Invalidity dossier

US 10244284

Display apparatus and video processing apparatus

Current assignee: LG Electronics, Inc.

Added 9/25/2026, 12:46:22 PM

At a glanceNo PTAB challenges3 lawsuits on fileasserted by LG Electronics, Inc.Media & Broadcasting (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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Summary: US 10,244,284 B2

Source note: The authoritative full text you supplied (Google Patents, fetched 2026-09-25) is my primary source. Where third‑party databases differ slightly on dates, I flag it rather than auto‑correcting. Google Patents reports 2018‑02‑07 filing and 2019‑03‑26 issue; Unified Patents' portal reports 2018‑02‑06 application date and 2019‑03‑25 grant date.


Bibliographic data

Field Value
Patent number US 10,244,284 B2
Title Display apparatus and video processing apparatus
Application number 15/891,085
Publication (pre‑grant) US 2018/0167671 A1 (published 2018‑06‑14)
Inventors Toshiyuki Kurita; Hitoaki Owashi
Assignee (original) Maxell, Ltd.
Assignee (current) Maxell, Ltd. (Kyoto, JP) — via Maxell Holdings, Ltd. merger/name change recorded 2021‑11‑29 and 2021‑12‑03
Filing date 2018‑02‑07
Issue date 2019‑03‑26
Earliest priority JP 2007‑306750, filed 2007‑11‑28 (Google Patents lists prior‑art date 2007‑11‑28; Unified Patents lists priority 2007‑11‑27)
Anticipated expiration 2028‑10‑29 (Google Patents); 2028‑10‑28 (Unified Patents)
Legal status Active
Examiner Mekonnen D. Dagnew (Art Unit 2664)
CPC H04L 69/14; H04N 21/4122; H04N 21/41407; H04N 21/43637; H04N 21/4367; H04N 5/44

Continuity (per the specification's Incorporation by Reference and USPTO records): This patent is a continuation of US application 15/208,886 (filed 2016‑07‑13, now US 10,129,590), which is a continuation of US application 12/260,410 (filed 2008‑10‑29, now US 9,420,212), which claims priority to JP 2007‑306750.

Family members claiming priority through this chain (as listed on the Google Patents page): US 11,451,860; US 11,451,861; US 10,958,971; US 11,509,953; US 11,445,241; US 12,143,665; US 12,418,692.


Abstract (as issued)

"While presenting on a display apparatus videos of high picture quality obtained from portable video processing apparatuses such as a camera and a cellular, it is possible to communicate with the Internet and/or a home network. A display apparatus includes a first radio communication unit capable of receiving video information by radio from an external video processing apparatus, a second radio communication unit capable of connecting by radio to a network, and a control unit for controlling assignment of connection by radio transmission for each of the first and second radio communication units. The control unit assigns connection of the first radio communication unit with higher priority and controls the assignment of the transmission rate such that the transmission rate between the first radio communication unit and the external video processing apparatus is more than that between the second radio communication unit and the network."


Plain‑language overview

Problem addressed: HDMI was designed for in‑home, device‑to‑device wired links and does not contemplate simultaneously connecting to the internet or a home network while high‑quality video is being viewed. The patent's stated object is to let a display apparatus show high‑picture‑quality video wirelessly received from a portable device (camera, phone, etc.) while also communicating wirelessly with the internet/home network.

Core mechanism: Two (or more) radio modems share a limited radio‑frequency resource. A "transmission rate assignment controller" (e.g., 1001 in the video processing apparatus, 2017 in the display apparatus) allocates that resource between them, under control of a controller. The assignment to the video link is given priority over the network link, so the video stream is not degraded. Examples include two OFDM modems with different parameter schemes (FIG. 9: "scheme 1" = 17 Mbps vs. "scheme 2" = 5 Mbps), and a bank of fixed‑band modems (FIG. 4: modems 5001–5004 with bands A–D; FIG. 8: modems 9010–9013) that can be re‑allocated between video and network use (e.g., modems 5001–5003 for video, only 5004 for the network when HD video is being sent). The spec also describes user‑indicated control, MIMO, QPSK vs. 64QAM allocation of MSB/priority bits, and HDMI/CEC/DDC apparatus‑authentication features.


Independent claims — important caveat

I do not have the full, verbatim claim set for US 10,244,284. The text you supplied is truncated mid‑specification (it ends in the FIG. 2 discussion of modem 2015) and does not include the claims. I will therefore not fabricate claim language. What can be stated with grounding:

  1. Claim numbering and scope of challenge. In IPR2025‑00520, petitioner LG Electronics challenged claims 18–20, which indicates claim 18 is an independent claim with claims 19 and 20 depending from it. (Source: Ex Parte PTAB case summary for IPR2025‑00520, which lists "Challenged Claims: 18‑20".)

  2. Claim 18 is a method claim. Elements recited (as quoted in the IPR petition) include:

    • [18e] "controlling assignment between the first radio communication circuit and the external apparatus, and assignment between the second radio communication circuit and the internet or the home network;"
    • [18f] "controlling the assignment such that the assignment between the first radio communication circuit and the external apparatus is prioritized more than the assignment between the second radio communication circuit and the internet or the home network."

    The final step originally issued without the word "prioritized"; Maxell filed a Certificate of Correction inserting "prioritized" into that last step. (Source: IPR2025‑00520 petition, quoting the request for Certificate of Correction.) The IPR petition also records that a related district court construed similar language in a child of the '284 patent, and that the parties disputed whether "assignment … more than" requires assigning particular connection parameters (e.g., bandwidth, transmission schedule) to each connection.

  3. Other independent claims (lower confidence). DWPI abstract records for the '284 document describe (a) a display apparatus whose controller controls assignment between a first radio communication circuit and an external video processing apparatus, and between a second radio communication circuit and the internet/home network; (b) a video processing apparatus whose controller controls the first/second communicators in response to receiving a user indication, so that video is transmitted from the first while the second connects to the network; and (c) a method for processing video information with simultaneous transmit‑video/connect‑to‑network control. These are abstracting‑service characterizations, not verified claim text, so treat the exact independent‑claim set as uncertain.

Plain‑language bottom line (high confidence in substance, not in exact words): The claimed invention is a device or method in which one radio link carries video to/from a nearby external device, a second radio link carries internet/home‑network traffic, and a controller arbitrates the shared radio resource so the video link's assignment is prioritized over (more than) the network link's assignment.


Litigation and PTAB/CAFC status (as of the searches)

  • PTAB — IPR2025‑00520: LG Electronics, Inc. and LG Electronics USA, Inc. v. Maxell, Ltd., filed January 21, 2025 (portal lists Jan 22), against US 10,244,284, challenging claims 18–20. Asserted grounds included obviousness over Honkanen (US 2006/0135076 A1) in view of the Nokia N95‑1 user guide, and over Dua (US 2006/0258289) in view of Barnes (US 2005/0136949 A1). The proceeding was terminated as settled on July 9, 2025, with a post‑institution fee refund requested July 22, 2025. Sources: docketalarm IPR2025‑00520 records; ipverse.greyb case page ("Terminated‑Settled," termination date 2025‑07‑09).
  • District court: the patent was one of nine asserted in Maxell, Ltd. v. LG Electronics Inc. et al., originally 5:23‑cv‑00152 (E.D. Tex., filed 2023‑12‑29), then 5:24‑cv‑04972 (N.D. Cal., filed 2024‑08‑09). The parties filed a stipulation of dismissal with prejudice (Rule 41(a)(1)(A)(ii)), each side bearing its own costs. Google Patents additionally lists a W.D. Tex. case 6:22‑cv‑00334.
  • ITC: Google Patents lists two investigations involving this family — 337‑TA‑1324 and 337‑TA‑1312. I did not verify which claims of the '284 patent (if any) were asserted in each.
  • CAFC 2026 dockets: I found no Court of Appeals for the Federal Circuit 2026 appeal docket specifically naming US 10,244,284. I want to be explicit about this rather than infer one. The only 2026 appellate‑adjacent Maxell item the searches surfaced was a Unified Patent Court (The Hague) order dated 10 April 2026 (R.105.5) in Maxell v. Samsung — but that concerns EP 2061230, a different patent and a different forum, so it is not an appeal of US 10,244,284.
  • Caution on similar numbers: search results repeatedly surfaced U.S. Patent No. 8,116,284 (Motorola/Hytera CAFC 19‑2126, Hytera v. Motorola Solutions) and U.S. Patent No. 6,856,760. These are different patents and their holdings (e.g., the Hytera affirmance) say nothing about US 10,244,284.

Uncertainty statement

  1. Complete claim text: not available in the material I retrieved; the abstract, specification, and quoted claim fragments are reliable, but I cannot represent the full text of independent claims 1 (if any), 18, or any other independent claims.
  2. Date discrepancies: filing (2018‑02‑06 vs. 2018‑02‑07), issue (2019‑03‑25 vs. 2019‑03‑26), priority (2007‑11‑27 vs. 2007‑11‑28), and expiration (2028‑10‑28 vs. 2028‑10‑29) differ between Google Patents and Unified Patents; I have not adjudicated which is correct.
  3. No CAFC 2026 docket found for this patent; absence of a search hit is not proof that none exists, particularly for very recent filings.

Generated 9/28/2026, 7:03:40 PM

Cases on file (3)

Group view →

Specific litigation cases in our database that name US patent 10244284. The free-form analysis below may also discuss cases beyond this list.

Lawsuits filed per year

2022: 1 case1'222023: 1 case'23'242025: 1 case'25
Cases asserting US 10244284, by filing year.
  • IPR2025-00520USPTO Patent Trial and Appeal Boardterminated Jul 9, 2025terminated - settled

    Defendants: Maxell, Ltd.

  • 5:23-cv-00152; 5:24-cv-04972U.S. District Court for the Eastern District of Texas (originally); transferred to U.S. District Court for the Northern District of Californiaterminated Jul 2, 2025transferred; closed/dismissed (settlement)

    Defendants: LG Electronics Inc., LG Electronics U.S.A., Inc.

    Other patents asserted: 8736729, 6856760, 6973334, 7199821, 8339493, 7421188, 9818449, 10199072

  • 6:22-cv-00334U.S. District Court, Western District of Texas (Waco Division)terminated Jun 29, 2023terminated (closed/stayed)

    Defendants: Lenovo Group Ltd., Lenovo (United States) Inc., Motorola Mobility LLC

Litigation summary

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

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I'll research litigation involving US Patent 10,244,284 using litigation-focused sources.

Let me dig into the specific cases identified.

Litigation Involving U.S. Patent No. 10,244,284 ("the '284 Patent")

Patent owner: Maxell, Ltd. (Maxell Holdings, Ltd. → Maxell, Ltd.) — Display apparatus and video processing apparatus; priority date Nov. 28, 2007; granted Mar. 26, 2019.

I searched litigation-focused sources (Unified Patents portal, Docket Alarm, Justia, CourtListener, ITC/Federal Register, PTAB). The '284 Patent has been asserted in two ITC Section 337 investigations, two district court actions, and challenged in one PTAB inter partes review. Details below. Where a fact is uncertain I say so.


1. ITC Investigation — Certain Mobile Electronic Devices, Inv. No. 337-TA-1312

Field Detail
Complainant Maxell, Ltd. (Japan)
Respondents Lenovo Group Ltd. (China); Lenovo (United States) Inc. (Morrisville, NC); Motorola Mobility LLC (Libertyville, IL)
Jurisdiction U.S. International Trade Commission
Case No. 337-TA-1312
Complaint filed March 30, 2022
Instituted April 28, 2022
Status Instituted; ALJ Monica Bhattacharyya designated to preside

The complaint asserted the '284 Patent together with U.S. Patent Nos. 7,199,821, 7,324,487, 8,170,394, 8,982,086, and 10,129,590.
Sources: Lexology "ITC Institutes Investigation (337-TA-1312)" (https://www.lexology.com/library/detail.aspx?g=a29d3118-9eb3-4158-ab66-dbd12b9d89a6); Chinese MOFCOM trade-remedy notice (https://cacs.mofcom.gov.cn/cacscms/article/ssqdc?articleId=[173760](/patent/173760)).

2. ITC Investigation — Certain Mobile Electronic Devices, Inv. No. 337-TA-1324

Field Detail
Complainant Maxell, Ltd.
Respondents Lenovo Group Ltd.; Lenovo (United States) Inc.; Motorola Mobility LLC
Jurisdiction U.S. International Trade Commission
Case No. 337-TA-1324
Complaint filed June 16, 2022 (supplement June 30, 2022)
Instituted Aug. 16, 2022 (notice published 87 FR 51445, Aug. 22, 2022)
Asserted '284 claims Claims 1, 3, 4, 7, 9, 10, and 18–20
Outcome/Status On Feb. 6, 2023 the ALJ issued an initial determination (Order No. 16) terminating the investigation as to the '590 and '284 patents based on complainant's withdrawal; the Commission declined review on March 6, 2023. Investigation therefore terminated as to the '284 Patent.

Sources: 87 FR 51445 (https://www.federalregister.gov/documents/2022/08/22/2022-17975); Chinese trade-remedy summary of the March 6, 2023 partial final determination (https://www.ccpit-sichuan.org/newshow.aspx?mid=88&sid=227&id=12179).

⚠️ Note / caution: The record shows two separate Maxell investigations against Lenovo/Motorola (1312 and 1324) asserting an overlapping patent set that includes the '284 Patent. The two institution notices are distinct (they list slightly different '590 claims), so they appear to be genuinely separate investigations, but I could not fully reconcile the two complaint dates from the sources retrieved. The Google Patents page for the '284 Patent lists only 337-TA-1324 among ITC matters.

3. District Court — Maxell, Ltd. v. Lenovo Group Ltd., et al.

Field Detail
Plaintiff Maxell, Ltd.
Defendants Lenovo Group Ltd.; Lenovo (United States) Inc.; Motorola Mobility LLC
Jurisdiction U.S. District Court, Western District of Texas (Waco Division)
Case No. 6:22-cv-00334 (Judge Alan D. Albright; Mag. J. Derek T. Gilliland)
Filed March 30, 2022
Asserted '284 claims Claims 1, 3–5, 7, 9–11, 13–16, and 18–20 (direct infringement under §271(a); induced §271(b); contributory §271(c))
Outcome/Status Docket shows case terminated June 29, 2023, with case flags "CLOSED" and "STAYED." No judgment on the merits was entered on the public docket; the termination is consistent with resolution/settlement. Related Maxell–Lenovo case No. 6:21-cv-01169 (W.D. Tex.) also existed.

Sources: Docket Alarm case page (https://www.docketalarm.com/cases/Texas_Western_District_Court/6--22-cv-00334/Maxell_Ltd._v._LENOVO_GROUP_LTD._et_al/); Maxell complaint excerpts (https://insight.rpxcorp.com/litigation_documents/14681420); ExParte case summary (https://ai-lab.exparte.com/case/dct/txwd/6:22-cv-00334/maxell-ltd-v-lenovo-group-ltd).

4. District Court — Maxell, Ltd. v. [LG Electronics Inc.](/litigations/by-plaintiff/LG%20Electronics%20Inc.) and LG Electronics U.S.A., Inc.

Field Detail
Plaintiff Maxell, Ltd.
Defendants LG Electronics Inc.; LG Electronics U.S.A., Inc.
Jurisdiction Originally E.D. Tex. (filed Dec. 29, 2023); transferred to U.S. District Court, Northern District of California, San José Division (transfer granted July 1, 2024)
Case No. 5:24-cv-04972 (N.D. Cal.) — docketed as 5:24-cv-04972-EKL then 5:24-cv-04972-NW-SVK; Judges Eumi K. Lee → Noël Wise
Asserted '284 claims Claims 18–20
Status (current) Pending/settling. Maxell sued on nine patents, including the '284 Patent. On April 29, 2025 the parties filed notice of a prospective global settlement (recorded by MLex). A judge's April 25, 2025 order denied LG's bid to stay the case. LG's earlier motion for judgment on the pleadings under §101 concerned other patents ('188, '072, '449, '760), not the '284 Patent.

Sources: MLex, "Maxell, LG give notice of settlement in California patent row" (April 29, 2025) (https://www.mlex.com/mlex/articles/[2332346](/patent/2332346)/); N.D. Cal. Joint Case Management Statement (https://www.docketalarm.com/cases/PTAB/IPR2025-00393/LG_Electronics_Inc._v._Maxell_LTD/docs/04-11-2025-Patent_Owner/Exhibit-2002-Ex_2002.pdf); CourtListener docket 69032831 (https://www.courtlistener.com/docket/69032831/maxell-ltd-v-lg-electronics-inc/).

5. PTAB — LG Electronics, Inc. v. Maxell, Ltd., IPR2025-00520

Field Detail
Petitioner LG Electronics, Inc. (and affiliates)
Patent Owner Maxell, Ltd.
Forum USPTO Patent Trial and Appeal Board (inter partes review under 35 U.S.C. §311 et seq.)
Case No. IPR2025-00520
Filed Jan. 21, 2025
Patent at issue U.S. Patent No. 10,244,284
Outcome/Status Terminated — Settled (termination date July 9, 2025); joint motion to terminate filed July 1, 2025

Sources: Google Patents litigation badge for US10244284; Docket Alarm PTAB record (https://www.docketalarm.com/search/PTAB/dockets/?f=party_obj.name_exact-LG+Electronics); GreyB IPVerse case page (https://ipverse.greyb.com/ptab-web/cases/case-details/IPR2025-00520); joint motion to terminate (https://www.docketalarm.com/cases/PTAB/IPR2025-00520/...).


Items I could NOT confirm (flagged, not asserted)

  • Maxell v. [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.), No. 6:20-cv-00646 (W.D. Tex.) appears in the same document family as the '284 Patent, but I could not confirm the '284 Patent was actually asserted in that action. Do not treat it as a '284 case.
  • Samsung matters. A Maxell ITC complaint against Samsung Electronics (filed Dec. 17, 2024, DN 3793) and a Maxell ITC complaint against Samsung instituted Aug. 12, 2026 (91 FR 52712) exist, but I could not confirm from the retrieved sources that the '284 Patent was asserted in either. (Samsung did file a PTAB challenge involving the related '590 Patent — e.g., IPR2024-00906.)
  • No CAFC appeal involving the '284 Patent was found in the sources retrieved.
  • The Google Patents page itself lists the family as having a "First worldwide family litigation filed" (Darts-IP link) and a foreign counterpart litigation record, suggesting possible non-U.S. (e.g., German) proceedings involving the family; I did not verify any such action on the '284 Patent specifically.

Summary table of confirmed '284 matters

# Case Forum Parties Case No. Filed Status
1 Certain Mobile Electronic Devices ITC Maxell v. Lenovo / Motorola 337-TA-1312 Mar. 30, 2022 (instituted Apr. 28, 2022) Instituted; outcome unclear from retrieved sources
2 Certain Mobile Electronic Devices ITC Maxell v. Lenovo / Motorola 337-TA-1324 Jun. 16, 2022 (instituted Aug. 16, 2022) '284 terminated Mar. 6, 2023 (withdrawal)
3 Maxell, Ltd. v. Lenovo Group Ltd., et al. W.D. Tex. Maxell v. Lenovo / Motorola 6:22-cv-00334 Mar. 30, 2022 Terminated June 29, 2023 (closed/stayed)
4 Maxell, Ltd. v. LG Electronics Inc., et al. N.D. Cal. (from E.D. Tex.) Maxell v. LG Electronics 5:24-cv-04972 Dec. 29, 2023 Pending; settlement noticed Apr. 29, 2025
5 LG Electronics, Inc. v. Maxell, Ltd. PTAB (IPR) LG v. Maxell IPR2025-00520 Jan. 21, 2025 Terminated–Settled July 9, 2025

Bottom line: The '284 Patent is a currently asserted Maxell assertion patent that has been deployed against Lenovo/Motorola (ITC 337-TA-1312 and -1324; W.D. Tex. 6:22-cv-00334) and LG Electronics (N.D. Cal. 5:24-cv-04972), and was challenged at the PTAB by LG in IPR2025-00520. All confirmed matters appear to have resolved (settled/withdrawn/terminated) rather than by merits judgment, and none of the retrieved sources show a CAFC appeal on this patent.

If you need PACER-level confirmation of the exact disposition documents (e.g., the W.D. Tex. dismissal order or the N.D. Cal. settlement dismissal), that would require pulling the individual dockets, which I was unable to fully retrieve here.

Generated 9/28/2026, 7:04:00 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: LG Electronics, 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 research the PTAB proceedings for US10244284, starting with the one flagged in the patent record.

Let me gather the full picture — including any other IPRs on this patent and the key procedural events.

Proceedings overview

One AIA trial proceeding exists on US 10,244,284 — IPR2025-00520 (LG v. Maxell) — and it terminated on settlement before the Board ever decided institution, so zero claims have been canceled, zero sustained, and zero adjudicated: the patent comes out of the PTAB completely untested, not "hardened."

A flag on sourcing before the details: the prompt's structured block says the USPTO ODP API returns no AIA trial proceedings. That is not accurate as to this patent. The patent record itself carries the "PTAB case IPR2025-00520 filed (Settlement)" litigation tag, and multiple independent sources (Google Patents litigation metadata, Docket Alarm, GreyB/IPverse, petitioner's own fee-refund filing) confirm the proceeding. Treat IPR2025-00520 as the canonical (and only confirmed) proceeding, and treat the ODP "no activity" result as an ingest lag.


IPR2025-00520 — LG Electronics, Inc. & LG Electronics USA, Inc. v. Maxell, Ltd.

  • Type: Inter Partes Review (35 U.S.C. §§ 311–319), tech center 2600 / art unit 2699
  • Filed: 2025-01-21 (LG's own fee-refund filing states "On January 21, 2025, Petitioner filed a Petition…"; a related mandatory notice lists the same docket as "filed January 22, 2025" — the one-day discrepancy is a filing/assignment artifact, not two petitions)
  • Status: Terminated-Settled (verbatim from structured data). Plain English: the parties settled and the Board closed the case before the Director ever ruled on institution. No institution decision, no trial, no Final Written Decision.
  • Judge panel: APJs Jason W. Melvin, Kevin C. Trock, and Monica S. Ullagaddi (panel identification via third-party PTAB docket analytics — GreyB/IPverse and the Docket Alarm case page — because no institution decision ever formally constituted a panel). Judge career stats: Melvin ~80% institution / 86% FWD-invalidity rate; Trock ~69% / 88%; Ullagaddi ~70% / 78%.
  • Petition grounds (all § 103 obviousness; no § 102 or § 112 theories were asserted):
    • Ground 1 — claims 18–20 obvious over Honkanen (US 2006/0135076 A1) in view of the Nokia N95-1 User Guide.
    • Ground 2 — claims 18–20 obvious over Dua (US 2006/0258289 A1) in view of Barnes (US 2005/0136949 A1).
    • Additional grounds relying on Nokia N93 User Guide, the Bluetooth Specification, Tee (US 2006/0203758 A1), Kelton (US 2004/0125779 A1), Kao (US 2004/0264600 A1), IEEE 802.11g, and Malyan & Lenaghan (Eurocon 2003), supported by the declaration of Dr. R. Michael Buehrer (LG-1003).
    • Claims 19–20 are dependents adding different frequency bandwidths and different modulation methods limitations; LG argued Bluetooth vs. WLAN inherently supply those distinctions.
  • Institution decision: None. No § 314(a) decision issued. Termination was expressly styled a "Pre-DI settlement" (settlement prior to institution of trial) under 37 C.F.R. § 42.74. The Board never reached discretionary denial, Fintiv, § 325(d), or the merits.
  • Final Written Decision: None issued. Because no FWD exists, there is no claim-level verdict of any kind — claims 18, 19, and 20 were neither canceled nor upheld. Anyone who tells you an LG IPR knocked out claims of the '284 patent is wrong.
  • Settlement / termination: LG and Maxell filed a Joint Motion to Terminate on 2025-07-01, invoking 35 U.S.C. § 317(a) and 37 C.F.R. § 42.74, representing that the Office had not decided the merits. The Board entered its Termination Decision on 2025-07-09. The settlement agreement was filed as Confidential Exhibit LG-1020 with access "Board and Parties Only" and a concurrent request to treat it as business confidential information under § 317(b) and 37 C.F.R. § 42.74(c) — its terms are confidential and not public. Context: the IPR settlement tracked a broader 2025-04-29 notice of prospective settlement in the N.D. Cal. case Maxell v. LG, 5:24-cv-04972 (Judge Noël Wise). LG filed for a refund of $28,125.00 in post-institution fees on 2025-07-22, confirming nothing post-institution ever happened.
  • Appeal: None. A pre-institution § 317(a) termination is not appealable under § 319; there is no FWD to appeal. No Federal Circuit docket exists for this proceeding.
  • Defensive value: The single most useful fact for a defendant is the absence of a merits ruling — IPR2025-00520 is a nullity on validity. Nothing in it invalidates a claim, and because it died pre-FWD, it produces no § 315(e)(2) estoppel against LG and no estoppel against anyone else. It is, however, a roadmap: LG's Honkanen+N95 and Dua+Barnes § 103 combinations against claims 18–20 are public in the petition exhibits and remain fair game for a new petitioner.

Strategic summary

Claim status — canceled / sustained / untested. For US 10,244,284 the ledger is entirely blank. No claim has been canceled. No claim has been sustained. Every claim is untested at the PTAB. The only claims ever subjected to an AIA-trial petition are claims 18–20 (the method claims LG attacked), and that petition died before institution, so those claims carry no adjudicated validity anywhere. Claims outside 18–20, in particular the apparatus claims, have never been challenged in an AIA trial according to public records. Contrast this with the rest of the Maxell family: sibling/continuation patents in the same chain (e.g., the '590 and '212 parents, and the '860/'861/'971/'953/'241/'665/'692 continuations) have been asserted widely and, in the Samsung track, several Maxell patents took FWDs finding "all but two claims" unpatentable, plus district-court findings of non-infringement on five patents and invalidity on two (see the Samsung briefing at ptacts.uspto.gov, e.g., petitions 1558233 / 1558242). The '284 patent has simply not been through that wringer yet.

Estoppel landscape. § 315(e)(2) estoppel is triggered only by a final written decision. There was none here — the case terminated "Pre-DI" — so LG, LG Electronics USA, and their real parties-in-interest/privies are not statutorily estopped from validity grounds. Practically, LG will be contractually barred by the confidential settlement/license (Ex. 1020), so as a business matter LG is out, but the statutory estoppel hook does not exist. For a new defendant being asserted today, the full prior-art universe is available: LG's grounds (Honkanen+N95; Dua+Barnes; and the Tee/Kelton/Kao/802.11g/Malyan alternatives) can be re-run, and because no institution decision ever issued, there is no § 325(d) discretionary-denial record, no Fintiv timing analysis, and no adverse claim-construction ruling from the Board to fight.

Pattern signals. The Unified Patents page lists IPR2025-00520 as a "PTAB case… filed (Settlement)" but there is no evidence of a Unified Patents (defensive-aggregator) petition on this patent — the petitioner of record is LG, represented by Fish & Richardson (Timothy W. Riffe et al.); Maxell is represented by Mayer Brown (Robert G. Pluta, Nicholas H. Ciulla). IPR2025-00520 was part of a seven-petition LG salvo filed 2024-12-30 through 2025-01-22 against Maxell (IPR2025-00392 '493; -00393 '449; -00394 '072; -00444 '729; -00518 '760; -00519 '188; -00520 '284), all swept up in the LG–Maxell global settlement. That is a litigation-driven counterattack pattern, not an aggregator pattern — LG filed within weeks of Maxell's N.D. Cal. infringement contentions (LG-1012, 2024-12-18). Maxell, for its part, is an aggressive serial enforcer across the ITC (337-TA-1312 and 337-TA-1324 both name the '284 patent, per the ITC filings and the 2022 Lenovo complaint listing US 10,244,284) and district court, and it has shown a willingness to settle globally when the price is right.

One unresolved search hit worth flagging (unverified). Web search surfaced a IPR2026-00284 (Google LLC) docket. The snippet's exhibit content concerned unrelated SoftView claim-construction material and did not tie that proceeding to the '284 patent, so I am not asserting it is a second proceeding on this patent. It should be checked directly against PTAB E2E before relying on the "only one proceeding" conclusion.


Recommended next steps

  1. Do not plead "the patent has been invalidated." It has not. The correct representation is that IPR2025-00520 terminated on settlement pre-institution on 2025-07-09 with no FWD, so all claims remain live and unadjudicated. Pull the termination order and the Joint Motion to Terminate and put them in the file:

  2. Reuse LG's work product freely. Because there is no FWD, no § 315(e)(2) estoppel exists and a new petitioner can file a fresh IPR on claims 18–20 (and on the apparatus claims LG never touched) on the Honkanen+N95 or Dua+Barnes § 103 combinations. Request LG's petition and exhibits (LG-1001 through LG-1019, plus the Buehrer declaration LG-1003) from PTAB E2E; they are a free, expert-supported obviousness case.

  3. Time the filing to the asserted claims. If a demand letter or complaint targets claims 18–20, an IPR is viable and the § 315(b) one-year clock runs from service. If it targets the apparatus claims, treat this as a first-impression challenge — no PTAB record exists to leverage, and you should expect Maxell to lean on the absence of any adverse PTAB ruling.

  4. Watch for a follow-on petition. With LG out via confidential settlement, the natural next movers are the ITC respondents (Lenovo, per 337-TA-1312/1324) or a new district-court defendant. If you are monitoring, set PTAB E2E alerts on patent 10,244,284 and re-check IPR2026-00284 to confirm or clear the unverified hit above.

  5. Mind the expiration. The patent's anticipated expiration is 2028-10-29 (per the Google Patents record; priority 2007-11-28). Any IPR decision would land well before that, so there is runway for an active invalidity strategy — but also a real damages window if you do nothing.

Bottom line for a defendant: the PTAB has said nothing about this patent's validity — one petition was filed, settled, and closed before institution. That is a clean slate, not a hardened patent and not a dead one. The absence of a prior FWD is unambiguously good for a challenger: no estoppel, no adverse claim constructions, no § 325(d) baggage, and a ready-made prior-art package sitting in the public IPR2025-00520 file.

Generated 9/28/2026, 7:04:06 PM

Ownership chain (5)

Asserters network →

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

  1. 2017-10-01 · recorded 2018-01-25 · reel 045142/0208 · Assignment

    Hitachi Maxell, Ltd.Maxell, Ltd.

    Correspondent: Nadeen Nsouli

    internal reorg

  2. 2021-10-01 · recorded 2021-11-29 · reel 058255/0579 · Merger

    Maxell, Ltd.Maxell, Ltd.

    internal reorg

  3. 2021-10-01 · recorded 2021-12-03 · reel 058666/0407 · Change of Name

    Maxell, Ltd.Maxell, Ltd.

    change of name only

  4. ? · Assignment

    Hitachi, Ltd.Hitachi Consumer Electronics Co., Ltd.

    internal reorg

  5. ? · Assignment

    Hitachi Consumer Electronics Co., Ltd.Hitachi Maxell, Ltd.

    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 10,244,284. Let me start with several targeted searches.

Let me dig deeper into the assignment chain and reel/frame details.

I found key reel/frame data. Let me verify the merger/change-of-name reel frames and check for any additional records.

Assignment & Ownership Analysis — US 10,244,284 B2

Method note / source limitation. I ran live searches but the Assignment Center (assignmentcenter.uspto.gov) itself is not directly retrievable through my tools, and I hit my research-step ceiling before I could pull the patent-number-specific record screen. The findings below are reconstructed from (a) a USPTO Patent Assignment Abstract of Title reproduced in a PTAB exhibit (IPR2024‑00906, Ex. 1006, file history of reexam 90/014,651 for sibling patent US 10,129,590), (b) INPADOC legal-status records for sibling family member US 11,102,541 (same bulk Maxell reorganization), (c) Google Patents legal events for the '284 patent itself, and (d) Maxell's own infringement complaints. I flag confidence per item below rather than presenteverything as verified. I did not independently verify that every reel/frame listed covers the '284 patent number specifically.


Inventors

Inventor Employer at filing (determinable?)
Toshiyuki Kurita Hitachi group (Japan). The priority application JP 2007‑306750 (2007‑11‑28) and the original US filing 12/260,410 (2008‑10‑29) were made in the Hitachi consumer-electronics lineage (Hitachi, Ltd. → Hitachi Consumer Electronics). I could not confirm a specific Hitachi legal entity on the face of the record.
Hitoaki Owashi Hitachi group (Japan). Owashi is a long-time Hitachi consumer-electronics inventor. Same caveat.

Unusual patterns: None observed. There is no evidence in the record of inventors departing the original assignee within 12 months of filing, and no inventor-to-entity assignment or inventor-side sale appears in the chain. The inventors never appear as assignors after the original filings. This is the profile of a normal corporate-employee invention, not a fire-sale precursor.


Original assignee

Maxell, Ltd. is named on the issued patent (Google Patents "Original Assignee: Maxell Ltd"; the application 15/891,085 was filed 2018‑02‑07, i.e. after the 2017 Hitachi Maxell → Maxell, Ltd. reorganization, so Maxell, Ltd. was the applicant of record from day one).

  • Line of business: Japanese diversified manufacturer — energy products (coin-type lithium and silver-oxide batteries, all-solid-state batteries), information storage media (magnetic tape, optical discs, LTO data cartridges), semiconductor-process tapes, precision optical components and LED automotive lenses. Legacy consumer electronics (TVs, projectors, cameras, media players) underpin much of the asserted portfolio. (Source: Maxell IR materials; Maxell v. Olympus complaint, D. Del. 1:18‑cv‑00310, ¶1.)
  • Did it ship a product embodying the claims? Unclear / likely no for this specific patent. The '284 claims cover wireless display/video-processing radio-resource assignment. Maxell's current shipping products are batteries, tape media, and optical components; it does not appear to currently market a wireless display-link product. Maxell nonetheless asserts this family against TV/phone/PC makers. This is the one respect in which the "operating company" characterization is imperfect (see Verdict).
  • Current status: Operating and solvent. Publicly traded on the Tokyo Stock Exchange Prime Market (ticker 6810). Not in bankruptcy, not dissolved. It was a Hitachi subsidiary until 2017, when it separated from the Hitachi Group and renamed itself Maxell Holdings, Ltd.; in 2021 it collapsed the holding structure and renamed back to Maxell, Ltd.

Assignment timeline

Records found, newest-relevant first is not used — chronological order as requested.

Caveat on the 2017 record. Reel 045142/0208 is a 141-page bulk assignment. I retrieved its abstract from the file history of sibling patent US 10,129,590 (PTAB IPR2024‑00906, Ex. 1006). The abstract lists Assignor HITACHI MAXELL, LTD., execution date 2017‑10‑01, assignee address 1 Koizumi, Oyamazaki, Oyamazaki-cho, Otokuni-gun, Kyoto, Japan. The '284 patent is a continuation within the same family, so the same chain of title applies by law, but I could not personally confirm that the '284 patent number is listed on reel 045142/0208.

Caveat on the 2021 records. Reel/frame 058255/0579 and 058666/0407 were surfaced from INPADOC legal-status data for sibling US 11,102,541 (the same Maxell bulk reorganization filings). Google Patents legal events for the '284 patent list the identical two events on the identical dates, so I have high — but not absolute — confidence these reel/frames also cover the '284 patent.


  • 2017‑10‑01 (executed) / recorded 2018‑01‑25 — Reel 045142/0208

    • Conveyance: Assignment of assignors' interest (see document for details)
    • Assignor: Hitachi Maxell, Ltd.
    • Assignee: Maxell, Ltd. — 1 Koizumi, Oyamazaki, Oyamazaki-cho, Otokuni-gun, Kyoto, Japan
    • Correspondent: Nadeen Nsouli, 71 South Wacker Drive, Chicago, IL 60606. Single appearance in this chain; I could not confirm recurrence on other tracked patents, so I do not treat it as an NPE tell.
    • Context: Internal corporate reorganization — the 2017 separation of the Maxell business from the Hitachi Group and alignment of the IP estate under the newly renamed operating company.
  • 2021‑10‑01 (effective) / recorded 2021‑11‑29 — Reel 058255/0579

    • Conveyance: Merger
    • Assignor: Maxell, Ltd.
    • Assignee: Maxell Holdings, Ltd.
    • Correspondent: not captured in the sources retrieved
    • Context: Internal reorg — absorption-type merger (announced 2021‑04‑28, effective 2021‑10‑01) in which holding company Maxell Holdings, Ltd. absorbed its wholly owned operating subsidiary Maxell, Ltd.; Maxell, Ltd. was the disappearing entity at this step. Recorded as "MERGER; ASSIGNOR: MAXELL, LTD."
  • 2021‑10‑01 (effective) / recorded 2021‑12‑03 — Reel 058666/0407

    • Conveyance: Change of name
    • Assignor: Maxell Holdings, Ltd.
    • Assignee: Maxell, Ltd.
    • Correspondent: not captured in the sources retrieved
    • Context: Change of name only — the surviving holding company renamed itself "Maxell, Ltd." Recorded as "CHANGE OF NAME; ASSIGNOR: MAXELL HOLDINGS, LTD."

Note the apparent circularity — the merger (Maxell, Ltd. → Maxell Holdings, Ltd.) and the change of name (Maxell Holdings, Ltd. → Maxell, Ltd.) carry the same effective date, 2021‑10‑01, and reverse the parties. This is not an error: the holding company absorbed the operating subsidiary and then took the subsidiary's name. The net title effect is nil (same ultimate owner, same address, same group). This pattern is confirmed by the corporate-action notices (Maxell Holdings press release, 2021‑04‑28) and is corroborated identically in INPADOC for other family members and in UK IPO records for EP 1580954.

Earlier links in the chain (stated in Maxell's pleadings; reel/frame not retrieved): Per Maxell's complaints, Hitachi, Ltd. → Hitachi Consumer Electronics Co., Ltd. (2009), then Hitachi Consumer Electronics → Hitachi Maxell, Ltd. (2013), then the 2017 step above. So the full chain is Hitachi, Ltd. → Hitachi Consumer Electronics → Hitachi Maxell, Ltd. → Maxell, Ltd. → Maxell Holdings, Ltd. → Maxell, Ltd. — every step an internal Hitachi/Maxell corporate reorganization, nothing sold outside the group.


Timeline diagram

timeline
    title Ownership of US 10244284
    2007 : Priority JP filing by Hitachi group
    2009 : IP moved to Hitachi Consumer Electronics
    2013 : IP moved to Hitachi Maxell Ltd
    2017 : Reorg Hitachi Maxell to Maxell Ltd
    2018 : Reel 045142 0208 recorded
         : Continuation 15891085 filed
    2019 : Patent US10244284 issued
    2020 : Maxell assertion campaign begins
    2021 : Merger Maxell Ltd into Maxell Holdings
         : Name change back to Maxell Ltd

NPE / troll-pattern signals

  1. Shell-entity transfer — NOT PRESENT. No licensing-only LLC appears anywhere. Every assignee in the chain is a named Japanese operating corporation at the same Kyoto address (1 Koizumi, Oyamazaki). No Delaware/Texas single-purpose entity, no registered-agent service address. Reel 045142/0208 and reels 058255/0579 & 058666/0407 all name operating/formerly-operating corporate parents, not shells.

  2. Known asserter in the chain — NOT PRESENT (as to the named lists). Neither the current nor any prior assignee matches the enumerated NPE lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, DGC, Spangenberg entities). Maxell, Ltd. is a product company. Nuance to flag rather than ignore: Maxell does run one of the most active patent-assertion campaigns of any operating manufacturer (Apple, VIZIO, LG, Samsung, Olympus, etc., 2018–2025), and Unified Patents/RPX track it as a high-frequency plaintiff. That is litigation posture, not a chain-of-title NPE signal.

  3. Repeat correspondent across the chain — UNRESOLVED / NOT A FINDING. The only correspondent captured is Nadeen Nsouli, 71 South Wacker Drive, Chicago, IL 60606 on reel 045142/0208. I obtained no correspondent for reels 058255/0579 or 058666/0407 and could not confirm Nsouli appears on other links or on any NPE assertion list. A single appearance is expressly not a finding.

  4. Cascading transfers — NOT PRESENT. The chain's most recent three links (2017 → 2021 → 2021) span four years, all within one corporate group, and two of the three are a merger and a name change with the same effective date. That is the opposite of rapid chained-LLC laundering.

  5. Pre-litigation transfer — NOT PRESENT. The last real title transfer (the 2021 name change, reel 058666/0407) post-dates the earliest suits in the campaign (e.g., Maxell v. Olympus, 2018; Maxell v. Apple, 6:20‑cv‑00646, filed 2020‑07‑16). No assignment sits within 6 months before a suit against the '284 patent.

  6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 anywhere. Maxell is a listed, profitable manufacturer (TSE Prime, 6810). The 2017 and 2021 events are voluntary group reorganizations, not insolvency sales.

  7. Privateering — NOT PRESENT. Maxell asserts its own patents in its own name (e.g., plaintiff is "Maxell, Ltd.," and "Maxell, Ltd. and Maxell Holdings, Ltd." in the VIZIO action, C.D. Cal. 2:21‑cv‑06758). There is no NPE proxy asserting on Maxell's behalf and no evidence of a back-end royalty split to an outside monetizer. Maxell is the operating company doing the asserting.

  8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. It terminates at Maxell, Ltd. — and Unified Patents is adverse to Maxell (it funded/petitioned the sector) rather than the assignee.


Verdict

Operating-company assertion (with one explicit caveat).

The chain contains zero classic NPE signals: every link from Hitachi, Ltd. through Hitachi Consumer Electronics and Hitachi Maxell to today's Maxell, Ltd. is an internal reorganization of the same Japanese group — reel 045142/0208 (executed 2017‑10‑01), then the paired 2021 merger/name-change records at reels 058255/0579 and 058666/0407 (both effective 2021‑10‑01) — and the current owner asserts the patent in its own corporate name against real competitors. The signal that keeps this at "operating-company assertion" rather than "insufficient data" is the combination of (i) a solvent, publicly traded manufacturer as assignee and (ii) that assignee being the plaintiff of record in the Apple, VIZIO, LG and Samsung actions in which this patent family was asserted.

Caveat I want stated plainly: Maxell's current shipping products (batteries, tape media, optical components) do not obviously embody the wireless-display claims of the '284 patent, so the "ships products embodying the claims" prong of the rubric is only partly satisfied. If a stricter reading is applied, the honest label is "operating-company lineage monetizing a legacy portfolio" — which is not an NPE chain, but is a company behaving like a monetizer toward technology it no longer sells.

Verification link: https://assignment.uspto.gov/patent/index.html#/patent/search/result?q=[10244284](/patent/10244284) — search by patent number, then open the "Patent Assignment Abstract of Title" to confirm the reel/frame entries and correspondents above against the live record (particularly the correspondents for reels 058255/0579 and 058666/0407, which I could not capture).

Generated 9/28/2026, 7:04:26 PM

Prior art

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

✓ Generated

I'll search for the patent's citation records and prior art references.

Let me look for the patent's front-page citation list and examiner references.

Let me retrieve the issued patent's front-page "References Cited" and the Google Patents citation list.

Source basis and honest limitations

Two things up front, because they bound how much I can assert:

  1. I could not open a USPTO PatentCenter/Patent Full‑Text "References Cited" (form PTO‑892) page for US 10,244,284 directly within the available tool calls. What I did retrieve is the front‑page citation table as mirrored by Google Patents for this family, plus the litigation/PTAB record. I will say so at each point rather than present it as a USPTO‑verified list.
  2. The previously generated sections correctly flagged that the claim set is not in the supplied text. The litigation record I retrieved in this task partially fills that gap (see "Claim set" below). I still do not have verbatim claim language, so any § 102 mapping below is an assessment of potential relevance, not a novelty rejection.

One correction/refinement to the prior section's uncertainty, now resolved: the asserted claim set is claims 1, 3–5, 7, 9–11, 13–16, and 18–20 (from Maxell's infringement contentions against Lenovo, RPX litigation document). That confirms claim 1 is an independent claim (not "if any," as the earlier section hedged). So the '284 has at least two independent claims (1 and 18), with 18–20 being the method claims challenged in IPR2025‑00520.


A. The front‑page patent citations of US 10,244,284

Google Patents records "Patent Citations (11)" for this disclosure. All eleven are U.S. documents; no foreign patent documents appear in the citation list. Every entry carries Google Patents' "cited by examiner" marker (*), i.e., these appear to be examiner‑cited rather than applicant‑submitted art.

Caveat: the table I retrieved is rendered on the family publication US 2016/0323635 A1 (the 15/208,886 → US 10,129,590 member, same specification). Because the '284 is a straight continuation with an identical disclosure, the citation list is presumed identical, but I did not independently confirm the '284's own (56) block. Treat as high‑confidence, not verified.

# Full citation Priority / filing date Pub. date Brief description § 102 posture vs. 2007‑11‑28
1 US 5,838,384 A — Gateway 2000, Inc. 1995‑07‑17 1998‑11‑17 Computer/video system reference (exact title not captured in my source; described on the face as a Gateway 2000 video/PC apparatus document) Pre‑2007‑10‑29 → § 102(b)
2 US 6,037,991 A — "Method and apparatus for communicating video information in a communication system," Motorola, Inc. 1996‑11‑26 2000‑03‑14 Wireless communication of video information in a communication system Pre‑2007‑10‑29 → § 102(b)
3 US 2004/0193647 A1 — "AV data transmitter, AV data receiver, and AV data displaying/reproducing apparatus," Toru Ueda 2001‑07‑10 2004‑09‑30 AV data transmit/receive/display architecture — arguably the closest structural analogue to the two‑modem partition Pre‑2007‑10‑29 → § 102(b)
4 US 2003/0189638 A1 — "Narrow bandwidth, high resolution video surveillance system and frequency hopped, spread spectrum transmission method," Fry, Terry L. 2002‑04‑09 2003‑10‑09 Bandwidth‑constrained wireless video transmission Pre‑2007‑10‑29 → § 102(b)
5 US 2005/0034169 A1 — "Information processing system, information processing apparatus and method, recording medium, and program," Satoru Maeda (Sony) 2003‑06‑26 2005‑02‑10 Wireless AV information‑processing system between an apparatus and a display/other apparatus Pre‑2007‑10‑29 → § 102(b)
6 US 2005/0144478 A1 — "Content receiving/storing apparatus and content delivery system," Kabushiki Kaisha Toshiba 2003‑12‑25 2005‑06‑30 Content reception/storage plus network content delivery Pre‑2007‑10‑29 → § 102(b)
7 US 2006/0097955 A1 — "Portable electronic device," Kabushiki Kaisha Toshiba 2004‑11‑08 2006‑05‑11 Portable device (network/radio) reference Pre‑2007‑10‑29 → § 102(b)
8 US 2007/0072642 A1 — "Mobile communication terminal and method," Tita Kangas (Nokia) 2005‑09‑27 2007‑03‑29 Mobile terminal with multiple radio connections — temporally and technically the most on‑point face citation Pre‑2007‑10‑29 → § 102(b)
9 US 2007/0091835 A1 — [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) 2005‑10‑21 2007‑04‑26 Samsung publication on a multimedia/portable communication apparatus (title not captured in my source) Pre‑2007‑10‑29 → § 102(b)
10 US 2007/0242313 A1 — "Digital camera and controlling method therefor," Canon Kabushiki Kaisha 2006‑04‑11 2007‑10‑18 Digital camera control — relevant to the portable video‑processing‑apparatus half of the claims Pub. 2007‑10‑18, just before the 2007‑10‑29 critical date → § 102(b)
11 US 2008/0188182 A1 — "Entertainment system including selectable IR receive and transmit codes and day/night picture modes," Jeff Macholz 2007‑02‑06 2008‑08‑08 Entertainment system with selectable transmission modes Published after both critical dates → not § 102(b); at best § 102(e) as of its 2007‑02‑06 filing/priority date (see note)

§ 102 regime note (important): Because every claim traces to JP 2007‑306750 / US 12/260,410 (2008‑10‑29), all claims have an effective filing date before 16 March 2013, so pre‑AIA § 102/103 governs. The § 102(b) critical date is therefore 2007‑10‑29 (one year before the effective U.S. filing date). Ten of the eleven citations clear that date. Only US 2008/0188182 does not.

No foreign patent documents are listed in the citation block. The foreign members (JP 5033598 B2, CN 101447902 B, CN 104540008 B, CN 105407104 B) are counterparts, not cited art — see the Maxell litigation identification of foreign counterparts to sibling US 10,129,590.


B. The most relevant prior art is not on the face — it is the IPR art

For US 10,244,284 specifically, the references the parties actually fought over (IPR2025‑00520, LG Electronics v. Maxell, filed 2025‑01‑21, challenging claims 18–20) are more probative of the core concept than the eleven examiner citations above:

Reference Citation form Relevance
Honkanen US 2006/0135076 A1 Primary reference: obviousness of claims 18–20 in view of the Nokia N95‑1 guide
Nokia N95‑1 User Guide Non‑patent literature Secondary reference for the dual‑radio/user‑indication limitations
Dua US 2006/0258289 A1 Alternative primary reference in the Dua + Barnes combination
Barnes US 2005/0136949 A1 Secondary reference in the Dua + Barnes combination
Kao US 2004/0264600 A1 Additional combination for dependent claims 19–20
Bluetooth Specification; IEEE 802.11g standard Standards documents Alternative sources for the "user‑indication"/dual‑radio limitations (claims 19–20)

These four patent publications (Honkanen, Dua, Barnes, Kao) are applicant/party‑supplied art in IPR and do not appear in the face citation list above, which is itself a meaningful signal: the examiner's cited art and the art the industry considers closest are disjoint sets. All four are § 102(b)-class publications (2004–2006) relative to the 2007‑10‑29 critical date.

§ 102 vs. § 103 caveat: the IPR petitions framed these as § 103 obviousness combinations, not § 102 anticipation. That matters: no single one of them was asserted to disclose every element of claim 18. On the record I have, I could not verify any single reference that anticipates claim 18 or claim 1 outright. The Certificate of Correction inserting "prioritized" into claim 18's final step means any § 102 mapping must account for the corrected claim language.


C. Spec‑cited (body, not face) prior art

  • JP 2007‑202115 A, cited in the Background: "A conventional technique in which digitized video and audio signals are multiplexed for transmission as above is described in, for example, JP‑A‑2007‑202115." A JP "A" publication from 2007 is a § 102(b)‑class document relative to 2007‑10‑29 if its publication date precedes that date (a 2007 "A" publication number is consistent with a mid‑2007 publication — I did not verify the exact publication date). It is directed to HDMI‑style multiplexed digital AV transmission, i.e., the very background the patent distinguishes, so it is more likely relevant to the apparatus claims' framing (claim 1, 18 preamble) than to the priority‑assignment limitation.

D. Which claims each face citation could "potentially" reach — assessed

I flag this explicitly as analyst inference, not a rejection. No full element‑by‑element reading is possible without the verified claim text.

  • Claim 1 (display apparatus, first radio circuit → external video processing apparatus / second radio circuit → internet or home network / controller) and claim 18 (method counterpart): the concept‑bearing references are US 2007/0072642 (Kangas/Nokia), US 2007/0091835 (Samsung), US 2005/0034169 (Maeda/Sony) and US 2004/0193647 (Ueda) — each is a multi‑radio or AV‑transmit/receive architecture publication predating the critical date.
  • Claims 3–5, 7, 9–11, 13–16 (dependent, transmission‑rate/parameter/depending features): most plausibly read against US 2003/0189638 (Fry) (bandwidth‑constrained video transmission), US 2005/0144478 (Toshiba) (content delivery/storage) and US 2006/0097955 (Toshiba).
  • Claims 18–20 (method; 19–20 reciting a user‑indication limitation): the face citations do not obviously supply the user‑indication element; that is exactly why the IPR petition reached for N95 User Guide / Bluetooth Spec / IEEE 802.11g.
  • Claim 11's USB‑related feature: I do not have the claim text, so I cannot map this. Flagging rather than guessing.

Bottom line: on the face‑citation set, US 2007/0072642 and US 2007/0091835 are the most relevant; on the litigation record, Honkanen (US 2006/0135076) plus the Nokia N95‑1 User Guide are the art the industry actually advanced as the closest. Neither set alone, on the record I retrieved, establishes § 102 anticipation of claim 1 or claim 18.


E. Data point on citation volume + uncertainty statement

  • Unified Patents' portal lists "Patent Art (33)" and "Non‑Patent Literature (1)" for US‑10244284‑B2. Their "33" exceeds the 11 face citations, which suggests their count aggregates the citation block, family members, and/or cited‑by documents. I could not reconcile the 33 figure with the 11‑item citation table, and I am not going to invent what the other ~22 items are. Likewise I did not retrieve the single NPL item for the '284 itself (the "HDMI Technical Specifications and HD‑JPEG Display, Computer Technology and Development, Feb. 2006" NPL I saw belongs to a different Maxell patent, US 11,308,914).
  • Not verified: the '284's own (56) block; the full non‑patent citation; the complete claim text of claims 1 and 18; the exact publication date of JP 2007‑202115.
  • Do not confuse: US 8,116,284 and US 6,856,760 surfaced in searches are different patents; US 6,856,760 is a Maxell‑asserted patent in the separate LG/N.D. Cal. case and says nothing about the '284. Likewise the earlier Unified Patent Court Hague order (Maxell v. Samsung) concerns EP 2061230, not this patent.
  • Search‑limit disclosure: the USPTO‑specific citation query returned no usable PTO‑892 image before tool limits were reached, so the citation table above rests on the Google Patents family rendering, cross‑checked against the IPR/litigation record.

Generated 9/28/2026, 7:04:34 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 prior art references relevant to this analysis.

Obviousness Analysis — U.S. Patent No. 10,244,284 B2

Display apparatus and video processing apparatus (Kurita et al.)

Analysis date: April 26, 2026 · Statute: 35 U.S.C. § 103 (pre‑AIA, see note below) · Challenged claims analyzed: 18–20 (the only claims for which I have grounded text)


0. Scope, sources, and confidence — read this first

What I am building on. The prior sections of this analysis established: (a) the '284 patent's specification, abstract, and continuity chain (continuation of 15/208,886 → 12/260,410 → JP 2007‑306750, priority 2007‑11‑28); (b) that IPR2025‑00520 (LG Electronics v. Maxell) challenged claims 18–20 and was terminated as settled 2025‑07‑09 before any merits ruling; and (c) the identities of the references LG relied on. I do not repeat that content.

What is new here. This section performs the § 103 element‑by‑element analysis, identifies the combinations, and articulates the motivation‑to‑combine and reasonable‑expectation‑of‑success rationales (KSR factors).

Three hard caveats I will not paper over:

  1. I do not have the verbatim text of claims 18–20, nor of any other claim. What follows uses the claim‑element labels and quoted fragments reproduced in the IPR2025‑00520 petition's Appendix of Claims (e.g., [18.pre], [18.a]–[18.f]), which the prior section flagged as reliable but abstracted. Any element wording below that is not in quotation marks is my paraphrase and is flagged as low confidence.
  2. No tribunal has ruled on the merits of these grounds. The IPR settled before institution/decision. Nothing here is a holding.
  3. One reference‑attribution discrepancy. The petition designates LG‑1007 as "US 2005/0136949 A1 ('Barnes')," and the petition quotes it as describing a device 101 with WWAN/WLAN/WPAN capability and user‑routed video to a remote display. However, one prior‑art listing surfaced in search results renders US 2005/0136949 A1 as "Gruen et al." I do not auto‑correct either; I use the petitioner's label "Barnes" while flagging that the naming is uncertain.

Note on which § 103 applies: Because the '284 patent is a continuation whose every claim is supported by the 2007 JP priority document, the pre‑AIA §§ 102/103 framework governs, and the critical date against which the art is measured is on or about 2007‑11‑28 (Google Patents) / 2007‑11‑27 (Unified Patents).


A. The person of ordinary skill in the art (POSITA)

For a 2007 priority date in this field, a defensible definition is:

A POSITA would hold at least a bachelor's degree in electrical engineering, computer engineering, or computer science (or equivalent experience), and would have 2–5 years' experience designing or integrating wireless radio subsystems and consumer media devices (e.g., mobile handsets, portable media players, cameras, and TVs), including familiarity with the coexistence of multiple radios (Bluetooth, WLAN/802.11, cellular) in one device and with video delivery over those links.

This definition matters because almost every limitation in claim 18 is an architectural/control limitation, not an algorithmic one. A POSITA in 2007 already knew that Bluetooth and 802.11 shared the 2.4 GHz ISM band and could mutually interfere when co‑located, and already knew that digital video needed sustained, high bit rates. Those two pieces of background knowledge are the engine of the obviousness case.


B. The prior art of record and its § 102 status

Ref. Identifier (as designated in the record) Publication / availability § 102 status vs. 2007‑11‑28
Honkanen US 2006/0135076 A1, "Method and device for controlling radio access" (Honkanen, Kasslin, Katajainen, Kiukkonen; filed 2005‑11‑22; FI 20045450 priority 2004‑11‑22) 2006‑06‑22 § 102(b) — printed publication more than 1 yr before priority
N95 Nokia N95‑1 User Guide 2007 (device commercially released 2007) § 102(a) — predates priority date but is within the 2007 one‑year window; not a statutory bar
N93 Nokia N93 User Guide ~2005–2006 § 102(b) (if published before 2006‑11‑28)
Dua US 2006/0258289 A1, "Wireless media system and player and method of operation" (Robin Dua; filed 2005‑05‑12) 2006‑11‑16 § 102(b)
Barnes (attribution caveat supra) US 2005/0136949 A1 2005‑06‑23 § 102(b)
Kao US 2006/… (LG‑1017; number not verified) not verified presumed § 102(b); unverified
Bluetooth Specification Specification of the Bluetooth System 2000s § 102(b) as industry standard
IEEE 802.11g IEEE Std 802.11g‑2003 2003 § 102(b)
Tee / Kelton US 2006/0203758 A1 / US 2004/0125779 A1 2006 / 2004 § 102(b)
JP 2007‑202115 Cited on the face of the '284 patent published 2007‑08 § 102(a) (predates 2007‑11‑28; within one year)

Grounding: the prior‑art exhibit list appears in the IPR2025‑00520 Joint Motion to Terminate (LG‑1001 through LG‑1020) — https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2025-00520/LG_Electronics_Inc._v._Maxell_LTD/docs/07-01-2025-Petitioner/Motion__Motion_to_dismiss_due_to_settlement_pre_DI-6-Joint_Motion_to_Terminate.pdf — and the Honkanen text is at https://www.docketalarm.com/cases/PTAB/IPR2025-00520/LG_Electronics_Inc/docs/01-21-2025-Petitioner/Exhibit-1004-US_Pat_App_Pub_No_20060135076A1_Honkanen.pdf. JP 2007‑202115 appears in the '284 specification's Background section.

Important caveat: the fetched '284 text I was given contains the Description in full but not the "Citations / Cited By / Similar Documents" panels of the Google Patents page. I therefore cannot claim to have audited the complete examiner‑cited art list. The set above is the set I can ground.


C. The claim to be tested

Reproduced from the IPR Appendix of Claims (quoted fragments in quotation marks; bracketed paraphrases are mine and low confidence):

Element Text
[18.pre] "A method for video processing, the method comprising:"
[18.a] "transmitting, via a first radio communication circuit, digital video information by radio to an external apparatus"
[18.b] "connecting, via a second radio communication circuit, to an internet or a home network"
[18.c] "receiving digital information"
[18.d] "controlling each of the first and second radio communication circuits such that the first radio communication circuit transmits digital video information to the external apparatus and the second radio communication circuit connects to the internet or the home network simultaneously…"
[18.e] "controlling assignment between the first radio communication circuit and the external apparatus, and assignment between the second radio communication circuit and the internet or the home network"
[18.f] "controlling the assignment such that the assignment between the first radio communication circuit and the external apparatus is prioritized more than the assignment between the second radio communication circuit and the internet or the home network" — with a further sub‑element requiring this "when a user issues an indication to transmit digital video information by the first radio communication circuit while acquiring information from the internet or the home network by the second radio communication circuit"
Claims 19–20 Dependent; per the petition, they require different frequency bandwidths/bands and different modulation methods, respectively (paraphrase — unverified).

Prosecution note carried forward from the prior section: the phrase "prioritized" in [18.f] was not in the issued text; it was inserted by a Certificate of Correction obtained by Maxell. Two consequences: (i) the pre‑correction claim was amenable to a reading in which "assignment … more than" was purely quantitative without a priority ordering — which is precisely the construction fight the prior section flagged; and (ii) the correction itself is evidence that Maxell viewed the priority concept as the point of novelty, which weakens any argument that the priority feature is merely incidental.


D. The reference teachings

D.1 Honkanen — US 2006/0135076 A1

Title: "Method and device for controlling radio access." Abstract: "A method for controlling a number of simultaneous radio connections in a communication device…. Parameters of the radio connections are controlled such that interference between the radio connections is minimized."

Key teachings (verbatim from the publication):

  • ¶[0002]: "It is quite evident that users are willing to use different radios at the same time, like using a headset employing wireless Bluetooth® technology during a GSM phone call, and using a wireless local area network (WLAN) connection for Internet surfing…"
  • ¶[0004]: co‑located Bluetooth and WLAN on the 2.4 GHz ISM band "cause inter‑system interference to one another, which may result in a degraded quality of service." Two active connections on one band from one device "may even block each other's usage totally" because "the radio transceivers may be located within a few centimeters from each other."
  • ¶[0007] (claim‑level): "…monitoring properties of the radio connections in order to detect interference between at least two radio connections and adjusting parameters of at least one radio connection so that interference between the radio connections is minimized…"

Mapping to the '284 claims: Honkanen discloses [18.a]/[18.b]/[18.d] (two simultaneous radios, one to a local peripheral — the Bluetooth headset — and one to a WLAN/Internet) and, critically, [18.e] (a control unit that adjusts connection parameters — i.e., assignment — across multiple simultaneous radios). Honkanen does not expressly disclose (i) that the first radio carries digital video to an external apparatus (though the Bluetooth headset link is an external‑apparatus link, it is audio), nor (ii) that the first link's assignment is prioritized over the second's.

D.2 N95 — Nokia N95‑1 User Guide

The N95 was a 2007 dual‑radio handset (WLAN + Bluetooth + cellular) with a camera and a media player. The guide teaches the user‑driven transfer procedure: the user selects the item (e.g., a video clip), then selects Bluetooth as the transport, then selects the destination device — i.e., the "user issues an indication to transmit digital video information by the first radio communication circuit" sub‑element of [18.f]. The N93 guide teaches the same procedure (relevant to § 102(b) dating).

D.3 Dua — US 2006/0258289 A1

Title: "Wireless media system and player and method of operation." Abstract describes a wireless media player with RFID‑assisted connection setup over "a commonly supported wireless protocol such as Ultra Wideband (UWB) or Bluetooth."

Key teachings relevant to the claims:

  • Two transceivers: a short‑range transceiver 108 and a separate network transceiver 105 (cellular). The petition's quote of ¶63: "The short‑range transceiver 108 and antenna system 117 are specially designed to support the widest array of communication protocols and broadcast standards."
  • Simultaneous reception‑and‑re‑transmission: ¶156 — the user may "wirelessly transmit the incoming media to another electronic device to facilitate enhanced viewing, for example, on a large television with surround sound…"; ¶168 — "a user [can] browse movie trailers on his wireless media player 100, select a movie for download, pay for the movie, and use the media player 100 to re‑transmit the selected movie to a television in the vicinity."
  • Bandwidth‑driven assignment: Dua explicitly reasons about whether the available link has enough bandwidth to "receive the communication (e.g., movie data file) in a desired manner without buffering" and states that its "programmed rules will be based on bandwidth availability (anticipated, current)."
  • External display must support high bandwidth: ¶215 requires the receiving display to have a transceiver supporting "high bandwidth communication with other devices (such as the media player 100)."

Mapping: Dua supplies [18.a] (digital video to an external apparatus — the "television in the vicinity"), [18.b] (network transceiver 105 to the Internet), [18.c] (receiving digital information — the downloaded movie/media), [18.d] (simultaneous receive‑and‑forward), and the user‑indication sub‑element (user selects the media and the destination). Dua's "programmed rules … based on bandwidth availability" supplies the mechanism of [18.e]/[18.f] but not necessarily the relative priority between the two links.

D.4 Barnes — US 2005/0136949 A1 (attribution caveat)

The petition cites Barnes ¶63: "video transmission or computer data (e.g., web pages) received by the device 101 may be routed (e.g., as requested by the user) to a remote display device (e.g., via a wireless PAN to a display in an automobile) that may be large or of better quality than the display of the device." And Barnes ¶¶65–66 teach rule‑based network selection keyed to anticipated/current bandwidth, including selecting a "higher speed network" when the lower‑bandwidth link "does not provide enough bandwidth to receive the communication (e.g., movie data file) in a desired manner without buffering." Barnes also teaches WWAN + WLAN + MAN + PAN (Bluetooth) coexistence and contemporaneous voice/data links.

Mapping: Barnes supplies the prioritization teaching of [18.f] — allocate the higher‑bandwidth connection to the video task, and accept degraded throughput elsewhere, to avoid buffering/interruption.


E. The obviousness case

Ground 1 — Honkanen in view of N95 (claims 18–20)

Claim element Where taught
[18.pre] method for video processing Honkanen's control method + N95's video‑transfer workflow
[18.a] transmit digital video via first radio circuit to external apparatus N95 (select a video clip → send via Bluetooth to a nearby device); Honkanen's Bluetooth‑to‑external‑peripheral link
[18.b] second radio circuit to Internet/home network Honkanen ¶[0002] express: Bluetooth headset "during a GSM phone call," and "WLAN connection for Internet surfing"
[18.c] receiving digital information N95 receives/plays media; Honkanen's WLAN link receives Internet data
[18.d] simultaneous control of both circuits Honkanen's entire premise — "simultaneous operation of radios" (¶[0002], ¶[0006]–[0008])
[18.e] controlling assignment between each circuit and its peer Honkanen ¶[0007]: "adjusting parameters of at least one radio connection"; the control unit creates/manages simultaneous connections
[18.f] assignment to the video link prioritized over the network link This is the weakest link. Honkanen's stated objective is interference minimization, i.e., a neutral arbitration, not a preference for one link. N95 supplies only the user‑indication sub‑element.
Claim 19 (different frequency bands/bandwidths) Bluetooth (2.4 GHz ISM, ~1 MHz channels) vs. WLAN/802.11 (2.4 GHz, 20 MHz channels) — inherent, well‑known; see Bluetooth Specification and IEEE 802.11g
Claim 20 (different modulation methods) Bluetooth GFSK vs. 802.11g OFDM — inherent, well‑known; same exhibits

Motivation to combine (Ground 1). Both references are in the same field (handheld wireless devices with multiple radios) and the combination is a predictable use of a prior‑art technique to improve a prior‑art device (KSR Int'l v. Teleflex, 550 U.S. 398, 417 (2007)): Honkanen supplies the multi‑radio coexistence architecture; N95 supplies the user‑facing media‑transfer workflow that consumers would expect on such a device. The POSITA seeking to let a user push a captured video to a nearby display while still connected to WLAN would naturally look to the media‑transfer UI already shipped on the same vendor's handsets. The combination does not change the principle of operation of either reference — it merely adds a selection dialogue.

Expectation of success. High. Both procedures (Bluetooth object‑push to a paired display; WLAN association) were standardized, documented, and commercially deployed by 2007.

Why Ground 1 is not the strongest ground. The petitioner's own framing ("Honkanen … lacked specifics on user‑initiated actions") concedes that Honkanen does not teach prioritization. N95 does not cure that gap — the N95 guide teaches which link the user picks, not that the device should favor one link over another when arbitrating shared radio resources. Under In re Ratti/KSR's "predictable results" test, a POSITA could still argue that preferring the higher‑bit‑rate video link is a design choice; but that argument is better supported by Barnes, which says so expressly. See Ground 2.


Ground 2 — Dua in view of Barnes (claims 18–20) — the strongest combination

Claim element Where taught
[18.pre] Dua's media player method
[18.a] Dua ¶156/¶168 — re‑transmit received media "to a television in the vicinity" over short‑range transceiver 108
[18.b] Dua's network transceiver 105 / cellular data connection to the Internet
[18.c] Dua — receiving the media (trailer/movie) from the network
[18.d] Dua — receive from Internet while forwarding to the local display (simultaneous operation inherent in the disclosed re‑transmission use case)
[18.e] Dua — "programmed rules … based on bandwidth availability (anticipated, current)"; Barnes ¶¶65–66 same
[18.f] prioritization Barnes ¶66 — where the lower‑bandwidth link "does not provide enough bandwidth to receive the communication (e.g., movie data file) in a desired manner without buffering, the higher speed network is selected"; Barnes ¶63 — route video/data to a remote display "that may be large or of better quality than the display of the device"; Dua ¶215 — external display must support "high bandwidth communication"
Claims 19–20 Bluetooth vs. WLAN/802.11g frequency and modulation differences; Dua's short‑range transceiver 108 is expressly "specially designed to support the widest array of communication protocols and broadcast standards"

Motivation to combine (Ground 2) — the articulated rationale:

  1. Same problem space, complementary disclosures. Dua and Barnes both address a portable device holding two simultaneous wireless links — one to a network, one to a nearby device — and both address media. Dua provides the hardware and the media hand‑off; Barnes provides the allocation policy.
  2. Dua expressly invites the improvement. Dua states that its connection decisions are governed by "programmed rules … based on bandwidth availability (anticipated, current)." Barnes is a set of such rules — a POSITA reading Dua is directly led to Barnes's rule set to populate that policy. This is the classic "reference teaches the general mechanism; second reference supplies the specific parameter" combination endorsed in KSR and In re ICON Health & Fitness, 496 F.3d 1374, 1379–80 (Fed. Cir. 2007).
  3. Articulated, specific benefit. Barnes's own stated rationale — avoiding "buffering" and interruption when streaming video over an inadequate link — supplies the motivation with a reason that the case law requires, rather than a bare "would have been obvious" assertion. The benefit is "smoother, uninterrupted video streaming to the external display."
  4. Design‑incentive / predictable variation (KSR factors). In a device with a fixed, shared radio‑frequency budget, allocating more of that budget to the latency‑ and jitter‑sensitive HD video stream and less to best‑effort Internet traffic is a design choice within the ordinary skill of a POSITA — and the '284 patent itself concedes the trade‑off is tolerable: "this rarely influences the system operation since information regarding the network is less frequently exchanged as compared with video information." That concession in the specification is strong evidence that the relative‑priority allocation was a known, acceptable engineering trade‑off, not an invention.
  5. No change in principle of operation. Adding Barnes's rule engine to Dua's transceivers does not require modifying how either transceiver works; it modifies only the controller's selection logic — a software/control‑layer change, which the Federal Circuit treats as a predictable combination where the references are combinable (KSR, 550 U.S. at 417; Perfect Web Techs. v. InfoUSA, 587 F.3d 1324, 1330 (Fed. Cir. 2009)).

Expectation of success (Ground 2). Very high — the change is confined to the controller's allocation rules, uses documented bandwidth metrics, and produces a predictable, verifiable result (fewer buffering interruptions).

Mapping note on "more than." The district‑court dispute flagged in the prior section — whether "assignment … more than" requires assigning particular connection parameters — cuts against Maxell on obviousness in either reading: under a quantitative reading (bandwidth/rate allocated), Dua‑Barnes maps directly; under a qualitative reading (which link gets the better operating point when resources are scarce), Barnes ¶66 ("the higher speed network is selected") maps directly. Either way the combination discloses it.


Ground 2A — Dua + Barnes + N95 (claims 18–20)

Superadds N95 (and/or N93) to supply the explicit user‑selection sub‑element of [18.f] (user selects the video clip, selects Bluetooth, selects the destination). Motivation: Dua itself refers to "normal Bluetooth session set‑up procedure", and N95 documents exactly that procedure; the "familiar technique" rationale of KSR applies.

Grounds 1A / 2B / 2C — adding standards documents and Kao (dependent claims)

The Bluetooth Specification, IEEE 802.11g, and the WiMax specification are admissible as printed publications / industry standards and establish as a matter of record that Bluetooth (FHSS, GFSK, ~1 MHz channels) and 802.11g (OFDM, 20 MHz channels) differ in frequency band usage/bandwidth and in modulation method. That makes claims 19–20, if they recite nothing more, effectively admitted art for a device with two different radios. Kao (LG‑1017) was offered for the same purpose; I could not verify its number or content and flag it as unverified.


F. Additional and alternative combinations the record supports

# Combination What it supplies Relative strength
1 Honkanen + N95 multi‑radio coexistence + user‑selected media transfer Moderate for [18.a]–[18.e]; weak for [18.f]
2 Dua + Barnes dual‑transceiver media hand‑off + bandwidth‑driven prioritization Strongest
2A Dua + Barnes + N95/N93 adds explicit user indication Strong
3 Dua + Honkanen Honkanen's "adjusting parameters of at least one radio connection" supplies the express parameter‑adjustment teaching that a narrow reading of [18.e] may demand; Dua supplies the video/network topology Strong; and see the PTAB‑related Maxell briefing noting that Maxell "does not dispute that a POSITA would have been generally motivated to combine Dua … with these additional references" and that "one of ordinary skill in the art would have been motivated to incorporate Honkanen's coexistence technique so that interference among Dua's radios is detected and minimized" (https://aboutblaw.com/bmke)
4 Barnes + Honkanen Barnes for bandwidth‑priority routing; Honkanen for the two‑radio control unit Moderate–Strong on [18.e]/[18.f]
5 Any of the above + JP 2007‑202115 Multiplexed digitized video/audio transmission — relevant background, but it is examiner‑cited art of record already overcome during prosecution, so it adds little; useful only for § 103(c)/obviousness‑type‑doubling contexts Weak
6 Any of the above + Tee (US 2006/0203758) + Kelton (US 2004/0125779) Secondary evidence of the state of multi‑radio/media‑player art; evidentiary, not element‑mapping Supporting only

G. Anticipated patent‑owner (Maxell) rebuttals — and my assessment

Maxell argument Assessment
"Honkanen teaches away" — Honkanen's express goal is interference minimization, a symmetric objective, so it points away from deliberately favoring one link. Partially persuasive against Ground 1 only. But it does not touch Dua‑Barnes; and Honkanen's ¶[0006]–[0007] are broad enough to encompass adjusting one connection's parameters (which necessarily changes their relative operating points). Also, teaching away requires the reference to criticize, discredit, or discourage the claimed approach (In re Fulton, 391 F.3d 1195 (Fed. Cir. 2004)); Honkanen is silent on priority, and silence is not teaching away.
"The references are non‑analogous / from different fields." Not persuasive. All references are in handheld multi‑radio consumer devices. Both KSR and In re Bigio, 381 F.3d 1320 (Fed. Cir. 2004), defeat this.
"Dua's re‑transmission is store‑and‑forward, not simultaneous video streaming." Partly persuasive. Dua's disclosed use case is downloading/streaming and re‑transmitting. The counter is Barnes ¶¶63–66, which expressly contemplates contemporaneous voice + data and rule‑based selection for live/streaming content ("without buffering"), supplying simultaneity for the video path.
"Barnes selects among networks (network selection), not between a display link and a network link — different problem." The most substantive defense. Barnes ¶¶65–66 read naturally as selecting among available networks for a given task, which is not obviously the same as splitting a shared internal radio resource between two concurrent active links. Petitioner's own framing ("Barnes was introduced to teach the prioritization aspect … selecting a higher‑speed, higher‑bandwidth connection for video transmission") invites this attack. Rebuttal: Barnes ¶50 expressly contemplates contemporaneous use of WWAN + WLAN + MAN + PAN from one device, and ¶63 routes video to a PAN display while data flows elsewhere — so the allocation decision is between a display‑bound link and a network‑bound link in the same device. Combined with Honkanen's co‑location/interference problem (the reason a single device must arbitrate its shared RF budget), the gap closes.
Claim‑construction defense: "assignment … more than" requires a positive allocation of concrete parameters, and neither reference allocates parameters to both links. Contested, and it cuts both ways — see § E. The Certificate of Correction inserting "prioritized" arguably helps Maxell by importing a priority ordering that is not in Honkanen, while helping LG by confirming that priority is the concept one looks for in the art — which Barnes ¶66 supplies.
Secondary considerations (nexus, commercial success, licensing). None is in the record I have. Note that a settlement in IPR2025‑00520 is not evidence of non‑obviousness, and licensing activity by Maxell (nine patents asserted across the LG, Samsung, and Apple campaigns) is at least as consistent with portfolio monetization as with nexus‑bearing commercial success (In re GPAC, 57 F.3d 1573, 1580 (Fed. Cir. 1995)).

H. Bottom line

Highest‑confidence conclusion (substantive, not verbatim‑text‑dependent):

Claims 18–20 of US 10,244,284 are, more likely than not, obvious under 35 U.S.C. § 103 over U.S. 2006/0258289 (Dua) in view of U.S. 2005/0136949 A1 (Barnes), optionally further in view of the Nokia N95‑1/N93 User Guides.

The rationale is: Dua discloses the two‑transceiver architecture (short‑range transceiver 108 to a nearby external display; network transceiver 105 to the Internet), the simultaneous receive‑and‑re‑transmit media flow, the user selection of the video and destination, and an express "programmed rules … based on bandwidth availability" allocation policy. Barnes discloses the missing policy content — assign the higher‑speed/higher‑bandwidth connection to the video task to avoid buffering and interruption, while contemporaneously running other links. Both references are analogous art, both address the identical problem of delivering media from a multi‑radio portable device, and Barnes supplies a specific, articulated, predictable benefit that satisfies the KSR "reason the improvement would have been made" requirement. No reference teaches away, the combination changes no principle of operation, and the '284 specification itself concedes the trade‑off (network traffic is "less frequently exchanged") that the claims are said to embody.

Second‑best but still viable: Honkanen + N95 for claims 18–20, weakened by the absence of any express prioritization teaching in either reference — though the Bluetooth‑vs‑WLAN frequency/modulation differences squarely dispose of claims 19–20.

Reasons for caution I want stated explicitly:

  1. No merits ruling exists. The IPR terminated as settled 2025‑07‑09; the Board never instituted or decided. Citing IPR2025‑00520 as evidence of invalidity is procedurally improper as such.
  2. My claim text is fragmentary. Claims 1–17 and the full text of 18–20 are not in the record I retrieved. The element labels and quoted fragments come from the petition's Appendix of Claims; there may be limitations I have not assessed.
  3. Barnes's "network selection vs. link priority" distinction is a genuine, non‑frivolous defense and is the most likely locus of a merits fight.
  4. The [18.f] "prioritized" limitation is post‑issuance text, introduced by Certificate of Correction — meaning any invalidity theory that depends on reading "prioritized" into the original claim must account for the correction's effective date and scope.
  5. Unverified items: the Kao reference's identity; the "Barnes" attribution (a search hit renders US 2005/0136949 A1 as "Gruen et al."); and whether the N95‑1 guide's publication date falls before or after the 2007‑11‑28 priority date (it is relevant either way, but the § 102 subsection changes).
  6. I found no evidence of secondary considerations in the material available to me — that is an absence of evidence, not evidence of absence.

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