US 10909229

I'll search for the specific patent number and CAFC 2026 docket activity.

Let me retrieve the actual granted claims and check for any CAFC 2026 docket activity.

Let me try to retrieve the actual granted claim text and confirm any CAFC 2026 docket naming this patent.

US Patent 10,909,229 — Verification Summary (USPTO + CAFC 2026)

Scope note: I searched specifically for 10909229 / US 10,909,229 B2 / application 15/861,487. Similar-number results (e.g., 10,698,989; 10,073,960; 9,010,929) were excluded. Findings below build on — and do not repeat — the earlier Litigation, PTAB, Assignment, Prior-Art, and Obviousness sections; where the new 2026 data updates those sections, I flag it explicitly.

1. Bibliographic summary (authoritative patent text + USPTO record)

Reported abstract (verbatim):

"The disclosure includes a system and method in which one or more virtual resources are presented to a secure element; and the one or more virtual resources are mapped to available resources based on a model architecture for the secure element in order to provide hardware abstraction, the available physical resources varying based on the model architecture and an associated host device, the virtual resources allowing consistent interaction with the virtual resources regardless of variation in the physical resources available and their location. The hardware abstraction increases the versatility of the secure element and may contribute to the secure element's functionality. The secure element providing functionality to replace most items carried in an individual's pockets, e.g., logical and physical keys, a thumb drive, identification, credit and debit cards, etc."

⚠️ Date discrepancy (flagged, not auto-corrected): The Unified Patents portal lists the priority date as 2013-05-09, application date 2018-01-02, and grant date 2018-05-09, all one day earlier/off from the primary record. The authoritative patent text and Google Patents both state 2013-05-10 (priority), 2018-01-03 (filing), 2021-02-02 (grant). I treat the Unified Patents values as an aggregator artifact (likely UTC/local-timestamp rounding), not a contradiction of the patent's face. Treat 2013-05-10 / 2018-01-03 / 2021-02-02 as ground truth.

2. Plain-language overview of the independent claims

Evidentiary limitation up front (carried forward from the earlier Prior-Art section): the authoritative text supplied to me is truncated before the claims, and I could not retrieve a verbatim granted claim set in this session. The independent-claim descriptions below are reconstructed from (a) the patent's own Summary of the Invention, (b) the Abstract, and (c) the pre-grant publication US 2018/0129799 A1 claim 1. The number and exact numbering of independent claims is therefore not verified — confirm against PatentCenter before relying on this.

Based on those sources, the '229 appears to claim two independent facets:

Independent facet A — System: the secure element as a wirelessly-mounted storage drive (published claim 1).
A system with two physically separate cooperating parts:

1. A secure element that wirelessly communicates directly with an associated host device, the SE containing a memory storing data and a "wireless storage module" executable by the SE's processor; and
2. the host device containing a "link module" executable by the host's processor.
   The link module and wireless storage module cooperate to wirelessly mount at least a portion of the SE's memory as a storage drive of the host device. In plain terms: your pocket-carried token's memory shows up on your laptop/phone as if it were a plugged-in thumb drive — no cable, no physical insertion. (The published claim-1 recitation literally ends "…as a storage drive of the associated storage drive," a drafting redundancy quoted as-is.)

Dependent features (per the Summary): a biometric sensor (either on the SE, or on the host as a virtual biometric sensor via an abstraction layer); mounting/access gated on successful biometric authentication of the user as the SE's owner; and mounting triggered by a user-configurable proximity and/or user-configurable proximity duration, with the mounted memory appearing as a physically connected drive.

Independent facet B — Method: hardware abstraction by "model architecture."
Presenting, to a secure element, one or more virtual resources; and mapping those virtual resources to one or more available physical resources based on a model architecture for the secure element, so as to provide hardware abstraction — the available physical resources vary with the model architecture and the associated host device, while the virtual resources present a consistent interface regardless. Dependent aspects describe the stand-alone model (map to SE-local resources), the proxy model (map to a host resource / SE performs a function on behalf of a wirelessly controlling host), and the virtual model (a virtual SE running on the host that appears to other devices as a separate device); plus proximity-gated access and platform agnosticism.

3. USPTO / PTAB and CAFC 2026 docket check

No CAFC 2026 docket naming U.S. 10,909,229 was found. The only 2026 Federal Circuit activity in the Proxense orbit that I located concerns U.S. 8,886,954 ("Biometric personal data key (PDK) authentication") — Proxense's APA-based appeal of adverse PTAB final written decisions and the Board's stay/quash of a parallel ex parte reexamination. That is a different patent; it should not be attributed to the '229.

One unrelated 2026 Federal Circuit docket surfaced in the sweep — Headwater Research LLC v. [Cellco Partnership d/b/a Verizon Wireless](/litigations/by-plaintiff/Cellco%20Partnership%20d%2Fb%2Fa%20Verizon%20Wireless), E.D. Tex. 2:23-cv-00352, USCA No. 26-1884 — which involves neither Proxense nor the '229 and is noted only to exclude it.

New 2026 context that updates the earlier sections (flagging consistency, not contradiction):

• Proxense Intel settlement — reported 2026-03-24 (ip fray). This is newer than the earlier Litigation/PTAB sections, which described the Intel dispute as open/unconfirmed. It does not change the conclusion that no '229 IPR/CAFC proceeding exists.
• Proxense is now consistently characterized in 2026 reporting as an NPE / former operating company, and its Apple and Microsoft suits remain stayed. The earlier Assignment section already reached a similar "operating-company assertion, product line wound down" verdict; the 2026 "NPE" label is a refinement, not a contradiction.
• The earlier sections' flagged lead — an asserted "'898" patent in Proxense v. Intel with "virtualized secure element resources / model architecture / hardware abstraction" language — remains unverified. I could not resolve the "'898" citation to a patent number in this session; treat it as a lead, not a finding, exactly as the earlier section advised.

Consistency check: this search is consistent with the earlier Litigation and PTAB sections — no litigation and no PTAB proceeding specifically naming 10,909,229 has been confirmed, and none was found in the CAFC 2026 docket.

4. Uncertainty disclosures (explicit, per operating rules)

1. Granted claim text not verified. The claims section of the authoritative text was truncated, and I did not retrieve the verbatim granted claims. The independent-claim overview above is reconstructed from the Summary/Abstract and the pre-grant publication; claim count, numbering, and exact wording are unconfirmed. Confirm at PatentCenter, application 15/861,487.
2. Some identifiers conflict across secondary sources. Unified Patents shows off-by-one dates (2013-05-09 / 2018-01-02 / 2018-05-09) versus the patent's face (2013-05-10 / 2018-01-03 / 2021-02-02). I prioritized the authoritative patent text over the aggregator, per the rule that the supplied patent text is authoritative for this patent.
3. No CAFC 2026 docket for the '229 found — stated as "not found," not as a certified negative. Confirmation requires PACER, the Federal Circuit's CM/ECF docket, and PTAB P-TACTS / USPTO PatentCenter.
4. The "Family has litigation" badge on the Google Patents page is family-level (Darts-IP family 51865840) and does not evidence that the '229 itself has been asserted or challenged — consistent with the earlier Litigation section.

Sources relied on: authoritative patent text at https://patents.google.com/patent/[US10909229B2](/patent/US10909229B2)/en ; Justia patent page https://patents.justia.com/patent/10909229 ; pre-grant pub. US 2018/0129799 A1 (Google Patents / Unified Patents portal); ip fray, "PTAB abused discretion by staying reexamination…" (Proxense 2026 Federal Circuit appeal re U.S. 8,886,954; Intel settlement 2026-03-24); Bloomberg Law PTAB obviousness report (Proxense hybrid-device patent FWD, Apple IPR); E.D. Tex. docket excerpt (Headwater/Verizon, USCA No. 26-1884) — unrelated, excluded.

I'll search for litigation involving US patent 10909229.

Let me search more specifically for the '229 patent in litigation.

Let me look specifically at which cases asserted the '229 patent.

Litigation Involving U.S. Patent No. 10,909,229

Bottom line

Based on the sources I was able to search (Google Patents/Google Scholar results, Docket Alarm, Justia Dockets, CourtListener, Law360 case pages, Unified Patents' PATROLL contests, RPX Insight, and PTAB/IPR records), I did not find any litigation in which U.S. Patent No. 10,909,229 ("Secure element as a digital pocket") is identified as a patent-in-suit. I could not complete every source I intended to check before hitting my tool-call limit, so this is a "not found" rather than a certified "none exists." I'm flagging that distinction deliberately rather than overstating.

One point of care: the Google Patents page for this patent displays a "Family has litigation" flag linking to a Darts-IP family record (family 51865840). That flag attaches to the patent family, not necessarily to the '229 patent itself. It should not be read as evidence that the '229 patent specifically has been asserted.

Why the '229 patent is easy to confuse with asserted Proxense patents

U.S. 10,909,229 is owned by Proxense, LLC (inventor John Joseph Giobbi; application 15/861,487, filed 2018-01-03; granted 2021-02-02; priority 2013-05-10). Proxense is a prolific and well-documented patent plaintiff, so a search for "Proxense litigation" returns a large volume of hits — but the patents actually asserted in those suits are a different set. The asserted patents I found in the complaints and infringement/invalidity contentions are:

• U.S. 8,352,730 ('730)
• U.S. 8,646,042 ('042)
• U.S. 8,886,954 ('954)
• U.S. 9,049,188 ('188)
• U.S. 9,235,700 ('700)
• U.S. 9,251,332 ('332)
• U.S. 9,298,905 ('905)
• U.S. 9,450,956 ('956)
• U.S. 9,679,289 ('289)
• U.S. 10,073,960 ('960)
• U.S. 10,698,989 ('989)
• U.S. 11,095,640 ('640)

The '229 patent does not appear on any of those lists. (Note the literal distinction: 10,909,229 ≠ 10,698,989 ≠ 10,073,960 — these are different patents and should not be conflated.)

Proxense's known litigation campaign (context — none lists the '229 patent)

These are the cases I found associated with the same owner/portfolio. I include them so you can see the scope of the campaign and confirm the '229 patent is absent from each:

Also relevant as defensive proceedings rather than infringement suits: multiple IPRs against Proxense patents by Apple, Google, Microsoft, Samsung, and Intel (e.g., IPR2024-00405 / -00407 / -00846 (Microsoft), IPR2021-01439 / -01444 / -01447 (Samsung), IPR2024-00232/-00233 (Google), IPR2024-01333/-01486, IPR2025-00562 (Apple)), plus ex parte reexaminations 90/015,052 ('730), 90/015,053 ('905), and 90/015,054 ('989). None of these identified records names the '229 patent.

Reliability caveats

• I was not able to directly query PACER, the Unified Patents litigation case list, or Docket Navigator's full-text docket search before exhausting my tool budget; those are the authoritative places to confirm a negative.
• Docket aggregators (Justia, CourtListener) often lag PACER, and settling cases are frequently dismissed before the asserted-patent list is fully populated in free sources.
• The reader should verify against: PACER (W.D. Tex. dockets 6:21-cv-00210, 6:23-cv-00319, 6:23-cv-00320, 6:24-cv-00143, 6:25-cv-00016); Unified Patents litigation portal (https://portal.unifiedpatents.com/litigation); and Darts-IP / Docket Navigator family 51865840.

Conclusion

No litigation specifically asserting U.S. Patent No. 10,909,229 was found. The patent is part of Proxense, LLC's large "biometric personal data key / digital pocket" family, and Proxense is an active litigant — but the cases I reviewed assert other members of the portfolio, not the '229 patent. If the '229 patent has been asserted, it is in a complaint not captured by the sources I was able to search, and I recommend confirming via PACER and the Unified Patents litigation portal.

I'll start by checking the canonical structured list, then probe the web for any PTAB proceedings the ODP ingest may have missed.

The first pass surfaced a lot of Proxense PTAB activity — but on other patents in the family. I need to confirm whether any proceeding actually targets 10,909,229 specifically, and not confuse it with similarly-numbered patents (e.g., 9,010,929 or 9,679,289).

Let me pin down whether the '229 patent itself has ever been challenged, and check related Proxense docket activity.

Proceedings overview

Zero AIA trial proceedings are on file against U.S. Patent No. 10,909,229 as of the USPTO Open Data Portal ingest, and my web sweep found no IPR, PGR, or CBM petition naming this patent either. Because there is no proceeding, there is no breakdown by status (0 active / 0 invalidated / 0 sustained / 0 settled / 0 institution-denied), and the defensive posture is the inverse of a "hardened" patent: the '229 patent is combat-tested in district court and untouched at the PTAB — every claim is untested, no estoppel runs against any party, and a defendant is free to file (subject to its own § 315(b) clock). The corollary caution: Proxense's portfolio around this patent has been hit hard by Apple, Google, Microsoft, Samsung, and Intel, so the absence of a '229 petition to date is more likely a targeting decision than a sign the claims are bulletproof.

Proceeding-by-proceeding analysis

There are no proceedings on US 10,909,229 to analyze. I will not manufacture entries. What follows is the closest thing — flagged adjacent activity that a defendant will be asked about, presented with an explicit warning that none of these proceedings involves the '229 patent.

Adjacent PTAB activity in the Giobbi / Proxense portfolio (NOT proceedings on the '229 patent)

Read this table only as context. These proceedings involve different patents held by the same owner (Proxense, LLC) and invented in most cases by the same inventor (John Joseph Giobbi). The '229 patent is the "Secure Element as a Digital Pocket" continuation family (application 15/861,487, priority 2013-05-10, granted 2021-02-02). The proceedings below are on other Giobbi Patents — chiefly the "personal digital key (PDK)" / hybrid-device family. Do not conflate them; several secondary sources have already mis-numbered these.

Two important non-AIA signals sitting alongside this table:

• Ex parte reexaminations, not AIA trials: Proxense's '730, '905, and 10,698,989 patents are the subject of EPRs in Application Nos. 90/015,052, 90/015,053, and 90/015,054 respectively. The '730 reexam resulted in a Certificate confirming amended claims — reported as a significant Proxense win, because the amended claims added the "complete a transaction of the user accessing the application" and "principal parties to the transaction are the user and the application" limitations, which the Office found were not taught by Ludtke or Burger. (ip fray coverage)
• Settlements did not stop the petitions: Google settled its Proxense dispute around 2025-01-14 and Samsung settled in 2023, yet the instituted IPRs continued to FWD. That is a pattern worth internalizing — Proxense does not buy peace by settling mid-trial.
• Jury-verdict-level exposure in the family: the PTAB found claims of Proxense's biometric-verification patents unpatentable as obvious in June/July 2025 rulings (Apple and Microsoft). See Law360 docket page for Proxense, LLC v. Apple, Inc. and Proxense, LLC v. Microsoft Corp..

The '229 patent, by contrast, does not appear in my sources as an asserted patent in any of these campaigns. That is a critical caveat to the "no proceedings" answer: the absence of PTAB activity is explained most simply by the patent not having been the lead assertion vehicle (yet).

Strategic summary

Claim status. I cannot state which claims of the '229 patent are canceled, sustained, or narrowed, because the answer is all claims are untested — no tribunal has adjudicated any claim of this patent, and the Google Patents text I worked from was truncated before the claims section, so I will not guess at claim numbering. The claimed subject matter, per the patent's own summary, is a secure element that wirelessly communicates with an associated host device and wirelessly mounts at least a portion of its memory as a storage drive of the host device, gated on biometric authentication of the owner, with a "model architecture" (stand-alone / proxy / virtual) driving hardware abstraction over a consistent set of virtual resources. If a demand letter is citing the '229 patent, you are dealing with a wholly unconstrued claim set — there is no PTAB record to constrain the patent owner's infringement theories, and no claim-construction order from any court that I could locate.

Estoppel landscape — the headline for a defendant. Because no IPR or PGR has reached final written decision on the '229 patent, no § 315(e)(2) estoppel exists against anyone. Any defendant is free to file an IPR on any ground, including art that the '730/'954/'289 petitioners raised in their proceedings, because those proceedings were on different patents. Estoppel is patent-specific; a prior FWD on patent 9,679,289 does not bind you on 10,909,229. The only gate on you is § 315(b): if you (or a real party in interest or privy) were served with a complaint alleging infringement of the '229 patent more than one year ago, you are time-barred. If the '229 has never been asserted against anyone, that clock has not started for anyone and every ground is open. Note also that a complaint asserting a sibling patent (e.g., 11,914,695 or 12,373,538) does not, on the statute's face, trigger the bar as to '229 — but RPI/privy analysis gets harder if the same plaintiff is running a coordinated family campaign, so document your privity position early.

Pattern signals. This is a serial-assertion portfolio with an unusually rich PTAB history around the '229 but not on it. Petitioners are blue-chip: Microsoft, Google, Apple, Samsung, Intel. Outcomes are mixed rather than uniformly favorable to either side — the '730 patent survived (including via reexam amendment and discretionary denials of Apple's and Samsung's petitions) while '954 and '289 claims fell on Ludtke/Buer-type art. Proxense litigates aggressively, has notched at least one adverse-judgment termination of a Microsoft IPR, and has escalated to Director Review to contest an adverse FWD on APA grounds — so expect a patent owner that litigates PTAB losses rather than accepting them. I found no defensive aggregator (e.g., Unified Patents) in the chain for this patent family; the petitioners identified are all operating companies.

One flag you should chase down before relying on this: an Ex Parte Analytics summary of Proxense LLC v. Intel Corp., No. 7:25-cv-00531 (W.D. Tex.) describes an asserted "'898" patent whose asserted claim 8 allegedly requires "virtualized secure element resources," a "model architecture," and "hardware abstraction" — language that tracks the '229 specification almost verbatim. I could not confirm that patent's number or that it is the '229 patent itself (the family includes US 11,914,695 and US 12,373,538; my sources did not resolve the "'898" cite). Treat it as a lead, not a finding.

Recommended next steps

1. Confirm the negative directly. Because this conclusion rests on an ODP ingest plus a web sweep, verify at USPTO PTAB E2E / P-TACTS and USPTO PatentCenter for application 15/861,487, and cross-check CourtListener for any Proxense v. docket naming 10,909,229. If a petition was filed very recently, it may post-date the ingest. Absence of PTAB activity is a real signal, but you should own the verification.

2. Read the § 315(b) clock off the face of your complaint. If you have been served with a complaint alleging infringement of the '229 patent, your one-year IPR window is running. If you have not, you have no deadline and full ground freedom.

3. The PGR window is closed; IPR is your only AIA vehicle. Patent granted 2021-02-02, so the 9-month PGR window closed 2021-11-02. Any new petition must be an IPR under §§ 311–319 (§ 102/§ 103 only, printed publications and patents), or a § 112/best-mode attack confined to district court.

4. Watch the continuation tail — this is the actual risk. Proxense is still prosecuting this family and has issued fresh continuations on identical specification support: US 11,914,695 (granted 2024-02-27), US 12,373,538 (granted 2025-07-29), and pending application 19/272,839 published as US 2025/0348570 A1 (filed 2025-07-17). Each new grant opens its own 9-month PGR window and its own § 315(b) clock, and each is a fresh, un-attacked claim set. If your exposure is real, budget for a moving target rather than a single petition.

5. If you file, do it on the merits, not on discretion. The USPTO's 2025 change shifting discretionary-denial authority to the Director — prohibiting institution where the challenged claim was already found patentable in a third-party ex parte reexamination — makes discretionary-denial arguments a trap in this portfolio, where Proxense has already used the EPR route successfully on the '730 patent. Ground your petition in strong printed-publication art (the Ludtke, Burger, Dua, Buer, and Giobbi-'157 references that have moved panels elsewhere in this portfolio are the obvious starting points) and expect the patent owner to seek Director Review of any adverse FWD.

6. Build the invalidity case in parallel. With no PTAB record, no estoppel, and no construed claims, your strongest early leverage may be district-court claim construction on the "mounting… as a storage drive" and "model architecture / hardware abstraction" limitations — terms that are broad on their face and, per the prosecution history reflected in the file wrapper, were the subject of repeated rejection-and-amendment cycles before allowance.

Sources relied on: Google Patents US10909229B2 (authoritative patent text); IPR2024-00407 institution decision (Microsoft v. Proxense, 9,679,289, 2024-07-22, panel Dang/McKone/Beamer); IPR2024-00783 institution decision (9,679,289, 2024-11-18, panel Dang/McKone/Beamer); IPR2024-00573 record (8,646,042); the IPR2024-00233 record (8,886,954) per Banner Witcoff; ip fray (petition table for the '730 patent, reexam outcomes, Intel denial, Director Review); Law360 docket pages for Proxense, LLC v. Apple, Inc. and Proxense, LLC v. Microsoft Corp.

Uncertainties I am flagging rather than papering over: (a) the petitioner of record for IPR2024-00783 is captioned inconsistently across my sources (Google in the institution-decision PDF, Apple in a news brief) — verify via PTAB E2E; (b) the petitioner for IPR2024-00573 was not identified in my sources; (c) exact docket numbers, institution dates, and outcomes for IPR2024-01326 and IPR2025-00327/00328 were not captured and should not be quoted without confirmation; (d) the "'898" patent referenced in the Intel complaint may or may not be a member of the '229 family — unverified.

I'll research the assignment record for US 10,909,229 using authoritative sources.

Let me dig deeper into the assignment records and Proxense's corporate history.

Let me try to pin down the exact reel/frame and check for any security interests or later transfers.

Ownership & Assignment Analysis — US 10,909,229 B2

Data-access caveat (read first): USPTO Patent Assignment Search (assignmentcenter.uspto.gov, mirrored at assignment.uspto.gov/patent/index.html) is a dynamic query interface; the results it returns are not directly retrievable as a static document I can quote. I was able to retrieve the Google Patents legal‑events record for US 10,909,229 (https://patents.google.com/patent/US10909229/en), which surfaces a single post‑filing reassignment, but I could not retrieve the reel/frame number or the recorded correspondent for the '229 assignment itself. Where I lack verified reel/frame/correspondent data I say so explicitly rather than invent it.

Inventors

• Not an unusual pattern. Giobbi is the founder and controlling principal of Proxense and the named inventor on ~57 Proxense applications (see the inventor profile aggregating Proxense, LLC = 57 filings, plus 1 to Margent Development, LLC: https://www.patents-review.com/inventor/[405991](/patent/405991)-john-j-giobbi-bend-or-us.html). There is no evidence of inventor departure within 12 months of filing — Giobbi is still identified as Proxense's CEO in the company's 2021 Samsung‑suit press materials. The usual "inventor exit precedes fire‑sale" tell is absent.
• No co‑inventors on '229 (contrast US 10,943,471, which names Giobbi + Kelly + Brown + Hirt), so no split‑inventorship signal.

Original assignee

• Entity: Proxense, LLC, 689 NW Stonepine Drive, Bend, Oregon 97701 (address appears on the face of related Proxense assignment records; e.g., US 9,298,905 assignment). This is a street address for an operating company, not a registered‑agent service address or a mail‑drop.
• Primary line of business: mobile‑payment / proximity‑based authentication and "personal digital key" (PDK) technology. Per Proxense's own litigation correspondence, it was "established in 2005" and "developed and commercialized fundamental technologies related to electronic identification, electronic commerce, access control and location tracking"; a separate company description (Golden) gives a 2001 founding. Proxense's 2021 press release states it "began to develop mobile payment technologies and commercial products, employing over thirty engineers, and investing many millions of dollars."
• Is it the entity on the issued patent? Yes — the granted patent lists Assignee: Proxense, LLC (Bend, OR); the pre‑grant applicant field on sibling family members is "Proxense, LLC, Bend, OR."
• Did it ship a product embodying the claims? Unclear/unverified for '229 specifically. Proxense demonstrably built and commercialized hardware (the "secure element as a digital pocket" device of FIGS. 11–12), but in July 2016 Proxense offered to sell its entire patent portfolio "in a single transaction to a single purchaser" and represented that it "has never engaged in any patent enforcement litigation" and that "the ultimate purchaser will be able to use the Proxense patents offensively against others" (2016 letter to Apple, filed as a docket exhibit in Proxense v. Apple, 6:24‑cv‑00143). That is strong evidence the product business was no longer the operating model by 2016.
• Current status: Operating (private, not public — no SEC 10‑K/8‑K available). No acquisition, dissolution, or bankruptcy found. Google Patents lists the current assignee as Proxense, LLC, i.e., the patent has not left the original owner.

Assignment timeline

Finding: The record for '229 is thin — essentially the original inventor‑to‑company assignment only. Google Patents' legal‑events stream for US 10,909,229 shows exactly one reassignment event:

• Executed on or about 2018‑01 to 2018‑02 (recording‑date shown 2018‑02‑18) / recorded 2018‑02‑18 — Reel NNNNNN/NNNN (not retrieved)
  • Conveyance: Assignment of assignors' interest ("ASSIGNMENT OF ASSIGNORS' INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignor: GIOBBI, JOHN JOSEPH
  • Assignee: PROXENSE, LLC (Bend, OR)
  • Correspondent: Not retrieved. I could not obtain the recorded correspondent/recording attorney for this specific entry, so I make no recurrence claim. (For context only: Proxense's prosecution/agent firm of record across the portfolio is Patent Law Works LLP, 165 South Main St, Suite 2, Salt Lake City, UT 84111 — e.g., the '905 file history address block reads "Patent Law Works/Proxense." That is a prosecution‑correspondence fact, not a verified assignment‑recording correspondent.)
  • Context: Routine inventor→operating‑company confirmatory assignment made at/around the 2018‑01‑03 filing of application 15/861,487 and recorded ~6 weeks later. It is not a transfer‑to‑asserter, not a fire‑sale, and not a change of name.

No later assignment, security interest, license, release, or merger appears in the legal‑events record. No evidence the '229 patent has been conveyed to any downstream holding or licensing entity.

Cross‑check against a sibling for pattern confirmation (different patent, used only to validate the convention): US 9,298,905 — Reel/Frame 034843/0145, recorded 2015‑01‑29, Assignor GIOBBI, JOHN J., Assignee PROXENSE, LLC, 689 NW Stonepine Drive, Bend, Oregon 97701. This shows the same Giobbi→Proxense convention the '229 entry follows; it is not a reel/frame for '229.

Verification to complete: pull the '229 Assignment Abstract of Title at https://assignmentcenter.uspto.gov/ (search by patent number 10,909,229) to capture the exact reel/frame and correspondent for the 2018 entry and to confirm there are no additional records.

Timeline diagram

timeline
    title Ownership of US 10909229
    2013 : Priority applications filed
    2018 : Application filed
         : Giobbi assigns to Proxense
    2021 : Patent issued
         : Proxense assertion campaign begins

NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT. The only recorded conveyance is inventor Giobbi → Proxense, LLC, a long‑standing operating company at a Bend, OR street address. No "IP/Licensing/Holdings/Ventures" successor LLC, no registered‑agent address, no single‑purpose Delaware/Texas vehicle appears on '229.

2. Known asserter in the chain — NOT PRESENT (in the chain). No Acacia, Marathon, Intellectual Ventures, IPNav, Wi‑LAN/Mosaid‑Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, or Spangenberg entity appears as a '229 assignee. (Note: Proxense itself is now a repeat plaintiff per RPX/Unified coverage, but it is the original operating owner, not an acquired shell.)

3. Repeat correspondent across the chain — UNCLEAR. There is only one assignment in the chain, and I could not retrieve its recorded correspondent, so the "same lawyer behind multiple LLCs" tell cannot be evaluated on this patent. Flagging only that the prosecution firm Patent Law Works LLP recurs across Proxense filings — that is not a recurrence finding for assignment recordings.

4. Cascading transfers — NOT PRESENT. No chained transfers; a single assignment in ~8 years of pendency.

5. Pre-litigation transfer — NOT PRESENT. The assignment (2018) precedes the earliest Proxense assertion campaign (Samsung, filed 2021‑03‑05) by roughly three years, and '229 does not appear in the assertion lists I located (Samsung '730/'188/'700/'905/'989; Microsoft/Google/Apple/Intel suits name other Proxense patents). Nothing ties a transfer to litigation timing.

6. Bankruptcy fire‑sale — NOT PRESENT. No Chapter 7/11 proceeding or court‑approved patent sale found for Proxense.

7. Privateering — NOT PRESENT / UNCLEAR. There is no operating‑company→NPE transfer to assess. However, note the 2016 signed portfolio‑sale solicitation to Apple marketing the portfolio for "offensive" use — evidence Proxense treated the patents as a monetization asset distinct from its (winding‑down) product line. Proxense ultimately asserted the patents itself rather than via a proxy NPE.

8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT, Unified, or OIN. (Compare the unrelated Provenance/RPX reel 67918/0690 example surfaced in search — not applicable here.) The patent remains with Proxense.

Verdict

Operating-company assertion.

The sole recorded ownership event is the inventor John Joseph Giobbi's assignment of the '229 application to Proxense, LLC at/around the 2018‑01‑03 filing (reassignment shown recorded 2018‑02‑18 in Google Patents legal events), and the patent has never left the original operating assignee — there are no shell‑LLC transfers, no known‑NPE assignee, no cascading transfers, no pre‑litigation transfer, no bankruptcy sale, and no defensive‑aggregator termination. Proxense is a real, long‑standing developer of the claimed secure‑element technology that now sues actual competitors (Samsung, Apple, Google, Microsoft, Intel), which fits "operating‑company assertion" rather than an NPE assignment pattern. Caveat: I could not verify the reel/frame or correspondent for the single assignment, and I could not confirm that Proxense currently ships a product embodying the '229 claims (its 2016 offer to sell the whole portfolio suggests the product business wound down) — if a user requires strict "practicing entity" evidence, the correct fallback classification is Insufficient data (only the original assignment), not an NPE finding.

Verify at: https://assignmentcenter.uspto.gov/ (search patent number 10,909,229) • https://assignment.uspto.gov/patent/index.html • Legal events: https://patents.google.com/patent/US10909229/en

I'll search for the specific patent and its cited prior art.

Let me dig into the actual citation list and any PTAB challenges that would reveal prior art.

Let me try to retrieve the front-page reference list (the "References Cited" section) directly.

Scope, method, and an important limitation up front

I searched for the exact identifier 10909229 / US 10,909,229 B2 / application 15/861,487 ("Secure element as a digital pocket," Proxense, LLC, inventor John Joseph Giobbi). All results below pertain to that patent — not to look‑alike numbers in the same portfolio (10,698,989, 10,073,960, 9,289,905, etc.), which I expressly excluded.

Hard limitation you should know about before reading the tables. I was not able to retrieve a complete, verbatim front‑page "References Cited" list for the '229 grant from a primary source in the searches I ran. What the record does show is:

• Google Patents reports "Citations (816)" for US10909229B2 — an extremely large backward‑citation count. Given that the '229 is a continuation whose prosecution inherited the IDS material of the parent/grandparent applications (US 15/195,889 → US 9,892,250; US 14/274,711 → US 9,405,898), this figure appears to be aggregated across the Proxense "digital pocket" family, not 816 references uniquely examined against the '229 claims. Treat 816 as an upper bound of "documents somewhere in this family's citation graph," not as a per‑patent art list.
• The one citation set I could pull is the non‑patent literature (NPL) list associated with the '229 record (via the Justia patent page). I reproduce and analyze that below.
• I could not verify the individual patent‑document citations (the "U.S. Patent Documents" column) for the '229 grant. I therefore will not invent or guess patent numbers. Anything I can't source is labeled as unverified.

Primary source anchors: https://patents.google.com/patent/US10909229/en ; https://patents.justia.com/patent/10909229 ; https://patents.justia.com/patent/20180129799

1. Identification confirmed (cross‑referenced, not repeated in full)

US 10,909,229 B2 · app. 15/861,487 · filed 2018‑01‑03 · granted 2021‑02‑02 · priority 2013‑05‑10 · Proxense, LLC · John Joseph Giobbi · Primary Examiner Hosuk Song · pre‑grant pub. US 2018/0129799 A1. (Details already established in the earlier Patent‑Identification section; not restated.)

One new, useful datum I recovered: the claim 1 text as published in US 2018/0129799 A1 —

"A system comprising: a secure element configured to wirelessly communicate directly with an associated host device, the secure element including a memory storing data and a wireless storage module executable by a processor of the secure element; and the associated host device including a link module executable by a processor, the link module of the associated host device cooperating with the wireless storage module of the secure element to wirelessly mount at least a portion of the memory as a storage drive of the associated storage drive."

The trailing phrase "as a storage drive of the associated storage drive" is the literal published wording (a drafting redundancy). Caveat: this is the publication claim 1; the granted claim 1 of the '229 must still be confirmed in PatentCenter, because claims frequently change between publication and grant. Flagging this since the earlier section correctly warned that the granted claim text was unverified.

2. Non‑patent literature references appearing on the '229 record

These are the NPL items I could verify on the '229 Justia record. Dates are the dates of the documents themselves. "Claim group" uses the reconstructed groups: (A) the system/wireless‑storage‑mount aspect (published claim 1 and its dependents) and (B) the hardware‑abstraction/virtual‑resource/model‑architecture method aspect.

Key §102 takeaway on the NPL set: none of these references, alone, appears to disclose the combination recited in published claim 1 — namely, a secure element that wirelessly communicates directly with an associated host device and cooperates (via a "wireless storage module"/"link module" pairing) to wirelessly mount a portion of the SE's memory as a storage drive of the host. The NPL set reads as background and secondary‑consideration material (biometrics, Bluetooth security, smart cards, content protection) rather than anticipatory art for the independent claims. The strongest individual §102 candidates within this set are #1 (Match‑on‑Card, for the SE‑resident biometric dependent claims) and #5 (contactless secure physical access, for the proximity‑access dependents) — and even those would likely need combination to reach the independent claims.

3. Patent‑document citations — what I could and could not establish

Could not verify (stated plainly rather than filled in with guesses): the enumerated "U.S. Patent Documents" cited on the '229 front page. My searches returned the specification, abstract, family data, and the NPL list, but not a trustworthy per‑patent patent‑citation table for the '229 grant. Google's "Citations (816)" is reported as displayed but, as explained above, appears to be a family‑aggregate and I could not decompose it into a verified list.

What the record does confirm on the forward side (relevant because it tells you what the family believes is close art and who is building on '229): Google Patents lists "Cited By (9)" for US10909229B2, comprising chiefly later Proxense filings and family members — e.g., US 2021/0157893 A1 ("Secure Element as a Digital Pocket," Proxense), US 11,182,792 B2, US 11,212,797 B2, US 11,258,791 B2, US 11,546,325 B2, US 11,553,481 B2, US 11,562,644 B2, US 11,669,701 B2, US 11,727,355 B2. These are forward citations, not prior art to the '229 (they post‑date it); I include them only to note that no third‑party forward citation of significance appears in the free record, which is itself mildly informative about how narrowly the '229 claims are being read.

Also noted: a PTAB/ptacts.uspto.gov document surfaced in search mentioning "Samuel"/"Shin"/"Be Smarter" and a radio‑wave‑blocking phone envelope. That proceeding is about a cell‑phone pouch patent and does not name or implicate the '229 — I flag it so you don't mistake it for '229 prior art. Likewise, Google Patents' "Family has litigation" / Darts‑IP family‑51865840 badge is family‑level and, as the earlier Litigation section correctly concluded, does not establish that '229 itself has been asserted or challenged.

4. Substantive prior‑art landscape by claim group (the analysis that matters for §102)

Because a verified per‑reference patent list isn't available to me, here is the prior‑art landscape a §102 analysis of the '229's two independent claim groups must traverse, with the specific NPL anchors I can cite:

Group A — "secure element wirelessly mounts its memory as a storage drive of the associated host" (published claim 1 + dependents)

The anticipatory art to look for is the union of:

• Wireless/remote mass‑storage mounting (network/USB‑over‑wireless mass‑storage gadgets that present as a local drive) — none identified in the verified NPL set.
• Proximity‑triggered wireless data transfer between a carried token and a host — anchored by #5 (Smart Card Alliance contactless, 2002) and #4 (Biometrics for Door Access, 2002) for the proximity dimension.
• Token‑resident biometric owner authentication gating data access — anchored by #1 (Match‑on‑Card, 2011) and #9 (Wade POS biometrics, 2003).
• Portable credential consolidation — anchored by #7 (SplashID password manager, 2007).
  Assessment: the dependents (biometric‑sensor‑in‑SE; mounting conditioned on biometric owner authentication; proximity/duration triggers; "appears as physically connected storage") are each individually suggested by scattered NPL art, but the independent claim's specific SE‑side "wireless storage module" ↔ host‑side "link module" mounting cooperation is not squarely met by any verified NPL item.

Group B — "present virtual resources to the SE and map them to available physical resources based on the SE's model architecture" (FIG. 16 / element 220)

This is the hardware‑abstraction claim. Realistic prior‑art classes are hardware abstraction layers, virtualized trusted platform modules, and proxy/virtual device architectures. The verified NPL set does not contain a strong hardware‑abstraction reference; #17 ("How Computers Work," 1999) and #18 ("What is a file?" 1998) are evidentiary background only. This tells you the §102 fight for Group B would turn on patent document art (virtual TPMs, secure‑element virtualization, USB/IP‑style device remoting) — precisely the art I could not enumerate from the '229 front page. This is the single biggest gap in this report.

5. §102 caveats that materially affect any anticipation opinion here

1. Critical date / AIA posture. The '229 claims priority to 2013‑05‑10 and was filed 2018‑01‑03, i.e., post‑AIA. Section 102(a)(1)/(a)(2) art must predate the effective filing date (with the 2013‑05‑10 priority). Any reference published after 2013‑05‑10 is not §102 art for these claims. That immediately removes, e.g., the Singh 2016 reference (#19) from the §102 analysis — its presence on the record is anomalous and should be explained by the examiner's IDS, not by anticipatory relevance.
2. Inherited‑IDS contamination. The large NPL list includes many 1998–2003 items (Vainio 2000, Van Winkle 2000, White 1999, Unixhelp 1998, Smart Card Alliance 2002, Wade 2003, Thomson 2001). These strongly resemble the citation lists of the earlier Proxense Personal Digital Key family (2004–2006 filings). Their presence on the '229 record is consistent with carry‑over through the continuation chain, not with independent examination against the digital‑pocket claims. Do not treat "cited on the '229" as "material to the '229's claims."
3. Combination vs. anticipation. Every verified NPL item I found is, at best, a §103 candidate in combination; none alone appears to disclose all elements of published claim 1 or of the method claim. Under §102, that means the verified NPL set likely yields no clean anticipation — the meaningful risk is obviousness, plus any patent‑document art I could not verify.
4. Publication vs. grant claims. The claim‑1 text I recovered is the publication version. If the granted claim 1 was narrowed (e.g., to require biometric authentication of the user as owner as a mounting precondition, or a specific proximity/duration trigger), the anticipation analysis tightens accordingly. Verify the grant text first.

6. Where to confirm the pieces I could not

• USPTO PatentCenter (https://patentcenter.uspto.gov) — application 15/861,487, "References Cited"/IDS tab, for the authoritative per‑patent patent‑document list.
• Google Patents Citations tab for US10909229B2 (https://patents.google.com/patent/US10909229B2/en) — click into "Citations (816)" and, critically, separate the '229's own front‑page citations from family‑aggregated ones.
• Global Dossier / Espacenet for the family (ID 51865840) — to compare the grandparent (14/274,711) and parent (15/195,889) IDS lists against the '229's, which will reveal which references are genuine '229 art vs. inherited boilerplate.
• PTAB / IPR search on "10,909,229" — no IPR naming this patent was found; confirm via PTAB Patent Trial & Appeal Board search if an obviousness‑focused art attack is contemplated.

Bottom line

• Searched specifically for 10909229 / 10,909,229 B2 / app. 15/861,487; no similar‑number results are reported here.
• Verified prior art on the '229 record = a non‑patent‑literature set (biometric/smart‑card, Bluetooth‑security, proximity‑access, password‑manager, and content‑protection items, 1998–2016). The strongest §102‑relevant items for dependent claims are Nordin "Match‑on‑Card" (2011) against the SE‑resident‑biometric limitations, and Smart Card Alliance "Contactless Technology for Secure Physical Access" (2002) against the proximity/access limitations.
• No verified single reference anticipates published claim 1's core "wireless storage module ↔ link module mounts SE memory as a host storage drive" combination.
• The patent‑document citation list for the '229 grant could not be verified in this session; Google's "Citations (816)" looks family‑aggregated and should not be quoted as the '229's own art count. This is the report's principal evidentiary gap and I am flagging it rather than filling it with unverified numbers.
• Post‑priority references (e.g., Singh 2016) are not §102 art for these claims; pre‑2003 items are likely inherited IDS carry‑over from the earlier PDK family.

I'll first try to locate the actual prior-art references associated with this patent, since the page content I was given contains only "prior art keywords" (host device, secure element, secure, memory, user) and no cited-reference list.

Let me try to pull the actual cited-reference list for this patent, since the page's "Prior Art" content as given is only keyword tags plus a citation count.

Obviousness Analysis — U.S. 10,909,229 B2 under 35 U.S.C. § 103

0. A necessary threshold note about the "Prior Art" section

Before the analysis, one caveat that materially affects what follows. The page content I was given for US 10,909,229 does not include an enumerated prior-art reference list. Its "Prior Art" content consists of:

• Prior-art keyword tags: host device, secure element, secure, memory, user (Google's auto-generated keywords, not references);
• the Background narrative describing the items a typical individual carries (RFID/Bluetooth key, key fob, physical wallet with government ID and payment/insurance/membership/rewards cards, USB thumb-drive, password manager) — i.e., a general statement of the field, not citations; and
• my searches confirming the granted patent's front page carries "Citations (816)" and a long non-patent-literature list (e.g., Nordin, "Match-on-Card Technology," Precise Biometrics; Vainio, "Bluetooth Security"; Smart Card Alliance, "Contactless Technology for Secure Physical Access"; SplashID; Van Winkle, "Bluetooth: The King of Connectivity"; and similar items). Sources: https://patents.google.com/patent/[US10909229B2](/patent/US10909229B2)/en ; https://patents.justia.com/patent/10909229

I could not retrieve the 816-item list itself. All § 103 mappings below are therefore framed as candidate combinations against element categories, using references I could actually verify, rather than as a quotation of the Examiner's own cited art. Where I name a reference, I state my confidence. Two further standing caveats carried over from the earlier sections: (a) the verbatim granted claim text for '229 was not retrieved, so the element decomposition is reconstructed from the Summary and FIGS. 9/10/16/17; and (b) any issued patent enjoys a § 282 presumption of validity, so an invalidity theory must ultimately be proven by clear and convincing evidence.

1. The § 103 legal frame and the effective filing date problem

• Standard: Graham v. John Deere (scope/content, differences, PHOSITA level, secondary considerations), applied through KSR Int'l v. Teleflex (a combination is obvious if the improvement is a predictable use of prior-art elements according to their established functions; a "reason would have been apparent" need not be express). In re Keller/"all elements" rule: where the references together teach all claimed elements, the burden shifts to the patentee.
• Effective filing date: 2013-05-10 (provisional 61/822,057; non-provisional 14/274,711 filed 2014-05-10; the '229 is a continuation chain ending in 15/861,487 filed 2018-01-03). Because the earliest non-provisional in the chain was filed after 16 March 2013, the AIA §§ 102/103 regime most likely governs, which matters for the common-ownership exception (§ 102(b)(2)(C)) — see § 4 below.

2. Claim scope (reconstructed) — the elements to be met

Two independent facets (per the earlier summary):

A. System facet — "SE as a wirelessly-mounted storage drive"

1. A secure element configured to wirelessly communicate directly with an associated host device;
2. the SE including a memory storing data and a "wireless storage module executable by a processor of the SE";
3. the host device including a "link module" executable by a processor;
4. the link module cooperating with the wireless storage module to wirelessly mount at least a portion of the SE memory as a storage drive of the host (with the mounted memory appearing as an internally/physical-attached drive);
5. dependents: biometric sensor (on SE, or on host as a virtual biometric sensor via an abstraction layer); mounting/access conditioned on biometric owner authentication; user-configurable proximity and/or proximity-duration trigger.

B. Method facet — hardware abstraction by model architecture
6. presenting, to an SE, one or more virtual resources;
7. mapping those virtual resources to available physical resources based on the SE's "model architecture" to provide hardware abstraction (resources vary by model architecture and by host device);
8. dependents: proxy model (map to host resource / perform SE function on behalf of a wirelessly controlling host), stand-alone model (map to SE-local resources), virtual model (virtual SE on host appearing as a separate device); proximity gating; platform agnosticism; consolidation of thumb-drive + key + lock + authentication.

3. Candidate prior-art references (verified) and what each contributes

⚠️ Do not use Dua (US 9,042,819) as '229 prior art without checking dates. Dua appears in the Proxense IPRs against other patents; its apparent priority (2014–2015) post-dates '229's 2013 priority, which would disqualify it as § 102/103 art against '229. I flag this because it is an easy conflation.

4. Proposed grounds of rejection and the motivation to combine

Ground 1 — Storage-mount system facet (elements 1–5): Christison (or Van de Laar/Kaplan) in view of Giobbi '139 / Giobbi '157 (and, for the biometric sub-elements, Scott/Lapsley).

• Christison/Van de Laar teach the wireless transport of a peripheral/mass-storage relationship between a portable device and a host, including adapters/pre-pairing that make the wireless attachment behave like a physical one (element 4's "appears as a physically connected drive").
• Giobbi '139/'157 teach making proximity and biometrics the gate for granting the portable token's privileges to a host — precisely elements 5 and 8, and directly the "mounting/access conditioned on successful authentication" dependent.
• Motivation (KSR): Both references are in the same field of portable-token/host security; a PHOSITA facing the Background's stated problem (one device to replace the thumb-drive + key + wallet, compatible with existing hosts) would predictably combine a wireless-USB/wireless-docking transport with the known biometric/proximity token gate to obtain a secure, hands-free drive. The result is the predictable aggregation of two known functions (secure access + wireless peripheral transport) — the classic KSR "familiar elements according to known methods" situation. The Background's own admission that individuals already carry RFID/Bluetooth keys and USB thumb-drives supplies the express "known problem" motivation.

Ground 2 — "Appears as a physical drive" and the module nomenclature (element 4's second half): network/remote-storage mounting art (SMB/CIFS network drive mapping, iSCSI block-device mounting, USB-over-IP redirection) in view of Ground 1.

• These long-established technologies mount remote memory so that the OS presents it as a local drive letter/volume — directly meeting "treated as an internal drive or a physically connected thumb drive."
• Motivation: Substituting a short-range wireless link for the wired/network transport is the predictable use of a known technique (wireless USB / Bluetooth / Wi-Fi) to improve a known device (a mountable remote drive) in the same way, yielding the expected benefit of cable-free convenience. KSR holds this is obvious absent evidence of unexpected results.

Ground 3 — Hardware-abstraction method facet (elements 6–8): hardware abstraction layer / device-virtualization art (HALs; USB device redirection; VM device pass-through) in view of Grounds 1–2.

• HALs that expose a consistent virtual resource and map it to whatever physical resource exists (local sensor vs. remote sensor) are a decades-old, textbook abstraction; USB redirection likewise maps a physically separate device to appear local ("proxy"). This meets elements 6–7 and the proxy/stand-alone/virtual dependent modes.
• Motivation: The Summary itself frames the abstraction as serving a stated goal — portability/versatility "regardless of variation in the physical resources available and their location." A PHOSITA with the abstraction pattern and the wireless-token transport of Grounds 1–2 would apply the known HAL technique to the known portable-token context to achieve platform independence — again a predictable application, not an inventive leap. The "platform agnostic" dependent claim is particularly vulnerable because KSR teaches that mere software portability/predictable adaptation to environments is ordinarily obvious.

5. Where the patentee has its best non-obviousness argument

To be balanced, the strongest rebuttals the record supports:

1. No single reference teaches the mounting of SE memory as a host drive conditioned on biometric/proximity authentication. The specific closed-loop ("swipe → authenticate owner → auto-mount pocket-resident memory as a local drive") may not be squarely taught anywhere on the verified list; the combination must be shown to be more than "adjacent in the art."
2. The three-model architecture abstraction (stand-alone / proxy / virtual) with a "balanced model" that lets one token act as both mobile and stationary component is a system-level design choice not obviously pre-figured. If the claims require runtime model selection, that is a stronger non-obviousness hook.
3. Secondary considerations — Proxense's large continuation family and licensing activity could be argued as objective indicia, but there is no evidence of record of a nexus between any secondary consideration and the '229 claims specifically; absent nexus, they carry little weight.

6. Bottom line and confidence

• On the reconstructed claim scope, the '229 subject matter is a strong § 103 candidate: the wireless storage-mount facet reads on known wireless-USB/docking art plus known biometric/proximity token art, and the abstraction facet reads on conventional HAL/device-virtualization art. Motivation to combine is supplied both by the patent's own Background (the admitted multi-item burden) and by KSR's predictable-use rationale.
• Confidence is qualified, in this order of uncertainty: (1) I did not retrieve the verbatim granted claims — the element decomposition is reconstructed and must be verified; (2) I did not retrieve the 816-item cited-art list, so I cannot say which references the Examiner actually applied or distinguished; the named references above are art I verified as existing in this field (mostly from Proxense's own PTAB records against other patents), not the '229 prosecution record.
• Recommended verification: pull the '229 file wrapper and "References Cited" list from USPTO PatentCenter (https://patentcenter.usptog.gov) or the patent's Google Patents "Citations" tab; confirm the exact independent claims; and check the effective-date/common-ownership status of any Giobbi-family reference before relying on it, given AIA § 102(b)(2)(C).

This adds to — and does not disturb — the earlier sections' findings that the '229 patent is a Proxense continuation and that no litigation or CAFC 2026 docket specifically naming it was located.