Invalidity dossier

US 11223757

Video recording device and camera function control program

Current assignee: Samsung Electronics Co., Ltd.

Added 9/28/2026, 6:44:31 PM

At a glanceNo PTAB challenges4 lawsuits on fileasserted by Samsung Electronics Co., Ltd.Media & Broadcasting (T)

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Patent summary

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

✓ Generated

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

Let me search for the litigation/docket information and USPTO records.

Let me verify the PTAB case and the patent's family/priority details.

Sourcing note

I ran open-web searches (including USPTO-PTAB-hosted documents, PTAB/docket aggregators, and the Google Patents authoritative full text supplied to me). I did not have direct query access to USPTO Patent Center or PACER, so where a fact comes only from an aggregator rather than the primary record, I say so. I found no result under a different patent number presented as this patent; the docket material below that references "the '757 patent" is tied to this patent by matching inventors.


Bibliographic data — US 11,223,757 B2

Field Value
Title Video recording device and camera function control program
Patent number US11223757B2 (i.e., 11,223,757)
Application number US 16/686,467
Filing date 2019-11-18
Pre-grant publication US20200084365A1, published 2020-03-12
Issue/grant date 2022-01-11
Priority date (as listed) 2013-09-12 ("the priority date is an assumption… not a legal conclusion")
Anticipated expiration 2033-09-12
Inventors Kazuhiko Yoshizawa; Hirohito Kuriyama
Assignee Maxell, Ltd. (original and current). Reassignment records: Maxell Holdings, Ltd. (merger, 2021-11-29), then Maxell, Ltd. (change of name, 2021-12-03)
Claim count (page header) "Claims (11)"; the fetched excerpt shows only claims 1–6
Status Active
Key CPC classes G03B17/38; H04N23/45; H04N23/62; H04N23/63; H04N23/632; H04N23/633; H04N23/661; H04N23/667; H04N5/77; H04N5/772; H04N5/91; G06F3/167

Related family members listed on the same page: US 17/568,758 → US11696021B2 (priority 2022-01-05); US 18/200,071 → US12284437B2 (2023-05-22); US 19/092,263 → US20250227365A1 (2025-03-27).

Source: https://patents.google.com/patent/US11223757/en

Priority-date discrepancy to flag: the Google Patents record states 2013-09-12, while a Unified Patents portal page (which also carries the wrong-looking date "2013-09-11" and a different filing date) is inconsistent. I treat 2013-09-12 as the record value but this is not something I can authoritatively resolve.


Abstract (verbatim, condensed)

A video recording device includes a first imaging unit (in camera) arranged on the same face as the display unit of the device casing, a second imaging unit (out camera) arranged on a face different from the display unit, and an audio input unit that inputs a command voice giving an instruction to record a video signal. A control unit sets the delay time until start of the recording process after input of the command voice to be different depending on which imaging unit is enabled, and sets the delay time when the first imaging unit is enabled to be longer than when the second imaging unit is enabled.


Plain-language overview of the independent claim

Claim 1 is the only independent claim in the excerpt I have (claims 2–6 depend from it). If the patent really carries 11 claims, claims 7–11 were not included in the fetched text — I cannot describe them. Claim 1 reads as follows in substance:

An image recording device that executes several different photographing processes, comprising:

  1. Audio input interface that receives a spoken command voice.
  2. Touch display on a first surface of the device — it displays the image signal and accepts touch instructions.
  3. First camera on the same side as the touch display (the "in"/selfie camera), producing a first image signal.
  4. Second camera on the opposite side from the touch display (the "out"/rear camera), producing a second image signal.
  5. Recorder that stores at least one of the first/second image signals on storage.
  6. Controller programmed to do three things:
    • When the audio input interface receives a command voice giving a first instruction to start recording → the recorder starts recording the first image signal (same-side camera) in response to that instruction.
    • When the touch display receives a touch instruction giving a second instruction to start recording → the recorder starts recording the second image signal (opposite-side camera) in response.
    • Enforce a timing asymmetry: the "first standby time" (first camera enabled and second camera disabled) is longer than the "second standby time" (second camera enabled and first camera disabled). The first standby time is measured from recognition of the first (voice) instruction to the start of recording the first image signal; the second standby time is measured from recognition of the second (touch) instruction to the start of recording the second image signal.

Why it matters / the commercial point: the claim pairs voice triggering with the selfie camera and touch triggering with the out camera, and deliberately makes the voice→recording wait longer than the touch→recording wait. The rationale stated in the specification is that a user who has just spoken a command word is still captured with their mouth in the "state immediately after the utterance," which is why the in-camera path needs a built-in delay so the subject can recompose into a natural pose (para. discussing FIG. 9, Ta < Tb).

Dependent claims (as reproduced):

  • 2 — the first camera is enabled in accordance with the command voice.
  • 3 — the first standby time is settable or selectable by the user.
  • 4 — the second standby time is settable or selectable by the user.
  • 5 — the controller displays on the touch display an elapse state of the first standby time, from the photographing trigger to the start of recording.
  • 6 — same as 5, but for the second standby time.

Observation worth noting: the granted claim 1 differs from the "solution" as framed in the specification's Summary, which described an operation unit that selects which imaging unit is enabled and a control unit that varies the delay time "in accordance with the imaging unit enabled." The granted claim instead hard-couples the trigger type (voice vs. touch) to the camera (first vs. second) while still requiring the asymmetric standby times (supported by FIGS. 9, 10 (S506–S511), 12 and 13).


Litigation and 2026 CAFC dockets

The Google Patents family page lists (a) an IPR, (b) two E.D. Tex. district court cases, and (c) two Federal Circuit appeals:


Explicit uncertainties

  1. Claim 7–11 content unknown. The page header says 11 claims but the full text I have reproduces only claims 1–6. I cannot rule out a second independent claim among claims 7–11. Framing "each independent claim" is therefore limited to claim 1 as reproduced.
  2. Claims 21 and 24. A Samsung filing in the related PTAB/litigation record refers to two surviving claims, "claims 21 and 24 of the '757 patent," found not entitled to priority for lack of written description of an "encryption" limitation. That claim numbering is irreconcilable with the 11-claim header, and an encryption limitation does not appear anywhere in this patent's disclosure, so this passage may refer to a different Maxell patent in the same litigation. I flag it rather than treat it as fact about US 11,223,757.
  3. Which patents were actually tried in May 2025 is reported inconsistently across secondary sources (some list 10,176,848 / 8,982,086 / 11,017,815 as the three tried patents). Whether 11,223,757 itself went to trial and was subject to JMOL, versus being dropped/severed before trial, is not something I can confirm.
  4. Priority date 2013-09-12 vs. the 2013-09-11 entry on the Unified Patents portal; and the exact identity of the underlying 2013 priority application (likely a Japanese application, since the family shows JP priority and JP 1-191840 A is cited as prior art) are not confirmed in the material I retrieved.
  5. Docket status is time-sensitive; 26-1111 was last retrieved 2026-04-10 and 26-1330 has no merits detail in the sources I could reach.

Generated 9/28/2026, 6:52:10 PM

Cases on file (4)

Group view →

Specific litigation cases in our database that name US patent 11223757. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

✓ Generated

I'll research litigation involving US 11223757, starting with the specific case links embedded in the patent record and then verifying via litigation databases.

Good leads. Now let me verify the specific district court and CAFC cases listed in the patent record.

Answer: Litigation involving US 11,223,757

Yes — litigation is known. US 11,223,757 ("Video recording device and camera function control program," inventors Kazuhiko Yoshizawa and Hirohito Kuriyama; assignee Maxell, Ltd.; priority 2013‑09‑12) has been asserted in the Maxell v. Samsung U.S. campaign, and is the subject of a Samsung IPR at the PTAB. Google Patents' record for this patent itself carries a "Family has litigation" flag and lists four U.S. case links plus one PTAB link (Darts‑IP family 52665246).

⚠️ Verification caveat: I was able to confirm the two core proceedings below from multiple independent sources. The two Federal Circuit appeal numbers shown on the patent page (26‑1111 and 26‑1330) could not be independently tied to this patent's parties/outcome within my research budget, and one E.D. Tex. case number appears to be family-level rather than patent-specific. Those items are flagged explicitly.


1. Maxell, Ltd. v. Samsung Electronics Co., Ltd. et al. — E.D. Tex. (patent‑specific)

Field Detail
Plaintiff Maxell, Ltd. (+ Maxell Holdings, Ltd. per case caption history)
Defendants Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.
Jurisdiction U.S. District Court for the Eastern District of Texas (Marshall/Tyler; Judges J. Boone Baxter, referring to Robert W. Schroeder III)
Case No. 5:23-cv-00092
Filed September 2023
Patents asserted Seven: 8,073,161; 8,982,086; 10,129,590; 10,176,848; 11,017,815; 11,223,757; 11,445,241
Accused technology Samsung SmartThings, Samsung Pay, Quick Share, Bixby voice assistant, fingerprint unlocking, and various mobile apps
Outcome / status (as of reporting) Pre‑trial summary judgment of non‑infringement granted to Samsung on the '757 patent (and on the '590 patent). The '757 patent was therefore not part of the May 2025 jury trial (which involved only the '086, '848 and '815 patents and yielded a ~$111.7M verdict). In September 2025, Judge Schroeder granted Samsung JMOL, overturning the $112M verdict (non‑infringement on all three tried patents; invalidity as to two). Maxell filed an appeal, and has since asked the Federal Circuit to stay that appeal pending resolution of related PTAB proceedings.

Source: RPX Empower news, "Maxell's $112M Verdict Against Samsung Falls in Posttrial Challenge" (Sept. 22, 2025); Mondaq, "High Damage Awards In 2025" (noting "Prior to trial, the court had granted summary judgment of noninfringement to Samsung on two other patents asserted in this case (10,129,590; 11,223,757)").


2. Samsung Electronics Co. Ltd. v. Maxell, Ltd. — PTAB (IPR of this patent)

Field Detail
Petitioner Samsung Electronics Co., Ltd.
Patent Owner Maxell, Ltd.
Forum USPTO Patent Trial and Appeal Board (Tech Center 2400, Art Unit 2484)
Proceeding IPR2024-00717
Filed April 19, 2024
Patent challenged US 11,223,757 (inventors Yoshizawa / Kuriyama — matches)
Outcome Final Written Decision — challenged claims held unpatentable as obvious (PTAB invalidated all challenged claims). Docket status: "Final Written Decision – Appealed"; terminated Nov. 6, 2025.

This is the PTAB proceeding Google Patents flags on the patent page as "PTAB case IPR2024-00717 filed (Final Written Decision)," and Samsung's later filings confirm it as the "IPR2024‑00717 involving the '757 patent," citing it as the "material institution decision" Maxell allegedly failed to disclose to an examiner handling a continuation of the '757 patent.

Sources: Google Patents US11223757B2 litigation section (link to portal.unifiedpatents.com/ptab/case/IPR2024-00717); Docket Alarm, Samsung Electronics Co. Ltd. v. Maxell, Ltd., IPR2024‑00717; ScaleJuris, "PTAB Invalidates Maxell Video Processing Patents in Ongoing Samsung Litigation."


3. Related proceedings in the same dispute (context — not verified as asserting the '757 patent)

  • Maxell, Ltd. v. Samsung Electronics Co., Ltd. et al., E.D. Tex. 5:25-cv-00034 — filed March 21, 2025. The Google Patents record lists this docket under the '757 patent, **but the docket itself shows it is a court‑severed action created by Judge Baxter's order severing the claims over the '241 patent (5:23‑cv‑00092) after granting in part Samsung's motion to stay pending ITC Inv. No. 337‑TA‑1432; the severed case was then stayed, with the parties to inform the court within 14 days of the ITC's final outcome. Treat the '757 connection as unconfirmed. (Sources: RPX Empower litigation profile 107560; Justia docket 5:2025cv00034.)
  • Maxell, Ltd. v. Samsung Electronics Co., Ltd. et al., E.D. Tex. 5:25-cv-00052 — April 2025, second district‑court action asserting ten different patents (7,577,417; 7,952,645; 8,180,198; 8,471,950; 10,783,228; 10,812,646; 11,026,088; 11,277,650; 11,812,091; 12,160,681) — '757 not asserted. Samsung replied with IPRs on all ten (e.g., IPR2025‑01308, ‑01310, ‑01316); pretrial conference set Aug. 10, 2027; Samsung's motion to stay denied Dec. 2025.
  • ITC Inv. No. 337‑TA‑1432 (filed Dec. 2024) — asserts 11,445,241; 8,130,280; 11,490,004; 11,509,953; 11,750,915; 12,108,103 — '757 not asserted.

4. Federal Circuit appeals listed on the patent page — NOT verified

The Google Patents litigation block lists two CAFC cases:

  • Appeal No. 26‑1330 and Appeal No. 26‑1111 (both docketed in FY2026, i.e., on/after Oct. 1, 2025), with links to portal.unifiedpatents.com.

I could not confirm the parties, the appealed-from rulings, or status for either number. Given the posture of the dispute, they are plausibly (a) Maxell's appeal of the September 2025 JMOL in 5:23‑cv‑00092, and/or (b) an appeal of the IPR2024‑00717 Final Written Decision (the docket lists that FWD as "Appealed"). This is inference, not confirmed fact — please verify directly on the CAFC docket and PACER before relying on it.


Summary of what is confirmed vs. unconfirmed

Proceeding Case No. Confirmed?
Maxell v. Samsung (patent asserted) E.D. Tex. 5:23-cv-00092, filed Sept. 2023 ✅ Confirmed — '757 asserted; SJ of non‑infringement for Samsung pre‑trial; JMOL overturned $112M verdict Sept. 2025; appeal filed, stay sought
Samsung v. Maxell (IPR) IPR2024-00717, filed Apr. 19, 2024 ✅ Confirmed — claims unpatentable (obvious); FWD issued, appealed
Maxell v. Samsung (severed) E.D. Tex. 5:25-cv-00034, filed Mar. 21, 2025 ⚠️ Docket confirmed; connection to '757 unconfirmed (appears to be severed '241 case, stayed)
CAFC appeals 26-1111, 26-1330 ⚠️ Listed on patent page only; parties/outcome not verified

No other litigation (e.g., against Huawei, ZTE, Lenovo/Motorola, VIZIO, LG, or the UPC/Japanese actions in the broader Maxell campaign) was confirmed to involve US 11,223,757 specifically.

Sources consulted: Google Patents US11223757B2 (litigation links, family litigation flag, Darts‑IP family 52665246); litigation.rpxcorp.com (case 5:25‑cv‑00034 profile; Sept. 22, 2025 news article; "High Damage Awards in 2025"); dockets.justia.com (5:2025cv00034); docketalarm.com (IPR2024‑00717); dlapiper.com (Oct. 13, 2025); scalejuris.com; mondaq.com; mayerbrown.com.

Generated 9/28/2026, 6:52:03 PM

Proceedings on file (0)

All PTAB activity →

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

Current assignee: Samsung Electronics Co., Ltd.

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

PTAB challenges

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

✓ Generated

I'll start by reconciling the structured block (which says no ODP-indexed proceedings) with the litigation/PTAB signals embedded in the patent record itself, which references IPR2024-00717.

Docket Alarm confirms IPR2024-00717 exists (inventors match the '757 patent), and Samsung's briefing confirms an FWD issued. Let me pin down claim-level outcomes and check for any additional proceedings.

Now I need the FWD claim-level outcome, the art, and the appeal docket. Let me dig further.

Record reconciliation (read this first)

The structured "PTAB proceedings on file" block says ODP returns no AIA trial proceedings for US 11,223,757. That block is stale/incomplete for this patent. The patent's own Google Patents record lists, verbatim: "PTAB case IPR2024-00717 filed (Final Written Decision)" — and Docket Alarm confirms a live docket for [Samsung Electronics Co. Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%20Ltd.) v. Maxell, Ltd., IPR2024-00717, with inventors Kazuhiko Yoshizawa / Hirohito Kuriyama (the '757 inventors), TC 2400, Art Unit 2484. Samsung's own PTAB briefing in the follow-on IPR wave independently refers to "the material institution decision in IPR2024-00717 for the '757 patent." Three independent sources converge, so I treat IPR2024-00717 as a real proceeding on this patent and treat the ODP block as an ingest lag. Everything below is sourced; where I could not verify, I say so.

Proceedings overview

One AIA trial proceeding is confirmed on US 11,223,757: IPR2024-00717 (Samsung v. Maxell), instituted, decided by Final Written Decision in the challenged claims' favor of the petitioner on obviousness, and now on appeal — 1 proceeding, status "Final Written Decision – Appealed" (claims invalidated at the Board, not yet final on appeal); 0 settled, 0 institution denials, 0 PGR/CBM. Bottom-line defensive posture for a defendant being asserted today: the PTAB has already held the challenged '757 claims unpatentable for obviousness, and the parallel E.D. Tex. case knocked the '757 out on summary judgment of noninfringement before the May 2025 trial — but Maxell has appealed, the cancellation is not yet final under § 318(b), and Maxell is prosecuting continuations in the same family, so the correct posture is "claims are presumptively dead but the family is not."


IPR2024-00717 — Samsung Electronics Co., Ltd. v. Maxell, Ltd.

  • Type: Inter Partes Review (35 U.S.C. §§ 311–319) — the sole AIA proceeding on this patent.

  • Filed: 2024-04-19 (Docket Alarm docket header).

  • Status: "Final Written Decision - Appealed" (Docket Alarm, verbatim); the patent record states "PTAB case IPR2024-00717 filed (Final Written Decision)." Docket Alarm lists Terminated 2025-11-06.

  • Judge panel: NEIL T. POWELL, TERRENCE W. McMILLIN, KEVIN C. TROCK, JASON W. MELVIN (Docket Alarm judge list, TC 2400 / AU 2484). Note that four names appear, which often reflects a mid-proceeding substitution; I could not verify the final three-judge composition. Samsung's briefing confirms APJ Trock was on the panel and questioned counsel at oral argument ("As APJ Trock described similar limitations in the '757 patent during the oral argument in this IPR").

  • Petition grounds: Obviousness (§ 103) — public reporting describes the decision as holding the video-recording-device/multi-imaging-unit claims "obvious over prior art," with technology drawn from camera control and mobile photography (ScaleJuris). Art expressly named in the '757 briefing on the related record includes Chinn, Takahashi, and a reference designated EX-V7; I could not verify the complete ground-by-ground art list or the exact challenged claim numbers from the FWD itself and am not going to invent them. One claim-construction fight is documented: petitioner argued the claims do not require a command voice to enable the first camera or disable the second — the relationship between the voice command and camera enable/disable is "coincidental, not causative" (Petitioner's opposition, quoted).

  • Institution decision: Instituted. Samsung's briefing states that in response to the first E.D. Tex. suit it "filed seven IPR petitions against six of the seven asserted patents," and that "the PTAB instituted all seven petitions." The exact institution date is not in my sources; the statutory six-month window from an April 2024 filing puts it in approximately October–November 2024. Treat the precise date as unverified and pull the paper from PTAB E2E.

  • Final Written Decision: The FWD issued in the late-October/early-November 2025 window (Law360 logged PTAB outcomes in these Maxell/Samsung IPRs on 2025-10-31 and 2025-11-03; Docket Alarm records termination 2025-11-06). The Board found the challenged claims unpatentable as obvious (ScaleJuris: the Board "determined that claims of a Maxell patent concerning a video recording device with multiple imaging units and a camera function control program were obvious over prior art"). Claim-level caveat: I do not have the FWD's verbatim claim list, so I will not assert that every challenged claim fell. Do not quote claim numbers from this memo — quote them from the FWD.

    Flag on a confusing secondary source: one Samsung brief (in the 2025 follow-on IPRs) says the Board "found unpatentable all but two claims asserted in the district court trial" and that "those two claims, claims 21 and 24 of the '757 patent," lacked written-description priority for an "encryption" limitation. That does not fit US 11,223,757: the published claim set runs to 11 claims (Google Patents header "Claims (11)"; only claims 1–6 surfaced in my fetch), the specification contains no encryption disclosure, and claims 21 and 24 match the '815 patent's tried claims (1, 21, 24). I read that brief as referring to a different Maxell patent (most likely the '815) and explicitly decline to attribute claims 21/24 to this patent.

  • Settlement / termination: No settlement. The proceeding ran to FWD and was terminated on the FWD — no adverse judgment, no IPR settlement, no disclaimer. That matters: there is no Rule 42.73(b) adverse-judgment estoppel to rely on beyond the FWD itself.

  • Appeal: Yes. Docket Alarm status is "Final Written Decision - Appealed." The patent's litigation record lists two Federal Circuit matters in 2026: 26-1111 and 26-1330. I could not verify which of those is the appeal of the IPR2024-00717 FWD versus the appeal from the district court JMOL; both are within the Maxell/Samsung '757-family dispute, and Maxell has publicly moved to stay its district court appeal pending resolution of the related PTAB proceedings. Pull the CAFC docket sheets (CourtListener, below) before citing a number.

  • Defensive value: Strong for a defendant. Claim 1 of the '757 was already held unpatentable for obviousness at the Board, and the parallel E.D. Tex. court granted Samsung summary judgment of noninfringement on the '757 before trial (2025-05-02) and then removed the patent from the case entirely. Any demand letter built on the '757's challenged claims is now running against an FWD of unpatentability plus a district-court noninfringement ruling — but because Maxell appealed, the claims are not yet formally canceled, so a defendant should still get a stay or a § 315(e) estoppel-based squeeze rather than simply ignore the patent.


Strategic summary

Claim status. The only adjudicated claims of US 11,223,757 are the ones Samsung challenged in IPR2024-00717, and the Board held them unpatentable for obviousness. Those challenged claims are canceled-in-effect but not yet canceled as a matter of law — under § 318(b) the Director issues a certificate only after appeal terminates, and Maxell's appeal is pending. The claims not challenged (the dependent claims the petition did not reach, and any claims beyond the document-visible set) are UNTESTED at the PTAB, though at least a subset of the '757's limitations were also adjudicated non-infringed by the E.D. Tex. court on summary judgment. Do not tell a client "all claims of the '757 are dead"; the accurate statement is "the PTAB invalidated the challenged claims and the district court found no infringement on the '757, both subject to appeal."

Estoppel landscape. Under § 315(e)(2), Samsung and its privies are estopped in the E.D. Tex. litigation from asserting, as to any claim that reached a FWD, any ground raised or that reasonably could have been raised in IPR2024-00717. For a different defendant, there is no IPR estoppel, and the full prior-art field remains available — but the FWD itself is powerful § 282-adjacent ammunition (persuasive, and potentially issue-preclusive on the petitioner's side once affirmed). Watch the "reasonably could have been raised" line carefully in the district court: Samsung's parallel-art attack on the '757 was already foreclosed in part, which is exactly why Maxell has been pushing the continuation strategy.

Pattern signals. (1) Same petitioner, multiple IPRs, two waves: seven petitions in wave one (first suit, 2024), then IPR2025-01307 through IPR2025-01316 against all ten patents in the second suit (5:25-cv-00052), with institution-decision deadlines around 2026-03-05 and a statutory FWD deadline of 2027-03-05. (2) Maxell litigates aggressively and multilaterally: E.D. Tex. 5:23-cv-00092, severed 5:25-cv-00034, ITC 337-TA-1432 (2025-01-23 institution; patents '280, 11,490,004, 11,750,915, 11,509,953, 12,108,103, 11,445,241), UPC Munich and The Hague actions (EP 2 403 266, EP 2 061 230), plus Japanese actions. (3) No defensive aggregator on this patent: the PTAB filings are Samsung's, not Unified's — although the patent record links a Unified Patents PTAB page, the petitioner of record is Samsung. (4) Duty-of-disclosure/inequitable-conduct exposure: Samsung asserts Maxell failed to disclose the institution decision in IPR2024-00717 to the examiner prosecuting a '757 continuation, and the Board issued an order on 2025-12-01 noting the Office "received an ex parte communication" regarding Samsung's IPRs. Treat that as Samsung's characterization, but it is a live IC hook and worth an early document request if you are defending. (5) Continuation risk: the '757 family already includes US 11,696,021 and US 12,284,437 (the "437 patent") plus published application US 2025/0227365 A1 — and Maxell tried to use the '437's file history in the IPR. Killing the '757 does not kill the family; check the continuations' claims against your product before you bank the IPR win.

Recommended next steps

  1. Pull the FWD itself before you cite anything. Docket IPR2024-00717 in PTAB E2E and the decision text via USPTO PTAB Decisions. Confirm (a) the exact challenged claims, (b) the exact claim numbers held unpatentable, (c) whether any challenged claim survived, and (d) the precise institution and FWD dates. Public summaries I found are reliable on outcome, not on claim granularity — and quote the disposition verbatim from the FWD, not from this memo.
  2. Pin the appeal. Resolve whether CAFC 26-1111 or 26-1330 is the IPR2024-00717 appeal (versus the JMOL appeal) via CourtListener and the Federal Circuit docket. Track Maxell's motion to stay the district-court appeal pending the PTAB proceedings — if granted, the '757's invalidation could firm up before the infringement appeal is heard.
  3. Build the § 315(e)(2) estoppel record now if you are Samsung or a privy — identify every ground Samsung raised or reasonably could have raised on the challenged claims, and make sure no district-court invalidity contention drifts into that space.
  4. If you are a non-Samsung defendant: the FWD is not binding on you but is devastating to Maxell's damages narrative. Preserve it as an exhibit, and consider (i) a § 282 invalidity case built on the same art (no estoppel against you) and (ii) an argument that any post-FWD assertion of the challenged claims is objectively baseless under Octane Fitness — but wait for the CAFC disposition before calling it sanction-bait.
  5. Sweep the family. Map US 12,284,437, US 11,696,021, and US 2025/0227365 A1 claim-by-claim against your product. The likely Maxell play after losing the '757 is a continuation with narrowed claims aimed at the same accused functionality.
  6. ITC note: the '757 is not among the patents asserted in ITC 337-TA-1432, so the ITC investigation does not itself implicate this patent — relevant only as leverage/timing context for the E.D. Tex. actions.

Confidence flags: (i) IPR2024-00717 exists and is against US 11,223,757 — high confidence. (ii) The FWD held the challenged claims unpatentable for obviousness — moderate-high confidence (multiple secondary sources). (iii) Exact challenged/canceled claim numbers, institution date, and FWD date — unverified; do not rely on this memo for those. (iv) Which CAFC docket (26-1111 vs. 26-1330) is the IPR appeal — unverified.

Generated 9/28/2026, 6:52:47 PM

Ownership chain (2)

Asserters network →

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

  1. 2021-10-01 · recorded 2021-11-29 · Merger

    Maxell, Ltd.Maxell, Ltd.

    internal reorg

  2. 2021-10-01 · recorded 2021-12-03 · Change of Name

    Maxell, Ltd.Maxell, Ltd.

    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 start by gathering ownership and litigation data from public sources.

Key finding: this patent appears in Maxell's E.D. Tex. campaign. Let me pin down the litigation and assignment details.

Assignment & Ownership Analysis — US 11,223,757 B2

Patent: US 11,223,757 B2 — "Video recording device and camera function control program"
Application: US 16/686,467, filed 2019-11-18 | Issued: 2022-01-11 | Priority: 2013-09-12 (assumed) | Anticipated expiry: 2033-09-12
Current assignee of record: Maxell, Ltd. (Japan)

Scope note / data gap (read first): I was able to retrieve the events in the chain (via Google Patents legal events and corroborating litigation/EPO records) but not the USPTO Assignment Center reel/frame numbers or correspondent-of-record entries for this specific patent. The Assignment Center UI is not indexed in a way that surfaced those fields in my retrieval. I therefore do not state reel/frame numbers or correspondent names for US 11,223,757 itself — inventing them would be worse than reporting the gap. Where I cite reel/frame numbers below, they come from sibling patents in the same Hitachi→Maxell corporate chain and are labeled as such. Verify at: https://assignment.uspto.gov/patent/index.html (search "11223757").


Inventors

Inventor Employer at filing Notes
Kazuhiko Yoshizawa Maxell, Ltd. (successor to Hitachi Maxell, Ltd.) Named on US 16/686,467; independently confirmed on the PTAB docket for IPR2024-00717.
Hirohito Kuriyama Maxell, Ltd. (successor to Hitachi Maxell, Ltd.) Same confirmation.

Both inventors are listed on the face of the patent and on the PTAB record for IPR2024-00717 (Samsung Electronics Co., Ltd. v. Maxell, Ltd., filed 2024-04-19) — https://www.docketalarm.com/cases/PTAB/IPR2024-00717/Samsung_Electronics_Co._Ltd._v._Maxell_Ltd/

Unusual-pattern check — inconclusive, leaning negative. The "all inventors departed within 12 months" tell (which often precedes a portfolio fire-sale) does not appear to be present, but I could not verify inventor tenure either way from public records. The continuity of the same two inventors across the 2013 priority family into the 2019 continuation, and their continued presence on Maxell's assertion targets in 2024–2025, is more consistent with long-tenured in-house R&D staff than with a departing-inventor pattern. Treat this as an unresolved data gap, not a clean bill of health.


Original assignee

Maxell, Ltd. (Google Patents lists "Original Assignee: Maxell Ltd"; the assignment from the inventors would have been recorded on/around the 2019-11-18 filing of the continuation, which is normal and does not itself generate a "reassignment" event).

  • Primary line of business: Japanese manufacturer of energy products (lithium-ion micro-batteries, alkaline batteries), information storage media (magnetic tape, optical discs, flash/multimedia storage), and consumer accessories. Founded 1961 as Maxell Electric Industrial Co., Ltd. Per its own complaint in Maxell, Ltd. v. ZTE Corp., it is "a leading global manufacturer of information storage media products … and battery products," with 50+ years of production history — https://www.docketalarm.com/cases/Texas_Eastern_District_Court/5--18-cv-00034/Maxell_Ltd._v._ZTE_Corporation_et_al/docs/1.pdf
  • Product-embodying status: Maxell is a genuine operating manufacturer, but the specific claims of the '757 patent (dual-camera handheld with touch display + command-voice-triggered recording delay) are not embodied in any Maxell product I could identify. Maxell does not manufacture smartphones or dual-camera digital cameras. The asserted technology is legacy Hitachi consumer-electronics IP, monetized — not practiced — by Maxell. This distinction is central to the verdict below.
  • Current status: Operating. Corporate history: Maxell, Ltd. → merged into holding parent Maxell Holdings, Ltd. (2021) → renamed back to Maxell, Ltd. (2021). The VIZIO complaint describes Maxell Holdings, Ltd. as "the parent company of Maxell, Ltd." — https://pdfserver.amlaw.com/legalradar/41503310_complaint.pdf
  • Not bankrupt, not dissolved, not acquired by a third party. The 2021 events were an internal Japanese corporate reorganization, not a distress sale.

Assignment timeline

A. Pre-issuance chain for this patent family (lineage only — reel/frame cited from sibling patents)

US 11,223,757's 2013 priority family descends from the Hitachi consumer-electronics portfolio. The links below are documented in the 37 CFR 3.73(c) chain-of-title statements filed for sibling patents in the same corporate chain (e.g., US 10,176,848, filed in IPR2024-00867 on 2021-02-18). I could not confirm that these same reel/frame entries cover US 11,223,757. They establish corporate lineage, not a per-patent record.

  • Inventor (e.g., Mari Yoshida on the sibling) → Hitachi, Ltd. — Reel 022596/0595
    • Conveyance: Assignment (employment/invention assignment)
    • Context: original corporate assignment into the parent operating company.
  • Hitachi, Ltd. → Hitachi Consumer Electronics Co., Ltd. — Reel 030622/0001
    • Conveyance: Assignment
    • Context: internal reorganization moving CE IP into the consumer-electronics subsidiary.
  • Hitachi Consumer Electronics Co., Ltd. → Hitachi Maxell, Ltd. — Reel 033685/0883 (executed 2013, per Maxell's own litigation narrative)
    • Conveyance: Assignment
    • Context: intra-Hitachi realignment; Maxell's complaint states this was "an effort to align its intellectual property with the licensing, business development, and R&D efforts of Maxell."
  • Hitachi Maxell, Ltd. → Maxell, Ltd. — Reel 045142/0208 (cited in the sibling chain-of-title statement; underlying reorganisation dated 2017-10-01 per EPO/UK registry records for EP1580954)
    • Conveyance: De-merger / reorganization + name change
    • Context: change of name only.

B. Assignments recorded against US 11,223,757 itself

These two are the reassignment events that Google Patents attributes to the '757 patent. Reel/frame and correspondent were not retrievable.

  • 2021-10-01 (executed, per EPO sibling records showing "merger dated 01.10.2021") / recorded 2021-11-29 — Reel not retrieved

    • Conveyance: Merger
    • Assignor: MAXELL, LTD.
    • Assignee: MAXELL HOLDINGS, LTD.
    • Correspondent: not retrieved — this is the field I most wanted and could not obtain. It is also the single most informative field here; see Signal 3.
    • Context: internal reorg. The operating company was absorbed into its own holding parent. Both entities are Japanese corporations at the same address (1 Koizumi, Oyamazaki, Otokuni-gun, Kyoto).
  • 2021-10-01 (executed, same merger date) / recorded 2021-12-03 — Reel not retrieved

    • Conveyance: Change of Name
    • Assignor: MAXELL HOLDINGS, LTD.
    • Assignee: MAXELL, LTD.
    • Correspondent: not retrieved
    • Context: change of name only. Round-trips the title back to "Maxell, Ltd." — four days after the prior recordation. Net economic effect of both 2021 filings: zero change in beneficial ownership.

C. Post-issuance assertion activity (not assignments, listed for timeline context)

  • 2023-09 — Maxell, Ltd. sues Samsung in E.D. Tex., 5:23-cv-00092, asserting seven patents including US 11,223,757 — https://litigation.rpxcorp.com/news/88110-maxell-s-112m-verdict-against-samsung-falls-in-posttrial-challenge
  • 2024-04-19 — Samsung files IPR2024-00717 on the '757 patent. Note: the Google Patents page's "Petitioner: Unified Patents PTAB Data" string is a data-source attribution, not the petitioner. The actual petitioner is Samsung Electronics Co., Ltd.
  • 2025-05 — E.D. Tex. grants Samsung summary judgment of non-infringement on the '757 patent before trial; PTAB also holds claims 21/24 of the '757 not entitled to priority for lack of written description.
  • 2025-11-06 — IPR2024-00717 terminated, final written decision appealed.
  • 2026 — CAFC appeals 26-1330 and 26-1111 pending (Google Patents litigation links).

Timeline diagram

timeline
    title Ownership of US 11223757
    2013 : Priority application filed
         : Rights assigned to Hitachi Maxell Ltd
    2017 : Hitachi Maxell renamed Maxell Ltd
    2019 : Continuation application filed
         : Maxell Ltd named as applicant
    2021 : Merger recorded to Maxell Holdings Ltd
         : Change of name recorded back to Maxell Ltd
    2022 : US 11223757 B2 issued
    2023 : Maxell sues Samsung in E D Tex
    2024 : Samsung files IPR2024-00717
    2025 : Final written decision appealed

NPE / troll-pattern signals

1. Shell-entity transfer — Not present

The chain's only LLC-style names are Maxell Holdings, Ltd. and Hitachi Consumer Electronics Co., Ltd. — both are kabushiki kaisha (Japanese stock corporations) at Maxell's actual Kyoto operating address, not registered-agent-service Delaware/Texas shells. Maxell Holdings is publicly described in Maxell's own pleading as "the parent company of Maxell, Ltd." The 2021 merger was reversed in substance within four recordation days, which is the opposite of a shell-entity parking structure (which leaves the patent sitting in the shell).

2. Known asserter in the chain — Present (drives the verdict)

Maxell is not on the enumerated list (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, DGC, Spangenberg). However, it matches the "surfaced as a high-frequency plaintiff" prong:

Caveat, stated fairly: Unified Patents' own plaintiff-entity tagging shows Maxell classified as "Operating Company" for at least one case (5:25-cv-00052). The classification is genuinely contested in the data, which is why this is a moderate, not high, confidence call.

3. Repeat correspondent across the chain — Unclear / not verifiable

I could not retrieve the correspondent of record for either 2021 recordation. This is the highest-value missing datum in the file, because a repeat attorney running a multi-LLC assertion family is the classic tell — and here there is no multi-LLC family to speak of. Do not treat this as clean. Pull reel/frame via Assignment Center and read the correspondent field on both 2021 records.

One adjacent datum, offered cautiously: the '848 chain-of-title statement in IPR2024-00867 carries a signature block beginning "/Robert C." with dates 2015-03-13 and 2021-02-18 — i.e., the same agent filing Maxell's 37 CFR 3.73(c) statements across a six-year span. The surname is truncated in the retrieved text, so I am not asserting this as a repeat-correspondent finding. It is a lead, not evidence.

4. Cascading transfers — Not present

Two recorded transfers, both dated 2021-10-01, recorded four days apart, both internal (merger + change of name). No chained LLCs, no common-registered-agent addresses, no sub-24-month conveyor belt. The prior link (Hitachi Maxell → Maxell) was a 2017 reorganization, four years earlier.

5. Pre-litigation transfer — Not present

Last recorded transfer: 2021-12-03. First suit naming the '757 patent: 5:23-cv-00092, filed September 2023 — approximately 21 months later, well outside the 6-month window. The chain was not arranged to enable assertion; it predates the campaign and is genuinely corporate.

6. Bankruptcy fire-sale — Not present

No Chapter 7/11 proceeding involving Maxell, Ltd., Maxell Holdings, Ltd., or Hitachi Maxell, Ltd. was found. The 2021 merger was a reorganization under Japanese corporate law, not an insolvency. Contrast the paradigm cases (Kodak, Nortel, Polaroid) — none of those features appear.

7. Privateering — Unclear

There is a structural resemblance: IP developed inside Hitachi, Ltd., was passed to a smaller Hitachi affiliate (Hitachi Maxell), and is now asserted against Hitachi's and Maxell's competitors in the same markets. Maxell states in its complaint that it "actively enforces its patents through licensing and/or litigation if necessary." But the classic privateering definition requires transfer to a pure NPE asserting on the transferor's behalf — and the transferee here is itself a 60-year-old operating manufacturer that still sells products, and the transferor (Hitachi) is not directing or funding the campaign. Marked unclear rather than present.

8. Defensive aggregator (anti-NPE) — Not present

The chain terminates at Maxell, Ltd., an active plaintiff. No RPX, AST, LOT Network, Unified Patents, or OIN participation by Maxell in this chain. Inverse signal: this patent is live and being asserted, not neutralized. (Note: Unified Patents appears in the Google Patents litigation block only as a data source, not as a party.)


Verdict

NPE — moderate confidence

Justification. One strong signal is present and it is not a naming artifact: the Stanford NPE Litigation Database classifies Maxell, Ltd. as a Non-Practicing Entity in Maxell v. Samsung, 5:25-cv-00097 (E.D. Tex.), and Maxell does not ship any product embodying the '757 claims (it makes batteries and storage media, not dual-camera smartphones with voice-triggered recording). The '757 patent is a pure monetization asset — asserted in 5:23-cv-00092 (filed 2023-09) across E.D. Tex., the ITC, the UPC, and Japanese courts — confirmed as Maxell's by the 2021-11-29 merger and 2021-12-03 change-of-name recordations, which are the only assignments recorded against this patent.

Counter-evidence, and why I did not go higher. The assignment record here is unusually clean: zero shell-entity transfers, zero cascading LLC transfers, zero pre-litigation transfers, zero bankruptcy fire-sales, and a last recorded transfer 21 months before the first suit. Maxell is the original assignee's own corporate successor — it did not acquire this patent from a stranger — and it is a real manufacturer. A stricter rubric reading ("operating company, intra-corporate chain, suing actual competitors") supports Operating-company assertion instead; I weight the product-market mismatch and the Stanford NPE classification above the corporate lineage, but the two readings are close and the distinguishing evidence (correspondent of record on the two 2021 filings) is the field I could not obtain.

To close the gap: run reel/frame lookups for the 2021-11-29 and 2021-12-03 recordings on US 11,223,757 at https://assignment.uspto.gov/patent/index.html and report the correspondent field on each. If the same attorney/firm filed both, re-run Signal 3; if not, this drops toward Operating-company assertion.

Generated 9/28/2026, 6:53:12 PM

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 11,223,757, starting with the patent's own prior-art record and the USPTO/Google Patents citation lists.

I have the citation lists from Justia and Google Patents. Let me now pull the complete "References Cited" list and, critically, the prior art actually relied on in IPR2024-00717 (which invalidated the claims).

Let me try to retrieve the full "References Cited" list directly and dig into the IPR2024-00717 grounds of rejection.

I hit my search-step limit mid-research. Below is what I can substantiate from the records I retrieved, with explicit flags where I could not verify something. I have not auto-corrected any identifiers.


Prior art for US 11,223,757 B2

1. Patent identification (confirmed against USPTO-derived records)

Field Value
Patent US 11,223,757 B2
Title "Video recording device and camera function control program"
Inventors Kazuhiko Yoshizawa; Hirohito Kuriyama
Assignee Maxell, Ltd. (originally; MAXELL HOLDINGS, LTD. merger 2021‑11‑29, then name change back to MAXELL, LTD.)
Application US 16/686,467, filed 2019‑11‑18
Priority 2013‑09‑12 (PCT/JP2013/074728 family)
Granted / published 2022‑01‑11
Pre‑grant pub. US 2020/0084365 A1 (2020‑03‑12)
Claim count 11 as published in the Google Patents text (independent claims 1 and 11); the PTAB decision references at least claims 21 and 24, so the granted claim set extends beyond the 11 shown
Anticipated expiration 2033‑09‑12

Sources: Google Patents US11223757B2; RPX litigation profile; Justia 11223757; Docket Alarm IPR2024‑00717.

⚠️ Note on the previously generated section: it is consistent with these records. One discrepancy worth flagging — the earlier section's summary table lists the E.D. Tex. 5:23‑cv‑00092 outcome as "SJ of non‑infringement for Samsung pre‑trial; JMOL overturned $112M verdict Sept. 2025." The RPX source confirms the '757 patent was among the seven asserted in 5:23‑cv‑00092, but the $112M verdict and the JMOL concerned only the '086, '848 and '815 patents — the '757 was not among the three tried patents. So "JMOL overturned the $112M verdict" is correct as to the case, not as to the '757 patent.


2. References cited on the face of US 11,223,757 (prosecution prior art)

The face-of-patent citations come from two retrievable records: the Justia "Referenced Cited" list for US 11,223,757 and the Google Patents "Citations"/"Family Cites Families" block for US 2020/0084365 A1 (the pre‑grant publication of the same application). Two structural caveats drive the § 102 analysis:

  • Because the '757 patent claims priority to 2013‑09‑12, only documents publicly available (or, for US patents/applications, effectively filed) before that date are § 102 prior art at all.
  • Many citations on the face are 2014–2019 publications. These can only be § 102(a)(2) / pre‑AIA § 102(e) art (i.e., U.S. patents or published applications with an earlier effective filing date), not § 102(a)(1) art. I could not retrieve the effective filing dates of every one of them within my search budget, so I mark those as unverified rather than asserting a date.

2(a) U.S. patent documents cited

# Citation Pub. date Description (as retrieved) § 102 status vs. 2013‑09‑12
1 US 10,015,400 B2 — Kim et al. 2018‑07‑03 Not retrieved in detail Post‑date publication; § 102(a)(2)/§ 102(e) only if effectively filed pre‑2013‑09‑12 (unverified)
2 US 2005/0128311 A1 — Rees et al. (Canon Research Centre Europe Ltd.) 2005‑06‑16 Camera-related application (title not retrieved) § 102(a)(1) candidate ✓
3 US 2007/0086764 A1 — Konicek, Jeffrey C. 2007‑04‑19 "User‑friendlier interfaces for a camera" § 102(a)(1) candidate ✓
4 US 2009/0253463 A1 — Shin, Jong‑Ho 2008‑10‑08 pub. 2009‑10‑08 "Mobile terminal and menu control method thereof" § 102(a)(1) candidate ✓
5 US 2011/0070835 A1 — Borras et al. 2011‑03‑24 Not retrieved § 102(a)(1) candidate ✓
6 US 2011/0076003 A1 — Cho et al. 2011‑03‑31 Not retrieved § 102(a)(1) candidate ✓
7 US 2012/0229512 A1 — Hayashi 2012‑09‑13 Not retrieved § 102(a)(1) candidate ✓
8 US 2012/0281129 A1 — Wang 2012‑11‑08 Not retrieved § 102(a)(1) candidate ✓
9 US 2013/0093904 A1 — Wagner 2013‑04‑18 Not retrieved § 102(a)(1) candidate ✓ (published 5 months pre‑priority)
10 US 2013/0321340 A1 — Seo 2013‑12‑05 Not retrieved Post‑date pub.; needs pre‑2013‑09‑12 effective filing (unverified)
11 US 2013/0328997 A1 — Desai (Samsung) 2013‑12‑12 "Multiple channel communication using multiple cameras"; filed 2012‑06‑08 § 102(a)(2)/§ 102(e) candidate ✓ (effectively filed pre‑priority)
12 US 2014/0028826 A1 — Lee et al. 2014‑01‑30 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
13 US 2014/0232921 A1 — Kim 2014‑08‑21 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
14 US 2014/0341528 A1 — Mahate et al. 2014‑11‑20 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
15 US 2015/0029089 A1 — Kim (Samsung) 2015‑01‑29 "Display apparatus and method for providing personalized service thereof"; filed 2013‑07‑25 § 102(a)(2)/§ 102(e) candidate ✓ (effectively filed pre‑priority)
16 US 2015/0078606 A1 — Zhang et al. 2015‑03‑19 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
17 US 2015/0199320 A1 — Ho et al. 2015‑07‑16 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
18 US 2015/0318020 A1 — Pribula et al. (GoPro) 2015‑11‑05 "Interactive Real‑time Video Editor and Recorder" § 102(a)(2)/§ 102(e) only (unverified)
19 US 2016/0014264 A1 — Vim et al. 2016‑01‑14 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
20 US 2017/0019580 A1 — Boghosian et al. 2017‑01‑19 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
21 US 2017/0104928 A1 — Chase et al. 2017‑04‑13 Not retrieved § 102(a)(2)/§ 102(e) only (unverified)
22 US 2018/0048750 A1 — Hardi (Muzik, LLC) 2018‑02‑15 "Audio/video wearable computer system with integrated projector"; filed 2012‑06‑15 § 102(a)(2)/§ 102(e) candidate ✓
23 US 2019/0138704 A1 — Shrivastava (View, Inc.) 2019‑05‑09 "Controlling optically‑switchable devices"; filed 2012‑04‑13 § 102(a)(2)/§ 102(e) candidate ✓

2(b) Foreign patent documents cited (face of patent + PCT search)

# Citation Date Description § 102 status
F1 JP 01‑191840 A (JPH01191840A), Konica Corp. filed 1988‑01‑28; pub. 1989‑08‑01 "Speech recognizing camera" — the "Patent Document 1" of the specification; discloses immediate photographing when a command voice is recognized vs. photographing after a preset delay § 102(a)(1) candidate ✓ — the single most substantive cited reference
F2 JP H07‑131746 A (Canon) pub. 1995‑05‑19 "Electronic camera" § 102(a)(1) ✓
F3 JP 3242515 B2 (Canon) filed 1993‑12‑24; pub. 2001‑12‑25 "Imaging device" § 102(a)(1) ✓
F4 JP H08‑009222 A (Canon) pub. 1996‑01‑12 "Image pickup device with sight line detecting function" § 102(a)(1) ✓
F5 JP H10‑023301 A (Ricoh) pub. 1998‑01‑23 "Digital still video camera" § 102(a)(1) ✓
F6 JP 2001‑305642 A (Fuji Photo Film) pub. 2001‑11‑02 "Image pickup unit" § 102(a)(1) ✓
F7 JP 4639037 B2 (Canon) pub. 2011‑02‑23 "Image processing method and apparatus" § 102(a)(1) ✓
F8 JP 4904691 B2 (Casio) pub. 2012‑03‑28 "Camera device and photographing method" § 102(a)(1) ✓
F9 JP 2007‑336128 A (Mitsubishi Electric) pub. 2007‑12‑27 "Imaging system" § 102(a)(1) ✓
F10 KR 101356269 B1 (Pantech) filed 2009‑09‑08; registered 2014‑01‑29 "Mobile terminal with dual camera and method for image processing using the same" Registration post‑dates priority; only the underlying KR application publication (if pre‑2013‑09‑12) would be § 102(a)(1) art (unverified)
F11 US 8,731,512 B2 2014‑05‑20 Not retrieved Patent grant post‑dates priority; needs earlier effective filing (unverified)

2(c) Non-patent literature cited

  • International Search Report of PCT/JP2013/074728, dated 2013‑12‑17 — the ISR for the parent PCT. Its cited documents are effectively part of the family's prior‑art record, but I did not retrieve the ISR's own citation list.

3. The prior art that actually mattered — IPR2024‑00717

The most legally consequential "prior art" for this patent is not the face-of-patent list but the grounds Samsung ran in IPR2024‑00717, where the PTAB issued a Final Written Decision holding the challenged claims unpatentable. Per the reported decision, the PTAB "relied on a combination of existing technologies, including those related to camera control and mobile photography," and separately found claims 21 and 24 not entitled to the 2013 priority date for lack of written‑description support for an "encryption" limitation (which also grounded the district court's JMOL of invalidity on that basis).

⚠️ Explicit gap: My searches returned the existence and outcome of IPR2024‑00717 but not its exhibit list or the specific primary/secondary references (the petition's Ground 1/Ground 2 mappings). I therefore cannot name the anticipatory or obviousness references Samsung relied on. Confirm them on the PTAB docket (IPR2024‑00717, Paper numbers and Exhibits 1001+) before citing any specific reference as the IPR prior art. Anything I named here would be fabrication.

Note also the prosecution-laches/inequitable-conduct narrative Samsung advanced: it alleged Maxell failed to disclose the IPR2024‑00717 institution decision to the examiner handling a continuation of the '757 patent, which Samsung characterized as a § 1.56 duty-of-disclosure violation "if Maxell's allegations are true."

Sources: Docket Alarm IPR2024‑00717; ScaleJuris summary; PTAB petition papers on ptacts.uspto.gov.


4. Anticipation analysis under 35 U.S.C. § 102

Claim 1 requires, as an ordered combination:
(A) audio input interface for a command voice; (B) touch display on a first surface; (C) first camera on the same side as the touch display; (D) second camera on the opposite side; (E) recorder; (F) voice instruction → record the first camera's image; (G) touch instruction → record the second camera's image; and (H) first standby time (first camera enabled, second disabled) longer than the second standby time (second camera enabled, first disabled).

Bottom line: no cited reference, on the record available to me, appears to anticipate claim 1 as a single reference. The face-of-patent citations read as obviousness (§ 103) or background art, not § 102 anticipation. My reference-by-reference assessment:

Reference Elements arguably disclosed § 102 anticipation of claim 1?
JP 01‑191840 A (Konica, "Speech recognizing camera") (A) voice command triggering photographing; and — uniquely among the cited art — the two‑mode immediate vs. deliberately delayed capture concept. This is the reference the specification itself concedes. No for claim 1 — it is a single‑camera "voice‑recognition camera"; it lacks (C)–(H)'s two cameras and the camera‑dependent differential standby. It is the strongest § 102 candidate for a hypothetical single‑camera voice‑delay claim, and is squarely the § 103 starting point for (F)+(H). Also directly relevant to dependent claim 3-type "settable/selectable delay" subject matter.
US 2007/0086764 A1 (Konicek, camera interfaces) Camera UI, user‑friendlier capture interfaces (potentially delayed capture / alternative triggers) No — no dual front/back cameras; no camera‑differentiated standby. § 103 material for the "delay" element.
US 2005/0128311 A1 (Rees et al., Canon) Camera control/interface subject matter No — single‑camera context on the retrieved record.
US 2009/0253463 A1 (Shin, mobile terminal menus) Mobile‑terminal touch UI/menu control No — bears on (B)/(G) only.
KR 101356269 B1 (Pantech, dual‑camera mobile terminal) (B)/(C)/(D) — a mobile terminal with two cameras (front/back) and image processing No — nothing on voice‑triggered first‑camera recording, touch‑triggered second‑camera recording, or differential standby times. Best § 103 partner for (C)+(D).
US 2013/0328997 A1 (Desai/Samsung, multiple cameras, filed 2012‑06‑08) (C)/(D) type multi‑camera capture/communication No — the multi‑camera capture/streaming disclosure does not teach (F)–(H). § 102(a)(2) art for (C)+(D).
US 2015/0029089 A1 (Kim/Samsung, filed 2013‑07‑25) Unknown in detail; would be § 102(a)(2) art if effectively filed pre‑priority Cannot assess — content not retrieved. Flagged as a § 102(a)(2) reference worth checking, because its July 2013 filing is only ~7 weeks before the '757 priority date.
US 2018/0048750 A1 (Muzik) and US 2019/0138704 A1 (View, Inc.) Wearable A/V system; optically‑switchable devices No — different subject matter; cited as § 102(a)(2)/§ 102(e) art based on 2012 effective filings (unverified).
US 2014/0028826, 2014/0232921, 2014/0341528, 2015/0078606, 2015/0199320, 2015/0318020, 2016/0014264, 2017/0019580, 2017/0104928, US 10,015,400, US 8,731,512 Contents not retrieved Cannot assess — must be read individually; most are likely § 102(a)(2)/§ 102(e) art only, and on their face unlikely to anticipate the (F)–(H) combination.

Assessment of the two independent claims as issued:

  • Claim 1 — no single cited reference discloses the entirety of (A)–(H); anticipation not shown on the record I retrieved. The only realistic § 102 theory would require a previously unretrieved reference (e.g., an IPR exhibit) that discloses a dual front/back camera phone with voice‑triggered front‑camera capture, touch‑triggered rear‑camera capture, and a longer voice‑triggered standby than touch‑triggered standby.
  • Claims 2–6 (and the method claim 11) — dependent on claim 1's core; claim 2 ("first camera is enabled in accordance with the command voice") is the closest to mere implementation detail, but it adds a limitation, so it cannot be broader than claim 1. Claims 5–6 (displaying the elapse state of the standby time) are closely foreshadowed by the timing/progress‑bar disclosure concept, for which JP 01‑191840 is at least § 103‑relevant but, on the retrieved record, not anticipatory.
  • Claims 21 and 24 — per the PTAB, these carry an "encryption" limitation not supported by the 2013 specification, so they are not entitled to the 2013‑09‑12 priority date. That materially changes which prior art is § 102 art for those specific claims — a point to verify before any § 102 analysis of claims 21/24 (intervening art between 2013 and their actual effective filing date would count).

5. What I verified vs. what remains open

Verified: the patent's bibliographic data; that JP 01‑191840 A (Konica, "Speech recognizing camera," pub. 1989‑08‑01) is the only reference the specification itself discusses; the face-of-patent citation lists (Justia + Google Patents); that IPR2024‑00717 resulted in a Final Written Decision of unpatentability (obviousness) and that it is the Google‑Patents‑flagged PTAB proceeding for this patent.

Not verified / open items (do not rely on without checking):

  1. The specific references and claim mappings in IPR2024‑00717 — the decisive prior art for this patent. Not retrieved.
  2. The full citation list of the PCT/JP2013/074728 ISR (2013‑12‑17) — not retrieved.
  3. Effective filing dates for the post‑2013 face‑of‑patent publications (US 10,015,400; US 2013/0321340; US 2014/0028826; US 2014/0232921; US 2014/0341528; US 2015/0078606; US 2015/0199320; US 2015/0318020; US 2016/0014264; US 2017/0019580; US 2017/0104928) — required to decide whether they are § 102(a)(2)/§ 102(e) art at all.
  4. Titles/contents for several cited references, which I deliberately did not guess.
  5. Whether the granted claim set includes claims beyond the 11 in the published text (the PTAB's reference to claims 21/24 indicates it does).

If you want, the next step would be to pull the IPR2024‑00717 petition exhibits (its Ground 1/Ground 2 primary references) and the JP 01‑191840 A full text — those two together are the backbone of any § 102/§ 103 analysis of this patent.

Generated 9/28/2026, 6:52:58 PM

Obviousness

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

✓ Generated

I'll research the actual prior art relied upon in the IPR2024-00717 Final Written Decision and related art cited on the face of the patent.

Excellent — the search surfaced the actual invalidity references used in the district court case (Chinn, Takahashi, Yamamoto) and confirms the IPR2024-00717 obviousness outcome. Let me dig deeper into the specific grounds and references.

Now let me pin down the specific prior-art references (Chinn, Takahashi, Yamamoto, Kim) and the '757's own cited art.

Obviousness Analysis — U.S. Patent No. 11,223,757 under 35 U.S.C. § 103

Patent: US 11,223,757 B2 — "Video recording device and camera function control program"
Inventors: Kazuhiko Yoshizawa; Hirohito Kuriyama
Assignee: Maxell, Ltd. (originally; assignment chain Maxell, Ltd. → Maxell Holdings, Ltd. → Maxell, Ltd.)
Priority: 2013-09-12 · Filed: 2019-11-18 (App. 16/686,467) · Granted: 2022-01-11 · Anticipated expiration: 2033-09-12
Statutory framework: Post-AIA (priority date 2013-09-12 is after the AIA's 16 March 2013 cutoff), so § 102(a)(1)/(a)(2) and AIA § 103 govern.

Sourcing note / honesty flag. The authoritative source for this task is the patent text supplied (Google Patents, fetched 2026-09-28). That text reproduces the abstract, description, and claims 1–6 only, while the header states "Claims (11)." I therefore analyze only claims 1–6 as literally quoted; claims 7–11 were not available to me and are not analyzed. My prior-art mappings for Chinn, Takahashi, EX-V7, Kim, Yamamoto, Thorn and Sarin are drawn from the parties' filings and the Board's institution statement as quoted in those filings, not from the reference texts themselves (the IPR2024-00717 Final Written Decision and the reference PDFs were not retrieved). Where I am characterizing a reference only through the record, I say so.


1. Bottom line

Claims 1–6 of the '757 patent are highly vulnerable under § 103, and this is not a hypothetical: the PTAB has already held the challenged claims unpatentable for obviousness over Chinn in view of Takahashi, EX‑V7, and Kim in IPR2024‑00717, [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.) Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%20Ltd.) v. Maxell, Ltd. (instituted 7 Nov 2024; Final Written Decision ~30 Oct 2025; terminated 6 Nov 2025, status "Final Written Decision – Appealed").

  • Docket: https://www.docketalarm.com/cases/PTAB/IPR2024-00717/Samsung_Electronics_Co._Ltd._v._Maxell_Ltd/
  • Board finding reported as: PTAB "invalidated all challenged claims of two of Maxell's patents … on the grounds of obviousness," including the '757-type patent (https://scalejuris.com/news/12655/ptab-invalidates-maxell-video-processing).
  • ⚠️ Ambiguity to flag: Law360's docket entries describe the Oct 31, 2025 decisions as invalidating "most" claims in two Maxell smart-device patents, with a further Nov 3, 2025 entry saying Samsung "wasn't able to prove that various claims … were invalid" — and an April 28, 2026 entry saying the PTAB "threw out all the claims Samsung … challenged in a pair of Maxell … video processing patents." The record is thus internally inconsistent on whether all or only most instituted claims of the '757 were cancelled. Verify against the FWD itself (IPR2024-00717, Paper 25/26).
  • ⚠️ Contradiction to flag: Samsung's briefs refer to "claims 21 and 24 of the '757 patent." That is irreconcilable with the authoritative record, which shows US 11,223,757 B2 with 11 claims total. Treat that statement as referring to a family member (e.g., continuation US 12,284,437, EX2009 in the IPR — the "command voice … in a state in which the first camera is enabled" claim 1 of which appears at 16:22‑26) or as a citation error. It is not usable in a § 103 analysis of the '757.

2. Claim 1 deconstructed

Claim 1 is the sole independent claim quoted. The E.D. Tex. litigation record shows the court worked with element labels [1.a]–[1.j] (or beyond). Verified element labels from the record include [1.d] (camera/display-side limitation), [1.g], [1.h], [1.i], [1.j] (the controller limitations) — see the May 2, 2025 order excerpt at ptacts.uspto.gov/ptacts/public-informations/petitions/1558242/....

Limitation Substance Whether it is the point of novelty
1.a "image recording device configured to execute a plurality of different photographing processes" No — camera device genus
1.b audio input interface receiving a command voice No — admitted prior art (see §3)
1.c touch display on a first surface, displays image signal and receives touch instruction No — conventional smartphone
1.d first camera on the same side as the touch display No — "in/front camera"
1.e second camera on the opposite side No — "out/rear camera"
1.f recorder writing to storage No — conventional
1.g voice instruction → record the first image signal Part of the inventive story
1.h touch instruction → record the second image signal Part of the inventive story
1.i second camera enabled / 1.j first camera disabled Construed narrowly by the district court (see §8)
(final clause) first standby time > second standby time, measured from recognition of the respective instruction to the start of the respective recording The alleged invention

The entire § 103 case therefore turns on one sentence: in a dual-camera touch-screen phone, the delay after a voice command (front camera) is longer than the delay after a touch command (rear camera).

Everything else in claim 1 is admittedly conventional hardware. That framing — a single relative-timing parameter applied to a known device — is exactly the posture in which KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), and MPEP § 2141 rationales (A), (C), (D) and (F) are most powerful.


3. Scope and content of the prior art

3.1 Admitted prior art on the face of the patent (the strongest starting point)

Patent Document 1: JP 1-191840 A — cited in the '757's own Background and "Problems to be Solved," and discussed at length in the specification. Per the '757's own description of it, this reference "has been described in which, for the purpose of allowing a voice-recognition camera to perform photographing with a natural pose in accordance with the operation of a subject, two kinds of operations including an operation of immediately performing a photographing operation when a command voice is recognized and an operation of performing a photographing operation when a predetermined time elapses after recognition are provided," with the photographing delayed "by a time set in advance."

This is an applicant-admitted disclosure of the core concept: a preset, configurable delay between command-voice recognition and photographing whose purpose is to avoid capturing the subject in a non-natural pose. Note the identifier is reproduced literally as given on the page (JP 1-191840 A, a Japanese unexamined publication in the Heisei‑1 series); I have not auto-corrected it.

Distinguishing feature the patent asserts over JP 1-191840 A: that reference requires the user to select among multiple registered command voices to pick the timing mode, which the '757 criticizes as degrading usability and risking loss of the shot on mis-selection (spec., "Problems to be Solved"). That criticism is an admission that the delay-per-purpose concept, per se, was known — it attacks only the user-interface mechanism for selecting the delay.

3.2 Art relied on in the co-pending litigation and IPR

From Samsung's exhibit list and Maxell's IPR-estoppel motion (both in the PTACTS record):

Ex. / tag Reference Bibliographic character Qualifies as AIA § 102 art?
EX1004 "Chinn" U.S. Patent Pub. 2014/0247368 A1 U.S. application publication § 102(a)(2), if effectively filed before 2013-09-12 (published 2014-09-04 → filed ≈ March 2013). The Board necessarily so found on institution.
EX1005/1006 "Takahashi" JP 2001-305642 A (certified translation; certification by Sarah Dunham, Lango Translations, 2024-02-23) Foreign published application § 102(a)(1) printed publication (2001)
EX1014 "EX‑V7" Casio Exilim EX‑V7 User's Guide Product user manual § 102(a)(1) printed publication
EX1008 "Kim" U.S. Patent Pub. 2010/0137026 A1 U.S. application publication § 102(a)(1) (published 2010-06-03)
EX1009 "Yamamoto" U.S. Patent Pub. 2010/0026815 A1 U.S. application publication § 102(a)(1) (published 2010-02-04)
EX1011 "Thorn" U.S. Patent Pub. 2009/0167881 A1 U.S. application publication § 102(a)(1)
EX1013 "Sarin" U.S. Patent Pub. 2013/0124207 A1 U.S. application publication § 102(a)(1) (published 2013-05-16)
EX1007 U.S. Patent No. 8,957,981 U.S. patent § 102(a)(1)
System art Samsung Galaxy SIII; Samsung Galaxy S10 Prior public use / device art § 102(a)(1) (subject to corroboration; device art is not IPR-eligible, hence only used in district court)

3.3 The two ground sets actually pleaded / instituted

(A) IPR2024-00717 — Grounds 1 and 2. The Board's Institution Decision is quoted verbatim in the record as finding Petitioner "demonstrates a reasonable likelihood of prevailing in its challenge to claims 1–11 as obvious over Chinn, Takahashi, EX‑V7, and Kim (Grounds 1 and 2)." (Quoted at ptacts.uspto.gov/ptacts/public-informations/petitions/1558242/..., citing Paper 9 at 52.) Note the claim range 1–11 matches the '757's 11-claim set exactly — a strong confirmation that the IPR maps to this patent.

(B) E.D. Tex. 5:23-cv-00092 — Dr. R. Michael Guidash's seven grounds for claims 1, 5 and 9 (from Maxell's IPR-estoppel motion, .../petitions/1558236/...):

Ground Combination Status
1 Samsung Galaxy SIII asserted until SJ/JMOL
2 Galaxy SIII + Chinn + Takahashi asserted
3 Samsung Galaxy S10 asserted
4 Galaxy S10 + Chinn + Takahashi asserted
5 Galaxy SIII + Yamamoto + Takahashi asserted
6 Chinn + Yamamoto + Takahashi withdrawn 2024-11-11
7 Chinn + Yamamoto + Takahashi + Kim withdrawn 2024-11-11

Two features of this table matter for the § 103 opinion:

  1. The same three references (Chinn, Takahashi, Kim) appear in both the IPR and the district-court theory — the petitioner had redundant, mutually corroborating routes to the same result. That is the hallmark of a claim that is obvious, not of one whose patentability depends on a single fragile reference.
  2. The withdrawn grounds (6, 7) still teach something: Samsung had a fourth independent combination available and elected to drop it, i.e., the claim was reachable from Yamamoto + Takahashi as an alternative core as well.

4. Element-by-element obviousness of claim 1

4.1 Primary combination — Chinn + Takahashi + EX‑V7 + Kim (the instituted grounds)

Claim 1 element Supplied by Rationale
1.a plural photographing processes Chinn (camera application with multiple capture modes); Galaxy SIII/S10 Conventional
1.b audio input receiving command voice Chinn — voice-command capture; Chinn is the reference Maxell attacked on the "voice command" point, which confirms voice-triggered recording is Chinn's role Voice-activated shutters were well known (and are admitted prior art in JP 1-191840 A)
1.c touch display on a first surface Galaxy SIII/S10 system art; conventional smartphone hardware Not the point of novelty
1.d first camera on the same side as the display Chinn / Galaxy devices Front camera = standard from ~2010
1.e second camera on the opposite side Chinn / Galaxy devices Rear camera = standard
1.f recorder/storage Conventional Not the point of novelty
1.g voice → record first (front) image signal Chinn, with Takahashi and EX‑V7 supplying camera selection/voice-activation teachings. Maxell's opposition brief frames its argument as "Chinn does not disclose a voice command for enabling the first camera and disabling the second camera and that it would also not be obvious in view of Takahashi and EX‑V7" — i.e., Petitioner used Takahashi/EX‑V7 precisely to fill that gap Combination of a voice-activated capture reference with a camera-selection reference
1.h touch → record second (rear) image signal Touch-shutter iconography (Galaxy system art; EX‑V7 manual shows the camera UI conventions) Conventional
first standby > second standby The relative-delay concept comes from the admitted art (JP 1-191840 A); the specific apportionment comes from the problem itself (see §5) See motivation analysis

4.2 Backup / alternative combinations

  • Ground 2 / Ground 4 (Galaxy SIII or S10 + Chinn + Takahashi). This is the cleanest § 103 case because it uses § 102(a)(1) device art for every hardware element (dual cameras, touch display, camera-select UI, touch shutter) and Chinn/Takahashi only for the voice-trigger and the camera-selection logic. The only remaining question is the relative delay, which is a design choice on top of known structure.
  • Ground 5 (Galaxy SIII + Yamamoto + Takahashi). Reaches the claim without Chinn at all — proof that no single reference is load-bearing.
  • The "admitted art" combination: JP 1-191840 A + any dual-camera touch-screen phone. JP 1-191840 A already teaches a preset delay between command-voice recognition and photographing for the express purpose of obtaining a natural pose. Adding a second, opposite-side camera and a touch shutter to that camera is the routine modernization step the Federal Circuit has repeatedly held obvious (Leapfrog Enters. v. Fisher‑Price; "applying modern electronics to older mechanical devices"). The only step left is deciding which mode gets the long delay — and the specification's own reasoning supplies the answer (§5).
  • Grounds 6/7 (Chinn + Yamamoto + Takahashi [+ Kim]) — withdrawn, but confirm at least a fourth combination.

4.3 Claim 2 — "the first camera is enabled in accordance with the command voice"

This is the limitation Maxell fought hardest ("the prior art … does not disclose or render obvious a voice command for enabling the first camera and disabling the second camera"). Two independent reasons it is not a saving limitation:

  1. The Board rejected the premise. In the parallel '815 IPR the panel (APJ Trock) characterized the relationship between the voice command and the camera enabling/disabling as "coincidental, not causative," and Petitioner argued the same construction for the '757 ("Petitioner's Reply at 4–14 and discussed in detail during the oral argument"). Under that reading, Art need only show the first camera being enabled when the voice instruction is received, not that the voice caused the enabling. Any dual-camera device running a voice-shutter application satisfies this.
  2. Even on Maxell's narrower reading it is obvious. Voice-controlled camera-mode switching (e.g., spoken commands to change capture mode/torch/zoom) was routine in the 2010–2013 smartphone art; combining it with a voice shutter is an aggregation of two known voice features.

4.4 Claims 3 and 4 — standby times "settable or selectable by a user"

  • JP 1-191840 A expressly discloses a delay "set in advance" — i.e., a configured delay value. That is the claim 3/4 concept in the admitted art.
  • The '757's own specification concedes that "fixed values different from each other may be set … in advance, [or] arbitrary values may be set thereto by the user … a method may be used in which the standby times are selected from among a plurality of values prepared in advance" — a self-description of a conventional settings menu, not of an invention.
  • Exposing a delay constant as a user setting (or offering preset values in a menu) is the paradigm of an obvious design choice among a finite number of identified, predictable solutions (KSR, 550 U.S. at 421) and of MPEP § 2141 rationale (A) (known elements combined by known methods to yield predictable results). Digital cameras had user-selectable self-timer delays for decades; EX‑V7's manual is exactly that genre of art.

4.5 Claims 5 and 6 — displaying the elapse state of the standby time

  • A countdown/progress indication of a pending capture is the universally implemented self-timer UI on digital cameras and phone camera apps. The '757's own specification concedes the design is open: "the design of the timing display icon 341 may be variously represented. Instead of the progress bar, for example, a remaining time display according to countdown using a numerical value or an animation … any design may be employed as long as the remaining time can be roughly perceived."
  • Given the primary reference teaches a delay, communicating the remaining delay to the user is an obvious, if not obligatory, ancillary feature — a known technique applied to a known device with predictable results (MPEP § 2141 rationale (D)). MPEP § 2141 rationale (A) also applies: the display element was a familiar element (a timer indicator) used to improve the device in a way already known in the art.

5. Motivation to combine — why a POSITA would have arrived at claim 1

The '757's own background supplies the motivation, which makes this a particularly strong § 103 case (the specification is an admission of the problem, and the solution is the obvious answer to that problem).

  1. The problem was expressly known and stated in the art. The specification concedes that in self-portrait use of the in/front camera, "when voice recognition is made, and immediately the photographing process is started, there is a problem in that the user is photographed with the form of his mouth to be in a state immediately after the utterance of the command voice. In order to avoid this, it is necessary to delay the start of the photographing process after the voice recognition by a predetermined time." A reference that frames the objective problem this precisely is itself a teaching of the claimed solution.

  2. The two halves of the invention come from the same field of endeavor. Chinn, Takahashi, EX‑V7, Kim, Yamamoto and JP 1-191840 A are all camera/camera-phone capture-control art. Where all references are "in the same field of endeavor," the KSR and MPEP § 2141 motivation analysis is at its most favourable.

  3. The claimed asymmetry is dictated by physical constraint, not insight. When the subject is the photographer (front camera), the user cannot reach the shutter — so voice triggering is the natural trigger, and a delay is required to regain a pose. When the subject is remote (rear camera), the user is behind the device with a free hand on the touch display — so a touch shutter with effectively zero lag is optimal. Pairing voice→front/long-delay and touch→rear/short-delay is therefore the "next step" a skilled artisan would take as a matter of routine, not an inventive leap (cf. the UPC Local Division The Hague's reasoning in Maxell v. Samsung on routine modifications, https://www.meissnerbolte.com/de/upc/upc-aktualisierung).

  4. KSR rationales squarely met (MPEP § 2141):

    • (A) Known elements combined by known methods to yield predictable results — voice shutter + timer delay + dual-camera phone + touch shutter.
    • (C)/(D) Known technique applied to a known device ready for improvement — inserting a timer between recognition and capture, in a device already designed to accept mode-specific capture parameters.
    • (E)/(F) Design incentives / obvious to try — minimizing shutter lag for the far-subject case while allowing pose-recovery lag for the self-image case is routine capture-quality optimization, driven by the market demand for self-portraiture that Maxell's own background describes as pervasive.
    • (G) Teaching/suggestion in the art — JP 1-191840 A's express teaching that a preset voice-recognition-to-capture delay yields a natural pose is a direct suggestion to apply such a delay where a natural-pose problem exists — i.e., in the in-camera/self-image mode.
  5. Reasonable expectation of success. The modification is the insertion of a delay constant and a mode test. There is no unpredictability, no criticality of numerical ranges (the claim recites only a relative inequality, Ta < Tb), and the specification's own figures treat the delays as arbitrary user-settable values ("the standby time Ta … is close to zero").

  6. The specification's own comparative argument is an admission. The '757 argues it is better than JP 1-191840 A because in the prior art "a command voice is selectively used according to a photographing purpose, [so] the usability of the camera is degraded" — i.e., the patent's advance is removing a user step by automating the mode selection. Automating a previously manual selection, using information already available to the device (which camera is enabled), is a textbook obviousness scenario.


6. What the patent owner would (and did) argue — and why the record defeats it

Maxell's argument Record response
"Chinn does not disclose a voice command for enabling the first camera and disabling the second camera." The Board read those limitations as coincidental, not causative (oral argument, Paper 25 at 23:25–24:06, quoted in the record): the claim requires the state of enablement, not causation by the voice. On that reading Chinn + a camera-selection reference suffices.
The claim requires the same touch instruction to both start recording and switch cameras. The district court accepted that reading for non-infringement (May 2, 2025 order, applying In re Varma, 816 F.3d 1352 (Fed. Cir. 2016): one element performing two functions cannot be satisfied by two different elements). Note the double-edged effect: the narrow construction defeated infringement but constricted the claim, making it easier to find a narrower obviousness theory — the prior-art device need only show the front camera enabled/rear camera disabled at the moment the touch instruction is received.
Priority / written-description attack on the prior-art date. Relevant: the Board and the district court found certain claims not entitled to the 2013-09-12 priority date for lack of written description of an "encryption" limitation. ⚠️ Flag: the brief attributes those claims to "the '757 patent" as claims 21 and 24, which cannot be right for an 11-claim patent (see §1). If any '757 claim loses the 2013-09-12 date, the prior-art universe expands (e.g., more 2013–2019 art becomes § 102(a)(1) art), further strengthening § 103.
Secondary considerations. No objective indicia were preserved. The § 112/burden findings and the JMOL of invalidity mean there is no jury validity finding on the '757; the pretrial SJ of non-infringement meant the '757 was never tried in the May 2025 jury trial (which covered only the '086, '848 and '815 patents) — see RPX, https://litigation.rpxcorp.com/news/88110-maxell-s-112m-verdict-against-samsung-falls-in-posttrial-challenge. Any commercial-success argument would also be undercut by the nexus problem (Samsung's success is not attributable to the claimed differential standby delay).
Prosecution-conduct issues (procedural, not § 103). Samsung has alleged that Maxell failed to disclose the IPR2024-00717 Institution Decision to the examiner handling a continuation of the '757 — an alleged violation of 37 C.F.R. § 1.56. That bears on equitable defences in the family, not on the § 103 merits, but it should be noted when assessing risk across the family (US 11,696,021; US 12,284,437; US 2025/0227365).

7. Conclusion on each claim

Claim § 103 conclusion (probability-weighted)
1 Obvious. Chinn + Takahashi + EX‑V7 + Kim (instituted Grounds 1–2 of IPR2024-00717); alternatively Galaxy SIII/S10 + Chinn + Takahashi; alternatively JP 1-191840 A + a dual-camera touch smartphone. The only non-conventional feature is a relative delay inequality, supplied by the admitted prior art and by routine design choice. The PTAB has already so held.
2 Obvious. Voice-based camera enabling was known; the Board read the limitation as non-causative.
3, 4 Obvious. JP 1-191840 A discloses a pre-set delay; user-settable/preset-selectable timing is a routine design choice (self-timer precedent).
5, 6 Obvious. Countdown/progress display of a pending timed capture is ubiquitous self-timer UI; the specification concedes any design will do.
7–11 Not analyzed — not reproduced in the authoritative text supplied. Given the family's continuation practice (the '437 continuation adds an "encryption"-related limitation that the Board found unsupported), these claims carry heightened § 112 and priority risk that would feed back into § 103 by moving their effective filing date later.

8. Caveats, contradictions and items requiring verification

  1. IPR2024-00717 FWD text not retrieved. My element mapping rests on (a) the Board's institution statement as quoted in Samsung's opposition filing, and (b) the parties' characterizations. The precise disclosure findings for Chinn, Takahashi, EX‑V7 and Kim should be read directly from Papers 9 (Institution Decision) and the FWD.
  2. "All" vs. "most" claims invalidated. Law360 entries are inconsistent (see §1). Verify whether all of instituted claims 1–11 were cancelled, or whether some survived (the Nov 3, 2025 entry suggests some claims were not shown unpatentable).
  3. "Claims 21 and 24 of the '757 patent" — irreconcilable with the 11-claim record. Flagged as a likely citation to the '437 continuation or an error. Do not rely on it.
  4. Reference identifiers reproduced literally, not corrected: "JP 1-191840 A" (the '757's Patent Document 1); "JP 2001-305642 A"/"JP2001305642A" (Takahashi, as written in the exhibit list, which also renders it "JP2001305642A"); "EX‑V7" (Casio Exilim EX‑V7 User's Guide, EX1014); "U.S. Patent Publication No. 2014/0247368" (Chinn, EX1004); "U.S. Patent Publication No. 2010/0137026" (Kim, EX1008); "U.S. Patent Publication No. 2010/0026815" (Yamamoto, EX1009); "U.S. Patent Publication No. 2009/0167881" (Thorn, EX1011); "U.S. Patent Publication No. 2013/0124207" (Sarin, EX1013); "U.S. Patent No. 8,957,981" (EX1007).
  5. The unit of prior-art date is critical. Chinn (US 2014/0247368 A1, published 2014-09-04) can only be § 102(a)(2) art if its effective filing date precedes 2013-09-12. Confirm Chinn's filing/priority date; if it post-dates 2013-09-12, Ground 2/4 in the district court and Grounds 1–2 in the IPR collapse as to Chinn, and the analysis must be re-run on Yamamoto + Takahashi + Kim (Grounds 6/7) and on the Galaxy system-art grounds, which do not depend on Chinn.
  6. District court outcome posture. Maxell suffered pre-trial SJ of non-infringement on the '757 and did not try it; Samsung also obtained JMOL (Sept. 2025) overturning the $112M verdict on the three tried patents, and Maxell has appealed with a request to stay the appeal pending the PTAB proceedings. The '757's validity has therefore been adjudicated only at the PTAB, not by a jury — worth stating plainly in any opinion letter.

Key sources for this analysis: US11223757B2 (Google Patents, litigation/claims/description); https://www.docketalarm.com/cases/PTAB/IPR2024-00717/...; https://ptacts.uspto.gov/ptacts/public-informations/petitions/1558242/... (Board institution quote; '437/'757 claim-language dispute; exhibit list incl. Chinn/Takahashi/EX‑V7/Kim/Yamamoto); https://ptacts.uspto.gov/ptacts/public-informations/petitions/1558236/... (Maxell's estoppel motion listing Guidash Grounds 1–7 and the Nov. 11, 2024 withdrawals); https://scalejuris.com/news/12655/ptab-invalidates-maxell-video-processing; https://www.law360.com/cases/64f9fbca5ec7b902cacc45f2/articles; https://litigation.rpxcorp.com/news/88110-....

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