Invalidity dossier

US 10724875

System and method to manage utility meter communications

Current assignee: Nagravision SARL

Added 9/24/2026, 5:58:12 PM

IndustryEnergy (E)
At a glanceNo PTAB challengesNo litigation on fileEnergy (E)

Active provider: DeepSeek · deepseek-v4-flash

Patent summary

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

✓ Generated

I'll run targeted searches for this exact patent number and any CAFC/litigation activity.

Verification status (important, per your strict rule)

I ran targeted searches for the exact string 10724875 / US 10,724,875 against patent databases and litigation/docket sources. Results:

  • USPTO/patent record: The authoritative full text of US 10,724,875 B2 was retrieved (https://patents.google.com/patent/US10724875/en). I did not independently retrieve a live USPTO PatentCenter page for application 16/685,241 — the bibliographic data below comes from that authoritative full-text record and its embedded legal-events/assignment entries.
  • CAFC 2026 dockets: I found no Court of Appeals for the Federal Circuit docket, appeal, IPR, or district-court action naming US 10724875. The Nagravision/Kudelski dockets that surfaced concern different patents (e.g., US 7,725,720, US 7,725,740, US 8,356,188 in Nagravision SA v. Comcast Corp., E.D. Tex. 2:16-cv-01362, and the DMCA action Nagravision SA v. Zhuhai Gotech, S.D. Tex. 4:15-cv-00403). Do not treat the absence of hits as proof that no such proceeding exists — absence of evidence in my searches is not evidence of absence.
  • I did not auto-correct the number; all identifiers below are reproduced literally as they appear in the record.

1. Bibliographic summary — US 10,724,875 B2

Field Value (as recorded)
Patent number US 10,724,875 B2
Title System and method to manage utility meter communications
Application no. US 16/685,241
Pre-grant publication US 2020/0080866 A1 (published 2020-03-12)
Filing date 2019-11-15
Issue (grant) date 2020-07-28
Priority date 2011-08-30 (EP 11179337.8 / EP 11179337; US provisional 61/528,822)
Continuity Continuation of US 14/342,270, which is a National Stage of PCT/EP2012/066803 (filed 2012-08-30); parent matured as US 10,520,332 B2
Inventors Joel Wenger; Corinne Le Buhan
Assignee (original) Nagravision SA (assignment recorded 2019-12-11)
Current assignee Nagravision SARL (change of name from Nagravision S.A.; effective 2021-12-20, recorded 2024-06-19)
Classifications G01D 4/002 (remote reading of utility meters); Y02B90/20; Y04S20/30; Y04S20/32; Y04S20/42; Y04S20/50
Legal status Active
Anticipated expiration 2032-08-30 (as listed; corresponds to the 2012-08-30 PCT filing)
Maintenance fee 4th-year fee paid 2023-12-19 (large entity)
Claims 18 total — independent claim 1 (method) and independent claim 10 (system)

Continuation family (same title/spec, priority 2011-08-30): US 10,520,332 B2 · US 10,724,875 B2 · US 10,982,972 B2 · US 11,359,933 B2 · US 11,733,061 B2 · US 12,158,359 B2. Foreign: EP 2751525 B1 / EP 2565585 A1, WO 2013/030248 A1, CN 103827636 B, BR 112014004855 B1, ES 2647684 T3.


2. Abstract (as issued)

"A method for managing communications within a network comprising utility meters, each associated and connected to at least one utility management center through at least one intermediate data concentrator. A message is sent by a utility meter to the destination data concentrator. This message includes metering data measurement reported by said utility meter, its utility meter identifier, the destination data concentrator identifier and the management center identifier. Then, on the basis of several metering data measurements, a metering counter differential consumption value is calculated by difference of two metering counter consumption indexes measured by the utility meter within a time period interval. Then, a report containing at least the metering counter differential consumption value is sent from the destination data concentrator towards the utility management center to which said utility meter is associated."


3. Independent claims in plain language

Claim 1 — Method

A method for managing utility-meter communications in a network where multiple utility meters are each tied to at least one utility management center through at least one intermediate data concentrator. Each meter has a meter identifier and sends messages to a "destination data concentrator" identified by a concentrator identifier; each destination concentrator produces reports for the management center, identified by a management-center identifier. The method has three steps:

  1. Meter → concentrator message: the meter sends a message containing (a) a metering data measurement it reports, (b) the utility meter identifier, (c) the destination data concentrator identifier, and (d) the utility management center identifier.
  2. Derive the delta: determine a metering counter differential consumption value as the difference between two metering counter consumption indexes measured by that meter within a time-period interval.
  3. Concentrator → center report: the destination data concentrator sends, to the management center with which that meter is associated, a report containing at least that differential consumption value.

Practical reading: the meter pushes a lightweight, self-addressed-and-routed reading upward; the concentrator (not the meter) computes the consumption delta and reports it to the correct provider among several competing ones. Note that in claim 1 the "determining" step is not grammatically assigned to the data concentrator — that assignment appears expressly in claim 10.

Claim 10 — System

A system comprising:

  • a utility management center identified by a management-center identifier;
  • a destination data concentrator identified by a concentrator identifier;
  • a plurality of utility meters associated with and connected to that management center, each identified by a meter identifier, each configured to produce and send utility meter messages to the destination data concentrator.

Operation: a meter sends a message containing the metering data measurement, meter ID, destination concentrator ID, and management-center ID; the destination data concentrator determines the metering counter differential consumption value from two meter counter indexes measured within a time-period interval; and the destination data concentrator sends to the associated management center a report containing at least that differential value.


4. Dependent claims (quick tour)

Depending on claim 1 (claims 2–9):

  • 2 — report includes a detailed tariff computation based on a tariff table plus the differential value.
  • 3 — securing the report sent to the management center.
  • 4 — securing by encrypting the report with an encryption key.
  • 5 — securing by signing the report with a digital signature.
  • 6 — the center processes the report only if the digital signature authenticates it.
  • 7 — concentrator sends an acknowledgement to the meter upon receipt.
  • 8 — the meter sends its message in response to a request from the concentrator (polling).
  • 9 — concentrator sends a configuration message to update the meter's reporting rate.

Depending on claim 10 (claims 11–18): mirror images of the above — 11 tariff computation; 12 securing; 13 encryption with a digital key; 14 signing; 15 process-only-if-authenticated; 16 acknowledgement; 17 request-driven reporting; 18 reporting-rate configuration.

Specification support worth noting (not claim language): PKI with RSA key pairs and X.509 certificate chains; a random payload key Kp encrypted under the concentrator's public key KpubC2; optionally a negotiated long-term session key Ks over a Secure Authenticated Channel (SAC); ΔCPT values accumulated over a reporting period ΔRT into a per-meter report MRup u,c,p or a consolidated report CR c,p covering all meters served by one provider; roaming/re-routing by an intermediate concentrator or provider that is not the intended recipient (possible because Uid/DCid/Pid are in each message); and a preference for transmitting the absolute counter index CPT rather than ΔCPT when the link is unreliable so the concentrator can interpolate a missing reading.

Cited prior art of record includes US 2008/0068213 A1 (Cornwall, AMR serial numbering), US 5,974,369 (WPS Energy Services, recording and processing metered information), US 6,006,212 (Itron), US 2005/0240540 A1 (Borleske), WO 2008/086231 A2 (Itron), US 5,079,715 (Venkataraman), and US 2011/0050456 A1 (Itron). The two references discussed in the specification's background are US 2008/0068213 and US 5,974,369.


5. Explicit uncertainty flags

  1. No litigation/CAFC record found for US 10,724,875. My searches surfaced only unrelated Nagravision/Kudelski matters. I cannot confirm from the sources retrieved whether this patent has ever been asserted, challenged at the PTAB, or appealed.
  2. Dates as listed. The record shows a 2019-11-15 filing date for 16/685,241 with a 2011-08-30 priority claim and an anticipated expiration of 2032-08-30. The Google Patents record also displays an "Active / 2036-03-27" entry for the parent US 14/342,270, which is inconsistent with a 20-year-from-2012 term and likely reflects a terminal disclaimer or a record artifact — I have not verified which, so treat term/expiration figures as unverified.
  3. "Prior art date" vs. priority date. Google Patents labels 2011-08-30 as "prior art date" (an assumption, not a legal conclusion) and separately lists 2012-08-30 as the PCT filing date.
  4. No live USPTO PatentCenter confirmation was obtained for the assignment chain beyond the legal-events entries reproduced in the full-text record (2019-12-11 assignment to Nagravision S.A.; 2024-06-19 change of name to Nagravision SARL, effective 2021-12-20).

Sources: https://patents.google.com/patent/US10724875/en ; family EP counterpart https://patents.google.com/patent/EP2751525B1/en ; NL register entry (EP 2751525, applicant/inventors/priority/expiration) https://mijnoctrooi.rvo.nl/fo-eregister-view/search/details/800187547_EPV/0/0/1/10/0/0/0/null/null?locale=en ; parent patent PDF https://patentimages.storage.googleapis.com/80/7a/b0/d76bc599dbe53d/US10520332.pdf

Generated 9/29/2026, 5:23:34 AM

Cases on file (0)

Specific litigation cases in our database that name US patent 10724875. 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 research litigation involving US 10724875 across patent litigation databases and court records.

Initial searches didn't surface litigation. Let me search dedicated patent litigation databases directly.

Litigation Search Report — U.S. Patent No. 10,724,875

Patent under review: US 10,724,875 B2 — "System and method to manage utility meter communications"

  • Current assignee: Nagravision SARL (formerly Nagravision S.A.), part of the Kudelski Group
  • Application No. 16/685,241; filed 2019-11-15; granted 2020-07-28
  • Priority date: 2011-08-30; anticipated expiration 2032-08-30
  • Family members: US 10,520,332; US 10,982,972; US 11,359,933; US 11,733,061; US 12,158,359; plus EP 2751525, CN 103827636, BR 112014004855, WO 2013030248

Result: No litigation found

I could not identify any litigation — district court, ITC, or Federal Circuit — involving US 10,724,875. No case data was returned for this specific patent number from the sources searched (Unified Patents litigation portal, CourtListener/RECAP, Justia dockets, Docket Alarm, PACER-adjacent aggregators).

Per your strict-instruction rule, I want to be explicit about the basis for this finding and its limits:

What I did find (and why it does NOT count)

Several Nagravision/Kudelski enforcement actions surfaced, but none assert US 10,724,875:

  1. Nagravision SA v. Zhuhai Gotech Intelligent Technology et al. — S.D. Tex., No. 4:15-cv-00403 (filed 2015-08-06). DMCA (17 U.S.C. §1201) and Federal Communications Act (47 U.S.C. §§605) claims over pay-TV set-top boxes and IKS piracy. ~$101.85M default judgment; affirmed by the Fifth Circuit (Feb. 2018). Not a patent case; different technology.

  2. Comcast Cable Communications, LLC v. OpenTV, Inc. et al. — N.D. Cal., No. 3:16-cv-06180 (filed 2016-10-26). Declaratory judgment of non-infringement (Kudelski broadcast patents). Does not involve the '875 utility-meter patent.

  3. Nagravision SA v. Comcast Corporation et al. — E.D. Tex., No. 2:16-cv-01362. Asserted US 8,356,188; 7,725,720; 7,725,740. Different patents.

  4. OpenTV, Inc., Nagravision S.A., Nagra France S.A.S. v. Apple Inc. — N.D. Cal., No. 5:15-cv-02008. Asserted '081, '736, '169, '429, '740. Different patents.

These are all Kudelski pay-television/conditional-access matters. The '875 patent is from a distinct smart-grid / utility-metering family. I am flagging this deliberately so the results are not mistaken for '875 litigation.

Caveat on search completeness

Litigation databases are not perfectly indexed by patent number, and a patent granted in mid-2020 (with continuations running into 2024) could in principle have been asserted very recently. My searches did not have complete visibility into:

  • Very recent 2025–2026 filings that may not yet be docketed/indexed in the sources reachable here, and
  • Cases where the patent is asserted but the number appears only in an exhibit or claim chart.

Recommended verification steps

If you need a litigation-grade clearance opinion, confirm directly against:

  • PACER (all district courts, party search "Nagravision")
  • USPTO Patent Center / Assignment for the '875 patent, which lists any §290 statutory notices of suit
  • Unified Patents litigation portal (https://portal.unifiedpatents.com/litigation/caselist) filtered by the patent family
  • ITC EDIS (Section 337 investigations)

Bottom line: based on the sources searched, no litigation involving US 10,724,875 is known. I state this with moderate confidence, and recommend a primary-source PACER/Patent-Center confirmation before relying on it for any legal purpose.

Generated 9/29/2026, 5:23:23 AM

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 verify the structured block's "no proceedings" default against public sources before writing.

The BPAI/PTAB ex parte appeal on the parent is a notable find. Let me pin down its disposition and check the sibling patents.

Proceedings overview

Total AIA trial proceedings on US 10,724,875: 0. The canonical list from the structured "PTAB proceedings on file" block (USPTO ODP) is empty, and independent web searching confirms it: no IPR, PGR, or CBM has ever been filed against US 10,724,875 or against any of its five sibling patents (US 10,520,332, 10,982,972, 11,359,933, 11,733,061, 12,158,359). Breakdown by status is therefore not applicable — there is nothing to categorize as active, invalidated, sustained, settled, or denied.

Bottom-line defensive posture: This is not a "hardened patent that beat two IPRs" posture, and it is not a "claims canceled" posture either — it is a clean-slate patent. All 18 claims sit untested at the PTAB, which cuts both ways for a defendant: no claim is estoppel-protected or pre-canceled, but there is also no petitioner roadmap, no FWD claim construction, and no institution-denial reasoning you can borrow. The one genuinely useful piece of Board precedent is an ex parte appeal decision during prosecution of the parent application — and it is favorable to the patent owner, which is the more important fact below.


Appeal 2018-002421 — Nagravision S.A. (Applicant) v. USPTO Examiner ⚠️ (not an AIA trial — included because it is the only adjudicative PTAB/Board activity in this family)

  • Type: Ex parte patent prosecution appeal (35 U.S.C. § 134), decided by the Patent Trial and Appeal Board acting in its ex parte appeals capacity. This is not an IPR, PGR, or CBM. It does not appear in the ODP AIA-trial dataset and confers no § 315(e) estoppel on anyone.
  • Application: US 14/342,270 — the parent of the '875, which issued as US 10,520,332 on 2019-12-31.
  • Decided: 2019-09-25 (Decision PDF: https://e-foia.uspto.gov/Foia/RetrievePdf?system=BPAI&flNm=fd2018002421-09-25-2019-0)
  • Status: Reversed — all rejections of claims 1–16 vacated. Verbatim: "We reverse the Examiner's decision to reject claims 1–16."
  • Judge panel: Not confirmed from the sources retrieved — I did not retrieve the signature block and will not guess APJ names.
  • Grounds contested: All § 103(a) obviousness, in four tiers:
    • Claims 1–3, 14, 16 — over Di Martini (US 2008/0177678 A1)
    • Claims 4, 7, 8, 10–12, 15 — over Di Martini + Cumeralto (US 2010/0026517 A1)
    • Claims 5, 6, 13 — over Di Martini + Ransom (US 2005/0131583 A1)
    • Claim 9 — over Di Martini + Borleske (US 2005/0240540 A1)
    • The Examiner withdrew a § 112 rejection that had been in the Final Office Action.
  • Disposition table (verbatim from the decision):
Claims Rejected Basis Affirmed Reversed
1–3, 14, 16 § 103 Di Martini None 1–3, 14, 16
4, 7, 8, 10–12, 15 § 103 Di Martini, Cumeralto None 4, 7, 8, 10–12, 15
5, 6, 13 § 103 Di Martini, Ransom None 5, 6, 13
9 § 103 Di Martini, Borleske None 9
Outcome None 1–16
  • Panel reasoning (core of the reversal): The Examiner's own finding was that "Di Martini does not explicitly disclose that each utility meter message includes said management center identifier," and filled that gap with an asserted motivation ("reduce processing time and 'electric power consumption'"). The Board rejected that gap-filling. This matters directly to the '875, whose independent claim 1 recites the identical triad — "said utility meter identifier, said destination data concentrator identifier, and said utility management center identifier."
  • Settlement / termination: N/A — ex parte.
  • Appeal: The Board decision is the terminal action; a § 145/§ 141 appeal to the Federal Circuit was not taken (the parent issued shortly thereafter). No CAFC docket identified. I found no Federal Circuit opinion involving this family.
  • Defensive value: Do not treat this as a "free kill." It says that when the examiner's best § 103 combinations (Di Martini, Cumeralto, Ransom, Borleske — every one of which appears in the '875's face citations) were put to a three-judge Board panel, the panel reversed in full. Any new § 103 theory built on those same four references has already lost once. Your best IPR art needs to be art that is not Di Martini/Cumeralto/Ransom/Borleske, aimed at the three-identifier message limitation or the concentrator-side ΔCPT computation.

Pattern signals from Nagravision's other PTAB history (context only — different patents)

Two AIA trials have been filed against Nagravision, neither on this family, both by Apple, both terminated-settled before institution:

Takeaways: (a) Nagravision has faced exactly two PTAB challenges in its history, against its conditional-access portfolio; (b) both were settled, meaning Nagravision has never litigated an IPR to a Final Written Decision — there is zero track record of how it performs when an IPR is actually instituted; (c) no defensive aggregator (Unified Patents or similar) appears anywhere in this family's chain — the Nagravision filings were both operating-company (Apple) challenges.


Strategic summary

Claim status — the whole patent is untested. Claims 1–18 of US 10,724,875 (18 claims per the patent) have never been before the Board in an AIA trial. Nothing is canceled, nothing is sustained by a FWD, nothing has been narrowed by amendment. If you face assertion today, you are writing on a blank slate: you cannot point to a canceled claim, but equally the patent owner cannot point to a Board decision upholding one. The five-member continuation family (US 10,520,332 → 10,982,972 → 11,359,933 → 11,733,061 → 12,158,359, the last granted 2024-12-03) means the same disclosure is asserted through at least six separate claim sets with separate statutory windows, separate § 315(b) clocks per petitioner, and separate § 315(e) estoppel scopes. Do not assume a challenge to the '875 disposes of the family; conversely, an IPR on one sibling does not estop you against the others.

Estoppel landscape. There is no § 315(e)(2) estoppel of any kind against anyone on this patent — estoppel arises only from a petitioner's instituted IPR/PGR, and none exists. Every prior-art ground remains fully available: § 102/§ 103 on any art, including the four references already litigated in the ex parte appeal. One practical asymmetry: a future petitioner is not barred from re-using Di Martini/Cumeralto/Ransom/Borleske, and the ex parte reversal is not binding precedent on a PTAB trial panel — but it is admissible evidence of what a panel did with that art, and it materially raises your burden in front of the same institution-deciding body.

The 2026 procedural environment is now the dominant variable, not the merits. As of late 2025 the Board's institution behaviour changed sharply: the Director assumed personal authority over institution determinations (October 2025), the "settled expectations" doctrine is being used to deny petitions against older patents, and an October 2025 NPRM proposed mandatory denial where a claim was previously upheld by the USPTO, ITC, or a court, plus mandatory denial where a parallel proceeding will resolve validity first, and a requirement that petitioners abandon all § 102/§ 103 defences elsewhere. Institutional data reported for Q4 2025 shows institution rates around 14% under the new bifurcated procedure, against a historical 60–70%. See https://thenaplesroundtable.org/wp-content/uploads/formidable/29/2025-in-Review-Unified-Patents.pdf and https://www.bsa.org/files/policy-filings/09022026bsausptofee.pdf. Two features of the '875 make this acute: (i) its 2011 priority / 2012 PCT filing date places it squarely in the "old patent" category the settled-expectations doctrine is reported to immunize, and (ii) the 2019-09-25 Board reversal — reversing an examiner's § 103 rejections of the parent's claims 1–16 — is exactly the kind of "previously upheld by the USPTO" event the proposed rules would treat as a mandatory-denial trigger. I flag this as a rule-design consideration, not a legal conclusion — whether an ex parte appeal reversal in a parent application counts as a "claim previously upheld" under any final rule is unresolved and I have not verified it against the final rule text.

Litigation context. Consistent with the previously generated litigation section, no infringement suit asserting the '875 or any sibling has been identified. This is coherent with the IPR picture: a patent that is never asserted never attracts an IPR. The absence of PTAB activity here is best read as evidence of non-enforcement, not of strength.


Recommended next steps

  1. Do not brief "the IPRs." If you are drafting an invalidity position or a defence strategy, state plainly that no AIA trial has ever been filed against US 10,724,875. Asserting otherwise is fabrication.
  2. Use the ex parte appeal as your validity benchmark and your art screen. Pull the full decision at https://e-foia.uspto.gov/Foia/RetrievePdf?system=BPAI&flNm=fd2018002421-09-25-2019-0 and treat Di Martini (US 2008/0177678 A1), Cumeralto (US 2010/0026517 A1), Ransom (US 2005/0131583 A1) and Borleske (US 2005/0240540 A1) as spent art. Centre any new challenge on (a) the claim-1 requirement that the meter→concentrator message carry the management center identifier, and (b) the concentrator-side ΔCPT computation — the two limitations the Board treated as the differentiators.
  3. Verify the null result in primary sources before relying on it. I state "zero AIA trials" with moderate-to-good confidence, but my searches cannot see everything:
    • PTAB E2E / PTAB Center search by patent number 10,724,875 and by the five siblings (https://ptacts.uspto.gov/ptacts/).
    • USPTO Open Data Portal AIA-trial API (the source of the empty structured block).
    • Docket Navigator / Unified Patents litigation portal filtered to Nagravision, and the § 290 statutory-notice filings on the '875's Patent Center record.
      The residual risk is a very recent, not-yet-indexed petition (2026 filings may lag in the sources reachable here), and ex parte reexaminations, which are not AIA trials and which I did not search — note that reexam requests hit an all-time high of 726 in 2025, so if a third party is attacking this family off-court today, that is the more likely vehicle than an IPR.
  4. If an IPR is contemplated, budget around the § 315(b) clock and the 12-month statutory FWD deadline from institution, and expect a materially harder institution path than the pre-2025 baseline: the Director's summary-notice process, the parallel-litigation stipulation requirement, and the mandatory-denial proposal all bite harder here than on a young, unadjudicated patent.
  5. Watch the family, not the patent. With US 12,158,359 granted 2024-12-03 and continuations running to that date, the live assertion risk is at least as likely to land on a younger sibling — which would carry its own clean § 315(b) clock and its own estoppel scope, and would not be shielded by the "'875 is old" argument.

Generated 9/29/2026, 5:23:55 AM

Ownership chain (2)

Asserters network →

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

  1. 2019-11-25 · recorded 2019-12-11 · reel 051247/0558 · Assignment

    Joel Wenger; Corinne Le BuhanNagravision S.A.

    internal perfection of title

  2. ? · recorded 2024-06-19 · reel 067767/0405 · Change of Name

    Nagravision S.A.Nagravision SARL

    change of name only

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 10,724,875 across USPTO Assignment Center, Google Patents legal events, and related sources.

Let me query the USPTO Assignment Center and related databases directly.

I have enough to reconstruct the record from the authoritative Google Patents legal events (the full text provided), cross-referenced against corporate-registry data for the assignee. Note up front: my live searches for the USPTO Assignment Center reel-level detail (correspondent of record, execution dates) returned only the reel/frame numbers and conveyance summaries already embedded in the patent's legal-events block — the correspondent field itself was not retrievable through the sources reachable here. I flag each place that matters rather than guess.


Assignment / Ownership Reconstruction — US 10,724,875

Patent: US 10,724,875 B2 — "System and method to manage utility meter communications"
Application: 16/685,241 (filed 2019-11-15; granted 2020-07-28)
Priority: 2011-08-30 (EP 11179337.8; US prov. 61/528,822)
Chain depth: two recorded events, both inside a single corporate family

Inventors

Inventor Employer at filing (determinable?)
Joel Wenger Nagravision S.A. — applicant of record; no independent employment record surfaced
Corinne Le Buhan Nagravision S.A. — applicant of record; no independent employment record surfaced

The patent names exactly two inventors. Both are presumed Nagravision personnel: the PCT/EP2012/066803 applicant was Nagravision, and both inventors executed the assignment to Nagravision S.A. There is no evidence in the record of either inventor assigning to an entity other than the original employer.

Pattern notes (for the fire-sale screen):

  • No inventor-departure signal. The inventors did not assign to a third party, form a holding entity, or appear as assignors post-2019. Nothing suggests a pre-fire-sale exodus.
  • Unusual — but benign — late assignment. The inventors executed their assignment on 2019-11-22 to 2019-11-25, i.e. ~8 years after the 2011 priority filing and 7–10 days after the 2019-11-15 continuation was filed. This is a confirmatory/perfecting assignment tied to the new continuation, not a sale. It is a chain-of-title housekeeping step, not a distress event.
  • Possible name-coincidence to flag, not a finding. A European patent attorney named Joel-Théophile Wenger (Leman Consulting S.A., 62 route de Clémenty, 1260 Nyon, CH) has represented Nagravision in unrelated EP prosecutions (e.g. EP 0 974 229 B8 representative of record). I cannot confirm this is the same individual as the inventor Joel Wenger. Flagged only so the overlap is not mistaken for evidence of anything; treat as unclear.

Original assignee

Nagravision S.A. (Cheseaux-sur-Lausanne, Switzerland) — a large operating company in the Kudelski Group, publicly traded on the SIX Swiss Exchange (ticker KUD.S). Primary line of business: digital-TV conditional-access / content-security systems (pay-TV smart cards, set-top security, DRM), not utility metering. The '875 family is an outlier in the portfolio — a smart-grid/AMI metering line rather than the core pay-TV line (compare the prior-generation litigation profile in the litigation summary, all pay-TV/CA matters).

  • Did they ship a product embodying the claims? Unclear. Kudelski/Nagravision marketed smart-metering and IoT security offerings during the 2011–2015 window, but I did not locate a specific commercial AMI/data-concentrator product mapping to the claims. Flagged as unclear, not asserted.
  • Current status: Operating. The entity still exists but was renamed Nagravision Sàrl (Swiss commercial register CHE-105.200.676; the register shows the "as Nagravision SA" history running through ~2019, consistent with a name change effective 2021-12-20). No bankruptcy, dissolution, or fire-sale found.

Assignment timeline

2019-11-22/2019-11-25 (executed) / recorded 2019-12-11 — Reel 051247/0558

  • Conveyance: Assignment
  • Assignor: Joel Wenger; Corinne Le Buhan (individuals)
  • Assignee: Nagravision S.A., Switzerland
  • Correspondent: Not retrievable from the sources reachable here. The Patent Assignment Search record was not surfaced with its correspondent field; this is a gap, not an absence of a correspondent.
  • Context: Internal perfection of title — inventors' rights assigned to the applicant company, executed 7–10 days after the 2019 continuation was filed and recorded ~4 weeks later. Not a sale; no consideration party outside the original family.

2021-12-20 (effective) / recorded 2024-06-19 — Reel 067767/0405

  • Conveyance: Change of Name
  • Assignor: Nagravision S.A.
  • Assignee: Nagravision SARL, Switzerland
  • Correspondent: Not retrievable from the sources reachable here.
  • Context: Change of name only — Swiss corporate re-registration (SA → Sàrl), same legal person, no change in beneficial ownership and no new third-party acquirer.

No other recorded events. There is no post-issuance transfer, security interest, license, merger, or release in the record for this patent. The only two entries are (i) the original inventors→company assignment and (ii) an intra-family change of name. Per the framework, this is effectively a single-owner chain — see Verdict.

Timeline diagram

timeline
    title Ownership of US 10724875
    2011 : Priority filed by Nagravision
         : Inventors Wenger and Le Buhan
    2012 : PCT application filed
    2019 : Continuation filed
         : Inventors assign to Nagravision SA
         : Reel 051247 frame 0558
    2020 : Patent granted
    2021 : Nagravision SA renamed Nagravision Sarl
    2024 : Change of name recorded
         : Reel 067767 frame 0405

NPE / troll-pattern signals

  1. Shell-entity transfer — Not present. The patent never left the operating-company family. No "IP/Patents/Licensing/Holdings/Ventures"-suffixed LLC appears at any reel. Both recorded assignees (Nagravision S.A., Nagravision SARL) are the same Swiss operating entity before and after the 2021-12-20 rename recorded at Reel 067767/0405.

  2. Known asserter in the chain — Not present. Neither Nagravision S.A. nor Nagravision SARL matches the public NPE lists (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, Round Rock, etc.). Kudelski has been a practicing-company litigant (pay-TV), which is a different posture from an NPE. No asserter-directory hits on this patent family.

  3. Repeat correspondent across the chain — Unclear / not assessable. The correspondent of record was not retrievable for either Reel 051247/0558 or Reel 067767/0405 through the sources reachable here. With only two events and no correspondent data, no recurrence can be shown. (The Joel-Théophile Wenger / Leman Consulting EP-prosecution name is not established to be a recording correspondent and is not treated as a finding.)

  4. Cascading transfers — Not present. Only two events exist, ~5 years apart, and the second is a pure rename. There is no chained-LLC sequence and no <24-month cluster.

  5. Pre-litigation transfer — Not present. No litigation involving US 10,724,875 is on record (per the earlier litigation section). There is no transfer within any pre-suit window because there is no suit and no third-party transfer.

  6. Bankruptcy fire-sale — Not present. No Chapter 7/11, no assignment-for-benefit, no court-supervised sale. Assignee remains an active, publicly traded group subsidiary.

  7. Privateering — Not present. No transfer to any entity that could be asserting on Nagravision's behalf; ownership stayed in-house.

  8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. It terminates at the original family.

Verdict

Insufficient data.

Within this framework the correct categorical call is not an NPE: all eight troll-pattern signals are absent, and the record shows only the original inventors→Nagravision assignment at Reel 051247/0558 (recorded 2019-12-11) plus a pure change of name at Reel 067767/0405 (effective 2021-12-20, recorded 2024-06-19). I select "Insufficient data" rather than "Operating-company assertion" only because the framework reserves the latter for a current assignee that is actively suing on the patent, and no assertion (or defensive-aggregator terminus) exists — so there is no transfer event beyond the original assignment to analyze for NPE signatures. Substantively, ownership is a clean single-family operating-company chain (Kudelski Group / Nagravision), and the patent is best characterized as held by its original corporate owner, non-asserted, with no NPE indicators.

Verification links:

Residual gaps to close with primary sources (I could not fully resolve these): (1) the correspondent of record on Reels 051247/0558 and 067767/0405; and (2) whether any parent/priority-application assignment (2012, for national-stage 14/342,270) was separately recorded, since the legal-events block for '875 shows only the 2019 confirmatory assignment. Confirm both in USPTO Patent Center / Assignment Search before relying on this for any clearance purpose.

Generated 9/29/2026, 5:24:09 AM

Prior art

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

✓ Generated

I'll research the prior-art citations for US 10,724,875. Let me verify the reference details and identify the most relevant art.

Let me verify the remaining references to complete the analysis.

Prior-Art Analysis — U.S. Patent No. 10,724,875

Patent: US 10,724,875 B2, "System and method to manage utility meter communications"
Assignee: Nagravision SARL (Kudelski Group) | App. No. 16/685,241 | Filed 2019‑11‑15 | Granted 2020‑07‑28 | Priority 2011‑08‑30 | Claims: 18 (1–9 method; 10–18 system)

Note on dates: my environment reports today as 2026‑09‑29 while the task header states 2026‑04‑26. This is immaterial to the prior-art analysis below, because every reference relevant to §102 has a date years before the '875 priority date of 2011‑08‑30.

Note on scope: the litigation section concluded no litigation is known against the '875 patent. That finding does not restrict this analysis — prior art of record is independent of enforcement history. I found nothing in the record that contradicts the earlier section.


A. Threshold framing (why §102 vs. §103 matters here)

With a 2011‑08‑30 priority date, the '875 patent is judged under pre‑AIA 35 U.S.C. §102/§103. All twelve cited references were published 1992–2013 but filed / priority‑dated 1987–2008, i.e., they qualify as §102(b) printed publications or §102(e)/(a)(2) patent documents relative to the '875 priority date. (US 2013/0300577, published 2013‑11‑14, relies on its 2007‑01‑04 priority for §102(e) treatment.)

Critical structural observation: independent claims 1 and 10 require a combination of three things working together:

  1. A utility-meter message that carries four data elements — the metering measurement, the utility meter identifier, the destination data concentrator identifier, AND the utility management center identifier;
  2. Determination of a metering counter differential consumption value from the difference of two counter indexes over a time interval; and
  3. A report sent from the data concentrator to the management center containing that differential value.

Almost every cited reference is AMR configuration / reconfiguration art (Itron / Elster) or pre‑smart‑meter RF pulsing art. None of them, on their face, discloses the management-center identifier embedded in the meter-to-concentrator message combined with concentrator-side differential computation and reporting. So the realistic §102 exposure is low, and the more plausible attack vector is §103. I state this up front so the per-reference notes are not overread.


B. Background art expressly discussed in the '875 specification

These two are cited in the "Background Art" narrative (not merely listed) and are therefore the examiner's/inventor's own characterizations of the closest art.

B1. US 2008/0068213 A1 — Cornwall et al. ("Managing serial numbering of encoder-receiver-transmitter devices in automatic meter reading systems")

  • Full citation: U.S. Pub. No. 2008/0068213 A1; App. 11/828,710; filed 2007‑07‑26; pub. 2008‑03‑20; assignee Itron, Inc.; priority U.S. Prov. 60/833,350 (2006‑07‑26).
  • Description: ERT/AMR devices transmit Standard Consumption Messages (SCM) carrying a consumption reading plus a 26‑bit ERT serial number, and Interval Data Messages (IDM) carrying differential consumption values for 47 intervals. The spec's own characterization of this reference is limited to: periodic wake‑up/low‑power ERT devices that are uniquely identifiable and RF‑report consumption.
  • §102 exposure: The ERT serial number (meter identifier) + consumption/differential consumption data map loosely onto the "utility meter identifier" and "differential consumption value" elements of claim 1. But it discloses no data concentrator, no management‑center identifier in the meter message, and no concentrator‑to‑management‑center report. Anticipates nothing in claims 1/10 as a whole. Potential §103 relevance to the differential‑consumption element only. (Independently confirmed: same reference is cited in the family's EP 2 751 525 and WO 2013/030248 publications.)

B2. U.S. Pat. No. 5,974,369 — WPS Energy Services ("Recording and processing metered information")

  • Full citation: U.S. Pat. No. 5,974,369; filed 1996‑08‑28; granted 1999‑10‑26; assignee WPS Energy Services Inc. (Inventor per Justia: recording‑node architecture.)
  • Description: A "recording node" receives energy‑related consumption meter data, calculates a consumption amount and rate for a particular time interval, stores it, receives price data from an external source over a (distributed) network, and makes accumulated consumption values and prices available for billing. Crucially the spec itself notes the network "preferably does not include a central processor."
  • §102 exposure: This is the closest prior art for claim 2 / claim 11 ("detailed tariff computation based on a tariff table and the metering counter differential consumption value") — the recording node combines consumption amounts with externally supplied price data. It is also superficially relevant to claim 1's "report containing the differential value." However, it lacks the meter→concentrator→management‑center identifier architecture and the separate concentrator role; the "recording node" is not a stateful multi‑tenant data concentrator. Best characterized as §103 art against claims 2/11, and against the general "compute billing values at an intermediate node" concept.

C. References of record — the 12‑item "Patent Citations" list

C1. U.S. Pat. No. 5,079,715 — Krishnan Venkataraman, "Electronic data recorder for electric energy metering"

  • Dates: filed 1987‑12‑28; granted 1992‑01‑07.
  • Description: Earliest reference; an electronic recorder that accumulates and stores electric‑energy metering data for later retrieval. General data‑logging art.
  • §102 exposure: None against claims 1/10. It predates networked concentrator architectures and contains no identifier‑addressed messaging or differential‑value reporting. Cited for general background (§102(a) prior art of the "metering data recorder" genus only).

C2. US 2005/0131583 A1 — Ransom ("System and method for federated security in an energy management system")

  • Dates: priority 1994‑12‑30; pub. 2005‑06‑16. (Marked * — examiner‑cited in the record.)
  • Description: Security architecture for energy management — federated security/key management among energy‑system nodes.
  • §102 exposure: Not an anticipation reference for claims 1/10. It is the reference most on‑point for the security‑related claims 3–6 and 12–15 (signing/encryption/authentication of reports), and its energy‑management federated security framing is a logical §103 combination partner should an examiner want to attack the security limitations. Anticipates nothing structural.

C3. U.S. Pat. No. 6,006,212 — Itron ("Time‑of‑use and demand metering in conditions of power outage with a mobile node")

  • Dates: filed 1997‑12‑09; priority U.S. Prov. 60/059,170 (1997‑09‑17); granted 1999‑12‑21; inventors Schleich & Myers; assignee Itron, Inc.
  • Description: RF transmitter sends a linearly incremented count; a receiver with an asynchronous receiver counter decodes it. Claims expressly recite differentially encoded consumption values (N‑1 consumption value, differential consumption intervals in a buffer) and an interrogate/receiver device that transfers decoded data to a billing system.
  • §102 exposure: The most substantive §102 candidate for the "metering counter differential consumption value" element of claim 1 (and the corresponding element of claim 10). Its receiver computes/transfers billed quantities. But it discloses no data concentrator identified by an identifier in the meter's message, no management‑center identifier in the meter message, and no concentrator‑generated report. So it does not anticipate claims 1/10 as a whole — it is strong §103 art against the differential‑value limitation. This is the single reference I would expect an examiner to lead with against the core computation feature.

C4. US 2005/0240540 A1 — Borleske, Scoggins, Uy ("System and method for efficient configuration in a fixed network automated meter reading system")

  • Dates: filed 2004‑04‑26; pub. 2005‑10‑27; assignee Elster Electricity / Elster Solutions (granted as U.S. Pat. No. 7,262,709 B2); (examiner‑cited).
  • Description: A collector (data‑collector/meter) identifies sets of meters, sends updated configuration parameters, uses status flags and acknowledgements to verify/retransmit, and resets billing/demand data. The collector reads usage/TOU/load‑profile data from meters and forwards it to a remote location/server, which may itself do the processing.
  • §102 exposure: Directly relevant to:
  • Claim 9 / claim 18 — "configuration message … to update a reporting rate" (the collector→meter configuration download is squarely disclosed, though its object is TOU/season configuration rather than reporting rate);
  • Claim 7 / claim 16 — acknowledgements between meter and collector;
  • Partially relevant to claim 1/10's collector‑intermediary architecture (collector forwards metering data to a remote billing server).
  • Does not anticipate claims 1/10 (no management‑center identifier in the meter message; the "differential consumption value" computation is not the collector's role). It is the strongest §103 art for the claim 7–9 / 16–18 dependent features.

C5. US 2011/0050456 A1 — Itron ("Versatile radio packeting for automatic meter reading systems")

  • Dates: priority 2006‑02‑03; pub. 2011‑03‑03; same family as U.S. Pat. No. 7,830,874 B2 (Itron; "Versatile radio packeting for automatic meter reading systems," filed 2007‑02‑05).
  • Description: RF packet structures for AMR endpoints, including positive outage notification and multi‑collector message reception.
  • §102 exposure: Background/packet‑format art; no bearing on the identifier‑addressing or concentrator‑report architecture of claims 1/10. §103 relevance only to messaging‑format details. Anticipates nothing.

C6. WO 2008/086231 A2 — Itron ("Utility data collection and reconfigurations in a utility metering system")

  • Dates: priority 2007‑01‑04; pub. 2008‑07‑17; assignee Itron, Inc.
  • Description: Collecting utility data and performing reconfigurations (including demand resets) in a metering system — the parent disclosure from which US 2010/0176967 and US 2013/0300577 descend.
  • §102 exposure: Same family as C7/C8/C9 below; relevant only to claims 8/9 and 17/18 (request/configuration messaging) as §103 art. Anticipates nothing in claims 1/10.

C7. US 2010/0176967 A1 — Cumeralto et al. ("Collecting utility data information and conducting reconfigurations, such as demand resets, in a utility metering system")

  • Dates: priority 2007‑01‑04; pub. 2010‑07‑15; assignee Itron, Inc.
  • Description: Utility data collection + reconfiguration commands (e.g., demand resets) issued through the metering system.
  • §102 exposure: As C6. §103 art against the request/configuration dependent claims (8, 9, 17, 18). Anticipates nothing in claims 1/10.

C8. US 2013/0300577 A1 — Itron ("Collecting utility data information and conducting reconfigurations … ")

  • Dates: priority 2007‑01‑04; pub. 2013‑11‑14; assignee Itron, Inc. (continuation in the same family as C6/C7).
  • §102 exposure: Same as C6/C7; §103 art for configuration/request dependent claims. As a 2013 publication, its pre‑AIA §102(e) date rests on the 2007‑01‑04 priority. Anticipates nothing in claims 1/10.

C9. US 2010/0026517 A1 — Itron ("Utility data collection and reconfigurations in a utility metering system")

  • Dates: priority 2008‑01‑04; pub. 2010‑02‑04; assignee Itron, Inc.; (examiner‑cited).
  • §102 exposure: Same family. Relevant only as §103 art to dependent configuration/request claims. Anticipates nothing.

C10. US 2008/0177678 A1 — Paul Di Martini ("Method of communicating between a utility and its customer locations")

  • Dates: priority 2007‑01‑24; pub. 2008‑07‑24; (examiner‑cited).
  • Description: Methods for utility↔customer‑premises communication (metering data exchange between a utility and end‑user locations).
  • §102 exposure: Broad communications‑topology art; no differential‑value computation or concentrator‑report structure. §103 relevance to the general "utility reports to customer location" context; anticipates nothing in claims 1/10.
  • (I did not obtain the full text of this reference within the step budget — the description above is based on the title/record data and should be verified against the document itself before being relied on.)

C11. U.S. Pat. No. 5,079,715 ... — see C1 (deduplicated)

C12. U.S. Pat. No. 5,974,369 — see B2 (this reference appears both in the specification discussion and in the citation list; deduplicated).

The apparent "12" in the citation table is inflated by the same WPS reference appearing in both the Discussion and the citation list. The genuinely distinct references of record are: US 5,079,715; US 2005/0131583; US 5,974,369; US 6,006,212; US 2005/0240540; US 2011/0050456; US 2008/0068213; WO 2008/086231; US 2010/0176967; US 2013/0300577; US 2008/0177678; US 2010/0026517.


D. "Family Cites Families" references (secondary — cited in sibling EP/CN/KR members)

These are listed in the family record and are lower‑confidence relevance:

Reference Dates Description §102 exposure
US 6,907,401 B1 (Verizon Corporate Services) 2000‑03‑13 / 2005‑06‑14 "Portal switch for electronic commerce" None against claims 1/10; only illustrative of intermediary brokering in commerce.
KR 20010109852 A (김태훈) 2000‑06‑02 / 2001‑12‑12 "Gauge auto management system" (meter auto‑management) Generic remote‑meter‑management art; no identifier/addressing architecture. None.
CN 1647041 A (Landis+Gyr) 2001‑09‑25 / 2005‑07‑27 "Utility meter having computer network access for receiving an interpretive language program to implement new meter functionality" Relevant as §103 art to claims 9/18 (downloading configuration/program to update meter behavior). Does not anticipate claims 1/10.
US 7,627,283 B2 (Nivis, LLC) 2004‑09‑10 / 2009‑12‑01 "System and method for a wireless mesh network of configurable signage" Mesh‑networking/reconfiguration art; peripheral. None against claims 1/10.

E. Synthesis — claim‑by‑claim prior‑art map

Claim(s) Subject matter Most relevant cited reference(s) Anticipation (§102) or obviousness (§103)?
1, 10 (independent) Meter message w/ measurement + meter ID + concentrator ID + management‑center ID; differential value; concentrator→center report None discloses the full combination. Closest: US 6,006,212 (differential consumption + receiver→billing transfer) and US 2008/0068213 (ERT ID + differential IDM) No §102 anticipation identified. US 6,006,212 is the strongest §103 springboard against the differential‑value limitation; the identifier‑addressing/report combination is the residual inventive gap.
2, 11 Report with detailed tariff computation from a tariff table US 5,974,369 (consumption + external price data at a recording node) Best §103 combination (with a concentrator‑architecture primary reference). Not a clean §102 hit, but the closest single reference on tariffs.
3–5, 12–14 Securing the report (encrypt / sign) US 2005/0131583 (federated security for energy management) §103 only; security of meter/energy reports was notoriously well‑known.
6, 15 Process report only if authenticated US 2005/0131583; general PKI/signature art §103 only.
7, 16 Acknowledgement from concentrator to meter US 2005/0240540 (status flags + acknowledgements); US 6,006,212 §103 on the ack‑verification feature.
8, 17 Meter message sent in response to a concentrator request US 2005/0240540; WO 2008/086231 / US 2010/0176967 family (polled reads) §103.
9, 18 Configuration message to update reporting rate US 2005/0240540 (configuration download); CN 1647041 (program download to meter) §103 — configuration‑download art is dense.

F. Bottom line

  1. No cited reference anticipates independent claims 1 or 10 as a whole. The novelty‑critical feature — a meter message that simultaneously carries the utility‑meter ID, the destination‑concentrator ID, and the utility‑management‑center ID, with the concentrator then computing and reporting the metering counter differential value to the management center — is not shown in any reference of record.
  2. The single most substantive reference is U.S. Pat. No. 6,006,212 (Itron) — it expressly discloses differentially encoded consumption values and a receiver that transfers decoded data to a billing system, and is the best §103 art against the "differential consumption value" element of claims 1/10.
  3. U.S. Pat. No. 5,974,369 (WPS Energy Services) is the key reference for the tariff‑computation dependent claims (2, 11), and US 2005/0131583 (Ransom) for the security dependent claims (3–6, 12–15).
  4. US 2005/0240540 (Borleske / Elster) best covers the configuration/acknowledgement/request dependent claims (7–9, 16–18).
  5. The bulk of the record (US 5,079,715; US 2011/0050456; the Itron "Utility data collection and reconfigurations" family; US 2008/0177678; WO 2008/086231; the four family‑cited references) is background/configuration art with no §102 anticipation and only marginal §103 value.

Confidence and caveats: I am high‑confidence on the citation list and dates because they come from the patent's own record. I am moderate‑confidence on my characterization of US 2008/0177678 (Di Martini) and the four family‑cited references, because I did not retrieve their full texts within the research budget — verify those against the documents before relying on them. Finally, note the §102/§103 characterization is my analytical judgment as a technical analyst, not a legal conclusion or a substitute for an examiner's or counsel's validity opinion.

Generated 9/29/2026, 5:24:13 AM

Obviousness

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

✓ Generated

I'll verify the content of the key prior-art references cited on the patent page before building the obviousness analysis.

Let me verify the remaining cited references relevant to message-addressing and multi-party reporting.

Obviousness Analysis — U.S. Patent No. 10,724,875 B2

35 U.S.C. § 103 (pre-AIA § 103(a))

Analyst note on dates: this task states the current date as April 26, 2026; the session header states 2026-09-29. I flag the discrepancy but it does not affect the analysis, which turns on art predating the 2011-08-30 priority date. Nothing in the previously generated litigation section contradicts the claim/family data used here.


I. Governing framework and assumptions

Governing law. The '875 patent is a continuation of application 14/342,270, which is the U.S. national stage of PCT/EP2012/066803, which claims priority to EP 11179337.8 and U.S. Provisional 61/528,822, both filed 2011-08-30. Because the claims therefore have an effective filing date before 2013-03-16, pre-AIA 35 U.S.C. §§ 102/103 apply. All references relied on below published well before 2011-08-30 and thus qualify as prior art under pre-AIA § 102(a)/(b), and none is commonly owned with the patentee.

Legal standard. Graham v. John Deere Co., 383 U.S. 1 (1966) (scope and content of prior art; differences; PHOSITA level; secondary considerations). KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) (combination of known elements; predictable results; design incentives and market forces; "obvious to try" where a finite number of predictable solutions exist). In re Keller, 642 F.2d 413 (CCPA 1981) (test is what the combined teachings would have suggested, not bodily incorporation of one reference into another).

PHOSITA. A person having ordinary skill in the art as of 2011-08-30 would be someone with a bachelor's degree in electrical/computer engineering or computer science, or equivalent, plus 2–4 years of experience in automated metering infrastructure (AMR/AMI), utility telemetry networks, and applied cryptography. This is the level at which the combinations below are assessed.

Claim construction points that materially broaden the attack.

  1. No security limitation in claim 1 or claim 10. Security appears only in dependent claims 3–6 and 12–15, even though the specification and the Summary of the Invention emphasize securing messages. Mapping claim 1 therefore does not require any reference to teach encryption or signatures.
  2. The "determining" step of claim 1 is actor-neutral. Claim 1 recites "determining a metering counter differential consumption value based on a difference of two metering counter consumption indexes" without naming an actor. The preamble designates the data concentrator as the entity that "produce[s] and send[s] reports," and the specification confirms the concentrator performs the derivation, but the claim text itself is broad.
  3. None of the specification's more distinctive embodiments is claimed. The consolidated consumption invoicing report CR_c,p, the roaming/re-routing of messages by non-destination nodes, the reporting-period accumulation in memory (ΔRT), and the acknowledgement/retransmission and iic mechanisms are described but are largely absent from the granted claims. This means much of what the specification presents as differentiating is not part of the § 103 inquiry. Claims 7–9 and 16–18 do capture acknowledgement, polled reporting, and configuration messages — each of which is squarely conventional in AMR.

II. The references of record and what each supplies

Reference Source URL Core teaching relevant to § 103
US 5,974,369 A — WPS Energy Services ("Recording and processing metered information"); granted 1999-10-26 https://patents.google.com/patent/US5974369 Node (concentrator analogue) receives meter data over discrete periods; calculates accumulated consumption amount for a time interval and resets/repeats for the next interval; receives and stores price data from an external source; calculated consumption values and prices are available over the network to a service provider for billing. Expressly discussed in the '875 Background Art.
US 2008/0068213 A1 — Cornwall et al. (Itron) https://patents.google.com/patent/US20080068213A1/en AMR infrastructure where each meter/ERT must be uniquely identifiable (26-bit SCM serial; 32-bit IDM serial) so readings are "properly associated with its corresponding location and customer account"; SCM carries ERT type, tamper fields, consumption data; IDM carries "Last Consumption Count" plus 47 interval "Differential Consumption Intervals."
US 2011/0050456 A1 — Cornwall et al. (Itron), pub. 2011-03-03 https://patents.google.com/patent/US20110050456 Versatile radio packets whose body includes an endpoint ID field and a serial number field plus a message-type field; a reader filters/relays a subset of packets to the processing center using type-discriminating information. Demonstrates source/destination-style addressing and selective relaying in AMR packets.
WO 2008/086231 A2 / US 2010/0026517 A1 — Cumeralto et al. (Itron) https://patents.google.com/patent/WO2008086231A3/en ; https://patents.google.com/patent/WO2008086213A1#5 Endpoints, a collector/reader, endpoint-specific database, one-way "bubble-up" and two-way modes; reader sends an instruction/command requesting a set of consumption information, endpoint responds with a message containing the requested consumption information; commands for correcting a clock, changing a TOU schedule, or configuration programming of storage; confirming message after successful receipt of consumption data.
US 2005/0131583 A1 — Ransom (Power Measurement) https://patents.google.com/patent/US20050131583 Federated security between Non-Affiliated Entities — expressly "a group of competitor utilities"; security device provides access data; authenticatable, encrypted, non-repudiatable energy management data; PKI, certificates, session keys; billing data and "tariffs for gas, water, steam and air."
US 2005/0240540 A1 — Borleske (Elster) https://patents.google.com/patent/US20050240540A1 Efficient configuration in a fixed-network AMR system — reconfiguring deployed meters over the air.
US 5,079,715 A — Venkataraman https://patents.google.com/patent/[US5079715A](/patent/US5079715A) Electronic data recorder for electric energy metering (corroborates interval/counter recording).
US 6,006,212 A — Itron https://patents.google.com/patent/[US6006212A](/patent/US6006212A) Time-of-use and demand metering with a mobile node (interval-based counter data).
US 2008/0177678 A1 — Di Martini https://patents.google.com/patent/US20080177678A1 Communicating between a utility and its customer locations.

Verification caveat: I retrieved and read the full or near-full text of US 5,974,369, US 2008/0068213, US 2011/0050456, WO 2008/086231/US 2010/0026517, and US 2005/0131583. I did not retrieve full text for US 5,079,715, US 6,006,212, US 2005/0240540, or US 2008/0177678 before my search budget was exhausted; those four are mapped below only to the extent of their titles/abstracts and the '875 patent's own characterizations, and I flag that limitation rather than assert paragraph-level support.


III. Primary reference: element-by-element chart for claim 1

Claim 1 limitation US 5,974,369 (primary) Supplement / motivation
Network of utility meters each associated with a management center through an intermediate data concentrator; meter identified by meter ID; meter sends messages to a destination data concentrator identified by an ID; concentrator sends reports to the management center identified by an ID Recording node receives meter data and makes calculated values available over a distributed/process-control network to a service provider for billing; the node is functionally the intermediate aggregation point between meter and provider. US 2008/0068213 supplies unique meter identification ("Each ERT must be uniquely identifiable... associated with its corresponding location and customer account"). US 2011/0050456 supplies explicit source/endpoint ID fields and relaying to a processing center. Destination/management-center identifiers are conventional packet-addressing fields (the '875 specification itself acknowledges IP v4/v6 and ANSI/IEC messaging).
Utility meter message includes metering data measurement, meter identifier, destination data concentrator identifier, management center identifier Metering data measurement: yes ("receiving sets of metering data"). Multiple identifiers in one message: not taught (single-node/peer network). US 2008/0068213 (SCM/IDM: serial number + consumption data + ERT type in one packet) and US 2011/0050456 (endpoint ID + serial number + message type in one packet) teach multi-field metering messages. Adding a provider ID to such a message follows from deregulation where a meter's consumption is billed to a chosen provider — precisely the scenario Ransom addresses between "competitor utilities."
Determining a metering counter differential consumption value from two counter indexes measured within a time period interval Explicit: the recording node "calculat[es] an accumulated consumption amount for a particular time interval," stores it, and "resets and begins calculating values for the next time interval" — i.e., per-interval deltas of metered counts. Pulses from the meter may be counted and summed. US 2008/0068213's IDM "Differential Consumption Intervals" (47 × 9-bit differential values) and "Last Consumption Count" are the same concept expressed as packet fields. US 6,006,212 supplies interval/TOU counter differencing.
Sending, from the concentrator to the management center to which the meter is associated, a report including at least the differential value Explicit: "Consumption values and price data stored in the recording node are available to other nodes in the network"; the '875 Background admits the service provider "can receive previously accumulated consumption values... for billing purposes over network." "Management center" reads on the provider-side billing system under BRI; nothing in claim 1 requires the elaborate management-center functions (load management, outage control) described in the specification.

Conclusion on claim 1. US 5,974,369 discloses every functional step of claim 1 — receiving metered counter data, computing a per-interval differential consumption amount, and forwarding it to a utility's billing system — as the '875 applicant itself conceded in the Background Art. The only genuine gap is the multi-identifier utility meter message (Uid + DCid + Pid). That gap is filled by US 2008/0068213 and/or US 2011/0050456, and closing it requires no more than routine packet design.


IV. Anticipation cross-check (§ 102)

US 5,974,369 likely does not anticipate claim 1 standing alone, for one structural reason: its distributed network is deliberately decentralized ("no central network computer node or central processor," per its own summary), and it does not describe a meter message bearing both a concentrator identifier and a management-center identifier. A § 102 rejection would require reading "destination data concentrator identifier" and "management center identifier" out of a description that does not use that architecture. § 103 is the correct and stronger ground. (This same decentralization language is the patentee's best § 103 rebuttal hook — addressed in § VIII.)


V. Combinations that render the claims obvious

Combination A — Claim 1 (and claim 10)

US 5,974,369 + US 2008/0068213 A1

Rationale: US 5,974,369 teaches the aggregation-and-forwarding architecture (meter → recording node → provider, with the node computing the period differential and holding price data); US 2008/0068213 teaches that AMR endpoints transmit multi-field messages bearing a unique identifier so the reading "can be properly associated with its corresponding location and customer account." A PHOSITA implementing the '369 node in a modern RF/PLC AMR grid would necessarily adopt the '213 message structure, adding a provider identifier so the aggregated consumption is routed to the correct one of several competing providers. KSR rationales: (i) combination of known elements with predictable results; (ii) known technique (packet source-and-destination addressing) applied to a known device ready for improvement.

Combination B — Claims 1 and 10 (strengthened)

US 5,974,369 + US 2008/0068213 A1 + US 2011/0050456 A1

US 2011/0050456 makes the addressing element even more explicit: its versatile packet body contains an endpoint ID field and a serial number field and its reader relays a filtered subset of packets to a processing center. That is precisely the claimed flow: a meter message carrying its own identity plus routing context, delivered to a concentrator that then reports upstream. This combination removes any doubt that multi-identifier metering messages were known and conventional.

Combination C — Claims 3–6 and 12–15 (security and authentication)

Combination A or B + US 2005/0131583 A1

Ransom teaches exactly the security architecture the dependent claims recite: a security device that provides access data between non-affiliated entities that "may not fully trust one another" — expressly "a group of competitor utilities"; energy management data that is authenticatable, encrypted, and non-repudiatable; PKI/certificate/session-key mechanics; and billing data including "tariffs for gas, water, steam and air." This maps onto:

  • Claims 3/12 (securing the report) — Ransom's secure EM data exchange;
  • Claims 4/13 (encryption with a key) — Ransom's public/private key and session key disclosure;
  • Claims 5/14 (digital signature) — Ransom's authenticatable/non-repudiatable data;
  • Claims 6/15 (process only if authenticated) — Ransom's assertion-validation and access-limiting device.

Motivation is unusually strong here: the '875 specification concedes that PKI with RSA key pairs and X.509 certificates is the industry-standard requirement of smart-grid standards, and that "secured messages" are obtained "by combining signing and encryption processes." Where the specification itself characterizes the security layer as conventional, importing Ransom's federated-security teachings is the epitome of a predictable combination. The multi-provider (deregulated) setting supplies the reason to authenticate cross-entity data.

Combination D — Claims 7, 8, 9 and 16, 17, 18 (acknowledgement, polling, reconfiguration)

Combination A or B + WO 2008/086231 A2 (US 2010/0026517 A1), optionally + US 2005/0240540 A1

  • Claims 7/16 — acknowledgement from concentrator to meter: WO 2008/086231 describes a "confirming message after successful receipt of utility consumption data by the utility data collector" (its claim 17) and addresses the failure mode of unacknowledged reset/read commands; US 5,974,369 itself sends an acknowledgement signal over the network upon a successful update ("step 170 then sends an acknowledgement signal... accessible to the device that sent the data" — https://lexdana.ai/patent/[5974369](/patent/5974369)).
  • Claims 8/17 — meter message sent in response to a concentrator request: WO 2008/086231 discloses a reader that selectively transmits "an instruction that includes a command requesting a set of consumption information from such endpoint," with the endpoint "respond[ing] to such command by transmitting a message that includes the requested consumption information." This is claim 8 almost verbatim.
  • Claims 9/18 — configuration message updating the reporting rate: WO 2008/086231's endpoint receives commands for "correcting a clock of the endpoint, changing a time of use (TOU) schedule, or configuration programming of the storage means"; US 2005/0240540 is directed to "efficient configuration in a fixed network automated meter reading system." Adjusting a reporting interval is a species of configuration programming.

These limitations are, in substance, the ordinary housekeeping channel of any two-way AMR system. Adding them to Combination A/B is a textbook KSR "arrangement of old elements" with predictable results and no change in the principle of operation.

Combination E — Claims 2 and 11 (detailed tariff computation in the report)

US 5,974,369 alone (or Combination A/B + US 2005/0131583)

US 5,974,369 expressly discloses the tariff-computation feature: price data is received at the recording node from an external source, pricing is updated when a price change is implemented, and the service provider receives "previously accumulated consumption values and associated prices for past consumption intervals, for billing purposes." Its claim 30 recites "receiving, storing, and updating pricing information, on an ongoing basis, at the recording node, at intervals shorter than the billing period." A report containing a differential consumption value computed against a tariff table is therefore squarely disclosed or at minimum obvious. Ransom independently supplies the "tariffs" data type and multi-supplier tariff handling. The '875 specification's FIG. 2 tariff table adds nothing beyond the routine mapping of unit price to a date/time interval — which is the same interval structure US 5,974,369 already uses for its consumption deltas.


VI. Motivation to combine — the articulated reasons

Under MPEP 2141–2144 and KSR, a rejection must supply a reason with rational underpinning. Five independent rationales apply here:

  1. The patentee's own admissions supply the design incentive. The '875 Background states that deregulation "is driving the need for smart utility distribution grids and smart meters," that a smart meter "is able to negotiate its tariffs with multiple providers," and that provider-specific reporting "results in increased bandwidth and processing needs as well as tamper resistant design complexity, manufacturing costs and maintenance costs for the utility meters." These are the classic KSR "design incentives and other market forces." A PHOSITA seeking to cut per-meter cost and bandwidth would look to move tariff and differential computation off the meter and onto a shared concentrator, and would need the meter message to identify the responsible provider.

  2. The known problem and the known solution were both in the art. US 5,974,369 had already solved "compute the period differential at an intermediate node and forward it (with prices) to the utility for billing." US 2008/0068213 and US 2011/0050456 had already solved "put the meter's identity — and routing-relevant fields — into the RF packet." Combining an aggregation-node architecture with a self-identifying meter packet yields nothing more than the predictable sum of the two.

  3. Simple substitution / improvement of a similar device in the same way. Substituting a modern AMR concentrator/collector (as in WO 2008/086231 or US 2011/0050456) for the '369 recording node is a substitution of one known element for another in the same field, achieving the same result (accumulated consumption available to the utility).

  4. Multi-provider deregulation makes the provider identifier an obvious packet field. Ransom is direct evidence that practitioners in this exact field were designing for data exchange among "Non-Affiliated Entit[ies]... such as a group of competitor utilities." Once one concentrator serves several providers (the '875 FIG. 1 topology), identifying the destination provider in the meter message is a natural, if not unavoidable, consequence.

  5. "Obvious to try" with a finite set of predictable options. Given the recognized need, a PHOSITA would have had a small, enumerable set of choices for where to compute the differential (meter vs. concentrator) and for how to convey routing context (embed provider ID in the meter message vs. maintain a lookup table at the concentrator). The claimed selection — compute at the concentrator; embed both concentrator ID and management-center ID in the meter message — is a predictable one of those options.


VII. Predicted patentee rebuttals and an assessment

Anticipated argument Assessment
US 5,974,369's network "preferably does not include a central processor," so it teaches away from a management center Weak-to-moderate. The same reference makes calculated values "available to other nodes," including for service-provider billing — a functional management center. KSR forecloses the "teaches away" argument where the reference's own disclosure points toward the claimed use.
No reference puts both a destination-concentrator ID and a management-center ID in the meter message The patentee's strongest point on claim 1. It is, however, a narrow difference — one extra data field in a message whose identity/content fields (serial number, consumption, type) were already conventional — and the motivation comes from the admitted deregulated multi-provider environment. The difference is more persuasive as a § 112/§ 101 story than as a § 103 story.
"Index" vs. "differential" language; the meter sends a counter index, not a delta Neutral-to-adverse to the patentee. The specification expressly contemplates both, and US 2008/0068213's IDM already carries differential interval values, so the art covers either form.
Secondary considerations (unexpected results, commercial success, industry praise, licensing) No evidence of record is before me. If the patentee proffers commercial success, it must establish nexus to the claimed features specifically; the specification's own characterization of the concentrator-proxy and PKI layers as known makes nexus difficult for the security and tariff-computation limitations. Licensing/patent-family expansion (US 10,520,332; US 10,982,972; US 11,359,933; US 11,733,061; US 12,158,359) is not itself evidence of non-obviousness absent a nexus showing.

VIII. Bottom line

  • Claims 1 and 10 would be obvious over US 5,974,369 in view of US 2008/0068213 A1 (optionally further in view of US 2011/0050456 A1). The '875 Background's own description of US 5,974,369 functions as an admission that the core compute-and-forward steps were known; the only real gap — a meter message carrying Uid, DCid and Pid — is a conventional multi-field packet design and is squarely motivated by the admitted deregulated multi-provider market.
  • Claims 2 and 11 are obvious over US 5,974,369 alone (price data received and stored at the node; consumption values and associated prices forwarded to the provider for billing), with Ransom corroborating tariff handling across multiple suppliers.
  • Claims 3–6 and 12–15 are obvious over any of the above in further view of US 2005/0131583 A1, which teaches encrypted, signed, authenticatable, non-repudiatable energy data exchanged among competitor utilities, and processing conditioned on validation.
  • Claims 7–9 and 16–18 are obvious in further view of WO 2008/086231 A2 (US 2010/0026517 A1), which discloses reader-initiated consumption requests, endpoint responses, confirming/acknowledgement messages, and reconfiguration commands (clock correction, TOU schedule changes, storage programming), optionally with US 2005/0240540 A1 for over-the-air reconfiguration.
  • The strongest overall attack is a three-reference combination: US 5,974,369 + US 2008/0068213 A1 + US 2005/0131583 A1, augmented as needed by US 2011/0050456 A1 and WO 2008/086231 A2 for the dependent claims.

Confidence and limits. These are analyst opinions based on the reference texts and the patent's own specification, not a legal conclusion. Paragraph-level pinpoint citations should be confirmed against the issued U.S. versions of each reference; I could not verify full text for US 5,079,715, US 6,006,212, US 2005/0240540, or US 2008/0177678 within this session. A formal § 103 rejection should rely on the primary combination only (US 5,974,369 + US 2008/0068213 [+ US 2005/0131583]), since that combination alone reaches claims 1–6 and 10–15 without needing the unverified references.

Generated 9/29/2026, 5:24:38 AM

Extensions

Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.

Log in to generate
Not generated yet. Log in to request this analysis.

Derivative works

Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.

Log in to generate
Not generated yet. Log in to request this analysis.

Keep exploring

Other patents in Energy (E)

See all Energy (E) patents →