US 11778245

I'll search for this specific patent number and related litigation.

I have the patent's front matter. Now let me pull the claims and check for litigation/docket activity.

The patent's claim text isn't surfacing yet. Let me target the claims directly and check the listed litigation case numbers.

US 11,778,245 B2 — Summary

Caveat up front: I was able to retrieve and verify the patent's bibliographic data, abstract, and specification (the full text you supplied is the authoritative source), but I could not retrieve the issued claim set during my searches. Google Patents' extraction of this document (the "Definitions" section) captures specification phrases, not the numbered claims, and my searches did not surface the granted claim text. Accordingly, the claim overview below is inferred from the title and specification and is not authoritative — treat any statement about claim scope as unverified until the claim text is read directly.

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Bibliographic data (verified against the supplied full text)

Continuation chain (from the CROSS REFERENCE section): this patent is a continuation of Ser. No. 15/413,370 (filed Jan. 23, 2017), which is a continuation of Ser. No. 14/748,121 (now US 9,554,161), ← 14/265,258 (now US 9,064,271), ← 13/747,414 (now US 8,713,599), ← 12/191,261 (now US 8,359,612, filed Aug. 13, 2008). The application expressly rescinds any disclaimer of claim scope made in the parents and notes the claims here "may be broader than any claim in the parent application(s)." That matters for any claim-scope analysis: the issued claims are not necessarily coextensive with the 8,359,612 claims.

Abstract (verbatim from the record)

"A portable device includes solid-state memory, an Ethernet and/or wireless network connection, and an HDMI. The portable device receives content guide data from a first server and displays a content guide on a display. In response to a user's selection of a content item, the portable device requests the content item over the Internet from a second server. The portable device receives the content item, stores the content item in solid-state memory, generates display signals that represent the content item, and sends the display signals to a display. The second server may match the content item with relevant advertisements based on keywords associated with the content item and the advertisements. The second server may send selected advertisement URLs to the portable device. Using the URLs, the portable device may obtain the advertisements over the Internet and cause the display to display the advertisements in conjunction with the content item."

(Note the arguably odd "first server/second server" framing in the abstract versus the specification, where the HME server 104 and the content server play those roles.)

Plain-language overview of the disclosed subject matter

The specification (which is what I can verify) discloses:

1. A pocket-sized, hard-disk-free portable device with solid-state memory, Ethernet/wireless, HDMI, and an IR remote receiver (FIG. 2: 202, 204, 206, 208, 210, 212, 214).
2. A home media engine (HME) server that supplies user-interface commands and content-guide data over the Internet; the device renders UI signals to whichever TV/monitor it is plugged into.
3. Automatic keyword matching of advertisements to content items via a metadata database (content keywords vs. ad keywords).
4. Bid-based ad selection (advertisers bid; highest bids win the available ad slots), proactive/off-peak caching of ads based on bid rank and predicted presentation probability, and revenue models (billing advertisers, premium content billing, revenue sharing with content providers, selling UI control).
5. Timepoint-based ad insertion — the feature the title emphasizes: a content provider submits a list of timepoints at which ads may be inserted (optionally with per-timepoint content keywords and a maximum ad duration); the portable device or the HME server monitors progress, and when a timepoint is reached the presentation is interrupted so ads can be presented, with the server notified (e.g., to bill the advertiser).

Likely independent-claim structure (UNVERIFIED — inference only)

Based only on the title and the corresponding specification passages, I would expect something along these lines, but I cannot confirm the count of independent claims or the exact wording:

• A method claim: presenting content data at a device; detecting/reaching a timepoint relating to the content data; in response, interrupting the presentation to present additional content (e.g., an advertisement); and notifying a server over the Internet (e.g., that the timepoint was reached and/or that the additional content was presented).
• Possibly a system/apparatus claim (portable device with solid-state memory + network interface + display interface) and/or a non-transitory computer-readable medium claim reciting the same operations.

I do not know with confidence the number of independent claims, whether a system or CRM claim is present, or how the timepoint is expressed (elapsed playback time, frame reference, timestamp, etc.).

Litigation / docket status

• Google Patents' "Family has litigation" data for this family lists three U.S. district court cases in the Northern District of California: 5:26-cv-02811, 3:26-cv-02811, and 3:25-cv-11048 (source: Unified Patents litigation data, as displayed on the patent page; also a Darts-ip "first worldwide family litigation" link). Important: that flag is attached to the family, and I could not verify from the search results that US 11,778,245 specifically is an asserted patent in those cases rather than merely a family member caught by the family-level flag.
• Adeia's own reporting describes an NDCA declaratory-judgment action against Adeia Media entities (motion to dismiss filed March 13, 2026; granted with leave to amend June 18, 2026), plus Adeia complaints against DIRECTV (C.D. Cal., 2:26-cv-07222, filed July 2, 2026 per UniCourt) and against DISH/Sling (D. Colo., announced April 1, 2026), with DISH filing a retaliatory DJ action in California. I cannot confirm that US 11,778,245 is among the patents asserted in any of those 2026 actions.
• Federal Circuit: I found no CAFC docket or appeal involving 11,778,245. The CAFC 2026 material returned by search (e.g., appeal 26-117, Tessell) is unrelated. My searches were not exhaustive, and the tool budget was exhausted before I could query the CAFC docket by case name, so absence of a hit here should not be read as a definitive "no appeal exists."

Where I am uncertain

1. The claims. This is the significant gap. I have not verified the issued claim language, independent-claim count, or scope for US 11,778,245.
2. Whether this specific patent (vs. the 8,359,612 family) is in suit, and the plaintiff/defendant posture in NDCA 5:26-cv-02811, 3:26-cv-02811, and 3:25-cv-11048.
3. Reassignment/ownership details (the security interests from HPS Investment Partners, Morgan Stanley Senior Funding, and Bank of America, and the 2024 change of name) are as listed on Google Patents and are not a substitute for the USPTO assignment records.

If you want the claim overview firmed up, the definitive next step is to pull the claim text directly from the USPTO PatentCenter/Patent Public Search record for application 16/102,206 or the granted PDF for US 11,778,245 (patents.google.com/patent/US11778245B2/en and the linked USPTO PatentCenter entry).

I'll research litigation involving US patent 11778245. Let me search multiple sources.

Let me search more specifically for the case numbers and litigation databases.

I found key cases. Let me dig deeper to confirm whether US 11778245 is specifically at issue in these cases.

Litigation Involving U.S. Patent No. 11,778,245

Below is what I was able to confirm from the authoritative patent record and from litigation/company sources. Important caveat up front: U.S. 11,778,245 ("the '245 patent") is a TiVo/Adeia portfolio patent (continuation of a chain going back to application 12/191,261, priority date 2008‑08‑13). The cases tied to it are declaratory-judgment actions brought against the patent owner (Adeia/TiVo), and I was not able to verify from available search results which specific patent numbers are recited in those complaints. I flag that limitation explicitly rather than assert more than the record supports.

Cases tied to the '245 patent (per Google Patents litigation data)

The patent's own Google Patents page (https://patents.google.com/patent/US11778245/en) lists the following as "Family has litigation" — all in the U.S. District Court for the Northern District of California:

The page also flags a "First worldwide family litigation filed" reference via Darts‑ip (family 41682050), but provides no independent case detail.

1. DIRECTV, LLC v. Adeia Inc. et al — N.D. Cal., No. 3:25-cv-11048

• Plaintiff: DIRECTV, LLC
• Defendants: Adeia Inc.; Adeia Guides Inc.; Adeia Media Holdings LLC; Adeia Technologies Inc.; Adeia Media Solutions Inc. (collectively "Adeia Media")
• Jurisdiction: U.S. District Court, Northern District of California
• Case No.: 3:25-cv-11048
• Cause of action: 28:2201 Declaratory Judgment (Nature of Suit 830 – Patent)
• Filed: December 29, 2025
• Substance: DIRECTV sought a declaratory judgment of non‑infringement of seven Adeia Media patents and a declaratory judgment of invalidity of three (different) Adeia Media patents (per Adeia's 10‑K filing, https://investors.adeia.com/static-files/219a54b3-aeb9-42bf-bf6a-2bd3543020c0).
• Status/Outcome: On March 13, 2026, Adeia Media moved to dismiss. On June 18, 2026, the court granted the motion to dismiss with leave to amend. The action remains pending; no trial date set. (Adeia 10‑K annual report, FY2025.)

2. DISH Network LLC v. Adeia Inc. — N.D. Cal., No. 5:26-cv-02811

• Plaintiff: DISH Network LLC
• Defendant: Adeia Inc.
• Jurisdiction: U.S. District Court, Northern District of California
• Case No.: 5:26-cv-02811
• Cause of action: Declaratory Judgment (Nature of Suit 830 – Patent)
• Filed: April 1, 2026
• Status: Open/pending (no outcome reported as of the available results).
• Note on the second number: Google Patents separately lists 3:26-cv-02811 in the same district. This is consistent with a division/reassignment of the same DISH action within N.D. Cal. (San Jose "5:" vs. San Francisco "3:" designation), but I could not independently confirm that the two numbers are one and the same case — treat it as an open item.

3. Related action (context, not a direct '245 suit): Adeia Media v. DIRECTV — S.D.N.Y.

• Filed: January 12, 2026, U.S. District Court for the Southern District of New York
• Substance: Adeia Media's complaint against DIRECTV for breach of contract and misappropriation of trade secrets under the Defend Trade Secrets Act. On January 15, 2026, Adeia Media moved for a preliminary injunction asking the court to order DIRECTV to withdraw its N.D. Cal. DJ action and cease use of Adeia's confidential information. DIRECTV responded February 10, 2026; Adeia replied February 23, 2026.
• This is the companion/offensive response to the DIRECTV declaratory-judgment action above. It is not itself a case asserting the '245 patent, but it directly relates to the dispute that generated the N.D. Cal. DJ case.

What I could NOT confirm

• Whether 11,778,245 is one of the specific patents named in either the DIRECTV or DISH declaratory-judgment complaints. The Google Patents "family has litigation" linkage places the patent in these cases, but the complaint-level patent lists I could retrieve for the DIRECTV action (’528, ’526, ’010, ’961, etc.) did not include the '245 number in the excerpts available to me, and I could not retrieve the DISH complaint text. I recommend pulling the actual complaints (N.D. Cal. ECF) or the Adeia 10‑K patent schedules to confirm the exact asserted/declared-on patent numbers.
• No CAFC appeal involving the '245 patent was found.
• No PTAB/IPR proceeding specific to the '245 patent was found in the results (the IPR material that surfaced concerned unrelated patents).
• No affirmative infringement suit in which Adeia/TiVo asserted the '245 patent was found; the identified litigation is defensive (DJ) and contractual.

Summary

The only litigation currently tied to U.S. 11,778,245 are three N.D. Cal. entries reflected in the patent's own litigation record — the DIRECTV, LLC v. Adeia Inc., 3:25-cv-11048 declaratory-judgment action (filed 12/29/2025; motion to dismiss granted with leave to amend 6/18/2026; pending) and the DISH Network LLC v. Adeia Inc. declaratory-judgment action at 5:26-cv-02811 / 3:26-cv-02811 (filed 4/1/2026; pending), plus the related SDNY Adeia v. DIRECTV breach-of-contract/trade-secret action. I could not verify that the '245 patent is specifically named in those complaints, so that linkage should be confirmed against the primary court filings before being relied upon.

Sources: Google Patents US11778245B2 (litigation data attributed to Unified Patents and Darts‑ip); PacerMonitor case page 3:25-cv-11048; Adeia Inc. Form 10‑K (FY2025) at investors.adeia.com; Ex Parte AI case dockets for 3:25-cv-11048 and 5:26-cv-02811.

Note: Some sources rendered the assignee as "Adelia" — that is an OCR artifact; the correct entity name is "Adeia."

I'll verify the structured data against live sources before writing.

The second result references a different '117 patent (Samsung/Vizio/LG/Hisense). Let me pin down whether any IPR names this patent or its family.

No IPR hits on the patent itself yet. Let me check the litigation history and any 2025–2026 petitions against this family.

Proceedings overview

Total AIA trial proceedings on file: 0. The USPTO Open Data Portal returns no IPR, PGR, or CBM naming US 11,778,245, and I could not corroborate any petition against this patent (or its application, 16/102,206) through targeted web searches of PTAB filings and litigation reporting — so the breakdown is 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials, and the defensive posture is "no PTAB track record either way": the patent has never been tested at the Board, so a defendant cannot point to canceled claims as res judicata-style leverage, but also faces no adverse FWD or estoppel that would make a first-filed IPR a wasted effort. Treat the absence as an open window, not as evidence of strength.

No proceedings to report

There is no proceeding number to list. Rather than populate the template with invented case numbers, the relevant content is the verification trail and the caveats below.

• Type / Filed / Status / Panel / Grounds / Institution / FWD / Settlement / Appeal: not applicable — no proceeding exists.
• Verification note (structured source): the supplied "PTAB proceedings on file" block confirms the ODP query returned no AIA trial proceedings as of the most recent ingest. The ODP index is the canonical list and is normally complete for IPR/PGR/CBM petitions once docketed; the practical gap is same-day petitions not yet ingested.
• Verification note (independent): searches for petitions naming 11,778,245 returned nothing. I also searched for AIA challenges to earlier members of this continuation chain (12/191,261 → US 8,359,612 → US 8,713,599 → US 9,064,271 → US 9,554,161 → 15/413,370 → 16/102,206) and could not substantiate an IPR/PGR naming any of them. I cannot state with certainty that no family member was ever challenged pre-2018, because PTAB dockets for older cases are not fully surfaced by general web search — that residual uncertainty should be cleared against PTAB E2E before relying on it.
• ⚠ False-positive caution — a different "the '117 patent": a PTAB filing in a 2025 proceeding summarizes four IPRs against "the '117 patent" — IPR2018-01262 (Samsung, filed 2018-06-15), IPR2020-00043 (Vizio, filed 2019-10-15), IPR2020-01283 (LG and Hisense, filed 2020-07-16) and IPR2020-01337 (LG and Hisense, filed 2020-07-21), all denied institution (three on the merits, IPR2020-00043 discretionarily under § 314(a) in view of parallel litigation). That document (https://ptacts.uspto.gov/ptacts/public-informations/petitions/1553843/download-documents) is textually about a different patent: the challenged claims (1, 2, 4–7, 9, 13–16, 18–20) and the art (Thayer, Godwin, Toffolo, Morris, Oki, Weindorf, Bruning, Yanagucchi, Fujimaki, Ottenstein, Henry) are display/backlight art and the petitioners are TV OEMs — not the portable-media-device subject matter of 11,778,245, and not the Barton/TiVo family. Do not import those four denials into this patent's file. Anyone doing docket research on "the '117 patent" in the TiVo/Adeia portfolio should confirm the patent number digit-for-digit.

Strategic summary

Claim-status picture. Because no AIA trial was ever instituted, no claim of US 11,778,245 has been canceled, narrowed, or adjudicated unpatentable at the Board. Every claim is untested at the PTAB rather than sustained. That is materially different from a "survived IPR" posture: an FWD upholding claims gives the patent owner a hardened asset and gives a defendant a bad estoppel/optics problem, whereas here the patent simply has a clean, empty PTAB record. The corollary is that there is no PTAB-confirmed narrowing to lean on and no certified claim construction to borrow. Separately, note that this is a continuation granted 2023-10-03 from an application filed 2018-08-13 claiming benefit back to 2008-08-13, with an anticipated expiration of 2028-08-13 — so the commercial runway is roughly two years and the family's exposure strategy (many sibling continuations, including US 11,778,248, US 11,985,366, US 12,063,396 and US 12,328,459) is the more likely battleground than this single patent.

Estoppel landscape. No § 315(e)(1) or § 315(e)(2) estoppel attaches to anyone. Estoppel is generated by a final written decision in an instituted IPR (or by termination after institution), and neither exists here. Consequently every prior-art ground — including grounds that could have been raised — remains fully available to any defendant in district court, and any defendant (or third party) remains free to file a first IPR without risking a General Plastic-style "follow-on petition" problem. The only practical estoppel-like constraints are ordinary district-court ones (e.g., IPR-time-bar math under § 315(b), and any stipulation a defendant chooses to make).

Pattern signals. This is an Adeia (formerly TiVo/Rovi) media patent, and the patent owner's revealed preference across the portfolio has been licensing campaigns backed by district-court and ITC pressure rather than PTAB trials, with several campaigns ending in licenses/settlements (e.g., the Disney litigation resolved in December 2025 with a long-term license). There is no defensive aggregator (Unified Patents, RPX, etc.) visible in this patent's chain. The family now has live litigation in the Northern District of California: Google Patents' family-litigation field lists N.D. Cal. matters 3:25-cv-11048, 3:26-cv-02811 and 5:26-cv-02811 for this family, and Adeia's public reporting describes (i) a DIRECTV declaratory-judgment action filed 2025-12-29 in N.D. Cal. seeking noninfringement of seven Adeia Media patents and invalidity of three (Adeia's motion to dismiss granted with leave to amend on 2026-06-18) and (ii) a further N.D. Cal. DJ action filed 2026-04-01 against Adeia Media as to ten Adeia Media patents, stayed 2026-07-09 pending the DISH bankruptcy. I could not confirm which of those captioned matters, if any, names 11,778,245 specifically — verify against the complaints before relying on it. There is no Federal Circuit appeal involving this patent that I can identify.

Recommended next steps

• If you are a defendant: because there is no FWD, there is nothing to quote and no canceled claim to cite. The immediate work is (1) confirm on PTAB E2E (https://ptacts.uspto.gov/ptacts/) and the PTAB Decisions page (https://www.uspto.gov/patents/ptab/decisions) that no petition against 11,778,245 or its siblings (11,778,248, 11,985,366, 12,063,396, 12,328,459, 11,070,853, 11,368,728, 11,343,546, 11,330,308, 11,317,126, 11,350,141) has been filed, and (2) calendar the § 315(b) one-year deadline from service of the complaint on you — that is the single date that decides whether an IPR remains available at all.
• Trial-stage milestones if you file: an IPR filed today would draw a § 314(b) institution decision at roughly six months and a § 316(a)(11) final written decision at no later than twelve months from institution, with an oral hearing typically about two to three months before the FWD. That timeline is what makes an early filing attractive here: there is no prior-instituted IPR of this patent for the Board to coordinate or deny under General Plastic / § 314(a) follow-on concerns.
• Bucket the art now: since no estoppel exists and no ground has been "reasonably could have raised"-limited, treat the prior-art search as unconstrained — including the 2018–2023 intervening art that was never before the examiner on this continuation (the disclosure describes ad-matching on content keywords, timepoint insertion of advertisements, pre-fetching/remote cache management, and notifying a server upon presentation, all of which are areas with dense post-2008 art).
• Preserve the district-court record: the absence of PTAB activity means validity will be litigated in court first unless you change that. If you intend to file an IPR, file before substantial district-court investment in invalidity to keep discretionary-denial and estoppel arguments clean.
• Bottom line for the demand-letter scenario: you cannot say "claims 1–5 have been canceled." You can say the opposite of the hardened-patent scenario too — this patent has never been through institution, so nothing about its validity has been insulated from challenge.

Confidence and limits: the "zero proceedings" conclusion is high-confidence as to the ODP-sourced list and as to this patent number; it is medium-confidence as to family members, because complete historical PTAB docket coverage for pre-2018 cases is not reliably searchable from the open web. I have deliberately not supplied judge-panel names, petition grounds, institution reasoning, FWD dispositions, settlement terms, or appeal docket numbers, because none exist for this patent and inventing them would be worse than the blank.

I'll research the assignment record for US 11,778,245, starting with the USPTO Assignment Center and cross-referencing Google Patents legal events and SEC filings.

Let me pull the Google Patents legal events and search for the specific recorded assignments and correspondents.

This TTABVUE filing appears to contain TiVo's assignment chain. Let me dig into it and search for the specific reel/frame records.

I hit the tool-step limit before I could query assignmentcenter.uspto.gov directly, so the reel/frame data below is drawn from (a) the authoritative Google Patents legal-events extract in the record you supplied, (b) a TTABVUE filing that reproduces TiVo Solutions Inc.'s recorded assignment table, and (c) EP/register and SEC corroboration. I flag every place I could not verify a reel/frame.

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Inventors

James M. Barton — sole named inventor on US 11,778,245.

• Employer at time of filing: TiVo Inc. (Alviso/San Jose, CA). Barton was a co-founder of TiVo (1997) and served as VP of R&D, then Chief Technology Officer, per TiVo's own executive disclosures and the Goldwasser arbitration record (which repeatedly refers to "the Barton Patent," U.S. 6,233,389). The '245 application (Ser. No. 16/102,206, filed 2018‑08‑13) is a continuation of 12/191,261, filed 2008‑08‑13, so the inventive work dates to his TiVo CTO tenure.
• Notable: sole-inventor, single-assignee, and the examiner record shows the same inventor across the entire continuation chain (Barton is also inventor on the sibling '346, '308, '126, '141, '748, '366, '096 and '859 members). There is no "inventors departed within 12 months of filing" red flag — this is a career inventor whose employer is the assignee.

Original assignee

TiVo Solutions Inc. (named on the issued patent; "Original Assignee: Tivo Solutions Inc." per the front-page record).

• Line of business: TiVo is the DVR/personal-video-recorder pioneer (hardware + subscription service + technology licensing). TiVo Inc. was reorganized out of existence as an operating parent and merged into TiVo Solutions Inc. (merger dated 2016‑09‑07, recorded at the USPTO as a Change of Name on 2018‑10‑12; the EP register states TiVo Inc. was "registered as Applicant/Proprietor in place of TIVO INC. … by virtue of merger dated 07.09.2016").
• Did they ship a product embodying the '245 claims? The specification describes a pocket-sized, hard-disk-free portable device with solid-state memory + HDMI that streams downloaded Internet content (with ad insertion) to any TV. TiVo's commercial line was set-top DVRs; I could not verify a TiVo-branded product that ships the specific portable/HDMI ad-insertion claims. Treat "product embodying the claims" as unverified.
• Current status: Operating as a licensing subsidiary, not dissolved. TiVo Solutions Inc. is now Adeia Media Solutions Inc., part of Adeia Inc. (NASDAQ: ADEA) — the pure-play IP-licensing company separated from the Xperi product business in 2022. TiVo (as an operating brand) was subsumed into the Rovi/TiVo → Xperi (2020) → Adeia/Xperi (2022) transactions.

Assignment timeline

Caveat: Google Patents supplies the recording dates and the assignor/assignee/conveyance text as shown below, but not reel/frame numbers. I could verify a reel/frame for only one entry (the 2020 secured-party release, reel 6971/0011, from a TTABVUE filing that lists TiVo Solutions Inc.'s conveyances as "Assignment 7 of 8"). All other reel/frame values are unverified — do not treat them as recorded facts. Direct verification: https://assignmentcenter.uspto.gov/ (search patent number 11778245).

1. Executed ~2008‑08 (unverified) / recorded 2018‑10‑12 — Reel not verified

   • Conveyance: Assignment (Assignment of Assignors' Interest)
   • Assignor: Barton, James M.
   • Assignee: TIVO INC. (California)
   • Correspondent: not verified (prosecution firm of record; see note below)
   • Context: Initial inventor-to-employer assignment (recorded against the 2018 continuation to perfect the chain).

2. Recorded 2018‑10‑12 — Reel not verified

   • Conveyance: Change of Name
   • Assignor: TIVO INC.
   • Assignee: TIVO SOLUTIONS INC.
   • Correspondent: not verified
   • Context: Internal reorganization / merger — not an arm's-length sale (TiVo Inc. merged into TiVo Solutions Inc.).

3. Recorded 2019‑11‑22 — Reel not verified

   • Conveyance: Security Interest (security agreement)
   • Assignor: TiVo Solutions, Inc.; Rovi Guides, Inc.; Rovi Solutions Corporation; Rovi Technologies Corporation; VeVeo, Inc.
   • Assignee: HPS Investment Partners, LLC, as Collateral Agent
   • Correspondent: not verified
   • Context: Securitization — blanket lien on the TiVo/Rovi patent portfolio as loan collateral.

4. Recorded 2019‑11‑25 — Reel not verified

   • Conveyance: Patent Security Agreement
   • Assignor: same TiVo/Rovi group
   • Assignee: Morgan Stanley Senior Funding, Inc., as Collateral Agent
   • Correspondent: not verified
   • Context: Securitization — parallel/refinancing secured credit facility.

5. Recorded 2020‑06‑01 — Reel not verified

   • Conveyance: Security Interest
   • Assignor: TIVO SOLUTIONS INC. and a wide grantor group (Rovi Guides/Solutions/Technologies, VeVeo, Tessera & Invensas entities, DTS, iBiquity, Pharos)
   • Assignee: Bank of America, N.A.
   • Correspondent: not verified
   • Context: Securitization — large multi-entity credit facility (post Xperi/TiVo combination).

6. Recorded 2020‑06‑05 — Reel 6971/0011 (corroborated; frame may be 0011 vs. 0111 — verify), 15 pages

   • Conveyance: Release by Secured Party (Release of Security Interest)
   • Assignor: MORGAN STANLEY SENIOR FUNDING, INC.
   • Assignee (released parties): Rovi Technologies, Rovi Solutions, VeVeo, Rovi Guides, TiVo Solutions Inc.
   • Correspondent: SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP — Monique L. Ribando, New York, NY (recurrence note: Skadden/Ribando is the correspondent of record on this TiVo Solutions recording. Skadden is a large full-service firm that does the patent-recording work for the TiVo/Rovi operating group; a single appearance is not an NPE-troll tell. I could not confirm Ribando on any other link of this chain.)
   • Context: Release of security interest (lien cleaned off the portfolio).

7. Recorded 2020‑06‑05 — Reel not verified

   • Conveyance: Release of Security Interest
   • Assignor: HPS Investment Partners, LLC
   • Assignee (released parties): same TiVo/Rovi/VeVeo group
   • Correspondent: not verified
   • Context: Release of security interest.

8. Executed (effective) 2022‑08‑15 / recorded 2024‑09‑27 — Reel not verified

   • Conveyance: Change of Name (not an assignment of interest)
   • Assignor: TIVO SOLUTIONS INC.
   • Assignee: ADEIA MEDIA SOLUTIONS INC.
   • Correspondent: not verified (the EP register records the corresponding address change from 2160 Gold Street, San Jose CA 95002 → 3025 Orchard Parkway, San Jose CA 95134)
   • Context: Change of name only — part of the Xperi/Adeia separation; same corporate person, new name, no change in beneficial ownership.

(Priority events on the Google Patents page — "Priority to US16/509,326," "…17/138,531," "…18/227,802," etc. — are domestic-priority claims to continuation applications, not assignments, and are excluded from the chain above.)

Timeline diagram

timeline
    title Ownership of US 11778245
    2008 : Barton assigns to TiVo Inc
    2016 : TiVo Inc merged into TiVo Solutions Inc
    2018 : Assignment and name change recorded
    2019 : HPS security interest recorded
         : Morgan Stanley security interest recorded
    2020 : Bank of America security interest
         : Lender releases recorded Jun 2020
    2022 : TiVo Solutions renamed Adeia Media Solutions
    2023 : Patent issued Oct 2023
    2025 : DIRECTV declaratory judgment filed
    2026 : DISH declaratory judgment filed

NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT. Every link moves between (i) the original operating parent (TIVO INC. → TIVO SOLUTIONS INC., a merger-driven change of name, recorded 2018‑10‑12), (ii) institutional lenders acting as collateral agents (HPS 2019‑11‑22; Morgan Stanley 2019‑11‑25; Bank of America 2020‑06‑01), or (iii) a change of name to Adeia Media Solutions Inc. (2024‑09‑27). No "IP Holdings/Licensing/Ventures" purpose-built LLC, no registered-agent-service address. The recorded addresses are genuine corporate offices (2160 Gold Street, San Jose → 3025 Orchard Parkway, San Jose).

2. Known asserter in the chain — PRESENT (partial / qualified). The current assignee, Adeia Media Solutions Inc. (Adeia Inc., NASDAQ: ADEA), is a pure-play IP-licensing entity with no product revenue — it describes itself as an "intellectual property management and licensing business" formed from the Xperi/TiVo merger. It is a high-frequency patent plaintiff (see the earlier litigation section: DIRECTV DJ, 3:25-cv-11048; DISH DJ, 5:26-cv-02811/3:26-cv-02811). It does not appear on the classic NPE rosters (Acacia, Marathon, Intellectual Ventures, Wi-LAN/Conversant, Vringo, Pendrell, Round Rock, etc.) — it is the original innovator's own successor, not a third-party aggregator. Cite: reassignment to Adeia Media Solutions Inc. recorded 2024‑09‑27.

3. Repeat correspondent across the chain — NOT PRESENT (insufficient evidence). The only correspondent I could attribute is Skadden, Arps, Slate, Meagher & Flom LLP / Monique L. Ribando, New York, NY on reel 6971/0011 (the 2020 release by secured party). One appearance by a large full-service firm representing the operating group is not the "single lawyer running a family of shells" pattern; I could not confirm any recurrence.

4. Cascading transfers — NOT PRESENT. Eight recorded conveyances span 2008–2024; the post‑2018 activity is securitization plus a name change, not multiple chained LLC transfers inside 24 months. No shared correspondent-address clustering.

5. Pre-litigation transfer — NOT PRESENT. The only event near the litigation window is the 2024‑09‑27 change of name to Adeia Media Solutions Inc., which is a pure name change, not a transfer of title, and it precedes the earliest identified suit (DIRECTV, filed 2025‑12‑29) by ~15 months. There is no assignment executed within 6 months before a suit naming this patent.

6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 proceeding for TiVo Solutions Inc., Xperi, or Adeia was found; the 2019–2020 lien recordings and 2020 releases are ordinary secured financing, not distress sales.

7. Privateering — UNCLEAR / partially present. The 2022 Xperi–Adeia separation carved the patent portfolio into a standalone public licensing company (Adeia) while the product business stayed at Xperi. That is an "IP separation" with privateering-like optics. However, Adeia is the same corporate successor-in-interest asserting for its own account, not an operating company covertly funding a proxy NPE against its rivals, so it does not cleanly fit the privateering template.

8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. The patent is live and assertive (three N.D. Cal. litigation flags on the family record), not neutralized.

Verdict

NPE — moderate confidence.

The chain documented above (reel 6971/0011 release, 2020‑06‑05; HPS/Morgan Stanley/BofA security interests 2019‑11‑22/25 and 2020‑06‑01; change of name to Adeia Media Solutions Inc. recorded 2024‑09‑27) shows no classic troll mechanics — no shell-LLC transfer, no cascading transfers, no pre-litigation assignment, no bankruptcy sale. The sole reason this lands as an NPE rather than an "operating-company assertion" is that the current owner (Adeia Media Solutions Inc.) is an undisputed non-practicing licensing entity that does not ship products and is actively litigating (DIRECTV and DISH declaratory-judgment actions). Notably, however, that entity is the original innovator's own corporate successor (TiVo → Rovi → Xperi → Adeia), not a third-party assertion vehicle — so this is best characterized as a legitimate public IP-licensing company, not a vexatious shell operation.

Confidence caveat (material): I could not reach the USPTO Assignment Center to capture reel/frame numbers for links 1–5, 7, and 8, and I could not retrieve the correspondent of record for any entry except reel 6971/0011 (Skadden/Ribando). Before relying on this chain in a diligence or enforcement context, pull the reel/frame and correspondent fields directly at https://assignmentcenter.uspto.gov/ (patent 11778245) — the correspondent field is the field most likely to sharpen or dispel the repeat-correspondent signal, and it is the one field I could verify for only a single link.

Verify: https://assignmentcenter.uspto.gov/ • https://assignment.uspto.gov/patent/index.html (search "11778245")

I'll research the prior art citations for US 11,778,245. Let me start with targeted searches.

The searches are returning unrelated EPO search reports. Let me target the Google Patents citation data and the family members directly.

I found a strong lead: US 11,778,245 shares its exact title with US 10,051,296 (Barton), and I have family citation data for US 8,359,612. Let me pull the actual front-page references for the '245 patent and its sibling.

Prior Art for U.S. Patent No. 11,778,245 — Findings and Limits

Bottom line up front (read this before the tables)

I ran targeted searches against the patent record and the USPTO-facing sources, and I have to flag a material evidentiary gap rather than paper over it:

I was not able to retrieve the authoritative, front-page "References Cited / U.S. Patent Documents" list for U.S. 11,778,245 (application 16/102,206) itself from a primary source within my search budget. Google Patents' extraction of this document does not expose the numbered claim set or the (56) references table in the text I could reach, and the queries I ran surfaced large volumes of unrelated EPO/PCT search reports (textile machinery, cell cultures, connectors) rather than the '245 reference list.

This matters because your task asks for each patent citation for 11,778,245 with a §102 anticipation mapping. I can give you (a) the citation lists I did verify for the closest family members that share this specification, and (b) clearly-labeled candidates — but I cannot honestly present a per-reference §102 claim map for the '245 patent when I have neither the '245 reference list nor the '245 claim text. Per the operating rules, I am saying so explicitly rather than fabricating the table.

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1. What the USPTO-record search for 11778245 confirmed

The number-specific search confirms the same bibliographic core already established in the earlier sections (which I am not repeating): US 11,778,245 B2, application 16/102,206, filed 2018‑08‑13, issued 2023‑10‑03, inventor James M. Barton, earliest priority 2008‑08‑13, in the continuation chain rooted at 12/191,261 (now US 8,359,612).

One new, directly relevant finding from this search: a sibling patent with the identical title —

US 10,051,296 B2 (Barton) — "Interrupting presentation of content data to present additional content in response to reaching a timepoint relating to the content data and notifying a server over the internet."

Because 16/102,206 is a continuation of 15/413,370 (filed 2017‑01‑23), and US 10,051,296 issued in July 2018 from an application in that same chain, US 10,051,296 and US 11,778,245 share substantially the same specification. The examiner-cited references on the US 10,051,296 front page are therefore the best proxy available to me for the art considered against this disclosure. I present them below as a proxy, explicitly labeled as such — not as the '245 citation list.

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2. References verified on the sibling patent US 10,051,296 (proxy for the '245)

These appeared on the US 10,051,296 front page marked "* cited by examiner." The trailing codes are the classification and the examined-art field as printed (H04N/G06Q classes, right-column art units):

Critical caveat on §102 dates. All three publications post-date the '245 earliest priority date of 2008‑08‑13. That means, standing alone, their publication dates do not qualify them as §102(a)(1)/(a)(2) prior art against a claim entitled to the 2008 priority date. They could only be prior art as §102(e) / pre-AIA §102(e) references by virtue of an earlier effective U.S. filing date. I could not verify their underlying filing dates within the search budget, so I cannot confirm they clear the 2008‑08‑13 bar. See also the alternative in §4 below (claims not entitled to the 2008 priority date).

A note on P‑1. Available data associates a document numbered 2009/0100468 with both an inventor "Shaffer" and with Cisco Technology, Inc. (priority 2007‑10‑10, publication 2009‑04‑16). I cannot reconcile those two records confidently, so treat the assignee/inventor attribution of P‑1 as unverified and confirm against the document itself.

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3. References verified for the root family patent US 8,359,612 (also a proxy)

US 8,359,612 is the first patent in this continuation chain (the specification that the '245 incorporates by reference). Its citation list is verified (PubChem record). This is the art that was considered against this same disclosure at the start of the family, so several of these likely carried forward into the later continuations:

I did not individually pull the bibliographic data or content of R‑1 through R‑7, R‑9 through R‑11, so I am deliberately not assigning titles or §102 mapping to them — that would be fabrication. R‑8 I can identify because it is the same inventor's own related application (US 8,261,300), which is not prior art against the '245 (common ownership / same inventive entity) and is flagged here only for completeness.

Forward citations are not prior art. The "Cited By" lists that surface for this family (e.g., the Verisign URL-keyword-navigation patents US 9,646,100, US 9,811,599; the TiVo US 10,097,885; and US 2009/0100468 as a citing entry on some pages) are later documents that cite this family. They cannot anticipate the '245 and should be excluded from any §102 analysis.

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4. Why I will not yet give you a per-claim §102 anticipation table

To map a reference to "which claim(s) it potentially anticipates under 35 U.S.C. § 102," I need three things, and I currently have only part of one:

1. The issued '245 claim set — not retrieved (the earlier summary flagged this too; this search did not close the gap). Without claim language I cannot identify independent-claim count, claim type (method / system / CRM), or the limitations that would need to be met element-by-element.
2. The definitive '245 (56) reference list — not retrieved. I have proxies from two siblings, not the '245 list.
3. The content of each reference — not retrieved for the P‑1–P‑3 and R‑1–R‑11 set (beyond classification fields).

An important cross-reference / contradiction flag: the earlier "Patent summary" section already recorded that the '245 specification expressly rescinds any disclaimer of claim scope in the parents and states the claims "may be broader than any claim in the parent application(s)." Two consequences for prior art:

• The '245 claims are not necessarily coextensive with US 8,359,612's claims, so a reference that was overcome in the '612 prosecution does not automatically fail against the '245.
• Conversely, because this is a continuation filed in 2018 off a 2017 parent off a 2008 root, if any '245 claim is later held not entitled to the 2008‑08‑13 priority (new matter / lack of written-description support), the effective critical date shifts toward 2017 and the P‑1–P‑3 (2009) references — and a large body of 2009–2017 art — become squarely available under §102(a)(1). That is the single most important prior-art consequence of this family's structure, and it is why I flag the date issue rather than dismiss these references.

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5. Where the "brief description + §102 claim" mapping can legitimately go next

To complete your task properly, pull these primary documents and I can build the element-by-element §102 chart:

1. US 11,778,245 B2 granted PDF / Patent Public Search (App. 16/102,206) → the (56) "References Cited" list and the claims. (patents.google.com/patent/US11778245B2/en; USPTO PatentCenter.)
2. US 10,051,296 B2 full document → confirm the P‑1–P‑3 citations and, crucially, their effective filing dates for the §102(e) analysis.
3. US 8,359,612 B2 full document → confirm the R‑1–R‑11 list and read R‑4 (US 6,981,045) and R‑5 (US 2006/0095472), which by class are the most likely advertisement-insertion/streaming anticipatory candidates.

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Explicit uncertainties

• The '245 (56) reference list is not verified. The P‑1–P‑3 and R‑1–R‑11 sets are verified for sibling/root family members, not for the '245.
• The '245 claim text is not verified, so no claim numbers are assigned above; any claim-level §102 statement would be speculative.
• §102(e) dates for P‑1–P‑3 are unverified; their 2009 publication dates fall after the 2008‑08‑13 priority date and do not by themselves establish prior-art status.
• Attribution of P‑1 (Shaffer vs. Cisco Technology) is inconsistent across sources and is flagged as unresolved.
• Unrelated search noise (EPO/PCT reports on textile machinery, cell cultures, electrical connectors) was excluded; those documents have no bearing on the '245.

Sources: Google Patents US11778245B2 (https://patents.google.com/patent/US11778245B2/en); US 10,051,296 B2 front-page references (patentimages.storage.googleapis.com/.../US10051296.pdf); PubChem patent record for US‑8359612‑B2 (citation list); USPTO PatentCenter (App. 16/102,206).

I'll first try to close the two gaps the Prior Art section flagged — the '245 claim text and the content of the proxy references — before building the §103 analysis.

Let me pull the '245 claim text and the front-page references from Justia/other primary-facing sources.

Excellent — I now have the published claim set (from the '245's own pre-grant publication). Let me pin down the granted claims and the '245's own front-page references.

Obviousness Analysis — U.S. Patent No. 11,778,245 B2 under 35 U.S.C. § 103

Date of analysis: April 26, 2026 | Grounds built from the Prior Art section of this file, as instructed.

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0. Status update to earlier sections (read first — two prior gaps closed, three contradictions flagged)

Two things changed this round, and both matter for the §103 analysis:

(A) Claim text — PARTIALLY CLOSED. The earlier "Patent summary" section reported that the '245 claim set could not be retrieved. I was able to retrieve the claim set of the pre-grant publication that corresponds to the '245 application: US 2019/0141365 A1, which Justia's record expressly ties to Application 16/102,206, "Patent Grant number: 11778245," inventor James M. Barton, filed Aug. 13, 2018 (https://patents.justia.com/patent/20190141365). That publication carries claims 21–40. Those are, as of this writing, the closest verifiable proxy for the issued claims.

Strict caveat: claims 21–40 are the published claims. The granted claims of 11,778,245 are presumably renumbered (e.g., 1–20 or 1–25) and may have been amended during prosecution. I have not verified the granted claim numbering or wording. Every claim-level statement below is made against the published claim set and must be re-verified against the granted text (USPTO Patent Public Search, App. 16/102,206) before being relied on in any filing or opinion.

(B) One prior-art attribution — CORRECTED. The Prior Art section guessed that R‑4 = US 6,981,045 B1 was "one of the most likely advertisement-insertion ... anticipatory candidates" "by class." That guess is wrong on the reference's subject matter. The family's own face-reference list (Justia, US 11,778,248 — a same-family, same-inventor sibling) prints "6981045 | December 27, 2005 | Brooks," and Google Patents titles US 6,981,045 B1 as "System for redirecting requests for data to servers having sufficient processing power to transcast streams of data in a desired format." It is a server-selection / stream-routing reference, not ad-insertion art. This matters: it maps to the routing element (URL identifies a server), not the ad-insertion elements.

(C) Contradiction flagged — two different "priority" dates. Google Patents shows the '245 priority date as 2008‑08‑13; the Unified Patents portal entry for the sibling US 11,778,248 shows Priority Date: 2008‑08‑12 (and Grant Date 2023‑10‑02 vs. 2023‑10‑03). Per the operating rules I am not reconciling these; I note them literally. The practical effect is nil for §103 (one day), but it should be picked up in any priority/§102 date chart.

(D) Contradiction flagged — abstract vs. spec server labels. Unchanged from the earlier "Patent summary" note: the abstract speaks of a "first server" (guide data) and "second server" (content), while the specification assigns those roles to HME server 104 and the content servers 110A–N. This matters because the granted claims of a later sibling (US 2024/0205468, US 12,063,396) do formalize a "first/second/third/fourth server" architecture — see §1 below.

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1. What the claim set actually recites (published claims 21–40, used as the §103 template)

The published claims present two independent method claims plus dependents. Notably, neither independent claim requires the portable device, the solid-state memory, the HDMI, or the two-server architecture — those appear only as dependents (¶39) or in sibling patents. That is the single most important fact for the obviousness analysis: the independent claims are drafted at a level of generality that reads on ordinary client-side/server-side ad-stitching.

Independent Claim 31 (published) — "device-side" method

Independent Claim 21 (published) — "server-side" method

Dependents (the real battleground)

Net: the §103 exposure is concentrated in the two independent claims (which are combinations of four or five individually ancient techniques) and in the bid/keyword/caching dependents (which are the only limitations with any arguable specificity — and even those were conventional by 2008).

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2. Threshold issue #1: the critical date controls which art is even available

This is dispositive of the whole analysis and must be resolved first.

• If the '245 claims are entitled to 2008‑08‑13 (root application 12/191,261), then §102/§103 art must predate that date.
• The '245 specification expressly rescinds any disclaimer of claim scope in the parents and states the claims "may be broader than any claim in the parent application(s)" (CROSS REFERENCE section, quoted in the earlier Patent summary). If any granted claim is later held not supported by the 2008 disclosure — a live risk given that the "set of time points"/"timepoint"-centric claims were first added years into the chain — the effective filing date slides to 2017‑01‑23 (parent 15/413,370) or 2018‑08‑13 (16/102,206), and a large body of 2009–2017 art becomes available.

Consequence for the grounds below: I have split the art into "Pre‑2008 art" (available on either view) and "Intervening art" (available only if priority is lost). The two strongest combinations (Grounds 1 and 2) are built on pre‑2008 art.

Art inventory relevant to §103 (all from the Prior Art section plus this round's verification):

Not prior art, and must be excluded: US 2007/0300261 A1, the pre-grant publication of US 8,261,300 (Barton), is the same inventor / common ownership art and cannot be used against the '245 (flagged in the earlier section; it stays flagged). Likewise, forward citations (US 9,646,100; US 9,811,599; US 10,097,885; US 2009/0100468-as-citing) are not prior art.

Also not prior art: US 2023/0043625 A1 (client-side secondary-content insertion with manifest-identified playback breaks) post-dates even the 2018 filing. It is useful only as evidence that the '245's independent claims read on what became the industry-standard ad-stitching architecture by 2023 — i.e., as an enablement/§112-type or damages/narrowing point, not an invalidity ground.

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3. Person of ordinary skill in the art (POSITA)

A POSITA at the 2008 priority date would hold a bachelor's degree in EE/CS (or equivalent) plus ~2–3 years of experience in network-delivered media systems, or a master's plus ~1 year — a person familiar with (i) HTTP/streaming delivery of MPEG-encoded A/V to consumer devices, (ii) client-side and head-end ad insertion and splicing, (iii) carrier/network client-server architectures, and (iv) the basic economics of ad-supported media (impressions, targeting, auctions). This is the level the field's litigation papers use, and every reference above is plainly within it. Zigmond, Guideworks and Brooks are all analogous art to the same problem: getting the right advertisement into the right content stream at the right moment, delivered over a network to a consumer display.

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4. Proposed grounds of obviousness

GROUND 1 — Zigmond + Guideworks (+ Brooks) ⇒ Claims 21 and 31

Why this is the lead ground: these are the two best references I could actually read, both pre‑2008, and between them they disclose every element of both independent claims.

Motivation to combine (KSR, Graham factor 2):

1. Same field, same problem. Both references address inserting targeted advertising into video programming delivered to a consumer's equipment. Combining them is combining references "in the same field of endeavor" directed to the same need.
2. Predictable, complementary improvements. Zigmond supplies what ad to pick and how to report it; Guideworks supplies where (time-stamped break points) and the data plumbing (ad identifiers, URLs, metadata). The combination yields nothing more than the predictable aggregate: an ad, chosen for the program, placed at the program's designated break, and reported out. KSR's "familiar elements according to known methods … to yield predictable results."
3. Market force. Both references are monetization references. The ad-supported Internet-video economy (the very subject of the '245 specification's §6.0 "Techniques for Deriving Revenue") gave a strong, articulated incentive to make delivery measurable and targeted.
4. The '245 specification itself treats the location of the logic as a design choice — it describes the device independently selecting and inserting ads or the server doing so, and states "[t]he advertisement URLs do not need to be sent … exactly at the time that the advertisement is to be downloaded." That is an admission-style statement that the server-side/client-side split is an implementation option, which undercuts any argument that moving the decision to one side is inventive.

Reasonable expectation of success: all steps are known techniques operating on known data structures (breaks, URLs, ad identifiers); no new hardware or physics is required.

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GROUND 2 — Pyle + Jain (+ Guideworks) ⇒ Claims 31 and 21

This ground is strongest on the title limitations — reaching a timepoint, interrupting, and notifying a server over the internet — because Jain is a beacon-based insertion reference.

Motivation to combine: manifest-driven playout was the ordinary way to deliver time-indexed media over a network; adding a beacon at the insertion point is the standard way to make an insertion measurable — the references' own stated purposes (ad tracking/monetization) supply the motivation. A POSITA would combine them because each is a known technique applied to a known structure with a predictable result, and the combination solves the same problem (knowing that an ad actually played) that Zigmond's clearinghouse solves.

Also apply here: if the granted claims contain the "interrupting … and resuming" language reflected in the '245 title and in the family's later means-plus-function claim (US 2025/0071351: "means for interrupting presentation of the content data … presenting the one or more particular additional content … means for resuming presentation"), then Santangelo independently teaches it: "determine whether content will be inserted at the beginning of play out," "receive pause/stop signal," "determine whether secondary content should be inserted," insert and present, then "proceed … when the user is ready to resume viewing the primary content."

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GROUND 3 — Wu + Doherty ⇒ Claims 21[c]–[e], 31[b]/[e], and the "interruption" limitation

• Doherty supplies the selection and scheduling engine (a "scheduler" that "selects advertisements and controls when each advertisement is inserted," re-scheduling as the user progresses) — i.e., 21[c] "obtaining … additional content for insertion."
• Wu supplies the interruption/insertion mechanic: "the output of the recorded media stream … may be stopped or paused while the present embodiment outputs sub-advertisement stream … as a full screen display"; the ad "cannot be turned off, fast forwarded through, or skipped." That is 21[d] / 31[e] / the title's "interrupting presentation."
• Motivation: the petition record itself articulates it — dividing media into sections each including an item of information was common; applying Doherty's known scheduler to Wu's known recorder "would have been simply applying a known technique … to a known device … to yield predictable results," with the benefit of "facilitating scheduling suitable advertisements for the user at the right time."

Note: I could not verify Wu's and Doherty's dates. Wu plainly reads as a 2002-era reference ("in the 2002 timeframe" appears throughout that petition), which would place it pre-2008; Doherty likewise. Verify both dates before asserting this ground. If both are pre-2008, this is a very clean combination for the interruption element.

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GROUND 4 — Brooks (US 6,981,045) for the routing/two-server architecture

The '245 abstract — and the family's later claims (e.g., the '245 sibling US 11,778,248 and US 12,063,396, which recite "a content data URL that identifies a second/third server … storing the requested content data" and "a supplemental content data URL that identifies a … fourth server") — recites a server that hands the device a URL identifying another server. Brooks is the family's own cited reference for precisely that: a "system for redirecting requests for data to servers having sufficient processing power to transcast streams of data in a desired format."

Motivation: routing a client to a server that can actually serve the stream is a load-balancing/quality-of-service improvement — a classic articulated "improvement in one art" rationale; and it is the natural way to implement a guide server that does not itself store the content. This ground is only needed if the granted '245 claims recite the multi-URL/multi-server structure. (The published claims 21–40 do not — so verify.)

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GROUND 5 — Contextual/keyword-matching dependents (28, 29, and the analogous matching in 27)

Zigmond alone teaches selecting advertisements based on "the content of the video programming," "subject matter, cast members, permitted themes," i.e. matching an ad attribute to a content attribute. The dependents' recitation of a formal "ad keyword" matched against the content is a predictable, trivial formalization of Zigmond's content/subject-matter selection — a labeling and data-structure choice, not an inventive step. Cohen (P‑3, US 2009/0307732, G06Q 30/02 "targeted advertisements") is the examiner-cited sibling reference for the same idea and would be the natural secondary reference if its §102(e) filing date precedes the critical date (unverified) — which is why Zigmond (2004, verified) should be the primary and Cohen the optional secondary.

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GROUND 6 — Bid-based and billing dependents (24, 25, 34) — weakest ground; a reference gap

Claims 24/34 ("advertisement associated with a highest bid amount") and 25 ("storing advertiser banking information … used to pay the highest bid amount") are the only limitations I cannot map to any reference I have read. Zigmond, Guideworks, Pyle, Jain, Wu, Doherty and Brooks are not, on their faces, ad-auction references, and the '245's own (56) list is still unverified.

Recommendation: treat the bid/billing dependents as requiring an additional, independently located reference — a keyword-advertising auction patent (the Overture/GoTo.com–era art and its descendants) combined with Ground 1. The motivation to combine is the strongest in the whole patent (advertisers' willingness to pay + the patentee's own specification describing bids, keyword bidding and stored bank-account/credit-card data), but I will not name a bid-art reference I cannot verify, because inventing one would be worse than the gap. This should be the first target of a supplemental search.

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Contingent Ground 7 — if priority is lost (claims not entitled to 2008‑08‑13)

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5. The global motivation-to-combine case (applies to every ground)

1. All references are analogous art in one field — delivering audiovisual programming with advertising to consumer equipment over a network. No field-of-endeavor gap to argue.
2. All limitations are known techniques. Content delivery + break schedule; ad lookup from a database; ad insertion at a break; notifying a remote party that an ad played; resumes after the ad. By 2008, every one of these was separately documented (Zigmond 2004; Guideworks 2008; Brooks 2005; and the streaming-era beacon/manifest work in Pyle/Jain).
3. Market incentive and the "predictable results" rubric. Ad-supported distribution creates a direct, articulated incentive to place an ad at a designated break, choose it based on the content, and report its presentation so it can be billed. KSR holds that such design incentives, plus "obvious to try" with a finite number of identified, predictable solutions, counsel obviousness.
4. The specification's own disclosures help the challenger — the Background admits the Internet-video/MPEG delivery state of the art; the description calls the portable device's independent ad selection an alternative to server selection; and the specification's own §5.0 ("Example Advertisement Presentation Techniques") and §6.0 (revenue) read as catalogues of conventional options.
5. Verification/teaching-away check: Guideworks' motivation is skip-substitution rather than monetization, but it does not disparage the claim's approach, so it is not a teaching-away. No reference identified here criticizes inserting ads at publisher-designated breaks.

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6. Graham factor 3 (differences) and factor 4 (objective indicia)

Differences that remain (and are the patentee's best rebuttals):

• The particular packaging of the two independent claims — a set of timepoints supplied up front by a server, with the device later notifying that server, which then supplies/inserts the additional content. No single reference I read shows this exact loop end-to-end; it is the combination that must be sustained.
• Fixed ranking across time — nothing I read ranks ads within a break by a per-impression bidding metric.
• The dependents' distinct implementation choices — remote cache-management instructions keyed to "the content data and a specified time," display in a non-occupied (letterbox) portion, HDMI, portable hard-disk-free device. These are individually old but, taken as a set, are more specific than most of the art I read; a plaintiff will argue the claimed combination of the portable-device context plus remote cache management plus ad insertion is not shown in one place.

Objective indicia (secondary considerations) — none established:

• No commercial success evidence was found for a product embodying the claims (the earlier Assignment section could not identify a TiVo-branded portable/HDMI product reading on them). This is a negative for the patent owner on factor 4.
• Licensing (the Adeia campaign; the Disney December 2025 license noted in the PTAB section) can be argued as industry recognition — but Adeia is a portfolio licensor, and blanket/portfolio licenses are weak evidence of this patent's non-obviousness.
• Copying by competitors could be argued, but no evidence is in the record here.
• Unexpected results / long-felt need: not evidenced. The disclosed device (portable, no HDD, HDMI out) was a design trend, not an overcoming of a technical hurdle identified in the art.

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7. Weaknesses in the §103 case / what would defeat each ground

Two structural risks that cut against the challenger:

• The '245 has never been through an instituted AIA trial (per the PTAB section: 0 proceedings). The claims are untested, not confirmed — but also not narrowed. No PTAB FWD exists to quote for either side, and no estoppel constrains the available grounds: every ground above, including grounds that "could have been raised," remains available in district court and in a first-filed IPR.
• If the priority date holds, the pre‑2008 art set is what decides the case: Zigmond (2004), Guideworks (2008‑06), Brooks (2005), and Wu/Doherty (if 2002-era, verified). Everything else — P‑1, P‑2, P‑3, Pyle, Jain, Santangelo, '642 — is either date-dependent or intervening.

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8. Verification plan and confidence

Must verify before any of this is used in a filing or opinion:

1. Granted claim text and numbering for US 11,778,245 (USPTO Patent Center, App. 16/102,206 / granted PDF). The published claims 21–40 are a proxy only.
2. The '245's own (56) "References Cited" list — still unretrieved; the P‑1–P‑3 and R‑1–R‑11 sets belong to siblings, not to the '245.
3. Effective filing dates of Pyle, Jain, Wu, Doherty, Santangelo — these determine whether Grounds 2 and 3 are available at all.
4. A keyword-advertising auction reference for dependents 24/25/34.
5. US 6,981,045 (Brooks) body text, to confirm it teaches the URL/redirection element actually relied on.
6. The 2008‑08‑12 vs 2008‑08‑13 discrepancy, and whether any granted claim is unsupported by the 2008 root (which is the whole §103 strategy for the intervening art).

Confidence:

• High that the independent claims are, on their face, combinations of individually well-known techniques and are exposed under §103 on the pattern above. The published claim language is extremely broad, and the strongest art (Zigmond, Guideworks) is pre-2008 and directly on point for the elements I could read.
• Medium on the specific reference-by-reference mappings, because reference content was verified for only seven of the references (Zigmond, Guideworks, Pyle, Jain, Wu, Doherty, Santangelo — all read from quoted petition/patent text) and not for P‑1, P‑2, P‑3, R‑1…R‑11, Brooks' body, or the '642 in detail.
• Low/unknown on the bid-based dependents, where I found no art and declined to invent references.

Bottom line: the obviousness attack on US 11,778,245 does not rest on a single anticipatory "magic" reference — none is needed. It rests on the thesis that the '245's independent claims are an aggregation of four well-worn techniques (content delivery, break schedules, content-based ad selection, and playback reporting for billing), each documented in the pre-2008 record, and that the patent's own specification describes the allocation of those functions between server and device as an implementation choice. The two vulnerabilities the patent owner can exploit are (i) the priority date, which if sustained excludes a decade of art, and (ii) the bid/auction dependents, for which no reference is yet identified.