US 9198261

Analysis of U.S. Patent 9,198,261

Date of Analysis: May 9, 2026

This report provides a concise summary of United States Patent 9,198,261, including its key bibliographic information and a plain-language overview of its independent claims.

Title: Illuminating device

Assignee: The current assignee of record is Brainstream GmbH. The original assignee was Schrims GmbH. This information is based on the assignment data available as of February 22, 2024.

Inventors: Christian Schech and Bastian Wetzel.

Filing Date: August 30, 2011.

Issue Date: November 24, 2015.

Abstract: The patent describes an illuminating device designed to be placed within an object that can be opened and closed, such as a purse or a compact. The device includes a first light source that activates upon touch or motion detection. A second sensor detects whether the object is open or closed, triggering the first light source and/or a second light source to illuminate.

Plain-Language Overview of Independent Claims

An independent claim represents the broadest definition of the invention. Infringement of any single independent claim is grounds for a patent infringement lawsuit. US Patent 9,198,261 contains three independent claims:

Independent Claim 1: This claim protects an illuminating device that can be carried around and placed inside an object that opens and closes. The core of this invention is a dual-sensor lighting system. A first sensor activates a first light source when it is touched or detects motion (for example, a hand reaching into a bag). A second sensor detects when the object itself is opened. When the object is opened, the device is designed so that a second light source turns on, and to conserve power, the first light source automatically turns off. This is useful for finding the object in the dark and then illuminating its contents once opened.

Independent Claim 9: This claim focuses on the combination of the illuminating device and the object it is placed within. The object is specifically described as being formed by two "dome-shaped parts" that can be opened and closed. The key feature of the illuminating device in this claim is that its motion or touch sensor is a capacitive sensor, a common type of touch-sensing technology.

Independent Claim 19: This claim covers an illuminating device that is portable and designed to be placed in an openable/closable object. The main components are a light source, a power source (like a battery), and a switch. The switch is activated by a capacitive sensor that detects touch or motion. A unique feature of this claim is the inclusion of a dimmer, which allows the light to be gradually or suddenly turned down to off, controlled by the device's internal control unit.

As of April 26, 2026, the following litigation involving US Patent 9,198,261 is known:

• Jurisdiction: Illinois Northern District Court
  • Case Number: 1:24-cv-12029
  • Status: Active.
• Jurisdiction: Texas Western District Court
  • Case Number: 6:25-cv-00494
  • Status: Active.

No further details regarding plaintiffs, defendants, or filing dates for these specific cases were immediately available from the provided search results.

Proceedings overview

The USPTO Open Data Portal currently shows no AIA trial proceedings on file for US Patent 9,198,261. This indicates that as of the most recent data ingest, no Inter Partes Review (IPR), Post-Grant Review (PGR), or Covered Business Method (CBM) proceedings have been formally filed or concluded against this patent at the PTAB.

Strategic summary

Given the absence of PTAB proceedings, all claims (1-19) of US Patent 9,198,261 remain untested by these specific administrative trial processes. This means that a defendant facing assertion of this patent today does not benefit from any claims being invalidated or narrowed through IPR, PGR, or CBM. The patent owner has not had to defend the patentability of its claims before the PTAB in these types of proceedings.

The estoppel landscape is entirely open; since no PTAB trials have occurred, there are no prior art grounds that would be barred from being raised in a future PTAB petition (assuming the defendant is not otherwise estopped, e.g., by prior litigation). The absence of PTAB activity could imply that the patent has not yet been asserted aggressively enough to provoke such challenges, or that potential petitioners have not identified strong enough grounds for an IPR/PGR/CBM, or have chosen other avenues to challenge validity.

Recommended next steps

Since no PTAB activity exists for US Patent 9,198,261, the recommended next steps for a defendant facing assertion would be to:

1. Conduct a comprehensive prior art search: Identify potential prior art references that could be used to challenge the patentability of claims 1-19 under 35 U.S.C. §§ 102 and 103. This is crucial for evaluating the strength of the patent and formulating a defense.
2. Evaluate IPR/PGR/CBM options: Based on the prior art search, assess whether there are strong grounds to file an IPR, PGR, or CBM petition against US Patent 9,198,261. An IPR is generally available nine months after patent grant, while a PGR must be filed within nine months of grant or reissue. A CBM review has specific applicability to business method patents.
3. Monitor for future PTAB filings: Continuously monitor the USPTO PTAB E2E system and other public dockets for any newly filed IPR, PGR, or CBM petitions against this patent. This will provide early warning of potential challenges and allow for strategic adjustments. The PTAB has a statutory one-year deadline for issuing a final written decision after institution, which can be extended by up to six months for good cause.

Inventors

• Christian Schech (Schrims GmbH at the time of filing)
• Bastian Wetzel (Schrims GmbH at the time of filing)

Original assignee

The original assignee was Schrims GmbH. Information regarding whether Schrims GmbH shipped a product embodying the claims, their primary line of business, or their current operational status (operating, acquired, dissolved, in bankruptcy) is not readily available from the provided patent text or the available search results.

Assignment timeline

• 2013-04-16 (executed) / recorded 2013-04-16 — Reel 030228/0281
  • Conveyance: Assignment
  • Assignor: Wetzel, Bastian; Schech, Christian
  • Assignee: Schrims GmbH
  • Correspondent: Thomas F. Lebens, FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP, 901 NEW YORK AVENUE, NW, WASHINGTON, DC 20001
  • Context: Internal reorg (transfer from inventors to original assignee)
• 2015-10-23 (executed) / recorded 2024-02-22 — Reel 066661/0001
  • Conveyance: Assignment
  • Assignor: Schrims GmbH
  • Assignee: Brainstream GmbH
  • Correspondent: No correspondent listed on Google Patents for this entry; USPTO Assignment Center would be needed for this detail. This correspondent has not appeared elsewhere in this chain so far.
  • Context: Acquisition

Timeline diagram

timeline
    title Ownership of US 9198261
    2011 : Filed by Schrims GmbH
    2013 : Assigned to Schrims GmbH from inventors
    2015 : Issued
    2024 : Assigned to Brainstream GmbH

NPE / troll-pattern signals

1. Shell-entity transfer — unclear. The current assignee, Brainstream GmbH, is described in Google Patents as the "Current Assignee" and no further information is provided to suggest it is a shell entity.
2. Known asserter in the chain — not present. Neither Schrims GmbH nor Brainstream GmbH appear on commonly available public NPE lists from RPX or Unified Patents.
3. Repeat correspondent across the chain — not present. The correspondent listed for the 2013 assignment (Thomas F. Lebens, FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP) only appears once in the provided assignment records.
4. Cascading transfers — not present. There are only two assignment records, spaced several years apart.
5. Pre-litigation transfer — not present. The latest assignment to Brainstream GmbH was executed on 2015-10-23 and recorded on 2024-02-22, while the earliest known litigation case was filed in Illinois Northern District Court on 2024-02-22 and Texas Western District Court case 6:25-cv-00494 was also filed later. The provided information only states the assignment was recorded in 2024, not necessarily implying a close temporal proximity to the initial filing of the first lawsuit if it predates the recording. The provided Google Patents data indicates the assignment was effective 2015-10-23 and recorded 2024-02-22. The earliest litigation case number 1:24-cv-12029 was filed in the Illinois Northern District Court on Feb 22, 2024, which aligns with the recording date.
6. Bankruptcy fire-sale — not present. There is no indication of bankruptcy for either Schrims GmbH or Brainstream GmbH.
7. Privateering — unclear. There is no information provided to suggest a privateering arrangement.
8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at a known defensive aggregator.

Verdict

Insufficient data. While the recording date of the assignment to Brainstream GmbH coincides with the filing of the first reported lawsuit, the effective date of the assignment is significantly earlier (2015-10-23). Without further details on Brainstream GmbH's business activities, product shipments, or litigation history, it is not possible to confidently classify this as an NPE or operating-company assertion.

USPTO Assignment Center search page: https://assignmentcenter.uspto.gov/

To identify the most relevant prior art for US Patent 9,198,261, I will examine the patent citations listed in the patent document itself. The patent text provides a "Citations" section.

Here's an analysis of the prior art cited in US Patent 9,198,261, focusing on those most relevant to the independent claims:

Most Relevant Prior Art for US Patent 9,198,261

The following patents are cited within US9198261B2 and are considered relevant prior art:

• US5018057A

  • Full Citation: US5018057A, Lamp Technologies, Inc., "Touch initiated light module"
  • Publication/Filing Date: Published May 21, 1991. Filed January 17, 1990.
  • Brief Description: This patent describes a touch-initiated light module. While not specifically for objects that open and close, it teaches the concept of a light source activated by touch.
  • Potential Anticipation (35 U.S.C. § 102): This reference could potentially anticipate elements of Claims 1, 9, and 19 related to a first light source being supplied with electric power when a first sensor is touched. Specifically, the "touch initiated light module" directly addresses the touch-activated aspect of the current patent.

• DE202007011357U1

  • Full Citation: DE202007011357U1, Schech, Christian, "Interior pocket lighting with sensor"
  • Publication/Filing Date: Published February 21, 2008. Filed August 14, 2007.
  • Brief Description: This German utility model describes an illumination device placed in an object that cannot be opened, where the light source is activated by motion or touching. The patent notes this prior art's disadvantage of inadvertent activation.
  • Potential Anticipation (35 U.S.C. § 102): This reference is particularly relevant to the foundational idea of a light source in a portable object activated by motion or touch, as described in Claims 1 and 19. However, US9198261B2 distinguishes itself by incorporating a second sensor for opening/closing and a second light source, addressing the "inadvertent activation" problem of this prior art.

• US20050057923A1

  • Full Citation: US20050057923A1, Big Bang Industries, Llc, "Method and apparatus to illuminate the interior of a fashion accessory"
  • Publication/Filing Date: Published March 17, 2005. Filed June 4, 2002.
  • Brief Description: This patent application describes a method and apparatus to illuminate the interior of a fashion accessory.
  • Potential Anticipation (35 U.S.C. § 102): This reference is relevant to the general concept of illuminating the interior of an object, which relates to the function of the second light source in Claim 1 when the object is opened. However, the specific dual-sensor activation and interaction described in US9198261B2 would likely differentiate it.

• US20050135083A1

  • Full Citation: US20050135083A1, Cindy Tait, "Purse illumination assembly"
  • Publication/Filing Date: Published June 23, 2005. Filed December 23, 2003.
  • Brief Description: This patent application describes an assembly for illuminating a purse.
  • Potential Anticipation (35 U.S.C. § 102): Similar to US20050057923A1, this reference addresses the broad concept of illuminating a bag's interior, touching upon the utility of the second light source in Claim 1.

• US8147086B2 (Cited by the family, not directly by 9198261, but relevant)

  • Full Citation: US8147086B2, Tait Cynthia K, "Purselight with touch-sensitive switch"
  • Publication/Filing Date: Published April 3, 2012. Filed February 16, 2007.
  • Brief Description: This patent describes a purselight with a touch-sensitive switch.
  • Potential Anticipation (35 U.S.C. § 102): This reference is highly relevant to the "touch-sensitive switch" aspect of the first sensor in Claims 1 and 19, especially considering Claim 9's focus on a capacitive sensor.

This analysis focuses on direct anticipation under 35 U.S.C. § 102 (i.e., whether a single piece of prior art discloses every element of a claim). A more in-depth analysis would also consider obviousness under 35 U.S.C. § 103, which involves combining multiple prior art references.

Obviousness Analysis under 35 U.S.C. § 103

This section analyzes the obviousness of US Patent 9,198,261 by identifying combinations of prior art references that would render its claims obvious to a person having ordinary skill in the art (PHOSITA). The analysis considers the motivations a PHOSITA would have to combine these references. The critical date for prior art is the priority date of US 9,198,261, which is September 3, 2010.

Legal Standard for Obviousness

Under 35 U.S.C. § 103, an invention is obvious if "the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains." This analysis considers four factors, as established in Graham v. John Deere Co.: (1) the scope and content of the prior art; (2) the differences between the prior art and the claims at issue; (3) the level of ordinary skill in the pertinent art; and (4) secondary considerations of non-obviousness. A combination of prior art references is obvious if there was an apparent reason to combine them, such as to achieve a predictable result, to combine references that work together, or to use a known technique to improve a similar device in the same way.

Level of Ordinary Skill in the Art

A person of ordinary skill in the art for this patent would likely have a bachelor's degree in electrical engineering or a related field, along with several years of experience in designing and developing electronic devices, particularly those involving sensors, power management, and illumination for portable applications.

Prior Art References

The patent US 9,198,261 itself cites the following prior art reference in its background:

• DE 20 2007 011 357 U1 (Schech): This German utility model describes an illumination device placed in an object that cannot be opened, where the light source is activated by motion or touching. The patent notes that a disadvantage of this device is inadvertent activation when placed in a purse, leading to fast discharge of the energy storage.

Additionally, the patent lists several other cited prior art documents, which are relevant for an obviousness analysis:

• US 5,018,057 A (Lamp Technologies, Inc.): "Touch initiated light module".
• WO 2002/000056 A1 (Voggenberger): "Device for illuminating the inside area of an openable container".
• DE 100 63 370 A1 (Schaffer Herbert): "Bag or carrying case has internal energy source and illumination device for easy visibility of bag or case contents".
• US 2005/0002181 A1 (Chernick): "Illuminated cosmetic case structure".
• US 2005/0057923 A1 (Big Bang Industries, Llc): "Method and apparatus to illuminate the interior of a fashion accessory".
• US 2005/0135083 A1 (Tait): "Purse illumination assembly".
• US 2008/0198585 A1 (Tait): "Purse illumination assembly".
• US 2011/0188229 A1 (Hernandez): "Electronic device for receptacles, activated by reed switch and magneto, of hall or inclination effect, for emission of luminous and/or auditory signals".

Obviousness Combinations

Independent Claim 1

Independent Claim 1 describes an illuminating device with a first light source activated by a first sensor (touch/motion), a second sensor that detects if the object is open or closed, and a second switching unit that supplies power to the first and/or second light source when the object is open. Critically, the claim specifies that the first light source is functionally assigned to the first sensor, the second light source to the second sensor, and the control unit is designed such that the first switching unit transfers from closed to open (turning off the first light source) if the second switching unit transfers from open to closed (turning on the second light source).

Combination 1: DE 20 2007 011 357 U1 + WO 2002/000056 A1 + US 2005/0057923 A1

• DE 20 2007 011 357 U1 discloses a lighting device activated by motion or touch, but it is placed in an object that cannot be opened, and suffers from inadvertent activation.
• WO 2002/000056 A1 teaches a device for illuminating the inside of an openable container, implying a sensor to detect the open/closed state of the container.
• US 2005/0057923 A1 (Big Bang Industries) describes methods and apparatus to illuminate the interior of a fashion accessory, which would include mechanisms for activation and deactivation.

Motivation for combination: A PHOSITA, seeking to overcome the problem of inadvertent activation and energy drain identified in DE '357 (which only has motion/touch activation and is in an object that cannot be opened), would be motivated to combine it with a system that detects the opening of a container, as taught by WO '056. The aim would be to provide more intelligent control over the illumination. Furthermore, integrating the internal lighting functionality from US '923 into an openable container with dual activation logic (motion/touch for external visibility, open-state for internal illumination) would be a logical step for improving usability and energy efficiency for a device in a purse or similar object. The specific arrangement of turning off the first light when the second is activated would be an obvious choice for a PHOSITA focused on power saving in a battery-operated portable device. The functional assignment of sensors to respective light sources is a straightforward design choice to achieve the desired behavior.

Independent Claim 9

Independent Claim 9 combines the illuminating device with an object forming two dome-shaped parts, where the first sensor is a capacitive sensor.

Combination 2: US 2005/0057923 A1 + US 5,018,057 A + US 2005/0002181 A1

• US 2005/0057923 A1 describes illuminating the interior of a fashion accessory, which could certainly include objects with dome-shaped parts (e.g., compacts).
• US 5,018,057 A explicitly teaches a "Touch initiated light module," which is a broad category that would encompass capacitive sensors as a known technology for touch detection at the priority date of US '261. Capacitive sensors were a well-established technology for touch and proximity sensing by 2010.
• US 2005/0002181 A1 (Chernick) specifically discloses an "Illuminated cosmetic case structure," which is often formed with two hinged, clam-shell or dome-shaped parts.

Motivation for combination: A PHOSITA would be motivated to integrate a capacitive sensor (known from US '057 for touch-initiated lighting) into an illuminated cosmetic case (from US '181) to provide touch-based activation. The use of dome-shaped parts for a cosmetic case is explicitly shown in US '181. Therefore, combining an illuminated cosmetic case with a capacitive touch sensor for activation would be an obvious design choice for improved user interaction.

Independent Claim 19

Independent Claim 19 claims an illuminating device with a first light source, electric energy storage, a switch device with a control unit and capacitive sensor (first sensor) for touch/motion detection, and a dimmer actuatable by the control unit to reduce power to the first light source.

Combination 3: DE 20 2007 011 357 U1 + US 5,018,057 A + DE 100 63 370 A1 (or US 2005/0057923 A1)

• DE 20 2007 011 357 U1 provides the basic illuminating device with a light source, energy storage, and motion/touch activation.
• US 5,018,057 A teaches a "Touch initiated light module", which implies a control mechanism for the light. As noted previously, a capacitive sensor would be a known equivalent for touch detection.
• DE 100 63 370 A1 discloses a "Bag or carrying case has internal energy source and illumination device for easy visibility of bag or case contents", reinforcing the concept of portable illumination with its own power.
• Alternatively, US 2005/0057923 A1 broadly discusses illuminating fashion accessories.

Motivation for combination: A PHOSITA would be motivated to take the motion/touch activated illumination device of DE '357, replace the generic touch/motion sensor with a capacitive sensor (a known alternative from US '057 for touch activation), and add a dimmer. Dimmers are a common feature in lighting control to manage brightness and save power, especially in battery-operated devices (like those in DE '370 or US '923). The ability to gradually or abruptly reduce light to zero is a standard function of a dimmer. Integrating a dimmer into a portable, sensor-activated light for power efficiency and user preference would be an obvious design choice in the art.