Invalidity dossier

US 9542118

Expositive flash memory control

Current assignee: Samsung Electronics Co., Ltd., Samsung Electronics America, Inc.

Added 9/24/2026, 3:13:17 AM

At a glanceNo PTAB challenges2 lawsuits on fileasserted by Samsung Electronics Co., Ltd. +1Semiconductor (T)

Active provider: DeepSeek · deepseek-flash

Patent summary

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

✓ Generated

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

Let me dig into the claim set and litigation/appeal status.

Let me verify the claim set (independents) and check for any CAFC appeal activity.

US 9,542,118 B1 — "Expositive flash memory control" (as literally numbered: 9542118)

Caveat on the request: I could not confirm any Court of Appeals for the Federal Circuit (CAFC) 2026 docket involving this patent number. Details on the litigation/appeal question are in the last section, with the searches I ran and their limits stated explicitly.


Bibliographic data (confirmed)

Field Value
Patent number US 9,542,118 B1 (Google Patents renders it "US9542118B1")
Title Expositive flash memory control
Application no. 14/880,529
Filing date 2015-10-12 (Google Patents "Filing date"; FreePatentsOnline agrees)
Issue/publication date 2017-01-10
Priority / prior-art date 2014-09-09 (Google Patents "Prior art date"); priority chain includes provisional 62/063,357 (2014-10-13)
Inventors Robert Lercari; Alan Chen; Mike Jadon; Craig Robertson; Andrey V. Kuzmin
Original assignee Radian Memory Systems LLC
Current assignee Radian Memory Systems LLC (per Google Patents); FreePatentsOnline lists "Radian Memory Systems, LLC"
Status Active (Google Patents); anticipated expiration 2035-09-08
Classifications G06F 12/1009, G06F 12/109, G06F 3/06, G06F 12/02, G06F 12/0246 and related
Litigation flag Google Patents shows "Family has litigation" (Darts-IP family 57705973)

Source: https://patents.google.com/patent/US9542118B1/en and https://www.freepatentsonline.com/9542118.html

Priority relationship (from the specification, confirmed in the text you supplied): the application is a continuation-in-part of US 14/848,273 (filed 2015-09-08, "Techniques for Data Migration Based On Per-Data Metrics and Memory Degradation"), and claims benefit of provisionals 62/199,969 (2015-07-31), 62/194,172 (2015-07-17) and 62/063,357 (2014-10-13). It also incorporates by reference US Pub. 2014/0215129 ("Cooperative Flash Memory Control") and US 9,229,854.


Abstract (verbatim)

"This disclosure provides techniques of hierarchical address virtualization within a memory controller and configurable block device allocation. By performing address translation only at select hierarchical levels, a memory controller can be designed to have predictable I/O latency, with brief or otherwise negligible logical-to-physical address translation time. In one embodiment, address transition may be implemented entirely with logical gates and look-up tables of a memory controller integrated circuit, without requiring processor cycles. The disclosed virtualization scheme also provides for flexibility in customizing the configuration of virtual storage devices, to present nearly any desired configuration to a host or client."


Plain-language overview of the independent claim(s)

Claim 1 (independent — the claim I can confirm as independent from the granted-claim text): A flash memory device comprising two elements:

  1. A flash storage whose storage locations sit inside hierarchically arranged structural elements, where each element at a higher level gives access to a subset of elements at the level below (e.g., channel → die → erase unit → page).
  2. A memory controller that, when it receives an incoming address value with a memory access command, does not simply decode the address field-by-field. Instead it generates multiple hierarchical sub-address values (one per hierarchical level), and at least one of those sub-addresses is produced at least in part using a modulo operation — i.e., it takes a remainder of (at least part of) the incoming address divided by the number of access-enabled structural elements at that level. At least one of the resulting hierarchical sub-address values is a virtual address.

In plain terms: the incoming host address is treated as a mixed-radix tuple (channel value, die value, erase-unit value, page value). The controller recovers the individual tuple members, including at least one by taking a modulus against the configured count of usable elements at that level, and at least one of the recovered values is a virtual (remappable) address rather than a fixed physical one. This lets the controller remap at a chosen level (e.g., substitute a spare erase unit) while still guaranteeing the host that the address stays inside the specified parent structure.

Claim 30 (appears to be an independent claim — see uncertainty note below): A flash memory device where the hierarchical sub-addresses map to channel address, die address, erasable-unit address and page address, with communication channels coupling the controller to at least one flash die each. Source: https://www.patents-review.com/a/14880529-expositive-flash-memory-control.html

Dependent claims (examples I could confirm):

  • Claim 2: the dies form one hierarchical level; the number of dies is register-configurable, and the modulo operation for that level depends on that programmed number.
  • Claim 3: same idea applied to communication channels.
  • Claim 4: a hierarchical sub-address selects an address translation table dedicated to a specific structural element at a level below the top; the remainder from the modulo operation is applied to that table to obtain a physical address, mapping to erasable units or programmable (page) units.
  • Claim 5: that level is the die level, where each die has an access-enabled set plus a reserve set of erase units, and the controller performs defect management by substituting a reserve erase unit for a defective one.
  • Claim 6: the same reserve-substitution scheme applied at the erase-unit/page level.

These claim texts come from a third-party patent-data mirror (https://companyprofiles.justatic.com/patent/9542118). I did not independently verify them against the USPTO full-text/PatentCenter image, so treat them as high-confidence-but-secondary-sourced.


What I could not confirm (explicit uncertainty)

  1. Total claim count and number of independent claims. I confirmed claim 1 as independent. The claim text I retrieved for "claim 30" is labeled as being from application 14/880,529, which may be the pre-grant publication claim set rather than the granted claim set (published claims commonly differ from granted claims after prosecution). I therefore cannot state with confidence whether the granted patent has 20, 30, or some other number of claims, or how many independent claims it has.
  2. No CAFC 2026 docket found for 9542118. My searches surfaced (a) the Google Patents "family has litigation" flag pointing to Darts-IP family 57705973, (b) Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. / [[Samsung Electronics America](/litigations/by-defendant/Samsung%20Electronics%20America), Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.), No. 2:24-cv-01073-JRG (E.D. Tex.), and (c) Samsung Electronics Co., Ltd. v. Radian Memory Systems LLC, IPR2025-01266 (PTAB), which the docket shows was terminated — settled prior to institution on 2025-12-30. Neither the IPR docket entry I retrieved nor the district-court documents I retrieved identified 9542118 as the patent at issue. The asserted-patent list in the Radian v. Samsung complaint materials I saw named U.S. 11,544,183; 11,709,772; 11,681,614; 11,740,801; 11,347,657; 11,347,656; and 11,307,995 — 9542118 was not on that list. So: I have no authoritative evidence that 9542118 is (i) asserted in the 2:24-cv-01073 action or (ii) on appeal at the Federal Circuit in 2026. I ran out of search steps before I could query a Federal Circuit docket directly (e.g., CAFC CM/ECF or Docket Alarm's appellate coverage), so I am flagging this as unverified rather than affirmatively negative.
  3. Assignee chain detail. Google Patents' reassignment entries show a 2016 change of name from Radian Memory Systems, LLC → Radian Memory Systems, Inc., and a 2024-05-20 assignment back to "RADIAN MEMORY SYSTEMS LLC." FreePatentsOnline still lists the assignee as "Radian Memory Systems, LLC." I have not verified the current chain of title against USPTO Assignment records directly.

Search queries used: US patent 9542118 Expositive flash memory control; 9542118 patent Radian Memory Systems CAFC 2026 docket; "9542118" claim 1 "flash memory device" memory controller hierarchical sub-address modulo; Radian Memory Systems Federal Circuit appeal docket 2026 Samsung IPR. All patent-number lookups were run on the literal string 9542118; no similar/adjacent patent numbers were substituted.

Generated 10/1/2026, 4:32:46 PM

Cases on file (2)

Group view →

Specific litigation cases in our database that name US patent 9542118. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

✓ Generated

I'll search for litigation involving US patent 9542118 across patent litigation sources.

Let me search more specifically to determine whether US 9,542,118 itself is asserted in any case.

Let me check whether US 9,542,118 itself was ever asserted or challenged, and look for other Radian litigation.

Summary of findings for US Patent 9,542,118

Direct answer: Based on my searches, I found no litigation in which US 9,542,118 ("the '118 patent") is itself an asserted patent-in-suit. The '118 patent appears in the public record only as (a) a parent/ancestor of patents that have been asserted in litigation, and (b) a cited prior-art reference in prosecution. I could not confirm any complaint, IPR, or other proceeding that directly names the '118 patent as a challenged or asserted patent. I flag this as a negative finding subject to the caveat below.


The patent

The one district-court case in the family

The relevant family litigation is:

Field Detail
Plaintiff Radian Memory Systems LLC
Defendants Samsung Electronics Co., Ltd. and [[Samsung Electronics America](/litigations/by-defendant/Samsung%20Electronics%20America), Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.)
Jurisdiction U.S. District Court, Eastern District of Texas (Marshall Division), Judge Rodney Gilstrap
Case No. 2:24-cv-01073-JRG
Filed December 24, 2024 (Dkt. 1, a 347-page complaint)
Patents asserted US 11,347,656 B1; US 11,740,801 B1; US 11,307,995 B1; US 11,681,614 B1; US 11,709,772 B1; US 11,347,657 B1; US 11,544,183 B1 — the '118 patent is NOT among them
Status Radian withdrew its corrected preliminary-injunction motion on July 11, 2025 (Dkt. 64) and, after Samsung's sworn testimony, moved to dismiss the case without prejudice under Rule 41(a)(2)/12(b)(1) on July 17, 2025 (Dkt. 69). Samsung opposed and sought to keep its invalidity counterclaims. The motion-to-dismiss outcome is not reflected as final in the sources I retrieved.

The '118 patent's connection to that case

The '118 patent is a parent (ancestor) of three of the asserted patents. From Radian's complaint (¶¶ 475–476):

"The examiner also cited Radian's U.S. Pat. No. 9,542,118 ('the '118 Patent')." … "The '656, '657, and '995 Patents asserted by Radian in this action are descendants of Radian's '118 Patent, which was cited against Samsung's '631.5 Application."

So the '118 patent is present in the dispute as a genealogical ancestor and as a piece of prosecution history (it was cited during prosecution of Samsung German Patent App. No. 10 2019 118 631.5), not as a claim asserted against Samsung.

The PTAB proceeding (also in the family, not on the '118 patent)

  • Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. v. Radian Memory Systems LLC, IPR2025-01266 (P.T.A.B.), filed July 9, 2025, challenging US 11,544,183 (a descendant of the '118 patent). It was terminated December 30, 2025 (pre-institution settlement). (Source: Docket Alarm case tracker for IPR2025-01266.) This was described as "one of seven petitions challenging patents-at-issue in a co-pending district court action"; none of the petitions identified in my results targeted the '118 patent.

On the Google Patents "family has litigation" flag

The Google Patents page for US 9,542,118 displays a "Family has litigation — First worldwide family litigation filed" banner linking to a Darts-ip family record (family ID 57705973). This is a family-level indicator. It is consistent with the Radian v. Samsung and IPR2025-01266 activity described above — but it does not establish that the '118 patent itself is the asserted or challenged patent. I found no source tying that flag to a case naming the '118 patent directly.


Bottom line

  • Litigation directly asserting US 9,542,118: none found.
  • Litigation involving the '118 patent's family: Radian Memory Systems LLC v. Samsung Electronics Co., Ltd. et al., No. 2:24-cv-01073-JRG (E.D. Tex., filed Dec. 24, 2024), plus PTAB IPR2025-01266 (filed July 9, 2025; settled/terminated Dec. 30, 2025) — in both, the '118 patent appears only as an ancestor of the asserted patents, not as an asserted patent itself.

Caveats

  • I was limited to a small number of searches and did not have direct access to PACER, Docket Navigator, or the Darts-ip/Unified Patents caselists, so I cannot rule out an assertion of the '118 patent in a case not surfaced by these searches (e.g., an older or non-public action, or an ITC investigation). Treat the "no direct assertion found" as a search-based negative, not a certified null.
  • The most recent status of the district-court case (whether the motion to dismiss was granted) is not confirmed by the documents I retrieved.
  • Per your instruction, I have interpreted patent numbers literally and did not substitute any similar numbers; the "9588904," "9229854," "9229854," "11,544,183," etc. appearing above are cited exactly as found in the sources.

Generated 10/1/2026, 4:32:44 PM

Proceedings on file (0)

All PTAB activity →

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

Current assignee: Samsung Electronics Co., Ltd., Samsung Electronics America, Inc.

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

PTAB challenges

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

✓ Generated

I'll verify the structured data against live sources before writing anything.

The searches surfaced Samsung IPRs on Radian continuation patents, but nothing yet on '118 itself. Let me drill down specifically on the '118 patent and on the broader Radian PTAB docket.

AIA Trial Proceedings — US Patent 9,542,118 ("Expositive flash memory control")

Sourcing note: The canonical list in the structured "PTAB proceedings on file" block (USPTO Open Data Portal) returns no AIA trial proceedings for US 9,542,118. I independently searched PTAB/PTAB-E2E dockets, Docket Alarm's PTAB collection, Unified Patents' PTAB case list, and Federal Circuit/PTAB news sources. Nothing contradicts the ODP result. Every IPR naming Radian Memory Systems as patent owner that I could locate is directed to a different patent in the same family — not to '118. Details on those are in the appendix, clearly labeled as related-portfolio activity rather than proceedings on this patent.


Proceedings overview

Total AIA trial proceedings on US 9,542,118: 0 (0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution-denied).

The defensive posture is therefore the opposite of a hardened patent record: US 9,542,118 has never been tested at the PTAB and has never been construed by any court. No claims have been canceled, no claims have been confirmed, no estoppel has attached. Any defendant facing assertion of this patent starts from a blank slate — with the full menu of § 102/§ 103 grounds available — but also without the benefit of an adverse FWD or a favorable prior PTAB panel's reasoning. The main signal to draw is the inverse of the usual one: well-asserted patents attract IPRs, and this one has been in the portfolio but not in the case. That is a fact about claim selection, not a fact about validity.


Proceedings on US 9,542,118

None. There is no IPR, PGR, or CBM proceeding to report for this patent. Accordingly:

  • Judge panel: N/A — no panel has ever been assigned.
  • Petition grounds: N/A.
  • Institution decision: N/A.
  • Final Written Decision: N/A. No claim of '118 has ever been held unpatentable or patentable by the Board.
  • Settlement / termination: N/A.
  • Appeal: N/A — no FWD, so nothing to appeal to the Federal Circuit. I found no CAFC docket involving '118 arising from a PTAB case.
  • Defensive value: A defendant can pursue IPR against '118 free of § 315(e)(2) estoppel from any prior petitioner, and free of any Board precedent construing the claims. The absence of an FWD also means the patent owner has never had to defend the claims — the intrinsic record is the specification, the prosecution history, and whatever the district court does.

Patent profile for scoping a challenge (from the patent document itself):

  • Application 14/880,529, filed 2015-10-12; issued 2017-01-10; priority date 2014-09-09 (provisional 62/048,162, via CIP of 14/848,273).
  • Assignee: Radian Memory Systems LLC (originally LLC; later Inc.; re-assigned back to Radian Memory Systems LLC per the Google Patents reassignment record).
  • Anticipated expiration 2035-09-08 per the patent record — a long runway, which cuts against the "wait it out" defense and for early IPR investment.
  • Claim 1 is directed to a memory controller that subdivides an incoming address into fields corresponding to hierarchical groups (channels / dies / erase units / pages), at least one field being a virtual address resolving within the bounds of a hierarchically superior structure. Representative dependent subject matter includes per-block-device address-space-layout (ASL) configuration, pseudo-physical geometry export, block-device allocation, and virtualized erase-unit remapping (see the FIG. 2, FIG. 4, FIG. 7 and FIG. 12 descriptions). The listed art of record that matters for a starting point: US 9,229,854 (Kuzmin, same family), US 2014/0215129 (Kuzmin, "Cooperative Flash Memory Control"), US 2014/0365719 (Kuzmin), US 2014/0122781 (Smith, "Hierarchical flash translation layer"), US 8,341,332 (Ma), US 8,266,367 (Yu), US 8,176,238, US 8,571,331 (Shalvi), and US 8,949,517 (Cohen).

Appendix — Related-portfolio PTAB activity (NOT proceedings on '118)

This is context, not a proceeding on this patent. Do not cite these numbers as challenges to '118.

In 2025, Samsung Electronics Co., Ltd. and [Samsung Electronics America, Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.) filed a coordinated set of IPRs against seven Radian continuation patents — the same seven patents Radian asserted against Samsung in Radian Memory Systems LLC v. Samsung Electronics Co., Ltd., No. 2:24-cv-01073 (E.D. Tex., complaint filed 2024-12-24; before Judge Rodney Gilstrap). Radian's counsel described it as "one of seven petitions challenging patents-at-issue in a co-pending district court action."

Proceeding Challenged patent Filed Status
IPR2025-01266 US 11,544,183 2025-07-09 Terminated–Settled (2025-12-30)
IPR2025-01289 US 11,681,614 2025-07-14 Terminated–Settled (2025-12-30)
IPR2025-01321 US 11,709,772 2025-07-17 Terminated–Settled (2025-12-30)
IPR2025-01350 US 11,740,801 2025-07-28 Terminated–Settled (2025-12-30)
IPR2025-01376 US 11,307,995 2025-08-05 (per Unified Patents case list) Terminated–Settled (2025-12-30)
IPR2025-01377 US 11,347,656 2025 Terminated–Settled (2025-12-30)
IPR2025-01378 US 11,347,657 2025 Terminated–Settled (2025-12-30)

What actually happened in the lead case (IPR2025-01266, the best-documented):

  • Grounds (as reflected in the patent owner's Preliminary Response): four grounds against the '183 claims, built on Ellis (US 2013/0205102) and Sinclair (US 7,739,444) in combination with Son — all § 103 obviousness, attacking limitations such as "logic to receive a write request from a host … accompanied by an address that designates a specific one of the subdivisions," "logic to send the host the information indicating extent of page utilization," and defect-detection/substitution logic.
  • No institution decision was ever reached. The Board's 2025-12-30 entry is a "DECISION Settlement Prior to Institution of Trial 37 C.F.R. § 42.74" — i.e., a pre-institution termination. A joint motion to terminate with a confidential settlement agreement was filed 2025-12-19.
  • No FWD, no claim-level holding, no estoppel. Because these settled before institution, § 315(e)(2) estoppel never attached to Samsung — on the '183 patent or on any of the other six. That is a materially different posture from an FWD-based loss.
  • Panels: none were constituted (no institution), so there are no public APJ assignments to cite.
  • Counsel: Petitioner — Quinn Emanuel Urquhart & Sullivan LLP (James Glass et al.). Patent owner — Lowenstein & Weatherwax LLP (Kenneth Weatherwax), with Nathan Lowenstein, Colette Woo, Dennis Courtney and Xu Zhou designated as back-up counsel.
  • Related district court outcome: the E.D. Tex. case was resolved by joint stipulation and dismissed without prejudice — no infringement finding, no claim construction, no validity ruling; Radian remains free to refile the same seven patents. The parallel settlement across all seven IPRs is consistent with a global resolution.
  • Other litigation context: Radian's preliminary injunction motion against Samsung was withdrawn on 2025-07-11 after the U.S. government filed a statement of interest (2025-06-24) on NPE preliminary-injunction availability under eBay.

Why '118 sits outside that fight (observation, not a holding): the seven asserted patents all issued 2022–2023 and all claim priority to the same 2013/2014/2015 provisional chain that includes '118. Radian asserted the newer continuations, not the '118 parent, and Samsung correspondingly petitioned only the asserted patents. I found no public record explaining the claim-selection decision, and I won't speculate beyond noting it. Practically, an accused infringer today may face any of the seven asserted patents, the untested '118, or newer continuations — the '118 specification is the shared disclosure backbone for all of them.

One further data point on the breadth of the '118 disclosure: an international search report for PCT/US2020/054595 cites US 9,542,118 B1 as X-category art (novelty-destroying alone) against all of claims 1–20 of that application, with US 2016/020910 A1 (SanDisk) as Y-category for claims 6, 13 and 19 (and JP 2019-179571 A, US 2017/0017580 A1, and Narayan et al., "MOCA," as A-category art). I did not confirm the applicant identity for that PCT, so treat this only as evidence that the '118 specification is broad enough to be used as primary art against later-filed flash-management claims elsewhere — useful ammunition if you are drafting IPR grounds against family members, not a challenge to '118 itself.


Strategic summary

Claim status. For US 9,542,118: every claim is UNTESTED. Zero claims canceled, zero sustained, zero construed. Contrast this with the asserted continuation patents: those were challenged across seven Samsung IPRs, but all seven terminated pre-institution by settlement, so not a single claim of any Radian patent has been invalidated or confirmed by the PTAB. For a defendant, the operative fact is that there is no claim-level adjudication anywhere in this family to bank on. Conversely, there is no adverse precedent to overcome either.

Estoppel landscape. No § 315(e)(2) estoppel exists against anyone with respect to '118, because no IPR on '118 ever reached a final written decision. Even on the seven continuation patents, the pre-institution settlements mean Samsung is not estopped from relitigating the Ellis/Sinclair/Son combinations it raised in its petitions in district court. That cuts against a defendant in one narrow sense — you cannot ride Samsung's estoppel — but it also means the ground you raise in a new IPR is not pre-judged. Practically complete freedom: every § 102 and § 103 ground supported by art that a POSITA could have located is available, uninhibited by prior Board proceedings. If you are a defendant, remember the reverse-facing risk: any IPR you file and lose on grounds you raised or reasonably could have raised will estop you in the parallel litigation.

Pattern signals.

  • No repeat petitioner on '118 — nobody has ever filed against it.
  • Samsung filed a single, coordinated seven-petition volley (July–August 2025) rather than serial filings against one patent. That is a one-shot "clear the whole case" strategy, and it ended in a global settlement rather than a merits fight. Expect the same playbook shape — multi-patent, single-campaign — if Radian refiles against a different defendant.
  • Radian litigates and negotiates, but has not litigated a PTAB FWD to judgment. It has not needed to defend a claim in an instituted trial. Its PTAB posture to date is defensive filing (POPR, § 314(a) discretionary-denial briefing invoking Fintiv and the 2025-03-26 Director workload-management memo, argued at length in the '183 record) followed by settlement.
  • No defensive aggregator in the chain. I found no Unified Patents, RPX, or other third-party-routed challenge against this family — only the Samsung campaign. That means no publicly funded validity work product on '118 to reuse, and no § 315(b) privity complications to map.
  • Settled party economics: the E.D. Tex. dismissal was without prejudice, so Radian can refile the same patents — and can add '118 and newer continuations next time. Your exposure to the untested '118 claims is live, not historical.

Recommended next steps

  1. If you have been contacted about '118, do not assume it is vulnerable just because it has no PTAB history. The absence of IPRs is a claim-selection signal, not a validity signal. Build your invalidity case from first principles: the Kuzmin-family pre-filing publications (US 2014/0215129 "Cooperative Flash Memory Control" and US 2014/0365719), Smith's US 2014/0122781 "Hierarchical flash translation layer," Ma US 8,341,332, Yu US 8,266,367 / 8,176,238, Shalvi US 8,571,331, and Cohen US 8,949,517. The '118 priority chain runs to 2014-09-09, so anything publishing before that date is fair game; the CIP lineage (14/848,273, filed 2015-09-08) is also worth attacking on § 112 written-description grounds to push the effective date later and bring more art into play — that is exactly the priority challenge Samsung pressed in the district court case, where it contended Radian failed to carry its burden of showing entitlement to its asserted priority dates.
  2. Treat the family, not the patent, as the unit of analysis. The seven Samsung IPRs show the real assertion surface is the 2022–2023 continuations (US 11,307,995 / 11,347,656 / 11,347,657 / 11,544,183 / 11,681,614 / 11,709,772 / 11,740,801). Run a claim-chart sweep across the whole family before committing IPR budget to '118 alone — a win on '118 that leaves six siblings standing buys you little.
  3. Verify the ODP/PTAB-E2E status yourself before filing. I confirmed the absence of '118 proceedings as of this date, but PTAB records are ingested with lag; check PTAB E2E (https://ptacts.uspto.gov) and the Board's decision page (https://www.uspto.gov/patents/ptab/decisions) for both "9,542,118" and the application number 14/880,529, and check CourtListener (https://www.courtlistener.com) for any CAFC appeal, before you rely on a clean slate.
  4. Watch for a refiling. Radian v. Samsung was dismissed without prejudice; the seven IPRs terminated on 2025-12-30 by pre-institution settlement. There is no § 315(b) one-year clock running against anyone right now on '118 (no '118 complaint has been served), so a future defendant would have a full year from service of a complaint to petition — and Radian would have no Fintiv ground to argue if the IPR is filed promptly.
  5. If an active proceeding ever appears on '118, the milestones to calendar are: PO preliminary response due ~3 months after notice of accord; institution decision due within 6 months of the petition's filing date (§ 314(b)); FWD due within 12 months of institution (§ 316(a)(11)), extendable up to 6 months for good cause. None of these apply yet.

Bottom line: there is no PTAB activity on US 9,542,118, and the structured ODP data saying so is corroborated by my search. The patent is untested, unconstrued, and un-estopped — for a defendant that is an opportunity, and for a plaintiff it is an untested asset riding on a family that has been asserted once and settled globally before any tribunal reached the merits.

Generated 10/1/2026, 4:33:07 PM

Ownership chain (4)

Asserters network →

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

  1. 2015-10-13 · Assignment

    Alan Chen; Mike Jadon; Andrey V. Kuzmin; Craig Robertson; Robert LercariRadian Memory Systems, LLC

    founder/employee assignment

  2. 2016-11-08 · Change of Name

    Radian Memory Systems, LLCRadian Memory Systems, LLC

    internal reorg

  3. 2016-11-29 · Change of Name

    Radian Memory Systems, LLCRadian Memory Systems, LLC

    change of name only

  4. 2024-05-20 · Assignment

    Radian Memory Systems, LLCRadian Memory Systems, LLC

    internal reorg

Assignment history

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

✓ Generated

I'll research the assignment record for US 9,542,118 across the sources available to me.

Assignment & Ownership Analysis — US 9,542,118 ("Expositive flash memory control")

Data-availability note (read first): I do not have authenticated live access to the USPTO Assignment Center API/UI in this session, so I could not read reel/frame numbers or the correspondent-of-record for any of the four recorded events. The ownership events below are taken from the Google Patents legal-events record embedded in the authoritative patent text supplied to me (https://patents.google.com/patent/US9542118/en → "Reassignment" entries), cross-checked against secondary sources. Where a field (reel/frame, correspondent) is not in my evidence, I say so rather than invent it. Verification link: https://assignmentcenter.uspto.gov/ (search "9542118") and https://patents.google.com/patent/US9542118/en.


Inventors

Inventor Residence (per patent) Employer at filing Role / background
Robert Lercari Thousand Oaks, CA Radian Memory Systems Co-founder, VP of Engineering; ex-Curtiss-Wright Controls, VMETRO, Micro Memory
Alan Chen Simi Valley, CA Radian Memory Systems Principal software architect
Mike Jadon Manhattan Beach, CA Radian Memory Systems Co-founder, CEO & director; ex-GM at Curtiss-Wright Controls / VMETRO / Micro Memory
Craig Robertson Simi Valley, CA Radian Memory Systems Prolific Radian inventor (appears on dozens of Radian filings)
Andrey V. Kuzmin Moscow, RU Radian Memory Systems Co-founder & Chief Scientist; ex-Isilon, Veritas, Micro Memory; R&D located in Russia

Patterns worth noting

  • Single-employer cluster, not a disparate group: all five were Radian personnel/founders at filing, and all assigned to Radian on the same date (see timeline). This is a normal startup-employee-assignment posture — not the "inventors scattered across unrelated companies" profile that often precedes a fire-sale.
  • No evidence of inventor departure within 12 months of filing. I found no source indicating any of the five left Radian in the 12 months after the 2015 filing. (Contrast: Richard M. Mathews, a former Radian CTO who is not an inventor on the '118 patent, is documented as having left Radian — he appears on Radian patents, but not this one.)
  • Geographic split: four inventors in Southern California, one (Kuzmin) in Moscow — consistent with the company's stated "R&D in Russia" model. Relevant only as an entity-location note, not an NPE signal.

Original assignee

  • Entity on the issued patent: Radian Memory Systems, LLC, Calabasas, CA (front page / FPO record). Google Patents attributes the 2015 filing to Radian Memory Systems LLC, which was then renamed Radian Memory Systems, Inc. (2016).
  • Primary line of business: software-defined flash storage — memory-controller software marketed as "Symphonic Cooperative Flash Management," targeting SSDs / data-center flash, with an OEM/cloud/service-provider go-to-market. The '118 patent's claims (hierarchical LBA virtualization in a memory controller) map directly onto that product concept.
  • Did it ship a product embodying the claims? Unclear. Radian was covered as a startup "developing transformative software" and won the 2015 Flash Memory Summit "Most Innovative Technology" award for Symphonic, and founder bios describe delivered "system-level implementations." I found no evidence of a mass-market, revenue-shipping ASIC/controller product, and one industry profile notes only seed/angel funding (~$4.5M across four rounds through 2014). Treat "ships products" as unconfirmed.
  • Current status: appears to still exist as the original owner family — not dissolved or in bankruptcy. Current owner of record per Google Patents is Radian Memory Systems LLC; a sibling Radian Memory Systems Holdings, LLC was identified in Radian's own PTAB mandatory notices (IPR2025-01266). One aggregator lists the assignee as "Radian Memory Systems, ILLC," Plano, TX — flag this: if accurate, it suggests the IP-holding entity's address of record shifted to Plano, Texas, which lies in the Eastern District of Texas. I could not verify this name/address (it may be an OCR artifact of "LLC") and I do not treat it as a finding.

Assignment timeline

Chronological, from the Google Patents reassignment events on the '118 record. Reel/frame and correspondent were not retrievable and are marked accordingly.

  • 2014-09-09 (priority) / not separately recorded — no assignment record tied to this date (priority is a provisional-parent reference only).
  • 2015-10-13 / recorded 2015-10-13 — Reel NNNNNN/NNNN (not available)
    • Conveyance: Assignment of Assignors' Interest
    • Assignor: Alan Chen; Mike Jadon; Andrey V. Kuzmin; Craig Robertson; Robert Lercari (five individual inventors)
    • Assignee: Radian Memory Systems, LLC
    • Correspondent: not available in my evidence — flag for follow-up; if a single attorney/firm recurs here and on Radian's later recordings, that is a signal to track.
    • Context: Founder/employee assignment of the invention to the operating startup — internal, pre-issuance.
  • 2016-11-08 / recorded 2016-11-08 — Reel NNNNNN/NNNN (not available)
    • Conveyance: Change of Name
    • Assignor: Radian Memory Systems, LLC
    • Assignee: Radian Memory Systems, Inc.
    • Correspondent: not available.
    • Context: Internal reorganization — LLC converted to Inc.; no change in beneficial ownership.
  • 2016-11-29 / recorded 2016-11-29 — Reel NNNNNN/NNNN (not available)
    • Conveyance: Change of Name (second/duplicate recording)
    • Assignor: Radian Memory Systems, LLC
    • Assignee: Radian Memory Systems, Inc.
    • Correspondent: not available.
    • Context: Internal — same-conveyance re-record (correction/duplicate of the Nov 8 event); no substantive ownership change.
  • 2024-05-20 / recorded 2024-05-20 — Reel NNNNNN/NNNN (not available)
    • Conveyance: Assignment of Assignors' Interest
    • Assignor: Radian Memory Systems, Inc.
    • Assignee: Radian Memory Systems LLC
    • Correspondent: not available.
    • Context: Internal entity reorganization — operating entity (Inc.) back into a "LLC" holding entity. Timing is ~7 months before Radian filed Radian v. Samsung (E.D. Tex. 2:24-cv-01073, filed 2024-12-24), though that suit names descendant patents, not the '118 patent.

Summary: four recorded events, all intra-Radian (inventors → LLC; LLC → Inc. by name change; duplicate name-change recording; Inc. → LLC). No third-party acquirer, no licensor/NPE assignee, and no defensive aggregator appears anywhere in the recorded chain. The '118 patent has never left the Radian corporate family.


Timeline diagram

timeline
    title Ownership of US 9542118
    2014 : Priority date Sep 9
    2015 : Inventors assign to Radian LLC
         : Application filed Oct 12
    2016 : Name change to Radian Inc
         : Duplicate name change recorded
    2017 : Patent issued Jan 10
    2024 : Assigned back to Radian LLC
         : Radian sues Samsung in EDTX

NPE / troll-pattern signals

  1. Shell-entity transfer — NOT PRESENT. The only assignee names in the chain are Radian Memory Systems, LLC and Radian Memory Systems, Inc. (2016-11-08 / 2016-11-29; 2024-05-20). These are the same corporate family via a name change and an intra-family reorganization, not a transfer to an unrelated "IP/Holdings/Ventures" licensing shell. Caveat: the Radian Memory Systems Holdings, LLC sibling named in the IPR2025-01266 mandatory notices, and the unverified Plano, TX address, warrant a one-line "watch" flag — but neither is a documented shell transfer of this patent.

  2. Known asserter in the chain — NOT PRESENT. Radian Memory Systems appears on none of the named NPE lists (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation, Spangenberg entities). No such entity appears in the '118 chain.

  3. Repeat correspondent across the chain — UNCLEAR (no data). I could not retrieve the correspondent-of-record for any of the four events, so I cannot test for a repeating recording attorney/firm. This is the single most important field to pull from the Assignment Center — if one attorney/firm recurs across the 2015, 2016 ×2, and 2024 recordings, re-run this signal.

  4. Cascading transfers — NOT PRESENT. The four events are spread over 2015 → 2016 → 2016 → 2024, i.e., not a chain of LLCs flipping within <24 months. Two of the four are the same "Change of Name" conveyance.

  5. Pre-litigation transfer — NOT PRESENT (for this patent). The nearest event, 2024-05-20 (Inc. → LLC), is ~7 months before the 2024-12-24 Samsung suit — just outside the 6-month window — and, critically, that suit does not name the '118 patent. Any pre-litigation-arrangement inference would attach to the asserted descendants, not to US 9,542,118.

  6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 record, no sale proceeding, no court-ordered transfer appears for Radian in my sources.

  7. Privateering — NOT PRESENT / UNCLEAR. No SEC filing or third-party (Patents Progress/EFF) coverage in my evidence shows an operating company pushing the '118 patent to an NPE. The '118 patent remains with its originator, which is itself now a litigant on a different (descendant) set of patents — that pattern is not classic privateering (no separation of owner vs. product-maker).

  8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. The patent has not been neutralized.


Verdict

Insufficient data — for an NPE-pattern call.

Justification: the four recorded ownership events (2015-10-13 inventors → Radian Memory Systems, LLC; 2016-11-08 and 2016-11-29 LLC → Inc. change of name; 2024-05-20 Inc. → Radian Memory Systems LLC) are entirely internal to the original assignee family, so every affirmative NPE signal (shell transfer, known asserter, cascading transfers, fire-sale, defensive termination) is not present and only the correspondent test and the unverified Plano, TX address remain open. What keeps this out of "Operating-company assertion / non-asserting" and forces "insufficient data" is that I (a) could not retrieve reel/frame or correspondent for any event, and (b) cannot confirm Radian ships a product embodying the '118 claims — the '118 patent itself is not asserted in any located suit; it is only an ancestor of patents asserted in Radian v. Samsung (E.D. Tex. 2:24-cv-01073). Recommended next steps: pull the four entries from https://assignmentcenter.uspto.gov/ (search 9542118) to capture reel/frame + correspondent, and verify whether the current holder's address of record is Plano, TX — those two data points would resolve the signal-1 and signal-3 "unclear" calls.

Verification links: Assignment Center — https://assignmentcenter.uspto.gov/ ; Google Patents legal events — https://patents.google.com/patent/US9542118/en (Reassignment entries, dates 2015-10-13, 2016-11-08, 2016-11-29, 2024-05-20).

Generated 10/1/2026, 4:33:24 PM

Prior art

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

✓ Generated

I'll research the specific prior-art citations for US 9,542,118.

Let me get the full front-page citation list for this patent.

Let me retrieve the complete citation list from the patent's front page.

Prior Art for US 9,542,118 B1 — "Expositive flash memory control"

Search scope note / compliance with the strict rule: I searched on the literal string 9542118 only. All identifiers below are reproduced exactly as they appear in the sources; I did not substitute or "correct" any number.

Retrieval limitation (stated up front): I was able to retrieve the front-page "References Cited" list only through two secondary mirrors — FreePatentsOnline (freepatentsonline.com/9542118.html) and Justia Patents (patents.justia.com/patent/9542118) — and both render the list truncated. I did not retrieve the USPTO front-page image or the PTO-892 "Notice of References Cited," so I cannot (a) certify the list is complete, (b) distinguish examiner-cited from applicant-cited (IDS) references, or (c) retrieve the Foreign Patent Documents and Other Publications sections. Treat the tables below as partially retrieved, secondary-sourced rather than the full record. Items I could not verify are flagged.


1. The critical framing point for § 102

This is a granted patent whose claims issued over the references on its front page. A reference that appears in "References Cited" without an express § 102 rejection is, by definition, one the examiner did not consider anticipatory of the issued claims. So the "which claim might it anticipate under § 102" column below is my own mapping of each reference's apparent disclosure to the claim elements, not a record of any actual rejection. I have no PTO-892 for 14/880,529, so I cannot tell you which (if any) of these were applied in a § 102 rejection that was later overcome by amendment.

For orientation, the relevant claim elements (building on the previously generated claim summary, which I do not repeat in full) are:

  • Claim 1: hierarchically arranged structural elements; controller generating multiple hierarchical sub-address values, at least one via a modulo operation returning a remainder of (part of) the incoming address divided by the quantity of access-enabled structural elements at that level; at least one sub-address is a virtual address.
  • Claims 2–3: register-configurable number of dies / channels driving that level's modulo.
  • Claim 4: sub-address selects an address translation table dedicated to a structural element at a lower level; remainder applied to the table.
  • Claim 5: die-level access-enabled set + reserve set of erasable units; defect management by substituting a reserve unit.
  • Claim 6: same reserve-substitution at the erase-unit/page level.
  • Claim 30 (uncertain — see prior summary): sub-addresses map to channel, die, erasable-unit, page addresses.

2. Most relevant front-page prior art (retrieved)

2a. The four closest references

# Full citation Date Brief description Claims it could potentially implicate under § 102
1 US 9,229,854 B1 — Kuzmin et al., "Multi-array operation support and related devices, systems and software" (Radian Memory Systems) Granted 2016-01-05; filed 2013-10-07 (per the '118 specification's incorporation-by-reference paragraph) Techniques for addressing/operating multiple flash arrays (channels/dies) collectively; multi-array I/O operations. Same family and same first-named inventor (Kuzmin) as the '118 CIP parent. Cited on the '118 front page, and independently incorporated by reference into the '118 specification. Claim 1 and Claim 30 — channel/die multi-array addressing; hierarchical multiple-array structure. Strongest candidate for the "hierarchical sub-address" concept, though I found no disclosure of a modulo operation against a count of access-enabled elements, which is claim 1's point of novelty.
2 US 2014/0215129 A1 — Kuzmin et al., "Cooperative flash memory control" (Radian Memory Systems) Published 2014-07-31; app. 13/767,723 The "cooperative management mode" reference: geometry export to host, host file system maps its LBA range directly onto physical block addresses, and a defective erase unit ('B') is reported to the host and noted in the LBA-to-PBA map. Also incorporated by reference into the '118 spec. Claims re defect management (potentially claim 5, and by extension claim 6): disclosure of defective erase units and mapping around them. Also touches the block-device/ASL subject matter. Does not appear to teach modulo-based hierarchical sub-address derivation or a host-invisible reserve set — in cooperative mode the defect is reported to the host, which is the opposite of the '118 hierarchically-virtualized mode.
3 US 2014/0122781 A1 — Smith et al., "Hierarchical flash translation layer" Published 2014-05-01 A flash translation layer organized hierarchically. Directly on the "hierarchical addressing" theme of claim 1. Claim 1, claim 30 — hierarchical address organization in flash. But an FTL-based hierarchical scheme is the very approach the '118 patent distinguishes from (it maps LBAs arbitrarily and does not preserve address-space division at each hierarchy level), so a § 102 mapping would likely fail on the "modulo of a quantity of access-enabled structural elements" and on the "at least one sub-address is a virtual address that preserves parent-structure boundaries" limitations.
4 US 2014/0365719 A1 — Kuzmin et al., "Memory controller that provides addresses to host for memory location matching state tracked by memory controller" (Radian Memory Systems) Published 2014-12-11 Controller exposes address information to the host matched to state it tracks — i.e., the "expositive/pseudo-expositive" control philosophy. Claims re geometry export / block-device definition; tangential to claim 1. Relevant to the mode/exposition architecture rather than the modulo sub-address mechanism.

2b. Also-cited references bearing on the addressing/striping and non-power-of-2 limitations

# Full citation Date Brief description (from title unless noted) Potentially implicates
5 US 8,072,463 B2 — Van Dyke, "Graphics system with virtual memory pages and non-power of two number of memory elements" 2011-12-06 Virtual memory pages across a non-power-of-two number of memory elements (graphics memory). Claim 1 — the only retrieved reference whose title squarely addresses non-power-of-two element counts, i.e., the arithmetic that motivates claim 1's modulo step (the '118 spec expressly generalizes the power-of-2 ASL example to "modulo arithmetic that reflects the tuple composition"). Different field (graphics), so any § 102 mapping would depend on whether it discloses flash-style hierarchical access-enablement.
6 US 8,346,332 B2 — Ma et al., "Multi-level controller with smart storage transfer manager for interleaving multiple single-chip flash memory devices" 2012-12-25 Multi-level flash controller interleaving multiple single-chip flash devices (the FPO record lists this under class 711/103). Claim 30, claims 2–3 — channel/die-level interleaving and configurable device counts.
7 US 8,266,367 B2 — Yu, "Multi-level striping and truncation channel-equalization for flash-memory system" 2012-09-11 Striping data across channels/levels in a flash system. Claim 30 and the ASL/striping subject matter (block-device bandwidth by stripe width).
8 US 8,176,238 B2 — Yu, "Command queuing smart storage transfer manager for striping data to raw-NAND flash modules" 2012-05-08 Queuing + striping to raw NAND. ASL/striping; claim 30.
9 US 8,037,234 B2 — Yu, "Multi-level striping…" (same family as #7) 2011-10-11 see #7 as #7
10 US 8,321,650 B2 — Steinmetz, "Alignment-unit-based virtual formatting methods and devices employing the methods" 2012-11-27 Alignment-unit / virtual formatting in storage. Virtual-address formatting aspects; claim 1's "virtual address" element.
11 US 8,006,046 B2 — Steinmetz 2011-08-23 Steinmetz storage formatting (companion to #10) as #10
12 US 8,943,917 B2 — Cohen, "Self-journaling and hierarchical consistency for non-volatile storage" 2015-02-03 Hierarchical consistency / journaling in non-volatile storage. Hierarchical organization of non-volatile storage; tangential to claim 1.
13 US 8,572,331 B2 — Shalvi, "Method for reliably updating a data group in a read-before-write data replication environment using a comparison file" 2013-10-29 Reliable data-group update / replication. Peripheral — retention/reliability, not addressing.
14 US 2012/0059972 A1 — Chen, "Hybrid storage apparatus and hybrid storage medium controller and addressing method thereof" 2012-03-08 Hybrid storage + an addressing method. Claim 1 — address translation/derivation in a hybrid storage controller.
15 US 2014/0101371 A1 — Nguyen, "Systems and methods for nonvolatile memory performance throttling" 2014-04-10 Performance throttling of non-volatile memory. Peripherally relevant to the "predictable I/O latency" benefit, not to any claim limitation.
16 US 2013/0297852 A1 — Fai, "Systems and methods for providing early hinting to nonvolatile memory charge pumps" 2013-11-07 Charge-pump hinting. Background/peripheral only.
17 US 2013/0166825 A1 — Kim, "Method of controlling non-volatile memory, non-volatile memory controller therefor, and memory system including the same" 2013-06-27 NVM control method. Peripheral.
18 US 2013/0013852 A1 — Hou, "Memory controlling method, memory controller and memory storage apparatus" 2013-01-10 Memory control method. Peripheral.
19 US 2015/0261456 A1 — Alcantara, "Configurable read-modify-write engine and method for operating the same in a solid state drive" 2015-09-17 Configurable RMW engine in an SSD. (Note: published 2015-09-17 is AFTER the '118 priority date of 2014-09-09 — it would only qualify as § 102 art if its own filing/priority date predates the '118 priority; I could not retrieve its filing date.) Peripheral; possible § 102(a)(2) (pre-AIA §102(e)) question depending on its filing date.
20 US 2015/0113203 A1 — Dancho, "Device and method for managing die groups" 2015-04-23 Managing flash die groups. (Same post-priority concern as #19 — publication post-dates the '118 priority date; filing date not retrieved.) Claim 30 / die-level addressing if its filing date qualifies.
21 US 7,991,944 B2 — Lee et al. 2011-08-02 (title/abstract not retrieved) Unassessed
22 US 8,025,455 B2 — Kim et al. 2011-09-20 (not retrieved) Unassessed
23 US 8,055,833 B2 — Danilak et al. 2011-11-08 (not retrieved) Unassessed
24 US 8,065,471 B2 — Yano et al. / US 8,065,473 B2 — Ito et al. / US 8,068,365 B2 — Kim all 2011-11-22 / 2011-11-29 (not retrieved) Unassessed
25 US 8,082,389 B2 — Fujibayashi et al.; US 8,084,?-class items; US 8,076,?… 2011-12-20 / 2011-12-27 (partial; not retrieved) Unassessed

Plus additional published applications visible in the FPO/Justia excerpt but not resolvable within my step budget: 20030039262 (Wong), 20030065866 (Spencer), 20050144413 (Kuo), 20060221719 (Maeda), 20070233939 (Kim), 20070283428 (Ma), 20080147964 (Chow), 20080189485 (Jung), 20090036163 (Kimbrell), 20090089490 (Ozawa), 20090172219 (Markicks), 20090172257 (Prins), 20090254705 (Abali), 20090271562 (Sinclair), 20090300015 (Kazan), 20090327602 (Moore), 20120033519 (Confalonieri), and a further truncated run beginning 2010….


3. My assessment of the single most relevant references

If the question is "what reference is closest to the inventive concept of claim 1," my answer based on the retrieved material is:

  1. US 2014/0122781 A1 (Smith, "Hierarchical flash translation layer") — closest on the hierarchical addressing concept, but it is an FTL, which the '118 patent characterizes as the disfavored "linearly virtualized" extreme (arbitrary LBA→anywhere mapping, no preserved address-space division). Any § 102 argument would fail on the boundary-preserving hierarchical sub-address and modulo-of-access-enabled-count limitations.

  2. US 9,229,854 B1 (Kuzmin) — closest on flash multi-array/channel/die addressing and shares the family; the most dangerous art given its early filing (2013-10-07) and incorporation by reference. Still, I found no teaching of the claim-1 modulo limitation in what I could retrieve.

  3. US 2014/0215129 A1 (Kuzmin, "Cooperative flash memory control") — closest on the defect-management / geometry-exposition dependent claims (claim 5 / claim 6 territory), but it reports defects to the host rather than masking them via a die-local reserve set, which is the '118 advance.

  4. US 8,072,463 B2 (Van Dyke) — the only retrieved reference that addresses non-power-of-two memory element counts, which is the motivation for the modulo step, but in a graphics VMM context.

Bottom line: On the retrieved record I see no single front-page reference that discloses every limitation of claim 1 — specifically the combination of (a) hierarchical sub-addresses recovered from the incoming address, (b) at least one recovered via modulo division by the count of access-enabled elements at that level, and (c) at least one sub-address being a virtual address while parent-structure boundaries are preserved. That is consistent with the claims having issued.


4. Related item retrieved (the '118 patent as itself prior art)

Worth flagging because it came up in the same searches: the international search report for JP 2022553951 A cites US 9542118 B1 (Radian Memory Systems, LLC), 10 January 2017, with the "X" (novelty-destroying) category, against that application's claims 1–5, 7–12, 14–18 and 20, and as "Y" against claims 6, 13, 19 (combined with US 2016/020910 A1, SanDisk, 2016-07-14). This is the '118 patent being used as anticipating art against someone else — not art against the '118 patent — but it confirms the citation structure the examiner later saw. Source: patentimages PDF for JP2022553951A.


5. Explicit uncertainties

  • Completeness: the citation list is truncated at the source; Foreign Patent Documents and Other Publications sections were not retrieved. There may be non-US references I did not see.
  • No PTO-892 / no § 102 rejections identified. I cannot state which of these were applied by the examiner, or under § 102 vs § 103.
  • Descriptions for items #21–25 and the long application run are title-only; I could not retrieve abstracts.
  • Filing dates for US 2015/0261456 and US 2015/0113203 were not retrieved, so their status as pre- or post-2014-09-09 art is unresolved; a post-priority publication date alone does not disqualify them (a pre-priority filing date would let them qualify under pre-AIA § 102(e) / AIA § 102(a)(2)).
  • The prior "Patent summary" section flagged uncertainty about whether the "claim 30" text is from the granted or pre-grant claim set; my claim mapping above inherits that uncertainty.

If you want, I can (with additional search budget) pull the actual PTO-892/PTO-1449 from the 14/880,529 file wrapper in PatentCenter to get the definitive, complete, examiner-vs-applicant-attributed citation list and any express § 102 rejections.

Generated 10/1/2026, 4:33:30 PM

Obviousness

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

✓ Generated

I'll ground this in the actual prior art record. Let me pull the references cited on the face of the patent and the incorporated-by-reference documents.

I have the granted claim set and the face-of-patent prior-art list. Let me verify two load-bearing third-party references before writing the analysis.

Obviousness Analysis — US 9,542,118 B1 under 35 U.S.C. § 103

Patent under analysis: US 9,542,118 B1, "Expositive flash memory control," app. 14/880,529, filed 2015‑10‑12, granted 2017‑01‑10, assignee Radian Memory Systems. Source: https://patents.google.com/patent/[US9542118B1](/patent/US9542118B1)/en


0. Corrections and contradictions relative to the earlier sections (flagged per instruction)

  1. Claim-count uncertainty is now resolved (supersedes earlier "could not confirm"). The earlier section flagged that the "claim 30" text might be from the pre‑grant publication and that the total claim count and number of independents were unverified. The granted set obtained from the third‑party mirror is internally consistent with the face‑of‑patent record and shows 32 claims with three independent claims: 1, 14, and 30. Source: https://companyprofiles.justatic.com/patent/[9542118](/patent/9542118). This confirms, rather than contradicts, the earlier statements that claim 1 is independent, claim 30 is independent, and claims 2–6 read as described.
  2. Earlier claim characterizations verified: claim 2 (register‑configurable die count feeding the modulo), claim 3 (register‑configurable channel count), claim 4/20 (sub‑address selects a translation table dedicated to a structural element; remainder applied to that table), claim 5/21 (die‑level access‑enabled set + reserve set, defect substitution), claim 6/22 (erase‑unit‑level reserve set) — all match the granted text.
  3. New matter not in the earlier sections that matters for § 103: claims 7, 8, 23, 24 (per‑block‑device parameter registers, per‑device/per‑die translation tables), 9–11, 25–27 (register‑selected "wide" vs. "deep" write‑sequencing mode), 12, 28 (modulo for every sub‑address), 13, 29 (reserve set of dies), 31–32.
  4. Date inconsistency in a retrieved source (not material): the Arteris application surfaced as US 2026/0228121 A1 carries a publication date of 2026‑08‑06 and grant date 2026‑08‑25, i.e., later than the current analysis date. It is not prior art to the '118 and is cited below only as evidence of what was conventional, not as a § 102/103 reference. Source: https://www.patents-review.com/a/20260228121-modulo-operations-interleaved-memory-non-power-of-two.html

1. What "the Prior Art section of this page" contains

The Google Patents page for the '118 exposes prior art in three layers, and I use all three:

(a) "Prior art keywords / prior art date": flash memory; address; units; access; hierarchical; prior‑art date 2014‑09‑09.

(b) The "Referenced Cited" list on the face of the patent (US patents, US application publications, one WO publication, and non‑patent literature), reproduced in full at https://companyprofiles.justatic.com/patent/9542118 and https://www.freepatentsonline.com/9542118.html. Notable members:

Ref Title as listed Relevance to the '118 claims
US 2014/0215129 A1 (Kuzmin, Jadon, Mathews) Cooperative Flash Memory Control Geometry export; host‑direct physical addressing; physical address = quadruple of channel/device/die/LUN; transparent defect remapping into reserved space
US 2014/0122781 (Smith) Hierarchical flash translation layer Hierarchical L2P translation in flash
US 2014/0365719 (Kuzmin) Memory controller that provides addresses to host… Remap/spare reporting to host
US 8,341,332 (Ma) Multi-level controller… for interleaving multiple single-chip flash memory devices Channel/die interleaving of flash
US 8,176,238 (Yu); US 8,266,367 (Yu); US 8,032,734 (Yu) Striping / channel equalization for flash Multi‑die striping
US 8,072,463 (Van Dyke) Graphics system with virtual memory pages and non‑power‑of‑two number of memory elements Component selection by remainder w/ non‑power‑of‑two population
US 8,074,022 (Okin) Programmable heterogeneous memory controllers Register‑programmable controller configuration
US 8,321,650; US 8,006,046 (Steinmetz) Alignment‑unit‑based virtual formatting Virtual‑to‑physical formatting granularity
US 5,568,423 (Jou); US 7,339,823 (Nakayama); US 7,404,031 (Oshima); US 7,581,078 (Ware); US 7,752,381 (Wong); US 7,970,983 (Nochimowski); US 6,134,631 (Jennings) Flash control / multi‑plane / FTL address management Background art for FTL remap and multi‑plane
US 8,949,517 (Cohen) Self‑journaling and hierarchical consistency for non‑volatile storage Hierarchical non‑volatile storage structures
US 9,229,854 (Kuzmin, Wayda) Multi‑Array Operation Support… Controller "educates host on array composition, capabilities and addressing restrictions"
WO 2009/100149 — Non‑volatile memory control
NPL NamelessWrites (Zhang et al.); Arpaci‑Dusseau "Removing the Costs of Indirection…"; Strunk "Hybrid Aggregates"; FIOS scheduler; NVMe 1.0b; "Optimizing NAND Flash Performance" (FMS 2008); "High‑Speed NAND Flash: Design Considerations…" (FMS 2009) De‑indirection, predictability, multi‑die scheduling

(c) Applicant‑admitted prior art (AAPA) inside the '118 specification itself, which is usable as prior art: the linearly‑virtualized FTL mode with L2P tables, bad‑block tracking/remapping, garbage collection, wear leveling; the cooperative mode with geometry export; multi‑plane and multi‑page command support; read/write caching. E.g. col. description at "linearly virtualized mode shown at 114" and the FTL bad‑block discussion.


2. Critical date and a threshold legal wrinkle the challenger must confront

  • Presumptive prior‑art date: 2014‑09‑09 (Google's "prior art date"; the CIP parent 14/848,273 priority). Claim 1's modulo‑based hierarchical decomposition appears only in the CIP/provisional chain (62/199,969 of 2015‑07‑31; 62/194,172 of 2015‑07‑17; 62/063,357 of 2014‑10‑13), so a defendant may argue claim 1 is entitled to no earlier than 2014‑09‑09 or 2014‑10‑13, and—for the "modulo ≈ mixed‑radix decomposition plus per‑level LUT" subject matter—possibly only 2015‑07‑17/2015‑07‑31. Art published between 2014‑09 and 2015‑08 is therefore in play.
  • Family‑art caveat (important). US 2014/0215129 and US 9,229,854 are Radian's own work and share inventors with the '118 (Kuzmin, Jadon are named on both the '118 and '129). A challenger relying on them must address (i) AIA § 102(b)(1)(A) (disclosure by an inventor/joint inventor within the grace period — the '129 publication of 2014‑07‑31 falls within one year of a 2014‑09‑09 priority) and (ii) § 102(b)(2)(C) (common ownership) to the extent they qualify only as § 102(a)(2) art. For that reason the stronger § 103 case is built on third‑party art (hierarchical FTL; multi‑channel/multi‑die interleaving; modulo component selection; programmable controller registers; FTL bad‑block remapping with spare substitution), with the Radian family used only as corroborating evidence of what a POSITA knew — a use consistent with Abbott/Standard Oil practice.

3. Person having ordinary skill in the art (POSITA)

A POSITA here is a memory‑system architect/controller designer with a B.S. in EE/CS and ~3–5 years in flash/SSD controller design: familiar with NAND geometry (channels, dies, planes, erase units, pages), FTL L2P tables and bad‑block remapping, multi‑plane/multi‑die interleaving, and standard address decoding (bit‑field extraction and interleaving/modulo). (This skill framing parallels the record in Netlist reexaminations of interleaving patents, e.g. the Dr. Kozyrakis declaration describing "address interleaving and decoding (generation of decoded row, column, bank, and rank select signals from an encoded address)" as core undergraduate/two‑year‑experience material. Source: https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2022-00615/…/Exhibit-1010…pdf)


4. Limitation‑by‑limitation mapping of independent claim 1

Claim 1 requires: (i) flash storage with hierarchically arranged structural elements where a higher level enables access to a subset of lower‑level elements; (ii) a controller that, on receiving an address with an access command, generates multiple hierarchical sub‑address values; (iii) at least one of those sub‑addresses generated at least in part via a modulo operation = remainder of (a portion of) the incoming address divided by the quantity of access‑enabled structural elements at that level; and (iv) at least one sub‑address being a virtual address.

Claim‑1 element Grounding prior art Notes
(i) Nested channel→die→plane→erase‑unit→page hierarchy in flash Kuzmin '129 ¶[0060] (physical address is a "quadruple of channel, device, die and LUN"; ¶[0059] die/plane registers); face‑of‑patent flash architecture refs (Jou '423, Nakayama '823, Yano '471); '118 AAPA ¶ "channels, dies, erase units and pages constitute… respective hierarchical physical elements" Not seriously contestable; conceded by the '118's own description.
(ii) Controller decomposes an incoming address into per‑level sub‑addresses Kuzmin '129 ¶¶[0059]–[0060], [0109] (controller returns number of channels, targets per channel, LUNs per target, EUs per LUN); US 2014/0122781 Smith "Hierarchical flash translation layer"; US 8,341,332 Ma; US 8,176,238 / 8,266,367 Yu (striping address generation across dies/channels); US 5,568,423 / US 6,134,631 (FTL address decoding) Address decomposition into channel/die/EU/page fields is the ordinary way flash controllers and DRAM controllers decode addresses.
(iii) At least one sub‑address via modulo by the number of access‑enabled elements EP 0 313 788 B1 ("contents of address m is stored in Dq, where q = mod(m, n)" — modulo interleaving across devices, which the document itself identifies as the standard technique): http://data.epo.org/publication-server/rest/v1.2/patents/EP0313788NWB1/document.pdf. US 6,202,133 (Netlist/Compaq lineage) claiming allocation of logical addresses to modules "according to first and second interleaving schemes" with a configuration register selecting which interleaving scheme is used: https://patentimages.storage.googleapis.com/5a/1d/9a/e1d5843708b55c/US6202133.pdf. US 8,072,463 Van Dyke (non‑power‑of‑two number of memory elements with virtual pages). US 8,341,332 Ma / 8,266,367 Yu (flash channel‑striping). The "quantity of access‑enabled structural elements" divisor is satisfied by the declared/usable count: Kuzmin '129 expressly contemplates that the controller chooses what capacity to advertise — in host‑owned/shared defect management it "does not need to reserve any spare … and thus can advertise full device capacity," implying the exported element count is a controller‑set number, not a fixed physical constant. The '118's own FIG. 3 example (1024 pseudo‑physical vs. 1124 actual EUs/plane) is exactly this.
(iv) At least one sub‑address is a virtual address FTL bad‑block remapping art (US 6,134,631; AAPA in Kuzmin '129 ¶[0004] describing L2P tables, bad‑block tracking, "remaps valid memory so as to avoid these bad blocks"); Kuzmin '129 ¶¶[0069], [0126]–[0129] (controller transparently remaps a failed write "to reserved memory space," tracks it in metadata, and can "allocate remapped space to a reserved EU using a like page assignment"); Kuzmin '129 ¶[0119] (reserve pool of erased units) Kuzmin '129's "like page assignment" is precisely the '118's architecture: remap at one level (EU) while preserving ordering at other levels, and the higher‑level (channel/die) fields remain physical so the remapped data still lands in the die the host expects.

Conclusion on claim 1: The combination of (A) a flash controller that decomposes an address into hierarchical sub‑addresses and exports geometry (Smith '781; Kuzmin '129; Yu/Ma striping), (B) conventional modulo/interleave decoding whose modulus is a programmable number of memory elements (EP '788; US 6,202,133; US 8,072,463; US 8,341,332), and (C) FTL‑style spare‑substitution at one level while preserving other levels (FTL bad‑block remapping art; Kuzmin '129 ¶¶[0069], [0119], [0126]–[0129]) renders claim 1 obvious.


5. Independent claims 14 and 30

  • Claim 30 adds only that the four sub‑addresses are channel address, die address, erasable‑unit address, and page address (plus channels coupling the controller to at least one die). Kuzmin '129 ¶[0060] discloses exactly this ordered set ("a quadruple of channel, device, die and logic unit number (LUN)"), and the '118's own AAPA states the LBA is subdivided into "respective channel, die, erase unit and page address fields." Claim 30 is the weakest of the three independents.
  • Claim 14 adds (a) the lowest level = independently programmable units (pages) and a higher level = flash dies, and (b) that the controller generates a page address in dependence on at least one remainder produced in generating the die address. Generating a lower‑level field from leftovers of the higher‑level decomposition is the ordinary arithmetic of mixed‑radix decomposition (EP '788; US 8,072,463; the Arteris description confirms this is textbook modulo‑address decoding, albeit post‑dating the '118), and US 8,266,367/8,176,238 Yu generate intra‑die page addresses as part of striding across dies.

6. Dependent claims — where the second reference comes from

Claim group Added limitation Best supporting art Why the combination is motivated
2, 3, 18, 19, 31 Register‑programmed die count / channel count defines the modulus divisor US 8,074,022 Okin (programmable heterogeneous memory controllers); US 6,202,133 (configuration register selects interleaving scheme); Kuzmin '129 ¶¶[0082], [0109], [0182] (mode register; geometry export used to configure operation) A designer who exports geometry to the host must let the host program the geometry; a register is the canonical mechanism (also the '118's own AAPA: "mode register or other configuration circuit").
4, 20 Sub‑address selects a dedicated address translation table; remainder applied to it; maps to pages or EUs FTL L2P tables (US 6,134,631; AAPA ¶[0004]); Kuzmin '129 ¶[0067]/[0069] (metadata per EU; remap to reserved EU "using a like page assignment"); US 8,321,650 / 8,006,046 Steinmetz (virtual formatting at alignment‑unit granularity) Per‑die/per‑zone translation tables are the natural consequence of confining virtualization to a sub‑hierarchy; the '118 itself later claims exactly this idea in US 11,288,203 ("independent address translation per zone," https://www.ipqwery.com/ipowner/en/owner/ip/[1091497](/patent/1091497)-radian-memory-systems-llc.html).
5, 6, 13, 15–17, 21, 22, 29 Access‑enabled set + reserve set at die/EU/page level, with defect substitution FTL bad‑block remapping art; Kuzmin '129 ¶¶[0119], [0126]–[0129] (reserve capacity, transparent remap, "spare capacity for defects," alert when exhausted, host‑owned mode advertising full capacity) Spare‑pool substitution is the acknowledged purpose; the '118's novelty is where the substitution is confined (inside the parent structure), which follows directly from "the LBA is nonetheless guaranteed … to resolve to a physical erase unit within the LBA‑specified physical die."
7, 8, 23, 24, 31 Per‑block‑device (namespace) parameter registers and per‑die translation tables Kuzmin '854 (controller "educates the host on array composition, capabilities and addressing restrictions"; multi‑array partitioning); Kuzmin '129 ¶[0109]; Yu/Ma multi‑device striping; the '118's own successor patents (US 11,022,387 namespaces across channels/dies) If different regions have different bandwidth/endurance targets, per‑region parameters are the obvious implementation; the '118's provisional title itself ("Techniques for Memory Controller Configuration") signals that this is configuration plumbing, not a new capability.
9, 10, 11, 25, 26, 27 Register‑selected mode: successive writes to successive dies vs. successive pages within one die (wide vs. deep) US 8,341,332 Ma; US 8,266,367 Yu; US 8,176,238 Yu (all describe programming stripes across multiple flash devices and the alternative within‑device sequential programming); Kuzmin '129 ¶[0059] (die capable of multiple simultaneous IO commands, multi‑plane); '118 AAPA FIG. 6 discussion of wide vs. deep ASLs The wide/deep trade‑off (bandwidth vs. endurance) is inherent to interleaving; making it selectable via a register is a predictable design choice (KSR "known method … familiar elements").
12, 28 Every sub‑address generated via modulo Wholly conventional mixed‑radix decomposition (EP '788; US 6,202,133; Arteris description as field evidence) If the technique works for one level it plainly works for all; no criticality asserted.
32 Same as 12 Same Same

7. Motivation to combine (KSR/§ 103 rationale)

A POSITA at the critical date would have been motivated to combine, for reasons grounded in the references themselves:

  1. Same field, same problem, same known trade‑off. Both the FTL bad‑block/spare art and the interleaving art exist to solve flash's P/E asymmetry, wear, and latency problems. The '118's own admitted prior art recites that the FTL mode makes I/O latency "unpredictable" and that "the host is unable to avoid sequential issuance of logical block addresses that resolve to the same flash die, meaning that resource conflicts may arise at random." The obvious response — let the host see the hierarchy so it can schedule without conflicts — is exactly the cooperative/geometry‑export teaching of Kuzmin '129 ¶[0109] and the "educate the host on array composition, capabilities and addressing restrictions" teaching of Kuzmin '854.
  2. Interleaving already forced hierarchical address decomposition. Channel/die striping (Yu, Ma) requires decoding a single address into channel/die/page fields — the "plurality of hierarchical sub‑address values" element. Modulo is the textbook device‑selection mechanism (EP '788 states q = mod(m, n) and explains why; US 6,202,133 makes the scheme programmable via a configuration register).
  3. Defect virtualization per structural element is enabled by the same decomposition. Once the address is decomposed and the host has been given a pseudo‑physical (idealized) view, restricting spare substitution to within the same parent (die) — the '118's stated guarantee — is the conservative choice that preserves the host's scheduling assumptions. Kuzmin '129 ¶[0127]–[0129] already performs exactly that ("allocate remapped space to a reserved EU using a like page assignment"; "entire EUs are simply remapped to spare EUs, such that … internal page ordering is preserved").
  4. Reasonable expectation of success / predictable results. The references are implementing well‑understood digital arithmetic (bit‑field selection and division/remainder) on established flash hardware; the '118 itself says the mechanism can be "implemented entirely with logical gates and look‑up tables … without requiring processor cycles." A predictable‑result, easy‑implementation combination weighs heavily toward obviousness. The appearance of an Arteris application in 2025‑26 claiming modulo‑based non‑power‑of‑two channel decoding as a hardware problem to be solved without a divider confirms both the conventionality of the technique and that replacing integer division with small LUTs/adders is a routine optimization. (Non‑prior‑art evidence: https://www.patents-review.com/a/20260228121-modulo-operations-interleaved-memory-non-power-of-two.html)
  5. Finite number of identified solutions. For the stated goal (configurable, defect‑tolerant, bandwidth/endurance‑tunable regions with predictable latency), the design space is essentially the elements already known: hierarchical address fields + selectable layout + per‑level remap tables + programmable registers. The '127 case is, on its face, a predictable arrangement of those elements.

8. Counter‑considerations a defense would press (and the challenger's rebuttal)

  1. The modulus is the access‑enabled quantity, not the total quantity. This is the sharpest distinction in claim 1. The '118 uses 1024 pseudo‑physical EUs/plane (not the 1124 present) as the divisor, so the LBA space "skips over" reserved and defective elements. Rebuttal: this is simply the divisor equal to the declared/idealized count, and Kuzmin '129 expressly makes the advertised element count a controller choice under the defect‑management mode (reserve spare or "advertise full device capacity"). Whether a controller divides by total or by usable‑element count is a design choice dictated by whether it reserves spares — an unquestionably obvious selection.
  2. Confinement of virtualization within a parent (die) as a design guarantee. Rebuttal: the guarantee is a property arising from applying the modulus/LUT at one level only; the references teach per‑EU remapping with preserved page ordering (Kuzmin '129) and per‑die/zone translation (the '118's own later Zone patents; Steinmetz's alignment‑unit virtual formatting).
  3. Objective indicia (secondary considerations). Expect the patentee to argue: (a) industry adoption of "zoned"/Open‑Channel SSD interfaces and namespace configuration, (b) forward compatibility across flash generations (the '118's FIG. 11 teaching), and (c) licensing interest. Two evidentiary problems: (i) nexus — the '118's own later families claim the commercial zone/namespace features, so any success may be attributable to those claims; and (ii) from the earlier section of this analysis, no litigation was found in which the '118 itself is asserted or challenged — it appears only as an ancestor of asserted patents (Radian v. Samsung, No. 2:24‑cv‑01073‑JRG; IPR2025‑01266 on US 11,544,183, terminated by pre‑institution settlement 2025‑12‑30). Weak or absent assertion history undercuts a robust commercial‑success/significance narrative, though it does not by itself defeat one.
  4. Teaching away / "physical access" preference. A patentee might point to Kuzmin '129's statements preferring host‑owned schemes and warn about memory‑controller‑owned translation "creat[ing] unpredictable latencies" (¶[0152]). Rebuttal: those statements disfavor full FTL address translation at the controller; the '118 claims exactly the opposite extreme of what '129 warns against — a limited, localized remap table per structural element. That is the '129 teaching, not a departure from it.

9. Bottom line

  • Claim 1 is obvious over: (A) hierarchical‑FTL / geometry‑export / address‑field art (Smith US 2014/0122781; Yu US 8,176,238 & 8,266,367; Ma US 8,341,332; Kuzmin US 2014/0215129 ¶¶[0059]–[0060], [0109]) in view of (B) modulo/interleave component‑selection art with programmable element counts (EP 0 313 788; US 6,202,133; US 8,072,463 Van Dyke) in view of (C) FTL bad‑block remapping with spare substitution preserving internal page order (art cited on the face of the '118; Kuzmin '129 ¶¶[0069], [0119], [0126]–[0129]).
  • Claims 14 and 30 are obvious on the same record — claim 30's channel/die/EU/page quadruple is verbatim Kuzmin '129 ¶[0060]; claim 14's dependent page address and remainder relationships are ordinary mixed‑radix decoding.
  • Dependent claims 2–13 and 18–29 are obvious by further combination with the register‑programmability art (US 8,074,022 Okin; US 6,202,133's configuration register; Kuzmin '129's mode register and geometry export) and the per‑die/per‑zone translation‑table art (US 8,321,650 / 8,006,046 Steinmetz; Kuzmin '129 ¶¶[0067], [0069]).
  • Strongest non‑obviousness argument for the patentee is the claim‑1 phrase "quantity of access‑enabled structural elements" as the modulus divisor, coupled with the guarantee that lower‑level virtualization never crosses a higher‑level (die/channel) boundary. In my assessment that distinction is a design choice within the express contemplation of the prior art, so it is unlikely by itself to sustain the claims — but it is the only limitation I would expect to receive substantive prosecution‑style attention, and it is the reason a challenger should lead with art that expressly makes the exported/declared element count a controller‑set or host‑selected number.

Confidence: Medium. The mappings above rest on my own reading of the granted claims and on the reference titles/abstracts and the Kuzmin '129 / '854 disclosures retrieved; I did not independently verify, against full texts, (i) the assignee of US 2014/0122781 (my search returned a different Smith patent, US 9,432,298, to Patents1, LLC — so the '781 document itself remains unverified), (ii) the precise disclosures of US 8,341,332, US 8,176,238, US 8,266,367, US 8,072,463, US 8,074,022, US 8,321,650 or US 8,006,046 beyond their titles/abstracts, or (iii) the '118's actual prosecution history (i.e., which references, if any, the examiner applied). Those should be pulled from the full‑text PDFs and the file wrapper before any of this is relied on in a petition or invalidity contention. Patent numbers and identifiers are cited literally as they appeared in the sources; no similar numbers were substituted.

Generated 10/1/2026, 4:34:29 PM

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