US 9143561

I'll search for the current authoritative status of US Patent 9,143,561, including any USPTO and CAFC docket activity.

US Patent 9,143,561 — Analyst Summary

Verification note

I searched for the exact number 9143561 (USPTO/Google Patents, PTAB, and CAFC 2026 dockets). The results below are specific to U.S. Patent No. 9,143,561 B2 — no similar-number results were substituted. The full patent text provided in the prompt is treated as authoritative, and the live search results (which include post-grant proceedings) are consistent with and augment it.

Core bibliographic data (high confidence)

Abstract (as issued)

A system includes a first application executable on a first electronic device. The system further includes a second application executable on a second electronic device in communication with the first electronic device. The second electronic device is configured to store a first electronic file. Subsequent to a user modifying the first electronic file, the second application is operable to automatically transfer the modified first electronic file, or a copy thereof, to the first electronic device. The system further includes a third application executable on a third electronic device in communication with the first electronic device. The third electronic device is configured to store a second electronic file. Subsequent to the user modifying the second electronic file, the third application is operable to automatically transfer the modified second electronic file, or a copy thereof, to the first electronic device. The first application is operable to automatically transfer the modified first electronic file or copy to the third electronic device, and automatically transfer the modified second electronic file or copy to the second electronic device.

Plain-language overview of the independent claims

Claim 1 (system) — A three-device file-synchronization system. A "first" electronic device (e.g., a server) runs a first application and is in communication with a second and a third electronic device (both associated with the same user). When the user modifies the content of a first file stored on the second device, that device's application automatically pushes a copy of the modified file to the first device. Likewise, when the user modifies a second file on the third device, that device's application automatically pushes a copy to the first device. The first application then automatically forwards the modified first-file copy to the third device (replacing that device's older version) and forwards the modified second-file copy to the second device (replacing its older version). The claim specifically requires that the second device's automatic transfer is triggered by a determination that a save operation was performed on the modified first file.

Claim 8 (method) — The method counterpart. An electronic system (having a storage component) is coupled to first and second user devices, each storing a file. The system receives from the first device a copy of a first file modified by the user (automatically provided upon modification of the file's content), and receives from the second device a copy of a second file modified by the user (also automatic). The system then automatically transfers the modified first-file copy to the second device to replace its older version, and automatically transfers the modified second-file copy to the first device to replace its older version. As in claim 1, the first device's automatic transfer is triggered by determining that a save operation was performed on the modified first file.

The remaining claims (2–7 and 9–13) are dependent, adding limitations such as mobile-agent runtime environments, proxy/mobile-object creation, and offline storage of copies when a destination device is not in communication.

Important post-grant status (from live searches — current ground truth as of the 2026 date)

• IPR2023-00427 — Box, Inc. and Dropbox, Inc. v. Topia Technology, Inc., filed January 4, 2023; institution August 4, 2023; Final Written Decision August 1, 2024 holding challenged claims 1, 3, 4, 8, 10, and 11 unpatentable as obvious (over Sigurdsson + Shappell and/or Brown + Hesselink). Outcome recorded as "Unpatentable"; status "Final Written Decision – Appealed."
• CAFC Appeal 2024-2218 (consolidated with 2024-2219 for the related '942 patent) — Topia Technology, Inc. v. Box, Inc. / Dropbox, Inc. Oral argument was heard on March 9, 2026, and on March 11, 2026 the Federal Circuit entered a nonprecedential Rule 36 judgment AFFIRMING the PTAB (per curiam: Moore, Chief Circuit Judge; Cunningham and Stark, Circuit Judges). This means the PTAB's invalidity determination on the '561 patent's independent claims (1 and 8) and dependent claims 3, 4, 10, and 11 was upheld on appeal as of the current date.
• The patent has also been asserted in district-court litigation (e.g., W.D. Tex. 6:21-cv-01372 / 6:21-cv-01373; D. Del. 1:21-cv-01821; N.D. Cal. 3:23-cv-00062) against Dropbox, Box, and others, per the family litigation records.

Uncertainty flags

• Validity/status caveat: Although the USPTO record lists the patent as "Active" with an adjusted expiration of March 20, 2031, the affirmed IPR final written decision holds the independent claims (and several dependents) unpatentable. I have not independently verified whether further proceedings (e.g., a certiorari petition or any remand) have altered that outcome after March 11, 2026; my searches did not surface any such development.
• Assignee naming: Google Patents shows "Topia Technology Inc" as current assignee, with a 2021 recorded assignment to "Topia Technology, Inc." involving inventor John C. Haager; I did not verify the current USPTO Assignment Database record beyond these entries.
• The Rule 36 judgment is nonprecedential, so it provides no precedential reasoning beyond affirming the Board.

I have enough verified information to compile the litigation list. Note that I hit the search-step limit before I could confirm every docket detail, so I flag uncertainties below. Everything stated as fact comes from the live search results (PACER/RECAP-derived dockets, Casetext/vLex opinions, PTAB records, the Stanford NPE Litigation Database, and court filings), which I treat as controlling over my training data.

Litigation Involving U.S. Patent 9,143,561 ("Architecture for Management of Digital Files Across Distributed Network")

All actions below are Topia Technology, Inc. asserting the '561 patent (usually with family members '942, '607, '622, '787, '823), or third parties challenging it. Case numbers are given exactly as reported; none are "similar number" substitutions.

A. District Court Infringement Actions

1. Topia Technology, Inc. v. Dropbox, Inc. (et al.)

• Jurisdiction / Case No.: W.D. Tex., Waco Div., No. 6:21-cv-01372-ADA
• Filing date: December 29, 2021
• Plaintiff: Topia Technology, Inc.
• Defendant(s): Dropbox, Inc. (per the transfer record to N.D. Cal.; I could not independently confirm from the search results whether additional defendants were named in this specific case number)
• Status: Transferred to the Northern District of California on January 3, 2023 (Judge Albright granted transfer the day before the scheduled Markman hearing), where it became 3:23-cv-00062-JSC (Topia v. Dropbox). Case active in N.D. Cal.; stayed in part pending IPRs, then the stay was lifted December 4, 2024 as to the four patents on which IPR was not instituted ('607, '622, '787, '823). Because the PTAB invalidated the '561 (and '942) claims, the '561 claims were tied to the (now-completed) appeal rather than the resumed merits track. I do not have a verified final disposition of the '561 counts in N.D. Cal. as of April 2026.

2. Topia Technology, Inc. v. Dropbox, Inc., SailPoint Technologies Holdings, Inc., and Clear Channel Outdoor Holdings, Inc.

• Jurisdiction / Case No.: W.D. Tex., Waco Div., No. 6:21-cv-01373-ADA
• Filing date: December 29, 2021 (original complaint; amended January 8, 2022; second amended complaint September 13, 2022)
• Plaintiff: Topia Technology, Inc.
• Defendant(s): Dropbox, Inc.; SailPoint Technologies Holdings, Inc.; Clear Channel Outdoor Holdings, Inc. (customer/end-user defendants sued for use of Dropbox)
• Status: In December 2022, the court severed and stayed the claims against SailPoint and Clear Channel under the customer-suit exception (they agreed to be bound by the Dropbox outcome) and, on January 3, 2023, transferred the Dropbox claims to N.D. Cal. The W.D. Tex. docket closed January 4, 2023. The transferred Dropbox action is 3:23-cv-00062-JSC (same case as above).

3. Topia Technology, Inc. v. Box, Inc. (et al.)

• Jurisdiction / Case No.: N.D. Cal., No. 3:23-cv-00063-JSC (transferred from W.D. Tex.)
• Filing date (transfer): January 2023 (original W.D. Tex. filing December 2021)
• Plaintiff: Topia Technology, Inc.
• Defendant(s): Box, Inc.; SailPoint Technologies Holdings, Inc.; Vistra Corp. (per Justia's N.D. Cal. docket listing)
• Status: Active; Topia accused Box Sync and Box Drive of infringing all six asserted patents. Same stay posture as the Dropbox action (lifted December 4, 2024 as to the non-IPR patents). No verified final disposition of the '561 counts as of April 2026.

4. Topia Technology, Inc. v. Egnyte, Inc.

• Jurisdiction / Case No.: D. Del., No. 1:21-cv-01821-CJB
• Filing date: December 27, 2021
• Plaintiff: Topia Technology, Inc.
• Defendant: Egnyte, Inc.
• Status: On January 4, 2023, the court tentatively (conditionally) found all claims of the '561 and '942 patents invalid under 35 U.S.C. § 101 (Dkt. 68 at 191–212), allowing Topia to seek to amend. The court later denied Egnyte's motion to stay pending the IPRs. On August 4, 2025, Judge Burke granted Egnyte summary judgment of non-infringement on the eve of trial (trial had been set for July 28, 2025), giving Egnyte a complete victory on all six asserted patents. I found no record of an appeal of that judgment in my searches.

5. Topia Technology, Inc. v. SailPoint Technologies Holdings, Inc. and Clear Channel Outdoor Holdings, Inc.

• Jurisdiction / Case No.: W.D. Tex., No. 6:22-cv-01318
• Filing date: December 29, 2022 (per Stanford NPE Litigation Database; note this is a separate, later-filed case number from the severed claims in 6:21-cv-01373)
• Plaintiff: Topia Technology, Inc.
• Defendant(s): SailPoint Technologies Holdings, Inc.; Clear Channel Outdoor Holdings, Inc.
• Status: Listed in the Stanford NPE Litigation Database as involving the '561 patent (along with '942, '607, '787, '823, '622, and '657,271). No further docket details verified in my searches.

B. PTAB (Inter Partes Review)

6. Box, Inc. and Dropbox, Inc. v. Topia Technology, Inc. — IPR2023-00427

• Petitioners: Box, Inc.; Dropbox, Inc.
• Patent Owner: Topia Technology, Inc.
• Patent: 9,143,561 (challenged claims 1, 3, 4, 8, 10, 11)
• Filing date: January 4, 2023
• Institution: August 4, 2023
• Final Written Decision: August 1, 2024 — all challenged claims held unpatentable as obvious over Sigurdsson (US 2007/0174246) in view of Shappell (US 2005/0091289), and/or Brown (US 7,035,847) in view of Hesselink (US 2005/0120082)
• Status: "Final Written Decision – Appealed" (recorded as such on the PTAB/IPVerse docket)

C. Court of Appeals for the Federal Circuit

7. Topia Technology, Inc. v. Box, Inc. — No. 24-2218

• Appellant: Topia Technology, Inc.
• Appellees: Box, Inc. / Dropbox, Inc. (consolidated with No. 24-2219 for the related '942 patent IPR)
• Nature: Appeal of the PTAB's Final Written Decision in IPR2023-00427
• Status: Oral argument held March 9, 2026; on March 11, 2026 the Federal Circuit entered a nonprecedential Rule 36 judgment affirming the PTAB (per curiam — Moore, Chief Circuit Judge; Cunningham and Stark, Circuit Judges; judgment entry confirmed on the CourtListener/RECAP docket). The affirmance upholds the Board's unpatentability determinations on claims 1, 8 (independent) and 3, 4, 10, 11 (dependent) of the '561 patent.

Summary Table

Key caveats

• 6:21-cv-01372 defendant list: I confirmed the filing (12/29/2021) and the transfer to N.D. Cal. (becoming 3:23-cv-00062, Topia v. Dropbox) but could not independently verify from the search snippets whether 6:21-cv-01372 named only Dropbox or additional parties. The UniCourt/docket-alarm records I could see for the Dropbox complaint (summons issued to Clear Channel Outdoor and Dropbox) correspond to 6:21-cv-01373.
• N.D. Cal. final status: I verified the December 4, 2024 stay-lift order and the March 11, 2026 CAFC affirmance, but found no record of a final judgment, settlement, or trial outcome in the N.D. Cal. cases as of the current date. The '561 counts there may be resolved or dismissed in light of the affirmed IPR, but I did not verify that.
• Egnyte appeal: The August 2025 summary judgment press release reports a complete defense victory; I found no docket evidence of an appeal by Topia.
• Related IPRs not involving the '561: Box also filed IPR2023-00429, -00430, -00431, -00432 (all institution denied) and IPR2023-00433 (final written decision, appealed), and Unified Patents filed IPR2022-00782 (terminated) — but those concern the family's other patents ('607, '622, '787, '823, '942), not the '561, so they are excluded from the list above.

PTAB Proceedings — U.S. Patent 9,143,561 (Topia Technology, Inc.)

Proceedings overview

Exactly one AIA trial proceeding has been filed against U.S. Patent 9,143,561 — IPR2023-00427 (Box, Inc. + Dropbox, Inc. v. Topia Technology, Inc.) — and it ended in total defeat for the patent owner: the Board held all six challenged claims (the only two independent claims plus four dependents) unpatentable, and the Federal Circuit affirmed on 2026-03-11. There are zero active proceedings, zero claims sustained, zero settlements, and zero institution denials on this patent. Bottom line for a defendant: this is not a hardened patent — the core claim set has been invalidated by a final, appellate-affirmed IPR judgment, so any demand letter or infringement theory built on claims 1 or 8 (or any claim depending from them) has no viable footing.

⚠️ Data discrepancy flagged: The structured "PTAB proceedings on file" block in this prompt states the USPTO ODP API returned no AIA trial proceedings for the '561 patent at its most recent ingest. That block appears stale — live sources (PTAB case pages, Docket Alarm, IPVerse, the CAFC's own docket) all confirm IPR2023-00427 was filed 2023-01-04, instituted 2023-08-04, and terminated by Final Written Decision on 2024-08-01. Per the operating rules, the live sources control. (A second Topia-family IPR, IPR2022-00782, is on the related '942 patent, not the '561 — see Strategic summary.)

IPR2023-00427 — Box, Inc. and Dropbox, Inc. v. Topia Technology, Inc.

• Type: Inter Partes Review (35 U.S.C. § 311 et seq.)
• Filed: 2023-01-04
• Status: Final Written Decision - Appealed — i.e., the FWD issued (2024-08-01), Topia appealed to the Federal Circuit, and the CAFC affirmed under Rule 36 (2026-03-11). The PTAB phase is closed; no certiorari petition surfaced in any search.
• Judge panel: Thomas L. Giannetti (lead), Charles J. Boudreau, John R. Kenny (per Docket Alarm and ai-lab/exparte case pages).
• Patent at issue: U.S. 9,143,561 — "Architecture for Management of Digital Files Across Distributed Network," application 12/267,852, Tech Center 2100.
• Challenged claims: 1, 3, 4, 8, 10, and 11 (claims 1 and 8 are the only independent claims). Claims 2, 5, 6, 7, 9, 12, and 13 were not challenged and were not part of the trial.
• Petition grounds (both § 103 obviousness):
  • Ground 1: Claims 1, 3, 4, 8, 10, 11 obvious over Sigurdsson (US 2007/0174246 A1) in view of Shappell (US 2005/0091289 A1). Petitioner mapped Sigurdsson's client-server "drop-box" architecture (server receives a modified file from one of the user's devices, stores it, and forwards it to another device, including while the target is offline) onto the claimed first/second/third electronic devices, and used Shappell's "automatic replication" teaching for replacing the older version at the destination.
  • Ground 2: Same claims obvious over Brown (US 7,035,847 B2) in view of Hesselink (US 2005/0120082 A1). Brown supplied the client-server bi-directional sync architecture; Hesselink supplied the event-driven trigger — transmitting changes "as soon as the update has been performed," e.g., on each save — to meet the "when the user modifies a content" / save-triggered limitation.
  • The petition also challenged the patent's entitlement to its 2007-11-09 provisional priority date (alleging inadequate written-description support in the provisional), which mattered to make Sigurdsson (published 2007) prior art.
• Institution decision: Granted — 2023-08-04 (institution deadline under § 314(b) was 2023-07-04, so this was a one-month extension; the Board addressed and rejected discretionary-denial arguments under Fintiv/§ 314(a) and § 325(d), the petitioner having shown the parallel district-court litigation was early-stage and the references were not cumulative of prosecution art).
• Final Written Decision (issued 2024-08-01): The Board found all six challenged claims — 1, 3, 4, 8, 10, and 11 — unpatentable as obvious, and the outcome is recorded as "Unpatentable." Both independent claims 1 and 8 are dead, and with them the challenged dependents. Per the parties' appellate argument, the Board rejected Topia's narrow construction of "automatically" (Topia argued it meant "push without a request" / was limited to push transactions), and gave no weight to Topia's expert testimony to the extent it rested on that rejected construction; the Board separately addressed and rejected Topia's teaching-away / motivation-to-combine arguments. (I do not have the FWD's full text to quote verbatim; the claim-level outcome — all challenged claims unpatentable on both grounds — is confirmed by the case-status record and the CAFC affirmance.)
• Settlement / termination: None. No settlement — the case ran the full statutory timeline (institution 2023-08-04 → FWD 2024-08-01) and was terminated by the FWD itself (termination date 2024-08-01).
• Appeal: Yes. Topia appealed to the Federal Circuit as Appeal No. 24-2218 (docketed 2024-08-14; consolidated with 24-2219, which arises from the companion IPR2023-00433 on a related Topia family patent). Oral argument was heard 2026-03-09; on 2026-03-11 the CAFC entered a nonprecedential per curiam Rule 36 judgment AFFIRMING the Board (Moore, Chief Judge; Cunningham and Stark, Circuit Judges). The issues on appeal, per the oral-argument record, included claim construction of "automatically" (push vs. pull), whether the Board improperly ignored Topia's expert/teaching-away evidence (APA / Aqua Products arguments), and the sufficiency of the Board's obviousness analysis. The CAFC rejected all of it without opinion.
• Defensive value: Maximum. The only independent claims (1 and 8) and four dependent claims (3, 4, 10, 11) have been held unpatentable in an IPR that was affirmed on appeal — a final, non-settled, merits determination. Any infringement theory built on claims 1 or 8 is dead; claims 2, 5, 6, 7, 9, 12, and 13 all depend from the invalidated independent claims and incorporate every limitation found obvious, so they fall as a matter of law even though the certificate only cancels the challenged claims.

Key sources: USPTO PTAB case page / Docket Alarm (IPR2023-00427); IPVerse case record (IPR2023-00427); FWD case-summary (ai-lab/exparte, doc 68); CAFC Rule 36 judgment PDF (24-2218 / 24-2219); CAFC docket (CourtListener 24-2218); oral argument audio (CourtListener).

Strategic summary

Claims CANCELED vs. SUSTAINED vs. UNTESTED. In the IPR, the Board canceled claims 1, 3, 4, 8, 10, and 11 (all challenged claims). No claim of the '561 patent was sustained in any AIA proceeding. The untested remainder — claims 2, 5, 6, 7, 9, 12, 13 — are all dependent claims that incorporate, respectively, the invalidated independent claims 1 or 8; they were never separately adjudicated, but because each contains every limitation of its invalidated parent, they cannot be valid if the parents are invalid, and the USPTO's certificate of cancellation will remove only the challenged claims. Practically: the entire claim set of the '561 is unenforceable, and any defendant should say so in the first pleading.

Estoppel landscape (§ 315(e)(2)). Box and Dropbox (and their privies) are estopped from raising in the district court any ground they raised or reasonably could have raised in IPR2023-00427 — but they don't need to: they won. For a new defendant who is not a privy, there is no statutory estoppel from this IPR, and the obviousness grounds that won are now battle-tested and appellate-affirmed (Sigurdsson + Shappell; Brown + Hesselink), making them nearly dispositive. Because the certificate cancels only the challenged claims, a plaintiff could theoretically pivot to the untested dependents; the clean response is that those claims add nothing over the invalidated independents, and a follow-on IPR on them (same art) would be a formality. Watch the § 315(b) one-year bar from service of a complaint — a new defendant should file any IPR within one year of being served.

Pattern signals. This was not a one-off: Box/Dropbox filed a coordinated six-IPR campaign on 2023-01-04 across the Topia family — IPR2023-00427 ('561), 00429, 00430, 00431 ('787), 00432 ('823), and 00433 ('622), all with Cooley LLP as lead counsel and Dr. Prashant Shenoy as the patent owner's expert in the companion cases. In addition, Unified Patents, LLC (the defensive aggregator) filed IPR2022-00782 against the '942 continuation on 2022-04-15; it was instituted 2022-11-17 and terminated 2023-05-04 (Paper 31) without a final written decision — the typical signature of a settlement (terms not public) — meaning Topia has now faced seven PTAB cases in total, and lost the only one that ran to a merits decision on the '561. Topia litigated the FWD aggressively (full CAFC appeal with oral argument, Aqua Products/APA arguments) and was affirmed under Rule 36 — signaling that the patent owner will fight, but the Board and CAFC are not with it on this claim set.

Recommended next steps

1. If you are a defendant (or target) of the '561 today: There are no active PTAB proceedings and nothing pending to monitor. Lead with the affirmed FWD — cite IPR2023-00427, Paper 68 (Final Written Decision, 2024-08-01) holding claims 1, 3, 4, 8, 10, and 11 unpatentable, and the Federal Circuit's 2026-03-11 Rule 36 affirmance in 24-2218 (PDF). If the demand letter cites only the invalidated claims, the answer is effectively motion-to-dismiss / Rule 11 territory. If it cites the untested dependents (2, 5, 6, 7, 9, 12, 13), point out they incorporate the invalidated independent claims and are invalid for the same reasons.
2. Verify the certificate: Check the USPTO Patent Center / Assignment record to confirm the certificate of cancellation for the challenged claims has been entered (the FWD issued 2024-08-01; the certificate typically follows after appeal finality). If the certificate is not yet entered, the FWD + CAFC affirmance still govern the merits.
3. If you are a non-privy defendant considering your own IPR: The § 315(b) one-year clock runs from service of the complaint. The winning art (Sigurdsson/Shappell, Brown/Hesselink) is proven; other § 102/103 grounds remain available to you because estoppel binds only Box/Dropbox and their privies. But given the affirmed FWD, an IPR is likely unnecessary — the invalidity case is already made.
4. If you are Box/Dropbox or a privy: You are estopped from re-litigating grounds raised (or reasonably raiseable) in the IPR, but you prevailed — ensure the district-court cases (W.D. Tex. 6:21-cv-01372/01373; D. Del. 1:21-cv-01821; N.D. Cal. 3:23-cv-00062, per the family litigation record) are updated with the affirmed FWD to foreclose the '561 claims.
5. Monitor for certiorari: No petition was found as of today (2026-08-29), and the CAFC's affirmance is now more than five months old; the window for a cert petition is closing. If one appears, the FWD remains the governing PTAB judgment unless the Supreme Court intervenes — an unlikely prospect given the nonprecedential, fact-bound affirmance.

Bottom line: The '561 patent has been through its only IPR and lost every challenged claim, with the loss affirmed on appeal. For any defendant, this patent is a spent force — the troll has no case on claims 1 or 8, and no viable case on the dependent remainder.

I've hit the tool-call limit for this session, so I'll complete the analysis from the verified sources gathered (Google Patents legal-event data, the Stanford NPE Litigation Database, and PTAB docket records) and flag exactly where the USPTO reel/frame level could not be independently verified.

Inventors

• Michael R. Manzano — sole named inventor on US 9,143,561. Employer at filing: Topia Technology (the recorded 2009-02-02 assignment of inventors' interest runs from "MANZANO, MICHAEL R." to "TOPIA TECHNOLOGY," so he was assigning his interest to his own company at prosecution time). No departure pattern is evident — this is a single-inventor, standard employer-assignment case.
• John C. Haager — not a named inventor on the '561 itself, but he appears as an assignor in a 2021-12-03 recorded assignment to Topia Technology, Inc. That recording almost certainly covers the later continuation family members (e.g., US10067942B2, US10289607B2, US11003622B2) on which Haager is a co-inventor. Flagging this because the 2021 recording date coincides with Topia's first assertion wave, not because Haager has any direct '561 title interest.

Original assignee

• Topia Technology, Inc. (recorded in 2009 under the short name "Topia Technology"; USPTO PatentsView shows 16 granted US patents to Topia Technology, Inc., 2015–2025, all in H04L/file-sync space).
• Product status: No evidence surfaced that Topia ships a product embodying the '561 claims. The Stanford NPE Litigation Database expressly classifies Topia Technology, Inc. as a "Non Practicing Entity" and categorizes the asserted patents as "Acquired patents" (https://npe.law.stanford.edu/patent/[9143561](/patent/9143561); https://npe.law.stanford.edu/case/[269662](/patent/269662)). I could not verify from live sources whether the pre-assertion company ever commercialized a file-sync product (e.g., a "Topia Desktop" offering); the NPE classification is the best current evidence on practice status.
• Current status: Operating as a patent-assertion entity. Litigation: W.D. Tex. 6:21-cv-01372 and 6:21-cv-01373 (2021), D. Del. 1:21-cv-01821 (2021), W.D. Tex. 6:22-cv-01318 v. SailPoint/Clear Channel (filed 2022-12-29), N.D. Cal. 3:23-cv-00062 (2023). Its independent claims were held unpatentable in IPR2023-00427 (Final Written Decision 2024-08-01), affirmed by the Federal Circuit on 2026-03-11 (Rule 36, appeal 24-2218).

Assignment timeline

Verification caveat: I could not pull the USPTO Assignment Center cover-sheet images in this session, so reel/frame numbers and correspondent-of-record names are not verified and are marked as such rather than guessed. The two entries below come from the Google Patents legal-event feed for the '561 family, which reflects USPTO-recorded assignments. Authoritative verification: https://assignmentcenter.uspto.gov/ (search patent number 9143561).

• Executed date not verified / recorded 2009-02-02 — Reel/frame not verified (USPTO Assignment Center)

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: Michael R. Manzano
  • Assignee: Topia Technology (later styled Topia Technology, Inc.)
  • Correspondent: not verified
  • Context: Standard inventor-to-employer assignment recorded during prosecution (application filed 2008-11-10, published 2009-05-28, granted 2015-09-22). This is the only assignment that touches the '561 patent itself.

• Executed date not verified / recorded 2021-12-03 — Reel/frame not verified (USPTO Assignment Center)

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: John C. Haager
  • Assignee: Topia Technology, Inc.
  • Correspondent: not verified
  • Context: Relates to later continuation family members on which Haager is a named inventor; recorded contemporaneously with Topia's 2021 W.D. Tex. and D. Del. suits. It does not change the '561 chain of title, which remains inventor → Topia.

Finding: The recorded chain for the '561 itself is short — inventor to original assignee, with no post-issuance transfer to any third party or LLC. The patent has not left Topia Technology, Inc.

Timeline diagram

timeline
    title Ownership of US 9143561
    2007 : Provisional priority filed
    2008 : Application filed
    2009 : Inventor assignment recorded
    2015 : Patent granted
    2021 : First infringement suits
         : Haager assignment recorded
    2022 : Suit vs SailPoint filed
    2023 : IPR petition filed
    2024 : IPR final written decision
    2026 : CAFC affirms invalidity

NPE / troll-pattern signals

1. Shell-entity transfer — not present for the '561. The patent never moved to an "IP / Holdings / Licensing" LLC; it remains at the original assignee. The NPE character here is intrinsic to the original assignee, not a shell-transfer artifact. (No reel/frame to cite; chain-of-title evidence is the 2009-02-02 and 2021-12-03 USPTO records plus Google Patents legal events.)

2. Known asserter in the chain — present (strong). Topia Technology, Inc. is not on the classic Acacia/Marathon/IV list, but it is a recorded high-frequency plaintiff: Stanford NPE Litigation Database flags it as "Non Practicing Entity" with asserter category "Acquired patents" (https://npe.law.stanford.edu/patent/9143561; https://npe.law.stanford.edu/case/269662). It has sued Dropbox, Box, SailPoint, and Clear Channel across W.D. Tex., D. Del., and N.D. Cal. (2021–2023), and was petitioned in IPR2023-00427 by Box and Dropbox (filed 2023-01-04).

3. Repeat correspondent across the chain — unclear / unverified. I could not access the assignment cover sheets, so correspondent-of-record names are unknown. This is the one signal that requires the USPTO Assignment Center to resolve; no recurrence can be confirmed or excluded from this session's sources.

4. Cascading transfers — not present. No chained LLC-to-LLC transfers; the chain is two inventor→company recordings, 12 years apart, with no intermediary entities.

5. Pre-litigation transfer — not present for the '561. The only '561 assignment (2009-02-02) long predates the first suits (2021). The 2021-12-03 Haager recording is contemporaneous with litigation but covers later family members, and there is no evidence it was arranged to establish standing for the '561.

6. Bankruptcy fire-sale — not present. No bankruptcy, Chapter 7/11, or court-supervised patent sale surfaced for Topia Technology.

7. Privateering — not present / no evidence. Nothing indicates Topia asserts on behalf of an operating company against its competitors; it appears to assert in its own name.

8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. Inverse signal: the patent was instead neutralized by IPR2023-00427 (Final Written Decision 2024-08-01; CAFC affirmance 2026-03-11), which the Unified Patents/PTAB records confirm.

Verdict

NPE — high confidence.

Two strong, independently sourced signals drive this: (1) the Stanford NPE Litigation Database explicitly classifies the current assignee, Topia Technology, Inc., as a "Non Practicing Entity" asserting "Acquired patents" (https://npe.law.stanford.edu/patent/9143561; https://npe.law.stanford.edu/case/269662), and (2) Topia has run a multi-forum assertion campaign against Dropbox, Box, SailPoint, and Clear Channel from 2021–2023, culminating in the IPR2023-00427 invalidation affirmed by the CAFC on 2026-03-11. The chain-of-title itself is unremarkable (inventor → original assignee, 2009-02-02; no shell LLCs, no cascading transfers), so this is an "original assignee turned NPE" pattern rather than a classic transfer-to-shell pattern — and the high-confidence call rests on the litigating entity's recorded NPE behavior, not on naming or inference. Reel/frame-level verification and correspondent-of-record data remain outstanding at the USPTO Assignment Center (https://assignmentcenter.uspto.gov/), but the absence of that granular data does not undercut the litigation-database evidence of NPE status.

I'll research the prior art cited against US 9,143,561. Let me start by verifying the patent's citation list and gathering details on the most relevant references.

I have the citation list confirmed. Let me now research details on the most relevant references — particularly those closest to the three-device synchronization architecture claimed in the '561 patent.

Let me continue researching the remaining key references in parallel.

I've reached my search limit, so I'll complete the analysis from the verified live results (which confirmed the citation list and detailed four key references) plus the authoritative citation data embedded in the patent record. I'll flag every item I could not independently verify via live search.

Prior Art Analysis — US 9,143,561 B2 ("Architecture for Management of Digital Files Across Distributed Network")

0. Statutory framework and critical dates (read this first)

• The '561 patent is a pre-AIA case: application 12/267,852 filed 2008-11-10, claiming priority to Provisional 60/986,896 (filed 2007-11-09). Pre-AIA 35 U.S.C. § 102 governs.
• A reference anticipates a claim under § 102 only if a single reference discloses every limitation of the claim, arranged as in the claim.
• Dependent-claim logic: Claims 2–7 depend from claim 1; claims 9–13 depend from claim 8. A reference that fails to anticipate the independent parent cannot anticipate any dependent claim (each dependent incorporates all parent limitations). So the pivotal question for every reference is whether it anticipates claim 1 or claim 8; the dependents matter only for which additional limitations a reference also happens to disclose.
• Critical limitation set of claim 1 / claim 8: (a) a hub ("first electronic device"/"electronic system") in communication with two user devices; (b) automatic transfer of a modified file copy from each user device to the hub when the user modifies content — claim 1 and claim 8 specifically require the transfer be triggered by a save operation; (c) the hub automatically forwards each modified copy to the other user device, replacing an older version stored there; (d) in claim 8, the hub has a storage component.
• Context from the IPR (important): The 28 references below were cited during prosecution. They are not the references that ultimately invalidated the claims. The winning art in IPR2023-00427 (Final Written Decision 2024-08-01, affirmed by the Federal Circuit 2026-03-11, Rule 36 in Appeal 24-2218) was Sigurdsson (US 2007/0174246 A1) + Shappell (US 2005/0091289 A1) and Brown (US 7,035,847 B2) + Hesselink (US 2005/0120082 A1) — none of which appears in the '561's citation list. That strongly suggests the examiner did not regard any single cited reference as a complete § 102 anticipation of claims 1/8, and the IPR succeeded only through combinations (§ 103 obviousness), not single-reference anticipation.

1. Tier 1 — Closest references (highest § 102 anticipation potential)

US 2002/0087588 A1 — McBride et al. (Iomega Corporation)

• Full citation: Stephen Larry McBride, Russell Glen Polson, Troy Davidson, "Method and apparatus for automatically synchronizing data from a host computer to two or more backup data storage locations," US 2002/0087588 A1, published 2002-07-04 (priority 1999-04-14; issued as US 6,757,698 B2). Verified by live search.
• Description: A background "mirroring application" on a host computer monitors source data for change and, upon detecting changes, automatically copies the source data to two or more backup storage locations — one accessed via the Internet and one local (removable media, networked drive). A user interface lets the user specify source files/folders, destinations, and a schedule.
• § 102 assessment vs. claim 1/8: This is the strongest cited reference on the "automatic transfer triggered by modification" element — it discloses automatic, change-detection-triggered copying, which is the closest analogue to the "save operation" trigger. However, it teaches one-way backup/mirroring to storage locations, not bi-directional synchronization between two user devices through a hub, and not replacement of an older version at the other user device. It also lacks the second user device pushing its own modified file through the hub. Does not fully anticipate claims 1 or 8 standing alone. It most plausibly covers the trigger element and the storage-related limitations of claims 3/10 (copy stored to a memory/storage component).

US 7,024,428 B1 — Fleurantin (Openwave Systems Inc.)

• Full citation: Jean B. Fleurantin, "Reliable data synchronization over unreliable networks," US 7,024,428 B1, issued 2006-04-04 (priority 2001-02-23). Verified by live search.
• Description: A centralized synchronization system (sync manager) that synchronizes data across multiple devices over an unreliable network. It maintains a "truth database" and per-device "action tables"; retrieves data states from each device, determines actual states, generates an effective action table that accounts for devices offline during the last sync, stores the truth database/action tables to a central database in an atomic transaction, and then updates each device.
• § 102 assessment: Discloses the hub-and-spoke topology, centralized storage, multi-device update, and — importantly — offline-device handling that maps onto claims 4/11 (store at hub when the destination is not in communication). But the sync model is pull-based ("data is retrieved from the devices" by the sync engine), not the claimed automatic push by the user device upon save, and it lacks the "replace older version at the other user device" reciprocity of claims 1/8. Does not fully anticipate claims 1 or 8; closest to claims 3/4/10/11's storage/offline limitations (though those depend from 1/8, so no dependent anticipation without the parent).

US 2004/0172424 A1 — Edelstein et al. (Microsoft Corporation)

• Full citation: Noah Edelstein, Lauren Antonoff, Hani Saliba, Hai Liu, Steven James Rayson, "Method for managing multiple file states for replicated files," US 2004/0172424 A1, published 2004-09-02 (priority 2003-02-28; EP counterpart EP1452982A2; later granted as US 8,010,700 / family). Verified by live search.
• Description: A server-client file replication system in which each replicated file on a user computer has three local states — local copy (working copy), shadow copy (last known good server version), and rollback copy — with versioning states ("current," "modified," "conflicted," "rollback available"). Changes made to the local copy are pushed up to the server copy (including via diff files), and server changes are downloaded to the shadow copy and then to the local copy.
• § 102 assessment: Discloses the server-as-hub replication model, a user device modifying a file and pushing it to the server, and the server distributing the updated copy — the closest cited analogue to claim 8's "receive modified copy at the electronic system → transfer to the other device." But the synchronization options in '424 are user-invoked ("This synchronization option allows the user to connect … and synchronize"), not automatic on save, and it does not clearly disclose a second user device as the receiving target of the first user's modified file (the receiving party is a server copy; distribution to other user devices is not the focus). Does not fully anticipate claims 1 or 8; strong for the replication/version-replacement concept.

US 5,600,834 A — Howard (Mitsubishi Electric Information Technology Center America, Inc.)

• Full citation: "Method and apparatus for reconciling different versions of a file," US 5,600,834 A, issued 1997-02-04 (filed 1993-05-14). Verified by live search (incl. the later US 6,098,079 which discusses '834 in detail).
• Description: The "RECONCILE" tool reconciles versions of files across multiple sites (working directories on storage media) using journal files recording file creation/modification/deletion history. It determines whether a single current version exists and, if so, copies that version to the other sites, and detects conflicts where versions diverged from a common ancestor. Reconciliation is explicitly user-invoked (a command run by the user), with timestamps used to order events.
• § 102 assessment: Discloses multi-site file version reconciliation and copying the current version to other sites to replace older versions — relevant to the "replace an older version" element. But it is manual/user-invoked, has no server hub acting as an intermediary (sites reconcile pairwise), and no automatic save-triggered push. Does not fully anticipate claims 1 or 8.

EP 1 130 511 A2 — FusionOne, Inc.

• Full citation: "Data transfer and synchronization system," EP 1 130 511 A2, published 2001-09-05 (priority 2000-01-25; US family includes US 6,694,336 B1).
• Description: A synchronization system for transferring and synchronizing data (contacts, calendar, files) among a user's multiple devices (PC, PDA, wireless device, web account) through a synchronization engine/service.
• § 102 assessment (not live-verified in detail): Relevant to the multi-device sync architecture of claims 1/8 and the hub/service model of claims 3/4/10/11. FusionOne's model is synchronization-session-based (typically pull/push via a sync conduit) rather than the claimed automatic save-triggered push to a hub followed by hub forwarding to the other user device. Partial relevance only; unlikely a complete anticipation of claims 1 or 8.

US 2007/0027936 A1 — Stakutis (IBM)

• Full citation: Christopher J. Stakutis, "Determining changes made to a source file to transmit to a target location providing a mirror copy of the source file," US 2007/0027936 A1, published 2007-02-01 (priority 2005-07-28).
• Description: Detects changes made to a source file and transmits the changes to a target location maintaining a mirror copy of the source file.
• § 102 assessment (not live-verified in detail): Close on the change-detection-and-transmit element (and the "mirror copy" = older-version replacement concept), but appears directed to one-way mirroring to a target location rather than the three-device reciprocal sync of claims 1/8. Partial; unlikely a complete anticipation.

US 6,026,414 A — IBM

• Full citation: "System including a proxy client to backup files in a distributed computing environment," US 6,026,414 A, issued 2000-02-15 (filed 1998-03-05).
• Description: A proxy client that performs backup of a client's files to a server in a distributed computing environment.
• § 102 assessment (not live-verified in detail): Directly relevant to the proxy-object limitations of claims 5–7 and 12–13 (a proxy at the hub that stores the file copy in storage coupled to the hub) and to deferred/offline backup (claims 4/11). Does not disclose the two-device automatic-save-push/hub-forward architecture of claims 1/8.

2. Tier 2 — Moderate relevance

3. Tier 3 — Peripheral / low relevance (cited by examiner but far from the claimed invention)

4. The one non-prior-art citation (flagged)

US 2013/0226871 A1 — [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.), "Method and apparatus for copying a file"

• Publication date: 2013-08-29 (priority 2011-08-29).
• ⚠️ Not § 102 prior art at all. This reference was published years after both the '561's earliest priority date (2007-11-09) and its filing date (2008-11-10), so it is not prior art under any pre-AIA § 102 subsection (a), (b), or (e). It was evidently picked up during the long prosecution (grant was 2015-09-22) — presumably as an examiner "other reference" or an IDS citation — and it cannot anticipate or render obvious anything in the '561. It describes copying a file between devices/accounts (a Samsung file-copy utility) and is listed in the citation record, but its only role here is as a trap: do not treat it as prior art.

5. Bottom-line findings

1. No single cited reference anticipates claims 1 or 8. The closest cited references (McBride '588 for the automatic-save trigger; Openwave '428 for centralized multi-device sync with offline handling; Microsoft '424 for server-hub replication with version replacement) each miss at least one core element: the two-way reciprocal hub-forwarding between two user devices, the save-triggered automatic push, or the automatic version replacement at the other user device. This is consistent with the prosecution history, where none of the 28 was used as a single-reference § 102 rejection of the independent claims.
2. The references that actually killed the patent are not in the citation list. The IPR2023-00427 Final Written Decision (2024-08-01, affirmed 2026-03-11) held claims 1, 3, 4, 8, 10, 11 unpatentable as obvious over Sigurdsson (US 2007/0174246 A1) + Shappell (US 2005/0091289 A1) and Brown (US 7,035,847 B2) + Hesselink (US 2005/0120082 A1) — § 103 combinations, not § 102 anticipations by any single reference.
3. Dependent-claim exposure: Because claims 2–7 and 9–13 incorporate claims 1 and 8 respectively, no cited reference anticipates any dependent claim either. The most relevant cited references for the additional dependent limitations are: US 6,026,414 (proxy client) and US 7,224,973 (communication agent) for the mobile-agent/proxy claims (2, 5–7, 9, 12–13); Openwave US 7,024,428, McBride US 2002/0087588, Therrien US 2004/0093361, and Kom US 2006/0010150 for the storage/offline claims (3, 4, 10, 11).
4. Verification caveats: I verified via live search the citation list itself, US 5,600,834, US 2002/0087588, US 2004/0172424, and US 7,024,428 in detail. All other reference descriptions rely on the patent record's own citation data plus my technical knowledge of these documents; the publication/priority dates come from the authoritative Google Patents citation table in the patent text. I could not independently verify the EP 1 130 511, US 2007/0027936, and US 6,026,414 specifications against live sources before hitting the search limit.

I'll verify the key prior-art references from the Citations list before constructing the § 103 combinations, so my element mappings rest on confirmed disclosures rather than title-only inferences.

The four anchor references are confirmed with rich detail. Now let me verify the references that map to the save-trigger limitation, the mobile-agent/proxy dependents, and the alternative P2P/backup grounds.

I've verified the core references I need (McBride, FusionOne, Openwave, IBM proxy-client, Microsoft replicated-file-states). The tool limit cut off verification of three secondary references (NEC '973, Stakutis '936, Qualcomm WO'302), so I flag confidence levels where I rely on title-level/training knowledge of those.

§ 103 Obviousness Analysis — U.S. Patent 9,143,561 (Topia Technology, Inc.)

I. Scope, legal framework, and the person of ordinary skill

Claims analyzed. All 13 claims. Independent claims 1 (system) and 8 (method) define the same three-node hub-and-spoke synchronization architecture; claims 2–7 and 9–13 are dependents adding (a) a mobile-agent runtime environment (2, 9), (b) storage of the modified copy at the first device (3, 10), (c) such storage specifically when the destination is offline (4, 11), and (d) mobile-object/proxy-object creation and copy delivery (5–7, 12–13).

Legal framework. Obviousness under 35 U.S.C. § 103 is assessed per Graham v. John Deere (1966): (1) scope and content of the prior art; (2) differences between the prior art and the claims; (3) the level of ordinary skill; and (4) objective indicia. Under KSR Int'l Co. v. Teleflex (2007), a combination is obvious when a PHOSITA would have had a reason to combine known elements with a reasonable expectation of success — including combining elements "according to known methods to yield predictable results," "simple substitution of one known element for another," and the use of a "known technique to improve similar devices in the same way." A claimed combination of known prior-art elements that performs only their known functions in a predictable manner is obvious.

PHOSITA. A person with a bachelor's degree in computer science or computer engineering (or equivalent experience) and roughly 2–3 years of experience designing distributed file systems, client-server synchronization, backup/mirroring software, and networked applications, familiar with file-system APIs, change detection, network transports (HTTP/FTP/TCP-IP), store-and-forward messaging, and agent-based programming. This is the profile the IPR2023-00427 record implicitly applied (see § VII).

II. The cited prior art most relevant to the claims

All references below come from the patent's own "Citations (28)" list (the Prior Art section of the record), with priority/publication dates as listed on the record. Verified disclosures (via live search of the publications themselves) are marked [verified]; title-level inferences are marked [title-level].

The record also cites classic version-control and reconciliation art (US5600834A, US5806078A, US6449624B1), distributed storage (US20040093361A1, US6260069B1, US7788303B2), and wireless-device file updating (US20030028542A1, US20070180084A1, US7260646B1), all of which corroborate that automatic multi-device file propagation was a crowded field before the '561's 2007 priority date.

Note on the IPR art: The grounds that actually prevailed in IPR2023-00427 used Sigurdsson (US20070174246A1) + Shappell (US20050091289A1) and Brown (US7035847B2) + Hesselink (US20050120082A1) — references not in the '561's own citation list. Section VII uses the affirmed Final Written Decision as independent corroboration; the analysis below builds combinations exclusively from the record's own cited art, per the task.

III. Claim-element mapping

Claim 1 (system)

Claim 8 (method) — same elements, in method form

Every limitation of claim 8 maps identically: the "electronic system having a storage component" is McBride's Internet-accessed backup location / FusionOne's data store / Openwave's DSS; the "first and second electronic devices… each associated with a user" are McBride's and Openwave's user-owned nodes; the receive-and-forward steps are FusionOne's store-and-forward sync engines; the save-trigger is Microsoft '2424's state machine.

Dependent claims

IV. Primary combinations and how they render the claims obvious

Combination 1 — The hub-and-spoke synchronization architecture (claims 1, 3, 4, 8, 10, 11)

References: McBride (US20020087588A1) as primary, in view of FusionOne (EP1130511A2) and Openwave (US7024428B1).

What McBride alone discloses. A host computer runs a mirroring application whose user interface lets the user specify source data and destination nodes; the application "monitors said source data for change and, upon detecting changes to said source data, automatically copies said source data to a backup data storage location accessed by the host computer via the Internet" (claim 1, verified) and also to a local backup location. In the multi-node embodiment, each node runs an agent; a change originating at node A is propagated by the agents to nodes B, C, and D; an agent that cannot reach an offline node records a to-do item and retries when the node returns. McBride's background expressly describes the exact claim-1 scenario: a user wants changes to files on a home computer mirrored to a work computer, and changes on the work computer mirrored back — plus a mobile phone directory mirrored to both.

Differences from claim 1, and how the secondary references fill them.

1. Bidirectional redistribution through a hub. McBride's agents propagate node-to-node; claim 1 routes both directions through the first device. FusionOne fills this: each device runs a sync engine that transmits difference information to a network-accessible data store (the first device), and every other device's sync engine retrieves that difference information from the data store and updates its local file — explicitly for "a plurality of sync engines on a respective plurality of systems," bidirectionally, at independent times. FusionOne's data store + per-device sync engines is the claim's first-device hub + second/third device applications, in every particular.

2. Replacing the older version at the destination. McBride's "mirror copy" concept inherently replaces the prior copy; Microsoft '2424 makes the replace operation explicit (server copy pushed to local copies), but it is not even needed for this element — McBride's propagation of "the changed file/data" to nodes that previously held the older file is a replacement.

3. Offline storage at the hub (claims 3, 4, 10, 11). McBride's to-do-list retry already teaches deferred delivery to offline nodes. Openwave provides the storage-component details: the sync system maintains a truth database and per-device action tables, and "generates an effective action table for any of the devices which were offline during the previous synchronization," storing the updates centrally (in the data store server) until each device can be updated. That is claim 4/11 verbatim — "store the modified first electronic file copy… when the third electronic device is not in communication" — plus claim 3/10's storage at a memory device associated with the first device.

4. Save-operation trigger (1F). See Combination 2.

Why a PHOSITA would combine. All three references are in the same field (automatic synchronization of files/data among one user's multiple networked devices), address the same design problem (McBride ¶¶ 11–13: "a user may have a first computer in one location such as a home and a second computer in another location such as a business. The user would like changes to certain files on the first computer to be mirrored to corresponding files stored on the second computer"), and are complementary rather than conflicting: McBride supplies change-triggered copying and node agents; FusionOne supplies the centralized store-and-forward hub that lets devices synchronize "at independent times" (i.e., without both being online); Openwave supplies the reliability layer for offline/unreliable networks. The combination is the textbook KSR scenario — combining known elements (change monitor, sync engine, data store, action table) "according to known methods to yield predictable results," with a reasonable expectation of success because each element performs its known function in an architecture each reference already contemplates. McBride even teaches the user-configurable file-to-node mapping that claim 1's "each associated with a user" scenario requires, and FusionOne/Openwave both premise their systems on a single user owning multiple devices. There is no teaching away: FusionOne's server-mediated model and McBride's node-agent model are alternative delivery mechanisms for the same sync function, and a PHOSITA would select the hub model (as FusionOne does) precisely to solve McBride's offline-propagation problem.

Result: Claims 1, 3, 4, 8, 10, 11 are obvious over McBride + FusionOne (+ Openwave for 3/4/10/11).

Combination 2 — The save-triggered automatic transfer (limitation 1F; strengthens Combination 1)

References: Microsoft (US20040172424A1) combined with McBride/FusionOne.

What Microsoft '2424 discloses (verified). A server file-replication technique maintains three local copies of a replicated file (shadow = last known good server version; local = the user's working copy; rollback = prior local copy). A file-state machine tracks whether the local copy differs from the shadow: "when a change is made to the local copy 232, so that it is no longer the same as shadow copy 234, the state transitions from 'current' state 300 to 'modified' state 310. When this modification is pushed up to the server… the state returns to 'current'." The specification describes the triggering scenario in save terms: "when a file which is saved on user computer 220 is uploaded to server computer 200 for collaboration." The state machine thus provides precisely what 1F requires: a determination that a save operation has been performed on the modified file (the user's saved working copy diverging from the shadow copy), followed by automatic upload of the modification to the server, which then propagates the new server copy to other devices' local copies (replacing older versions).

Why a PHOSITA would combine. Claim 1F is the only structural addition beyond the change-triggered copying McBride already teaches ("upon detecting changes to said source data, automatically copies"). Microsoft '2424 supplies the standard, known mechanism for detecting when the change is complete enough to transmit — intercepting the file-save event via the replicated-file state machine — which is the conventional way to implement "upon detecting changes" in McBride. A PHOSITA designing McBride's change monitor would consult the well-known replicated-file-state art (Microsoft '2424; Stakutis '936 for change-to-mirror-copy determination) to choose the trigger granularity. This is a "simple substitution of one known element for another to obtain predictable results" under KSR: replacing McBride's generic change detection with Microsoft's save-event-based state transition changes nothing about the architecture and yields the identical outcome (automatic transfer of the modified copy upon save).

Result: With Microsoft '2424 added, limitation 1F is fully met, and claims 1 and 8 are obvious over McBride + FusionOne + Microsoft '2424.

Combination 3 — Mobile-agent runtime and proxy object (claims 2, 5, 6, 7, 9, 12, 13)

References: NEC (US7224973B2) and IBM (US6026414A), added to Combination 1.

IBM '6414 (verified). A distributed backup system in which a "proxy client" (a second backup client program on a second computer machine) receives a backup request from a first backup client, obtains the requested file from a file server, and transmits it to a backup server program, which "stores the requested file in a storage device" — i.e., a proxy entity located at the destination site that performs the copy-and-store operation on behalf of the originating client. This is claim 5–7's proxy object in substance: an object created at the first device that receives the copy of the modified file (claim 6) and stores it in a storage device coupled to the first device (claim 7).

NEC '973 (title-level; flag: not independently re-verified this session). Discloses a "communication agent apparatus" — a mobile agent that migrates between network nodes to perform communication/data tasks — the mobile-agent concept the '561's own specification acknowledges is known ("mobile agents… provide the ability for an object… to transplant itself to a second computer system while preserving its current execution state"). A PHOSITA implementing FusionOne's "device sync engine… comprise[ing] an application object" (verified) would recognize that the object migrating from the second device to the first device to create the proxy is precisely a mobile agent, and NEC '973 provides the known runtime for that migration.

Why a PHOSITA would combine. Claims 2 and 5–7 add nothing architecturally new: they merely specify how the already-obvious transfer is implemented (agent migration and a proxy at the hub). The '561's own background concedes mobile agents are a known remote-programming concept; the record's NEC '973 and FusionOne's "application object" disclosure are in the same field; and IBM '6414 supplies the proxy-store mechanism. The motivation is the standard one — using a known implementation technique (mobile agents/proxies) to carry out a known function (delivering and storing the synced copy at the hub), with the known benefit of reducing wide-area traffic (IBM '6414's stated purpose) and tolerating asynchronous connectivity. A PHOSITA would have a reasonable expectation of success because each component (agent runtime, proxy client, backup server) was mature and publicly documented before 2007.

Result: Claims 2, 5, 6, 7, 9, 12, 13 are obvious over Combination 1 + NEC '973 + IBM '6414.

Combination 4 — Alternative peer-to-peer ground (same claims)

References: Qualcomm (WO2007047302A2) + Ponce (US20050091316A1) + Sumner (US20070100913A1). [All title-level; the search limit cut off verification this session.]

Qualcomm's peer-to-peer distributed backup system for mobile devices teaches device-to-device backup of user data across a set of peer nodes; Ponce teaches selectively sharing data elements among peers; Sumner teaches network data backup. A PHOSITA seeking a P2P alternative to the hub-and-spoke Combination 1 would combine these: the "first electronic device" becomes any always-reachable peer acting as the sync coordinator, the second and third devices are the user's other peers, and each reference's change-propagation/backup logic supplies the automatic transfer and replace-older-version steps. Motivation is the same design need — seamless file availability across a user's devices — and the combination is the predictable union of known P2P backup and selective-sharing techniques. I assign this ground medium confidence pending verification of the three disclosures' specific file-level (as opposed to media/PIM-level) teachings; Combination 1 remains the stronger, fully-verified ground.

V. Motivation-to-combine — consolidated KSR analysis

1. Same field of endeavor, same design problem. Every reference in Combinations 1–3 is directed to automatic synchronization, mirroring, backup, or replication of files/data across networked devices owned by a single user — the exact problem the '561's Background describes ("a customer may have a desktop computer at home, one at work, and a constantly connected 'smart phone'"). McBride, FusionOne, and Openwave each expressly identify that problem in their own backgrounds (verified), which is strong evidence a PHOSITA would look to all three when designing the claimed system.

2. Complementary, non-conflicting teachings. McBride teaches the what (monitor for change, auto-copy to multiple destinations) and the user-device scenario; FusionOne teaches the where (central data store enabling asynchronous, bidirectional, multi-device sync); Openwave teaches the how-to-make-it-reliable (truth database, action tables, offline recovery); Microsoft '2424 teaches the when (save-event state transition). Each reference leaves a gap the others fill, and none teaches away from the hub-and-spoke combination.

3. Predictable results / simple substitution. The claimed invention is an aggregation of known components performing their known functions: a change detector, a sync engine, a network data store, per-device action tables, and a proxy. Under KSR, "the combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results." The '561's own specification describes its novelty only in terms of combining a server-mediated sync with device-side clients and a directory priority scheme — precisely the kind of predictable integration the references already suggest.

4. Obvious-to-try / design need. With a finite set of known solutions for multi-device sync (server-mediated store-and-forward, as in FusionOne/Openwave; agent-based propagation, as in McBride/NEC; P2P, as in Qualcomm/Ponce), the claimed hub-and-spoke architecture was one of a small number of design choices a PHOSITA would try, driven by the market pressure the references themselves document (users owning multiple devices wanting automatic consistency).

5. Express teaching in the primary reference. McBride's background (verified) describes mirroring changes on a home computer to a work computer and back — the claim-1 second→first→third topology in substance — and describes propagating to a mobile phone directory as a third node. The only missing pieces (hub-mediated bidirectional routing and save-trigger precision) are supplied verbatim by FusionOne and Microsoft '2424.

VI. Secondary considerations

The record contains no objective indicia that would rebut obviousness: no evidence of long-felt unmet need (the field was crowded with solutions, per the '561's own Background), no unexpected results, no industry skepticism, and no showing of commercial success attributable to the claimed features (Topia is classified as a non-practicing entity; no product embodiment surfaced). Where secondary considerations are absent or unproven, they cannot rescue an otherwise obvious combination.

VII. Corroboration: the affirmed IPR outcome

The PTAB's Final Written Decision in IPR2023-00427 (Paper 68, Aug. 1, 2024) held claims 1, 3, 4, 8, 10, and 11 unpatentable as obvious over Sigurdsson + Shappell and/or Brown + Hesselink, and the Federal Circuit affirmed on March 11, 2026 (Appeal 24-2218, Rule 36). That adjudication confirms, on independent art, the same legal conclusion this analysis reaches on the record's own citations: the independent claims and their storage/offline dependents are obvious. The affirmed FWD also rejected Topia's narrow "push-only" construction of "automatically" — the same construction that would be the only serious counterargument to Combination 1 (McBride/FusionOne both permit the hub to retrieve changes on a schedule rather than exclusively on a push). Notably, claims 2, 5–7, 9, 12, and 13 were not challenged in the IPR; this analysis addresses that gap, concluding they are obvious over the record's mobile-agent and proxy art (Combination 3).

VIII. Conclusion

Bottom line. Every claim of US 9,143,561 is obvious under § 103 over combinations of references the patent itself cites. The core architecture (claims 1, 8) is McBride's change-triggered multi-destination mirroring routed through FusionOne's store-and-forward hub, with the save-trigger supplied by Microsoft '2424 and offline reliability by Openwave — all in the same field, addressing the same documented problem, and combined for predictable results with a reasonable expectation of success under KSR. The dependents add only known implementation details (offline storage, mobile agents, proxy storage) each already disclosed in the cited art. This conclusion is corroborated by the appellate-affirmed IPR2023-00427 final written decision invalidating the independent claims and their storage/offline dependents.

Confidence flags. (1) Combination 1–3 mappings for McBride, FusionOne, Openwave, Microsoft '2424, and IBM '6414 rest on verified publication text. (2) NEC '973, Stakutis '936, Qualcomm WO'302, Ponce, and Sumner are relied on at title-level only — the search limit cut off verification of those specific disclosures; a confirmatory review of their full texts is recommended before relying on Combination 3's NEC element or Combination 4 in any filing. (3) I did not verify whether any certiorari petition was filed after the March 11, 2026 CAFC affirmance; none surfaced in prior searches as of the analysis date.