Invalidity dossier

US 10241643

Navigating content hierarchies and persisting content item collections

Current assignee: Microsoft Technology Licensing LLC

Added 10/1/2026, 5:12:08 PM

At a glanceNo PTAB challengesNo litigation on fileSoftware Technology & Computing Systems (T)

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Patent summary

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

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US Patent 10,241,643 — Analyst Summary

Scope note on sourcing. I searched the open web (Google Patents, Justia, aggregators) for this exact number. I did not obtain a direct USPTO PatentCenter/Global Dossier record or a CAFC docket query result in this session, so the bibliographic data below is cross-checked against the authoritative full text you supplied plus Google Patents/Justia. Where I am inferring rather than reading, I flag it.

Bibliographic data

Field Value
Patent number US 10,241,643 B2 (as literally printed; no auto-correction applied)
Title "Navigating content hierarchies and persisting content item collections"
Application no. 13/724,717
Pre-grant publication US 2014/0181708 A1 (published 2014-06-26)
Filing date 2012-12-21
Priority date 2012-12-21
Issue/grant date 2019-03-26
Inventors Erez Kikin-Gil; Mark Eugene Pearson; Vignesh Sachidanandam; Doreen Grieb; Patrick Malatack
Assignee / original assignee Microsoft Technology Licensing, LLC (assigned from Microsoft Corporation in Jan. 2015)
Examiner Not confirmed from my sources (flagging as unknown)
Legal status Active; adjusted expiration listed as 2033-04-14 (per Google Patents; not a legal conclusion)
CPC classes G06F16/168; G06F3/0481; G06F3/0482; G06F3/04842; G06F3/0485; G06F3/04883; G06F16/9027
Family TW 102142475 (TW 201428514 A); CN 201380067706.3 (CN 105190612 B); PCT/US2013/077172 (WO 2014/100704 A1); EP 13826816.4 (EP 2936350 A1); AR P130105036 (AR 094286 A1); later US continuation 16/290,497 (pub. US 2019/0196670 A1)

Abstract (verbatim)

"Navigation of multiple information item hierarchies within a same application display pane or view is provided. Information items may be displayed in a customized collection of information items, for example, a 'favorites' collection, that may be assembled from a variety of content sources and that may be persisted across a variety of information item views."

Plain-language overview of the independent claims

Important caveat: the authoritative full text you supplied is truncated inside the Detailed Description (it ends partway through the discussion of Fig. 17B) and does not include the claims section. I reconstructed claim content from a Justia claim listing for the granted patent and from the pre-grant publication's claim listing. The claim wording below is therefore a summary, not a verbatim reproduction, and portions of the snippets were cut off mid-limitation.

  • Claim 1 — Method of navigating a customized collection of files and folders (touch-centric). Display a graphical representation of a collection of files and folders within a single display view of a touch device. The view shows a first folder with a first file inside it, a second folder with a second file inside it, and a "first graphical file indicator" (a "+N" badge) inside the first folder showing how many files in that folder are not yet represented. When the user touch-selects that indicator, the unrepresented files are displayed in-line (left-to-right / right-to-left) inside the first folder's graphical representation — without deleting or pushing the first folder representation off screen. Space is made by moving the second folder and its file off-screen (left or right motion), and those off-screen items are redisplayed when the user touch-scrolls left or right. In short: an in-place, non-destructive "expand in line" rather than a drill-down into a folder.

  • Claim 10 — System for navigating a customized collection of files and folders. A memory plus a processing unit coupled to it, where the processing unit is operable to: assemble a collection of multiple files and folders from a variety of content sources; provide a graphical representation of that collection within a single display view of an electronic display having a touch interface, including showing a first folder with a first file inside, a second folder with a second file inside, and a graphical file indicator within the first folder presenting a count of unrepresented files; receive a touch selection of that indicator; and then display the unrepresented files in an in-line display configuration within the first folder's representation, without deleting or moving the first folder off-screen. (This is the apparatus/system counterpart of claim 1; the snippet I retrieved was truncated before the end of the claim.)

  • Further independent claim(s) — not confirmed. The granted patent very likely includes at least one additional independent claim (e.g., a computer-readable storage medium / instructions claim) mirroring the method and system claims, but I could not verify this from an authoritative source in this session. Treat the count of independent claims as unverified.

Contrast with the pre-grant publication (US 2014/0181708 A1), whose claims were broader and differently worded:

  • Pre-grant claim 1: a method of navigating related information items — providing a graphical representation of a collection of information items, a selectable control for displaying additional related information items, a graphical representation of a nested collection hierarchically related to the collection, a selectable control for displaying items in the nested collection, and exposing either the additional items or the nested collection's items in-line with the collection's items upon selection.
  • Pre-grant claim 10: a method of displaying a customized collection — assembling it from a variety of content sources, displaying it alongside other items/collections, and persisting its display regardless of changes to the display of unrelated items.

So the granted claims are noticeably narrower and touch-interface-specific relative to the published application — consistent with amendment during prosecution. That narrowing is a point worth flagging for any validity/infringement analysis.

Litigation / CAFC 2026 docket check

  • No CAFC 2026 docket activity and no district-court, IPR, or PGR proceeding specifically identifying US 10,241,643 was found in my searches. I could not confirm any pending or decided appeal involving this patent. Treat "no litigation found" as a search limitation, not proof that none exists (I did not query PACER, Docket Alarm, or the CAFC's own docket directly).
  • Caution / do not conflate: a WilmerHale "Federal Circuit Patent Watch" item from August 2026 discusses a "'243 patent" in an IPR involving an analogous-art dispute over a "Tian" publication. Nothing in that summary ties it to US 10,241,643 (the subject matter described there does not match this patent), so I am not attributing that case to this patent. It may be a different patent whose number also ends in "243."
  • The searches did turn up a third-party listing giving an "approximate value" for this patent (patentleaderboard.com), which is a commercial estimate, not a legal or docket fact.

Uncertainty summary

  1. Independent claim count and exact claim language are not authoritative here — your supplied full text omitted the claims, and the Justia snippets were truncated. Do not rely on the above claim summaries as verbatim claim text; pull the granted claims from USPTO PatentCenter or the patent PDF for any legal use.
  2. Examiner, and any post-grant proceedings, are unconfirmed.
  3. No litigation is confirmed either way; I found no positive evidence of any, and the "'243 patent" in the 2026 Federal Circuit write-up is a different matter as far as I can tell.
  4. Bibliographic fields (dates, assignee, expiration, status) are taken from the supplied Google Patents text and are explicitly marked there as assumptions, not legal conclusions.

Generated 10/1/2026, 5:21:04 PM

Cases on file (0)

Specific litigation cases in our database that name US patent 10241643. The free-form analysis below may also discuss cases beyond this list.

No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.

Litigation summary

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

✓ Generated

I'll search for litigation involving US patent 10241643 across litigation-tracking sources.

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Search Results: Litigation Involving US Patent 10,241,643

Bottom line

I found no record of any litigation (district court infringement suit, declaratory judgment action, ITC investigation, or PTAB proceeding) involving US Patent 10,241,643 ("Navigating content hierarchies and persisting content item collections").

Based on the searches I was able to run, this patent does not appear to have been asserted in any known patent lawsuit, nor has it been the subject of any known post-grant challenge.

Important caveats about this conclusion

I want to be explicit about the limits of what I can verify, per your instruction not to fabricate:

  1. Access limitations. I could not directly query the paywalled/authenticated litigation databases you named (Docker Navigator, Unified Patents' litigation caselist portal, PACER, or the CAFC docket). My searches were general web searches, which do surface these sources but not comprehensively. A definitive "no litigation" conclusion would require direct queries against those databases.

  2. No negative results were returned. None of my search queries returned a docket entry, complaint, case caption, or docket number referencing 10,241,643. Searches for the patent number together with litigation terms (e.g., "district court," "E.D. Tex," "C.D. Cal," "complaint") returned no case results.

  3. Apparent reason it is unlikely to appear. The patent is owned by Microsoft Technology Licensing, LLC — an operating company and prolific patent defendant, not a typical patent monetization/assertion vehicle. US 10,241,643 has no apparent assignment history to an NPE or assertion entity. Patents of this profile are far less likely to be litigated as an asserted patent than those held by non-practicing entities.

Patent identity (for record confirmation)

To confirm I searched the correct patent and did not conflate similar numbers:

Field Value
Patent number US 10,241,643 B2
Title Navigating content hierarchies and persisting content item collections
Application no. US 13/724,717
Filing date December 21, 2012
Grant/publication date March 26, 2019
Original assignee Microsoft Technology Licensing, LLC
Inventors Erez Kikin-Gil; Mark Eugene Pearson; Vignesh Sachidanandam; Doreen Grieb; Patrick Malatack
Pre-grant publication US 2014/0181708 A1 (June 26, 2014)
Related family members WO 2014/100704 A1; EP 2936350 A1; CN 105190612 B; TW 201428514 A; AR 094286 A1; and continuation US 16/290,497 → US 2019/0196670 A1

Note: The family members above (PCT, EP, CN, TW, AR national/regional counterparts) are foreign prosecution/publication records, not litigation. I saw no indication that any foreign counterpart has been litigated either, but my search coverage on foreign dockets is even thinner.

What you should do to confirm definitively

Because this is a negative finding, I recommend verifying it directly against authoritative sources:

  • Docket Navigator — search patent number 10,241,643 (or the application number 13/724,717) for both district court and PTAB records.
  • Unified Patents litigation portal — https://portal.unifiedpatents.com/litigation/caselist (search by patent number).
  • PACER — nationwide party/patent search.
  • USPTO PTAB (P-TACTS) — check for any IPR/PGR/CBM filed against 10,241,643.
  • USPTO Patent Center / Assignment records — confirm the ownership chain remains with Microsoft and see whether any security interest or transfer has occurred.

Bottom line, stated precisely

Based on the searches I could perform, no litigation or PTAB challenge involving US 10,241,643 is known to exist as of today's date (April 26, 2026). This is a negative finding limited by my inability to directly query authenticated litigation databases — I cannot rule out a filing that those databases alone would reveal. I did not locate any case caption, case number, jurisdiction, filing date, or outcome to report because no such record appeared in my results.

If you can give me access to or search outputs from Docket Navigator, Unified Patents, or PACER for this specific number, I can review the exact dockets and give you the per-case detail (plaintiff, defendant, jurisdiction, case number, filing date, status) that you requested.

Generated 10/1/2026, 5:20:56 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.

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 start by searching for any PTAB proceedings involving this patent and its family.

No direct hits yet. Let me run more targeted searches on the patent number, its family, and any litigation that would have spawned IPRs.

Let me check the continuation patent, litigation, and any Unified Patents-style challenges.

Proceedings overview

Total AIA trial proceedings on file: 0. The structured "PTAB proceedings on file" block (USPTO Open Data Portal) returns no IPR, PGR, or CBM proceedings naming US 10,241,643, and my independent web searches across the PTAB decisions/E2E corpus, Docket Alarm PTAB dockets, and general news likewise surfaced no petition, institution decision, FWD, or appeal involving this patent. Breakdown: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution-denied. Defensive posture: the patent is completely untested at the PTAB — every claim stands as issued and no statutory estoppel (§ 315(e)(2)) has attached to any party. A defendant therefore faces an untouched property right but also has a clean slate: all § 102/§ 103/§ 112/§ 101 grounds, and the option to file the first IPR, remain open.


Proceedings

No proceedings to report.

I want to be explicit about the negative finding rather than dress up the absence, because the absence is a substantive datapoint:

  • No IPR/PGR/CBM docket exists for US 10,241,643 in the sources I could reach (USPTO PTAB E2E, Docket Alarm PTAB docket index, Federal Circuit/CourtListener). Nothing to enumerate at the proceeding level — no petitioner, no panel, no institution ruling, no FWD, no appeal.
  • No litigation-driven PTAB activity is apparent either. Nothing in the searches tied the '643 patent to a district-court assertion (which is the usual precursor to a defendant-filed IPR). Searches for the patent number alongside litigation terms returned only the patent itself, the inventor's other filings, and unrelated IPR papers.
  • Family note (context, not a proceeding): the '643 patent issued from App. No. 13/724,717 (filed 2012-12-21, granted 2019-03-26), and has a continuation, App. No. 16/290,497 (pub. US20190196670A1). No AIA trial proceeding appears against the '643 patent or the continuation publication. See the authoritative record at Google Patents — US10241643B2 and the continuation at US20190196670A1.

I do not know with high confidence whether any pre-issuance contested matter (e.g., a pre-issuance opposition-style filing, or a Docker-style appeal from prosecution) exists; those are not AIA trials and would not appear in the ODP AIA-proceedings field. The provided text shows a standard prosecution with a Final Rejection, an After-Final response, and an Advisory Action — consistent with ordinary examination, not a contested proceeding. Treat that as background, not a finding of PTAB activity.


Strategic summary

Claim status — CANCELED / SUSTAINED / UNTESTED. There is no PTAB narrowing here. Because no IPR/PGR/CBM ever reached a Final Written Decision, every claim of US 10,241,643 is "UNTESTED" at the PTAB, and all of them remain in force as issued. There are no canceled claims to point a defendant toward and no surviving-as-amended claim set. Note also that the authoritative text supplied does not reproduce the full claim listing, so I will not state a claim count or quote claim numbers — nothing in the record gives me an FWD-style claim-by-claim disposition to quote, and I will not manufacture one. What a defendant can say with certainty is that no claim has been invalidated administratively.

Estoppel landscape. This is the key point and it cuts in the defendant's favor. Because there has been no final written decision in any IPR/PGR, 35 U.S.C. § 315(e)(2) estoppel has never attached — not to any petitioner, real party in interest, or privy. Practically, that means:

  • No ground is foreclosed. Unlike a patent that has survived an IPR (where the surviving claims are insulated from the petitioner's art but everyone else is still free), here everything is still on the table for everyone, including any party that later petitions. The full § 102/§ 103 prior-art space, § 112 written-description/enablement, and § 101 subject-matter challenges are all live.
  • First-mover advantage is intact. A defendant today could file the first IPR on this patent, control the art selection, and — if it reaches an FWD — become the estoppel source for its own later litigation positions rather than inheriting someone else's. There is no prior petitioner record to ride on or to be bound by.
  • § 315(b) one-year bar is the clock to watch. If a complaint asserting the '643 patent is served, the defendant's IPR window closes one year after service. Given no PTAB history, an early IPR assessment should be scoped immediately upon service.

Pattern signals. None of the usual patterns are present: no repeat petitioner (there is no petitioner at all), no aggressive patent-owner PTAB-appeal posture (no FWD to appeal), and no defensive-aggregator chain (no Unified Patents / RPX-style filing detected). The patent is owned by Microsoft Technology Licensing LLC — a well-resourced, non-practicing-entity-adjacent assertion of a big-tech portfolio patent would be unusual, which itself is part of why an assertion of this patent is, at least as of now, not a familiar narrative. One environment note that does matter going forward: the patent has been in force since 2019-03-26 (roughly seven years as of today). Under the USPTO's March 2025 "Interim Processes for PTAB Workload Management" and the acting Director's "settled expectations" discretionary-denial doctrine — under which discretionary denials clustered heavily on patents in force six years or more — a newly filed petition against this patent could face discretionary-denial headwinds on age alone, independent of the merits. So the clean-slate benefit is real, but the timing gate is steeper for an old, never-challenged patent than for a fresh one.


Recommended next steps

  1. Reframe the risk model. There is no FWD to cite and no canceled claim to rely on. Do not build a defense on "the PTAB already killed this." Build it on the fact that the patent is pristine and un-litigated at the Board, so validity is an open question the defendant can shape from scratch.

  2. Commission a § 102/§ 103 landscape now targeting the claimed "in-line" hierarchy navigation and "persistent favorites collection" features. Because no petitioner has ever put art on the record, there is no § 315(e)(2) estoppel to worry about — the defendant is free to run the full groundset and to pick the strongest art without inheriting anyone else's bad choices. The '643 file history also shows an Advisory Action and an After-Final response, so study the prosecution record closely for § 112 and § 101 openings (software-GUI claims of this vintage are frequent § 101 targets).

  3. Consider a § 101/§ 112 challenge in district court or an early IPR in parallel. Given the age-based discretionary-denial risk, sequence the filing early and be prepared to address the "settled expectations" factor directly in the petition, or to argue it away (e.g., no evidence of the owner's investment in or commercialization of the patented subject matter — one of the recognized exceptions to the settled-expectations presumption).

  4. If an assertion letter or complaint arrives, calendar the clocks immediately: the § 315(b) one-year IPR bar from service; and, if an IPR is filed and instituted, the statutory one-year trial deadline (35 U.S.C. § 316(a)(11)) with the FWD due at that mark and the ~3-month pre-institution window for an institution decision.

  5. Verify in the primary sources before relying on this. Confirm the null result directly at USPTO PTAB E2E (search by patent number) and USPTO Patent Center for App. No. 13/724,717, and check CourtListener for any district-court or Federal Circuit docket. My searches found nothing, but the ODP ingest can lag and newly filed petitions may not yet be indexed.

Bottom line: zero PTAB proceedings, zero estoppel, zero narrowing — as of today this patent is a completely untested right, which means the defense is unbuilt rather than foreclosed. The absence of PTAB activity here is not the "hardened by IPR" signal; it is the "no one has tried yet" signal, and it comes with a first-mover IPR opportunity plus a real age-based discretionary-denial caveat.

Generated 10/1/2026, 5:21:04 PM

Ownership chain (2)

Asserters network →

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

  1. 2012-12-21 · Assignment

    Kikin-Gil, Erez; Pearson, Mark Eugene; Sachidanandam, Vignesh; Grieb, Doreen; Malatack, PatrickMicrosoft Corporation

  2. ? · recorded 2015-01-09 · Assignment

    Microsoft CorporationMicrosoft Technology Licensing, 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 this patent's ownership chain before writing. Let me pull from multiple sources.

Let me dig deeper on the specific assignment records and any litigation involving this patent.

Ownership & Assignment Reconstruction — US 10,241,643 B2

Scope note / data limitation (read first): I was able to retrieve the event-level ownership record from Google Patents' legal-events feed (which mirrors USPTO assignment data) and corroborating USPTO assignment-abstract data for comparable Microsoft patents, but I was not able to pull the reel/frame for this specific patent from the USPTO Assignment Center within this session — the search returned no abstract-of-title for application 13/724,717. I therefore do not invent reel/frame numbers below. Where I cite a reel/frame, it is from a different Microsoft patent and is labeled as an analogue, not as this patent's record. Verify at assignmentcenter.uspto.gov (search patent 10241643) or assignment.uspto.gov.


Inventors

Inventor Employer at filing Basis
Erez Kikin-Gil Microsoft Corporation Listed assignor on the 2012-12-21 assignment to Microsoft; UX/design role
Mark Eugene Pearson Microsoft Corporation Same — listed assignor on 2012-12-21 assignment
Vignesh Sachidanandam Microsoft Corporation Same
Doreen Grieb Microsoft Corporation Same
Patrick Malatack Microsoft Corporation Same — program management, file/cloud storage UX

Pattern assessment: All five inventors are named assignors on the inventor→Microsoft Corporation assignment, which was executed the same day as filing (2012-12-21). That is the standard "all inventors are employees" signature and is consistent — but not conclusive — with all five being Microsoft employees at filing. I could not verify departure dates for any inventor from a primary source; I found no evidence of a coordinated inventor exodus within 12 months of filing (the classic fire-sale pre-cursor), so I am not flagging that pattern. Flag it as unclear / not verifiable from the record retrieved, not as absent on the merits.


Original assignee

Recorded original assignee: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052 (per the 2012-12-21 assignment event listing assignors "MALATACK, PATRICK; GRIEB, DOREEN; SACHIDANANDAM, Vignesh; KIKIN-GIL, EREZ; PEARSON, Mark Eugene").

Discrepancy to note: Google Patents lists "Original Assignee: Microsoft Technology Licensing LLC." That is Google back-filling the current owner. The 2012 record shows the original assignee was Microsoft Corporation; MSL did not exist until 2014.

  • Primary line of business: Microsoft is a publicly traded operating company (NASDAQ: MSFT) — OS, productivity software, and cloud services (Windows, Office, OneDrive).
  • Product embodying the claims: The specification is directed to in-place navigation of nested content hierarchies and a persisted "favorites" collection across views (FIGS. 2–13). This subject matter maps to Microsoft's file/collection-browsing surfaces shipped in the Windows 8/8.1/10 era and OneDrive/SkyDrive file views. I did not find a clean, citable mapping of the issued claims to a specific shipping SKU, so I state this as likely but not established rather than proven.
  • Current status: Operating. MSL (Microsoft Technology Licensing, LLC) is Microsoft's wholly-owned patent-holding/licensing subsidiary, created in 2014 to consolidate the Microsoft patent portfolio. No bankruptcy, dissolution, or acquisition event.
  • Portfolio maintenance: Legal status Active, adjusted expiration 2033-04-14 (typically indicates PTA and fee maintenance). A continuation, US 16/290,497 (US20190196670A1), was filed 2019-03-01, and the family extends internationally (PCT/US2013/077172; EP2936350A1; CN105190612B; TW201428514A). Active prosecution + foreign filings = a maintained corporate portfolio, not abandoned inventory.

Assignment timeline

Two recorded conveyance events. Reel/frame not retrieved for this patent — flagging honestly rather than substituting another patent's numbers.

  • 2012-12-21 (executed) / recorded 2012-12-21 — Reel not retrieved

    • Conveyance: Assignment of assignors' interest (employment/original assignment)
    • Assignor: Kikin-Gil, Erez; Pearson, Mark Eugene; Sachidanandam, Vignesh; Grieb, Doreen; Malatack, Patrick
    • Assignee: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052
    • Correspondent: not retrieved for this record. On the closest comparable Microsoft record I could pull (a 2003-era Microsoft filing), the inventor→Microsoft correspondent was outside counsel Workman Nydegger (1000 Eagle Gate Tower, 60 East South Temple, Salt Lake City, UT 84111). For a 2012 filing the responsible firm may differ; treat as unverified.
    • Context: Original employment assignment; all rights transferred to Microsoft at filing.
  • 2015-01-09 (date shown in legal events) — Reel not retrieved

    • Conveyance: Assignment of assignor's interest (intra-corporate transfer)
    • Assignor: Microsoft Corporation
    • Assignee: Microsoft Technology Licensing, LLC, One Microsoft Way, Redmond, WA 98052
    • Correspondent: not retrieved for this record. On the analogous Microsoft→MSL recording I retrieved for a different Microsoft patent (application 10/369,006, issued as 7,185,285), the correspondent of record was CPA Global Limited, Liberation House, Castle Street, St Helier, JE1 1BL, Jersey — reel 034541/0477, executed 2014-10-14, recorded 2014-12-09. CPA Global (a bulk IP-administration/annuity agent) recurs across the Microsoft→MSL transfer wave, but that is a corporate-administration pattern, not an NPE tell. Single-patent analogue, so this is not a repeat-correspondent finding for this chain.
    • Context: Internal reorg — Microsoft carved roughly its entire patent estate into its wholly-owned licensing subsidiary. No change in ultimate control.

No third assignment exists. The chain terminates at Microsoft Technology Licensing, LLC, which remains the current assignee. No security interest, license, merger, or release recording surfaced.


Timeline diagram

timeline
    title Ownership of US 10241643
    2012 : Filed by five Microsoft inventors
         : Assigned to Microsoft Corporation
    2015 : Moved to Microsoft Technology Licensing
    2019 : Patent issued
         : Continuation application filed

NPE / troll-pattern signals

  1. Shell-entity transfer — not present. The only post-filing transfer is to Microsoft Technology Licensing, LLC, which takes the same One Microsoft Way, Redmond address as the assignor and is the consolidated patent-holding vehicle for a Fortune-100 operating company. It is not a single-purpose LLC, not a registered-agent address, and not a licensing-only shell divorced from a product business.
  2. Known asserter in the chain — not present. Neither assignor nor assignee matches any name on the Acacia / Marathon / Intellectual Ventures / IPNav / Wi-LAN / Conversant / Vringo / Pendrell / Innovatio / MPHJ / Lumen View / Round Rock / Document Generation / Spangenberg lists, nor any RPX or Unified Patents high-frequency-plaintiff listing. Microsoft Corporation and MSL are operating-company holders.
  3. Repeat correspondent across the chain — unclear / not established. The correspondent of record for this patent's two events was not retrieved. The CPA Global appears on the analogous Microsoft→MSL recording (reel 034541/0477) as the bulk-transfer administrator — an admin agent, not a litigating NPE attorney, and only one appearance, so no recurrence finding.
  4. Cascading transfers — not present. Two events, ~25 months apart (2012-12-21 → 2015-01-09), both within the same corporate family; no chained LLCs, no shared-agent clustering across distinct owners.
  5. Pre-litigation transfer — not present. I found no infringement action naming US 10,241,643. The intra-corporate transfer occurred in early 2015, more than four years before issuance (2019-03-26) and with no subsequent suit, so the chain was plainly not arranged to time an assertion.
  6. Bankruptcy fire-sale — not present. Microsoft has never filed for bankruptcy protection; no reorganized-debtor conveyance exists in this chain.
  7. Privateering — not present. No evidence (SEC filing, Patent Progress or EFF coverage, or litigation record) that Microsoft transferred this patent to an NPE to assert on its behalf. The transfer went into Microsoft's own house, not out to a third-party asserter.
  8. Defensive aggregator (anti-NPE) — not present (no defensive-aggregator terminus). The chain does not end at RPX, AST, LOT Network, Unified Patents, or OIN. (Microsoft is a LOT Network founder, but that does not change ownership of this patent, so it is not a finding under this signal.)

Verdict

Insufficient data (no NPE-relevant record).

Justification: The entire recorded chain consists of (a) the inventor→Microsoft Corporation assignment executed/recorded 2012-12-21 and (b) the Microsoft Corporation→Microsoft Technology Licensing, LLC intra-corporate transfer dated 2015-01-09 — both internal to a single operating company, with no third-party or licensing-shell transferee anywhere in the chain. None of the eight NPE signals is present, so no NPE verdict is supportable; conversely, "Operating-company assertion" cannot be entered because I found no infringement suit on this patent. I did not obtain the reel/frame or correspondent of record for either event from the Assignment Center, so I cannot close the file on the correspondent-recurrence signal — hence "insufficient data" rather than a clean defensive/non-asserting call.

Verify at: USPTO Assignment Center — search 10241643 · Google Patents legal events for US10241643B2

Generated 10/1/2026, 5:21:26 PM

Prior art

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

✓ Generated

I'll research US Patent 10241643 and its prior art citations. Let me search for authoritative sources.

Let me get the full "References Cited" section and citation details from authoritative patent sources.

Let me try to access the full reference list from the Google Patents page and the patent PDF directly.

Summary of findings

I was able to verify the identity and claim set of US 10,241,643, but I must be upfront about one material limitation up front, because it affects the completeness of your requested deliverable:

The full patent text provided to me does not contain the "(56) References Cited" section — that section appears in the front matter of the printed patent, and the text I was given begins at the Background. My web searches did surface a fragment of the reference list from the patent PDF (patentimages.storage.googleapis.com/.../US10241643.pdf), but I could not retrieve a complete, verified, itemized citation list before hitting my tool-call limit. I therefore report the references I could actually observe, clearly flagged, rather than inventing a full list.


1. Patent identification (verified)

Field Value
Patent number US 10,241,643 B2 (do not confuse with US 2014/0181708 A1 or US 2019/0196670 A1)
Title Navigating content hierarchies and persisting content item collections
Application no. 13/724,717
Filing date 2012-12-21
Priority date 2012-12-21
Grant date 2019-03-26
Assignee Microsoft Technology Licensing, LLC (originally Microsoft Corporation)
Inventors Erez Kikin-Gil; Mark Eugene Pearson; Vignesh Sachidanandam; Doreen Grieb; Patrick Malatack
Prior publication US 2014/0181708 A1 (2014-06-26)
Continuation US 2019/0196670 A1 (app. 16/290,497, filed 2019-03-01)
Primary examiner Tuyetlien T Tran
Attorney/agent Merchant & Gould P.C.
Status Active; adjusted expiration 2033-04-14

Sources: Google Patents (patents.google.com/patent/US10241643B2/en), the patent PDF, and Justia (patents.justia.com/patent/10241643).


2. Claim set (from the granted patent)

The granted claims are directed to the navigation / in-line expansion aspect (not the "favorites persistence" aspect — that subject matter appears in the continuation, US 2019/0196670 A1):

  • Claim 1 (method, "navigating a customized collection of files and folders"): assemble a collection of files and folders from a variety of content sources; display graphical representations within a single display view of a touch display, including: a first folder and a second folder; a first file shown within the first folder and a second file shown within the second folder; and a first graphical file indicator presenting a value indicating the number of unrepresented files within the first folder. On a touch selection of that indicator, the unrepresented files are displayed in a left-to-right/right-to-left "in-line" configuration, without deleting or moving the first folder off-screen, where the view accommodates the expansion by moving the second folder/second file off-screen in a left or right motion, and the off-screen items are redisplayed on left/right touch scrolling.
  • Dependent claims 2–9: graphical representation types (thumbnail, image, name, attribute); item types (documents, data items, images, objects); context-relatedness (claim 4); folder-expansion sizing (claim 5); collapsing via touch with indicator-count update (claims 6–7); two-row multi-column touch-scrollable format (claim 8); exterior-boundary naming (claim 9).
  • Claim 10: system counterpart (memory + processing unit) of claim 1.
  • Claim 20: media-storage-device (CRM) counterpart.

The specification (Figures 2–6) describes the "in-line" expansion and the +N / nested-collection icons (e.g., elements 230, 235, 245, 250, 415, 439, 440).


3. Prior art cited by US 10,241,643 (partially retrieved)

The following are the entries I could actually observe in the "(56) References Cited" fragment of the patent PDF. Treat this as a partial list — the granted patent almost certainly cites additional U.S. patents/publications and possibly other foreign documents that I could not verify.

Reference Date Type Status of my verification
US 5,835,094 A — Ermel et al. 11/1998 U.S. patent (marked "*" in the list) Number/date observed in PDF fragment; full title/abstract not verified
US 6,181,342 B1 — Niblack 1/2001 U.S. patent Number/date observed; full title/abstract not verified
US 7,378,969 B2 — Chan et al. 5/2008 U.S. patent Number/date observed; full title/abstract not verified
CN 1647035 7/2005 Foreign patent document Number/date observed
CN 1955998 5/2007 Foreign patent document Number/date observed
Non-patent literature: "Windows Explorer — 25-11-2010 PDF — web tutorial on finding number of nested files and folders as of Nov. 25, 2012" 2010/2012 NPL (web tutorial) Description observed in PDF fragment

I could not confirm the full titles, abstracts, or examiner relevance annotations for any of these, and I could not retrieve the remainder of the list. I am explicitly not asserting details I did not observe.


4. Potential § 102 anticipation — qualified analysis

Because I lack the full text of each reference, the following is a framework keyed to the claim-1 limitations, not a verified anticipation conclusion:

The claim's novelty centers on four limitations that a § 102 reference would have to disclose in a single reference:

  1. Nested-expansion in a single display view without replacing the parent — the "in-line," non-"drill-down" behavior (spec ¶ re: "exposed and displayed additional information items do not replace the display of previously displayed information items").
  2. A numeric "unrepresented items" indicator (the +N badge) whose selection triggers expansion.
  3. Touch-based selection gesture.
  4. Re-flow by moving sibling folders off-screen left/right, with re-display via horizontal touch scrolling.
  • A tree/hierarchy-expansion reference (e.g., US 5,835,094 / US 6,181,342 / US 7,378,969, each of which I understand to relate to hierarchical/tree or file-system UI display) would be most relevant to limitation 1, and possibly limitation 2, but would not by itself appear to disclose the touch-gesture (3) or the off-screen re-flow by horizontal motion (4) — those are the features most likely relied on for patentability over the cited art.
  • The "Windows Explorer" tutorial NPL (about finding the number of nested files/folders) maps to limitation 2 (the count indicator), which is why it was likely cited.
  • The CN documents (1647035, 1955998) would need full-text verification; CN 1647035 (2005) and CN 1955998 (2007) are both pre-2012 and could bear on limitations 1–2.

Which claims: If any single reference did disclose limitations 1–4 together, it would anticipate independent claim 1 (and, being parallel in scope, claims 10 and 20), which would in turn render all dependent claims moot. Realistically, the cited art appears more likely to have been used in § 103 obviousness combinations against claim 1 (with the touch/scroll limitations as the distinguishing features), which is consistent with the 154(b) PTA of 114 days on a broadly-claimed family.


5. What I could not do / recommended verification

  • I could not retrieve the complete, verified "(56) References Cited" list or full bibliographic/abstract data for each reference within my tool budget. Do not treat the table in §3 as exhaustive.
  • Next step to close this gap: pull the "References Cited" tab from Google Patents (US10241643B2), or the front page of the grant PDF, or USPTO PatentCenter / Global Dossier (app. 13/724,717). Those are the authoritative sources for the exact cited list and examiner annotations.
  • Note also the distinction between references cited in the patent (true prior art candidates) and patents/publications that cite US 10,241,643 ("Cited By"), which are not prior art to it. Several search hits "referencing" 10,241,643 (e.g., EP 1499964, US 8,661,064) are later citing documents, not references cited within it.

If you can supply the front-page "(56)" listing (or grant a few more search steps), I can expand each citation to full citation + abstract + a limitation-by-limitation § 102/§ 103 chart.

Generated 10/1/2026, 5:21:11 PM

Obviousness

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

✓ Generated

I'll research the actual claim set and the prior-art references cited on this patent before building the § 103 analysis.

Let me pull the granted claim set and the specific prior-art references cited on the Google Patents page.

Let me get the granted claims and the cited references list.

Obviousness Analysis — US 10,241,643 B2 under 35 U.S.C. § 103

Important sourcing caveats (read first). Two limitations on what I can ground:

  1. The page content supplied to me does not actually contain a "Prior Art"/"Citations" section. The fetched Google Patents text (https://patents.google.com/patent/[US10241643B2](/patent/US10241643B2)/en) that I was given includes Classifications, Definitions, Description, Abstract and the bibliographic record, but it is truncated before the Claims, Cited References, and Similar Documents tables. The only genuinely "prior-art" fields present on the page are the algorithmic "Prior art keywords" — graphical representation, folder, files, file, collection — and the prior art date of 2012-12-21. I will not invent a citation list I cannot see.
  2. The claim text I use below is the published claim set of US 2019/0196670 A1 (Justia: https://patents.justia.com/patent/20190196670), a continuation in the same family (same inventors, same specification, priority to 2012-12-21) filed 2019-03-01. Its claims recite the "user-designated collection / file browser display" aspect that matches the '643 abstract. I could not independently verify the exact granted claim wording of the '643 patent from the material provided, so treat the mapping below as applying to the family claim set mutatis mutandis; if the granted independent claims differ, the element-by-element reasoning transfers directly.

1. The claim set to be analyzed

Claim 1 (independent):

  • 1[a] receiving user-identification of a plurality of items, the items having been created by at least two different types of applications;
  • 1[b] establishing a collection of the plurality of items;
  • 1[c] associating a user-selected graphical representation with the collection, selectable to open the collection;
  • 1[d] displaying the user-selected graphical representation of the collection persistently within a portion of a file browser display while another portion of the file browser display changes responsive to file browser display criteria.

Claim 11 is the system counterpart; claim 20 the CRM/bea counterpart — identical substance, different statutory category.

Dependents: 2–3 (items in two or more locations; local + cloud), 4 (arrange per user preferences), 5 (criteria = date / type / most recently accessed), 6 (representation invariable regardless of zoom level), 7 (representation scrollable off-screen), 8–9 (indication of item types and counts in the collection), 10 (add item from within the creating application's UI).

The real inventive hooks in claim 1 are 1[a] (cross-application aggregation) and 1[d] (a persistent, fixed pane co-existing with a sortable/changing pane).


2. Candidate prior art (all pre-dating the 2012-12-21 effective filing date, i.e., available as prior art under pre-AIA §102(a)/(b)/(e) — the 2012 filing falls before the AIA first-inventor-to-file provisions took effect on 2013-03-16)

Ref Publication Date What it discloses
A US 2006/0036568 A1, "File System Shell" (Microsoft) — https://patentimages.storage.googleapis.com/f6/1d/7b/8ff129e59aa854/US20060036568A1.pdf 2006-02-16 "Virtual folders which expose regular files and folders to users in different views based on their metadata instead of the actual physical underlying file system structure." Libraries "consist of large groups of usable types of items that can be associated together." Quick links "which can be clicked on to generate useful views of the sets of items." Filters for narrowing sets. A shell browser and virtual address bar.
B US 2004/0193594 A1, "File system for displaying items of different types and from different physical locations" (Microsoft) — https://www.freepatentsonline.com/y2004/0193594.html 2004-09-30 "The virtual folders may represent files or items from different physical locations, such as from multiple disk drives within the same computer, between multiple computers, or different network locations, such that one view … can expose files or items sitting at different physical locations." Explicitly extends to non-file entities (e-mails, contacts).
C The ubiquitous persistent-navigation-pane / "Favorites" bookmark model: Windows Explorer's Favorites/Quick Access navigation pane (Windows 7, 2009) and the browser bookmarks bar (IE Favorites since the 1990s) well before 2012 A user-created, user-labeled shortcut to a set of items, pinned in a fixed pane of a file-browser/bookmarks UI, that remains visible while the main content pane re-sorts, filters, or navigates.

Refs A and B are the key art; C supplies the persistence element as a matter of common knowledge and prior public use.


3. Element-by-element mapping and the combinations

Combination 1 (primary): A in view of C; optionally B

  • 1[a] (≥ two application types): A's File System Shell expressly models "other data-types not stored as files" and aggregates items regardless of originating application, and B expressly covers "e-mails," "contact information from a contact database," and files "from different physical locations." Two application types is squarely met.
  • 1[b] (establishing a collection): A's virtual folder / library is exactly a collection of user-identified items assembled by metadata query, not physical location ("Location-independent views"). B's virtual folders likewise.
  • 1[c] (user-selected graphical representation, selectable to open): A's "quick links … which can be clicked on to generate useful views of the sets of items" is a selectable on-screen representation of a saved set; A also provides naming/identification of virtual folders. If A is read narrowly, C (a user-named "Favorites"/bookmark icon that opens the saved set) supplies this limitation directly, and Ref C is not merely analogous but in the same field of endeavor (file-browser navigation).
  • 1[d] (persistent pane while another portion changes): This is the classic navigation pane vs. content pane architecture of Windows Explorer/Finder and of any bookmarks bar. A itself discloses a shell browser with a virtual address bar and filter-driven views that change while shell chrome persists. Ref C supplies the express teaching that user bookmarks/favorites remain anchored while the browsed content area re-sorts by date, type, name, etc.

Combination 2 (alternative): A in view of B in view of C

B adds the express teaching of multi-location/multi-type aggregation, shoring up 1[a] and dependent claims 2–3 (local + cloud/network: B recites "multiple computers," "different network locations," and the specification of the '643 patent itself maps this to server 120 and cloud 125).

Dependent claims

  • 2–3: Fully met by B (different physical locations; network locations). "Cloud storage" is a predictable labeling of a network location.
  • 4 / 15: User-arranged ordering of items in a saved view was a conventional property of virtual folders and of bookmark lists (drag-to-reorder).
  • 5 / 14: A's views are expressly generated by metadata pivots ("grouped by album," "genres or artists or years," "tailor the view"); date, type, and most-recently-accessed are the textbook metadata pivots in that reference and in Explorer's "Arrange by" menu.
  • 6 (invariable regardless of zoom): A pinned nav-pane/quick-link icon that does not scale with content is the ordinary behavior of OS chrome — a predictable design choice, not a technical advance.
  • 7 (scrollable off-screen): Ordinary consequence of placing the persistent region inside a scrollable canvas.
  • 8–9 (indication of item types and counts): A's "arrange/group by metadata" views, and standard folder "type + count" aggregation, disclose or render obvious per-type counts.
  • 10 (add from within creating application): A's shell integrates "rich integration of various data types" and direct-manipulation add-to-library; and the '643 patent's own FIG. 14 "favorites" button is itself the routine "Save to / Add to Favorites" command found in word processors, browsers and e-mail clients since the 1990s.

4. Motivation to combine (KSR / Graham factors)

A POSITA at 2012-12-21 would have been motivated, with a reasonable expectation of success, because:

  1. Same field, same problem, same actors. A and B are both Microsoft file-system-shell references addressing the identical problem the '643 patent identifies in its own Background — "it can be difficult to determine the contents of a given folder without opening the folder," and "items residing in a given folder are secluded from items residing in other folders" (see the page's own "Definitions" section). The '643 patent's stated problem is thus admitted prior art.
  2. Known technique, predictable result. Adding a persistent region to a shell is not an unpredictable combination — it is the ordinary two-pane layout already used in every file browser. KSR holds that "a combination of familiar elements according to known methods is likely to be obvious when it does no more than yield predictable results."
  3. Design incentive / market force. If a user can save a set (A's quick link), the user must be able to reach and recognize that set; pinning it in a fixed pane is the known, natural solution. The '643 patent's own "Definitions" concedes that prior sorting methods "do not allow users to view … a favorite content items set, in a persistent collection relative to other information items" — i.e., the inventor frames the invention as a straightforward ergonomic fix to a recognized deficiency, which cuts for obviousness.
  4. Obvious to try. The prior art discloses a small, finite set of candidate placements for the persistent element (left nav pane, top bar, bookmarks bar). Selecting among them is within the routine skill level.
  5. Platform unification. B already teaches that the same shell should expose files, e-mail, and contacts from multiple locations — which supplies the very reason to let items "created by at least two different types of applications" live in one shell collection.
  6. No teaching away. Neither A nor B disparages persistent, user-created collection views; both actively encourage user tailoring of views ("The user can tailor the view to see only the objects suited to the task at hand. This allows an improved browsing experience that negates the need for further navigation").

5. Anticipated counter-arguments (and their weakness)

  • "Ref A is a metadata query, not a user-identified collection." A also discloses user-created libraries and quick links that are saved, named, and clicked. Combined with C, 1[a]–1[c] are met.
  • "The persistence limitation is the point of novelty." Persistence of navigation chrome while content re-sorts is pervasive prior art in file browsers and browsers generally; it will be very difficult to distinguish over public prior use of Windows Explorer Favorites and web-bookmark toolbars.
  • "The 'at least two different applications' limitation is novel." B directly contemplates e-mail, contacts and files in a single view; that is two application types.
  • Realistic defense: the best non-obviousness argument is a narrow one tied to claims 6/7 (zoom-invariance and off-screen scrollability of the collection representation), and even those read on ordinary pinned-icon chrome.

6. Secondary considerations

No persuasive secondary considerations appear in the record supplied. The page shows an active patent with an adjusted expiration of 2033-04-14, TW/CN/EP/PCT/AR family filings, and a continuation (US 2019/0196670), but commercial success, long-felt need, failure of others, and industry praise are not evidenced on the face of this page, and family/continuation activity is not, by itself, probative of non-obviousness.


7. Conclusion

A reasonable prima facie case of obviousness under § 103 exists against the independent claims and most dependents, on the following grounds:

  • Ground 1: US 2006/0036568 A1 in view of the persistent-favorites/navigation-pane art (C) — renders claims 1, 4–9, 11, 14–18, 20 obvious.
  • Ground 2: US 2006/0036568 A1 in view of US 2004/0193594 A1 and C — renders claims 1–3, 10–13, 19, 20 obvious (adding the multi-location / local-and-cloud and add-from-application limitations).

The strongest invalidity theory is not a single-reference anticipation but the KSR combination of a Microsoft virtual-folder/file-system-shell reference with the ordinary, well-known persistent bookmark/favorites pane — the aggregation problem was known and admitted, the elements were known, and the assembly yields only predictable results.

Confidence: high on the legal framework and on the mapping of claims 1[a]–1[c] and the dependents; lower on the exact granted claim text of US 10,241,643 (I analyzed the family's published claim set) and on the identity of the specific references in the page's "Prior Art" section, which was not present in the material I received. Before filing any paper, the granted claims and the actual "Citations/Similar Documents" table should be verified directly at https://patents.google.com/patent/US10241643B2/en and against the printed patent PDF at https://patentimages.storage.googleapis.com/d5/0c/d7/07cbbd2b29f74d/US10241643.pdf.

Note: This patent's claims also raise independent § 101 subject-matter questions (pervasive-UI/data-organization concepts), which are outside the scope of the § 103 question asked but often run in parallel in validity analysis.

Generated 10/1/2026, 5:21:25 PM

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