US 9052204

I'll search for authoritative information on US patent 9052204, including any litigation or CAFC activity.

The first search returned unrelated results (a chemistry patent). Let me run more targeted queries.

Let me verify litigation/PTAB activity and confirm the independent claim language.

US Patent 9,052,204 B2 — Analyst Summary

Scope note on sources & searches. I do not have direct PAIR/Docket Navigator access in this session; the findings below come from the patent's own front-page/full-text data (Google Patents, Justia, FreePatentsOnline, and the issued-PDF at patentimages.storage.googleapis.com) plus open-web searches. My searches for litigation and for "CAFC 2026 dockets" tied to 9,052,204 returned no relevant proceedings. Every hit containing "'048 patent" in PTAB documents referred to different patents (U.S. 6,871,048; 7,413,048; 8,685,048) and must not be conflated with this one. One search returned an unrelated chemistry/wastewater document (EP 3378940A4) that merely matched the numeral — irrelevant to this patent. I flag all of this rather than inventing a docket history.

Bibliographic Data (from the issued patent)

Abstract (verbatim)

"There is provided a behavior pattern extraction system which can extract user's behavior pattern with high accuracy. The behavior pattern extraction system includes: a location information acquiring section measuring location points which each indicate a location of a user; a staying point extraction section setting staying points and staying records based on an range in which location points which are each measured in a first period are concentrated, wherein the staying points each indicate a location where the user has stayed temporarily; a representative staying point extraction section setting a representative staying point and a representative staying record based on an range in which the staying points which are set in a second period which is longer than the first period are concentrated, wherein the representative staying point indicates a location where the user has repeatedly visited, and the representative staying record indicates an error range of the location of the representative staying point; and a behavior pattern record section recording the representative staying point and the representative staying record in a storage area as behavior pattern information of the user."

Plain-Language Overview of the Independent Claims

Claim 1 — System (the core claim). Four cooperating functional blocks:

1. Location information acquiring section — measures "location points," each indicating the user's location (GPS or equivalent).
2. Staying point extraction section — looks at location points measured within a first (short) period, finds where they cluster, and from that cluster sets (a) a staying point = where the user temporarily stayed, and (b) a staying record = an error range around that staying point.
3. Representative staying point extraction section — takes the staying points gathered over a second, longer period, finds where those cluster, and sets (a) a representative staying point = a place the user repeatedly visits (e.g., home, work, a favorite shop) and (b) a representative staying record = that representative point's error range.
4. Behavior pattern record section — stores the representative staying point and representative staying record in a storage area as the user's behavior-pattern information.

Claim 12 — Method. The method counterpart of Claim 1: measuring location points; setting staying points/staying records from the cluster of location points in the first period; setting a representative staying point/record from the cluster of staying points over the longer second period; and recording them as the user's behavior pattern. (Claim 13 depends from 12 and adds the record-overlap/highest-accuracy mechanics.)

Claim 19 — Method (median/weighting variant). A method in which the staying point is set to a weighted median point of the location points measured in a given period — the weighting based on the time intervals between successive location-measurement times — and each staying record is a circle centered on the staying point whose radius equals the distance to the farthest measured location point.

Claim 20 — Method (weighted-median representative point). Appears to be an independent method claim directed to setting the representative staying point as a weighted median point of location points based on that weighting. Uncertainty flag: my sources render this with an independent-style preamble, but one fragment shows it referencing "said weighting," which can indicate dependency; I cannot confirm authoritatively whether 20 is independent or depends on 19.

Claim 21 — Computer-readable medium. A non-transitory computer-readable recording medium storing a program that, when executed, causes a computer to perform the behavior-pattern-extraction method.

Note on claim set: the granted patent renumbered claims relative to published application US 2012/0203732 A1 (which had independent claims at 1, 13, 14 and 21). In the granted set, Claim 12 appears to be the independent method claim. I am confident about independent Claims 1 and 21; my read that 19 and 20 are independent is based on secondary sources and should be verified against the official USPTO claim set before being relied on.

Dependent-Claim Themes (context)

• Location measurement records as error ranges derived from measurement accuracy (accuracy-dependent radius).
• Extracting estimated staying ranges where ≥ N measurement records overlap; picking the location point with the highest accuracy as the staying point; its record becomes the staying record.
• Analogous treatment one level up: estimated representative staying range = where the largest number of staying records overlap; highest-accuracy staying point = representative staying point.
• Alternative geometries: staying/representative record as a range covering all measurement records (or all location points) with the center used as the point; or median point with radius to the farthest point; and time-interval weighting (e.g., a weighted median).
• Handling a staying record that overlaps no other (kept as its own representative point).

Litigation / CAFC Check — Result

I found no evidence of any 2026 CAFC docket, PTAB proceeding (IPR/PGR), or district-court case involving US 9,052,204. Searches for the number combined with litigation terms returned either nothing or false positives on unrelated "'048" patents. If a litigation history exists, it is not visible in the sources available to me, and I am stating that limitation explicitly rather than asserting a negative as fact.

Would you like me to attempt a follow-up pass specifically targeting PACER/Docket Navigator-style queries or the NEC v. (defendant) line of cases, or to draft element-by-element claim charts for Claim 1 and Claim 12?

I'll search for litigation involving US patent 9052204 across multiple patent litigation sources.

Let me search more specifically for this patent in litigation databases and related sources.

Report: Known Litigation Involving U.S. Patent No. 9,052,204

Result of Search

I found no evidence of any litigation involving U.S. Patent No. 9,052,204. As of the date of this search (April 26, 2026), my searches across patent-litigation resources did not surface any district court case, CAFC appeal, ITC investigation, or PTAB proceeding in which U.S. Patent No. 9,052,204 was asserted, challenged, or otherwise at issue.

What I Searched

I queried patent-litigation-oriented sources using the exact identifier, including variations of the number and the patent's subject matter. Specifically I searched:

• The literal number "9052204" and "US 9,052,204" / "9,052,204" in connection with infringement complaints and lawsuits;
• The Unified Patents litigation/caselist domain (portal.unifiedpatents.com/litigation/caselist);
• Google Patents' entry for US9052204B2 (the "Litigation" / similar-matter tab content);
• General CAFC and PACER-style result queries;
• Assignee-based queries (NEC) combined with the patent's subject matter ("behavior pattern extraction").

None of these returned a case naming this patent.

Patent Identification (for confirmation of scope)

To ensure I was not conflating this patent with a similarly numbered one, I confirmed the following bibliographic data, which matches the requested patent:

There is a distinct family of "…204" patents (e.g., a "204 patent" appearing in unrelated ANDA/pharmaceutical and other cases, and the '204 patent in Atlantic Thermoplastics Co. v. Faytex Corp.). These do not involve U.S. 9,052,204 and were excluded per your instruction not to return similar numbers.

Important Caveats

Because I could not complete a fully authoritative check of every litigation database, I want to be precise about the limits of this conclusion:

1. No positive litigation found ≠ absolute proof none exists. My search did not return any litigation hits for this patent, but I cannot claim to have exhaustively queried PACER (which requires case-specific docket access) or a proprietary database such as Docket Navigator, Lex Machina, or RPX Insight, whose full records may not be fully indexed by general web search.
2. This is a low-litigation-profile patent. It is owned by NEC Corp (an operating company, not a known NPE), which is consistent with there being little or no public assertion history. The patent appears to have no reported assertion campaigns.
3. No PTAB challenge surfaced in the results either — i.e., no IPR/PGR/CBM referencing U.S. 9,052,204 appeared.

Recommended Verification Steps

If you require a legally definitive negative or positive finding, I recommend confirming directly against:

• PACER (pacer.uscourts.gov) — search by patent number across all district courts;
• Unified Patents Litigation Portal — https://portal.unifiedpatents.com/litigation/caselist (filter by patent);
• USPTO Patent Center / Assignment records for the '204 patent, to check ownership transfers that might precede an assertion;
• Docket Navigator / Lex Machina / RPX Insight (subscription) for the most complete assertion history.

Bottom Line

Based on the searches performed, no litigation is known involving U.S. Patent No. 9,052,204. If you would like, I can draft the same search against the sibling family members (e.g., the corresponding Japanese priority JP 2009-237423 and the PCT publication) or set up narrower queries against specific courts.

Proceedings overview

Total AIA trial proceedings on US 9052204: 0 (zero). The USPTO Open Data Portal structured block reports no IPR, PGR, or CBM proceedings for this patent, and targeted web searches (PTAB E2E/P-TACTS document corpus, Google Patents litigation/proceedings tabs, and general web) surfaced no petition, institution decision, FWD, settlement, or Federal Circuit appeal naming US 9,052,204. Bottom line for a defendant: there is no PTAB record to lean on — neither a cancelation you can cite nor a hardened "survived IPR" posture to overcome. You are working from a clean slate; validity has never been tested in an AIA trial, so any invalidity story must be built from scratch in district court or by filing a first-ever petition.

No proceedings to enumerate

There are no proceeding numbers to report. Consistent with the instruction not to invent proceeding numbers, I am reporting an empty set rather than a template with fabricated entries. What I checked:

Confidence note: The absence is well-supported but not absolute. USPTO's ODP ingest can lag, and some early-stage petitions are not fully indexed. I could not, however, surface even a petition number in public search, so the "no PTAB activity" default holds. If you have a specific litigation docket, verify the patent's "Proceedings" tab on the Google Patents page for US9052204 and the PTAB's P-TACTS search one more time before relying on this.

Strategic summary

Claim status. No claim of US 9,052,204 has been canceled, sustained, or construed by the PTAB — all claims are UNTESTED in an AIA trial. This is an unamended, un-narrowed patent as issued on 2015-06-09. Whatever claims you face in a demand letter are the original prosecution claims; the patent owner has not been forced to disclaim or amend anything. Note also that the patent remains active, with a projected expiration around 2032-01-21 (adjusted), so a defendant is looking at a long runway of exposure if the claims hold.

Estoppel landscape. Because there are no AIA proceedings, § 315(e)(2) estoppel does not exist for anyone. No petitioner, privy, or real party in interest is barred from raising any prior-art ground. This cuts both ways: it means a defendant is not estopped, but it also means the patent owner has taken no validity hit that would give you a free § 102/§ 103 roadmap from a public FWD. Every ground is still available and unvetted.

Pattern signals. None of the classic trolling/IPR-signal patterns are present on the PTAB side — no serial petitioner, no defensive aggregator (Unified Patents, RPX, etc.) in the chain, no PTAB appeal history. The current assignee is NEC Corporation (original assignee NEC Corp; inventor Takeo Oono), which is a large operating company rather than a shell NPE. That profile matters: NEC has not had this patent invalidated or narrowed, and it has not been forced to defend the claims at the Board either. It is a component of a portfolio (JP priority 2009-237423, PCT/JP2010/067867) rather than a litigated crown jewel.

Subject-matter vulnerability (for your own § 101/§ 112 analysis, not PTAB record). The claims are directed to extracting a user's "behavior pattern" from GPS location points by overlapping error ranges and selecting the highest-accuracy point — a claim set that reads like candidate Alice/Bilski subject matter and could invite § 101 or indefiniteness challenges (the specification itself uses inconsistent reference numbering, e.g., "estimated representative staying range 40" in one passage). None of that has been tested by the Board, so treat it as your own work product, not an established PTAB outcome.

Recommended next steps

• If you are a defendant: There is no FWD to cite and no canceled claim to lean on. Do not represent to a court or opposing counsel that any claim of the '204 patent has been invalidated — it has not. Your invalidity case must be built independently.
• Consider whether a first-filed IPR is worth it. With zero prior PTAB activity and no estoppel in place, you would be the first mover. Weigh the cost against a district-court-only invalidity defense; a petition here would not be aided by any prior Board construction.
• Verify the absence before relying on it. Re-check the Google Patents proceedings tab and PTAB P-TACTS for any petition filed after the ODP ingest date, since a recently filed petition may not yet be indexed. If you learn of a pending petition, the statutory deadline framework is: institution decision within ~6 months of the filing-date-accorded notice, and FWD within 1 year of institution (35 U.S.C. § 316(a)(11)), extendable for good cause.
• If a demand letter cites this patent: the absence of PTAB history means the demand is not backed by any adjudicated validity win — the patentee has never had these claims blessed by the Board, in district court, or on appeal. That is a favorable posture for pushing back, though it is far weaker than a cancelation.

Sources consulted: the structured USPTO ODP block in this prompt (canonical, showing no proceedings); Google Patents US9052204B2; PTAB P-TACTS / decisions corpus via web search. No specific PTAB opinion or CourtListener docket exists to link because no proceeding was found.

I'll research the assignment record for US 9,052,204, starting with the patent's legal events and assignment history.

Let me dig deeper into the assignment records and legal events.

Let me look for the specific assignment record and the inventor's background.

Assignment & Ownership Analysis — U.S. Patent No. 9,052,204 (US9052204B2)

Scope note / sourcing caveat up front: The authoritative full text and the Google Patents "legal events" panel for this patent were retrieved directly. However, my searches did not surface the reel/frame number or the recorded-correspondent field for the one assignment in the chain, because the USPTO Assignment Center record pages are not fully crawlable by general web search in this session. I therefore report the event that is documented (assignor, assignee, conveyance type, recording date) and explicitly flag the two fields I could not retrieve (reel/frame and correspondent of record) rather than invent them. Verify at the USPTO Assignment Center and the Google Patents legal-events panel.

Inventors

• Sole inventor. The issued patent lists a single inventor, Takeo Oono, Tokyo (JP).
• Employer at filing = NEC Corporation. This is well-supported, not inferred from the name: the PCT applicant/assignee is NEC (PCT/JP2010/067867), the §73(b)-style power-of-attorney materials in the NEC prosecution family are executed by "NEC Intellectual Property Center, America / NEC Corporation of America" on behalf of NEC Corporation as assignee of record, and the application's agent of record is Sughrue Mion, PLLC — NEC's regular outside counsel (USPTO Customer No. 71799).
• Unusual-pattern check (all inventors departing original assignee within 12 months): Not determinable / no signal present. Only one inventor exists; there is no evidence in the record of departure, and no post-filing assignments away from NEC. Nothing to indicate a pre-fire-sale talent drain.

Original assignee

NEC Corporation (Minato-ku / Tokyo, JP) — named as assignee on the face of the issued patent (73).

• Primary line of business: diversified information/communications technology and electronics — telecom network infrastructure, IT services, AI/analytics, and devices. Publicly listed (Tokyo Stock Exchange: 6701). NEC has a substantial IT-services and analytics business; the claimed subject matter (behavior-pattern extraction from location history) sits squarely in NEC's data-analytics / smart-city / mobility portfolio.
• Did they ship a product embodying the claims? Not confirmed. The specification describes a general "behavior pattern extraction system" for carriers/application servers; I found no evidence of a specific branded NEC product mapped to the claims, and I will not assert one. NEC is nonetheless an operating company with products, not a holding/licensing shell.
• Current status: Operating (still the current assignee; no transfer, dissolution, or bankruptcy surfaced). No Chapter 7/11 event appears in the record for this patent's chain.

Assignment timeline

Chronological list of every recorded assignment surfaced:

• (execution date not retrieved) / recorded 2012-04-16 — Reel/Frame: not retrieved in this session (flag: this field must be confirmed at the Assignment Center)
  • Conveyance: Assignment — recorded as "ASSIGNMENT OF ASSIGNORS INTEREST" (Google Patents legal event labels it "reassignment," the standard label used for an inventor→company assignment).
  • Assignor: Takeo Oono (sole inventor).
  • Assignee: NEC Corporation.
  • Correspondent: Not retrieved. For context, the prosecution agent/attorney of record on the application is Sughrue Mion, PLLC (USPTO Customer No. 71799) — NEC's routine outside counsel. Because there is only one link in this chain, no recurrence test is possible; a single appearance by a law firm that does both operating-company and NPE work is not a signal.
  • Context: Inventor-to-employer assignment (ordinary corporate intake). This is the initial vesting step, not a transfer to a third party. The ~2012 recording date corresponds to the U.S. national-stage entry of the PCT (application 13/502,048, filed 2010-10-12; pre-grant pub 2012-08-09), which is consistent with NEC recording the assignment around entry rather than at grant.

No other assignments are recorded. Google Patents' legal-events timeline for US9052204B2 shows only: (i) the 2012-04-16 assignment to NEC Corporation, and (ii) the 2015-06-09 grant. There is no post-issuance assignment, change of name, security agreement, license, merger, or release on the record. The current assignee remains NEC Corporation. (Confirmed against the patent's own legal-events metadata: "Current Assignee — NEC Corp"; "Original Assignee — NEC Corp.")

Timeline diagram

timeline
    title Ownership of US 9052204
    2009 : Priority filing in Japan
    2010 : PCT application filed by NEC
    2012 : Oono assigns rights to NEC Corp
    2015 : Patent granted to NEC Corp
    2026 : Still held by NEC Corp

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The only assignment is inventor→NEC Corporation (an operating, publicly traded company). No "IP / Holdings / Ventures / Licensing" LLC ever appears as assignee; no registered-agent or single-purpose-LLC address is in the chain (2012-04-16 entry, the sole assignment).

2. Known asserter in the chain — Not present. Current and original assignee is NEC Corp, which does not appear on the Acacia / Marathon / IV / Wi-LAN / Conversant / Vringo / Round Rock / Spangenberg-type NPE rosters for this patent. No asserter name occurs anywhere in the record.

3. Repeat correspondent across the chain — Not present / insufficient data. The chain has a single link, so recurrence cannot exist. The application's agent of record is Sughrue Mion, PLLC (Customer No. 71799), but a single NEC prosecution engagement is not an NPE signal; the recorded correspondent for the assignment itself was not retrievable and should be confirmed.

4. Cascading transfers (<24 months through chained LLCs) — Not present. One assignment in the entire history; nothing cascading.

5. Pre-litigation transfer (assignment within 6 months of a first suit) — Not present. No infringement suit naming this patent was found (see prior litigation section), so there is no triggering suit to which any transfer could be tied.

6. Bankruptcy fire-sale — Not present. No Chapter 7/11 proceeding or patent-sale order appears for NEC regarding this patent.

7. Privateering — Not present. No transfer of this patent to a third-party assertion vehicle; NEC retained ownership throughout.

8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN; it terminates at the original operating company, NEC.

Unverified research lead (do not treat as a finding): A search result surfaced an Eastern District of Texas complaint (EDTX 2:19-cv-00311) referencing an "Oono '439 patent" asserted against Supercell over game-control claims. I could not verify that the inventor is the same Takeo Oono, and there is no evidence linking that patent or that case to US 9,052,204. It is flagged only as a name-coincidence lead to check if you want to rule out an Oono-patent assertion campaign; on the present record it is irrelevant to the ownership of US 9,052,204.

Verdict

Insufficient data (in the rubric's sense: only the original assignment is recorded).

Justification: The sole recorded assignment is the initial inventor→employer transfer, executed (date not retrieved) / recorded 2012-04-16, conveying Takeo Oono's rights to NEC Corporation; the patent then issued to NEC on 2015-06-09 and remains owned by NEC with no subsequent assignment, security interest, or transfer on the record. Every enumerated NPE signal is not present, and zero signals point toward assertion or aggregation. Substantively this is the profile of a clean operating-company-owned patent (not a shell transfer, not a privateering transfer, not a defensive-aggregator acquisition) — the "insufficient data" label reflects only that the chain contains nothing beyond original vesting, not any indication of troll activity.

Action item to close the two gaps: confirm the reel/frame and correspondent of record for the 2012-04-16 assignment at the USPTO Assignment Center (search by patent number 9052204 or application 13/502,048). Given NEC's reliance on Sughrue Mion, PLLC (Customer No. 71799) in this family, the recording correspondent is most likely that firm — but this should be verified, not assumed.

Verification links:

• USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search: 9052204 or 13/502,048)
• Google Patents legal events — https://patents.google.com/patent/US9052204/en

I'll search for the specific patent and its cited prior art references.

I found the citation list. Let me verify the details of each cited reference and the patent's own front-page citations.

I have the citation list. Let me verify details on the remaining references and confirm the patent's claims.

Prior-Art Analysis — U.S. Patent No. 9,052,204 (US9052204B2)

1. Patent Identified (positive confirmation)

Per your instruction to search the literal number 9052204 and not similar numbers, I confirmed the record below. Note: my searches also surfaced other patents with similar-looking identifiers — a different "905" patent (container tops, litigated in PTAB/ITC) and a different "905 patent" in a Federal Circuit web-search case (No. 21-2228). Both are unrelated to US 9,052,204 and are excluded.

Governing law note: priority is 2009-10-14 (pre-AIA). So the operative statute is pre-AIA 35 U.S.C. § 102(a)/(b)/(e): references published before 2009-10-14 are § 102(a)/(b) art; U.S. patents/publications filed before that date but published after are § 102(e) art. Because the grant occurred in 2015 and the priority is 2009, no AIA § 102(a)(1)/(a)(2) art applies.

2. Citations on the Face of the Patent (from the family record)

Google Patents' entry for this family lists 4 Patent Citations and 7 Non-Patent Citations, plus the two Japanese Patent Documents cited in the specification's CITATION LIST.

Because I worked from the family's citation table (the granted '204 and its pre-grant publication US 2012/0203732 A1 are the same application), the citation set is the same. Caveat: the table does not tell me whether each item was cited by the examiner or by the applicant (an IDS citation is not an admission of § 102 art).

2A. U.S. Patent Citations

3. Reference-by-Reference Analysis

Reference 1 — US 2010/0070456 A1 (Olympus Corporation)

• Full citation: US 2010/0070456 A1, "Information processing system, information processing method, and computer program product," Olympus Corporation; priority 2008-09-17; published 2010-03-18.
• Dates / § 102 status: earliest date is the 2008-09-17 priority; § 102(e)-eligible as a U.S. publication with a pre-2009-10-14 effective date (assuming a corresponding pre-2009-10-14 U.S. filing).
• Description (as shown in the citation table): an Olympus information-processing system/method/computer-program product. I could not verify its substance — my follow-up lookup for this reference did not complete (search budget exhausted), and the title alone doesn't confirm it discloses GPS stay-point/error-range processing. I will not characterize its disclosure beyond what's verified.
• Anticipation (§ 102) mapping: Cannot be responsibly mapped without its disclosure. On the face of it, an Olympus "information processing system" is general-purpose and unlikely to disclose the specific limitations of '204 claim 1 (staying records = error ranges of location; representative staying point = repeatedly-visited location from overlapping error ranges). Recommendation: pull the full document and check whether it discloses location measurement accuracy/error ranges and their overlap.

Reference 2 — US 2010/0211308 A1 (Microsoft; Zheng et al.), "Identifying Interesting Locations"

• Full citation: US 2010/0211308 A1, "Identifying Interesting Locations," Yu Zheng, Lizhu Zhang, Xing Xie, Wei-Ying Ma; Microsoft Corp.; filed 2009-02-19; priority 2009-02-18; published 2010-08-19. (Current assignee: Microsoft Technology Licensing LLC.)
• Dates / § 102 status: filed/priority before the '204 priority date (2009-10-14) but published after → qualifies as § 102(e) prior art (not § 102(a)/(b)).
• Description (verified): extracts "stay points" from GPS location histories — expressly: "a stay point is a geospatial position in the region which is within a prescribed maximum distance of locations where an individual spent a period of time exceeding a prescribed minimum period." Builds a tree-based hierarchical graph (TBHG) of stay points, then uses a HITS-based model to identify "interesting locations," popular travel sequences, and experienced travelers. Key disclosure match: temporal aggregation of raw GPS points into a stay point using distance + minimum-time thresholds.
• Anticipation (§ 102) mapping — direct, with a caveat: This is the closest single-reference match to the "staying point extraction section … setting staying points … based on a range in which location points measured in a first period are concentrated" concept. However, Zheng uses distance/time thresholds, not an "error range" or a "location measurement record" derived from location-measurement accuracy, and does not disclose a "staying record [that] indicates an error range." Accordingly:
  • It does not appear to anticipate independent claim 1 as a whole (the "error range / staying record" and "representative staying record = error range" limitations are absent).
  • It could anticipate narrower/dependent claim concepts limited to extracting stay points from location histories.
  • Realistically, Zheng is stronger as § 103 art (e.g., combined with a reference teaching location-accuracy/error bounds, such as the '204's own cited Patent Document 2 — see below).

Reference 3 — US 2011/0081634 A1 (Sony; Kurata et al.), "Behaviour Pattern Analysis System, Mobile Terminal, Behaviour Pattern Analysis Method, and Program"

• Full citation: US 2011/0081634 A1, Masatomo Kurata, Makoto Murata, Takashi Ogata, Yasutaka Fukumoto, Masanori Katsu; Sony Corp.; JP priority 2009-10-01/02 (JP 2009-230579); US filing 2010-08-24; published 2011-04-07.
• Dates / § 102 status — flag: the JP priority (2009-10-01) precedes the '204 priority (2009-10-14), but the U.S. filing (2010-08-24) follows it. Under In re Hilmer, a U.S. publication's § 102(e) date is its U.S. filing date, which here is after the '204 priority date. On those dates, this reference may not qualify as § 102(e) prior art against the '204 at all (it would be a later-filed "secret" application). This is an anomaly worth verifying — it suggests it was applicant-cited, or that the '204's actual invention date is later than its foreign priority, or that the reference has an earlier effective U.S./PCT date I could not confirm.
• Description (verified): a mobile terminal with a motion sensor (short-term "movement/state" patterns) plus location information; a server-side "clustering unit that clusters places where the user stays for a long time" using location + first-behaviour-pattern history, and computes a staying probability of each place and movement probability between places to predict the next long-term behaviour pattern.
• Anticipation (§ 102) mapping: the "cluster places where the user stays for a long time" and staying-probability computation are conceptually related to the '204's staying point → representative staying point pipeline. But the reference's mechanism is motion-sensor behaviour classification + probabilistic clustering, not error-range overlap / smallest-location-error selection. Even setting aside the date problem, it does not appear to anticipate independent '204 claims; better as § 103 background/combination art.

Reference 4 — US 2012/0278320 A1 (Ogura), "Recommendation Information Providing System …"

• Full citation: US 2012/0278320 A1, Shoji Ogura, "Recommendation information providing system, recommendation information providing apparatus, recommendation information service method, and recommendation information distribution program"; published 2012-11-01.
• Dates / § 102 status — major flag: publication 2012-11-01 is after both the '204 priority date (2009-10-14) and its PCT filing (2010-10-12). For it to be § 102(e) art, it would need an effective U.S. filing date before 2009-10-14; its 2012 publication strongly suggests it does not. I could not retrieve its filing/priority date (search budget exhausted). On the dates I can verify, this reference does not appear to qualify as § 102 prior art against the '204. Its presence in the citation table may reflect (a) a § 102(e) date from an earlier-filed/PCT priority I couldn't confirm, or (b) citation in a related family application. Treat as UNVERIFIED.
• Description: on its face, a recommendation-information providing system/service — thematically adjacent (location-based recommendation) but not the stay-point/error-range extraction mechanism.

Specification-Cited Japanese Patent Documents (CITATION LIST)

These are cited in the '204 specification itself (both as "Patent Literature"), and both are § 102(b) printed publications (published well before 2009-10-14):

Non-Patent Citations (7) — dates matter most here

These were cited against the family and several predate the 2009-10-14 priority date, making them § 102(a)/(b) art (the most dangerous category):

Most relevant prior art overall: NPL-2 (Ashbrook 2003), NPL-6 (Zheng 2009), NPL-5 (Ye 2009), and PD2 (JP 2004-112482) — because they (i) predate the priority date as printed publications and (ii) collectively disclose stay/significant-location clustering and location-range overlap, the two core mechanisms of the '204.

4. § 102 Anticipation Summary (mapped to '204 claim concepts)

Disclosure limitation on my analysis: my search budget was exhausted before I could retrieve the verbatim granted claim set. The mapping below uses the claim concepts recited consistently in the '204 abstract and "Disclosure of Invention": (a) location-information acquiring section measuring location points; (b) staying-point extraction section setting staying points + staying records that indicate an error range of each staying point, based on a range in which location points in a first period are concentrated; (c) representative-staying-point extraction section setting a representative staying point + representative staying record (error range), based on a range in which staying points in a longer second period are concentrated; (d) behavior-pattern record section storing these as the user's behavior-pattern information. Verified claim-text mapping should be re-run.

Bottom line on § 102: On the art I could verify, no single cited reference appears to disclose all limitations of the '204's independent claims — chiefly because none of the patent citations teaches the hallmark limitation that the **staying record / representative staying record is a location error range, and that staying/representative points are selected as the smallest-error points among overlapping error ranges. The specification's own PD2 (JP 2004-112482) teaches "location by overlapping uncertainty ranges," and NPL-2/NPL-5/NPL-6 teach significant-place/stay-point clustering — a combination those four could support a § 103 attack, but a clean § 102 anticipation of independent claim 1 is not evident from the cited set.

5. Caveats & Recommended Verification (per your rules)

1. I did not fabricate the Olympus and Ogura disclosures — their follow-up lookups did not complete; I have flagged them as UNVERIFIED rather than guessed.
2. Two date anomalies (Kurata filed 2010-08-24; Ogura published 2012-11-01) mean those two citations may not be § 102 art against the '204 at all — confirm their § 102(e) effective dates and whether they were examiner- or applicant-cited.
3. Obtain the verbatim granted claims and the file wrapper (USPTO Patent Center, App. 13/502,048) to (a) fix the exact claim limitations and (b) see the actual Examiner rejections/citations with their statutory labels.
4. To be legally definitive, query USPTO Patent Center / Public PAIR, Global Dossier (PCT/JP2010/067867), and the JP prosecution for JP 2009-237423 — the Japanese search report's cited art (often the true § 102(b) art for a JP-origin invention) is not fully reflected in the "cited on the US face" list above.

If you'd like, I can (a) draft the verbatim claim chart once the granted claims are supplied, or (b) run the same citation analysis for the sibling family members (JP 2009-237423 and PCT/JP2010/067867).

I'll pull the actual claim set and the cited prior-art references so the §103 analysis is grounded in the literal claim language.

Let me retrieve the exact claim language and the full prior-art citation list from the patent page.

Let me try to retrieve the granted claim set directly.

Obviousness Analysis — U.S. Patent No. 9,052,204 B2 (35 U.S.C. § 103)

Technical-analyst work product. This builds on the previously generated Litigation Summary (which found no litigation or PTAB proceeding involving US 9,052,204) and does not repeat it. Obviousness is a legal conclusion; the following is a technical/evidentiary assessment, not a legal opinion.

1. Sources used and important limits

Caveats (must be stated):

• I could retrieve the full granted text of dependent claims 13–21 (via Justia) but not the verbatim granted text of independent claims 1 and 12; I reconstruct claim 1 from the patent's own "Disclosure of Invention" summary ([0009]–[0010]) and the Abstract, which track claim 1. The exact wording should be confirmed against the granted document before any filing.
• I have not read the Japanese specifications JP 2000-180199, JP 2004-112482, or JP 10-176929 in full; their content below is taken from the patent's own characterization plus search hits.
• Content of US 2006/0156209 A1 (Matsuura) and US 2010/0070456 A1 (Sugihara) is not verbatim-verified here; Matsuura's family content (stay/move ACTIVITY aggregation) is corroborated by search hits for the related JP 4431907 B2 / US 7,574,661 material.
• Per the operating rule, where search results and training data conflict, I follow the search results.

2. The claimed subject matter (elements)

Independent claim 1 (system) — reconstructed preamble/body

• E1 — location information acquiring section measuring location points each indicating a user location.
• E2 — staying point extraction section setting staying points and staying records based on a range in which location points measured in a first period are concentrated; staying point = a location where the user stayed temporarily; staying record = an error range of the staying point's location.
• E3 — representative staying point extraction section setting a representative staying point and representative staying record based on a range in which staying points set in a second period longer than the first period are concentrated; representative staying point = a repeatedly visited location; representative staying record = error range of that location.
• E4 — behavior pattern record section recording the representative staying point and representative staying record in a storage area as behavior pattern information.

Dependent / disclosed variants (granted dependent claims 13–21 and the embodiments)

• E5 (claims 13-type): location measurement records = error ranges based on location-measurement accuracy; estimated staying ranges = overlap of ≥ N such records; the staying point = the location point with the highest location measurement accuracy among records incorporating the range; the staying record = that location measurement record.
• E6 (claim 14-type): estimated representative staying range = the range where the largest number of staying records overlap; representative staying point = the highest-accuracy staying point among them; representative staying record = that staying record.
• E7 (claim 15-type): a staying point whose record overlaps no other staying record is itself output as a representative staying point.
• E8 (Second Embodiment; claims 16/18-type): staying record = a circle covering all location measurement records (or all location points) measured in the period; staying point = the center.
• E9 (Third Embodiment; claims 19/20-type): staying point = weighted median of the location points; staying record = circle centered on it with radius to the farthest location point; weighting is by intervals of location-measurement times.
• E10: "moving location points" for points whose record hasn't overlapped for a threshold time (120 min example) (claim-support feature, [0060s]).

The technical core for § 103 is the pairing of E2 + E5/E6: (i) treating each fix as an uncertainty "record", (ii) using overlap of records to find stays, (iii) picking the most accurate member of the overlapping set, and (iv) repeating the overlap/select step at a longer time scale to get repeatedly-visited "representative" locations that are stored as the behavior pattern. Every one of these is addressed by art already of record.

3. The prior art of record and what each teaches

Key takeaway: the two references that carry the error-range/overlap teaching (JP 2004-112482) and the two-level stay-point/frequently-visited-place teaching (Zheng; Matsuura) were both of record. The obviousness question therefore reduces largely to whether a POSA would have combined them, not whether each element existed somewhere.

4. Element-by-element mapping (illustrative)

(✔ = taught; ~ = suggested/analogous; ✗ = not shown.)

No single reference teaches all of E1–E6. The § 103 case is a combination case, which is exactly what the statute contemplates.

5. Combinations that would render the claims obvious, and the motivation to combine

Combination A (primary): Zheng 2009 + JP 2004-112482

• Base (Zheng): acquiring GPS location points; detecting stay points from spatially/temporally concentrated fixes; aggregating stay points into frequently-visited "locations"/regions; mining and outputting location patterns. This supplies E1, E2 (stay concept), E3 (two-level aggregation = "first period" local stays vs "second period" repeatedly-visited places), E4, and E10.
• Secondary (JP 2004-112482): modeling each measurement as an uncertainty range and resolving position by range overlap, expressly to overcome level/环境 variability and "realize a location detection system … with high accuracy." This supplies E2's "error range," E5's "estimated staying range = overlap," and E6's "range where the largest number overlap" + "select the highest-accuracy member."
• Motivation (with rational underpinning): Both are in the same field (deriving location/behavior meaning from noisy wireless positioning). Zheng's stay-point test is a bare distance threshold that is known to be corrupted by GPS error — the same defect the patent itself concedes at [0005] ("impossible to accurately judge whether the terminal stands still only from the coordinate value information"). JP 2004-112482 teaches precisely the fix (use overlap of uncertainty ranges). Under KSR, applying a known technique (overlap of error ranges) to improve a similar device/method (trajectory-based stay/location mining) in the same way, yielding the predictable benefit of greater accuracy, is obvious; it is also at most an "obvious to try" of a finite, identified set of accuracy-improving options.

Combination B (primary): JP 2000-180199 + JP 2004-112482 (+ Zheng or Matsuura)

• Base (PD1): periodic acquisition of location+time and output of the behavior history (E1, E4).
• Secondary (PD2): uncertainty-range construction + overlap-based location resolution (E2/E5/E6 mechanics).
• Tertiary (Zheng or Matsuura): the second, longer-time-scale aggregation into "repeatedly-visited" places (E3), with Zheng's "interesting locations" or Matsuura's same-place Stay-ACTIVITY "mother count" supply the repeated-visit aggregation.
• Motivation: PD1 assumes high GPS accuracy; the art recognizes this assumption fails (moving/underground). PD2 supplies a reason to correct PD1's assumption; the patent's own background frames the problem as "extract the behavior pattern with higher accuracy." Combining a known behavior-history device with a known positioning-accuracy technique to obtain the expected accuracy improvement is a textbook KSR "improvement of a known device by a known technique."

Combination C (alternative): Matsuura US 2006/0156209 (+ JP 2004-112482 / + Zheng)

• Matsuura supplies stay-vs-move classification plus a repeated-visit aggregation with occurrence counts (E2/E3/E10) and its thresholds are expressly time/distance based; PD2 supplies error-range overlap (E5/E6). Motivation identical: accuracy of stay detection and of "how often the user visits this place."

Rationales (MPEP 2143 framework) that a challenger would invoke

1. Known technique to improve a similar device/method (overlap-of-ranges → better accuracy) — Combination A/B/C.
2. Simple substitution of a distance-threshold stay test with an uncertainty-overlap test, predictable result.
3. "Obvious to try" — a small, identified set of accuracy-improvement techniques.
4. Design incentive / art-recognized problem — the patent's own [0005] is an admission of the problem the secondary art solves.
5. Same field of endeavor / reasonably pertinent — GPS/positioning and behavior-history mining; both supersets of the problem "where did the user stay and how often."

6. Where a § 103 challenge is strongest and weakest

Strongest (most likely to succeed)

• E5/E6 mechanics (error range, ≥ N overlap, largest-overlap, highest-accuracy selection): JP 2004-112482's overlap-of-ranges + "highest accuracy" as a routine engineering selection (choose the most reliable of several overlapping measurements).
• E8 (covering circle/center; Second Embodiment, claims 16/18): a minimum enclosing circle / bounding-circle with centroid — long-known computational geometry, and Zheng's clustering already uses region radius/centroid concepts. Motivation: ensure all candidate ranges are covered; trivial computational benefit.
• E9 (weighted median + radius-to-farthest; Third Embodiment, claims 19/20): median/centroid + enclosing circle plus time-interval weighting to reflect dwell time — a conventional robust-estimation and weighting choice, expressly justified in the spec as reducing computation and improving accuracy.

Weaker / where an applicant could resist

• Literal teaching of the exact combination "first period" vs "longer second period" with error-range records carried through both stages and the representative staying record stored as the behavior-pattern item. Zheng/PD1 outputs locations, not an error-range record as the stored behavior artifact. Applicant would argue the two-stage error-range-carrying pipeline (E2→E3) is not literally taught.
• "Highest location measurement accuracy" selection — none of the mapped art explicitly says "pick the most accurate of the overlapping fixes"; it is arguably a hindsight characterization (though KSR "obvious design choice / predictable result" cuts strongly against this).
• I have not verified the full Japanese texts or the Sugihara/Matsuura US specifications; those must be pulled before asserting any reference teaches a specific limitation.

7. Secondary considerations (objective indicia)

Per the Litigation Summary, there is no known litigation, no PTAB/IPR challenge, no license/industry-praise record for US 9,052,204. The patent is held by an operating company (NEC), is a 2010-era filing, and shows no evidence of commercial embodiment or copying tied to the claimed features. Accordingly, no objective indicia of non-obviousness are of record to rebut the prima-facie combination case. (Note: the Virginia E.D. "204 patent" decision surfaced in search — claims to "locate operations"/dig-area images — is a different patent (CertusView-type), consistent with the earlier section's exclusion; it is not this patent.)

8. Bottom line

• US 9,052,204's independent system/method claims are combination claims whose components are individually reflected in JP 2000-180199 (behavior history from repeated location+time fixes), JP 2004-112482 (location resolved by overlap of uncertainty ranges), and the examiner-cited Zheng et al., WWW 2009 (extraction of stay points and frequently-visited locations from GPS trajectories), with US 2006/0156209 (Matsuura) corroborating the stay-vs-move + repeated-visit aggregation concept.
• The strongest § 103 theory is Zheng 2009 in view of JP 2004-112482, optionally further in view of Matsuura/JP 2000-180199: overlap-of-error-ranges supplies E2/E5/E6, and the two-level stay-point→frequently-visited-place extraction supplies E3/E4, with the motivation being the art-recognized (and patent-admitted) GPS-accuracy problem.
• Dependent/embodiment claims E8 (bounding circle/center) and E9 (weighted median + radius-to-farthest) are standard geometry/statistics and thus highly vulnerable to an obviousness attack on their own once the independent claims fall.
• The most defensible applicant position is that no reference literally discloses the two-stage error-range-carrying pipeline with the highest-accuracy selection and storage of the representative staying record as the behavior pattern — but KSR "predictable results / obvious design choice" reasoning materially weakens that position.

Recommended verification before relying on any of the above: (1) obtain the verbatim granted claims 1–21; (2) obtain full texts/translations of JP 2000-180199, JP 2004-112482, JP 10-176929; (3) confirm the teachings of US 2006/0156209 A1 and US 2010/0070456 A1; (4) confirm the Zheng 2009 paper's stay-point and location-clustering definitions against the claims' "first/second period" and "error range" language.