through the end of the decade.
  3. If you are a defendant, calendar the § 315(b) one-year bar now. Any defendant served with a complaint alleging infringement of the '813 patent has one year from service to file an IPR. Because there is no prior petitioner, no third party has run this clock for you, and there is no joinder or "me-too" path available.
  4. Because no FWD exists, there is nothing to link. I cannot point to an FWD or a CourtListener opinion, and I will not manufacture one. If a PTAB proceeding is later filed, the institution decision would be due ~6 months from the petition's filing, with an FWD due within 12 months of institution (35 U.S.C. § 316(a)(11)) — those are the milestones to track.
  5. Investigate the sibling continuations in parallel. Given US 9,870,124 / US 10,430,032 / US 11,194,446 share the same priority disclosure, prior art developed against the '813 claims may be equally probative against the continuation claims — relevant if a licensing demand or assertion touches more than just the '813 patent.

Confidence and limits. High confidence that no AIA trial proceeding is on file for US 8,725,813, consistent with the canonical ODP-derived block and with my searches. Lower confidence that the search was exhaustive — a recently filed petition not yet indexed by ODP could exist. I found no PTAB FWD, no settlement, no termination, and no Federal Circuit appeal, and I have not fabricated any proceeding number, panel, or claim-level outcome.

Generated 9/29/2026, 5:21:24 PM

Ownership chain (2)

Asserters network →

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

  1. ? · recorded 2010-09-29 · Assignment

    Selvaraj Nalliah; Shivakumar Seetharaman; Salman Zafar; John Allen Atwood; David P. Limont; Joseph T. Flint; Alexandru LeconiucMicrosoft Corporation

  2. ? · recorded 2014-12-09 · Assignment

    Microsoft CorporationMicrosoft Technology Licensing, LLC

    internal reorg

Assignment history

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

✓ Generated

I'll research the assignment record for US 8725813, starting with what's embedded in the patent text and then verifying via assignment records.

Let me dig into the assignment records specifically, and check for any litigation or NPE activity involving this patent.

Let me try to locate the specific reel/frame records and check for any assertion activity.

Assignment Record — US 8725813 "Communications grouped as conversations"

Sourcing caveat (read first): I was able to confirm two recorded post-filing assignments via the Google Patents legal-events record (which mirrors USPTO assignment data), but I was not able to pull the individual reel/frame numbers for US 8725813 itself from the Assignment Center in this session. I therefore cite reel/frame only where I actually verified it (a sibling Microsoft patent that was recorded in the same December 9, 2014 batch). Where I could not verify, I say so rather than guess. Verify at: https://assignment.uspto.gov/patent/index.html (search patent 8725813).

Inventors

Inventor Employer at filing (determinable)
Selvaraj Nalliah Microsoft Corporation (per recorded assignment of inventors' interest)
Shivakumar Seetharaman Microsoft Corporation
Salman Zafar Microsoft Corporation
John Allen Atwood Microsoft Corporation
David P. Limont Microsoft Corporation
Joseph T. Flint Microsoft Corporation
Alexandru Leconiuc Microsoft Corporation

All seven inventors executed an assignment of their interest to Microsoft Corporation ("ASSIGNMENT OF ASSIGNORS INTEREST"), recorded at the USPTO on 2010-09-29 — i.e., the entire inventing team assigned to the same operating company. There is no evidence of any inventor departing or spinning out to a separate entity. The delay between the 2008-09-30 filing and the 2010-09-29 recording is notable (roughly two years) but is not unusual for confirmatory inventor assignments and is not, by itself, a fire-sale tell.

Original assignee

Microsoft Corporation (Redmond, WA), the entity named on the issued patent (grant 2014-05-13). Microsoft is an operating software company; the claimed subject matter — mobile-device grouping of e-mail messages into "conversations" with roll-up indicators and conversation-level actions (ignore/delete/move) — was embodied in Microsoft's mobile messaging stack, including Outlook Mobile / Windows Mobile (later Windows Phone) messaging and Exchange ActiveSync synchronization. Microsoft's primary line of business is software and cloud services. Current status: operating (Microsoft Corporation remains a going concern; it created the wholly-owned subsidiary Microsoft Technology Licensing, LLC in 2014 to hold and license its patent portfolio). No bankruptcy, dissolution, or acquisition of the original assignee occurred.

Assignment timeline

  • executed date not shown / recorded 2010-09-29 — Reel not verified (Assignment Center reel/frame not retrieved)

    • Conveyance: Assignment (Assignment of Assignors' Interest)
    • Assignor: Selvaraj Nalliah; Shivakumar Seetharaman; Salman Zafar; John Allen Atwood; David P. Limont; Joseph T. Flint; Alexandru Leconiuc (all inventors)
    • Assignee: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052
    • Correspondent: not retrieved (not shown in the Google Patents legal-events entry)
    • Context: Confirmatory inventor-to-employer assignment — routine.
  • executed (likely) 2014-10-14 / recorded 2014-12-09 — Reel not verified for 8725813; the parallel Microsoft→MTL recording for sibling patent US 7,185,285 used Reel 034541/0477, execution date Oct 14 2014, recording date Dec 9 2014

    • Conveyance: Assignment (Assignment of Assignor's Interest)
    • Assignor: Microsoft Corporation
    • Assignee: Microsoft Technology Licensing, LLC, One Microsoft Way, Redmond, WA 98052
    • Correspondent: (per the parallel Dec 9 2014 Microsoft recording) CPA Global Limited, Liberation House, Castle Street, St Helier, JE1 1BL, Jersey — CPA Global is Microsoft's long-time bulk IP-recording vendor; its appearance as correspondent on the December 2014 Microsoft→MTL portfolio transfers recurs across the Microsoft family, so a single appearance here is expected and not an NPE tell.
    • Context: Internal corporate reorganization — Microsoft consolidated its patent portfolio into its wholly-owned licensing subsidiary MTL (a captive IP-holding entity, not a third-party acquirer).

No further assignments are recorded. After the 2014 reorganization, the patent (and its continuation family — US 20100082759A1; continuations US 9870124, US 10430032, US 11194446) has remained with Microsoft Technology Licensing, LLC. Adjusted expiration is listed as 2030-01-13 new-terminal-disclaimer/PTA. I found no assignment into any third-party, licensing-only, or asserting LLC, and no litigation or NPE assertion naming US 8,725,813.

Timeline diagram

timeline
    title Ownership of US 8725813
    2008 : Filed by Microsoft Corporation
    2010 : Inventor assignment recorded
    2014 : Patent issued on May 13
         : Assigned to Microsoft licensing unit

NPE / troll-pattern signals

  1. Shell-entity transfer — not present. The only post-issuance transfer is Microsoft Corporation → Microsoft Technology Licensing, LLC (recorded 2014-12-09). MTL is a wholly-owned captive subsidiary of an operating company, not an anonymous single-purpose Delaware/Texas LLC; its address is Microsoft's own HQ (One Microsoft Way, Redmond WA). The "Licensing" suffix is real but the defined trap (no products, registered-agent address, unrelated principals) does not apply here.

  2. Known asserter in the chain — not present. Neither Microsoft Corporation nor Microsoft Technology Licensing, LLC appears on the standard NPE rosters (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Erich Spangenberg entities, etc.). No recurring high-frequency plaintiff is anywhere in the chain.

  3. Repeat correspondent across the chain — not a finding. I verified only one correspondent (CPA Global Limited, Jersey) on a sibling Microsoft→MTL recording (Reel 034541/0477, executed 2014-10-14, recorded 2014-12-09). CPA Global is a mainstream corporate IP-recording service used by operating companies, not an NPE assertion firm. Correspondence for the 2010-09-29 inventor assignment for 8725813 was not retrieved, so I cannot assess recurrence on this chain.

  4. Cascading transfers — not present. Only two recorded transfers spanning six-plus years (2010 and 2014), both internal to Microsoft. No chained LLCs, no shared-principal shell hops, no sub-24-month cascade.

  5. Pre-litigation transfer — not present. No infringement suit naming US 8,725,813 was located, so there is no assignment dated within six months of a first suit. The 2014 transfer predates nothing litigious.

  6. Bankruptcy fire-sale — not present. Microsoft has not filed Chapter 7/11; no proceedings, no patent auction.

  7. Privateering — not present. No evidence Microsoft conveyed the patent to an NPE to assert on its behalf; the transferee is Microsoft's own subsidiary, and no competitor has been sued.

  8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN; it terminates at Microsoft's captive licensing arm.

Verdict

Insufficient data — as to NPE status; not an NPE chain. The record reconstructs to exactly two recorded transfers: the inventors' assignment to Microsoft Corporation (recorded 2010-09-29) and Microsoft's intra-corporate transfer to its wholly-owned subsidiary Microsoft Technology Licensing, LLC (executed ~2014-10-14, recorded 2014-12-09). Both are routine corporate housekeeping by an operating company; none of the eight NPE signals is present, no third-party or licensing-only shell ever entered the chain, and no assertion activity against US 8,725,813 was located. Because the only records are internal corporate transfers and the exact reel/frame for 8725813 could not be pulled from the Assignment Center in this session, this is best classified as insufficient data rather than an affirmative NPE finding — with the substantive conclusion that the patent remains inside the Microsoft operating-company family.

Verification link: https://assignment.uspto.gov/patent/index.html (search "8725813"); and the Google Patents legal-events tab at https://patents.google.com/patent/[US8725813B2](/patent/US8725813B2)/en.

Generated 9/29/2026, 5:21:37 PM

Prior art

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

✓ Generated

I'll research the prior-art citations for US 8,725,813. Let me run several searches.

Let me gather details on the remaining cited references.

Prior-Art Analysis: US 8,725,813 B2

Method note / sourcing. I queried the web for the specific number 8725813 and for each of its cited references. Confirmed sources: the Google Patents record at patents.google.com/patent/US8725813/en (which lists the granted citations), the USPTO-mirror grant record at uspto.report/patent/grant/8,725,813, and patentimages.storage.googleapis.com full-text PDFs for references I could open. I was able to read full text for US 6,212,553, US 7,000,032, and US 2005/0055416; the remaining cited references I could only characterize from their titles, publication data, and abstracts. I flag below where a reference's "anti" conclusion rests on title/abstract only rather than full text — treat those as provisional.

Identifiers verified (literal). US 8,725,813 B2; application 12/242,676; filed and priority 2008-09-30; granted 2014-05-13; Microsoft Corporation → Microsoft Technology Licensing, LLC. Because the application was filed 2008-09-30, pre-AIA 35 U.S.C. §102 governs, and the key dates for the cited art are: §102(b) statutory bar = on sale/published before 2007-09-30; §102(a) = before the invention date (presumed 2008-09-30); §102(e) = U.S. patent/publication with an effective filing date before 2008-09-30. That date framework is used throughout.

Important non-finding (do not conflate). My searches surfaced several PTAB/IPR papers referring to "Low," "Riggsby," "Heidloff," and U.S. Patent No. 9,137,190. Those materials concern a different patent and must not be attributed to US 8,725,813. I found no IPR/PGR, litigation, or CAFC appeal naming US 8,725,813 in any result. I cannot query PACER/PTAB directly, so this is "nothing surfaced," not a certified negative.

The 14 patent citations of record for the '813 patent

# Reference Priority / Pub. or Grant date Assignee §102 window
1 US 6,212,553 B1 1996-05-31 / 2001-04-03 Microsoft §102(a),(b),(e)
2 US 7,000,032 B2 1999-09-10 / 2006-02-14 Ianywhere Solutions §102(a),(b),(e)
3 US 6,694,336 B1 2000-01-25 / 2004-02-17 FusionOne §102(a),(b),(e)
4 US 2002/0032722 A1 2000-09-11 / 2002-03-14 AvantGo §102(a),(b),(e)
5 US 2006/0271563 A1 2001-05-15 / 2006-11-30 Metatomix §102(a),(b),(e)
6 US 7,032,033 B1 2001-11-30 / 2006-04-18 Microsoft §102(a),(b),(e)
7 US 2004/0078441 A1 2002-10-17 / 2004-04-22 Malik, Dale W. §102(a),(b),(e)
8 US 7,359,991 B2 2002-11-05 / 2008-04-15 Microsoft §102(a),(e)
9 US 2005/0055416 A1 2003-09-05 / 2005-03-10 Heikes (America Online) §102(a),(b),(e)
10 US 7,239,877 B2 2003-10-07 / 2007-07-03 Accenture Global Services §102(a),(e)
11 US 2006/0010200 A1 2004-05-20 / 2006-01-12 Research In Motion §102(a),(b),(e)
12 US 2007/0100843 A1 2005-10-20 / 2007-05-03 Chen, Daniel Q. §102(a),(e)
13 US 2008/0222538 A1 2005-10-26 / 2008-09-11 Cardu, Salvatore §102(a),(e)
14 US 2009/0119678 A1 2007-11-02 / 2009-05-07 Shih, Jimmy §102(e) only (pub. after '813 filing)

Reference-by-reference assessment against the granted claims

Recall the granted independent claims (as summarized previously and re-verified against the patents.google.com claim text): Claim 1 (mobile device: conversation display mode → conversation-identifier-based grouping → conversation graphical element with an attachment roll-up icon → tree hierarchy of related messages → action menu including ignore → not downloading further conversation messages); Claim 8 (CRM; server: embed conversation ID → receive reply bearing same ID → threaded retrieval by ID → on "ignore," not send a new conversation message to the client); Claim 13 (method mirroring claim 8). Dependent claims 2–7 and 9–12, 14–20 add server retrieval/filters, action lists, GUID/incrementing IDs, etc.

1. US 6,212,553 B1 — "Method for sending and receiving flags and associated data in e-mail transmissions" (Microsoft; filed 1996-05-31; granted 2001-04-03)

Full text read. Discloses e-mail message items carrying a flag property for a recipient follow-up action with due dates/reminders, status display in the inbox, and automatic tallying of replies to a query.
Potential §102 relevance: maps to dependent claim 6 ("follow-up action," "clear flag action") and to the notion of per-message status reflected in a list view. It does not disclose conversation identifiers, conversation grouping, tree hierarchies, the attachment roll-up icon, or the ignore/do-not-download step. Not anticipatory of any independent claim; §103 material for claim 6.

2. US 7,000,032 B2 — "System, method, and computer program product for syncing to mobile devices" (Ianywhere; 1999-09-10 / 2006-02-14)

Full text overview read. Off-line/on-line interactive web content on mobile devices, channel/object syncing, "off-by-N" synchronization, and server-side selective object sending.
Potential §102 relevance: bears on claim 1's mobile-device platform and the client/server sync architecture behind claims 2–4 (requesting/receiving messages from a server; pre-determined-period limits). No conversations, no conversation IDs, no ignore action. Not anticipatory; §103/§102-backdrop material for the retrieval/synchronization limitations.

3. US 6,694,336 B1 — "Data transfer and synchronization system" (FusionOne; 2000-01-25 / 2004-02-17)

Overlapping with #2: general data-transfer/synchronization between a device and a server. Relevant only as background to the claim 2–4 synchronization features. Not anticipatory.

4. US 2002/0032722 A1 — "Method, system, and computer program product for synchronization of similar data objects with event information" (AvantGo; 2000-09-11 / 2002-03-14)

Synchronizing "similar data objects" and associating event information — background for the sync/filter features of the specification and claims 3–4. Not anticipatory.

5. US 2006/0271563 A1 — "Appliance for enterprise information integration and enterprise resource interoperability platform and methods" (Metatomix; 2001-05-15 / 2006-11-30)

Enterprise data integration/mapping. Appears to be cited for generic message/data mapping and integration rather than conversation threading. Not anticipatory; likely §103 background only.

6. US 7,032,033 B1 — "Handling collisions during synchronization of data between client and server computers" (Microsoft; 2001-11-30 / 2006-04-18)

Sync conflict/collision resolution. Background to the client↔server synchronization recited/spec-supported in claims 2–4. Not anticipatory.

7. US 2004/0078441 A1 — "Providing advanced instant messaging (IM) notification" (Malik; 2002-10-17 / 2004-04-22)

Advanced notification for instant messages. Potentially relevant to the notification/unread-roll-up aspects of claim 1 (icons/text conveying unread counts, status). Does not address conversations, IDs, trees, attachments, or ignore. Not anticipatory; §103 support.

8. US 7,359,991 B2 — "Folder synchronization" (Microsoft; 2002-11-05 / 2008-04-15)

Synchronizing folders between client and server. Directly relevant to the specification's statement that messages "may be stored in one or more folders, directories or subdirectories" (claim 2/4 retrieval, and claim 1's "accessing a plurality of e-mail messages"). Not anticipatory.

9. US 2005/0055416 A1 — "Managing instant messages" (Heikes, America Online; filed 2004-04-16, pub. 2005-03-10) — the most on-point cited reference

Full text read. Discloses capturing instant messages that satisfy a capture rule, grouping/presenting captured messages by predetermined categories (known/unknown, trusted/untrusted), informing the recipient unobtrusively, and giving the user "Ignore," "Ignore All," and "Block" controls. Critically, it states that "subsequent instant messages related to a previously deleted, ignored or blocked message or message source, in turn, may be deleted, ignored or blocked without being presented to the intended recipient."
Potential §102 relevance: this is the closest cited art to the "ignore the conversation" + suppress-future-related-messages limitations that distinguish the granted claims (claim 1 step (h)–(j); claims 8 and 13 steps (h)–(j)). It can reasonably be argued to anticipate a narrow claim to "receive indication a message/conversation is to be ignored; receive a new related message; do not present it."
Why it does not, on its face, anticipate claims 1/8/13: (i) it is instant messaging, not e-mail, and lacks a conversation identifier embedded in an outbound message/reply (claim 8/13 step (b),(d)); (ii) no tree hierarchy with reply indentation (claim 1 step (g)); (iii) no attachment roll-up icon on a conversation element (claim 1 step (f)); (iv) the suppression is keyed to a message source/rule, not a conversation threading ID. Best characterized as strong §103 art (and a §102 anchor for a hypothetical narrower claim).

10. US 7,239,877 B2 — "Mobile provisioning tool system" (Accenture; 2003-10-07 / 2007-07-03)

Mobile provisioning/deployment. Background to the mobile-client architecture of claim 1. Not anticipatory.

11. US 2006/0010200 A1 — "Handling an audio conference related to a text-based message" (Research In Motion; 2004-05-20 / 2006-01-12)

Linking a communication (audio conference) to a text-based message. Relevant to the specification's broader "communications" (voice/missed-call/IM) framing and the notion of associating related communications. Does not disclose conversation IDs, trees, attachment roll-up, or ignore. Not anticipatory; §103/§102 backdrop.

12. US 2007/0100843 A1 — "System and method for mapping between different information management systems" (Chen, Daniel Q.; 2005-10-20 / 2007-05-03)

Data-system mapping. Generic background; not anticipatory.

13. US 2008/0222538 A1 — "System and method for delivering virtual tour content using the hyper-text transfer protocol (HTTP)" (Cardu; 2005-10-26 / 2008-09-11)

HTTP content delivery. At most background to network transport; not anticipatory.

14. US 2009/0119678 A1 — "Systems and methods for supporting downloadable applications on a portable client device" (Shih, Jimmy; 2007-11-02 / 2009-05-07)

Portable client downloading/offline apps. Qualifies only as §102(e) art (its publication post-dates the '813 filing; its application filing of 2007-11-02 pre-dates it). Background to the mobile-client environment; not anticipatory.

Non-patent literature of record (5)

  1. "Configuring Outlook 2003 for Offline Use with Exchange 2003," Overview, Jul. 2004 (whitepapers.techrepublic.com) — §102(b) printed publication; offline/mobile e-mail sync background.
  2. Bramson, Steven et al., "Microsoft Exchange Server 2003 ActiveSync Architecture," White Paper, Jul. 2008 — dated within one year of filing, so §102(a) only; mobile sync architecture background.
  3. Goldberg, Yaron et al., "Active Mail—A Framework for Implementing Groupware," CSCW Proceedings, Nov. 1992, pp. 75–83 — the most substantive NPL for the conversation concept; §102(b) art (decades earlier). An e-mail-based groupware framework in which messages relate to a shared discussion. This is the reference most likely to be invoked against the broad "grouping communications as conversations" concept underlying claim 1 step (b)–(d), though it does not appear to disclose conversation IDs, tree indentation, attachment roll-up icons, or the ignore/do-not-download step.
  4. Larkin, Henry, "Applying Concurrent Versioning to Serverless Mobile Device Synchronisation," IEEE/ACIS ICIS 2007 — §102(a) (2007); mobile sync background.
  5. Larkin, Henry, "Data Representations for Mobile Devices," IEEE, 2007 — §102(a); mobile data-representation background.

Most relevant prior art (ranked) and §102 conclusion

  1. US 2005/0055416 A1 (Heikes/AOL) — closest to the ignore-and-suppress-future-messages limitations that are the distinguishing feature of claims 1, 8, and 13. Strong §103 art; possible §102 anticipation only of a much narrower claim.
  2. Goldberg et al., "Active Mail" (CSCW 1992) — closest to the conversation-grouping concept; §102(b) publication.
  3. US 6,212,553 (Microsoft flags/follow-up) — §103 art for the action-list/follow-up limitations (claim 6).
  4. US 7,000,032 / US 6,694,336 / US 2002/0032722 / US 7,032,033 / US 7,359,991 — the sync/retrieval cluster; §103 art for the "request/receive messages from server" and "limited storage / predetermined period" limitations (claims 2–4) and the mobile-client platform of claim 1.
  5. US 2004/0078441 (Malik) — notification/roll-up display art.
  6. Remaining references (##5, 10–14) — background/general §102(a)-(e) art; no meaningful §102 anticipation.

Bottom line on §102: On the record available to me, none of the 14 cited references, alone, discloses every element of granted claim 1, 8, or 13. In particular, no single reference appears to disclose the combination of (i) a conversation identifier embedded in an outbound message and echoed in the reply, (ii) a tree-hierarchy display with indented replies, (iii) a conversation-level attachment roll-up icon, and (iv) an "ignore" action that suppresses downloading/delivery of future conversation messages. The cited art is therefore best marshaled under §103 (obviousness) as combinations — most plausibly Heikes (ignore/suppress) + Goldberg "Active Mail" (conversation grouping) + the sync cluster (client/server retrieval) — rather than under §102 anticipation. The "ignore + don't-forward" limitation is the pivot the examiner appears to have relied on to distinguish the granted claims from the pre-grant publication's method claims.

Caveats and confidence

  • Full-text vs. title-only. US 6,212,553, US 7,000,032, and US 2005/0055416 were read in substance; conclusions for the other eleven rest on titles, dates, assignees, and abstracts and should be re-verified against full text before being relied on.
  • Date law. Because the application was filed 2008-09-30, pre-AIA §102 applies; the §102(b) bar date is 2007-09-30. References #10–14 published on/after that date qualify, if at all, only under §102(a)/(e), and #14 only under §102(e).
  • No contradiction found with the earlier-generated summary; this analysis builds on it. The earlier note that the granted claims differ from publication US 2010/0082759 A1 is consistent with the observed prosecution history (non-final action, response after final, allowance).
  • I did not locate any litigation, IPR/PGR, or CAFC 2026 proceeding naming US 8,725,813; treat as unverified-negative rather than conclusive.

Generated 9/29/2026, 5:21:53 PM

Obviousness

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

✓ Generated

I'll ground the analysis in the actual cited references before building the obviousness combinations.

Obviousness Analysis — U.S. Patent No. 8,725,813 (35 U.S.C. § 103)

Scope note. This analysis is built on the prior-art record appearing on the patent's own page — the "Patent Citations (14)," "Non-Patent Citations (5)," "Family Cites Families (7)," and the third-party "Cited By / Families Citing this Family" listings — supplemented by verified public text of the key references. Where I could not verify full text, I say so. Per the operating rules, all identifiers are quoted literally (including the claim's "related to a conversations"). This builds on, and does not repeat, the earlier bibliographic, claim-interpretation, and litigation sections.


1. Threshold: the operative prior-art date

Google Patents lists the patent's "Prior art date" as 2008-09-30, which is identical to the filing date of application US 12/242,676. No earlier domestic or foreign priority is asserted on the face of the record. The § 103 critical date is therefore 2008-09-30, and every reference discussed below predates it (except where I expressly flag otherwise).

Data anomaly to flag (not corrected): the "Related Child Applications (2)" table lists US 14/226,461, styled a "Continuation" of this family, with a priority date of 2011-04-23 and the title "Synthesized identifiers for system information database." That entry is inconsistent with the remainder of the family record (which shows only US 9,870,124 B2, US 10,430,032 B2, and US 11,194,446 B2 as same-priority continuations) and with the patent's own title. I interpret the entry literally as displayed and do not silently rename or re-date it; it should be verified against Patent Center before being relied on.


2. The prior art of record, characterized

Ref. (literal) Date What it teaches
US 6,212,553 B1 (Microsoft, "Method for sending and receiving flags and associated data in e-mail transmissions") 1996-05-31 / 2001-04-03 Receives flag data, stores it as one of a plurality of message properties, transmits the message with the property to a recipient; displays status of a follow-up action in conjunction with the message item; flag + due date. (link)
US 7,000,032 B2 (Ianywhere, "…syncing to mobile devices") 1999-09-10 / 2006-02-14 Selective/off-line synchronization to mobile clients; "selectively sending objects to a client depending on whether the client already has the objects" (FIG. 1L); sync as connect–exchange–removal of data. (link)
US 6,694,336 B1 (Fusionone, "Data transfer and synchronization system") 2000-01-25 / 2004-02-17 Client/server data synchronization.
US 2002/0032722 A1 (AvantGo, "…synchronization of similar data objects with event information") 2000-09-11 Filtered sync of data objects with event metadata.
US 7,039,033 B1 (Microsoft, "Handling collisions during synchronization of data between client and server computers") 2001-11-30 / 2006-04-18 Two-way sync state/conflict handling.
US 7,359,991 B2 (Microsoft, "Folder synchronization") 2002-11-05 / 2008-04-15 Folder-level synchronization — the container abstraction the patent later re-uses for "conversations."
US 2004/0078441 A1 (Malik, "Providing advanced instant messaging (IM) notification") 2002-10-17 User-configurable IM notification/presence handling.
US 2005/0055416 A1 (Heikes, "Managing instant messages") 2003-09-05 / pub. 2005-03-10 A screening component applying a capture rule; UI with "Ignore" and "Ignore All" buttons; disclosed that "subsequent instant messages related to a previously deleted, ignored or blocked message or message source, in turn, may be deleted, ignored or blocked without being presented to the intended recipient"; captured messages "organized and/or presented … according to a plurality of predetermined categories." (PDF)
US 2006/0010200 A1 (RIM, "Handling an audio conference related to a text-based message") 2004-05-20 Cross-modality association of a non-text communication with a text message.
US 7,239,877 B2 (Accenture, "Mobile provisioning tool system") 2003-10-07 / 2007-07-03 Provisioning/configuring mobile clients and services.
US 2009/0119678 A1 (Shih, "…supporting downloadable applications on a portable client device") 2007-11-02 Portable-client application delivery/management.
Goldberg, Safran & Shapiro, "Active Mail — A Framework for Implementing Groupware," CSCW '92, pp. 75–83 (ACM DOI) Nov. 1992 Piggybacks on ordinary e-mail; delivers a "text conversation tool"; a Conversation Window and a shared conversation log; explicitly frames the problem as "To which message does the current message respond? What was the sequence of messages exchanged on a particular topic?"; includes a folder hierarchy for persistent connections and a notification mechanism.
"Configuring Outlook 2003 for Offline Use with Exchange 2003" (NPL, 2004) Jul. 2004 Offline/cached mail client operation against a server mailbox.
"Microsoft Exchange Server 2003 ActiveSync Architecture" (NPL, 2008) and its companion Exchange ActiveSync documentation Jul. 2008 / 2005 Mobile-device sync of mail/calendar/contacts against an Exchange mailbox; per-collection sync of multiple e-mail folders; SyncKey = a GUID plus an incrementing number; per-object ServerId; filtering and truncation to limit how much mail is downloaded; attachment blocking with on-request download; smart reply/forward performed at the server; up-to-date notification. (white paper mirror; Microsoft EAS docs)
Larkin, "Applying Concurrent Versioning to Serverless Mobile Device Synchronisation" / "Data Representations for Mobile Devices" (NPL, 2007) 2007 Mobile sync data-representation and concurrency.

Record-level observation. The face-cited patent art is overwhelmingly synchronization infrastructure (US 7,000,032; US 6,694,336; US 2002/0032722; US 7,039,033; US 7,359,991; Larkin) plus message-property/flag technology (US 6,212,553) plus IM screening (US 2005/0055416; US 2004/0078441). Only one reference in the entire record — the Goldberg "Active Mail" paper — addresses conversation/thread organization of e-mail itself. That distribution matters: the strongest § 103 case is a server-side infrastructure case (claims 8 and 13) built on EAS + US 6,212,553 + Heikes, while the client UI case (claim 1) is a three-way-plus combination anchored on Active Mail.

A reference I will not use as prior art: the search surfaced US 2013/0060865 A1 ("receiving a synchronization command that includes a filter tag … preventing a second set of items … from being provided to the user device"). Its publication date is 2013, after the 2008-09-30 critical date, so it is not prior art here. I flag it only to show that the same design later became the subject of separate patenting — a datum relevant to obviousness-of-the-concept but not admissible as a § 103 reference.


3. Element-by-element mapping

3.1 Claim 1 (mobile device)

Claim 1 limitation Primary mapping Notes
Mobile device with display, processor, storage medium EAS white paper (Windows Mobile Smartphone/Pocket PC); US 2009/0119678 Conventional
Receive selection of a conversation display mode organizing e-mail into conversations Active Mail (conversation window / Input folder / Active Folder hierarchy); Outlook 2003 offline NPL Active Mail expressly diagnoses the "which message responds to which" problem
Access e-mail messages each including a conversation identifier US 6,212,553 (flag data "stored as one of a plurality of message properties" and transmitted with the message) Establishes the concept of a per-message, server-transmitted classifying property
Use identifiers to identify a conversation US 6,212,553 + US 7,359,991 (grouping by a shared container/property) —
Graphical element for the conversation Active Mail (folder/agent icons with notification state); US 6,212,553 (status displayed "in conjunction with the message item") —
…wherein the element comprises an icon indicating roll-up information … that at least one message has an attachment Weakest mapping in claim 1. Nearest record support is EAS's attachment handling ("attachment blocking with the option to allow downloading of attachments on request") and US 6,212,553's per-message status roll-up. The specific aggregate "paperclip-on-the-conversation" icon is not squarely disclosed by any single record reference. This is a conventionalization argument (KSR: "a combination of familiar elements according to known methods" / predictable UI aggregation), not a disclosure argument
Tree hierarchy displaying a reply indented and below the communication Active Mail's conversation log and its discussion of the Andrew Message System's "hierarchical drawings"; Usenet/newsreader and Notes-style threading in the art Also the weakest link; needs art outside the record
Menu of actions applicable to the conversation System as claimed: US 2005/0055416 (capture interface with Open/Buddy Info/Block/Ignore/Ignore All) Menu-based action lists are conventional
…including an action to ignore the conversation US 2005/0055416, expressly Direct hit on the word "Ignore"
On selection of ignore, not downloading additional messages related to the conversation US 2005/0055416 ("subsequent instant messages … may be deleted, ignored or blocked without being presented") + EAS filtering/truncation to limit what is downloaded The suppression result is disclosed; suppressing a whole conversation is the incremental step

3.2 Claims 8 and 13 (server-side storage medium / method)

These two independent claims are substantively identical (claim 8 adds only the § 101 carve-out "does not consist of a modulated data signal").

Limitation Primary mapping Notes
Receive message from a client for sending to a recipient EAS (mail submitted through the server; server-side smart reply/forward) —
Include a conversation identifier in the message US 6,212,553 (flag/associated data received and stored as a message property, then transmitted); EAS SyncKey/ServerId assignment of identifiers to synchronized objects Strong
Send the message US 6,212,553; EAS Strong
Receive a reply message that includes the same conversation identifier US 6,212,553 (properties travel with the message and its reply chain); Active Mail (replies stay in the same conversation) Strong
Receive a request for messages related to the conversation, the request including the conversation identifier EAS Sync (client sends the CollectionId/SyncKey per collection/email folder); US 7,000,032 / US 2002/0032722 (filtered sync requests) Strong
Identify the message and the reply using that identifier; send their information to the client EAS (server identifies changed objects after last sync and returns them); US 7,359,991 (folder synchronization) Strong
Receive an indication the conversation is to be ignored; receive a new message related to the conversation; not send information from the new message to the client US 2005/0055416 (ignore/block, and suppression of subsequent related messages) + EAS server-side filtering/attachment blocking Moderate–strong; the "per-conversation" granularity is the increment

4. Grounds of rejection

Ground A — Claims 8 and 13 (and their dependents 9–12, 14–20) over US 6,212,553 in view of US 2005/0055416 and the Exchange Server 2003 ActiveSync white paper.

Rationale: US 6,212,553 supplies the core "put a classifying property on an outbound message; the property persists into the reply stream; display status derived from the property" architecture — literally claim 8's steps of including an identifier, sending, and receiving a reply that carries it. EAS supplies the server-side retrieval protocol keyed on client-supplied identifiers (SyncKey = GUID + incrementing number; CollectionId; per-folder collections) and the information-suppression levers (filtering/truncation; attachment blocking). Heikes supplies the "ignore" action and the teaching that ignored subject matter is thereafter suppressed. The only element not literally shown is server-side rather than client-side suppression at conversation granularity — a distinction of location and grouping that a POSITA would implement routinely, since the server is the only actor that can decline to send.

Ground B — Claim 1 over Goldberg (Active Mail) in view of US 2005/0055416, US 6,212,553, and the EAS/Outlook-offline NPLs.

Rationale: Active Mail is the only record reference that squarely frames e-mail as conversations and builds a UI around a conversation window/folder with a notification indicator. US 6,212,553 supplies per-message property tagging and status display. Heikes supplies the ignore action and suppression. The ActiveSync/Outlook-offline NPLs supply the mobile-client context and the small-screen/bandwidth-driven need to limit what is fetched. The claimed mobile device is the obvious delivery vehicle once the client-server split of Active Mail is ported to 2003–2008 mobile messaging.

Ground C — Dependent-claim layer (any of A or B plus): US 7,000,032 / US 6,694,336 / US 2002/0032722 / the Outlook 2003 offline NPL for the "request/receive from a server" and "limited to a predetermined period of time" limitations (claims 2–4); US 6,212,553 for the action list of flag/follow-up (claim 6) and for applying an action to a message property (claim 7); EAS for the GUID/unique-string/incrementing-identifier limitations (claims 9, 12, 14, 17, 19, 20).


5. Motivation to combine (the KSR core)

A POSITA at 2008-09-30 had strong, documented reasons to combine these teachings, and none of the combinations is unpredictable:

  1. The patent's own admitted problem. The Background states that mobile devices' "small screen sizes and storage capacity … make it difficult for users to view, sort, organize, and manipulate communications" and that "current applications do not provide convenient ways for users to view communications compactly." That is an express design incentive, and it is the same problem the record's references address (Goldberg: dialogue continuity; EAS: "optimized to deal with high-latency and low-bandwidth networks as well as low-capacity clients").
  2. Bandwidth/storage economy. The ActiveSync white paper and the Exchange 2003 SP2 materials teach filtering, truncation, "allow only a certain amount of email to be downloaded," and attachment blocking precisely to save bandwidth. Extending "don't fetch what the user doesn't want" from content/size filters to a user-designated conversation-level suppression is a predictable extension of the same principle.
  3. Ignore/block was a known user-facing control. Heikes discloses "Ignore," "Ignore All," and "Block," and expressly extends their effect to subsequent related messages. Applying an already-known suppression control to a newly-identified grouping (a conversation) is the paradigm KSR case of using a known technique for its known purpose.
  4. Identifier-tagging of messages was known. US 6,212,553 discloses attaching structured associated data to an e-mail and carrying it through transmission; EAS discloses GUID-plus-increment identifiers for synchronized objects. Nothing in the claims' "conversation identifier" requires more than routine selection from these known schemes (the claims themselves recite the identifier generically).
  5. The UI conventions are conventional. Indented replies, paperclip/attachment indicators, envelope read/unread icons, and action menus were standard mail-client vocabulary by 2008 (Outlook 2003 offline NPL; Outlook/Outlook Web Access referenced throughout EAS). Aggregating per-message indicators to the conversation level is "a predictable use of prior art elements according to their established functions."
  6. Field density as objective evidence. The page's "Families Citing this Family (30)" and "Cited By (15)" listings show later filings by Facebook, IBM, Dropbox, Samsung, BlackBerry, Amazon, and Google in the same narrow space. A crowded field of incremental improvements on the same problem is consistent with a low non-obviousness bar.

Reasonable expectation of success: every element lives in the same art (client-server messaging/synchronization), uses deterministic data structures, and requires no experimentation beyond ordinary engineering. There is no teaching away in the record.


6. Where the obviousness case is weak — and how a patent owner would respond

I want to be candid about the soft spots rather than overstate the case.

  • The tree hierarchy is not in the record. No cited reference plainly discloses displaying, on a mobile client, message elements indented in a reply tree. Active Mail's conversation log is sequential rather than visibly indented, and the Andrew Message System is referenced only in Active Mail's own background discussion. A § 103 rejection on Ground B could be overcome by arguing that none of the references teaches "a reply communication indented and below the communication," unless the examiner adds art (usenet/newsreader threading, Notes, or Outlook conversation view). This is the single most likely point of non-obviousness in claim 1.
  • The attachment roll-up icon is not squarely disclosed. Ground B relies on conventionalization, which invites a "no disclosure of the specific aggregated indicator" rebuttal. The applicant deliberately narrowed claim 1 to this limitation during prosecution, which is evidence they viewed it as the distinguishing feature.
  • Granularity mismatch on "ignore." Heikes ignores senders; the claims ignore conversations. A patent owner will argue the identification of the conversation (rather than the sender) is a different unit of suppression. Rebuttable, but the response is inference, not literal disclosure.
  • All three independent claims require ignore. Because "ignore" was newly added in the granted claims relative to pre-grant publication US 2010/0082759 A1, any obviousness attack on the granted set must succeed on the ignore limitation. That is the hinge of the case.
  • Secondary considerations. The owner could point to the three same-priority continuations (US 9,870,124 B2; US 10,430,032 B2; US 11,194,446 B2), suggesting the family was commercially significant to Microsoft, and to the feature's presence in shipped mobile mail clients. But I found no evidence in the record of a nexus between the claimed aggregate (attachment roll-up + tree hierarchy + ignore) and any commercial success, and no long-felt-but-unsolved-need evidence. Without a nexus, these carry little weight under KSR.
  • Confidence levels. Ground A/claims 8 & 13: moderate-to-high — the identifier-on-message steps are nearly literal in US 6,212,553 and EAS. Ground B/claim 1: moderate — strong on the conversation-grouping and ignore elements, weak on the tree hierarchy and attachment roll-up. Dependent claims: high on the sync/period-of-time and GUID/incrementing-number limitations, which the EAS materials disclose nearly verbatim.

7. Caveats

  1. I worked from the citations displayed on the patent's Google Patents page plus verified public text. I did not retrieve the full text of every one of the 14 patent citations or all five NPL items; where I characterize a reference's disclosure, I did so from its abstract/claims/description excerpts or from a verified mirror, and I say so.
  2. The ActiveSync white paper is a third-party-mirrored copy dated "October 2020" in the mirror's header while the patent's NPL list cites the same document as "Jul. 2008." I treat the substantive content as the 2003/2008-era Exchange ActiveSync documentation; the mirror's display date is a hosting artifact and I do not treat it as changing the reference's date.
  3. This is a technical § 103 analysis, not a legal opinion, and it is not a substitute for a full IPR-style search. The strongest art against claim 1's UI limitations (thread-tree display on a handheld) is likely outside this record, and I have not attempted to assemble that art here beyond noting the gap.
  4. Consistent with the earlier sections, I found no litigation or PTAB record involving this patent; nothing in this analysis changes that finding.

Generated 9/29/2026, 5:22:14 PM

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