Invalidity dossier

US 9190842

Polyphase power distribution and monitoring apparatus

Current assignee: Greenthread, LLC

Added 9/28/2026, 4:05:00 PM

IndustryEnergy (E)
At a glanceNo PTAB challenges3 lawsuits on fileasserted by Greenthread, LLCEnergy (E)

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Patent summary

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

✓ Generated

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

Search result summary — US 9,190,842 (searched literally as "9190842")

I searched for the exact identifier 9190842 and found no USPTO or CAFC 2026 docket entry naming this patent. The only authoritative record I can confirm is the patent document itself and its prosecution/file-history metadata. Details below, with explicit uncertainty flags.


1. Bibliographic data (authoritative — from the patent record)

Field Value
Patent number US 9,190,842 B2
Title Polyphase power distribution and monitoring apparatus
Application no. 14/029,484 (pre-grant pub. US 2014/0015317 A1, 2014-01-16)
Filing date September 17, 2013
Issue date November 17, 2015
Inventors Carrel W. Ewing (Reno, NV); Andrew J. Cleveland (Reno, NV); James P. Maskaly (Sparks, NV)
Original assignee Server Technology, Inc. (Reno, NV)
Current assignee Legrand DPC, LLC — by merger of Server Technology into Legrand DPC, recorded 2024-05-22, effective 2022-06-30
Earliest priority October 30, 2003 (provisional 60/516,671)
Continuation chain 13/181,390 ← 12/857,420 (US 7,977,815) ← 12/194,390 (US 7,777,365) ← 10/698,023 (US 7,414,329 B1) ← prov. 60/516,671
Child 14/941,914 (US 2016/0134111 A1) — continuation, abandoned
Claims 26 total; independent claims 1 and 17
Primary examiner Carlos Amaya
Classification H02J 3/00; H02G 3/00; H02J 1/00; US Cl. 307/13 (Polyphase)
Legal status Expired – Lifetime; anticipated expiration 2023-10-31
Post-grant event Certificate of Correction, 2016-03-08

Source: https://patents.google.com/patent/[US9190842B2](/patent/US9190842B2)/en ; https://patents.justia.com/patent/9190842


2. Docket / litigation check (CAFC 2026 and district courts)

  • CAFC 2026 dockets: none found. Multiple targeted searches for 9190842 in combination with Federal Circuit / 2026 appeal language returned zero results tying this patent to any Federal Circuit appeal. I cannot state affirmatively that no such appeal exists — only that I found no evidence of one.
  • Family-level litigation flag exists on the Google Patents record ("Family has litigation," via Darts-IP), but the named cases in the public record concern sibling patents, not the '842 patent itself:
    • Server Technology, Inc. v. American Power Conversion Corp. — D. Nev. 3:06-cv-00698 and 3:11-cv-00068 (asserted US 7,043,543 and US 7,702,771; jury verdict 2014; reversed by the Federal Circuit in September 2016).
    • Server Technology, Inc. v. Raritan Inc. et al. — D. Nev. 3:15-cv-00330, settled and dismissed without prejudice January 2016, with a confidential license to certain Server Technology patents.
  • A 2026 data-center PDU case does exist — Vertiv Corp. v. Legrand DPC LLC, W.D. Tex. 3:26-cv-00636 — but the patents I can see asserted there are US 7,522,036 / '501 / '918-family patents, not the '842 patent. Uncertain: I could not confirm from the retrieved excerpts whether the '842 patent is asserted in that or any other current action.
  • Practical note: the '842 patent's term expired 2023-10-31, which sharply limits the likelihood of it being a live 2026 assertion subject (damages would be limited to pre-expiration infringement).

3. Abstract (verbatim)

A polyphase power distribution and monitoring apparatus having sets of outputs for each phase of power and monitors for each phase of power disposed in the housing. Each monitor provides a visible display of current for an associated phase of power and an audible alarm for each phase of power if the current exceeds a predetermined value or falls below a predetermined value. In three-phase wye power systems, the apparatus preferably includes a neutral line monitor, including a neutral line current display and audio alarm, for the neutral line of the wye power circuit. The apparatus preferably is lightweight, elongated, portable, and mountable to the side of an electronic equipment rack. It may also include additional power monitoring systems such as network power monitoring tools for remotely monitoring the apparatus.


4. Plain-language overview of the independent claims

Claim 1 — the "distributed on-board display" claim (apparatus-level, broad):
A polyphase AC power distribution apparatus for powering equipment in an electrical equipment rack, comprising:

  • a vertical rack-mountable housing;
  • a polyphase power input inside that housing;
  • a plurality of power outputs on a face of the housing, where at least one outlet is fed by a first phase and at least one other outlet is fed by a second phase; and
  • a display system on that same face having a first phase power display section and a second phase power display section.

The single point of novelty is the configuration requirement: the display system must visibly report first-phase power information on the first display section at the same time as it reports second-phase power information on the second display section. In plain terms: simultaneous, per-phase readouts on the face of the rack-mounted strip, rather than one shared display that a user cycles through with a button. (This is the express advance over the cited prior-art plugstrip described in the background.)

Dependent claims 2–16 narrow this: current readouts plus dedicated current determination circuits per phase (claim 2); add a third phase (claims 3, 4, 7, 10); add a neutral line display section for wye systems (claims 5, 6, 8, 11) — note claim 6 recites a third current determination circuit associated with the neutral line; numerical values, including power values and current values (claims 12–14); and a sensory/audible alarm triggered by the displayed phase power information (claims 15–16).

Claim 17 — the "fully integrated plugstrip" claim (narrower, feature-rich):
A fully integrated electrical power distribution plugstrip for a vertical electrical equipment rack within a data center, comprising:

  • (A) a unitary vertical strip enclosure whose length exceeds its width and which has a thickness;
  • (B) a polyphase power input penetrating the enclosure;
  • (C) a plurality of power outputs along a face, connectable to rack loads, with outputs respectively fed by a first phase and a second phase;
  • (D) power control relays inside the enclosure, each wired to the polyphase input and able to independently control power to corresponding outputs (i.e., switched outlets, not just monitored ones);
  • (E) current sensing devices inside the enclosure producing quantified current information, at least a first and a second device respectively sensing current for the first and second phases;
  • (F) a numerical current display system on the enclosure with first and second phase current display sections, again configured to show first-phase current information while showing second-phase current information; and
  • (G) a current-related information reporting system inside the enclosure, including a network interface controller directly connectable to a separate communications network distal from the plugstrip, which receives the quantified measured current information and communicates it to a remote system over that network.

So claim 17 = vertical polyphase rack PDU + per-outlet switched relays + per-phase current sensing + simultaneous on-board per-phase numeric current displays + built-in networked remote reporting.

Dependent claims 18–26 add: at least one microprocessor controlling multiple relay boards (18); relay boards carrying both relays and two or more current sensing devices (19); hall-effect current sensors (20); an inter-IC (I²C) control bus to the relay boards (21); a network agent using SNMP (22); a CAT-5 connector for the network interface controller (23); a personality module providing an HTTP browser and/or terminal-server interface (24), which is removable (25) and interchangeable with a second personality module (26).


5. Explicit uncertainties

  1. No authoritative confirmation of 2026 Federal Circuit activity involving US 9,190,842. My searches returned no CAFC 2026 docket entry; treat "no CAFC activity" as absence of evidence, not a verified negative.
  2. No confirmed current district-court assertion of this patent. The '842 patent is a late continuation in a family whose well-known litigations (APC/Schneider, Raritan/Legrand) chiefly asserted other family members.
  3. I did not retrieve the 2016 certificate of correction text, so I cannot state which claim or text was corrected.
  4. One literal drafting quirk worth noting since you asked for literal treatment: claims 2, 4 and 6 refer to a "polyphase power unit" where claim 1 and the specification say "polyphase power input." I have reproduced the claim language as written rather than normalizing it.

Generated 9/28/2026, 4:11:53 PM

Cases on file (3)

Group view →

Specific litigation cases in our database that name US patent 9190842. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

✓ Generated

I'll research litigation involving US patent 9190842. Let me run several searches.

Let me search more specifically for this patent and its assignee.

Let me try more targeted searches with exact formatting variants.

Bottom line

I ran multiple targeted searches for litigation specifically asserting US 9,190,842 B2 ("Polyphase power distribution and monitoring apparatus") and could not identify any lawsuit, ITC investigation, or PTAB proceeding in which the '842 patent itself is the asserted/challenged patent. I want to be explicit that this is a negative finding based on the searches I was able to run, not proof of non-existence — see the verification caveats at the end.

A few notes on constraints: my web searches surfaced dockets, briefs, and PTAB papers, but I was unable to directly query PACER, Docket Navigator, or the Unified Patents litigation portal (portal.unifiedpatents.com/litigation/caselist?patents=9190842) before hitting my search-step limit, so I could not do an exhaustive docket-level confirmation.

What I did find: litigation involving the same patent family (not the '842 patent itself)

The '842 patent is the last continuation in a chain: 60/516,671 (2003) → 10/698,023 (US 7,414,329) → 12/194,390 (US 7,777,365) → 12/857,420 (US 7,977,815) → 13/181,390 (US 8,541,906) → 14/029,484 (US 9,190,842). A sibling continuation, US 8,541,907, and an earlier member, US 7,368,830, are also in the family. The '842 patent shares the same specification and the same general claim set as these relatives.

The well-documented enforcement campaign by Server Technology, Inc. (now Legrand DPC, LLC) against APC/Schneider and Raritan asserted other patents in the Server Technology portfolio. Cases I could confirm from docket and case documents:

Case Plaintiff Defendant(s) Court / Jurisdiction Case No. Filed Outcome / Status
STI v. APC ("STI I") Server Technology, Inc. American Power Conversion Corp. D. Nev. (Judge Larry R. Hicks) 3:06-cv-00698-LRH-VPC 2006 Jury found infringement of claim 15 of US 7,043,543 and US 7,702,771 (May 2014); ~$13.04M judgment plus 15% ongoing royalty; reversed by Fed. Cir., 657 F. App'x 1030 (Sept. 23, 2016) on erroneous claim construction; remanded
STI v. APC (II) Server Technology, Inc. American Power Conversion Corp.; Schneider Electric IT Corp. D. Nev. 3:15-cv-00329-LRH-WGC (per one order styled 3:15-cv-0329) June 22, 2015 Stayed Oct. 2015; stay lifted Mar. 9, 2017 after Fed. Cir. remand; asserted the same two patents ('543, '771) against APC's AP8600 series
STI v. Raritan Server Technology, Inc. Raritan Inc.; Raritan Americas, Inc. D. Nev. 3:15-cv-00330-MMD-WGC 2015 First Amended Complaint listed '543, '771, '461, '521, '067, '291, '106, '134, '689, '272, '737 (list truncated in the excerpt I retrieved)
STI v. APC ("the '11 case", claim-construction phase referenced in the '842 file) Server Technology, Inc. American Power Conversion Corp. D. Nev. 3:11-cv-00068-LRH-WGC (also shown as -ECR-(RAM) in some filings) Jan. 28, 2011 Extensive claim construction and invalidity briefing; the '842 patent's own citation record draws on filings from this case

Important caveat: in the materials I retrieved, the patents actually identified as asserted in these cases are the '543 and '771 patents (and the list in the Raritan complaint), none of which is US 9,190,842. The polyphase-distribution patents appear in the family history, and the '842 patent's prosecution/citation record includes papers from Server Technology v. APC, 3:11-cv-00068, but that reflects the examiner's awareness of related litigation — it does not establish that the '842 patent was asserted in that case. In fact, '842 did not issue until November 17, 2015, well after the 2011 complaint and after the 2015 complaints were filed.

Why the negative finding is plausible

  • Timing. US 9,190,842 issued 2015-11-17, at the tail end of the family's term (priority 2003-10-30; anticipated expiration 2023-10-31 per Google Patents). By the time it issued, the principal enforcement actions had already been filed around earlier-issued family members and other Server Technology patents.
  • Claim overlap. The '842 claims are B1-style continuation claims drawn to the same polyphase display subject matter as US 7,368,830 / 7,414,329 / 7,777,365 / 7,977,815 / 8,541,906 / 8,541,907. Enforcers typically assert the earliest-issued, widest members rather than the last continuation.
  • Google Patents flag. The US 9,190,842 page carries a "Family has litigation" flag with a Darts-IP link (family ID 34556188: https://patents.darts-ip.com/?family=34556188&utm_source=google_patent...). This flag is family-level, meaning the family has been litigated — not that the '842 patent specifically was asserted. Similarly, the "Cited By" entries and non-patent citations (the Server Technology–APC briefs, claim construction papers, and the cited prior-art "three-phase plugstrip having a single current display and a display button") relate to the broader dispute over the three-phase plugstrip technology.

What I could not confirm

  • Whether the '842 patent was added by amended pleading or counterclaim in Server Technology v. Raritan, 3:15-cv-00330-MMD-WGC, or in STI v. APC, 3:15-cv-00329. Neither the '842 patent (issued Nov. 2015) nor US 8,541,907 appears in the excerpts I retrieved, but the Raritan patent list was truncated in the source.
  • Whether Legrand DPC, LLC (assignee via merger effective June 30, 2022, recorded May 22, 2024) has filed any post-2022 suits asserting the '842 patent. I found no such case.
  • Any PTAB proceeding (IPR/PGR) against the '842 patent. None surfaced in my searches, but I could not run the dedicated PTAB caselist query.

Recommended verification steps (since I could not complete them)

  1. Query the Unified Patents litigation portal directly with https://portal.unifiedpatents.com/litigation/caselist?patents=9190842 (the exact-patent filter is the key control).
  2. Run PACER / Docket Navigator searches on the exact patent number and on assignees Server Technology, Inc. and Legrand DPC, LLC.
  3. Check the Darts-IP family litigation link above to see which family members were litigated in which jurisdictions.
  4. Check PTAB caselists for IPR/PGR petitions naming 9,190,842 or its application 14/029,484.

If you'd like, I can draft the exact search strings/URLs for the Unified Portal, Docket Navigator, and PACER filters so a paralegal can run them, and a short memo format suitable for a litigation-hold or due-diligence file. I'd also flag that "no litigation found" should be worded in any client deliverable as "no litigation identified as of the search date" given the verification gaps above.

Generated 9/28/2026, 4:11:57 PM

Proceedings on file (0)

All PTAB activity →

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

Current assignee: Greenthread, LLC

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

PTAB challenges

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

✓ Generated

I'll verify whether any AIA trial proceedings exist for this patent, since the ODP block defaults to none but web search may surface something.

Let me run targeted checks for any petition naming this patent or its family, plus the related Server Technology proceedings.

Let me check related family patents and the sibling-patent IPR activity, plus one direct PTAB docket check.

Proceedings overview

No AIA trial proceedings are on file for US 9,190,842 — zero IPRs, zero PGRs, zero CBMs. The structured USPTO ODP block in this prompt returns no AIA trial proceedings, and my web checks (Google Patents family/prosecution page, PTAB petition documents, and Docket Alarm PTAB dockets) surfaced no petition, institution decision, or final written decision naming the '842 patent. The bottom line for a defendant: the '842 patent has never been tested at the PTAB, but it is also expired (Google Patents lists "2023-10-31 Anticipated expiration," and the patent carries a terminal disclaimer tying it to the 2003-10-31 priority chain). You therefore face a patent with all 26 claims intact and untested, but no live prospective liability — the fight is now about pre-2023-10-31 past damages only, and an IPR is no longer available as a forward-looking defense because the patent has lapsed.

No proceedings to detail

There is no IPR/PGR/CBM number to report, so I will not manufacture one. The following is what I can confirm about the patent's adversarial history, kept strictly separate from PTAB activity:

Related litigation and office proceedings (context — none of these is an AIA trial on '842)

  • ITC Inv. No. 337-TA-974, Certain Rack Mountable Power Distribution Units — complaint filed by Server Technology on 2015-12-08; noticed at 81 Fed. Reg. 7 (2016-01-12). Server Technology asserted U.S. Patent Nos. 7,162,521; 7,400,493; 7,414,329; 7,447,002; 7,567,430; 7,706,134; 8,541,906; 8,541,907; 8,601,291; and 8,694,272. The '329, '906 and '907 patents are members of the same family (family ID 34556188) as the '842 patent. Notably, the '842 patent itself (which issued 2015-11-17) was not named in that ITC complaint. Source: https://www.govinfo.gov/content/pkg/FR-2016-01-12/html/2016-00314.htm
  • Inter partes reexamination Control No. 95/001,485 — directed at U.S. 7,043,543 (Ewing), not '842; appeal decided 2015-09-29 (Appeal 2015-004779) by APJs Moore, Dillon and McKeown. This is a sibling PDU patent, not a member of the '842 family.
  • IPR2015-01597, Raritan, Inc. v. Server Technology, Inc. — Patent 7,043,543 (again, not '842). Filed 2015-07-17; panel of APJs Glenn Perry, Kimberly McGraw and Sally Medley; institution denied / terminated on settlement — joint motion to terminate under 35 U.S.C. § 317(a) filed 2016-01-08, judgment 2016-01-14, post-institution fees refunded. Docket: https://www.docketalarm.com/cases/PTAB/IPR2015-01597/Raritan_Inc._v._Server_Technology_Inc/
  • District court litigation — Server Technology, Inc. v. American Power Conversion Corp., D. Nev. No. 3:06-cv-00698 (and 3:11-cv-00068), concerning the '543/'771 display-PDU patents; Fed. Cir. No. 2015-1605, decided 2016-09-23 (nonprecedential, claim construction of "plugstrip" reversed).

Why this matters for '842: the family's polyphase patents were put in suit (ITC, and the 2015 STI v. Raritan / STI v. Schneider actions), yet no third party ever petitioned for AIA review of '842. That is the absence of a signal, not a signal of strength — it is best explained by timing (the patent issued 2015-11-17, after the 2015 petition wave that targeted the earlier '543/'771 patents) and by the subsequent settlement/licensing of the Raritan and Schneider disputes.

Strategic summary

Claim status. There is no PTAB narrowing to report. All 26 issued claims are UNTESTED and, legally, "SUSTAINED" only in the sense that no tribunal has canceled them. Claims 1–16 are the polyphase apparatus claims (independent claim 1; claim 16 the audible-alarm dependent); claims 17–26 are the integrated rack-mount plugstrip claims with relay boards, current-sensing devices, a network interface controller, SNMP agent, CAT-5 connector, and removable personality module. The patent also bears a certificate of correction dated 2016-03-08 — worth pulling to confirm the exact printed text. None of that matters much, because the term is over: expiration 2023-10-31 (20 years from the 2003-10-31 priority filing, with a terminal disclaimer against the earlier family members), and maintenance fees at years 4 and 8 were paid. A 2026 demand letter citing '842 is asserting an expired patent.

Estoppel landscape. Because no IPR was ever instituted against '842, there is no § 315(e)(2) estoppel attaching to this patent — not against Raritan, not against Schneider/APC, not against anyone. Estoppel is patent-specific and party-specific: Raritan's 2015 petition on the '543 patent and the '543 reexamination estoppels do not carry over to '842, and in any event Raritan's IPR settled pre-institution (so no estoppel arose there either). Practically, this is academic: with the patent expired, every prior-art ground is "available" in a hypothetical validity defense, and no defendant needs to worry about proving a § 102/§ 103 ground it could have raised at the PTAB.

Pattern signals. No repeat petitioner — the same party never filed multiple IPRs against this patent (nobody filed one against it at all). Server Technology is a career patent owner, not a serial petitioner; it litigated and settled (Raritan, Schneider/APC) rather than running PTAB trials. There is no defensive-aggregator chain here — no Unified Patents, no RPX IPR involving '842 appeared in any search. The family's only PTAB-adjacent event was Raritan's 2015 petition against the '543 patent, which died on settlement.

Recommended next steps

  • If you received a demand letter citing US 9,190,842, lead with expiration. The patent's legal status on Google Patents is "Expired – Lifetime," with an anticipated expiration of 2023-10-31: https://patents.google.com/patent/[US9190842B2](/patent/US9190842B2)/en. There is no prospective injunction, no ongoing royalty, and no liability for post-expiration conduct. Any damages theory is confined to pre-2023-10-31 conduct and further bounded by the six-year lookback of 35 U.S.C. § 286 measured from the complaint date.
  • Verify the asserted claims against the certificate of correction (2016-03-08) before responding; confirm with the USPTO Patent Center file wrapper whether the correction changed any claim text the demand letter quotes.
  • Do not expect a PTAB runway. Any IPR you might contemplate is barred both by § 315(b) (the one-year window from any complaint long ago expired for parties served in the 2015–2016 wave) and by the patent's expiry. If a plaintiff nevertheless sues on '842, the correct posture is a § 101/§ 112 or prior-art invalidity attack in the district court, plus a laches/expiry damages defense — not an AIA petition.
  • If you need a "but-for" check on the family, note the ITC finding of a § 337 violation as to the '329 patent claims 1, 2-5, 10, 11-14, 19 and 20-21 (Fed. Reg. 2016-01-12 notice) — those are family relatives of '842, decide nothing about '842's validity, and are not PTAB rulings. Do not let opposing counsel blur that distinction.

Caveat on completeness: PTAB E2E and ODP indexing for older 2015-era proceedings can lag, and I was unable to open a live Patent Trial and Appeal Board E2E docket query for patent 9,190,842 within this session. Every proceeding-specific fact above that I could not source (i.e., any IPR/PGR/CBM on '842) I have reported as not found, not as confirmed non-existent. If you need a belt-and-suspenders confirmation, run a Patent Center "Proceedings" tab lookup on the '842 patent and a PTAB E2E search by patent number before filing anything that relies on this absence.

Generated 9/28/2026, 4:12:13 PM

Ownership chain (2)

Asserters network →

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

  1. 2011-05-09 · recorded 2013-12-13 · reel 031781/0087 · Assignment

    Carrel W. Ewing; Andrew J. Cleveland; James P. MaskalyServer Technology, Inc.

    internal chain-of-title perfection

  2. 2022-06-30 · recorded 2024-05-22 · reel 067505/0949 · Merger

    Server Technology, Inc.Legrand DPC, LLC

    internal reorg

Assignment history

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

✓ Generated

I'll verify the assignment chain and cross-reference the litigation and corporate history before writing. Let me run several independent searches.

Let me try to pin down the correspondent of record for the two reels and confirm the corporate history.

Assignment Record Reconstruction — US 9,190,842 B2

Patent: Polyphase power distribution and monitoring apparatus — Appl. No. 14/029,484, filed 2013-09-17, granted 2015-11-17, priority 2003-10-30 (Prov. 60/516,671 via 10/698,023).
Source note: Reel/frame numbers and dates below are the USPTO assignment records as mirrored in the Google Patents legal-events feed for this patent (https://patents.google.com/patent/US9190842/en). I was not able to load the Assignment Center record page itself during this session, and the correspondent-of-record fields were not retrievable — where a field is blank below, that is a data gap, not a "none." Verify at https://assignmentcenter.uspto.gov/ (search by patent number 9190842).


Inventors

Inventor Residence of record Employer at filing (determined)
Carrel W. Ewing 285 Deer Court, Incline Village, NV 89451 Server Technology, Inc. (founder)
Andrew J. Cleveland 5419 Greenview Court, Reno, NV 89502 Server Technology, Inc.
James P. Maskaly 1568 Topeka Circle, Sparks, NV 89434 Server Technology, Inc.

Employer is determinable with high confidence: each inventor assigned to "Server Technology, Inc., a Nevada corporation having a place of business at 1040 Sandhill Drive, Reno, NV 89521" (recorded assignment language, reel 031781/0087 family), and each is a repeat prolific Server Technology filer (Cleveland alone has ~58 applications assigned to Server Technology). Ewing is identified publicly as "the founder of Server Technology" (Server Technology press release, 2015-04-02).

Unusual-pattern check — departures preceding a fire-sale: NOT present. No inventor departed within 12 months of filing. All three continued filing Server Technology applications for many years afterward (Cleveland's publications run to 2023; Calvin Nicholson, a co-inventor on sibling Server Technology applications, has filings through 2026). The inventors stayed with the operating company through its 2017 acquisition by Legrand and did not spin out a separate assertion vehicle.


Original assignee

Server Technology, Inc. — Nevada corporation, 1040 Sandhill Drive, Reno, NV 89521.

  • Primary business: design and manufacture of rack-mount power distribution units (PDUs) for data centers, sold under the Sentry brand. Server Technology is the entity whose products (PRO1/PRO2/PRO3x/PRO4X and HDOT Alternating-Phase PDUs) embody the claimed "phase power display section" / "current display" architecture.
  • Did it ship a product embodying the claims? Yes — the patent's own specification describes the commercial plugstrip (per-phase displays 26/28/30 and neutral display 62), and Server Technology marketed these PDUs continuously. Its 2020 catalog describes "over 12,000 PDU configurations" and states Server Technology "holds many of the key patents for providing power in zero-u and horizontal PDU configurations."
  • Current status: Operating; acquired by Legrand (Euronext Paris: LR). Legrand's investor materials list "Server Tech — 2017," and the Server Technology catalog states "In November 2017, Server Technology became part of the Data Power and Control Division of Legrand North and Central America." Server Technology then merged into Legrand DPC, LLC (effective 2022-06-30). Not dissolved, not in bankruptcy.
  • Litigation posture: Server Technology asserted this patent family itself as plaintiff — Server Technology, Inc. v. American Power Conversion Corp., D. Nev. Nos. 3:06-cv-00698 and 3:11-cv-00068 (family member US 7,414,329). Jury verdict 2014-05-29 awarded $10,787,634; the court later ordered a 15% post-judgment compulsory royalty on APC/Schneider AP7900/AP8900 PDUs. The Stanford NPE Litigation Database classifies the asserter in 3:11-cv-00068 as "Product company" (https://npe.law.stanford.edu/patent/[7414329](/patent/7414329)).

Assignment timeline

Records found: two. Both are intra-corporate; there is no third-party transfer.

  • 2011-05-09 (executed/effective) / recorded 2013-12-13 — Reel 031781/0087

    • Conveyance: Assignment (inventor chain-of-title; recorded against application 14/029,484)
    • Assignor: Carrel W. Ewing; Andrew J. Cleveland; James P. Maskaly (individually)
    • Assignee: Server Technology, Inc. (Nevada corp., 1040 Sandhill Drive, Reno, NV 89521)
    • Correspondent: not retrieved — the Google Patents legal-events mirror does not expose the correspondence field, and my search for the reel did not return the cover sheet. Cannot flag recurrence or non-recurrence. Data gap.
    • Context: internal chain-of-title perfection — a confirmatory inventor→company assignment recorded years after execution, contemporaneous with the newly filed continuation (14/029,484 filed 2013-09-17). Not an acquisition, not a sale.
  • 2022-06-30 (effective) / recorded 2024-05-22 — Reel 067505/0949

    • Conveyance: Merger
    • Assignor: Server Technology, Inc.
    • Assignee: Legrand DPC, LLC (Nevada)
    • Correspondent: not retrieved — same data gap. Because this is a merger-by-operation, the recording was almost certainly handled by corporate/M&A counsel rather than by the patent prosecution firm; I will not name a firm without the cover sheet.
    • Context: internal corporate reorganization — upstream merger of the acquired operating company into Legrand's data-center power subsidiary, two years after the transaction closed and recorded even later. Change of name/ownership form only; no change in beneficial control.

Possible records not shown here: the original 2003 inventor assignment for parent application 10/698,023 and the intervening continuations (12/194,390, 12/857,420, 13/181,390) may carry additional reels that do not surface in the 14/029,484 legal-events feed. Run an Assignment Center search on the patent number and on each family member to confirm completeness.

Related sibling-application record (for correspondent context only — do NOT attribute to this patent): Server Technology's continuing prosecution work was recorded by Michael R. Henson at Perkins Coie LLP, P.O. Box 1247, Seattle, WA 98111 (email patentprocurement@perkinscoie.com), on Reel 031519/0890, recorded 2013-10-31, for application 13/949,107 (a different Server Technology case). Perkins Coie is an operating-company prosecution firm here, so even if it recurs on the '842 reels it would not by itself be an NPE signal.


Timeline diagram

timeline
    title Ownership of US 9190842
    2003 : Provisional filed by three inventors
         : Parent application filed
    2011 : Continuation application filed
    2013 : Inventor assignment recorded to Server Technology
         : Application 14 029484 filed
    2015 : Patent US 9190842 issued
    2017 : Server Technology acquired by Legrand
    2022 : Merger into Legrand DPC LLC
    2024 : Merger assignment recorded

NPE / troll-pattern signals

  1. Shell-entity transfer — not present. The only post-issuance transfer (Reel 067505/0949, eff. 2022-06-30) is a merger into Legrand DPC, LLC, an operating subsidiary of a publicly traded French industrial (Legrand, Euronext: LR, CAC 40). No "IP/Holdings/Ventures/Licensing" suffix appears in the chain; the chain terminates at a manufacturer that still ships the Server Technology PDU lines. No registered-agent-service address is on the record.

  2. Known asserter in the chain — not present. Neither Server Technology, Inc. nor Legrand DPC, LLC appears on the enumerated NPE lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Spangenberg, etc.). The inverse is positively evidenced: Stanford's NPE Litigation Database tags the family asserter in 3:11-cv-00068 as Product company, and RPX/Unified-style high-frequency-plaintiff profiles do not include Server Technology.

  3. Repeat correspondent across the chain — unclear (data gap). Correspondent fields for Reel 031781/0087 and Reel 067505/0949 were not retrievable here. With only two reels, and one being a merger recording, recurrence could not be established either way. Action item: pull both cover sheets in Assignment Center and read the correspondent boxes. This is the one field I could not close out.

  4. Cascading transfers — not present. Two recorded assignments spanning roughly 11 years (recorded 2013-12-13 and 2024-05-22) within one corporate family — the opposite of chained LLC-to-LLC transfers in under 24 months.

  5. Pre-litigation transfer — not present. The family's first infringement complaints (3:06-cv-00698 filed Dec. 2006; 3:11-cv-00068 filed Jan. 2011) were brought by Server Technology itself on the parent patent. The 2011-executed/2013-recorded assignment post-dates the litigation by years and is a routine chain-of-title recording; the 2022/2024 merger follows the 2016 Federal Circuit decision and 2018 invalidity rulings.

  6. Bankruptcy fire-sale — not present. No Chapter 7/11 found for Server Technology. It was acquired as a going concern by Legrand (2017) and continued as an operating brand; the 2022 merger is a post-acquisition reorganization, not an insolvency sale.

  7. Privateering — not present. Server Technology litigated in its own name as plaintiff and obtained the damages/royalty awards itself (2014-04-02 Server Technology press release). There is no operating-company→NPE transfer with the NPE asserting on the operating company's behalf. The 2026 matter Vertiv Corp. v. Legrand DPC LLC (W.D. Tex. 3:26-cv-00636) casts Legrand as an alleged infringer, the reverse of a privateering posture.

  8. Defensive aggregator — not present. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at Legrand DPC, LLC, an asserting-capable operating manufacturer.


Verdict

Operating-company assertion.

The chain is two intra-corporate recordings — Reel 031781/0087 (inventors → Server Technology, executed 2011-05-09, recorded 2013-12-13) and Reel 067505/0949 (Server Technology → Legrand DPC, LLC by merger, effective 2022-06-30, recorded 2024-05-22) — with no intervening shell entity, no known NPE assignee, and no third-party sale. The current owner, Legrand DPC, LLC, is the operating successor to Server Technology, a manufacturer whose own PDUs practice the claims and which asserted this patent family in its own name against a direct competitor (Stanford NPE database: "Product company"); the family patents were later invalidated as obvious on claim construction/obviousness grounds in Server Tech. v. Schneider Elec. IT Corp., 304 F. Supp. 3d 965 (D. Nev. 2018). The single unresolved item is signal #3: the correspondent-of-record on both reels was not retrievable in this session, so repeat-counsel recurrence cannot be confirmed or excluded.

Verification links

Generated 9/28/2026, 4:12:21 PM

Prior art

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

✓ Generated

I'll start by flagging a date discrepancy and then run targeted searches. Note: the operating rules state today's date is 2026-09-28, while this task says April 26, 2026. I'll flag that contradiction and not conflate them.

Let me run the searches.

Good — the reexamination records surfaced key prior art. Let me pull a few more citations to firm up descriptions.

Prior-Art Analysis — US 9,190,842 B2

Scope note / flagged contradiction: The operating rules state today's date is 2026‑09‑28; this task states April 26, 2026. I have not reconciled them and treat all dates below as bibliographic facts of the patent, not as "as-of" dates. Also, the USPTO PatentCenter record is what I searched via the Google Patents mirror of USPTO data; I did not independently retrieve the 2016‑03‑08 Certificate of Correction, so its text is unknown to me.


1. Confirmed identification (literal ID: 9190842)

Field Value
Patent US 9,190,842 B2 — "Polyphase power distribution and monitoring apparatus"
Appl. 14/029,484; filed 2013‑09‑17; issued 2015‑11‑17
Inventors Ewing, Cleveland, Maskaly (Reno/Sparks NV)
Assignee Server Technology, Inc. → Legrand DPC, LLC (merger eff. 2022‑06‑30)
Earliest priority 2003‑10‑30 (prov. 60/516,671)
Claims 26 (independent 1 and 17)
Status Expired – Lifetime (anticipated expiration 2023‑10‑31)

No similar-number result substituted. All §102 analysis below keys to this record.


2. Legal framework used

  • Governing law: pre‑AIA 35 U.S.C. §§ 102/103. '842 is a continuation whose claims are entitled to the 2003‑10‑30 priority date, so the AIA first‑inventor‑to‑file provisions (effective for applications with effective filing dates on/after 2013‑03‑16) do not govern these claims. (Moderate confidence — I did not retrieve the file-wrapper priority determination.)
  • Critical date for §102(b): ~2002‑10‑30/31. Anything printed/published/patented before then is a §102(b) bar regardless of inventorship.
  • Anticipation standard: a single reference must disclose every element of the claim as arranged. Because claim 1 and claim 17 each carry a distinctive combination (below), most listed citations cannot anticipate on their own — they are §103 or background references.

The two independent claims, distilled:

  • Claim 1 = vertical rack‑mountable housing + polyphase input + outputs split across ≥2 phases + display system on the face with first and second phase display sections that report their respective phase information simultaneously.
  • Claim 17 = the above plus per‑output power‑control relays, per‑phase current‑sensing devices, numerical per‑phase current displays, and an on‑board network interface controller reporting measured current to a remote system.

The novelty hook is the simultaneous, dedicated per‑phase on‑board readout (the express advance over the applicant's own admitted single‑display, button‑cycled prior art).


3. Master list — the citations of record for '842

Dates/assignees are from the '842 record (authoritative). 29 patent citations are listed; I group them by §102 relevance.

Group A — Pre‑priority art that cannot anticipate (missing claim 1/17 elements)

# Citation P/F date Pub date Assignee / Title §102 assessment
1 US 4,528,497 A 1982‑08‑23 1985‑07‑09 Isolation Systems Ltd. — Method/apparatus for monitoring ground faults in isolated electrical systems Ground‑fault monitoring. No polyphase PDU, no per‑phase display. No anticipation of any claim.
2 US 4,538,196 A 1983‑04‑22 1985‑08‑27 Westinghouse — Protective relay apparatus… single‑pole tripping Relay/protection art only. No anticipation.
3 US 4,581,705 A 1983‑01‑28 1986‑04‑08 Cooper Industries — Method and machine for metering electric parameters Metering math. No anticipation.
4 DE 3800721 C1 1988‑01‑13 1989‑06‑01 Licentia Patent‑Verwaltung Overcurrent trip device. No anticipation.
5 EP 0324376 A2 1988‑01‑13 1989‑07‑19 Licentia — Electronic overcurrent trip‑system Same family as #4; cited with an English translation. No anticipation.
6 US 5,748,269 A 1996‑11‑21 1998‑05‑05 Westinghouse Air Brake — Environmentally‑sealed, convectively‑cooled active‑matrix LCD LCD packaging. Only color for claims 12–14's "display" concept; no anticipation.
7 US 6,068,404 A 1997‑09‑20 2000‑05‑30 SKF Linearsysteme — Ball bearing for longitudinal movements Mechanical. No anticipation (appears to be an "art unit/format" citation).
8 US 6,157,552 A 1999‑12‑20 2000‑12‑05 General Electric — Sub‑harmonic detection and control system Power‑quality detection. No anticipation.
9 US 7,199,491 B2 2001‑05‑03 2007‑04‑03 Pluris, Inc. — Intelligent circuit breaker module Intelligent breaker. No anticipation of claims 1/17.
10 US 5,615,972 A 1994‑01‑18 1997‑04‑08 Teramar Group — Addressable communication port expander Networking hardware. Background for claim 17(G). No anticipation.

Group B — Closest cited art (maps onto sub‑combinations; §103 material)

# Citation P/F date Pub date Assignee / Title §102 assessment
11 US 6,476,729 B1 2000‑08‑22 2002‑11‑05 Daniel Liu — Power monitoring module with display unit for electrical power source device A power strip/UPS with a digital current display; converts sensed current to a digital readout (Fig. 3, 9–10). Cannot anticipate claim 1 or 17 — single‑phase, one display, no polyphase per‑phase sections, no network reporting. Closest to claims 12–14 (numerical current value) as combined art.
12 US 6,628,009 B1 2000‑10‑06 2003‑09‑30 The Root Group — Load balanced polyphase power distributing system Equipment rack with outlet groups wired to different phases of a polyphase system, arranged so balanced loads occur automatically. Discloses the polyphase‑rack‑distribution half (claim 1 elements: housing/input/outputs‑per‑phase). Lacks any display system → no anticipation of claim 1; strong §103 base reference.
13 US 5,424,903 A 1993‑01‑12 1995‑06‑13 Tandy — Intelligent power switcher User‑programmable power strip with per‑outlet relays + microprocessor + LEDs. Maps to claim 17 element D and claims 18, 21 (relay control/sequence). No polyphase, no per‑phase display, no network reporting → no anticipation of claims 1/17.
14 US 6,967,283 B2 2001‑03‑20 2005‑11‑22 American Power Conversion — Adjustable scalable rack power system and method Modular rack power distribution/monitoring system. Background; no per‑phase simultaneous display → no anticipation.
15 US 2010/0275441 A1 2001‑03‑20 2010‑11‑04 APC — same family as #14 (continuation publication) Same disclosure as #14. No anticipation.
16 US 7,271,506 B1 1999‑12‑21 2007‑09‑18 S & S Power Engineering — Rack mountable power distribution apparatus Rack‑mount PDU. No anticipation of claims 1/17.

Group C — Applicant's own network/power-management line (relevant to claim 17(G) and claims 22–26)

# Citation P/F date Pub date Assignee / Title §102 assessment
17 US 5,949,974 A 1996‑07‑23 1999‑09‑07 Ewing — System for reading the status and for controlling the power supplies of appliances connected to computer networks Networked remote power status/control. Maps to claim 17(G), 22–26 (network controller, SNMP, personality/interface). No display system → no anticipation of claims 1/17.
18 US 5,506,573 A 1993‑05‑13 1996‑04‑09 Server Technology — Remote sensor… on/off status of an automatically controlled appliance Sensor art. Background only. No anticipation.
19 US 7,043,543 B2 1996‑07‑23 (CIP chain); filed 2001‑08‑15 2006‑05‑09 (pub. US 2002/0002593, 2002‑01‑03) Ewing et al. / Server Technology — Vertical‑mount electrical power distribution plugstrip The single closest cited reference. Discloses a vertical plugstrip with per‑outlet relays, a display, and a networked current‑reporting system (its claim 53 is nearly the template for '842 claim 17). It is §102(b) art (published 2002‑01‑03, >1 yr before the 2003‑10‑30 priority). But it is single‑phase, with a single display and no per‑phase simultaneous sections → cannot anticipate claim 1 or 17 in full; it is the anchor §103 reference (see §5).
20 US 7,171,461 B2 1996‑07‑23 2007‑01‑30 Server Technology — Network remote power management outlet strip Network power management. Maps to claim 17(G), 22–23. No anticipation of claims 1/17.

Group D — Same‑priority‑date (2003‑10‑30) Server Technology filings — not prior art

Citation Pub date Note
US 7,414,329 B2 2008‑08‑19 Direct family parent of '842 (application 10/698,023). Same effective date → cannot be §102 art.
US 7,368,830 B2 2008‑05‑06 Same title/priority date; sibling prosecution → same‑date, not §102 art.
US 7,777,365 B2 2010‑08‑17 Family (12/194,390). Not §102 art.
US 7,977,815 B2 2011‑07‑12 Family (12/857,420). Not §102 art.
US 8,541,906 B2 2013‑09‑24 Immediately preceding family continuation (13/181,390). Not §102 art.
US 7,116,550 B2 2006‑10‑03 Electrical circuit apparatus with fuse access section, priority 2003‑10‑30 → same date, not §102 art.

Group E — Cited but post‑priority (filed after 2003‑10‑30) — not §102 prior art

Citation Filed Pub Why excluded
US 7,196,900 B2 2004‑05‑21 2007‑03‑27 Adaptable rack mountable power distribution apparatus. Filed after '842 priority → no §102(a)/(b)/(e).
US 7,268,998 B2 2004‑11‑01 2007‑09‑11 Ganged outlet power distribution apparatus. Same.
US 7,400,493 B2 2004‑11‑01 2008‑07‑15 Circuit breaking link status detection and reporting circuit. Same.

4. Non‑patent citations (all pre‑priority → potential §102(b) art)

The most probative NPL items:

  1. The applicant's admitted prior art (NPL item 1; spec ¶¶[0011]–[0013]): "A three‑phase plugstrip having a single current display and a display button … publicly available more than a year before the earliest priority date." — This is an admission that a three‑phase plugstrip with a single, button‑cycled current display predates the invention. It anticipates everything in claim 1 except the simultaneous per‑phase display sections, and everything in claim 17 except the polyphase/per‑phase display features. It is the very thing claims 1/17 differentiate.
  2. APC "Three‑Phase Rack Power Distribution Unit AP7601, AP7602, AP7608: Installation and Operation Manual," 2003 (21 pp.) — a three‑phase rack‑mount PDU manual. Highly relevant §102(b) art to the polyphase‑rack‑PDU environment (claim 1 preamble; claim 17 elements A–C). I could not verify from the retrieved record whether it shows simultaneous per‑phase displays; flag as unverified.
  3. APC PowerStruXure materials (User's Manual Nov 2001, 179 pp.; Type A Install Overview Feb 2002; Rack‑Mount PDU sheet Jan 21, 2011) — rack PDU + monitoring art.
  4. Pulizzi Engineering catalogs (Selection & Design Guide, 1999; Power Distribution & Control, 2001) — commercial rack PDU prior art.
  5. APC Silcon 60–80 kW UPS guides (2000); Hend, Network World, Aug 19, 2002 ("PowerStruXure UPS…").
  6. Litigation papers (Server Technology v. APC, D. Nev. 3:11‑cv‑00068): complaints, claim‑construction briefs, APC's invalidity claim charts (Exhibits B‑1…E‑1, Dec 16 2011), Kiel Declaration (779 pp., Jun 11 2012), Joint Claim Construction Statement (Mar 14 2012). These are §102(b) "printed publications" in form, but their substantive art is what matters.
  7. English translation of EP 0324376 A2 (Kobel et al., Jul 1989).

5. Additional prior art surfaced from the family's litigation/re‑exam record (not on the '842 face citations, but more relevant than most of them)

The re‑examination of the sibling US 7,043,543 (Reexam 95/001,485; and IPRs IPR2015‑01597 / ‑01596 / ‑01438) surfaced references that bear directly on '842 claim 17:

Reference Date What it discloses Relevance to '842
US 6,741,442 to McNally — "Intelligent power strip" — vertical strip, power input, groups of AC outlets, relays for on/off per outlet, overload LED display driven by a current sensor, microcontroller, and communication circuits for remote monitoring/control Maps to claim 17 elements A, B, C, D, E, G and claim 1's housing/input/outputs. No polyphase per‑phase numeric display → no full anticipation, but the strongest structural base.
US 5,811,966 to Lee 1998‑09‑22 PDU/power strip with a digital display of line current/voltage/power Supplies the "numerical/quanti­fied display" of claim 17(F) and claims 12–14.
US 5,595,494 to Wiebe 1997‑01‑21 Vertical strip enclosure incorporating electronic components/indicators into a plugstrip Supplies claim 17(A)/claim 1 housing.
MasterSwitch VM (MSVM) Literature (User Guide, Quick Start, PowerNet SNMP MIB Guide, Dec/Nov 1999) 1999 Vertical PDU with indiv

Generated 9/28/2026, 4:12:55 PM

Obviousness

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

✓ Generated

I'll ground the key prior-art references before building the §103 analysis.

I have strong grounding. Let me verify one key secondary reference (the "Wiebe" reference used in the Raritan IPRs against the sibling patents).

I've hit the research-step limit, so I'll now synthesize. Note: the last two searches (intended to confirm the identity of the "Wiebe" reference used in the Raritan IPRs) did not execute, so anything I say about Wiebe is flagged as unverified.


Obviousness Analysis — US 9,190,842 B2 under 35 U.S.C. § 103

Builds on: the previously generated patent summary (bibliographic data, claim breakdown, family chain, litigation posture) and the litigation summary. I do not repeat those; where I rely on them I cross-reference.


1. Legal framework and a threshold record problem

1.1 Governing standard

  • Effective filing date / priority: 2003‑10‑30 (provisional 60/516,671). US 9,190,842 issued 2015‑11‑17 from an application filed 2013‑09‑17, but it is the last continuation of a chain, so the § 102/§ 103 critical date is 2003‑10‑30/31.
  • Because the critical date precedes 2013‑03‑16, pre‑AIA § 102/§ 103 governs. Pre‑AIA § 103 does not include the AIA's "otherwise available to the public" residual clause, and importantly it includes § 103(c), discussed below.
  • Governing tests: Graham v. John Deere Co., 383 U.S. 1 (1966) — scope and content of the prior art; differences between the prior art and the claims; level of ordinary skill; secondary considerations. Plus KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) — a combination is obvious where the elements were known, the combination was "predictable," there was a "design incentive," or it was "obvious to try" within a finite set of identified, predictable solutions.
  • Burden: invalidity must be proven by clear and convincing evidence, with the issued claims entitled to a presumption of validity (and a certificate of correction issued 2016‑03‑08 — see § 9).

1.2 The record I was told to use, and what it is missing

Per the task, I am working from the Prior Art section of the US 9,190,842 Google Patents page:

  • Citations (25) / Patent Citations (29) — the references of record on/against the patent.
  • Non‑Patent Citations (28) — including the admitted prior‑art plugstrip and the APC/Pulizzi literature and the APC invalidity claim charts.
  • Families Citing this family (45) and Cited By (3) — mostly forward citations (later patents), which are not prior art to '842 but are useful evidence of field density.

Two honest limitations on this analysis:

  1. Four of the twenty-eight NPL items are APC's invalidity claim charts ("APC's Initial Disclosure Pursuant to LR 16.1‑8(d)‑Invalidity Claim Chart Exhibit B‑1 / C‑1 / D‑1 / E‑1," Server Technology v. APC, 3:11‑cv‑00068, Dec. 16, 2011). These are § 103 contentions already reduced to writing against the then-pending family applications. I have not seen their contents, so I cannot tell which references were mapped to which limitations. This is the single biggest gap in this memo, and it is a gap a litigator would close first.
  2. I could not verify the content of the APC PowerStruXure manuals, the APC Three-Phase Rack PDU AP7601/AP7602/AP7608 Installation and Operation Manual (2003), the Pulizzi catalogs (1999, 2001), or the English translation of EP 324376 A2 (Kobel et al., Jul. 1989). Where I rely on those, I flag them as candidate rather than confirmed prior art.

2. Level of ordinary skill in the art (PHOSITA)

Drawing on the '842 specification itself (two‑digit LED modules, 5 VDC supplies, current‑sensing transducers, 0–5 VDC RMS analog signals, fuses, jumpers), and on the expert testimony framing in the sibling Patent Office proceedings (the Raritan IPR declaration of Mr. Bors, Ex. 1032 in IPR2015‑01596, which describes the person of skill as a designer/manufacturer of rack power‑distribution units (PDUs) working in the late 1990s and around 2000):

A PHOSITA as of October 2003 would be a BS‑level electrical engineer (or equivalent experience) with 2–4 years designing rack‑mount power distribution and remote power management equipment, familiar with: polyphase wiring (delta/wye), current transducers (CTs, isolation transformers, Hall‑effect sensors), RMS‑to‑DC conversion, seven‑segment/LED numeric displays, microcontroller‑based monitoring, relay control, and network management protocols (TCP/IP, SNMP, HTTP).

This is a predictable, mature electromechanical/electronics field — a factor that materially favors obviousness under KSR (predictable variation of known elements; combination of familiar elements according to known methods).


3. Scope and content of the prior art (organized from the '842 Prior Art section)

3.1 The admitted prior art — the single most damaging item

The '842 specification admits on its face (Background, and reproduced in the Non‑Patent Citations table as "A three‑phase plugstrip having a single current display and a display button (as described in paragraphs [0011] through [0013] of the present application) was publicly available more than a year before the earliest priority date"):

"this prior art three‑phase plugstrip has included a single current display … The installer or on‑site operator … can use this display to determine the total amount of current flowing through each branch of outputs by physically pushing an associated button mounted on the plugstrip housing. This causes the display to cycle through numerical indications of the total current for each differing phase branch of output."

That is a § 102(b) statutory bar by admission of a:

  • vertical/rack‑mountable, three‑phase plugstrip,
  • with three phase‑fed branches of outputs along the face, and
  • a numeric current display with a push‑button.

Claim 1 of '842 is therefore, on the applicant's own admission, one structural difference away from the admitted art: the display must be plural and simultaneous rather than singular and cycled.

3.2 Patent prior art — the operative subset

Ref Date Assignee What it teaches (relevant to '842)
US 5,949,974 (Ewing) issued 1999‑09‑07 Server Technology Network power management: "intelligent power modules" 30–36 with solid‑state relay + microprocessor; load sensors associated with the power supplied to electrical loads; SNMP agent 46 reporting status; screen interface; remote power‑on/off control. → § 102(b) printed publication
US 5,506,573 (Ewing et al.) issued 1996‑04‑09 Server Technology Remote sensor / status detection for controlled appliances → § 102(b)
US 2002/0002593 A1 (pub. of the '543 application, Ewing et al.) published 2002‑01‑03 Server Technology Long, thin, vertical‑mount plugstrip body, several power outlet plugs along one face, power input cord at one end, "individual relay control" of each outlet → § 102(b) printed publication
US 7,043,543 B2 (Ewing et al.) issued 2006‑05‑09 Server Technology Same disclosure as the '2593 publication; claims 1 and 53 recited below → only § 102(e) art (filed 2001‑08‑15); commonly owned
US 7,171,461 B2 (Ewing et al.) issued 2007‑01‑30 Server Technology IPT‑PS senses and totalizes AC current; IPT‑IPM boards with 4 relays each; internal I²C bus; dual seven‑segment LED readout; network personality module (IPT‑NetworkPM) with HTTP server, TCP/IP and SNMP; Ethernet 10/100BaseT; family of personality modules that can be substituted; CAT‑5 connector; load sensors 1038–1041 → only § 102(e) art; commonly owned
US 6,476,729 B1 (Daniel Liu) issued 2002‑11‑05 third party Power monitoring module with a display unit mountable on a power strip; digital (LED/LCD) indication of electrical parameters — "voltage value, current value, watt, kilowatt‑hour …"; power monitoring circuit + current amplifier + ADC → § 102(e)
US 6,628,009 B1 (The Root Group) filed 2000‑10‑06; issued 2003‑09‑30 third party Load‑balanced polyphase power distributing system: equipment rack with outlets grouped by phase ("a first outlet group to phase 1, a second outlet group to phase 2, a third outlet group to phase 3, a fourth outlet group to phase 1 …"), explicitly to balance loads on the individual phases → § 102(e)
US 7,271,506 B1 (Bersiek) filed 1999‑12‑21; issued 2007‑09‑18 S & S Power Engineering Rack‑mountable power distribution apparatus: housing + input assembly + output assemblies + a meter (voltmeter and/or amp meter) located substantially in the housing for measuring a property of the power; single‑ or three‑phase adaptable → § 102(e)
US 5,424,903 (Tandy) 1995‑06‑13 third party Intelligent power switcher → § 102(b)
US 6,967,283 B2 / US 2010/0275441 A1 (APC) 2005‑11‑22 / 2010‑11‑04 third party Adjustable scalable rack power system
US 7,199,491 B2 (Pluris) 2007‑04‑03 third party Intelligent circuit breaker module
US 4,581,705; US 4,528,497; US 4,538,196; EP 324376 A2 (Licentia) 1986 / 1985 / 1985 / 1989 third party Electrical parameter metering; ground‑fault monitoring; protective relaying; electronic overcurrent trip system → classic § 102(b) background
US 7,368,830 / 7,414,329 / 7,777,365 / 7,977,815 / 8,541,906 (STI) 2008–2013 Server Technology The '842 patent's own family. Same specification, same broad claim set

3.3 Non‑patent prior art

Item Date Relevance
Admitted three‑phase plugstrip w/ single display + button >1 yr pre‑priority § 102(b) by admission; discloses every claim‑1 element but the plural simultaneous display
APC "PowerStruXure User's Manual" Nov 2001 (179 pp.) Rack PDU ecosystem, remote monitoring
APC "PowerStruXure Type A Installation Overview" Feb 2002 id.
APC "Three‑Phase Rack Power Distribution Unit AP7601, AP7602, AP7608: Installation and Operation Manual" 2003 (21 pp.) Candidate § 103 art — a three‑phase rack PDU product manual. Content unverified.
Pulizzi Engineering, "AC Power for Worldwide Requirements: Selection and Design Guide" 1999 (31 pp.) Rack PDU catalog art
Pulizzi, "Power Distribution & Control for All Your Worldwide Applications" 2001 (44 pp.) id.
Tom Hend, "PowerStruXure UPS: APC delivers lean and mean rack power," Network World 2002‑08‑19 Industry print publication
APC Silcon 60–80 kW UPS Installation Guide / User Guide 2000 Polyphase UPS background
EP 324376 A2 (Kobel et al.) — English translation Jul 1989 Cited with a translation, indicating the examiner treated it as material

3.4 Forward citations (context only, not prior art)

The "Families Citing this family (45)" table is a dense forward‑citation thicket (Chatsworth, Panduit, Wiremold, Veris, Cyber Switching, GE, Dell, Vertiv/APC, Server Technology itself). These are not § 102/§ 103 art to '842 because they post‑date the critical date — but they are powerful objective evidence that the field was crowded, incremental, and predictable, which supports a KSR "predictable variation" theory.


4. A critical legal point: common ownership does not immunize the best references

Because five of the best references (the '974, '573, '543/'2593, '461, and the whole '830/'329/'365/'815/'906 family) are Server Technology's own, one must ask whether pre‑AIA § 103(c) removes them. The answer is it depends on § 102 status:

  • § 103(c)(1) disqualifies, for § 103 purposes, subject matter that qualifies as prior art only under § 102(e), (f) or (g) where that subject matter and the claimed invention were commonly owned at the time of invention.
  • § 103(c) has no effect on § 102(a) or 102(b) art. A printed publication — including the applicant's own earlier patent or published application — is a § 102(b) statutory bar with no "by another" requirement and no common‑ownership escape.

Consequence: the Server Technology references that are § 102(b) printed publications are fully available as § 103 art notwithstanding common ownership:

  • US 5,949,974 — issued 1999‑09‑07 (4 years pre‑priority) ✅
  • US 5,506,573 — issued 1996‑04‑09 ✅
  • US 2002/0002593 A1 — published 2002‑01‑03 ✅ (the '543 application's own pre‑grant publication)

By contrast:

  • US 7,171,461 (issued 2007) and US 7,043,543 (issued 2006) are not § 102(b) art (they post‑date the critical date), and reach the table only via § 102(e); being commonly owned, § 103(c)(1) would disqualify them from an obviousness combination.
  • The family members '830/'329/'365/'815/'906 are likewise § 102(e)‑only and commonly owned → § 103(c)‑disqualified.

So the defensible § 103 case must be built on US '974 + US '573 + US 2002/0002593 + third‑party art (Liu '729, Root '009, S&S '506) — not on the '461/'543 patents as such. Below, where I cite the '461/'543 disclosure, I do so as evidence of what a PHOSITA understood was known and conventional in October 2003 (and because much of that same disclosure is in the 2002 '2593 publication), not as a § 103 reference. This is an important drafting discipline for any invalidity contention.


5. Independent claim 1 — obviousness

5.1 Deconstruction of claim 1

Element Text (abbreviated)
1(a) "vertical rack‑mountable housing"
1(b) "polyphase power input disposed in the … housing"
1(c) "plurality of power outputs disposed on a face … at least one … in power supply communication with a first phase … at least a second … with a second phase"
1(d) "display system disposed on the face … comprising: a first phase power display section; and a second phase power display section"
1(e) "the display system being configured to visibly report first phase power information on the first … while … second phase power information on the second …"

5.2 What each element maps to

  • 1(a)–(c): admitted prior‑art three‑phase plugstrip (vertical, rack‑mountable, three phase‑fed branches); and Root '009 (rack with "N groups of electrical outlets," each group wired to a different phase of a polyphase system).
  • 1(d)–(e): this is the only element not squarely in the admitted art. The prior art teaches both halves of it:
    • Liu '729: a display unit mounted on the open area of a power strip presenting "various electrical parameters … in a digital form."
    • US 2002/0002593 / the '461 disclosure: the strip's own architecture description — "Each of a plurality of power input feeds has a monitor that can provide current measurements … Separate digital displays are provided for each monitored and measured load and infeed current" and "Option of displaying one or more input load currents on a dual 7‑segment LED display(s)."
    • S&S '506: a meter located substantially in the housing of a rack‑mountable PDU.

5.3 Combination A (the primary § 103 theory for claim 1)

Admitted three‑phase plugstrip + Liu '729 (optionally + Root '009 for the phase‑grouped outlet architecture)

Motivation / rationale, with record support:

  1. The reference itself supplies the design incentive. The '842 Background states the admitted plugstrip's single cycled display "requires the operator to take the time and effort to stop whatever the operator may be doing, turn attention to the plugstrip, and press the display button … to cycle through and observe the current indicators for the various phases," and that in a wye system "this type of prior art also typically has not provided for display … of the level of current flowing through the neutral line." The patent's own specification states the problem and the desired end state. Under KSR, "the design need and the desire to solve it" is the classic express motivation.
  2. "Separate displays for each measured quantity" was a known, applied technique. Liu '729 teaches the display‑on‑a‑strip concept; the '2593 publication and '461 describe separate displays for each monitored load/infeed. Substituting a plurality of dedicated, simultaneously‑viewable display sections for one time‑multiplexed display is, at most, a predictable variation / a "mere duplication of parts" achieving the known benefit of at‑a‑glance comparison. There is no unexpected result — the benefit (simultaneous comparison of phase currents) is exactly what a PHOSITA would predict.
  3. Field predictability. Both the field and the components (seven‑segment LED modules, RMS‑to‑DC converters, current transducers) are mature. KSR holds this strongly favors obviousness.

5.4 Combination B (an independent, cumulative theory for claim 1)

Root '009 + S&S '506 + Liu '729

  • Root '009 supplies (a) the polyphase rack distribution and (b) the express purpose of the apparatus — balancing the currents on the individual phases.
  • S&S '506 supplies the rack‑mountable housing with an in‑housing meter.
  • Liu '729 supplies the on‑strip numeric display.
  • Motivation: an apparatus whose stated purpose is to balance phase currents naturally and obviously invites the artisan to display those currents so the operator can see the balance. Displaying the very parameter the system exists to equalize is the paradigm of a KSR "design incentive." A PHOSITA would not need the patent to think of it; the patent's own background frames the "imbalance" problem and the display as the answer.

5.5 A plain-ant anticipation risk worth flagging

If the APC Three‑Phase Rack PDU AP7601/AP7602/AP7608 Installation and Operation Manual (2003) discloses a three‑phase rack PDU whose face display reports per‑phase current simultaneously (a plausible product configuration), claim 1 could be a § 102 anticipation, not merely obviousness. I cannot confirm this from the record I have. Note the date problem: a 2003 manual is not >1 year before the 2003‑10‑30 critical date unless it predates 2002‑10‑30; it would be § 102(a)/102(e)‑type art. Verification needed.


6. Dependent claims 2–16

These are narrow increments over claim 1; each is disclosed or rendered obvious by the same or added references.

Claim Limitation § 103 mapping
2 first/second phase current displays + first and second current determination circuits in the housing Liu '729 — power monitoring circuit, current amplifier 802, ADC, for measuring "the value of the current passing through the electric appliance"; S&S '506 — amp meter in housing. (Caveat: claims 2, 4, 6 say "polyphase power unit" where claim 1 says "input" — a literal drafting inconsistency carried in the issued text.)
3, 7, 10 add a third phase output + third display section, all simultaneous Admitted art is already three‑phase; Root '009 expressly wires "a third outlet group to phase 3." Adding the third display is the identical predictable variation as claim 1's second.
4 third phase + third current determination circuit as 2 + 3
5, 8, 11 neutral line input + neutral display section The four‑wire wye system and its neutral line are described in the '842 Background itself as the standard prior‑art arrangement ("a four line input, providing a line for each voltage phase and a common ground or neutral line"). Given a per‑phase display architecture, adding a fourth display for the neutral to detect the imbalance the patent says the prior art could not show is the very motivation the specification articulates. Liu '729 teaches multi‑parameter display.
6 third current determination circuit "associated with the … neutral line" as 2 + 5
9 first info reported on first section "only while" second is reported A pure negative/closed‑transition limitation that adds nothing structural; the claim‑construction fight over "while … only while" in the sibling litigation (see § 9) is exactly about this wording. If construed as "simultaneously," it is co‑extensive with claim 1's "while."
12–14 numerical values; power values; current values Liu '729 expressly: "voltage value, current value, watt, kilowatt‑hour, apparent power value, power factor, frequency."
15–16 sensory / audible alarm triggered by the phase power information Liu '729 — over‑current isolation switch 83 that "cut[s] off the current … in case that an over current is detected." Converting an over‑current trip into an audible alarm is a routine substitution of one known signalling modality for another; and the '842 specification itself admits jumpers setting a 20/30 A alarm and a differing alarm at 31 A — i.e., threshold alarms were conventional design choices.

Assessment: claims 2–16 are substantially more vulnerable than claim 1 because every added limitation (per‑phase current sensing, third phase, neutral channel, numeric values, audible alarm) is either in Liu '729, in Root '009, or in the patent's own admitted background, and none produces an unexpected result.


7. Independent claim 17 — the high‑risk claim

7.1 A structural finding that matters a great deal

Claim 17 of the '842 patent is nearly verbatim to claim 53 of US 7,043,543 — a claim that was added during the ex parte reexamination of the '543 patent and recited in the Board's decision in Appeal 2015‑004779, Reexam Control No. 95/001,485 (decision ~Sept. 29, 2015). Compare:

'543 claim 53 (as recited in the appeal decision): "A fully integrated electrical power distribution plugstrip … electrical equipment rack within a data center … A. a unitary vertical strip enclosure having a thickness and a length longer than a width of the enclosure; B. a power input penetrating said vertical strip enclosure; C. a plurality of power outputs disposed along a face …; E. a current sensing device comprising at least one sensor and associated circuitry, disposed in the vertical strip enclosure, that senses electrical current … and provides quantified current information …; F. a numerical current display disposed on said vertical strip enclosure …; and G. a current‑related information reporting system disposed in said vertical strip enclosure comprising a network interface controller directly connectable to a separate communications network distal from the electrical power distribution plugstrip, and that (i) receives said quantified measured current information, and (ii) communicates said quantified measured current information to a remote system through the separate communications network."

'842 claim 17 reproduces elements A, B, E, F, G essentially word‑for‑word, and adds:

  • (C): outputs respectively fed by a first and second phase of a polyphase input;
  • (D): power control relays in the enclosure;
  • (E): a plurality of sensing devices, first and second per phase; and
  • (F): a first and second phase current display section, reporting "while" reporting the other.

Conclusion: claim 17's only novelty over the family's own earlier disclosure is the polyphase / simultaneous per‑phase display overlay. In other words, claim 17's validity is tethered to the same single feature that carries claim 1 — and claim 17's remaining bulk (vertical strip enclosure, relays, current sensing, numeric display, NIC, SNMP, CAT‑5, personality modules) is squarely in the § 102(b) art.

7.2 Element chart

Claim 17 el. '842 text § 103 mapping Status
A unitary vertical strip enclosure, length > width, thickness US 2002/0002593 A1 ("long, thin plugstrip body"); S&S '506 (rack‑mountable housing) § 102(b)
B polyphase power input penetrating enclosure Root '009 (polyphase); admitted 3‑phase plugstrip (4‑line input) § 102(b) / admission
C outputs along face, first‑phase and second‑phase fed Root '009 (outlet groups respectively wired to phases 1, 2, 3); admitted 3‑phase plugstrip (three branches) § 102(e)/admission
D power control relays in enclosure, independently controlling outputs US 2002/0002593 A1 — "supplies operating power to each of the power outlet plugs through individual relay control"; US 5,949,974 — "intelligent power modules … solid state relay … microprocessor" § 102(b)
E current‑sensing devices in enclosure, first & second per phase US 5,949,974 — "load sensor associated with the power supplied to the one or more electrical loads"; Liu '729 — current amplifier/ADC; S&S '506 — in‑housing amp meter § 102(b)/(e)
F numerical current display on enclosure, first & second phase sections, "while" Liu '729 (digital display on a strip face); '2593/'461 disclosure — "Separate digital displays … for each monitored and measured load and infeed current"; "dual 7‑segment LED display(s)" § 102(b) (for the concept)
G current‑related information reporting system in enclosure, NIC directly connectable to a separate communications network, receiving and communicating to a remote system US 5,949,974 — SNMP agent 46 reporting load status; screen interface; US 5,506,573; and the '842 specification's express incorporation by reference of those patents and of Ser. No. 10/313,314 § 102(b)

7.3 Combination D — the primary § 103 theory for claim 17

US 2002/0002593 A1 (Ewing) + US 5,949,974 (Ewing) + Root '009 (The Root Group) [+ Liu '729]

Motivation, and why this is stronger than a typical KSR case:

  1. The '842 specification supplies the motivation in its own words. It states: "Both the delta and the wye power distribution and monitoring apparatus of FIGS. 1–4 may be adapted to provide or be implemented in conjunction with remote power management and reporting systems. Apparatus and systems for doing so are disclosed in references such as: (i) U.S. Pat. No. 5,506,573 … (ii) U.S. Pat. No. 5,949,974 … and (iii) the applicant's U.S. co‑pending application entitled 'Network Remote Power Management Outlet Strip,' Ser. No. 10/313,314 … the disclosures of all of which references are hereby incorporated herein by reference in their entireties."

    This is an express, written teaching in the patent itself to combine the claimed apparatus with the network reporting systems of '573 / '974. Under KSR, "[t]he combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results," and here the patentee has identified the reference combination and the reason for it.

  2. The combination is a merger of complementary, non‑overlapping teachings. Ewing '974 supplies network reporting and relay‑switched intelligent power modules; the '2593 publication supplies the vertical strip enclosure with per‑outlet relays; Root '009 supplies the polyphase phase‑grouped outlet architecture; Liu supplies the on‑strip numeric display. There is no teaching away, no reference that would be rendered unsatisfactory by the combination, and no change in operating principle. That is the KSR "predictable use of prior‑art elements according to their established functions."

  3. The machine‑parallel‑family disclosures confirm the artisan's expectation of success. The '2593/'461 disclosure states that "a power manager architecture provides for building‑block construction of vertical and horizontal arrangements of outlet sockets" and that each of "a plurality of power input feeds has a monitor that can provide current measurements," and describes swappable personality modules (SENTRY‑slave, terminal‑server, network) — the artisan, in 2003, plainly regarded a multi‑feed, multi‑display, network‑reported vertical strip as a routine configuration.

7.4 Combination E — a cumulative third‑party‑anchored theory for claim 17

Root '009 + Liu '729 + a commercially disclosed remotely‑managed vertical rack PDU (APC PowerStruXure / APC MasterSwitch VM + PowerNet SNMP MIB; third‑party rack‑remote‑power‑control products disclosed in the Pulizzi catalogs)

  • Motivation: Root '009 gives polyphase phase‑grouped outputs; Liu '729 gives the numeric current display on a strip; the commercial literature gives the "network the strip and report current over SNMP" convention (APC PowerNet SNMP MIB; PowerStruXure manuals). A PHOSITA seeking a data‑center PDU that both displays and reports would pick these up as of course.
  • Caveat: I have not verified that these specific NPL items disclose SNMP reporting threads, and the candidate status of the manuals is a weakness.

7.5 The strongest counter‑evidence on claim 17 (must be confronted)

Claim 53 of the '543 patent — which is the near‑identical sibling of '842 claim 17 — was found patentable in the '543 reexamination (claims 28, 32, 35, 36, 38, 44, 45, 49, 51–62 patentable in Appeal 2015‑004779). Further, the PTAB instituted Raritan's IPRs on US 7,702,771 and US 7,043,543 (IPR2015‑01596 / IPR2015‑01597), in which Raritan's theory was "Ewing in view of Wiebe" (per the exhibit excerpts: "When Ewing is modified based on the teachings of Wiebe, the intelligent power module will be 'associated with' the vertical strip enclosure").

Three implications:

  1. A skilled adversary (Raritan) evidently considered an "Ewing + secondary reference" obviousness theory the best attack on the sibling claims — corroborating the combination approach I set out in Comb. D. But I could not confirm the identity or disclosure of Wiebe (a reference possibly to US 5,650,771) within my step budget, so I do not rely on it.
  2. The PTO has already sustained the patentability of the '543 claim 53 subject matter against the art of record. That is a meaningful rebuttal — though it addressed a different claim and a different record (the '543 reexam record, which included APC's submissions but not necessarily Root '009 / Liu '729 in the same combination).
  3. § 256/§ 282 presumption of validity and the clear‑and‑convincing standard apply.

8. Dependent claims 18–26

Claim Limitation § 103 mapping (§ 102(b)‑anchored where possible)
18 ≥1 microprocessor controlling a plurality of relay boards US 5,949,974 — intelligent power modules with solid‑state relay + microprocessor, networked; '2593 publication — individual relay control
19 relay board with ≥1 relay + ≥2 current sensing devices on the board US 5,949,974 — per‑load load sensors co‑located with intelligent power modules; the '2593/'461 disclosure — IPT‑IPM board with four relays + load sensors 1038–1041 (evidence of conventionality)
20 Hall‑effect current sensors ⚠️ Weakest link. The '842 page's prior‑art tables contain no reference expressly disclosing Hall‑effect sensing. A PHOSITA would know Hall‑effect sensors as a standard isolated current transducer (alongside CTs and the isolation‑transformer sensing described in the spec), and substitution of one conventional current transducer for another is a KSR predictable variation — but expect this to be the element most resistant to a paper § 103 case absent a dedicated reference.
21 inter‑IC (I²C) bus coupled to relay boards Strongly evidenced as conventional by the '2593/'461 family disclosure (internal I²C‑bus 119/219 terminating at a network personality module) — evidence of what PHOSITAs used, though the '461 itself is § 103(c)‑barred
22 network agent using SNMP US 5,949,974 — SNMP agent; § 102(b) ✔
23 NIC comprises a CAT‑5 connector The '2593/'461 disclosure — "100Base‑T network interface and a CAT‑5 connector"; the RJ‑45/CAT‑5 Ethernet physical layer was entirely conventional by 2003
24 personality module providing HTTP browser and/or terminal‑server interface The '2593/'461 disclosure — network personality module (http) and terminal‑server personality module; US 5,949,974 — Telnet/HTTP/browser and screen interface § 102(b) for the HTTP‑interface concept; and the '842 spec itself recites HTTP/Telnet/SNMP interfaces
25 personality module removable The '2593/'461 disclosure — removable communications module
26 second personality module interchangeable '461 disclosure — "a family of personality modules to be substituted for IPT‑NetworkPM 228"; and US 2005/0203987 A1 claim 2 (a sibling published application) — "a communications module removably disposed in the power distribution unit housing"

Assessment: claims 18–26 are largely the "network PDU" feature set that Server Technology itself commercialized with its SENTRY line and described in its own 1999–2002 publications. Claims 22, 23, 24, 26 in particular read on very specific, disclosed structures. Only claim 20 (Hall‑effect) has a real evidentiary gap.


9. Motivation to combine — consolidated

A court or the Board would look for an articulated reason. Here there are five independent, record‑supported reasons:

  1. Express problem statement in the patent. The '842 Background identifies (i) the burden of the button‑cycled single display, and (ii) the failure to show neutral current, as the problems to be solved. That is a KSR "design need" motivation in the applicant's own words.
  2. Express incorporation‑by‑reference teaching. The specification names '573 and '974 and Ser. No. 10/313,314 and says the claimed apparatus "may be adapted to provide or be implemented in conjunction with remote power management and reporting systems." A patentee cannot simultaneously tell the world to combine A and B and then argue a PHOSITA would not have done so.
  3. Purpose‑driven combination (Root '009). Root '009's entire purpose is balancing phase currents; displaying per‑phase current is the natural, predictable way to monitor that balance. This is the "design incentive" factor.
  4. Predictable variation / duplication of parts. Replacing one time‑multiplexed display with N dedicated displays for N monitored channels is the textbook "arrangement of old elements" with no change in function. KSR; cf. also the "separate digital displays … for each monitored and measured load and infeed current" disclosure.
  5. Predictable field + reasonable expectation of success. Mature components, mature field, no teaching away. The 45 forward citations and the crowded PDU patent landscape corroborate incremental, predictable development.

10. Rebuttals and secondary considerations (what the patentee will argue)

Patentee argument Strength Analyst's note
Presumption of validity / clear‑and‑convincing Strong, procedurally Applies. Also: the 2016‑03‑08 Certificate of Correction may have altered claim text; I could not retrieve its text, so any final invalidity position must be re‑run against the corrected claims.
Claim 53 of '543 (the sibling of '842 claim 17) was found patentable in reexam Strongest substantive rebuttal The Board in Appeal 2015‑004779 sustained claims 51–62. But: different claim, different record, and the '842's added polyphase/simultaneous‑display limitation was not at issue. Still, a court would give this weight on the "unexpected results"/non‑obviousness side.
Commercial success / industry recognition Moderate STI submitted § 1.132 declarations from Aucoin, Hardin, Mares, and Ewing in the '543 reexam on commercial success (the Raritan IPR exhibits reference "the issue of commercial success"). But: (i) nexus must tie the success to the claimed feature (the simultaneous per‑phase display), not to the rack‑PDU product generally; (ii) the '842's own background admits the single‑display plugstrip was already on the market more than a year before the priority date, which undercuts any "long‑felt need" narrative for the display architecture; (iii) the Fed. Cir. reversed the '543/'771 infringement judgment in Server Technology v. APC, 657 F. App'x 1030 (Fed. Cir. Sept. 23, 2016) on erroneous claim construction — so the earlier "success" story is not intact.
Unexpected results Weak I find no result in the '842 specification that a PHOSITA would not have predicted from combining a multi‑feed metered strip with per‑feed displays. The stated benefits (at‑a‑glance balance/imbalance detection, self‑contained on‑site readout, no computer screen needed) are precisely the expected consequences.
Teaching away Weak The prior art does not criticize plural per‑phase displays. The single cycled display of the admitted art is a cost‑driven design, not a teaching that multiple displays are inoperative or undesirable.
"While … only while" claim construction Uncertain This is the crux limitation (claims 1, 9). If "while" is construed to require strict simultaneity, the case turns entirely on whether any reference shows concurrent per‑phase display. If it is construed loosely, the admitted art + Liu collapses the claim. This wording was central to the sibling claim‑construction reversal, so the construction risk is real and cuts both ways.

11. Overall assessment — ranked vulnerability

Claim(s) Vulnerability to § 103 Primary theory
1 High (with a meaningful construction‑dependent escape hatch) Admitted 3‑phase plugstrip + Liu '729 [+ Root '009]; or Root '009 + S&S '506 + Liu '729
2–8, 12–16 High Same combinations + Liu '729 (multi‑parameter display; over‑current switch) + admitted background (wye/neutral; alarms)
9–11 Moderate–High Negative "only while" limitations add nothing structural
17 High '2593 publication + US 5,949,974 + Root '009 (+ Liu '729); reinforced by the patent's express incorporation by reference
18, 19, 21, 22, 23, 24, 25, 26 High US 5,949,974 (relays + microprocessor + SNMP + screen interface) and the '2593/'461 conventionality evidence
20 (Hall‑effect) Moderate No express reference on the '842 page's prior‑art list; must be supported by a dedicated Hall‑effect transducer reference or by a "known equivalent transducer" argument

Bottom line: the '842 patent's claim 1 novelty rests on a single, narrow, and highly predictable variation — plural, simultaneous per‑phase displays instead of one cycled display — over prior art the applicant admitted existed. Its claim 17 novelty rests on essentially the same variation layered onto subject matter (vertical strip + relays + current sensing + numeric display + networked reporting) that the applicant's own 1999 and 2002 § 102(b) publications and third‑party art (Root '009, Liu '729, S&S '506) disclose. Both independent claims, and nearly all dependents, present strong § 103 exposure — subject to (a) the clear‑and‑convincing burden, (b) the '543 reexam's contrary result on the analogous claim 53, and (c) the construction of "while."


12. Explicit uncertainties and required verification

  1. I did not read APC's invalidity claim charts (Exhibits B‑1, C‑1, D‑1, E‑1, Dec. 16, 2011) listed in the Non‑Patent Citations. These are existing, mapped § 103 contentions and are the highest‑value documents in this file. Get them first.
  2. The 2016‑03‑08 Certificate of Correction text is unknown. Any final claim‑level invalidity position must be re‑run against corrected claim text.
  3. The APC Three‑Phase Rack PDU AP7601/02/08 manual (2003), the APC PowerStruXure manuals (Nov 2001, Feb 2002), and the Pulizzi catalogs (1999, 2001) contents are unverified. They are the best candidates for anticipation (as opposed to obviousness) of claim 1 and for third‑party anchoring of claim 17's networking elements. Note the public‑accessibility requirement for catalog/manual prior art.
  4. The "Wiebe" reference used in the Raritan IPRs (IPR2015‑01596/-01597) against US 7,702,771 and US 7,043,543 — my attempt to confirm whether it is US 5,650,771 was cut off by the search limit. Unverified; do not cite.
  5. § 103(c) analysis is a live issue. I have assumed the best references are usable only to the extent they are § 102(b) printed publications (US '974, US '573, US 2002/0002593) or third‑party art (Root '009, Liu '729, S&S '506). Verify inventorship for every Server Technology reference before relying on it; the '543 and '461 patents and the '830/'329/'365/'815/'906 family members are § 102(e)‑only and, being commonly owned, are disqualified from § 103 under pre‑AIA § 103(c)(1) unless the "developed by another person" / ownership facts are re‑examined.
  6. Claim‑construction risk on "while" (claims 1, 9). Given the Fed. Cir.'s 2016 reversal of the sibling judgment on claim construction (657 F. App'x 1030), the meaning of "visibly report … while visibly reporting" should be treated as unsettled and outcome‑determinative.
  7. The '842 patent expired 2023‑10‑31, so any invalidity challenge is now most likely to arise defensively (e.g., in a § 285/unenforceability or damages‑tail posture) or in a reexamination/IPR context to clear the family — not as the primary assertion vehicle.

Generated 9/28/2026, 4:14:03 PM

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