US 9532261

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

Let me try more targeted searches for litigation and claim details.

Let me pull the actual claim text and abstract for this specific patent.

Summary of Findings on US 9,532,261

Important caveat up front: My search pass surfaced the patent's bibliographic record and a large body of Headwater litigation activity, but it did not return the actual claim text or the abstract field for US 9,532,261. The authoritative full text you supplied was truncated in my copy before the claims and abstract sections. Accordingly, treat the claim overview in §4 below as specification-based inference, not authoritative claim language. I flag exactly where I am uncertain.

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1. Bibliographic data (high confidence)

Source: https://patents.google.com/patent/US9532261/en and your supplied full text.

Two discrepancies worth noting rather than auto-correcting:

• Priority date conflicts across sources. Google Patents lists 2009-01-28; the Unified Patents portal lists 2009-01-27 for US-9532261-B2 (https://portal.unifiedpatents.com/patents/patent/US-20030005112-A1). The Google Patents record also shows external priority claims from US 12/380,783 (2009-03-02) and several US 12/694,xxx / 12/695,020–12/695,980 applications filed 2010-01-27. I do not have an authoritative priority-chain determination.
• Assignee change. An assignment recorded 2017-01-04 to Headwater Research LLC (merger/name change from Headwater Partners I LLC / Headwater Management LLC).

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2. Litigation / CAFC docket status

I found no CAFC 2026 docket that specifically names US 9,532,261. The Headwater litigation activity in 2026 is extensive, but the search results do not tie the asserted patent numbers to docket entries:

• Headwater Research LLC v. Cellco Partnership (Verizon), E.D. Tex. No. 2:23-cv-00352-JRG-RSP — final judgment entered 2026-04-23 following a jury trial and bench trial; a reported $175 million verdict; reported ruling that Headwater cannot enforce "a pair of patents" against Verizon. Notices of appeal/cross-appeal to the Federal Circuit were docketed as USCA No. 26-1884 (Headwater's notice of appeal, later deactivated as premature under FRAP 4(a)(4)) with a subsequent Verizon cross-appeal. Source dockets: https://www.courtlistener.com/docket/67648165/headwater-research-llc-v-verizon-communications-inc/ and the ED Tex filings archived at archive.org.
• Headwater v. Google (W.D. Tex., later N.D. Cal. Nos. 5:26-cv-01460-NW and 3:26-cv-06192-LJC), Headwater v. Dish/Boost (E.D. Tex. 2:25-cv-00907), Headwater v. Charter and v. Comcast (E.D. Tex. 2:25-cv-00906/-00908, stayed pending settlement to 2026-09-01), Headwater v. Amazon (W.D. Tex.), and ITC Investigation No. 337-TA-1477.
• PTAB activity: Headwater patents are being challenged (e.g., Amazon IPR proceedings referenced in Law360, Jan. 7, 2026).

I cannot confirm from these results that US 9,532,261 is among the patents asserted in any of these matters. Any statement to that effect would be fabricated.

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3. Abstract

I do not have the abstract of US 9,532,261 from an authoritative source for this patent.

I specifically caution against a likely error: a search result for US 8,635,335 B2 — a different patent with the same title, the same three inventors (Raleigh, Raissinia, Lavine), same assignee (Headwater Partners I LLC), filed 2011-05-25 — has this abstract:

"A method comprising communicating a first set of data communications over a wireless cellular connection of a wireless cellular network to or from an end user device... identifying an alternative wireless network... and based on electronically processing an instruction set for offloading from the wireless cellular network to the alternative wireless network, determining whether to communicate the second set of data communications... over the alternative wireless network or over the wireless cellular connection, wherein the instruction set for offloading comprises at least one rule that takes into account at least one state associated with the wireless cellular connection."

That is the abstract of US 8,635,335, not verified as the abstract of US 9,532,261, even though the two are plainly siblings in the same family. Please do not attribute it to '261 without confirming.

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4. Independent claims — inference only (LOW confidence)

I was unable to retrieve the claim set of US 9,532,261. I therefore cannot state the number of claims, the number of independent claims, or quote any claim. What follows is what the specification (from your supplied authoritative text) indicates the claims likely cover:

The disclosure describes a wireless network offloading engine 106 coupled to wireless devices (FIG. 1) that:

• receives Available Network Characterization Scan (ANCS) reports from devices (data rate, latency/jitter, QoS, access-grant success probability, access-grant delay, location, timestamps);
• generates a multi-dimensional network map / prioritized network list (FIGS. 2–6), incorporating historical and remotely obtained data;
• supplies the list or an instruction set to the device, which may further customize it (geo-location, motion trace, performance history, cost function, incentives);
• causes the device to offload from a first network (e.g., cellular) to a second (e.g., Wi-Fi) when a performance/reliability threshold is satisfied, while avoiding frequent hopping; and
• monitors network performance and loops back (FIG. 14 flowchart 1400: obtain wireless network data → generate prioritized network list → connect to a network from the list → monitor performance → repeat).

FIG. 15 flowchart 1500 describes a method for using device-assisted services (DAS) to facilitate wireless offloading, starting with "monitoring network service usage activities of a device" using a verified/verifiable performance characterization agent, with network busy state stored/derived from a network statistics datastore. The supplied text cut off mid-sentence in this section, so I cannot report the remaining modules.

Plausible independent claims (inference, not verified): (a) a method/apparatus for offloading between a cellular connection and an alternative wireless network based on a rule/instruction set accounting for a state of the cellular connection; and (b) a server-side method for obtaining wireless network data and generating a prioritized network list. Do not rely on this as claim construction.

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5. Identifier-confusion warnings

1. "The '261 Patent" in PTAB petitions is a different patent. Search results returned PTAB petition documents discussing "the '261 Patent" involving CDMA orthogonal alert codes, an earliest priority date of August 7, 1996, and a parent US 6,111,869. That is not US 9,532,261. Do not conflate them.
2. US 8,635,335 and EP 2,577,333 B1 contain the same specification text as this family and are easily mistaken for the '261 patent. Note EP 2577333 adds 3GPP TS 23.261 / ANDSF discussion not present in the US text you supplied.
3. WO1995032261A1 (liquid-crystal compounds) matched on the digit string "32261" and is unrelated — excluded.

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Bottom line

• Bibliographic data for US 9,532,261: confirmed (Raleigh/Raissinia/Lavine; Headwater; filed 2014-01-15; issued 2016-12-27; app. 14/156,428).
• Litigation context: confirmed for Headwater v. Verizon (2:23-cv-00352, judgment 2026-04-23, appeal routing to the Federal Circuit as USCA 26-1884) and other 2025–2026 Headwater campaigns — but the specific patents asserted are not identified in the results I obtained.
• Abstract and claim text: not authoritatively obtained. If you need verified abstract/claim language, pull the full text directly from USPTO PatentCenter or the Google Patents "Claims" and "Abstract" sections for US 9,532,261, and I will analyze the claims from that source.

I'll search for litigation involving US patent 9532261.

Let me search more specifically for the patent owner's litigation campaigns.

Let me search for the specific patent number in its standard format.

Litigation Search: US Patent No. 9,532,261

Bottom line up front

I could not identify any litigation that asserts U.S. Patent No. 9,532,261 ("System and method for wireless network offloading") specifically. My searches surfaced no complaint, docket entry, PTAB related-matters table, or § 290 (AO 120) filing that names the '261 patent as a patent-in-suit. I want to be transparent that this is a negative finding based on the sources my searches reached, not a definitive absence — see the caveats at the end.

I deliberately did not treat the many similar-looking numbers in this family/portfolio (e.g., 9,522,261, 9,532,261-adjacent IDs) as this patent.

What the authoritative patent record itself says

The Google Patents record for US9532261 (provided in the materials) flags the family as having litigation:

• Owner: Headwater Research LLC (originally Headwater Partners I LLC); inventors Gregory G. Raleigh, Alireza Raissinia, James Lavine; priority date 2009-01-28.
• The page carries a "Family has litigation" banner linking to Darts-ip family 45353581: https://patents.darts-ip.com/?family=45353581&...

Important caveat: that banner is a family-level flag. It establishes that some member(s) of the family have been litigated — it does not establish that the '261 patent itself was asserted. I could not resolve the Darts-ip family page's case list from search results.

Closest family-linked litigation I found

The '261 patent is a member of the Raleigh/Headwater "wireless network offloading / prioritized network list" family. Within that family, the closest match I could confirm being asserted is U.S. Patent No. 10,791,471 (a later continuation in the same family, listed on the '261 Google Patents page as a priority-claiming descendant):

• Headwater Research LLC v. Apple Inc., No. 7:25-cv-00377 (W.D. Tex., filed Aug. 27, 2025), Judge Alan D. Albright; plaintiff's counsel Russ August & Kabat; patents-in-suit reported as 8,635,335; 10,237,757; and 10,791,471. Law.com Radar describes these as "three patents related to wireless network offloading technology." Status: pending.
  • Source: https://www.law.com/radar/card/headwater-research-llc-v-apple-inc-59806517-1
  • Note a conflicting reading: a PTAB related-matters table also lists 7:25-cv-00377 with 8,635,335; 10,237,757; 10,791,471.

Again: this is '471, not '261. I am flagging it only as the nearest confirmed relative, not as '261 litigation.

Context: Headwater's known campaigns (none verified as asserting '261)

For completeness, the Headwater enforcement campaigns I found are summarized below. None of the patent lists surfaced in my searches includes 9,532,261 — I include them so you can see I checked, and to avoid implying any of these assert the '261 patent:

Why the negative finding is plausible but not certain

• The '261 patent is one of hundreds of patents in the Headwater/Raleigh portfolio, and Headwater typically asserts only a handful of patents per case. It is entirely consistent that this particular patent has not (yet) been asserted.
• The family-level Darts-ip flag means the family is litigated; the asserted members are far more commonly the '541, '543, '042, '613, '510, '055, '429, '930, '464, '155, '364, '976, '918, '335, '757, '471 line — not '261.

Recommended verification steps (I could not complete these within this task)

To convert this into a definitive negative or positive finding, the following are the authoritative checks:

1. Unified Patents litigation portal — search the exact patent number: https://portal.unifiedpatents.com/litigation/caselist.
2. Darts-ip family 45353581 (linked from the patent's Google Patents page) — but resolve it case-by-case to confirm the specific patent, since it is a family-level flag.
3. PACER / CourtListener RECAP — full-text search "9,532,261" across district dockets.
4. PTAB P-TACTS — check related-matters filings for any IPR/PGR naming the '261 patent (an IPR is litigation-adjacent and would also confirm assertion).
5. USPTO § 290 index (AO 120 filings), which list patents-in-suit per case.

Explicit caveats

• Sources reached: general web search results (Google Patents, CourtListener/RECAP PDFs, Law.com Radar, Darts-ip link, PTAB filings, secondary news). I did not obtain live query results from the Unified Patents caselist or PACER directly.
• Conflicts noted: The patent lists tied to case No. 7:25-cv-00377 vary between sources (some list offloading-family patents; the PTAB table lists 8,635,335/10,237,757/10,791,471). I have reported both rather than picking one.
• No auto-correction: I have treated "9532261" as US Patent No. 9,532,261 only, and have not substituted any similar number.

If you can point me to the specific Headwater case docket you suspect, I can confirm whether 9,532,261 appears among the asserted patents.

I'll start by verifying the structured data against live sources, since the ODP block reports no AIA trials.

Let me search more specifically for this patent number and its family.

The family-level results are rich, but I need to pin down whether this patent ('261) was ever challenged. Let me run targeted checks.

I hit the tool-call limit mid-verification, but I have enough to answer honestly. Key point up front: the canonical ODP block says zero AIA trials on this patent, and my searches did not surface any IPR/PGR/CBM naming US 9,532,261. I did surface heavy PTAB activity against sibling patents in the same Headwater family — which is useful context but is not activity on this patent, and I will not dress it up as such.

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Proceedings overview

Total AIA trial proceedings on US 9,532,261: 0. No IPRs, no PGRs, no CBMs. Breakdown: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials. The U.S. Patent & Trademark Office Open Data Portal (ODP) AIA-trial feed returned no proceedings as of the most recent ingest, and my independent web searches — including PTAB P-TACTS petition pages, Docket Alarm PTAB dockets, CourtListener RECAP, and Google Patents' litigation-family flags — returned no petition, institution decision, FWD, or appeal indexed to this patent number.

The defensive posture this gives a defendant is therefore not "the patent has survived two IPRs and is hardened," and it is not "claims 1–5 have been canceled." It is a third, less comfortable posture: the patent is untested and fully intact, but it is a member of a family that the PTAB has been dismantling claim-by-claim. A defendant cannot cite a single PTAB holding against '261, and cannot rely on § 315(e)(2) estoppel recorded against '261 — there is none. What a defendant can do is import the Board's and the Nevada/Texas courts' reasoning about the shared specification and shared claim vocabulary, and bring its own IPR using the art that has already worked against the siblings.

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No proceedings exist for US 9,532,261 — the per-proceeding template below is intentionally empty

I am not going to populate the requested ### {PROCEEDING_NUMBER} — {Petitioner} v. {Patent Owner} blocks, because doing so would require inventing proceeding numbers. The constraints in my instructions are explicit: do not fabricate, and do not auto-correct identifiers. So: there is nothing to list.

One caveat I owe you, stated plainly: PTAB filings are indexed with a lag, and a petition filed within the last several weeks could exist without appearing in ODP, P-TACTS free-text search, or the aggregators I could reach. Treat "zero" as "zero as of 2026-09-30 on the sources checked," not as an eternal negative.

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Family-adjacent proceedings (context only — these are NOT proceedings on '261)

Label these correctly: none of the following challenged US 9,532,261. They are matters against Headwater Research LLC patents in the same Raleigh "device-assisted services" specification family, some of which share the '261 priority chain (12/380,778 et al., filed 2009-03-02; priority 2009-01-28).

IPR2024-00942 and IPR2024-00943 — Google LLC, [Cellco Partnership d/b/a Verizon Wireless](/litigations/by-plaintiff/Cellco%20Partnership%20d%2Fb%2Fa%20Verizon%20Wireless), Verizon Corporate Services Group, T-Mobile USA, Sprint LLC, and AT&T Services, Inc. v. Headwater Research LLC (U.S. 8,589,541)

• Filed 2024-06-17; instituted; combined Final Written Decision issued 2025-10-01, holding claims 2–23, 26, 41–60, 63, 64, 91–152, 155–171 unpatentable under 35 U.S.C. § 318(a). Panel: Hyun J. Jung, Scott B. Howard, and a third APJ whose name is truncated in the surfaced copy.
• Procedurally notable: Headwater statutorily disclaimed claim 1 (and a long list of other claims) rather than defend it. Verizon's 2025-12-22 notice to the E.D. Tex. court states Headwater did not file a notice of appeal within the statutory deadline. FWD: https://www.docketalarm.com/cases/PTAB/IPR2024-00942/Google_LLC_v._Headwater_Research_LLC/docs/10-01-2025-Board/Final_Written_Decision__original-20-Judgment_Final_Written_Decision_.pdf · Notice: https://storage.courtlistener.com/recap/gov.uscourts.txed.[224022](/patent/224022)/gov.uscourts.txed.224022.440.0.pdf

IPR2024-01041 and IPR2024-01042 — Cellco Partnership d/b/a Verizon Wireless v. Headwater Research LLC (U.S. 8,924,543)

• Both pending as of the 2025-09-29 related-matters update. Headwater voluntarily dismissed its assertion of the '543 patent, and parallel dismissals of '543 assertions against AT&T and T-Mobile followed. https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1556213](/patent/1556213)/download-documents

IPR2023-01253 (U.S. 9,143,976) — patent owner's preliminary response arguing § 325(d) discretionary denial

• Weighs in on the same Rao/Oestvall art family used across Headwater IPRs. https://storage.courtlistener.com/recap/gov.uscourts.txed.[218219](/patent/218219)/gov.uscourts.txed.218219.238.2.pdf

IPR2024-01407 — Samsung Electronics Co., Ltd. v. Headwater Research LLC

• Institution decision (Paper 9) and a Director Review Decision (Paper 17) both dated 2025-03-20; Headwater filed a statutory disclaimer on 2025-01-02 (Ex. 3001). https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1558614](/patent/1558614)/download-documents

Other sibling filings surfaced (numbers verified from PTAB/P-TACTS or Docket Alarm pages, details not fully verified): IPR2023-01336 (Samsung v. Headwater); IPR2024-00341 (Samsung and Google, '733 patent); IPR2025-01572 (Apple Inc. v. Headwater Research LLC, U.S. 10,064,055); IPR2026-00049 (U.S. 9,179,359, petition served 2026-02-09); IPR2026-00138 (Google LLC v. Headwater Research LLC).

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Strategic summary

Claim status of '261. Because no IPR has ever been instituted against it, every claim of US 9,532,261 remains UNTESTED — none canceled, none sustained by the Board, none disclaimed via the IPR-driven statutory-disclaimer mechanism Headwater has used repeatedly on siblings. Contrast that with U.S. 8,589,541, where claims 1, 24–25, 27–40, 61–62, 65–78, 80–82, 84–90, 153–154, and 172–174 were disclaimed and claims 2–23, 26, 41–60, 63–64, 91–152, 155–171 were held unpatentable. The '261 specification is the same "System and method for wireless network offloading" disclosure that issued as '335, '471, '757, and '580 — so the disclosure has been litigated hard (the '335 patent is asserted in E.D. Tex. Case No. 2:25-cv-00916 alongside '471 and '757), even though this particular patent number has not.

Estoppel landscape. § 315(e)(2) estoppel runs patent by patent. A petitioner who litigated IPR2024-00942/00943 over the '541 patent is estopped as to the '541 patent only — that estoppel does not reach '261, and no petitioner is estopped as to '261 because no petitioner ever filed against '261. Practically, this cuts both ways:

• For a defendant: all prior-art grounds are available against '261 with no § 315(e)(2) bar. Nothing is off the table.
• Against a defendant: there is no pre-baked invalidity judgment to borrow. You cannot walk into court and say "the Board already killed claim 1" — the Board never looked at '261's claims.
• Watch the priority date. Headwater has contended the asserted siblings are entitled to a date "no later than May 25, 2010." '261 sits on the 12/380,778 (2009-03-02) / 2009-01-28 chain, so Headwater may claim 2009-01-28 for '261. If so, 2010-era references must be checked against a 2009-01-28 or 2010-05-25 date, and the answer materially changes the art you can use. Lock this down in your invalidity contentions before relying on a 2010 publication.

Pattern signals. Three are worth a defendant's attention:

1. Headwater files defensively by disclaiming. Rather than fight IPRs on the merits, Headwater has repeatedly used statutory disclaimers to kill challenged claims itself (see the '541 FWD and the 2025-01-02 disclaimer in IPR2024-01407). That is a rational strategy in litigation but catastrophic for a plaintiff who needs those claims at trial.
2. Headwater does not always appeal. The '541 FWD went unappealed. That is a signal to check whether Headwater is litigating to settle rather than to win.
3. No defensive aggregator is visible in the '261 chain. The petitioners are operating companies — Google, Verizon, AT&T, T-Mobile, Sprint, Samsung, Apple, Amazon, Motorola, Lenovo, Charter, Comcast, Walmart, Uber, Target, Supercell, Tencent. Unified Patents' portal shows '261 in its database but I found no Unified-filed IPR against it. '261 has all the hallmarks of a reserve continuation: a member of the family Headwater rotates into assertion when the initially asserted claims get killed.

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Recommended next steps

1. Do not represent to a court that '261 has been invalidated. It has not. Any argument built on "the PTAB already canceled these claims" is wrong as to this patent number and would be sanction-bait.
2. If you receive a '261 demand letter, check the asserted claims against the '541 outcome — not because it binds, but because it informs. If Headwater asserts claims structurally parallel to the canceled '541 claims, the same Rao/Oestvall/Freund/Wyld art family (and the same reasoning the Board accepted in the 2025-10-01 FWD at https://www.docketalarm.com/cases/PTAB/IPR2024-00942/Google_LLC_v._Headwater_Research_LLC/docs/10-01-2025-Board/Final_Written_Decision__original-20-Judgment_Final_Written_Decision_.pdf) is your starting point for an IPR petition on '261.
3. Anchor your priority-date fight now. Demand Headwater's § 282/priority contentions for '261 and pin it to either 2009-01-28 or 2010-05-25 before you invest in art.
4. Consider a preemptive IPR on '261. It is a "clean" patent — no prior IPR, no estoppel, no FWD — which means (a) you can choose your own art and forum timing without racing another petitioner, and (b) nobody has already told the Board what the strongest grounds are. If '261 shows up in Headwater's next assertion wave (and the 2025 W.D. Tex./E.D. Tex. filings suggest the waves are yearly), being first is worth a lot.
5. Trial-stage milestones: because no proceeding is pending, there are no statutory 1-year § 316(a)(11) deadlines, oral hearing dates, or FWD due dates to track. If you file, the clock runs: PO preliminary response at 3 months, institution decision at 6 months from petition, FWD at 12 months from institution.
6. Verify the negative once more before relying on it. Re-run the search on PTAB P-TACTS and the ODP AIA feed for "9,532,261" at the time you actually need it, since indexing lag is the one way this answer could be wrong.

I'll research the assignment record and litigation history before assembling the analysis.

Initial results are rich. Let me pull the specific assignment records and litigation coverage for this patent.

Let me pin down the reel/frame numbers for this specific patent and check its litigation role.

Ownership & Assignment Analysis — US 9,532,261 B2

Method note (read first): I could not query assignmentcenter.uspto.gov directly from this session — the records below are reconstructed from (a) the Google Patents legal-events ledger supplied in the authoritative patent text, and (b) certified copies of the actual USPTO Patent Assignment Cover Sheets that Headwater filed as exhibits in Headwater Research LLC v. Samsung (E.D. Tex. 2:22‑cv‑00422) and Headwater Research LLC v. Verizon (E.D. Tex. 2:23‑cv‑00352). Those exhibits carry the reel/frame numbers verbatim, so the merger reel/frame below is high-confidence. The reel/frame for the 2014 inventor→Headwater assignment on this specific application is NOT confirmed — I flag it rather than guess. Verify all reel/frames at the Assignment Center search: https://assignmentcenter.uspto.gov/ (mirror: https://assignment.uspto.gov/patent/index.html) and the Google Patents legal-events tab: https://patents.google.com/patent/US9532261/en

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Inventors

Unusual pattern — flagged: this is not the classic "all inventors leave the assignee within 12 months → fire sale" pattern. It is the inverse and more legally hazardous pattern: two of three inventors came from Qualcomm and were subject to pre-existing Qualcomm assignment agreements, while the filing entity (Headwater) was created by one of them. Qualcomm's asserted co-ownership became the central standing defense in litigation — Samsung's brief (Headwater v. Samsung, Dkt. 274, filed 2024‑05‑28) argues that because Raleigh filed the '354 provisional after leaving Qualcomm and Raissinia filed within a year of his departure, Qualcomm is a presumptive co-owner, and that Headwater's failure to join Qualcomm defeats standing. Qualcomm is not shown as an assignee on the face of the patent or in any recorded US assignment — the interest, if any, is unrecorded and contractual. That is a genuine chain-of-title cloud, and it is the most commercially significant fact in this ownership file.

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Original assignee

Headwater Partners I LLC, a Delaware limited liability company (not a corporation, despite the LLC suffix-bearing name).

• Addresses of record over time: 350 Marine Parkway, Suite 300, Redwood City / Redwood Shores, CA 94065 → 2995 Woodside Road, Ste. 400, Woodside, CA 94062 → 1011 Pruitt Place, Tyler, TX 75703 → currently 110 N. College Avenue, Tyler, TX 75702.
• Primary line of business: IP holding, licensing, and enforcement. Headwater does not manufacture.
• Did it ship a product embodying the claims? No, not itself. In its own litigation briefing, Headwater concedes it "does not manufacture and sell mobile devices," but states it licensed the technology to ItsOn Inc. — a company founded by the same inventor, Dr. Raleigh — which "implemented Headwater's technology into software and services" delivered to carriers and, per Headwater, ended up in smartphones. This is a licensor/licensee commercialization relationship, not a product business of the assignee.
• Current status: Dissolved by merger. Effective 2016‑12‑29, Headwater Partners I LLC merged into Headwater Management LLC, and the surviving entity was renamed Headwater Research LLC (Delaware). Headwater Research LLC is operating as an active licensor and serial plaintiff. No public-company filings exist (privately held); no Chapter 7/11.

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Assignment timeline

Two US recordings are confirmed for this chain. A third (reel 024248/0209) is the original assignment for the 2010 priority family, not this application — included for family context only and labeled as such.

1. 2010‑01 (executed) / recorded c. 2010‑04 — Reel 024248/0209 (FAMILY‑LEVEL ONLY — app 12/694,455 "Device Assisted Services Install", not US 14/156,428)

• Conveyance: Assignment
• Assignor: Gregory G. Raleigh and co-inventors
• Assignee: Headwater Partners LLC, a Delaware limited liability company
• Correspondent: Not captured in the retrieved cover sheet
• Context: Original inventor-to-holding-company assignment for the 2010 priority filings; establishes Headwater's root of title for the family.

2. 2014‑01‑15/16 (executed — INFERRED from filing + recording dates) / recorded 2014‑01‑17 — Reel/frame NOT CONFIRMED

• Conveyance: Assignment ("Assignment of Assignors' Interest")
• Assignor: Gregory G. Raleigh; Alireza Raissinia; James Lavine
• Assignee: Headwater Partners I LLC, Delaware (350 Marine Parkway, Suite 300, Redwood City, CA 94065)
• Correspondent: Not captured in retrieved records
• Context: Inventor assignment to the founders' own IP-holding LLC at the moment the continuation (14/156,428) was filed — routine, not a third‑party transfer.
• ⚠️ Google Patents records the event exactly as: "2014‑01‑17 — Assigned to HEADWATER PARTNERS I LLC … ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: LAVINE, JAMES, RAISSINIA, ALIREZA, RALEIGH, GREGORY G." I could not retrieve the reel/frame from the Assignment Center; retrieve it by patent number before citing it.

3. 2016‑12‑29 (effective/executed) / recorded 2017‑01‑04 — Reel 041248/0777 (also 041248/0778) ✅ CONFIRMED from certified cover sheet (EPAS ID PAT4210295 / PAT3993166)

• Conveyance: Merger and Change of Name
• Assignor: Headwater Partners I LLC (merging into Headwater Management LLC)
• Assignee: Headwater Research LLC (surviving entity; 1011 Pruitt Place, Tyler, TX 75703)
• Correspondent: Ann Taylor — Headwater's own in-house IP administrator, 1011 Pruitt Place, Tyler, TX 75703, patent@headwaterllc.com, tel. 903‑201‑6211; signed "/Ann Taylor/" as submitter. Recurring correspondent flagged: the same Ann Taylor is the submitter/signatory on other Headwater recordings in this family (e.g., assignment for app 15/227,814, signed 2016‑08‑04). Separately, Sheppard, Mullin, Richter & Hampton LLP (390 Lytton Ave., Palo Alto; svpatents@sheppardmullin.com; submitter "Marc A. ___") is correspondent on the Headwater Partners I LLC assignment for app 13/134,028. Important nuance: the recurring correspondent here is the patent owner's own docketing staff and its outside prosecution firm — this is not the "one NPE lawyer servicing many unrelated shell LLCs" pattern.
• Property count: 56 properties. The visible portion of the schedule lists neighboring family members (9,491,564; 9,521,578; 9,532,161 — note 161, a distinct patent from 261). I did not see US 9,532,261 printed by number in the excerpt I retrieved, so treat its inclusion in this 56‑property block as highly likely but not independently verified.
• Context: Internal reorganization / change of name only. No change of beneficial owner, no cash consideration, no new principal. Corroborated by Google Patents legal events ("2017‑01‑04 — Assigned to HEADWATER RESEARCH LLC … MERGER AND CHANGE OF NAME … Assignors: HEADWATER MANAGEMENT LLC, HEADWATER PARTNERS I LLC"), and internationally by the EP register entry for the family (INPI/EP: "24/04/2018 — Transmission totale de propriété", BOPI 2018‑21).

No other recorded US assignments exist in the chain. There is no sale to a third party, no security agreement, no license recorded against the patent, and no subsequent re-assignment.

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Timeline diagram

timeline
    title Ownership of US 9532261
    2008 : Raleigh leaves Qualcomm
    2009 : Priority provisional filed
         : Raissinia leaves Qualcomm
    2014 : Continuation filed
         : Inventors assign to Headwater Partners I
    2016 : Headwater merger effective
    2017 : Merger recorded reel 041248
    2022 : Samsung suit filed
    2023 : Verizon suit filed
    2025 : Samsung verdict for Samsung

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NPE / troll-pattern signals

1. Shell-entity transfer — UNCLEAR / NOT PRESENT as defined.
The patent did move to a licensing-only entity, but the mechanism was an internal merger and change of name, not a sale of the portfolio into a newly created shell. Pursuant to the Delaware Certificate of Merger filed 2016‑12‑29 15:02 (File No. 4966025, SR 20167326785), Headwater Partners I LLC merged into its own affiliate Headwater Management LLC, renamed Headwater Research LLC — same principals, no arm's-length purchaser. The original assignee was already an IP-holding LLC created by the inventor in 2008, so there was no operating-company-to-shell step to detect. Address of record (1011 Pruitt Place, then 110 N. College Avenue, Tyler, TX) is a business address of the owner, not a registered-agent service address. Do not call this a shell transfer on the name alone.

2. Known asserter in the chain — PRESENT (under the expanded "high-frequency plaintiff" definition).
Headwater Research LLC does not appear on the enumerated list (Acacia, Marathon, IV, Wi‑LAN/Conversant, Vringo, Pendrell, Round Rock, MPHJ, Spangenberg, etc.). However, it is indexed by Unified Patents as a recurring patent owner/defendant-side target, with a large IPR docket (e.g., IPR2024‑01397, IPR2024‑00945, IPR2025‑01572 against Headwater-owned patents), and its litigation footprint is extensive: Headwater v. Samsung 2:22‑cv‑00422; v. Verizon/Cellco 2:23‑cv‑00352; v. AT&T 2:23‑cv‑00397; and a 2025 wave against Charter (2:25‑cv‑00901), Comcast/Xfinity (2:25‑cv‑00903), and Amazon, Apple and others (2:25‑cv‑00904/00906/00908/00909/00914/00916/00919). This is a serial-assertion posture by any measure. Caveat: US 9,532,261 itself does not appear in any asserted-patent list I could retrieve; the suits assert siblings such as 8,589,541; 8,924,543; 9,198,042; 9,215,613; 9,973,930; 8,639,935; 9,609,510. Do not assert this specific patent has been litigated without checking the docket.

3. Repeat correspondent across the chain — PRESENT as recurrence, but NOT probative of troll structuring.
The chain's second recording (reel 041248/0777, recorded 2017‑01‑04) carries correspondent Ann Taylor, Headwater's own in-house IP administrator at 1011 Pruitt Place, Tyler, TX (patent@headwaterllc.com), and she recurs as submitter on other Headwater recordings in the family (e.g., app 15/227,814, signed 2016‑08‑04). Sheppard, Mullin, Richter & Hampton LLP (Palo Alto) appears as correspondent on the related app 13/134,028 assignment. That is two recurring correspondents for one corporate family — the opposite of the red-flag pattern, where one outside attorney services a series of nominally unrelated shell LLCs. Prosecution-side counsel of record in the IPRs is Farjami & Farjami LLP (26522 La Alameda Ave., Suite 360, Mission Viejo, CA), and litigation counsel is Russ August & Kabat (Marc Fenster, Reza Mirzaie et al.). None of these are on any published NPE-assertion correspondent list that I can confirm.

4. Cascading transfers — NOT PRESENT.
Two recorded links, ~3 years apart (2014 recording → 2017 recording), the second being an internal merger. No chained LLCs, no sub-24-month relay, no shared agent address across unrelated assignees.

5. Pre-litigation transfer — NOT PRESENT.
The last recorded transfer is 2017‑01‑04. The first Headwater infringement suit in this family (Samsung, 2:22‑cv‑00422) was filed October 2022 — roughly 5 years 9 months after the recording, far outside any 6‑month window. There is no assignment arranged to set venue or manufacture standing; if anything, the delay created the opposite problem (the Verizon court found implied waiver arising from Headwater's 2017 investigation and 2023 filing — Headwater v. Cellco, E.D. Tex., order dated 2026‑04‑22).

6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 proceeding involving Headwater Partners I LLC or Headwater Research LLC appears in the record. The entity's transition was a solvent Delaware §18‑209 merger.

7. Privateering — NOT PRESENT (direction is reversed).
Classic privateering is an operating company parking patents with an NPE that sues on its behalf. Here the inventor himself owns the asserting entity, and the commercializing licensee (ItsOn Inc.) was also founded by him; Verizon was even an investor in both Headwater and ItsOn under a 2010 investment agreement. There is no separate operating-company principal hiding behind the plaintiff.

8. Defensive aggregator / anti-NPE neutralization — NOT PRESENT.
The chain terminates at Headwater Research LLC, an active plaintiff, not at RPX, AST, LOT, Unified Patents, or OIN. The patent is not neutralized; it is in an assertive family.

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Verdict

NPE — moderate confidence.

Justification: The current assignee of record, Headwater Research LLC (surviving entity of the 2016‑12‑29 merger recorded at Reel 041248/0777 on 2017‑01‑04), is a non-practicing licensing and enforcement entity with no product line, which has sued Samsung, Verizon, AT&T, T‑Mobile, Motorola, Apple, Amazon, Charter and Comcast, and which a district court itself described in the Verizon action as "a sophisticated patent-assertion entity" — that satisfies one strong signal (high-frequency asserter, signal 2). But the recorded chain is short and clean: Reel 024248/0209 (inventor → Headwater Partners I, family-level) followed by Reel 041248/0777 (internal merger, name change only, same principals, corroborated by the Delaware Certificate of Merger). Aggravating factors typically required for a high-confidence call — a genuine shell transfer (signal 1), cascading LLC relays (4), a pre-suit transfer within 6 months (5), or a bankruptcy sale (6) — are all absent, and the asserting entity was created by the named inventor rather than acquired by a third-party aggregator. The call stops at moderate, not high, for exactly that reason, with one important caveat: an unrecorded Qualcomm co-ownership claim over the inventors' pre-existing Dec. 2006 assignment agreements clouds this title and is being pressed as a standing defect — worth reflecting in any acquisition or licensing diligence.

Verify at: https://assignmentcenter.uspto.gov/ (search by Patent No. 9532261; retrieve the 2014‑01‑17 reel/frame) and https://patents.google.com/patent/US9532261/en (Legal Events tab).

I'll search for the USPTO record and prior-art citations for US 9,532,261.

Let me pull the citation lists from the Justia and Google Patents records.

Now let me retrieve the actual cited references for the '261 patent.

Scope, method, and a hard limit up front

I searched for US 9,532,261 specifically (as instructed — no fuzzy/similar-number substitution). What I could and could not obtain:

I am not going to pad this with reference descriptions I cannot verify, because fabricating what a cited patent discloses is exactly how a § 102 chart goes wrong.

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1. Verified record

Legal-framework note that matters for every § 102 call below: because 14/156,428 is a divisional whose claims trace to a 2011 (and via 13/134,005 to 2009) filing, and no claim appears to have a post-2013-03-16 effective filing date, the pre-AIA 35 U.S.C. § 102/103 regime governs. That means § 102(a)/(b) "known or used / printed publication / patented" art is measured from the 2009 invention/priority date, and § 102(e) art must have a U.S. filing date before that date.

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2. The actual claim set of US 9,532,261 (36 claims, 8 independent)

This is the single most important thing that was missing from the earlier section, and it materially changes the § 102 analysis. Source: https://patents.justia.com/patent/20140133297 (Claims section; record cross-references "Patent Grant number: 9532261").

Independent claim 1 (server-side method):

obtaining, by a server, wireless-network performance data from a plurality of end user devices; generating, by the server, a prioritized network list from the wireless-network performance data; and provisioning, by the server, the prioritized network list to a particular end user device.

• 2–6 dependents: performance data = economic-performance (2), network-performance (3), temporal (4), geo-location (5), motion-trace (6) data.
• 7–10: the particular device is associated with the list based on current device-specific (8), historical device-specific (9), or account-specific (10) data.
• 11: server system (network interface + prioritized-network-list generation engine + provisioning engine).

Claim 12 (device-side method): receive prioritized network list from remote server (device identified by a characteristic); identify available wireless networks different from current network; use list to select one; disconnect from current; connect to selected.

• 13–15: characteristic = current/historical device-specific, or account-specific data.
• 16–18: connection automatic (16), by user selection (17), or based on user preferences (18).
• 19–21: notification including an incentive offer; economic incentive (20); network-performance incentive (21).
• 22: device apparatus counterpart.

Claim 23 (ANCS method): device monitors available wireless networks at a particular location at a particular time of day; generates an available-network-characteristic-scan report including location + time-of-day; provides it to a remote server.

• 24–30: schedule-initiated (24), request-initiated (25), passive (26), active (27), active only if plugged into power (28), economic-performance data (29), network-performance data (30).
• 31: device apparatus counterpart.

Claim 32 (incentive method): connect to cellular; identify other available networks; provide a notification of an incentive offer to the user to incent offload; receive acceptance; connect to one of the other networks in response.

• 33–35: economic incentive (33); network-performance incentive (34); acceptance = user selection of network (35).
• 36: device apparatus counterpart.

Confidence caveat: HIGH that this is the '261 claim set (Justia presents it on the record that explicitly identifies the grant number and lists this application's filing date/inventors), but I did not pull the issued patent's front page/claims from USPTO PatentCenter in this session. Treat the claim numbering as medium-high and the claim text as high.

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3. The citation list — what I actually got

3(a) Foreign patent documents — VERIFIED fragment (from the '261's own Justia record)

The record's "References Cited" section shows the following WO documents, in this order (the fragment begins mid-list, so earlier entries are missing):

Source: https://patents.justia.com/patent/9532261

⚠️ Anomaly I must flag rather than smooth over: WO 2010088413, WO 2011002450, WO 2011149532 and WO 2012047275 were published after the 2009 priority date. Under pre-AIA § 102 they cannot be anticipatory art for any claim entitled to the 2009 date. Either (i) the '261 has claims not entitled to full 2009 priority, (ii) these were cited for § 102(e) purposes against a later-filed family member and carried onto this list, or (iii) the Justia page aggregates family-wide references. I cannot resolve which from the retrieved data, and I will not guess.

3(b) Non-patent literature — VERIFIED fragment

Also printed on the '261 record:

• "Ads and movies on the run," the Gold Coast Bulletin, Southport, Qld, Jan. 29, 2008
• "Jentro Technologies launches Zenlet platform to accelerate location-based content delivery to mobile devices," The Mobile Internet, Boston, MA, Feb. 2008
• Jing et al., "Client-Server Computing in Mobile Environments," GTE Labs. Inc. / Purdue University, ACM Computing Surveys, vol. 31, No. 2, Jun. 1999
• Kim, "Free wireless a high-wire act; MetroFi needs to draw enough ads to make service add profits," San Francisco Chronicle, Aug. 21, 2006
• Koutsopoulou et al., "Charging, Accounting and Billing Management Schemes in Mobile Telecommunication Networks and the Internet," IEEE Communications Surveys & Tutorials, First Quarter 2004, vol. 6, No. 1
• Loopt User Guide, metroPCS, Jul. 17, 2008
• Nuzman et al., "A compound model for TCP connection arrivals for LAN and WAN applications," Oct. 22, 2002
• Richtel, "Cellphone consumerism; If even a debit card is too slow, now you have a new way to act on impulse: [National Edition]," National Post, Canada, Oct. 2, 2007
• Rivadeneyra et al., "A communication architecture to access data services through GSM," San Sebastian, Spain, 1998
• Sabat, "The evolving mobile wireless value chain and market structure," Nov. 2002
• Sun et al., "Towards Connectivity Management Adaptability: Context Awareness in Policy Representation and End-to-end Evaluation Algorithm," Dept. of Electrical and Information Engineering, Univ. of Oulu, Finland, 2004
• Tan Zu-guo, Wang Wen-juan, "End to End QoS Solution for Real-time Multimedia Application," Computer Engineering and Applications, 2007, 43(4): 155-159
• "ASA/PIX: Allow Split Tunneling for VPN Clients on the ASA Configuration Example," Document ID 70917, Jan. 10, 2008
• Ahmed et al., "A Context-Aware Vertical Handover Decision Algorithm for Multimode Mobile Terminals and Its Performance," BenQ Mobile (Munich) / Univ. of Klagenfurt, 2006
• Dixon et al. … (list truncated at this point in the retrieved fragment)

Source: https://patents.justia.com/patent/9532261

3(c) U.S. patent documents — PROXY ONLY (not verified as printed on the '261)

I could not retrieve the "U.S. Patent Documents" sub-list from the '261's own face. The best proxies are its direct sibling/continuation US 11,425,580 (same title, states it is a continuation of the '261) and its parent US 8,635,335 (same title, same inventors, app. 13/134,005 — the application the '261 was divided from). Retrieved fragments include:

From US 8,635,335 (parent): 5,283,904 Carson (2/1994); 5,577,100 McGregor (11/1996); 6,631,122 Arunachalam (10/2003); 6,639,975 O'Neal (10/2003); 6,640,097 Corrigan (10/2003); 6,650,887 McGregor (11/2003); 6,651,101 Gal (11/2003); 6,654,814 Britton (11/2003); 6,658,254 Purdy (12/2003); 6,675,516 Nordman (1/2004); 6,683,353 Kannas (1/2004); 6,684,244 Goldman (1/2004); 6,725,031 Walter (4/2004); 6,748,195 Phillips (6/2004); 6,754,470 Hendrickson (6/2004); 6,765,864 Natarajan (7/2004); 6,765,925 Sawyer (7/2004); 6,782,412 Brophy (8/2004); 6,785,889 Williams (8/2004); 6,829,596 Frazee (12/2004); 6,829,696 Balmer (12/2004); 6,839,340 Voit (12/2004); 6,873,988 Herrmann (3/2005); 6,876,653 Ambe (4/2005); 6,920,455 Veselotti (7/2005); 6,922,562 Ward (7/2005); 6,928,280 Xanthos (8/2005); 6,934,249 Bertin (8/2005); 6,947,723 Gumani (9/2005).

From US 11,425,580 (continuation of the '261 — the closer proxy for the '261's 1449): 5,131,020 Liebesny (7/1992); 5,283,904 Carson (2/1994); 6,658,254 Purdy (12/2003); 6,660,514 Walsh (12/2003); 6,678,516 Nordman (1/2004); 6,683,523 Kannas (1/2004); 6,684,244 Goldman (1/2004); 6,690,918 Evans (6/2004); 6,694,362 Secor (6/2004); 6,697,821 Lee (6/2004); 6,704,873 Underwood (3/2004); 6,725,031 Walter (4/2004); 6,725,256 Albal (4/2004); 6,732,176 Stewart (5/2004); 6,735,206 Wolf (5/2004); 6,748,195 Phillips (6/2004); 6,748,437 Mankude (6/2004); 6,751,296 Albal (6/2004); 6,754,470 Hendrickson (6/2004); 6,757,717 Goldstein (6/2004); 6,760,417 Wallenius (7/2004); 6,763,000 Walsh (7/2004); 6,763,226 McZeal, Jr. (7/2004); 6,765,864 Natarajan (7/2004); 6,765,925 Sawyer (7/2004); 6,782,412 Brophy (8/2004); 6,785,889 Williams (8/2004); 6,792,461 Hericourt (9/2004); 6,829,596 Frazee (12/2004); 6,829,696 Balmer (12/2004); 6,839,340 Olli (12/2004); 6,842,628 Arnold (1/2005); 6,873,988 Herrmann (3/2005); 6,876,652 Ambe (4/2005) … (both fragments truncated; actual lists run to 100+ entries, dominated by 2001–2010 network/billing/policy art).

Sources: https://patentimages.storage.googleapis.com/16/42/fa/bc09538d91c45f/US8635335.pdf and https://patentimages.storage.googleapis.com/7c/5f/bc/0999dcbd3e569b/US11425580.pdf

I will not attach "brief descriptions" to these U.S. numbers. I do not have their verified abstracts in hand, and describing them from memory would risk fabricated § 102 content. Where I have a defensible description below, I say so explicitly.

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4. § 102 analysis — what can and cannot be asserted

4(a) References I can map to claims with defensible reasoning (from their own titles/disclosed subject matter)

Because the '261's independent claims are unusually narrow and generic (a server that crowd-sources wireless-network performance data from multiple devices and pushes a prioritized list; a device that receives such a list and switches; incentive offers to induce offload), the most dangerous art is any reference disclosing crowd-sourced/centralized network-performance collection + a ranked network list handed to the device.

4(b) The WO references — § 102 posture

• WO 2007107701 through WO 2009008817 (pub. Sep. 2007 – Jan. 2009): pre-2009-date publications, so they are facially available as § 102(a)/(b) art. Which claims they touch depends entirely on their disclosures, which I have not verified — I am not going to guess from the numbers.
• WO 2009091295 (Jul. 2009) and everything after: these cannot be § 102(a)/(b) art against claims entitled to the 2009-01-28 priority date, and cannot be § 102(e) art either (their international filing dates necessarily postdate the applicant's 2009 filings). See the anomaly note in § 3(a).

4(c) The U.S. patent-document citations

These are the standard defensive-citation corpus for this family (network policy, billing/mediation, traffic attribution, and device-agent art from 1994–2010). To call any of them "anticipatory under § 102" of a specific claim, I would need to read the reference's disclosure against that claim element-by-element. I am explicitly declining to produce that mapping from memory, because the risk of fabricating a disclosure is high and the consequence (a wrong § 102 chart) is severe. Two observations I can make safely:

1. Timing: every U.S. patent listed (5,131,020 through the mid-2000s numbers) issued well before the 2009 priority date, so all are facially available as § 102(a)/(b) art — the only question is disclosure, not date.
2. Subject matter mismatch is likely for most of them. The '261's independent claims are directed to wireless network performance data collection + prioritized list provisioning + offload (server-side, claims 1/11) and receiving a list and switching + incentive offers (device-side, claims 12/22/32/36). The bulk of the family's cited corpus is billing, mediation, policy-enforcement and traffic-attribution art — i.e., more probative against the other Headwater patents than against the '261. The genuinely dangerous art for the '261 sits in the network-selection/vertical-handover/ANDSF literature, not in the billing corpus. That is precisely why the Ahmed, Sun, and Jing NPL items appear on this record.

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5. Explicit contradictions / identifier warnings (carried forward and extended)

1. US 8,635,335 B2 is a different patent with the identical title and identical inventors. It is the '261's parent (app. 13/134,005). Its claim 1 ("A method for reducing congestion on a wireless cellular network… communicating a first set of one or more data communications over a wireless cellular connection… identifying an alternative wireless network… instruction set for offloading… at least one rule that takes into account at least one state associated with the wireless cellular connection") is not the '261's claim 1. Do not import it. Any § 102 analysis written against the 8,635,335 claims is analyzing the wrong patent.
2. US 11,425,580 B2 shares the title and is a continuation of the '261 — usable as a citation proxy, not as the '261 itself.
3. "The '261 Patent" in PTAB petitions (earliest priority Aug. 7, 1996; parent US 6,111,869; CDMA alert codes) is a completely different patent. Excluded.
4. WO1995032261A1 (liquid-crystal compounds) matched on the digit string only. Excluded. Likewise the WO 2007107701-style Justia formatting shows how easily 8-digit WO strings get mis-OCR'd into the digit string "9532261."
5. Priority-date discrepancy persists: Google Patents 2009-01-28 vs. Unified Patents 2009-01-27 (https://portal.unifiedpatents.com/patents/patent/US-20030005112-A1 lists US-9532261-B2 at priority 2009-01-27). This single day is not academic here — it controls whether any reference published 2009-01-27/28 is § 102(a) art. Resolve it from the patent's own priority claim before relying on any borderline-dated reference.
6. Continuity conflict to resolve: the record above shows US 14/156,428 (the '261) was filed 2014-01-15 as a divisional of 13/134,005, but 13/134,005 is itself the application that issued as 8,635,335. The '261 therefore sits in a chain that also reaches the 12/380,783 (2009-03-02) and 12/694,xxx/12/695,xxx (2010-01-27/28) filings listed in the Google Patents priority block. Which link supplies the claims' effective filing date is unresolved from the retrieved data — and it determines the § 102 cutoff.

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6. Bottom line

• The '261's claims are now known (36 claims; independents 1, 11, 12, 22, 23, 31, 32, 36) — this is new relative to the earlier section and supersedes the "inference only / LOW confidence" § 4 there. The claim-1 insight is that this patent is not about the cellular-connection-state rule of 8,635,335; it is about server-side crowd-sourced performance data → prioritized list → provisioning, plus device-side incentive-offer-driven offload and location/time-stamped ANCS reporting.
• I obtained only a truncated citation list for the '261 itself: 17 WO documents and ~15 NPL items are verified as printed on its record; the U.S. patent-document sub-list is confirmed only by proxy through its parent and continuation.
• The most relevant prior art for the '261, on the record as it stands, is the network-selection / vertical-handover NPL (Ahmed 2006; Sun 2004; Jing 1999), with the charging/billing NPL (Koutsopoulou 2004) bearing on the economic-performance and incentive-offer claims, and the 2007–2008 press items bearing on incentive-offer commercial context. I have not verified element-by-element disclosure for any of them, so I am labelling these as potentially relevant, not anticipatory.
• To finish the § 102 job properly, pull the '261's Form PTO/SB-08 (1449), the examiner's search notes, and the issue-file "List of references cited by examiner" from USPTO PatentCenter for application 14/156,428 — the same document types I found generated for the sibling 16/272,098 (which produced US 10,791,471). With that list, plus the '261's confirmed issue-date priority claim, the § 102 chart can be completed without guesswork. I can build it as soon as those documents are in hand.

Obviousness Analysis — U.S. Patent No. 9,532,261 ("System and method for wireless network offloading")

0. Critical evidence limitation (read first)

I could not obtain the two inputs the task assumes I have:

1. The claim set of US 9,532,261. The authoritative full text supplied to me was truncated after the FIG. 15 / flowchart 1500 passage (it ends mid-sentence at "the network busy state can include a"). The Abstract, Claims, and "References Cited"/Prior-Art sections of the Google Patents page were not in my copy.
2. The "Prior Art section of this page." My searches did not return the References Cited / Cited By / Similar Documents tables for US 9,532,261 specifically. The closest I got was the cited-reference list of sibling family members (US 8,635,335; US 11,425,580), and unrelated patents' (56) lists.

Per the strict rule, I am not going to fabricate a claim set or a prior-art list. Everything in §§3–5 below is therefore built from (a) the specification text I do have, (b) verified sibling-patent claim language that appears in search results, and (c) prior art verified to exist by publication date. Where I infer claim scope, I say so explicitly, and no statement below should be used as a claim-construction position.

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1. Critical-date analysis (this drives the entire § 103 analysis)

The § 103 analysis is only as good as the effective filing date, and this family has three competing dates:

This is the single most important issue for any obviousness challenge: US 13/134,005 is described on its face as a continuation-in-part. Subject matter added in the 2011 CIP gets a 2011 effective date, not 2009. If the asserted claim limitations (e.g., the "prioritized network list," "motion trace," "incentive offer," "multi-dimensional network map" concepts) were added in the CIP, then 2009–2011 art becomes available that would not be available against a true 2009-01-28 priority date.

The '261 patent was filed 2014-01-15 as a continuation. Under the AIA transition rules, if every claim is entitled to pre-2013 priority it is tried under pre-AIA §§ 102/103; if any claim has an effective filing date on/after 2013-03-16 it flips to AIA §§ 102/103. I flag this because it changes whether § 102(a)/(e) art counts and whether the "otherwise available to the public" catch-all of AIA § 102(a)(1) is available for the standardization documents discussed in § 4.

I do not have an authoritative priority determination and am not making one.

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2. What the claims most plausibly require (INFERENCE — not verified claim text)

Because I cannot quote the '261 claims, I anchor on the same-specification siblings whose claim language is in the search results, and on the specification you supplied:

US 8,635,335 (same title, same inventors, same spec), claim 1 — as reproduced in the Headwater v. DISH complaint analysis (2:25-cv-00920):

communicating a first set of data communications over a wireless cellular connection;
identifying an alternative wireless network;
based on electronically processing an instruction set for offloading from the cellular network to the alternative network, determining whether to communicate the second set of data communications over the alternative network or the cellular connection;
wherein the instruction set comprises at least one rule that takes into account at least one state associated with the wireless cellular connection.

US 10,791,471 (child of the '261 family chain), claim 1 — per the same complaint analysis:

identifying alternative wireless networks; obtaining current performance data on them; sending a network characterization report to a network element (comprising information on the alternatives and device-specific information); receiving data about the alternatives responsive to the report and customized to the wireless device; characterizing; applying rules to determine whether to switch.

US 9,532,261's own specification (verified text) discloses: ANCS reports; a wireless network offloading engine 106; prioritized network lists / multi-dimensional network maps; historical and remotely obtained data; temporal adjustment; motion trace / location trace; performance/reliability thresholds to prevent frequent hopping; incentive offers; and the FIG. 14 loop (obtain data → generate prioritized list → connect → monitor → repeat).

I will treat as the working hypothesis a claim set that recites some combination of: (i) obtaining wireless network data (ANCS); (ii) generating a prioritized network list from it; (iii) providing the list / an instruction set to a wireless device; (iv) the device offloading from cellular to Wi-Fi based on a rule accounting for a state of the cellular connection or a performance threshold; and (v) monitoring performance and updating.

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3. Prior art actually verified to exist and to predate the relevant dates

Grounding note: the only "References Cited" lists my searches returned belong to siblings (US 8,635,335 and US 11,425,580), not to '261. I present them as candidate art of the same technical character, not as "the prior art on the '261 face."

Caveat I must state plainly: several of the most useful items (ANDSF/23.402, 802.21-2008) are standards documents, and my search results did not return their verbatim text for me to quote paragraph-by-paragraph. I am relying on my knowledge of those standards, which is moderate, not high, confidence as to precise section numbers. They should be pulled and cited by section before any petition is filed.

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4. The threshold § 103 problem the patent faces

The specification itself is the best evidence of obviousness in places. Verified quotes from the '261 text:

• "Wireless networks such as Wi-Fi, 2G, 3G, 4G and WiMAX … often overlap with one another." — the problem is admitted to be pre-existing and well known.
• "The choice is generally made based on user selection, whether or not a better selection is available for a given situation." — the identified deficiency is simply that selection was manual/suboptimal. That is a classic "improve the prior art" framing, which under KSR Int'l Co. v. Teleflex is evidence of obviousness, not nonobviousness.
• "a technique of a similar type is often referred to as network load balancing." — the patent expressly concedes that the connection-count-based prioritization of FIG. 6 is a known technique.
• The "prioritized list" is defined comparatively weakly: a "prioritized list" is defined as a sorted list that is further sorted using historical and/or remotely obtained data. That is a data-organization distinction, not a technical advance — vulnerable under KSR's "familiar elements according to known methods" rationale.

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5. Obviousness combinations

Below I give four independent theories. Motivation is supplied in KSR-recognized categories: (a) known problem/known solution, (b) predictable result, (c) design incentive / market pressure, (d) explicit teaching or suggestion in the references, (e) "obvious to try" over a finite set of identified options.

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Combination A — ANDSF/TS 23.402 + IEEE 802.11k-2008 + 3GPP TS 23.829 (SIPTO) — the "network-generated prioritized list + measurement-driven offload" theory

Primary reference: 3GPP TS 23.402 (ANDSF), which provides policies and access network discovery information with an explicit priority order sent from a network-side function to the UE so the UE can select and hand over between 3GPP and non-3GPP access (Wi-Fi).
Secondary 1: IEEE 802.11k-2008 (the specification itself incorporates 802.11k-2008 by reference — verified text) supplies beacon/measurement reporting and neighbor reports, i.e., the ANCS mechanics.
Secondary 2: 3GPP TS 23.829 SIPTO/LIPA + Motorola S2-095964 supplies the offload purpose (relieve the cellular RAN by moving selected traffic to local/Wi-Fi access).

Mapping (to the inferred claim elements of §2):

• "obtain wireless network data" → 802.11k measurement/beacon reports; ISRP discovery information.
• "generate a prioritized network list" → ANDSF's prioritized inter-system mobility policy / discovery information. The word "prioritized" is not novel to the patent.
• "provide the list to the wireless device / instruction set" → ANDSF pushes policy to the UE; the UE applies it.
• "offload based on a rule accounting for a state of the cellular connection" → SIPTO/LIPA offload triggers; ANDSF rules conditioned on access-network availability/quality.
• "monitor performance and loop" → 802.11k periodic measurement reporting.

Motivation, stated as a POSITA would:

1. ANDSF and SIPTO were designed by the same standards body for the same problem the '261 patent addresses — cellular congestion relief via Wi-Fi offload. Combining them is not merely "obvious to try"; it was the stated roadmap of 3GPP.
2. The specification's own definition of "prioritized list" (a sorted list further sorted with historical/remotely obtained data) is met by ANDSF's straightforward extension of ISRP to historical data — predictable result.
3. Improving selection from user-driven to network-driven is the admitted purpose of the invention, so a POSITA would have looked to any network-side prioritization mechanism.

Principal vulnerability of this combination: if the '261 claims require genuinely device-derived, crowd-sourced network characterization (ANCS reports aggregated across many subscribers with scanning assignments to divide the reporting burden), ANDSF alone does not disclose that. § 5 of the specification's "Each wireless device can be given scanning assignments …" is a candidate nonobvious hook — Combination A would need Combination C or D to close it.

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Combination B — US 5,283,904 (Carson) + US 6,650,887 (McGregor) + 802.11k/802.21 — the "carrier-side multi-network service control" theory

References: Carson et al. (multi-system wireless service control/selection) and McGregor et al. (mobile data service control), both cited on the face of the same-spec sibling US 8,635,335, plus 802.11k-2008 / 802.21-2008 for the heterogeneous-access measurement and handover mechanics.

Theory: The '261 claims' core — a network-side engine that decides when a device should use one wireless network versus another based on a rule/state — is disclosed by Carson/McGregor, and the "alternative wireless network" element is closed by the well-known existence of Wi-Fi/cellular interworking (evidenced by 802.21-2008 and the SIPTO art).

Motivation: combining a service-control/multi-network architecture (Carson, McGregor) with a known heterogeneous-access handover standard (802.21) yields only the predictable combination of two known functions; KSR ("combination of familiar elements according to known methods is likely obvious when it does no more than yield predictable results").

Vulnerability: Carson (1994) and McGregor (2003) predate Wi-Fi offload as a named concept and are likely to be attacked as non-analogous with respect to Wi-Fi specifically. Also, if the claims require performance thresholds to avoid "frequent hopping," the obviousness story is weaker — though the specification itself frames the threshold as a conventional engineering tradeoff ("Even if a second network has a higher geo-priority … it may not be desirable to switch because of the risk of switching back and forth"), which is almost an admission that the threshold is an obvious design choice.

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Combination C — ANDSF/23.402 + 802.11k-2008 + US 2009/0318124 (Haughn) or WO 2009/118661 (Nortel) — the "crowd-sourced reporting + network-side list customization" theory

References: ANDSF (network-side prioritized discovery/policy); 802.11k (device measurement reporting); Haughn / Nortel (WLAN/cellular interworking and measurement reporting), as cited in the ISRs surfaced in the search results.

Theory: This is the combination aimed at the '471-style limitations (send a network characterization report comprising network info and device-specific information; receive data customized to the device responsive to the report). Each element has a direct analogue: 802.11k supplies the measurement-report uplink; ANDSF supplies the customized, prioritized downlink; Haughn/Nortel supply the interworking context in which such reporting is routine.

Motivation: (i) Design incentive — the more the network knows about local Wi-Fi conditions, the better it can steer traffic; a POSITA has a strong incentive to feed device measurements into the network's selection function. (ii) Explicit suggestion — 3GPP's own ISRP framework already contemplated UE-reported information as an input. (iii) Predictable result — feeding one known report into a known policy engine.

Vulnerability: the closest art may not disclose customizing the returned data to the requesting device versus broadcasting a common policy. A petitioner would need a secondary reference teaching per-subscriber policy generation (e.g., a subscriber-profile/policy art). Note this is exactly the limitation the DISH complaint chart maps to the Android Wi-Fi Suggestion API — i.e., the accused functionality is a generic OS feature, which cuts toward obviousness.

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Combination D — Any of A–C + a location/motion-trace reference — the "geo-prioritized network map" theory

References: Combination A or B, plus a location-services reference supplying device location and velocity for network selection (the ISR art in the search results includes mobility/position-based selection, e.g., Haughn; and the specification admits GPS/triangulation location estimation as conventional).

Theory: The FIG. 5 "motion trace" and FIG. 4 "geo-prioritized networks datastore" limitations reduce to: (i) detect location (admitted conventional); (ii) timestamp it; (iii) compute velocity from successive locations; (iv) filter the network list by predicted coverage duration.

Motivation: Steps (i)–(iii) are arithmetic on known data — the specification literally describes them that way ("By comparing the location associated with a first timestamp to a location associated with a second timestamp, it is possible to determine velocity as well as distance"). Step (iv) is a known design choice to avoid connecting to networks the user will leave (the specification concedes the analogous reasoning is used in "connection history"). Under KSR, "[a] person of ordinary skill is also a person of ordinary creativity."

Vulnerability: if the claims require the "constructive velocity" concept (a modified velocity that accounts for predicted future motion — a genuinely inventive-seeming twist in the spec), the art probably does not disclose it, and KSR "obvious to try" would be a stretch. This is the strongest candidate for a nonobvious limitation in the whole specification.

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6. Where an obviousness challenge would likely fail (be candid about this)

1. Scanning-assignment coordination across subscribers. The specification's "Each wireless device can be given scanning assignments to ensure that the reporting task is shared among subscribers or adjusted to fill in gaps in data" is a specific, non-trivial crowd-sensing coordination mechanism. I saw no reference in my search results disclosing assigned, partitioned scanning duties. This is the best nonobviousness argument in the disclosure.
2. "Constructive velocity" / net-velocity vs. speed for offload decisions (FIG. 5). Distinctive; likely absent from the art.
3. The incentive-offer loop (FIGS. 8–10) — if claimed, coupling a dynamic incentive state to the offload decision (rather than to billing generally) may survive, though the specification's own framing ("The incentive states 912 can indicate to a subscriber an 'incentive offer' that may entice the subscriber to choose one network over another") is a business-method-flavored concept with weak technical grounding.
4. The performance-threshold hysteresis to prevent hopping — I'd expect this to be found obvious (it's a standard hysteresis concept), but if the claim recites a specific dynamic threshold function tied to a cost-function output, the burden shifts.

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7. Secondary considerations (objective indicia) — what to check

• The search results show a $278.8M jury verdict (Headwater v. Samsung, E.D. Tex. 2:23-cv-00103, 2025-04-25) and a reported $175M verdict (Headwater v. Verizon, 2:23-cv-00352) — but I cannot confirm from these results that '261 was among the asserted patents in either. Do not attribute nexus to '261 on the basis of those verdicts. See the prior-section caveat: no source in my results ties '261 to a specific asserted-patent list.
• Copying: the DISH complaint describes the accused feature as Android's automatic Wi-Fi/cellular selection and Google Fi's "W+" curated hotspot network — which, if anything, supports independent development / prior art in the OS layer, not nexus.
• Long-felt need / licensing: ItsOn (founded 2008, licensed Headwater IP) is a licensing/implementation story, not evidence of failure of others.

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8. Bottom line and recommended next steps

Bottom line: The '261 claims, as best I can infer them from the specification and same-spec siblings, sit squarely in a crowded 2007–2009 art space (3GPP ANDSF/ISRP, SIPTO/LIPA, IEEE 802.21-2008, IEEE 802.11k-2008, plus U.S. cellular/WLAN interworking patents such as Carson, McGregor, and the Haughn/Nortel/Fu/Marinier applications). A strong KSR-style § 103 case is available against the prioritized-network-list + threshold-based offload + report-and-receive-customized-data subject matter via Combination A and Combination C. The scanning-assignment and constructive-velocity limitations are the most likely to survive a § 103 attack and should be the focus of any validity defense; any petition that ignores them risks a clean escape.

What I could not do, and what you should do next:

1. Pull the actual claim set of US 9,532,261 from USPTO PatentCenter or the Google Patents "Claims" tab. I could not obtain it, and every element-by-element mapping above is inference.
2. Pull the actual "References Cited" / "Prior Art" tables from the '261 Google Patents page (my searches returned sibling lists instead). If the examiner-cited art overlaps with what I've identified, that materially strengthens the § 103 case.
3. Resolve the priority date (2009-01-28 per Google Patents vs. 2009-01-27 per Unified Patents, with a 2011-05-25 CIP in the chain). This is dispositive for whether the 2009–2011 standardization documents and applications qualify as art.
4. Verify the standards text for 3GPP TS 23.402/ANDSF and IEEE 802.21-2008 by section number before relying on them; my confidence on their content is moderate, and I am flagging that rather than presenting it as verified.

Explicit non-assertions: I did not treat 9,522,261, 10,237,757, 10,791,471, 8,635,335, or US 8,633,335 as US 9,532,261; I did not repeat the earlier CDMA/"'261 Patent" confusion; and I have not attributed the US 8,635,335 abstract to the '261 patent.