Invalidity dossier
US 8863198
Television having silos that animate content source searching and selection
Current assignee: Qingdao Hisense Electronics Co Ltd
Added 10/1/2026, 9:16:23 AM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for this specific patent number and check for any CAFC/litigation activity.
Let me pull the claim language and check for litigation/appeal activity involving this patent or its owner.
US Patent 8,863,198 — Analyst Summary
Important search-conduct note: I searched for (a) the specific patent number in USPTO/patent databases and (b) CAFC 2026 docket activity tied to "8863198." I found no CAFC 2026 docket or Federal Circuit appeal for this specific patent number. I am therefore not able to confirm any CAFC 2026 appeal, appellant, or docket number for US 8,863,198. A later Google Patents banner on this family does carry a generic "Family has litigation / First worldwide family litigation filed" notice (linking to a Darts-IP family record, family ID 50099797), but that notice does not identify a court, a 2026 case, or a CAFC matter, and I could not verify it against an authoritative docket. Treat any litigation claim as unconfirmed unless corroborated.
Bibliographic data (verified)
| Field | Value |
|---|---|
| Patent number | US 8,863,198 B2 |
| Title | Television having silos that animate content source searching and selection |
| Application no. | 13/864,206 |
| Pre-grant publication | US 2014/0053221 A1 (Feb. 20, 2014) |
| Filing date | Apr. 16, 2013 |
| Priority date | Aug. 17, 2012 (per Google Patents; a PCT/US13/55371 filing of Aug. 16, 2013 appears in related prosecution) |
| Issue/grant date | Oct. 14, 2014 |
| Inventors | Sanjiv Sirpal (Oakville, CA); Salvador Soto (Toronto, CA); Mohammed Selim (Oakville, CA); Ron Cassar (Burlington, CA) |
| Original assignee | Flextronics AP, LLC (San Jose, CA) |
| Current assignee (per Google Patents) | Qingdao Hisense Electronics Co., Ltd. |
| Assignment chain | Flextronics AP → Z124 (2015) → Jamdeo Technologies Ltd. (2015) → Hisense International Co./Hisense USA Corp./Jamdeo (2015) → Qingdao Hisense Electronics (2019) |
| Claims | 12 claims, 37 drawing sheets |
| Primary examiner | Hoang-Vu A. Nguyen-Ba |
| Anticipated expiration (listed) | 2033-04-16 |
Caveat on assignee: "Original assignee" (Flextronics AP, LLC) is what appears on the face of the grant; the "current assignee" reflects post-grant recordal of assignments, not necessarily the entity that would assert the patent today. US patents do not themselves name a "current assignee."
Abstract (verbatim)
"An Intelligent TV can organize content into silos. a silo is a logical representation of a content source for the Intelligent television. Silo can include content applications (e.g., Live TV, VOD, media center, application center, etc.) and/or input sources. The Intelligent TV can receive a designation for a silo through the reception of signals from a remote control or a user interface. Based on the designation, the Intelligent TV can determine the silo desired by the user. Then, the Intelligent TV can transition to the desired silo and provide content from the silo."
Plain-language overview of the independent claims
Uncertainty flag: the claim set in the authoritative text supplied to me stops before the claims, so I could not retrieve the full verbatim text of all 12 claims. Based on the pre-grant publication (US 2014/0053221 A1) and the granted record, claim 1 is the principal independent claim and reads essentially as follows (summarized):
Claim 1 (method): A method for providing content in an Intelligent TV comprising three steps — (1) receiving a designation for a silo, where a "silo" is defined as a logical representation of a content source for the Intelligent TV; (2) based on that designation, determining the silo; and (3) providing content from the silo.
- Plain language: the TV conceptually groups every content origin into "silos"; the user (via remote or on-screen UI) selects a silo; the TV figures out which silo was selected and then plays/serves the content from it.
Claim 2 (dependent): The method of claim 1 wherein a silo is a content application or an input source — i.e., the silo can be an app like Live TV or VOD, or a hardware input.
Other independent claims: With 12 total claims and prior-art keywords "silo / content / content application / application / instructions," the set plausibly includes a companion apparatus/system claim and/or a non-transitory computer-readable-medium ("instructions") claim mirroring the method. I could not verify the exact wording or count of the remaining independent claims and am not asserting them as fact.
Practical observations on scope
- The grant title emphasizes silos that "animate" content-source searching/selection, and related family patents (e.g., US 10,341,738, "Silo manager") recite detailed sliding/zoom transition animations, strip/grid layouts, and panel hierarchies. The granted claim 1 of '198 does not itself recite animation — it is directed to the more general receive-designation → determine-silo → provide-content sequence. So the title is broader than the granted independent claim.
- The claim language is relatively functional and broad, which is typical of software/GUI-era television patents and relevant to obviousness/§101-style challenges.
Bottom line
US 8,863,198 is a Flextronics-origin (now Hisense-linked) "Intelligent TV" patent on logical content-source "silos," filed Apr. 16, 2013, issued Oct. 14, 2014, 12 claims, with a broad three-step independent method claim. There is a generic family-litigation flag on Google Patents, but I found no CAFC 2026 docket for this number, and I could not verify all independent-claim text — treat those two gaps as explicit unknowns rather than confirmed negatives.
Generated 10/1/2026, 10:03:15 AM
Cases on file (0)
Specific litigation cases in our database that name US patent 8863198. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll search for litigation involving US patent 8863198 across patent litigation databases.
The first search returned results for US 8,863,319 (an unrelated helmet patent) — I will not conflate that with the requested US 8,863,198. Let me search specifically for the correct patent and its owners.
Let me search the specific litigation databases and the patent's family litigation record.
Summary: No confirmed litigation specifically asserting US 8,863,198
Based on my searches of patent-litigation sources, I did not find any court case that specifically identifies U.S. Patent No. 8,863,198 ("Television having silos that animate content source searching and selection") as an asserted patent. I want to state that up front rather than pad the answer with tangentially related cases.
Important disambiguation warning
Searching for the number surfaced results for US 8,863,319 — a completely unrelated patent (a multi-layer helmet/sliding-shell technology asserted in BrainGuard Technologies, Inc. v. Revelyst Sales LLC, No. 8:24-cv-2652-JWH-ADS (C.D. Cal.), and its IPR2025-01029). Per your instruction not to auto-correct identifiers, I am not treating 8,863,319 as a typo for 8,863,198. They are different patents owned by different parties, and any litigation on the '319 helmet patent should not be attributed to the '198 television patent.
What the record shows about US 8,863,198
- Owner chain (from the patent's own front page): Flextronics AP, LLC (original assignee) → Z124 → Jamdeo Technologies Ltd. → [Hisense International Co., Ltd.](/litigations/by-defendant/Hisense%20International%20Co.%2C%20Ltd.) / Hisense USA Corp. → Qingdao Hisense Electronics Co., Ltd. (current assignee). Inventors: Sanjiv Sirpal, Salvador Soto, Mohammed Selim, Ron Cassar. Priority date Aug. 17, 2012; filed Apr. 16, 2013; granted Oct. 14, 2014; app. 13/864,206.
- Family litigation flag: The Google Patents page carries a "Family has litigation — First worldwide family litigation filed" indicator linking to a Darts-IP family record (family=50099797). This signals that some member of this patent family has been litigated somewhere, but the page does not identify which family member, the parties, or the forum. I could not retrieve the underlying Darts-IP record, so I cannot confirm the
'198patent itself is the asserted member.
Hisense-related cases I did find — none confirmed to assert '198
The '198 patent's owners (Hisense) appear as defendants in numerous recent patent suits, but none of the ones I could inspect list US 8,863,198 among the asserted patents:
| Case | Court / No. | Filed | Patents asserted (as identified in the sources) |
|---|---|---|---|
| InterDigital, Inc. et al. v. Hisense Co., Ltd. et al. | N.D. Ga., No. 1:26-cv-00754 | 2026 | US 8,085,846; 9,294,784; 10,250,877; 11,695,962; 11,399,168; 9,654,751 |
| Fairlight Innovations LLC v. Hisense Company Ltd. et al. | E.D. Tex., No. 2:26-cv-00494 (Judge Gilstrap) | June 22–23, 2026 | Not identified in retrieved records |
| Lonestar Crystal Display LLC v. Hisense Co., Ltd. et al. | E.D. Tex., No. 2:26-cv-00445 (Judge Gilstrap) | June 5–8, 2026 | Not identified in retrieved records |
| Cerinet USA, Inc. v. Hisense USA Corporation | N.D. Ga., No. 1:26-cv-03719 (Judge Geraghty) | July 2, 2026 | Not identified in retrieved records |
| Touchstream Technologies, Inc. v. Hisense Co. Ltd. et al. | E.D. Tex., No. 2:25-cv-00753 | Aug. 1, 2025 | Not identified in retrieved records |
| Err Content IP, LLC v. Hisense USA Corp. | E.D. Tex., No. 2:24-cv-01053 (Judge Gilstrap) | Dec. 16, 2024 | Not identified in retrieved records |
| Phenix Longhorn, LLC v. AUO Corp. / Hisense Visual | E.D. Tex. (Marshall Div.) | 2023–2024; defense verdict Feb. 4, 2026 | US 7,233,305 and 7,557,788 |
I emphasize that the blank "Patents asserted" cells reflect incomplete data, not a confirmation that '198 is or is not included. Those dockets would need to be pulled directly to be certain.
Bottom line
- Known litigation naming US 8,863,198 as an asserted patent: none that I can confirm.
- A family-level litigation flag exists (Darts-IP family 50099797), so litigation involving a related patent in this family is likely, but I could not verify which member or the parties.
- US 8,863,319 results are a different patent and should not be conflated.
Recommended verification steps (high confidence needed)
- Unified Patents litigation portal (
portal.unifiedpatents.com/litigation/caselist) — filter by patent number 8,863,198. - Darts-IP family 50099797 — to identify the specific litigated family member.
- PACER / Docket Alarm / Justia — full-text search
"8,863,198"across district courts (my search snippets did not return a direct hit). - USPTO Patent Center / Assignment records for the
'198patent to track any transfers tied to litigation.
If you have a specific district, party, or time window in mind, I can narrow further — but I will not fabricate a case number or outcome that the sources do not support.
Generated 10/1/2026, 10:03:29 AM
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.
Proceedings overview
Total AIA trial proceedings on file for US 8,863,198: zero (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials) — the canonical USPTO Open Data Portal record supplied in this prompt returns no AIA trial proceedings, and my independent web searches turned up no IPR, PGR, or CBM ever filed against this patent, which means the patent is untested rather than hardened: not one claim has been adjudicated by the Board, so every claim 1–N (as issued 2014-10-14) remains presumptively valid and available to the patent owner.
I want to be explicit about the limits of that statement, because "no activity" is the kind of finding that should not be overstated:
- The structured "PTAB proceedings on file" block in this prompt is the authoritative source, and it says the ODP API returns no AIA trials. That is the primary basis for the zero count.
- My web searches (queries targeting the patent number, the "silo" claim vocabulary, the inventors Sirpal/Selim/Soto/Cassar, and the current assignee Hisense) surfaced no petition, institution decision, FWD, or appeal referencing US 8,863,198. Searches for
"8863198" inter partes reviewreturned unrelated patents (e.g., the plant-pot design USD409946S and a Moskowitz IPR on a different '319 patent) — classic false-positive noise, not this patent. - I could not verify absence with 100% certainty because the Google Patents page for US 8,863,198 has no "PTAB" or "IPR" entries under its apps/litigation links, and the PTAB E2E docket is not directly searchable via the tools I have here. If a proceeding were filed and terminated within a narrow window and not indexed by ODP, my search would miss it. I flag that as a residual risk rather than a finding.
Bottom line defensive posture for a defendant: This is the rare case where the absence of PTAB history cuts for the patent owner. There are no canceled claims to point at, no FWD findings of unpatentability to import into a § 282 defense, and no § 315(e)(2) estoppel to exploit. You are the first party who would get to test these claims at the Board — which is an opportunity, but also means you carry the full burden of building the invalidity record from scratch.
Per-proceeding detail
No proceedings exist to enumerate. The following are the related matters I could confirm, presented so a defendant knows where the patent actually sits — but none of these are AIA trials on US 8,863,198, and none should be cited as if they were.
(No AIA proceeding) — n/a v. Qingdao Hisense Electronics Co., Ltd. (current assignee); originally Flextronics AP, LLC
- Type: n/a — no IPR / PGR / CBM on file
- Filed: n/a
- Status: No proceeding on file
- Judge panel: n/a — no panel has ever been assigned
- Petition grounds: n/a — no ground under § 102, § 103, or § 112 has been advanced at the Board
- Institution decision: n/a — no institution deadline has begun running
- Final Written Decision: n/a — no claim has been canceled, confirmed, or even construed by the Board
- Settlement / termination: n/a
- Appeal: n/a — no FWD, therefore no CAFC docket
- Defensive value: Neutral-to-unfavorable. You get the first shot at the claims, but you also have no Board precedent, no adopted claim constructions, and no canceled claims to lean on. Any IPR you file is a genuinely first-impression validity challenge.
Related context (district court, not PTAB)
These are not AIA proceedings and I am listing them only because they establish that the Jamdeo / Hisense "intelligent television" family — the family that includes US 8,863,198 (Jamdeo Technologies Ltd. / Hisense assignees) — has been asserted in litigation, which is the usual precursor to IPRs:
- Multimedia Technologies Pte Ltd v. Vizio Inc, No. 2:23-cv-00124 (E.D. Tex.) — asserts a portfolio of intelligent-TV patents, including US 9,055,255 (live TV application claims) and US 9,510,040 (global panel / sources-list claims). Complaint analysis at ai-lab.exparte.com — see the claim-chart excerpts discussing "intelligent television" limitations. (Note: I am relaying a third-party complaint-analysis page; verify against the actual docket before relying on it.)
- Multimedia Tech Pte Ltd v. Vizio Inc, No. 2:25-cv-00577 (C.D. Cal.) — a follow-on assertion of overlapping intelligent-TV patents, again including US 9,055,255 and the "global panel" claim set. See ai-lab-cl-prod.azurewebsites.net complaint analysis.
- Google Patents flags that the US 8,863,198 family "has litigation" (Darts-IP family 50099797), consistent with a portfolio that is being actively asserted.
Critical caveat: US 8,863,198 itself is not identified in the search results I obtained as an asserted patent in those complaints. Do not tell a client that '198 is in suit based on this. The sibling patents share specification language ("silos," "global panel," "live TV application"), so the family is clearly in play — but that is an inference about portfolio strategy, not a verified fact about '198.
Strategic summary
Claim status. Every claim of US 8,863,198 is UNTESTED at the Board. There are no CANCELED claims and no SUSTAINED claims, because no FWD exists. Unlike the typical well-asserted patent — where you would expect a claim-by-claim ledger of what died in IPR — here you must treat the full issued claim set as live. The only "narrowing" of record is whatever happened during original prosecution (the patent issued 2014-10-14 from App. No. 13/864,206, filed 2013-04-16, claiming priority to 2012-08-17), and any prosecution-history estoppel from that record is a § 282/claim-construction tool, not an invalidity adjudication.
Estoppel landscape. Because no IPR was ever instituted, § 315(e)(2) estoppel has never attached against anyone. There is no petitioner, no privy, and therefore no ground that is off-limits in district court. For a defendant today:
- All § 102 and § 103 prior-art grounds are fully available to you in litigation and in a new IPR.
- You are not bound by any Board claim construction from a prior proceeding — there is none. Phillips applies cleanly in court, and you would get the Board's Phillips-based construction in a new IPR.
- The only timing constraints on you as a would-be petitioner are the § 315(b) one-year bar (running from service of a complaint alleging infringement of this patent on you) and § 325(d) discretion, which is a non-issue since the Board has no prior-art record on this patent to defer to.
Available statutory vehicles — with one caveat. The patent is an AIA patent (filed 2013-04-16), so:
- PGR is time-barred. The § 321(c) nine-month window closed on or about 2015-07-14, nine months after the 2014-10-14 grant. You cannot file a PGR.
- CBM is effectively unavailable. CBM review was sunset for new petitions as of 2020-09-16, so even if the claims could be characterized as "covered business method" (a stretch for a television silo/user-interface patent, which the Board has generally treated as technological rather than financial), that door is closed.
- IPR under § 311 is the only live AIA vehicle — limited to § 102/§ 103 grounds on patents and printed publications.
- Ex parte reexam remains available for § 102/§ 103 art, and unlike IPR is not subject to the § 315(b) bar — worth keeping in reserve if a client is time-barred from IPR.
Pattern signals. No petitioner has ever filed on this patent, so there is no serial-petitioner pattern, no defensive aggregator (e.g., Unified Patents) in the chain, and no patent-owner appeal history at the CAFC for this patent. The strategic read: the patent is a candidate for a pre-assertion IPR by a defensive aggregator or a joint-defense group, precisely because the claims are untested and the family is being actively asserted against TV makers. If you are a defendant in the smart-TV space, you may not be the only one looking at this patent.
Recommended next steps
There is no FWD to link to, and no canceled claim to quote. State that plainly to the client: no claims of US 8,863,198 have been invalidated by the Board, so any demand letter asserting claims 1+ is asserting claims that have never been tested. Unlike a hardened-after-IPR patent, there is no "claim 1 is dead" argument available here.
Run an independent, fresh IPR-quality invalidity search before deciding strategy. Because nothing has been litigated, the prior art on this patent is an open field. The Google Patents face record shows heavy citation of 1990s–2000s interactive-TV/EPG art (Rowe, Alexander, Yuen, Ellis, Klosterman, Satterfield, etc.) — the same art families that populate this whole Jamdeo specification. Focus on art teaching a plural "content source" selection model with animated transitions between sources, which is the core of the silo claims. A Board rejection of the broadest independent claim would be the single most leveraged outcome available to you.
If any complaint asserting '198 has been served on you, calendar the § 315(b) one-year bar immediately. That is the only hard deadline on a would-be petitioner. If the one-year window has closed for you, shift to ex parte reexam or to a § 282 invalidity defense in the district court case.
If you institute, the trial clock is statutory and unforgiving. Under § 316(a)(11) the Board must issue an FWD within 12 months of the institution decision, extendable only by up to six months for good cause (37 C.F.R. § 42.100(c)). Key milestones to calendar: PO preliminary response (+3 months from notice of filing), institution decision deadline (+6 months from the petition's filing-date notice), PO response (+3 months post-institution), petitioner reply (+3 months), oral hearing (typically ~1 month before the FWD), FWD due at 12 months. No trial is currently running, so none of these clocks have started.
Do not represent the zero count as a verified all-clear. I could not directly interrogate the PTAB E2E docket with my available tools, and the ODP record you supplied is only as current as its last ingest. Before filing anything, run a Docket Alarm / Darts-IP / PTAB E2E docket check on US 8,863,198 and on the family members (US 9,060,152, US 9,807,446, US 9,119,967, US 10,051,314, US 10,079,864, and the other 13/864,xxx and 14/xxx,xxx siblings) — a third party's IPR on a sibling is not estoppel against you but is highly informative about which claim language the Board has accepted as unpatentable, and it is the closest thing you will get to a preview of how a '198 IPR would fare.
One-sentence bottom line for the client: No AIA trial has ever touched US 8,863,198 — there is no PTAB win to inherit and no estoppel to exploit, but also no Board finding that the claims are good, so the patent is wide open to a first-impression IPR challenge on § 102/§ 103 grounds, subject only to your own § 315(b) one-year clock.
Generated 10/1/2026, 10:03:39 AM
Ownership chain (6)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2013-10-29 · Assignment of assignors' interest
Ron Cassar; Sanjiv Sirpal; Mohammed Selim; Salvador SotoFLEXTRONICS AP, LLC
2015-03-31 · recorded 2015-04-10 · reel 035381/0780 · Assignment of assignors' interest
Sanjiv Sirpal; Mohammed Selim; Alexander De Paz; Salvador Soto; Saulo Dourado; Fuqu Wu; Dean BrittoJamdeo Canada Ltd.; Hisense USA Corp.; Hisense Electric Co., Ltd.; Hisense International Co., Ltd.
Correspondent: John P. Teresinski
internal reorg
? · recorded 2015-05-28 · Assignment
internal reorg
? · recorded 2015-07-09 · Assignment
internal reorg
? · recorded 2015-07-09 · Assignment
Jamdeo Technologies Ltd.Hisense International Co., Ltd.; Jamdeo Technologies Ltd.; Hisense USA Corp.
internal reorg
? · recorded 2019-01-09 · Assignment
Hisense International Co., Ltd.; Hisense USA Corp.; Jamdeo Technologies Ltd.Qingdao Hisense Electronics Co., Ltd.
internal reorg
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll research the assignment record for this patent across USPTO Assignment Center, Google Patents legal events, and related sources.
Let me dig deeper into the specific assignment records and the entities involved.
Let me find the actual reel/frame records and correspondents for each link in this chain.
Assignment & Ownership Reconstruction — US 8,863,198
Evidence-integrity note (read first): I did not obtain the reel/frame numbers, execution dates, or correspondents of record for the four post-issuance links on this specific patent. Those fields live in the USPTO Assignment Center record, and my searches surfaced the Google Patents legal-events entries (which carry dates and parties but not reel/frame) plus one related Jamdeo assignment PDF for a different application. I will not invent reel/frame numbers. Where a field is unavailable I say "not retrieved" rather than guess. This is a partial finding, not a clean negative.
There is also a contradiction to flag with the previously generated summary: that summary stated it "found no CAFC 2026 docket" — I likewise found no verified litigation. But the same summary noted the Google Patents "family has litigation" banner (Darts-IP family 50099797). That banner remains uncorroborated here; I could not open a Darts-IP record, a court docket, or a complaint.
Inventors
| Inventor | Residence at filing | Employer at filing (determinable) |
|---|---|---|
| Sanjiv Sirpal | Oakville, Ontario, Canada | Flextronics / Z124 Canadian design operation |
| Salvador Soto | Toronto, Ontario, Canada | Flextronics / Z124 Canadian design operation |
| Mohammed Selim | Oakville, Ontario, Canada | Flextronics / Z124 Canadian design operation |
| Ron Cassar | Burlington, Ontario, Canada | Flextronics / Z124 Canadian design operation |
Employer determination: The issued patent names Flextronics AP, LLC (San Jose, CA) as assignee, but all four inventors are Ontario-based. The corroborating address evidence is in a related assignment (app 14/674,908, "System and method for display device configuration"): the assignors' mailing address is recorded as "c/o Jamdeo Canada Ltd., 2305 Wyecroft Road, Suite 201, Oakville, Ontario, L6L6R2, Canada" — and that same instrument lists Sirpal, Selim, and Soto (plus Alexander De Paz, Saulo Dourado, Fuqu Wu, Dean Britto) executing to Jamdeo Canada Ltd. and the Hisense entities on 2015-03-31. This ties the '198 inventor group to the Flextronics→Z124→Jamdeo→Hisense Canadian operation rather than to Flextronics' San Jose parent.
Unusual-pattern check — not present: The classic red flag (all inventors departing the original assignee within ~12 months of filing, preceding a fire-sale) does not appear. Sirpal, Selim, and Soto were still executing assignment instruments tied to the same operation as late as March 2015, ~2 years after the April 2013 filing. Cassar appears in the original 2013 inventor→Flextronics assignment. The inventor team and the portfolio moved together through the corporate chain — consistent with a business-unit divestiture, not abandonment.
Original assignee
Flextronics AP, LLC (San Jose, California, US) — named on the face of the issued patent (Oct. 14, 2014).
- Primary line of business: Flextronics (now Flex Ltd., renamed 2015) is a global electronics manufacturing services (EMS) / design-and-build contractor. "Flextronics AP, LLC" functions as a holding/IP entity within the Flextronics group, not an end-product brand.
- Did it ship a product embodying the claims? Unclear. The patent is directed to an "Intelligent TV" silo UI. Flextronics was an ODM/EMS rather than a consumer-brand TV seller; whether a Flextronics-branded Intelligent TV shipped under this entity is not determinable from the records I retrieved. The software I saw (the "Jamdeo"/Z124-era Intelligent TV UI) was commercialized by the downstream Jamdeo/Hisense entities.
- Current status: Flextronics corporate parent is operating (as Flex Ltd.); the specific "Flextronics AP, LLC" IP-holding vehicle's current status was not independently verified.
Assignment timeline
Dates below are the Google Patents legal-event (recordation) dates; execution dates and reel/frame numbers were not retrievable in this session — treat the reel/frame field as an open item to confirm at the Assignment Center.
2013-10-29 (recorded) — Reel not retrieved
- Conveyance: Assignment of assignors' interest
- Assignor: Ron Cassar; Sanjiv Sirpal; Mohammed Selim; Salvador Soto (the inventors)
- Assignee: Flextronics AP, LLC
- Correspondent: not retrieved
- Context: Standard inventor→company employment/invention assignment to the original assignee.
2015-05-28 (recorded) — Reel not retrieved
- Conveyance: Assignment
- Assignor: Flextronics AP, LLC
- Assignee: Z124
- Correspondent: not retrieved
- Context: Internal reorg / divestiture — the Flextronics Intelligent-TV and multi-screen business was moved out to Z124 (the Flextronics-affiliated multi-display venture).
2015-07-09 (recorded) — Reel not retrieved
- Conveyance: Assignment
- Assignor: Z124
- Assignee: Jamdeo Technologies Ltd.
- Correspondent: not retrieved
- Context: Transfer of the family to the Jamdeo software/IP company (whose Canadian arm, Jamdeo Canada Ltd., is the Oakville operation addressed in the related 2015 instrument).
2015-07-09 (recorded) — Reel not retrieved
- Conveyance: Assignment
- Assignor: Jamdeo Technologies Ltd.
- Assignee: Hisense International Co., Ltd.; Jamdeo Technologies Ltd.; Hisense USA Corp. (co-owners)
- Correspondent: not retrieved
- Context: Transfer into the Hisense-affiliated group on a co-ownership basis.
2019-01-09 (recorded) — Reel not retrieved
- Conveyance: Assignment
- Assignor: Hisense International Co., Ltd.; Hisense USA Corp.; Jamdeo Technologies Ltd.
- Assignee: Qingdao Hisense Electronics Co., Ltd.
- Correspondent: not retrieved
- Context: Internal consolidation of the family under the Qingdao Hisense operating entity (the current assignee of record).
Related record — different application, same inventor group and same transaction wave
- Executed 2015-03-31 / recorded 2015-04-10 — Reel 035381 / Frame 0780
- Conveyance: Assignment of assignors' interest
- Assignors: Sanjiv Sirpal; Mohammed Selim; Alexander De Paz; Salvador Soto; Saulo Dourado; Fuqu Wu; Dean Britto
- Assignees: Jamdeo Canada Ltd. (2305 Wyecroft Road, Suite 201, Oakville, Ontario, L6L6R2, Canada) — with receiving parties including Hisense USA Corp. (7310 McGinnis Ferry Road, Suwanee, GA 30024), Hisense Electric Co., Ltd. (No. 218 Qianwangang Road, Qingdao, Shandong 266555, China) and Hisense International Co., Ltd. (Qingdao, P.R.C.)
- Property: U.S. App. 14/674,908, "System and method for display device configuration" (docket 1958936.00004)
- Name of submitter: JOHN P. TERESINSKI
- Source: http://legacy-assignments.uspto.gov/assignments/assignment-pat-035381-0780.pdf
- Context: Not a record for '198 (different application), but it is probative: it shows the Flextronics/Z124 multi-display inventor team, the Jamdeo Canada Oakville address, the Hisense co-owner set, and a named recording correspondent all in one instrument during the same 2015 restructuring window.
Timeline diagram
timeline
title Ownership of US 8863198
2012 : Priority date Aug 17
2013 : Filed Apr 16 by four inventors
: Assigned to Flextronics AP LLC
2014 : Patent issued Oct 14
2015 : Flextronics assigns to Z124
: Z124 assigns to Jamdeo Technologies
: Jamdeo and Hisense take co ownership
2019 : Assigned to Qingdao Hisense Electronics
NPE / troll-pattern signals
1. Shell-entity transfer — not present.
No link moves the patent to a licensing-only LLC with an "IP / Patents / Licensing / Holdings / Ventures" suffix. The chain runs Flextronics AP, LLC → Z124 → Jamdeo Technologies Ltd. → Hisense entities → Qingdao Hisense Electronics Co., Ltd. Z124 and Jamdeo are holding/software vehicles, but they remain tied to an operating consumer-electronics business (Hisense). No single-purpose Delaware/Texas LLC and no registered-agent-service address appears in the record I retrieved. (Reel/frame entries unavailable — this call is based on the party chain, not the recorded addresses.)
2. Known asserter in the chain — not present.
No assignee matches the public NPE lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). The terminal assignee, Qingdao Hisense Electronics Co., Ltd., is a large operating TV/appliance manufacturer.
3. Repeat correspondent across the chain — unclear (one data point only).
The only correspondent-type name I recovered is John P. Teresinski, recorded as the name of submitter on the related Jamdeo Canada assignment (Reel 035381/0780, recorded 2015-04-10). Because I could not retrieve the correspondent-of-record fields for the four '198 links, I cannot state that Teresinski recurs across this patent's chain. A single appearance is explicitly not a finding under the stated rule. Flag for follow-up: pull the reel/frame correspondent fields for '198 and compare against 035381/0780.
4. Cascading transfers — present (weak/moderate).
Two consecutive assignments were recorded on the same day, 2015-07-09 (Z124 → Jamdeo Technologies Ltd.; then Jamdeo Technologies Ltd. → Jamdeo/Hisense co-ownership), preceded by Flextronics → Z124 on 2015-05-28 — three recorded transfers in under seven weeks. However, the parties are affiliated operating/holding entities (Flextronics, Z124, Jamdeo, Hisense), not anonymous chained LLCs sharing a correspondent address. This pattern is equally consistent with a corporate divestiture-and-consolidation as with NPE laddering, so it is a weak signal at most.
5. Pre-litigation transfer — unclear.
The final transfer to Qingdao Hisense Electronics was recorded 2019-01-09. I could not verify any infringement suit naming this patent, so I cannot test the "assignment within 6 months before first suit" criterion. The Google Patents "family has litigation" banner (Darts-IP family 50099797) is uncorroborated and, on its face, does not identify a court, date, or 2026 case. Do not treat it as establishing assertion.
6. Bankruptcy fire-sale — not present.
No Chapter 7/11 sale. The original assignee's corporate parent (Flextronics/Flex) remained solvent and operating; the transfers read as a business-unit divestiture, not a distressed liquidation.
7. Privateering — unclear / not present.
No evidence either way that an operating company (Flextronics/Hisense) transferred the patent to an NPE to assert on its behalf. No SEC-filing, Patent Progress, or EFF coverage surfaced connecting this family to an assertion vehicle.
8. Defensive aggregator (anti-NPE) — not present.
The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at a product manufacturer, so the patent is not neutralized by a defensive aggregator.
Verdict
Operating-company assertion.
Justification. Every link in the recorded chain terminates at operating or operating-affiliated entities and ends at Qingdao Hisense Electronics Co., Ltd. (recorded 2019-01-09), a major consumer-TV manufacturer — none of the canonical NPE shell/asserter signals (12/13 note: shell-LLC transfer, known NPE assignee, defensive-aggregator terminus, bankruptcy sale) are present. The only "cascading" feature is the 2015-05-28 / 2015-07-09 / 2015-07-09 cluster (Flextronics → Z124 → Jamdeo → Jamdeo+Hisense), which is best explained as a business-unit divestiture given that the same inventor team was simultaneously assigning the related Jamdeo Canada property (Reel 035381/0780, executed 2015-03-31). Because I could not verify a filed suit, the "assertion" prong rests on the unconfirmed Google Patents family-litigation banner; if that banner cannot be corroborated, the defensible characterization narrows to non-NPE operating-company ownership chain (no NPE pattern) rather than an active assertion campaign.
Confidence caveat: This verdict is limited by two gaps — (a) no reel/frame, execution-date, or correspondent fields retrieved for the four '198 links, and (b) no verified litigation docket. If you need assertion-grade evidence, the next two pulls are: the Assignment Center correspondent-of-record for each '198 reel/frame, and a Darts-IP/court-docket query on family 50099797.
Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent number 8863198); legacy AOTW mirror — https://assignment.uspto.gov/patent/index.html. Patent text/legal events — https://patents.google.com/patent/US8863198/en. Related instrument — http://legacy-assignments.uspto.gov/assignments/assignment-pat-035381-0780.pdf (Reel 035381/0780).
Generated 10/1/2026, 10:04:00 AM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll search for the specific patent's citation data.
I have strong leads. Let me pull the actual front‑page (56) References Cited list and the Google Patents citation set.
§102 Prior‑Art Analysis — US 8,863,198 B2
0. Search‑conduct note and explicit caveats (read before the tables)
Tool limitation. I ran the searches I could against the sources below, but I hit the tool‑call limit mid‑investigation. I therefore could not retrieve the complete, authoritative front‑page "(56) References Cited" list of US 8,863,198 (the PDF's page 1, or the PatentCenter "References Cited" pane). What follows separates (a) references I verified with a citable source from (b) references I could only partially retrieve and (c) items I could not resolve. Do not treat (b) or (c) as a complete §102 list.
Sources actually used:
- Google‑hosted USPTO‑style PDF of the grant:
https://patentimages.storage.googleapis.com/2f/79/2c/06f62865dbfe2e/US8863198.pdf - FreePatentsOnline record (front‑page reference list, partial):
https://www.freepatentsonline.com/8863198.html - Justia Patents record (claim text, "Patent History," cited Office Actions/ISRs):
https://patents.justia.com/patent/8863198 - USPTO PTAB/PatentCenter petition document (a Written Opinion citing "Smith" and "Martin" against silo claims):
https://ptacts.uspto.gov/ptacts/public-informations/petitions/1555837/download-documents?... - Justia record for the related "Silo manager" patent:
https://patents.justia.com/patent/10341738
I did not complete a direct PatentCenter/Patent Public Search query for 8,863,198; the "USPTO database" element of your request was met only through USPTO‑origin documents surfaced indirectly (the patentimages PDF of the grant and the ptacts.uspto.gov petition exhibit). Note this as a gap.
Two contradictions to flag explicitly:
- Date. Your task header says Current Date: April 26, 2026; my operating context says today is 2026‑10‑01. I have used the later date for "as of" statements; nothing in this analysis turns on the difference.
- Claim count / claim set. My earlier section recorded 12 claims (from the grant's front page: "12 Claims, 37 Drawing Sheets"), and the PDF front page confirms 12. However, the Justia record reproduces a 20‑claim set with three independent claims (claim 1 method; claim 11 "tangible computer readable medium"; claim 16 "intelligent television comprising a display, a memory, a processor"). That 20‑claim text appears to be the pre‑grant publication (US 2014/0053221 A1) claim set, not the granted set. Treat the granted independent‑claim count as unverified — if the grant has 12 claims, the independent claims are most likely claim 1 (method) and claim 11 (tangible CRM), with the "intelligent television" apparatus claim cancelled/renumbered. This directly affects which claims any reference can "anticipate."
Priority/statutory framework (matters for which §102 subsection applies). '198 was filed 2013‑04‑16 claiming a 2012‑08‑17 priority. Because at least one claim has an effective filing date before 2013‑03‑16, the pre‑AIA §§102/103 regime most likely governs (AIA first‑to‑file applies only where all claims have effective filing dates on/after 2013‑03‑16). Practical consequence:
- Art published more than one year before 2012‑08‑17 is §102(b) art (the strongest form).
- U.S. patents/applications filed before '198's filing date but published/p issuing later are only §102(e) art — and only if they are not commonly owned.
1. Bibliographic confirmation (verified)
| Field | Value | Source |
|---|---|---|
| Patent | US 8,863,198 B2, "Television having silos that animate content source searching and selection" | PDF front page |
| App. No. / Filing | 13/864,206 / Apr. 16, 2013 | PDF front page |
| Priority (listed) | Aug. 17, 2012 | Google Patents |
| Pre‑grant pub. | US 2014/0053221 A1, Feb. 20, 2014 | PDF front page |
| Grant | Oct. 14, 2014 | PDF front page |
| Inventors | Sirpal; Soto; Selim; Cassar | PDF front page |
| Assignee (face) | Flextronics AP, LLC, San Jose, CA | PDF front page |
| Primary examiner | Hoang‑Vu A. Nguyen‑Ba | Justia |
| Claims / sheets | 12 / 37 | PDF front page |
| Classes | 725/59; 725/48; 725/56; 725/61; 348/553; 348/570; 348/731 | Justia |
2. Verified prior‑art references — the sibling PCT International Search Report
The most probative, US‑examiner‑style art I could verify sits in the International Search Report for PCT/US13/55371 (applicant Flextronics AP, LLC; international filing 16 Aug 2013; earliest priority 17 Aug 2012; ISA/US; search completed 23 Oct 2013; ISR mailed 08 Nov 2013; authorized officer Shane Thomas). Found via patents.justia.com/patent/8863198 and the ptacts document.
Important caveat: this ISR is for the PCT sibling, and its Box C reasons against claims 1–20 of the PCT claim set — a set that does not match the grant's 12 claims (the ISR's abstract figure is "Figure 53", the grant's disclosure runs to FIG. 25). So these two references are family‑level prior art on the same specification, not proven to be the references the U.S. examiner applied in 13/864,206.
2.1 US 5,539,479 A — "Bertram, R. et al." (Category X)
| Item | Detail |
|---|---|
| Citation | US 5,539,479 A (Bertram, R., et al.) |
| Date | July 23, 1996 |
| Description | Per the ISR, the primary anticipatory reference (category X = "cannot be considered novel … when taken alone" under PCT practice). The examiner cited col. 2, lines 38–40; col. 33, lines 28–33; col. 37, lines 52–66; col. 38, lines 45–49; and col. 37, line 66 – col. 38, line 2 — i.e., the disclosure concerning user‑selectable program/service options in a television receiver. I could not verify its title or assignee to a high confidence level; do not attribute one. |
| Claims it potentially anticipates | Under the ISR, PCT claims 1–20 (all). Mapped onto '198, that means claim 1 (receiving a designation for a silo/content source, determining the silo from the designation, providing content from it) and, if present in the grant, the CRM claim (11) and apparatus claim (16). It is §102(b) art (1996 ≫ one year before the 2012 priority date). |
| Why it matters | This is the single strongest §102 candidate I found. If '198 claim 1 is materially identical to PCT claim 1 (it appears to be), then Bertram is a serious anticipation/102(b) challenge — and the fact the U.S. grant nonetheless issued means either (i) the granted claim 1 was amended relative to the PCT claim 1, (ii) the U.S. examiner did not have Bertram before him (it isn't confirmed on the '198 face), or (iii) the examiner drew a distinction on "silo" as a logical representation of a content source encompassing both applications and input sources. Resolution requires the '198 file wrapper (IDS and any 892s). |
2.2 US 6,661,468 B2 — "Alten, J. et al." (Category A)
| Item | Detail |
|---|---|
| Citation | US 6,661,468 B2 (Alten, J., et al.) |
| Date | December 9, 2003 |
| Description | Cited as category A — "document defining the general state of the art which is not considered to be of particular relevance" — and mapped only to claims 1, 11, 20. Content: an interactive television/program‑guide‑type disclosure (the "46" family assigns 6,661,468 to Alten et al.). Title/assignee not verified to high confidence. |
| Claims it potentially anticipates | None, on the ISR's own categorization. A "category A" reference is not an anticipation reference under §102; it is at most §103 background or general state of the art bearing on claims 1, 11 (and 20 if present). It is §102(b) art by date, but the ISR did not treat it as disclosing the claimed subject matter alone. |
3. Partially retrieved references — the '198 front‑page list (FreePatentsOnline)
FPO's "US Patent References" block for 8863198 is truncated in the retrieved text; the entries I could see are below. The ordering is anomalous (it begins with a 2014 publication), so I cannot confirm this is the complete or in‑order (56) list.
| Citation | Pub. date | Description | §102 impact on '198 |
|---|---|---|---|
| US 2014/0109143 A1 — Craner et al., "Systems and Methods for Content Surfing" | April 2014 | Rovi/UVPI‑style "content surfing" — browsing/navigating among content sources/offerings and switching to one. | Weak/conditional. Published after both '198's 2012 priority and its Apr. 16, 2013 filing. It can only be §102(e) art if its own U.S. effective filing date precedes 2013‑04‑16 and it is not commonly owned. Its appearance on the '198 face means it was considered by the examiner (i.e., an IDS/892 citation), not that it was applied. Filing date unresolved — flagging as an explicit unknown. If earlier‑filed, it is most relevant to claim 1 and to the "transition between silos" concepts (claims 4–5/12–13). |
| US 8,683,519 B2 — McCarthy et al., "Favorites Mosaic" | Mar. 25, 2014 | A mosaic/matrix presentation of a user's favorite channels/sources with selection of one. Conceptually close to '198's "two or more silos" and "contextual experience … based on an organization of the silos." | Conditional §102(e). Granted after '198 was filed, so it is not §102(a)/(b) art. It is §102(e) art only if its effective filing date precedes 2013‑04‑16. Best mapped to claims 2, 9, 10 (silo = content application or input source; two or more silos; contextual organization). Effective filing date unresolved — flag. |
Do not miscount these as prior art. The same FPO block lists a long run of Flextronics sibling publications dated March 2014 — e.g. US 2014/0075475, /0075476, /0075477, /0075479, /0075483, /0075484, /0075487 (Selim, de Paz, Soto, Sirpal) and US 2014/0068682, /0068683, /0068685, /0068689, /0068674 (Sirpal et al.). These are co‑pending, commonly owned applications claiming the same 2012‑08‑17 priority with overlapping inventors. They are not §102 art against '198: they share an effective filing date and are excepted as commonly owned disclosures (pre‑AIA §103(c) / AIA §102(b)(2)(C)). A naive reading of the citation list will wrongly treat them as anticipatory.
4. Unverified but highly probative lead — "Smith" and "Martin"
A USPTO ptacts.uspto.gov petition exhibit reproduces a Written Opinion that reasons against silo claims 1–20 (claim 10 = non‑transitory computer‑readable media) using exactly the '198/'738 claim concepts, and cites:
- "Smith" — teaches (i) maintaining an order of silos displayed in a strip or grid with horizontal scrolling, (ii) a notification panel indicating the selected silo (highlight/pulsing row), (iii) a placeholder image during the transition, (iv) dynamic content within a displayed silo with "highlight and enlarge and possibly exhibit dynamic animated behaviors," (v) a non‑transitory CRM storing the method, and (vi) an "Interactive Overview Visualization Model display interface for use with a computer" (para. 0086).
- "Martin" — teaches a silo displaying selectable content and silo subcategories (EPG 44, linear live TV 42, VOD 46 with categories such as TV series/game zone 48; display page 40, user interface 18; paras. [0068]–[0079], figs. 4–6), combined with Smith for the stated purpose of "selecting a video‑on‑demand when a limited amount of linear live TV is available."
Assessment: this Smith + Martin combination is the closest thing I found to a §103 rejection of the animated silo strip/grid subject matter that the '198 title advertises. But I could not resolve the full citations (patent/publication numbers, dates, assignees) within my search budget. Treat "Smith" and "Martin" as named but unidentified references — they may belong to the related "Silo manager" family's prosecution (compare the litigated‑style claim language in patents.justia.com/patent/10341738) rather than to 13/864,206. Unverified.
5. Non‑patent "citations" on the '198 record (not prior art)
Justia's "Patent History" for 8863198 lists IDS‑type items for the family, including:
- International Search Report and Written Opinion for PCT/US13/55494;
- International Search Report and Written Opinion for PCT/US2013/055342, mailed Apr. 17, 2014 (12 pages);
- Official Action for U.S. Appl. No. 13/864,214, mailed Mar. 12, 2014 (12 pages);
- Actions for 13/970,442; 13/968,610 (Apr. 30, 2014, 11 pages); 13/968,732 (May 27, 2014, 12 pages).
These are prior prosecution papers in sibling applications — they evidence what art the same examiner corps applied across the family, but they are not themselves §102 references. The sibling 13/864,214 is the most interesting: it is the physically adjacent application number to '198's 13/864,206 and its first Office Action is dated about a month before '198 issued, i.e., the collateral prosecution is the best available proxy for the art the examiner saw. I did not retrieve that action's citations — explicit gap.
Also visible in search results but irrelevant as §102 art (wrong family and/or post‑priority): WO 2014/052191 A1, WO 2014/062416 A1, WO 2014/078781 A1 (United Video Properties; priorities Sept.–Nov. 2012, all after '198's 2012‑08‑17 priority), and the ActiveVideo/Rovi items appearing in "Cited By"/"Similar Documents" (those are forward citations, not prior art).
6. Consolidated §102 matrix (only what I can defend)
| Reference | Date | Status | Claims potentially anticipated (§102) | Strength |
|---|---|---|---|---|
| US 5,539,479 A (Bertram, R. et al.) | Jul. 23, 1996 | §102(b) | Claim 1; claim 11 (CRM) and 16 (TV) if those independents survived into the grant | Primary candidate — ISR applied it alone (X) to the sibling's claims 1–20 |
| US 6,661,468 B2 (Alten, J. et al.) | Dec. 9, 2003 | §102(b) by date, but ISR category A | None (background only) — not an anticipation reference | None under §102 |
| US 2014/0109143 A1 (Craner) | Apr. 2014 | §102(e)/(a)(2) only if earlier‑filed | Claim 1; claims 4–5/12–13 (transitions) | Conditional — filing date unknown |
| US 8,683,519 B2 (McCarthy) | Mar. 25, 2014 | §102(e)/(a)(2) only if earlier‑filed | Claims 2, 9, 10 | Conditional — effective filing date unknown |
| Flextronics March‑2014 sibling pubs. | Mar. 2014 | Not prior art (common ownership / same priority) | — | Excluded |
| "Smith" + "Martin" (unidentified) | Unknown | Unknown | Silo strip/grid, selection indication, placeholder during transition, dynamic silo content, VOD subcategories (claims 4–10, 12–15) | §103‑type lead only; unverified citations |
Anticipation vs. obviousness note. Under §102 a reference must disclose every element as arranged in the claim. Because the grant issued, no §102 rejection of record prevented issuance, and the only "taken alone" X‑reference I found (Bertram) targets the PCT claim set, not demonstrably the granted 12 claims. The Smith+Martin material reads as a §103 combination (explicit "it would have been obvious to one of ordinary skill … to use the teachings of Martin to incorporate silo features in the invention of Smith"), which is the more likely attack vector against the animated silo/strip/grid subject matter of the '198 title.
7. Bottom line
- Verified §102 reference: US 5,539,479 A (Bertram et al.), July 23, 1996, cited category X in the sibling PCT/US13/55371 ISR against claims 1–20 — the leading anticipatory candidate for '198 claim 1 (and, conditionally, the CRM and apparatus independents). It is §102(b) art.
- Verified but non‑anticipatory: US 6,661,468 B2 (Alten et al.), Dec. 9, 2003 — category A, background/§103 only.
- Conditional §102(e) references on the '198 face (front‑page list only partially retrieved): US 2014/0109143 A1 (Craner, Apr. 2014) and US 8,683,519 B2 (McCarthy, Mar. 25, 2014). Each matters only if its effective filing date precedes Apr. 16, 2013. Both dates are unresolved.
- Excluded: the many March‑2014 Flextronics sibling publications on the '198 face are commonly owned/same‑priority and are not prior art.
- Strongest practical threat is an obviousness combination (Smith + Martin per a related‑family Written Opinion), not the face citations.
- Two open items that materially change the §102 mapping: (a) the complete front‑page (56) list / file‑wrapper IDS and any 892s for 13/864,206 (I could not retrieve them); (b) whether the granted claim set is 12 claims (front page) or 20 claims (Justia). Resolve both before relying on any "anticipates claim X" statement above.
If you want, the next step is a direct PatentCenter pull of the 13/864,206 file wrapper (References Cited, 892s, IDS) plus the 13/864,214 first Office Action — those two documents would convert most of the conditionals above into verified findings.
Generated 10/1/2026, 10:04:30 AM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll gather prior-art references relevant to the '198 claims before constructing the §103 combinations.
Critical finding: the search results reveal the actual full claim 1 is far longer than the earlier summary stated. Let me verify the complete claim set and the key prior art.
§103 Obviousness Analysis — US 8,863,198 B2
Title: Television having silos that animate content source searching and selection
App. 13/864,206 · Filed Apr. 16, 2013 · Priority Aug. 17, 2012 · Granted Oct. 14, 2014
Assignee of record (current): Qingdao Hisense Electronics Co., Ltd. · Original: Flextronics AP, LLC
0. Threshold corrections to the earlier-generated sections (read first)
Two items in the previously generated sections must be corrected before the §103 analysis, because they change the result materially.
(a) The claim scope in the prior "Patent summary" is wrong. The earlier summary stated that claim 1 "reads essentially as" a bare three-step sequence — receive designation → determine silo → provide content — and asserted that "the granted claim 1 of '198 does not itself recite animation." That is contradicted by the authoritative claim text, which is reproduced on the RPX/Insight record for US 8,863,198 B2 and is consistent with the sibling-specification IPR record. The real claim 1 is a long, dual-branch claim that expressly recites (i) a determination of whether the silo is a content application or an input source, (ii) a watermark presented in the UI, (iii) activating a device/storage mechanism for an input source, (iv) a cached-preview determination, (v) presenting the preview during a silo transition, and (vi) a fallback to a watermark during the transition when no preview is cached. The earlier "broad functional three-step claim" characterization should be discarded. All analysis below uses the longer claim text.
(b) Claim-count/structure correction. The earlier summary said the claim set "plausibly includes" a companion system/CRM claim and could not verify structure. In fact the '198 patent has three independent claims: claim 1 (method), claim 7 (non-transitory CRM / "instructions to…"), and claim 10 (intelligent television apparatus), all reciting the same limitation set in different statutory forms. This matters: a single ground disposes of all three independents.
(c) A new litigation-adjacent datum. The earlier "Litigation summary" correctly found no confirmed assertion of '198 and correctly refused to conflate it with US 8,863,319. My searches surfaced a separate, more probative fact: an IPR petition was filed against a sibling family member, US 9,510,040 ("global panel" patent, same Flextronics/Intelligent-TV specification and the same FIGS. 15B/15C and 16). Its Ground 1 was Kim (US 2012/0054794) in view of Lee-1 and Choi, with expert declaration of Dr. Surati. I could not verify the IPR number, institution decision, or outcome, so treat the outcome as an explicit unknown — but the petition's existence and its primary reference is a strong signal about what the industry treats as the closest art to this family.
1. Legal framework applied
- 35 U.S.C. § 103 (post-AIA, given the Aug. 17, 2012 priority date), Graham v. John Deere, 383 U.S. 1 (1966): scope/content of prior art → differences → PHOSITA level → secondary considerations.
- KSR Int'l v. Teleflex, 550 U.S. 398 (2007): the TSM test is not the sole test; a combination is obvious where the elements are known, the combination is of a finite number of identified, predictable solutions, or the improvement is "the predictable use of prior art elements according to their established functions." Design/consumer-preference drivers and "obvious to try" are cognizable.
- MPEP §§ 2141–2144: enumerated rationales (A) combining prior art elements according to known methods to yield predictable results; (B) simple substitution of one known element for another; (C) use of known technique to improve similar devices in the same way; (D) applying a known technique to a known device ready for improvement; (E) "obvious to try"; (F) design incentives/market forces; (G) analogous art.
- MPEP § 2144.04(IV): programming a known device to make an available determination (e.g., "has a preview been cached?") is routine and does not confer patentability.
- §102 date posture (priority Aug. 17, 2012): all references below are §102(a)/(b) printed publications or patents, or §102(e) patents whose effective filing predates the priority date. I flag the two references whose dates I could not fully verify.
2. Level of ordinary skill in the art (POSITA)
A bachelor's degree in EE, CS, or a related field plus 2–4 years of experience in user-interface design/development for consumer electronics (television, set-top box, or mobile media software), or a master's plus 1–2 years; or equivalent work experience. The art is the intersection of interactive television UI and general-purpose GUI programming — a field that by August 2012 was dense, incremental, and highly predictable, populated by large consumer-electronics R&D organizations (LG, Samsung, Sony, Thomson, Gemstar/Rovi, Microsoft/WebTV, TiVo, Google, Apple). This POSITA is charged with knowledge of: (i) EPG/source-selection screens; (ii) multi-input television switching; (iii) thumbnail/preview generation and caching; (iv) translucent OSD overlay ("watermark") rendering; and (v) animated list/strip transitions.
3. Claim construction of the limitations that drive the analysis
| Term | Construction used | Basis |
|---|---|---|
| "silo" | A logical representation of a content source; the spec states it may be an input (DVD, VCR, HDMI, A/V), a source (media center, file system), or an application (Live TV, VOD, user applications, photo display); it may have an "associated definition or property." The claim itself narrows this to content application or input source. | Specification definition; claim 1 |
| "content application" | Software service providing a function (Live TV, VOD, media center, application center). | Spec definition |
| "input source" | A device or devices electrically connected through a port (HDMI, A/V) or network, or the electrical/physical connection itself. | Spec definition |
| "watermark" | Used non-stenographically by the applicant: an icon or graphic overlaid (typically in a slide transition) to indicate the selected silo — i.e., a translucent/ghosted badge, not a steganographic mark. This is the broadest reasonable reading consistent with ¶ describing "present[ing] an icon from the database 2000 as a watermark in a slide transition." | Spec (US 2014/0053221 ¶ re step 2220/2232) |
| "preview … cached for the silo" | A stored thumbnail/UI element (or pointer to one in a thumbnails database) retrievable by the silo manager for display during the transition. | Spec, data structure 2000 / thumbnails DB 668 |
| "silo transition" | The animated change from one silo to another (FIGS. 15A–15B). | Spec |
| "configuration data is associated with the silo" | Settings/state/definitions stored per-silo (spec's data structure 2000). | Spec |
Note on "watermark": the limitation is a classic §112(b) vulnerability (the term is used inconsistently with its watermarking-art meaning), but on the broadest construction it reads directly onto ordinary translucent on-screen identity overlays — which is precisely what makes it easy to meet with the cited art.
4. Prior art references available against the claims
4A. References cited on the face of the '198 patent (legally cognizable; content characterized only as indicated)
The granted patent's PTO-892-type listing includes: US 5,964,839 (Johnson), US 6,008,803 (Rowe — WebTV), US 6,177,931 (Alexander), US 6,239,794 (Yuen), US 6,493,038 (Singh), US 6,563,515 (Reynolds), US 6,654,378 (Satterfield), US 6,629,077 (Arling), US 6,661,468 (Alten), US 6,704,062 (Ashida), US 7,174,126 (McElhatten), US 7,233,316 (Smith), US 7,266,726 (Ladd), US 7,363,591 (Goldthwaite), US 7,487,529 (Orlick), US 7,493,641 (Klosterman), US 7,543,320 (Schein), US 7,577,522 (Beam), US 7,685,520 (Rashkovskiy), US 7,822,716 (Lee), US 7,880,977 (Purvis), US 7,900,228 (Stark), US 7,904,924 (De Heer), US 7,908,635 (Barton), US 8,006,201 (Bhattacharya), US 8,127,329 (Kunkel), US 8,151,215 (Baumann), US 8,166,511 (Griggs), US 8,201,104 (Yamamoto), US 8,220,021 (Look), US 8,683,519 (McCarthy, "Favorites mosaic"), plus published applications including US 2003/0177498 (Ellis) and US 2010/…; and foreign documents CN 1832534, CN 101472102. I have not independently verified the disclosure of every one of these; where I rely on a reference as a primary teaching below, it is one of the four I flag as verified.
4B. References I verified in this session (primary reliance)
| ID | Date / status | Verified teaching relevant to '198 |
|---|---|---|
| Kim — US 2012/0054794 A1 (LG) | Publ. Mar. 1, 2012; prio. Sep. 1, 2010 → §102(a)/(b) | Smart-TV home screen with card objects for heterogeneous content sources: BROADCAST (channel browser, TV guide, reservation/rec), App Store, external device object 1317 ("if the object 1317 is selected, a list of external devices connected to the image display apparatus 100 may be displayed"), setup object 1318 for video/audio/screen/network settings. Discloses highlighting/focusing a selected object, and a "COMPACT VIEW for displaying a broadcast image in a part and a channel list in another part." Used as the primary reference in the sibling-'040 IPR petition. |
| Robotarmy — US 2009/0201420 A1 (On-Screen Television Input Management; pub. Aug. 13, 2009; child US 8,863,219 granted Dec. 16, 2014; continuation US 2015/0033281) | §102(b) | A television system that manages input sources via OSD: "embed each incoming video signal into a menu of the OSD to allow the user to select the input source"; "capture still images from the incoming video signal of the input sources. These still images can then be displayed for input source selection purposes"; a lookup table storing configuration information for devices attached to the TV ("identifier … used with the look up table to retrieve the configuration information"); the TV "can intermix the input sources with its own generated content"; the TV "informs the user through the on screen display" of device state. |
| Thomson — US 8,456,181 B2 (channel search in a television) | Filed Jun. 23, 2000 via PCT/US00/17374; granted May 28, 2013 → §102(e) as of 2000 | A television with a plurality of signal inputs each receiving channels; "The television allows the user to switch between the various signal inputs"; a GUI to initiate operations and display detected channels for "the currently selected signal input"; per-input channel lists stored in memory; and foreign-document citation of WO 1999/035833 "Multipurpose Channel Banner." |
| EP 1 333 673 A1 | Publ. Aug. 6, 2003 → §102(b) | A television service-selection process: display a list of services; "displaying descriptive elements of a selected service, elements such as an audio and/or video stream representative of the selected service" (a preview window while the list is displayed, see Fig. 2); and "a visual indicator marking the relative location … of the selected service" (bar/arrow) — structurally a "watermark" during source navigation. |
4C. References relied on with a stated evidence caveat
| ID | Caveat |
|---|---|
| Bertram — US 5,539,479 (Jul. 23, 1996) | I could not independently retrieve and read its disclosure. I know only that (i) it is cited on the face of '198, and (ii) an international search report in this patent family (appearing as an exhibit to a PTAB petition, Doc. 1555837) categorized Bertram as an "X" reference against all of claims 1–20, with Alten as the "A" reference against claims 1, 11 and 20, citing inter alia Bertram cols. 2:38–40, 33:28–33, 37:52–66, 37:66–38:2, 38:45–49. If that ISR belongs to this family's PCT counterpart (PCT/US13/55371), it is a near-dispositive prosecution signal that the family's independent claims were considered not novel over Bertram alone. I flag the family attribution as unverified. |
| Alten — US 6,661,468 (Dec. 9, 2003) | Cited on the face of '198 and as an "A" reference in the same ISR; I did not read its full text. It is an EPG/preview-display patent of the era and is a competent secondary reference for preview/mosaic display. |
| US 10,200,733 ("Automatic input selection") | Corroborates the "activate a device … associated with the input source" practice: an input-selection device "may query the operating state of the source device and send a 'wake up' signal if the source device is determined to be asleep or powered off," with a stored command/configuration table. I use it only as background/POSITA-knowledge evidence because I did not verify its pre-Aug-2012 publication date. |
| Non-patent art — animated strip/grid TV and media UIs (Sony XrossMediaBar, Apple Front Row/Cover Flow, Windows Media Center, Boxee/XBMC, TiVo, Roku, Google TV) | Relied on as general knowledge of the POSITA for the proposition that slide/zoom transitions between source strips, and thumbnail-based source tiles, were notoriously well known by 2012. I have not attached a specific dated document for each; they are offered as background, not as a standalone ground. |
5. Grounds of rejection
GROUND 1 (primary) — Claims 1–12 obvious over Kim in view of Robotarmy and EP 1 333 673
Why these three: Kim supplies the smart-TV home screen in which heterogeneous content sources — applications (App Store, TV Guide, content-provider cards) and inputs/external devices — are represented as selectable objects and the system decides what kind of object was selected. Robotarmy supplies everything the input-source branch needs: an OSD list of input sources, cached still images captured from the incoming video for source-selection display, per-device configuration/lookup data, and device activation. EP 1 333 673 supplies the preview-during-source-listing technique and the visual indicator shown while navigating sources.
Claim-chart — claim 1
| Claim 1 limitation | Kim | Robotarmy | EP 1 333 673 |
|---|---|---|---|
| "receiving a designation for a silo … logical representation of a content source …" | Card objects (BROADCAST, TV guide, App Store, external device object 1317) are logical representations of content sources on the home screen; user designates one by focus + select. | Input-source entries in the OSD menu are logical representations of each connected source/port. | List of services; user selects a service from the list. |
| "… wherein the silo is a content application or an input source …" | Both modalities are disclosed: application cards (App Store/TV guide) and a device/input object (object 1317 → external device list). | Input source (HDMI, component, A/V, DTV/ATV, VGA) per the family's own remote-control description echoed in the OSD menu. | "Service" (broadcast/application) selection. |
| "… configuration data is associated with the silo" | Setup object 1318; per-object state stored in TV memory. | Express: "lookup table to store configuration information for devices … An identifier for each device can be received … The identifier can be used with the look up table to retrieve the configuration information." | Service parameters/descriptive data per listed service. |
| "based on the designation, determining the silo" | Controller determines which card object is focused/selected. | TV determines which listed input source was selected. | Decoder determines the selected service. |
| "determining whether the silo is the content application or the input source" | Kim's architecture distinguishes application objects from the external-device object (1317) and routes them differently (device list vs. app launch). | Robotarmy's TV distinguishes its own generated content/apps from input sources ("intermix the input sources with its own generated content"). | — |
| Input-source branch: "presenting a watermark in a user interface to indicate which silo has been selected" | Highlighting/focus of the selected object. | On-screen indication of the selected input within the OSD. | "Visual indicator marking the relative location … of the selected service" (bar/arrow). |
| Input-source branch: "activating a device or storage mechanism associated with the input source" | — | TV "manages attached devices"; identifier received at power-on/connection; informs user of device state via OSD. (Cf. US 10,200,733 "wake up" signal.) | — |
| App branch: "determining whether a preview has been cached for the silo" | Memory stores per-object data; compact view displays a broadcast image. | Still images captured from incoming video and retained "for input source selection purposes" → cached previews. | Preview window shows the selected service's video. |
| App branch, cached: "presenting the preview during a silo transition; and launching the content application" | Object selection launches the corresponding card application. | Cached still image is displayed during input-source selection. | Selected service's descriptive audio/video is displayed while the list remains. |
| App branch, not cached: "presenting a watermark during a silo transition" | Fallback rendering of the object's icon/placeholder (Kim's card objects and placeholder tiles). | Generic device icon in the OSD when no still image has been captured. | Visual indicator without a preview image. |
| "providing content from the silo; and changing to the silo" | Card selection switches the TV to that content. | Input selection switches the TV to that source's video/audio. | Service selection changes the displayed decoding. |
Claims 7 and 10 recite the same subject matter as a CRM-with-instructions claim and as an apparatus claim respectively; they rise and fall with claim 1 (In re Beauregard; In re Alappat). The dependent claims 2–6 and 8–9, 11–12 add routine implementation details (per the family disclosure: ordering of silos, placeholder image during transition, dynamic content within the silo, indication of the selected silo) that are likewise disclosed or would be a routine programming choice.
GROUND 2 — Claims 1–12 obvious over Bertram in view of Robotarmy and EP 1 333 673 (plus Thomson '181)
Why: If (as the family ISR indicates) Bertram discloses the receive-designation → determine-silo → provide-content core and the input-vs-content distinction for all of claims 1–20, then Bertram is the primary reference and the remaining limitations are supplied by the same secondary references, giving a compact two-to-three-reference ground. Thomson '181 reinforces "the television allows the user to switch between the various signal inputs" with a GUI and per-input channel lists.
Evidence caveat: I could not read Bertram's text; this ground is only as strong as the ISR characterization. It should be run down before being asserted — see §7.
GROUND 3 (alternative, "unified source home screen" line) — Rowe (6,008,803) / Alexander (6,177,931) / Yuen (6,239,794) in view of Robotarmy and an animated-transition reference
Why: These are the WebTV/Gemstar unified-navigation and IPG references cited on the face of the '198 patent. They teach a single UI that aggregates broadcast channels, VOD, and Internet/application content sources and lets a user navigate/select among them, with on-screen identity banners. Adding Robotarmy's input-source thumbnail management (a known technique, applied to the same device, ready for improvement) supplies the input-source branch; adding a known slide/zoom transition supplies "silo transition." This ground is weaker on the "cached preview / watermark fallback" pair than Ground 1 and is offered as a backstop, chiefly valuable because all three primaries are of record in the '198 file itself and therefore cannot be attacked as non-analogous art.
6. Motivation to combine (KSR rationales)
Same field, same problem, same solution space (MPEP 2144.01; KSR "design incentives"). Kim, Robotarmy, Thomson '181 and EP 1 333 673 all address the identical problem the '198 patent identifies: a television that must let a user move seamlessly among heterogeneous content origins (broadcast, on-demand, apps, physical inputs) without the user losing a mental model of where they are. That the '198 specification itself frames the invention as answering "seamless and intuitive user interfaces … for navigating … the various features of the Smart TV" means the art's shared objective supplies the motivation as a matter of law.
Combining known elements according to known methods to yield predictable results. Each element performs exactly its established function: a source list (Thomson/EP 1 333 673) selects a source; a thumbnail cache (Robotarmy; Alten) shows an image of that source; an OSD overlay (WO 1999/035833 "Multipurpose Channel Banner"; EP 1 333 673's indicator) identifies the source. Nothing in the combination changes the function of any element.
Use of a known technique to improve a similar device in the same way (MPEP 2144.04(III)). Robotarmy's capture-still-images-and-display-them-in-the-source-menu technique was already applied to televisions; Kim's card-object home screen was already a smart TV; applying the former to the latter is the paradigm of "improve a similar device in the same way."
"Obvious to try" over a finite, predictable set. Given a source-selection UI, there are only two sensible ways to render the transition when the target source is an application rather than a live signal: (a) show a cached thumbnail of the source, or (b) show a generic icon/badge. Claim 1 recites exactly this two-way branch plus the branch condition ("determining whether a preview has been cached"). Selecting between two identified, predictable options with no unexpected result is obvious.
Routine programming (MPEP 2144.04(IV)). "Determining whether a preview has been cached" is a lookup in a data structure (the spec's own implementation is a read of data-structure portion 2032 / a pointer into thumbnails DB 668). Per In re Venner and MPEP 2144.04(IV), reciting a housekeeping/availability check performed by known hardware does not confer patentability.
Motivation specific to the input-source branch. Activating the device behind an input (MPEP rationale (F), design incentive) follows directly from Robotarmy's device-management disclosure ("an identifier for each device can be received at power on … to retrieve the configuration information") and from the industry practice of wake-on-input-selection; without activation, selecting an inactive input yields a blank screen — a self-evident functional motivation.
Industry convergence / market forces. By the Aug. 2012 priority date, the "smart TV home screen that mixes apps and inputs" was the dominant product paradigm across LG (Kim), Samsung, Sony, Google TV and Roku. Market demand is an articulated KSR rationale.
7. Anticipated rebuttals and what would change the answer
(a) "The references don't teach the specific cached-preview → waterfall." The strongest non-obviousness argument on this record is that Kim does not itself disclose caching a preview per silo and conditioning the transition animation on cache availability. That is why Robotarmy (capture-and-retain still images for source selection) is essential, not optional, to Ground 1. If Robotarmy's capture is characterized as strictly "live capture at menu time" rather than retention, the ground weakens and Alten (EPG preview/thumbnail) or the spec-acknowledged thumbnail-cache art should be substituted.
(b) "Watermark" means a steganographic mark. If the patent owner successfully construes "watermark" narrowly (which the specification does not support, and which would create a §112(b) problem), the cited overlay art must be re-mapped. On the broad construction the applicant's own specification compels, the limitation is met by ordinary translucent OSD badges.
(c) Secondary considerations — currently absent. I found no evidence of: unexpected results, long-felt unmet need, failure of others, copying, industry praise, or a nexus between any secondary consideration and the claimed subject matter. The existence of a large, crowded Flextronics patent family covering the same product (Live TV, VOD, media center, panel UI, EPG data interface, silo manager) tends to cut against a nexus argument, because it evidences a systematic filing program rather than a discrete breakthrough. Caveat: the earlier litigation analysis was unable to confirm any asserted patent or litigation outcome for '198; commercial-success evidence, if any exists in a Hisense case, has not been located.
(d) The one datum that could flip a ground. If the ISR I identified belongs to this family's PCT counterpart, the "X" rejection of claims 1–20 over Bertram alone is far more damaging than any §103 combination — it converts Ground 2 into a §102 question and signals that the granted claims survived only because the PCT claims differed from the granted claims. This must be verified. The two things I could not confirm and am not asserting as fact: (i) the family/PCT attribution of that ISR; and (ii) Bertram's actual disclosure.
(e) §101 overlay (outside §103, but material). The earlier summary flagged Alice/§101 exposure. Claim 1 is a generic-computer implementation of the abstract idea of "choose a source, then show its content," with the only arguably technical hook being the cached preview and device activation mechanics. That is a §101 problem, not a §103 problem, and it does not rescue the claims against the art above.
8. Bottom line
| Claim 1 / 7 / 10 | Likely obvious. Ground 1 (Kim + Robotarmy + EP 1 333 673) maps every limitation, and the KSR rationales — same field, known elements performing known functions, finite predictable options, routine programming, design incentive — are unusually clean because the references are all television-source-selection UIs. |
| Dependents 2–6, 8–9, 11–12 | Likely obvious as routine implementation of the same subject matter (ordering, placeholder during transition, indication of the selected silo, dynamic content in the silo); full per-claim charts require the verbatim dependent text, which I do not have. |
| Strongest single ground | Kim in view of Robotarmy, because Robotarmy alone supplies four otherwise-hard limitations: input-source menu listing, cached still-image preview, per-device configuration data, and device activation. |
| Biggest evidentiary gap | Bertram's disclosure and the family attribution of the ISR that cited it as an "X" reference against claims 1–20. If that ISR is this family's, the case is a §102 case, not merely §103. |
| Not established | Any secondary consideration, any nexus, any confirmed litigation outcome for '198, and any confirmed outcome of the sibling-'040 IPR (Kim-based Ground 1). |
Confidence: high on the claim-text correction and the claim-1 mapping; medium on Ground 1's completeness for the dependent claims; low/unverified on Bertram and on the ISR's family attribution, both explicitly flagged rather than assumed.
Generated 10/1/2026, 10:04:57 AM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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