Invalidity dossier
US 12240248
Board, liquid accommodation container, and printing system
Current assignee: Epson Portland Inc., Epson America, Inc., Seiko Epson Corporation
Added 9/30/2026, 5:33:34 PM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll run targeted searches for this patent number and any associated 2026 litigation/docket activity.
Let me check the litigation/docket references associated with this patent and any Federal Circuit activity.
Let me check for any Federal Circuit appeal activity in 2026 and verify the second ITC reference.
US 12,240,248 B2 — Analyst Summary
Note on method: I searched for the exact identifier 12240248 / 12,240,248. The authoritative source is the full patent text supplied in this task (fetched from Google Patents, US12240248B2). Where I rely on sources outside that text, I say so and flag uncertainty. I did not substitute results for other numbers (e.g., 12,240,249, which is a different patent — see "Do not confuse" below).
1. Bibliographic identification
| Field | Value |
|---|---|
| Patent number | US 12,240,248 B2 |
| Title | "Board, liquid accommodation container, and printing system" |
| Assignee (current & original) | Seiko Epson Corporation (Tokyo, JP) |
| Inventors | Shuichi Nakano (Shiojiri, JP); Yasuhiko Kosugi (Matsumoto, JP); Jun Sato (Shiojiri, JP) |
| Application no. | US 18/907,860 |
| Filing date | 2024-10-07 |
| Publication date (A1) | 2025-01-23 — US 2025/0026126 A1 |
| Issue date | 2025-03-04 |
| Priority date | 2021-12-28 (JP 2021-214129 → JP7176609B2; JP 2021-214139 → JP7176610B2) |
| Anticipated expiration | 2042-04-11 |
| Legal status | Active |
| Continuity | Continuation of Ser. No. 18/527,895 (filed 2023-12-04) → continuation of Ser. No. 17/988,307 (filed 2022-11-16) → continuation of Ser. No. 17/717,857 (filed 2022-04-11) |
| Representative CPC | B41J 2/17503, 2/1752, 2/17523, 2/17526, 2/1753, 2/17543, 2/17546, 2/17553 |
2. Abstract (verbatim, as published)
"In a board that includes a plurality of contact portions that are arranged to contact corresponding apparatus-side terminals when the board is mounted in a printing apparatus, some contact portions are disposed in a first region, and the remaining contact portions are disposed in a second region. The some contact portions include a first contact portion, a second contact portion, a third contact portion, and a fourth contact portion. The remaining contact portions include a fifth contact portion. The some contact portions are arranged in a first pattern in the first region and the remaining contact portions are arranged in a second pattern in the second region, and the first pattern is asymmetrical to the second pattern with respect to a first virtual line."
3. Plain-language overview of the independent claims
Caveat on confidence: The patent text I was given includes the abstract, the full description, and the "Definitions"/exemplary-embodiment summary passages, but the claims themselves are truncated at the point where the description ends ("there is provided a board that is configured to be mounted i…"). I therefore reconstruct claim scope from (a) the recited "Exemplary embodiments" in the description, which mirror the claim language, and (b) the ITC record identifying which claims exist and were asserted. I flag the inferred items explicitly.
Claim 1 — the board claim (high confidence). A circuit board for mounting in a printing apparatus that has a print head, a liquid introduction portion, an accommodation section, and a set of apparatus-side terminals. The board has a base member, a device (an IC with a processing unit and/or storage unit), and five terminals — first through fifth — each coupled to the device and each having a contact portion that touches a corresponding apparatus-side terminal when mounted. The first terminal is used to detect whether it is short-circuited with at least one of the second, third, and fourth terminals (in the detailed embodiment: the data terminal is the first terminal; clock, reset, power-source, ground are the others). Geometrically, two orthogonal virtual lines (C1, C2) are defined; projecting every contact portion perpendicularly onto the second virtual line yields all-different projection positions, and the first virtual line passes through the midpoint between the two farthest-apart projections. The first through fourth contact portions sit in a first region on one side of that line, the fifth contact portion (the ground contact portion) sits in the second region on the other side, and the two groupings are asymmetric with respect to the line.
Stated technical purpose: to reduce the chance of a short circuit between terminals on the ink-cartridge board — especially a short involving the ground terminal — caused by conductive foreign matter (ink, pet urine, wire/staples/mechanical-pencil lead) bridging adjacent contact pads, and to enable apparatus-side detection of such a short (mounting detection and short-circuit determination via the data terminal, e.g. "container provided" vs. "short circuit occurring" vs. "no container").
Claim 7 — liquid accommodation container claim (medium confidence — inferred). Based on the ITC record, claim 7 of the '248 patent was asserted and remained in the investigation, and the description separately recites a "liquid accommodation container … mounted on an accommodation section of a printing apparatus" aspect. I infer claim 7 is directed to a liquid accommodation container (ink cartridge) comprising a board according to the disclosure (i.e., the board claim recast at the container level, with the same five-terminal / asymmetry / projection-position limitations). I do not have the verbatim claim 7 text and cannot confirm this reading word-for-word.
Other independent claims. Claims 13, 15, 20 and 21 of the '248 patent were asserted and then terminated at the complainants' request (ITC order of 2026-01-20, reviewing ALJ Initial Determination No. 11). Their verbatim text is not in the material I have, so I will not characterize them beyond noting their existence and that the patent contains at least 21 claims, with a printing-system aspect recited in the description as a further independent-claim family.
4. Litigation / docket status (as of the current date)
ITC Section 337 — Inv. No. 337-TA-1452, "Certain Ink Cartridges and Components Thereof II" (confirmed by multiple independent sources, including the USITC itself):
- Complaint filed 2025-05-13 by Epson Portland Inc., Epson America, Inc., and Seiko Epson Corp.; investigation instituted 2025-06-12; notice published 90 FR 25644 (2025-06-17).
- Patents asserted: US 8,764,172; US 9,370,934; US 11,535,038; US 12,240,248 ('248 patent); and US 12,240,249 ('249 patent).
- Claims of the '248 patent originally in the investigation: claims 1, 7, 13, 15, 20, and 21.
- 2026-01-20: Commission declined review of ID No. 11 (2025-12-11) — partial termination, at complainants' request, of claims 13, 15, 20 and 21 of the '248 patent (and certain claims of the other four patents). Claims 1 and 7 remained.
- 2026-04-01: Recommended remedies published for comment (general exclusion order plus cease-and-desist orders against Mountain Peak, Inc. and Straightouttaink, LP).
- 2026-05-08: Commission ordered partial review of ID No. 16 (2026-03-24) on the economic prong of domestic industry; comments due 2026-05-22.
- August 2026 (notice published 2026-08-18): Commission found a violation and issued a general exclusion order covering claims 1 and 7 of each of the '172, '934, '038, '248, and '249 patents**, plus cease-and-desist orders against Mountain Peak, Inc. and Straightouttank, LP; bond set at 100% of entered value during presidential review; investigation terminated. (Source: USITC notice, https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf; ITC news release https://www.usitc.gov/press_room/news_release/2025/er0612_67166.htm)
CAFC 2026 dockets — no matching result found. I searched for Federal Circuit activity tied to 12240248, to Inv. No. 337-TA-1452, and to Epson ink-cartridge appeals in 2026. I found no 2026 Court of Appeals for the Federal Circuit docket, appeal number, or opinion naming US 12,240,248. The Federal Circuit 2026 docket hits that surfaced (e.g., USCA Nos. 26-1884 in Headwater Research LLC v. Verizon in E.D. Tex.) are unrelated. Given that the ITC's final determination and GEO issued in August 2026, a presidential-review period and any subsequent CAFC appeal would be expected to post-date or barely overlap the present date, so this is a plausible non-finding rather than a definite absence. I cannot state with high confidence that no CAFC proceeding exists.
Unverified reference flagged: The Google Patents page for US12240248B2 also lists ITC case 337-TA-3828 among its litigation links. I could not independently corroborate that identifier, and its numbering is anomalous for a recent Epson ink-cartridge investigation (the current family of such investigations sits in the 337-TA-14xx range). I report it here literally as it appears rather than correcting it, but treat it as an unverified/possibly erroneous metadata artifact.
5. Do not confuse: US 12,240,249
A separate patent, US 12,240,249 (the '249 patent), issued the same day (2025-03-04), to the same assignee, with the same title and the same three inventors, and was asserted alongside the '248 patent in 337-TA-1452. One secondary news item (HT Syndication, March 5) attributes the shared abstract language to patent no. 12,240,249. Any analysis of the '248 patent must key on the exact number 12,240,248; the two are sibling continuations, not the same document.
6. Uncertainty summary
- High confidence: number, title, assignee, inventors, application number, filing and issue dates, priority, continuity chain, abstract, CPC classes, and the ITC 337-TA-1452 facts above.
- Medium confidence: that claim 1 is the board claim (supported by the description and abstract) and that claim 7 is a liquid-accommodation-container claim (inferred from the description and the ITC claim list).
- Low / no confidence: the verbatim scope of claims 7, 13, 15, 20, 21; whether a printing-system claim is independent and which number it carries; any CAFC 2026 proceeding involving this patent; the correctness of the 337-TA-3828 identifier.
Generated 9/30/2026, 5:41:43 PM
Cases on file (1)
Group view →Specific litigation cases in our database that name US patent 12240248. The free-form analysis below may also discuss cases beyond this list.
- Epson Portland Inc. et al. v. Dongguan Ocbestjet Digital Technology Co., Ltd. d/b/a Ocbestjet et al.filed May 13, 2025337-TA-1452U.S. International Trade Commission, Washington, D.C. (Section 337, 19 U.S.C. § 1337)terminated Aug 13, 2026terminated; violation found
Defendants: Dongguan Ocbestjet Digital Technology Co., Ltd. d/b/a Ocbestjet, Ocbestjet Printer Consumables (HK) Co., Ltd., Tatrix International China Co., Ltd., and 17 others
Other patents asserted: 11535038, 8764172, 9370934, 12240249
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US Patent 12240248, starting with the leads already present in the patent record (ITC Section 337 investigations) and then broader litigation databases.
Good — I've confirmed the ITC investigation. Now let me check the second ITC case number listed in the patent record and look for district court litigation.
I have the ITC picture. Now let me check for parallel district court suits and any PTAB/IPR challenges involving this patent.
Litigation Report — U.S. Patent No. 12,240,248 ("the '248 patent")
Patent: U.S. 12,240,248 B2, "Board, liquid accommodation container, and printing system" (Seiko Epson Corp.). Priority date 2021‑12‑28; application 18/907,860 filed 2024‑10‑07; granted 2025‑03‑04. Claim 1 and claim 7 are the claims that have been enforced.
Bottom line: The only litigation I can confirm involving the '248 patent specifically is a U.S. International Trade Commission Section 337 investigation. I did not find any district court (CAFC/PACER/EDTX) case or PTAB/IPR proceeding specifically asserting or challenging the '248 patent. Details and caveats below.
1. ITC Investigation No. 337-TA-1452 — Certain Ink Cartridges and Components Thereof II
| Item | Detail |
|---|---|
| Forum / Jurisdiction | U.S. International Trade Commission, Washington, D.C. (Section 337, 19 U.S.C. §1337) |
| Investigation No. | 337-TA-1452 (temporary docket 337-TA-3828, listed on the patent's Google Patents "litigation" links) |
| Complainants | Epson Portland Inc. (Hillsboro, OR); Epson America, Inc. (Los Alamitos, CA); Seiko Epson Corporation (Nagano, Japan) — collectively "Epson" |
| Respondents (20 named) | Dongguan Ocbestjet Digital Technology Co., Ltd. d/b/a Ocbestjet; Ocbestjet Printer Consumables (HK) Co., Ltd.; Tatrix International China Co., Ltd.; Luozhi Trading Co., Ltd.; Shenzhen Hongxinyuan E-Commerce Co., Ltd. d/b/a Jianjai/Vi‑US; Shenzhen Kaizhen Technology Co., Ltd. d/b/a PayForLess; Zhuhai Zhenyang Electronics Co., Ltd. d/b/a Oinkwere; Shangrao Shixuan E-Commerce Co., Ltd. d/b/a Inkgo; Zhuhai Hengyunda Electronics Co., Ltd. d/b/a Upriin; Zhuhai Rongtaida Electronics Co., Ltd. d/b/a Hookink; Zhuhai Shi Wei Tai Electronics Co., Ltd. d/b/a Ondula‑A; Zhuhai Yixing Electronics Co., Ltd. d/b/a Greenjob USSOP; Mei Jin Technology HK Co., Ltd. d/b/a YBFeir/MJing; ZhuHai MeiJiAn Trading Co., Ltd. d/b/a HaloFox; Qiong Wang d/b/a 7‑magic; Shen Zhen Sailing Technology Limited d/b/a Triple‑Color; Zhuhai Shuofeng E‑commerce Co., Ltd. d/b/a super‑ink‑club; Zhuhai Bowang Technology Co., Ltd. d/b/a office‑print‑club; Mountain Peak, Inc. d/b/a Billiontree Technology USA / Toner Kingdom (CA, USA); Straightouttaink, LP d/b/a discountinkllc/einkshop2014/Inkpro/inkprousa (CA, USA) |
| Complaint filed | May 13, 2025 (supplements May 19 and 30, and June 3, 2025) |
| Instituted | June 12, 2025 (Commission vote); published June 17, 2025, 90 FR 25644‑45 |
| Patents asserted | U.S. 8,764,172; 9,370,934; 11,535,038; 12,240,248; 12,240,249 |
| '248 patent claims asserted | Claims 1, 7, 13, 15, 20, and 21 |
| Accused products | "ink jet cartridge products and components thereof for use in Epson ink jet printers" |
| Status / Outcome | Concluded — violation found. ALJ initial determination March 24, 2026 (summary determination of violation, recommending GEO/CDO and 100% bond). Several respondents found in default (Commission affirmed Nov. 17, 2025 re: Order No. 6 of Sept. 15, 2025); four respondents terminated Jan. 8, 2026. Final Commission determination Aug. 13, 2026 (published Aug. 18, 2026): general exclusion order prohibiting importation of products infringing claims 1 and 7 of each of the five patents (including the '248 patent); cease and desist orders against Mountain Peak, Inc. and Straightouttaink, LP; bond of 100% of entered value during the Presidential review period; investigation terminated. |
This is the matter reflected in the "US case filed in International Trade Commission" links on the patent's Google Patents page (337‑TA‑1452 and the temporary docket 337‑TA‑3828).
2. Related ITC proceeding (does NOT involve the '248 patent)
Epson filed two companion Section 337 complaints on May 13, 2025. The other one, temporary docket 337‑TA‑3827 (Certain Ink Cartridges and Components Thereof I), asserts U.S. 8,540,347; 9,061,508; 11,535,037; 11,820,150; and 12,246,539 — not the '248 patent. I mention it only to distinguish it; it is not litigation "involving" U.S. 12,240,248.
3. District court litigation
No district court case specifically asserting or challenging U.S. 12,240,248 was confirmed by my searches. I found a large body of Epson ink‑cartridge enforcement litigation (e.g., ITC 337‑TA‑565, 337‑TA‑946; and numerous district court suits such as Seiko Epson Corp. v. BCH Technologies LLC, No. 1:19‑cv‑01067 (M.D.N.C.), and the multi‑case list in that complaint), but those involve different patents (e.g., U.S. 6,955,422; 8,794,749; 8,454,116; 8,764,172; 9,370,934). I could not attribute any district court docket to the '248 patent. (Note: one PTAB paper referencing an "EDTX Litigation" filed Aug. 21, 2024 relates to U.S. 11,562,402 in IPR2024‑01420 — a different patent, unrelated to the '248 patent.)
4. PTAB / IPR
No IPR, PGR, or other AIA post‑grant proceeding challenging U.S. 12,240,248 was found. No third‑party petitioner has been identified as to this patent.
Caveats
- The Google Patents page's Darts‑IP link ("First worldwide family litigation filed") is a family‑level flag; I have reported the ITC matters I could independently corroborate and have not treated the Darts‑IP family flag as an additional case.
- Search results include events dated August 2026 (the final GEO/CDO determination), which postdate the April 26, 2026 "current date" in your prompt. I am reporting them as found in the sources rather than suppressing them; please reconcile the date. If your question is limited to events as of April 26, 2026, the status at that time was: investigation instituted; ADJ summary‑determination ID of March 24, 2026 recommending relief; four respondents terminated January 2026; several respondents in default — with the final Commission determination not yet issued.
- Case number: ITC investigations are cited by investigation number (337‑TA‑1452); there is no district‑court-style case number. The temporary docket 337‑TA‑3828 (from the patent record) maps to this investigation.
- I did not have budget to pull the PACER docket or RPX/Unified Patents portal entries directly; those would be the best sources to confirm definitively whether a parallel district court suit on the '248 patent exists.
Primary sources: USITC News Release 25‑074 (June 12, 2025); 90 FR 25644‑45 (June 17, 2025); USITC "Notice of a Commission Determination Finding a Violation … Issuance of a General Exclusion Order and Cease and Desist Orders" (337‑TA‑1452, Aug. 13, 2026), https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf; Unified Patents litigation link https://portal.unifiedpatents.com/litigation/International%20Trade%20Commission/case/337-TA-1452.
If you'd like, I can attempt a follow‑up search specifically through PACER/RPX/Unified Patents to definitively rule a district court suit in or out — but I should flag that I already exhausted my search budget this round.
Generated 9/30/2026, 5:41:43 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: Epson Portland Inc., Epson America, Inc., Seiko Epson Corporation
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.
I'll start by searching for any PTAB proceedings and related litigation involving this patent.
Let me search more specifically for the ITC investigation and any PTAB challenges to Epson cartridge patents.
Let me check for any PTAB challenge specifically to the '248 or its sibling patent, and look into the second ITC case referenced.
PTAB / AIA Trial Analysis — US Patent 12,240,248 ("the '248 patent")
Bottom line up front: There are no AIA trial proceedings on file for US 12,240,248. The canonical structured source (USPTO Open Data Portal, "PTAB proceedings on file") returns zero IPRs, zero PGRs, zero CBMs, and zero derivations for this patent, and my independent web searches surfaced nothing to contradict that. There is therefore no FWD, no institution decision, no panel, and no Federal Circuit appeal to report. I will not manufacture proceeding numbers to fill the template.
The patent's actual adversarial history is not at the PTAB at all — it is a Section 337 investigation at the ITC, which I discuss below because it is the thing that actually matters for a defendant reading this patent.
Proceedings overview
Total AIA trial proceedings on file: 0. Breakdown by status: 0 active, 0 with claims invalidated, 0 with claims sustained, 0 settled, 0 institution denials. The defensive posture this gives a defendant is not "the patent survived two IPRs and is hardened" — it is the opposite corner of the matrix: the '248 patent has never been tested for patentability by the PTAB, and it has never been challenged anywhere on the merits. It issued 2025-03-04 and went straight into an ITC complaint two months later. Its only adjudicated "win" is a general exclusion order obtained against a docket of mostly defaulting respondents. So: no IPR estoppel runs against anyone, but also no claim has been canceled and no helpful FWD exists for a defendant to lean on. This is an untested, recently-issued patent — a PGR-style vulnerability profile, except the PGR window has closed.
No PTAB proceedings to itemize
Because the structured PTAB list is empty, there are no {PROCEEDING_NUMBER} entries. For completeness on the questions you asked that would normally be answered from an FWD:
- Judge panels: N/A — no proceeding.
- Petition grounds / § 102 / § 103 / § 112: N/A — no petition on file.
- Institution decisions: N/A.
- Final Written Decisions: N/A — no claim of the '248 patent has ever been canceled or sustained by the Board.
- Settlement / termination: N/A at the PTAB.
- Appeal: N/A — no PTAB appeal exists.
- Litigation flags on the patent record: The Google Patents record for US12240248B2 carries a "Family has litigation" / Darts-ip family flag and two ITC case links: 337‑TA‑1452 (
https://portal.unifiedpatents.com/litigation/International%20Trade%20Commission/case/337-TA-1452) and 337‑TA‑3828 (.../case/337-TA-3828). I was able to corroborate 1452 from primary sources. I could not corroborate 337‑TA‑3828 anywhere, and the number is chronologically inconsistent with a 2025 filing (that TA range does not correspond to a 2025 institution). Treat 337‑TA‑3828 as unverified metadata, possibly a data artifact, not as a proceeding. I am flagging it rather than reporting it as fact.
The proceeding that actually exists: ITC Inv. No. 337-TA-1452 — Epson v. Certain Ink Cartridges (not a PTAB trial)
- Type: U.S. International Trade Commission Section 337 investigation (19 U.S.C. § 1337) — not an IPR/PGR/CBM. It is a trade-remedy proceeding, not an AIA trial.
- Filed: Complaint filed 2025-05-13 by Epson Portland, Inc.; Epson America, Inc.; and Seiko Epson Corporation (collectively "Epson"). Supplements 2025-05-19, 2025-05-30, 2025-06-03. Instituted June 2025 (Commission vote 2025-06-12; notice of investigation published at 90 FR 25644-45, 2025-06-17).
- Status: Terminated — violation found. Commission determination of 2026-08-13 finding a violation of Section 337, issuing a general exclusion order (GEO) and cease and desist orders, and terminating the investigation.
- Asserts the '248 patent. The asserted patents were 8,764,172; 9,370,934; 11,535,038; 12,240,248; and 12,240,249. So the '248 patent is asserted alongside its sibling 12,240,249 (same 2021-12-28 JP priority, JP2021214129 / JP2021214139).
- Relief granted: GEO prohibiting importation of products infringing claims 1 and 7 of each of the five patents — including claims 1 and 7 of the '248 patent. CDOs issued against respondents Mountain Peak, Inc. (d/b/a Billiontree/Toner Kingdom) and Straightouttaink, LP. Source:
https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf - Respondents: ~20 named entities, overwhelmingly China-based e-commerce/aftermarket cartridge sellers (Ocbestjet, Tatrix, Luozhi, Shenzhen Hongxinyuan/Jianjai, Kaizhen/PayForLess, Zhuhai Zhenyang/Oinkwere, Zhuhai Rongtaida/Hookink, Zhuhai Shi Wei Tai/Ondula-A, Zhuhai Yixing/Greenjob USSOP, Mei Jin/YBFeir, Zhuhai Bowang, Mountain Peak, Straightouttaink, and others).
- Critical procedural fact — near-total default. The Commission found the majority of named respondents in default (Order No. 8, 2025-09-15, unreviewed 2025-11-17; a further tranche in Order No. 10). Note a date/number discrepancy between sources — some Chinese trade-remedy bulletins describe the 2025-09-15 default ruling as "Order No. 6." Either way, the substance is the same: the accused products were largely un-defended. Default in Section 337 means the ALJ accepts the complaint's allegations as true. Under Commission rule 210.16, that produces a violation finding without any merits adjudication of validity.
- Partial termination on withdrawal (2026-01-20). Following Order No. 11 of 2025-12-11, the Commission terminated the investigation as to certain claims based on Epson's withdrawal, including claims 13, 15, and 20-21 of the '248 patent (and claims of the other asserted patents). This is Epson voluntarily dropping claims — it is not a finding that those claims are invalid, and it is not a narrowing amendment or disclaimer of claim scope for § 315(e) purposes. The remaining asserted claims (1 and 7 among them) went forward.
- Domestic industry. Order No. 16 (2026-03-24) addressed the economic prong of domestic industry; the Commission granted partial review on 2026-05-08. The violation determination was entered over that background.
- Appeal: None reported. Respondents defaulted; there is no indication of a Federal Circuit appeal of the Commission's determination. The '248 patent therefore has no appellate claim construction and no appellate validity holding.
- Defensive value: The GEO on claims 1 and 7 of the '248 patent is a real import-blocking remedy — if you import or sell accused aftermarket cartridges, customs enforcement under the GEO is the practical risk, and it applies regardless of whether you were named. But the GEO is a trade remedy, not a validity judgment. It carries no claim-preclusive effect on patentability in a district court or before the PTAB, and because the respondents defaulted there is not even an adversarially-tested infringement record to inherit.
Strategic summary
Claim status of the '248 patent: everything is UNTESTED on validity. Not a single claim has been canceled by the Board, held unpatentable by any tribunal, or sustained after adversarial review. The claim-level facts that do exist: claims 1 and 7 are the claims the Commission found infringed and covered by the GEO (2026-08-13); claims 13, 15, and 20-21 were withdrawn by Epson from the ITC case (2026-01-20) and are untested by anyone. Because the ITC respondents defaulted, no claim was construed by the ALJ in an adversarial posture, no invalidity defense was tried on the merits, and nothing in the ITC record is binding on patentability. If a demand letter from Epson cites claims 1 or 7, those are the live, government-enforced claims — they are the ones to focus a validity challenge on.
Estoppel landscape — there is essentially none, which cuts both ways. Because no IPR or PGR was ever instituted, § 315(e)(2) estoppel is not triggered for anyone. A defendant or prospective IPR petitioner today is unconstrained by prior PTAB grounds: there is no "raised or reasonably could have raised" bar to inherit, no prior petitioner to piggyback on, and no prior institution denial to work around. Conversely, a defendant gets no benefit from a prior petitioner's work — there is no FWD, no Board claim construction, and no unpatentability record to borrow. The ITC default judgment likewise creates no issue preclusion on validity (ITC decisions are generally not given preclusive effect on patent validity in district court). Practically: the prior-art ground set is wide open, but you will be funding it from scratch. The obvious exploitable vulnerability is the patent's own priority chain — the '248 patent's claims rest on JP priority from 2021-12-28 via a chain of continuations (17/717,857 → 17/988,307 → 18/527,895 → 18/907,860). Whether the claims are entitled to that 2021 priority date determines what prior art qualifies, and that is exactly the kind of issue the Board resolves under Dynamic Drinkware. That is worth developing before filing.
Pattern signals. (1) No serial petitioner — nobody has filed anything at the PTAB against the '248 patent, including the aftermarket-cartridge importers who had the most direct incentive and chose default instead. (2) No defensive aggregator — Unified Patents appears in the record only as the data source for the ITC case link, not as a challenger. The absence of a Unified/RPX-style IPR against a patent this aggressively asserted is notable and suggests the target defendants are e-commerce sellers without the resources or US counsel to mount AIA challenges. (3) Patent owner posture is litigation-forward, not PTAB-forward. Epson has never had to defend this patent at the Board, has never appealed a PTAB outcome, and has already shown a willingness to drop claims (the January 2026 withdrawal of '248 claims 13, 15, 20-21) when they are not helping. A patent owner that trims its own asserted set is signaling that some claims are weaker than others — worth probing which ones and why. (4) The '248 patent also sits inside a large Epson campaign (companion investigations and the sibling '249 patent), so a challenge should be scoped across the asserted family, not just this one patent.
Recommended next steps
If you are a defendant facing assertion of the '248 patent:
- Do not look for a PTAB FWD — there isn't one. There is no claim you can point to as canceled and no disposition to quote. Any invalidity position you take must be built independently. Be explicit with your client that the "wait for the IPR" strategy is unavailable and nothing is already dead.
- Anchor on claims 1 and 7. Those are the claims the Commission found infringed and that are covered by the GEO (
https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf). They are also the claims a follow-on commercial demand is most likely to cite. - Exploit the default. The ITC violation rests on a record where the bulk of respondents never appeared. There is no adversarial ALJ claim construction and no validity trial. Nothing about the GEO tells you the claims are strong on the merits.
- Attack priority early. Given the continuation chain and the 2021-12-28 JP priority claim, run a full priority/written-description analysis first — it is potentially the cheapest route to opening up prior art, and it is a § 112 written-description issue that cannot be raised in an IPR (IPR is limited to §§ 102/103 patents-and-printed-publications grounds under § 311(b)). If the killer argument is § 112, your only PTAB vehicle was a PGR — and the PGR window closed roughly 2025-12-04 (nine months from the 2025-03-04 grant). That avenue is gone; § 112 arguments now live in district court or the ITC.
On timing for any IPR you are considering:
- There is no statutory bar running. An IPR can be filed now.
- Expect the Fintiv-type / Director discretionary-denial analysis to be the first hurdle. There is a live, concluded ITC investigation, and the current Director guidelines lean heavily toward discretionary denial where there is parallel litigation, settled expectations, or an older patent. This patent is young (granted 2025-03-04), which helps you — recent Board decisions have found "settled expectations" typically only after ~6+ years from issuance.
- Once instituted, trial runs on a statutory 1-year clock from the institution decision (35 U.S.C. § 318(a)), with the FWD due at that deadline, and a pre-institution Patent Owner Preliminary Response and an institution decision (§ 314(b)) before that.
- Be prepared for a § 325(d) / discretionary fight anyway: the Office examined this application on an Epson-heavy prior-art record, and you will need to show the Examiner materially erred — which is itself a recognized route to overcoming discretionary denial.
If you want to rely on the ITC outcome: you cannot. The 2026-08-13 determination is a trade remedy against importation, obtained largely by default, and it does not establish patentability, does not estop anyone, and does not preclude you from challenging validity.
One caveat on sourcing: I could not independently confirm the second ITC case number listed on the patent's Google Patents record (337‑TA‑3828) and consider it unreliable — do not cite it. The verified proceeding is 337‑TA‑1452 only.
Sources consulted: USPTO Open Data Portal "PTAB proceedings on file" block (canonical, empty); USITC Press Release 25-074 (2025-06-12), https://www.usitc.gov/press_room/news_release/2025/er0612_67166.htm; USITC Notice of Commission Determination, Inv. No. 337-TA-1452, https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf; Federal Register institution notice, 90 FR 25644 (2025-06-17), https://www.govinfo.gov/content/pkg/FR-2025-06-17/pdf/2025-11086.pdf; Google Patents record for US12240248B2, https://patents.google.com/patent/US12240248/en; Chinese Ministry of Commerce trade-remedy bulletins (claim-withdrawal and default orders, 2025-11-17, 2026-01-20, 2026-05-08, 2026-08-13).
Confidence note: I have high confidence that there are zero PTAB proceedings on this patent, based on the structured ODP data plus independent search. I have moderate-to-high confidence on the ITC timeline above (multiple corroborating primary and secondary sources, with minor discrepancies in order numbering and the exact institution date noted in-line). I have low confidence in anything regarding 337‑TA‑3828 and would not rely on it.
Generated 9/30/2026, 5:41:57 PM
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.
I'll start by pulling whatever public records I can on this patent's ownership chain and litigation posture.
The patent is being asserted directly by Epson entities. Let me probe the USPTO assignment API and district-court dockets for any recorded transfers.
Assignment & Ownership Reconstruction — US 12,240,248 B2
Patent: Board, liquid accommodation container, and printing system
Application: 18/907,860 · filed 2024-10-07 · granted 2025-03-04
Priority: JP 2021-214129 and JP 2021-214139, both 2021-12-28
Current assignee of record (Google Patents): Seiko Epson Corp
Sourcing caveat, stated up front. I was able to retrieve the full patent document and the litigation record below, but I was not able to query the USPTO Assignment Center / ODP assignment database directly in this session (it is a JavaScript application that does not expose reel/frame data to the crawler). I therefore will not state reel/frame numbers I did not observe. Where the record is blank, I say blank. Whoever verifies this report should run
12240248through https://assignmentcenter.uspto.gov/ (Patent Assignment Search) to confirm the negative finding in the Assignment timeline section.
Inventors
| Inventor | Employer at filing | Basis |
|---|---|---|
| Shuichi Nakano | Seiko Epson Corporation (Japan) | Sole/current assignee of record is Seiko Epson; inventor listed under Seiko Epson's portfolio (PatentLeaderboard, 50 patents credited to Seiko Epson) |
| Yasuhiko Kosugi | Seiko Epson Corporation (Japan) | Same; 63 patents credited to Seiko Epson (PatentLeaderboard profile 25146) |
| Jun Sato | Seiko Epson Corporation (Japan) | Same |
Pattern notes: No unusual pattern. All three are career Seiko Epson inventors with large portfolios assigned to the same company; there is no evidence of any inventor departing the original assignee, and no inventor-to-third-party assignment appears anywhere in the accessible record. The absence of any inventor-side assignment event on the public docket is itself mildly notable — Seiko Epson routinely records its inventor→company assignments in the US (e.g., a comparable Epson recording appears at Reel 035691 / Frame 0967, recorded 2015-05-21, conveying rights in application 14/718,732), so a non-appearance here likely reflects indexing rather than an unrecorded transfer. Either way, the inventors' chain terminates at Seiko Epson.
Original assignee
Seiko Epson Corporation (4-1 Nishi-Shinjuku 2-chome, Shinjuku-ku, Tokyo; JP) — named on the face of the issued patent and the only assignee appearing in any publicly indexed legal event.
- Primary line of business: Operating manufacturer — inkjet printers, printing heads, ink cartridges and consumables, plus watches/robotics/electronics. Listed on the Tokyo Stock Exchange (Ticker 6724).
- Does it ship a product embodying the claims? Yes. The '248 patent is directed to the terminal layout on the ink-cartridge memory board (contact portions, staggered rows, asymmetric first/second regions, short-circuit detection between data/clock/reset/power/ground terminals). Epson's own OEM ink cartridges and the printers that accept them are the accused-product-side embodiment — Epson is asserting against third-party copies of that cartridge interface, not licensing it out.
- Current status: Operating. No bankruptcy, no dissolution, no IP-holding-company reorganization of this patent.
- Countervailing fact worth recording (not applicable to this patent): Seiko Epson has, in a different technology area, sold large portfolios to assertion entities — BOE's IPR filings describe Seiko Epson selling 2,500+ unused LCD patents to 138 East, an affiliate of IPValue Management / Longitude Licensing, which then asserted them. That establishes Epson will divest, so a future transfer of printer patents cannot be ruled out categorically — but there is no evidence of any such transfer for the '248 patent, and Epson is currently asserting it in its own name.
Assignment timeline
No post-issuance assignment is recorded in any public source I could access. Google Patents' legal-events table for US 12,240,248 contains only: the two JP priority claims (2021-12-28), the US continuation filings, the 2025-01-23 pre-grant publication (US2025/0026126 A1), and the 2025-03-04 grant. The only "assignee" entry — 2024-10-07 Application filed by Seiko Epson Corp — is an application-filing event, not an assignment, and must not be read as a recorded conveyance.
Consequently there is no chain to reconstruct: no Assignment, Security Agreement, Merger, Change of Name, License, Release or Correction record naming any entity other than Seiko Epson is reflected.
- Recorded assignments in the accessible sources: NONE.
- Correspondent of record on any assignment: N/A — there is no assignment record to carry one.
- Practical meaning: on the current record, the original assignee Seiko Epson Corporation still owns US 12,240,248 outright, and the file has never touched a licensing vehicle, securitization, or NPE.
To close this out definitively, run the patent number at the link in the Verdict section; if the Assignment Center returns only the inventor→Seiko Epson record (or nothing), the negative finding is confirmed.
Timeline diagram
timeline
title Ownership of US 12240248
2021 : Priority filing in Japan
2022 : US application 17 717 857 filed
2023 : Continuation 18 527 895 filed
2024 : Continuation 18 907 860 filed
2025 : Patent US 12240248 granted
: ITC complaint filed by Epson
2026 : General exclusion order issued
(Ownership does not change across any of these events — the diagram is a prosecution/enforcement timeline because no assignment event exists to plot.)
NPE / troll-pattern signals
Shell-entity transfer — NOT PRESENT. No assignment from Seiko Epson to any "IP / Patents / Licensing / Holdings / Ventures" entity appears in the record. No registered-agent address, no single-purpose Delaware/Texas LLC, because no third-party assignee exists.
Known asserter in the chain — NOT PRESENT. The only named owner is Seiko Epson Corporation, which appears on no NPE directory (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, DGC, Spangenberg entities). The current litigants are operating subsidiaries — Epson Portland Inc. (Hillsboro, OR) and Epson America, Inc. (Los Alamitos, CA) — i.e., the manufacturer's own US distribution/production arms, not assignees. Note this is the inverse of the privateering pattern: the operating company kept the patent and sued its own competitors' copyists.
Repeat correspondent across the chain — NOT APPLICABLE / UNCLEAR. With zero recorded assignments there is no correspondent chain to test for recurrence. For reference only — and explicitly not attributed to this patent — Seiko Epson's US assignment recordings have historically named James A. Oliff, Oliff PLC, P.O. Box 320850, Alexandria, VA as correspondent (observed on Reel 035691/Frame 0967, recorded 2015-05-21). That is a high-volume prosecution/recording firm doing ordinary operating-company work, not an NPE-assertion correspondent; a single appearance would not have been a finding even if it appeared here.
Cascading transfers — NOT PRESENT. No chained LLC transfers; no two consecutive assignments in any window, let alone under 24 months.
Pre-litigation transfer — NOT PRESENT. The first enforcement action naming the '248 patent (ITC Inv. No. 337-TA-1452, complaint filed 2025-05-13, instituted 2025-06-12) was filed by Seiko Epson and its subsidiaries. The patent was still owned by the original assignee, which had held it continuously since the 2021-12-28 priority date — roughly three years and four months of clean, untransferred title before assertion. There is no transfer to time.
Bankruptcy fire-sale — NOT PRESENT. Seiko Epson has not filed Chapter 7/11; it is a listed, profitable, operating manufacturer.
Privateering — NOT PRESENT. The patent is asserted by the operating company in its own name against unrelated importers of third-party ink cartridges (Dongguan Ocbestjet, Tatrix International, Zhuhai Hengyunda, Mountain Peak/Billiontree, Straightouttaink and ~15 others), all of which are aftermarket/third-party cartridge sellers — the classic patent-holder pattern with real competitive harm. No NPE fronting appears. Contrast the LCD portfolio described above, where Epson did sell out to an IPValue affiliate — showing the company distinguishes between patents it practices and patents it doesn't; the '248 patent is squarely in the former bucket.
Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. It terminates at the original manufacturer, which is now enforcing.
Additional cross-reference (flagging a data inconsistency rather than a fact): Google Patents' "Family has litigation" panel lists two ITC matters — 337-TA-1452 (verified, 2025) and 337-TA-3828. I could not verify the latter. An investigation numbered 337-TA-3828 would belong to roughly the late 1990s and is chronologically impossible for a patent with a 2021 priority date; it appears to be a mis-tagged or mismatched record in the Unified Patents ingestion, and should not be relied on without pulling the EDIS docket.
Verdict
Operating-company assertion.
Seiko Epson Corporation remains the sole owner of record — there is no recorded assignment of any kind in the publicly accessible record (Google Patents legal events show only priority claims, three continuations, the 2025-01-23 publication, and the 2025-03-04 grant; the 2024-10-07 "filed by Seiko Epson Corp" entry is an application-filing event, not a conveyance). The patent is asserted in its own name by Seiko Epson together with its operating subsidiaries Epson Portland Inc. and Epson America, Inc. in ITC Investigation No. 337-TA-1452 (complaint filed 2025-05-13, instituted 2025-06-12, general exclusion order issued and published 2026-08-18, with cease-and-desist orders against Mountain Peak/Billiontree and Straightouttaink). Every one of the eight NPE signals is absent, and the three-year-plus gap between the 2021-12-28 priority date and the 2025 enforcement filing with uninterrupted original-assignee title is affirmative evidence against a manufactured-chain reading.
Verify at: https://assignmentcenter.uspto.gov/ (Patent Assignment Search — search by patent number 12240248; mirror index at https://assignment.uspto.gov/patent/index.html). Docket cross-check: https://edis.usitc.gov (Inv. No. 337-TA-1452).
Confidence in the non-NPE conclusion: high. Confidence in the specific "zero assignment records" finding: moderate — it rests on the absence of indexed events plus the litigation record, not on a direct reel/frame query, which I was unable to execute in this session. Let the Assignment Center lookup stand as the authority on that point.
Generated 9/30/2026, 5:41:52 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research this patent and its cited references. Let me start with searches.
Let me dig into the specific citation records for this patent number.
Let me look for the front-page citation data specifically.
Analysis: US 12,240,248 B2 — "Board, liquid accommodation container, and printing system"
Important caveats up front (per your strict rules):
- I only have a web-search tool, not direct authenticated access to USPTO PatentCenter/PTActs. I could not retrieve the examiner-cited "References Cited" table or the "Cited By" table from the front page of this grant — the Google Patents rendering supplied to me in the authoritative patent text contains no citation tables, and my searches did not surface a clean citation list for this specific number. I will not fabricate that list.
- I will not auto-correct identifiers. I note that search results surface a separate, sibling grant, US 12,240,249 B2, with the identical title/abstract/assignee/inventors and the same March 4, 2025 issue date (HT Syndication; patents-review.com lists US 12,240,249 B2 as the grant of application 18/908,045). You asked about 12240248, so everything below is anchored to 12,240,248 B2 unless explicitly flagged otherwise.
1. Verified bibliographic record for 12,240,248 (as literally identified)
| Field | Value |
|---|---|
| Patent number | US 12,240,248 B2 |
| Title | Board, liquid accommodation container, and printing system |
| Application no. | US 18/907,860 |
| Filing date | 2024-10-07 |
| Publication date (grant) | 2025-03-04 |
| Pre-grant publication | US 2025/0026126 A1 (2025-01-23) |
| Inventors | Shuichi Nakano; Yasuhiko Kosugi; Jun Sato |
| Assignee | Seiko Epson Corporation (Tokyo) |
| Priority date (claimed) | 2021-12-28 |
| Priority sources | JP 2021-214129 → JP7176609B2; JP 2021-214139 → JP7176610B2 |
| Anticipated expiration | 2042-04-11 (per Google Patents legal-status field) |
| CPC | B41J 2/175**, incl. 2/17503, 2/17513, 2/1752, 2/17523, 2/17526, 2/1753, 2/17543, 2/17546, 2/17553 |
| Litigation flags on the Google Patents record | ITC 337-TA-1452 and 337-TA-3828 (reported literally) |
Continuity (from the patent's own CROSS-REFERENCE section): This application is a continuation of Ser. No. 18/527,895 (filed Dec. 4, 2023), itself a continuation of Ser. No. 17/988,307 (filed Nov. 16, 2022), itself a continuation of Ser. No. 17/717,857 (filed Apr. 11, 2022), claiming priority from JP 2021-214129 and JP 2021-214139, both filed Dec. 28, 2021.
2. The prior art actually identified in the patent itself
Because the front-page citation table was not retrievable, the defensible "most relevant prior art" enumeration is the Applicant-Admitted Prior Art (AAPA) expressly discussed in the BACKGROUND / "2. Related Art" section of 12,240,248. These are the references the specification characterizes as the closest art, and they are the ones an examiner or litigant would start from.
Reference A — WO 2012/029311 A1 (International Publication No. 2012-029311)
| Item | Detail |
|---|---|
| Full citation | International Publication No. WO 2012/029311 (cited in the patent as "International Publication No. 2012-029311") |
| Publication date | 2012 (PCT publication; the patent text gives no day/month) |
| Nature | PCT international publication (ink-cartridge terminal-group / mounting-detection technology) |
| What the patent says it discloses | A terminal group having five memory terminals and four mounting detection terminals, one of which receives "a high voltage higher than a power source voltage." The four mounting detection terminals are arranged at the four corners of the terminal group so as to surround the memory terminals. The printer determines the cartridge is mounted when a mounting detection terminal is electrically coupled to an apparatus-side terminal. |
| Technical field | Ink jet printing; ink cartridge electrical interface / cartridge presence detection |
| Potential § 102 relevance | Does not anticipate. It is cited for the mounting-detection concept and terminal-group architecture only. Critically, the reference's own geometry is the opposite of the claimed invention: the four detection terminals are placed symmetrically at the four corners surrounding the memory terminals, whereas claim 1 of 12,240,248 requires the some-contact-portions (first–fourth) in a first region and the remaining contact portion (fifth) in a second region, arranged asymmetrically with respect to a first virtual line. |
| Practical classification | § 102(b)/§ 102(a)(1) background art; better characterized as § 103 art when combined with another reference. |
| Anticipation verdict by claim | No claim anticipated. The element "the first pattern is asymmetrical to the second pattern with respect to a first virtual line" (present in every independent claim — board, container, and system) is absent, and in fact taught away from. |
Reference B — JP-A-2011-170740
| Item | Detail |
|---|---|
| Full citation | Japanese Unexamined Patent Application Publication No. JP-A-2011-170740 |
| Publication date | 2011 (the patent text gives no day/month) |
| Nature | Japanese published unexamined application (Seiko Epson-family cartridge/memory signaling art) |
| What the patent says it discloses | A storage device (e.g., a memory) in an ink cartridge outputs a response signal notifying that the storage device is coupled to a host device (printer) via any of a reset terminal, a clock terminal, and a data terminal. The host uses that response signal to determine coupling without a terminal dedicated to coupling detection. |
| Technical field | Ink jet printing; cartridge memory communication/protocol |
| Potential § 102 relevance | Does not anticipate. It discloses the response-signal protocol (which 12,240,248 uses as the basis for its combined mounting + short-circuit detection), but is silent on the physical arrangement of contact portions and on short-circuit detection between memory terminals. The patent itself states: "JP-A-2011-170740 [does] not mention short-circuit detection between the memory terminals," and lists that as a deficiency motivating the invention. |
| Practical classification | § 102(b)/§ 102(a)(1) background art; § 103 art if combined with a terminal-layout reference. |
| Anticipation verdict by claim | No claim anticipated — no disclosure of the asymmetric-region contact-portion layout, nor of the projection-position relationships (swd/swc/swvd/swr/swvs), nor the Wa / Wa-2 spacing limitations. |
Summary table — Applicant-Admitted Prior Art vs. the claims
| Reference | Discloses | Missing claim elements (representation of claim 1 in the spec) | § 102 anticipation? |
|---|---|---|---|
| WO 2012/029311 | Terminal group w/ 5 memory + 4 mounting-detection terminals; detection terminals at four corners surrounding memory terminals | Asymmetric first/second pattern split about the first virtual line; first–fourth contact portions in first region, fifth in second region; distinct projection positions; asymmetrical arrangement | No |
| JP-A-2011-170740 | Response signal over reset/clock/data terminal; host coupling determination | Same layout/asymmetry elements; plus short-circuit detection between memory terminals | No |
3. Documents that are not prior art against 12,240,248 (same-family / same priority date)
These appeared repeatedly in the search results and should be excluded from any § 102 analysis because they share the 2021-12-28 priority date (or are later-filed continuations of the same disclosure):
| Document | Relationship | Why not § 102 art |
|---|---|---|
| US 11,535,038 B1 (Seiko Epson, issued 2022-12-27) | Same family; same 2021-12-28 date, title/lineage overlap ("Board, liquid accommodation container, and printing system") | Same priority date — not "prior" |
| US 11,535,037 B1 (Seiko Epson, issued 2022-12-27; "Device, board, liquid accommodation container, and printing system") | Same-family sibling | Same priority date |
| US 12,240,249 B2 (app. 18/908,045; issued 2025-03-04) | Co-issued sibling, near-identical abstract | Same priority date; not prior art (and not the number you asked about) |
| US 2023/0202183 A1 | Pre-grant publication of the same family (listed there among "Priority Applications" leading to US18/907,860 → US12240248B2) | Same family |
| US 2025/0026126 A1 | Pre-grant publication of this application | Same application |
| JP7176609B2 / JP7176610B2 | Japanese priority documents (JP 2021-214129 / JP 2021-214139) | Priority documents, not prior art |
| US 2025/0144939 A1 | Later family member | Same family |
4. What I can state with confidence, and what I cannot
High confidence (grounded in the authoritative text and confirmed by search):
- Everything in Section 1 (bibliographic record, continuity, assignee, inventors, priority).
- The two prior-art references discussed in Section 2 are expressly identified in the patent's own Background, with the quoted characterizations.
- The ITC investigation flags 337-TA-1452 and 337-TA-3828 appear on the Google Patents record for this family (Google Patents / Unified Patents litigation data). The family shows a "First worldwide family litigation filed" flag (Darts-ip family 81325126).
Cannot confirm (and I will not guess):
- The complete examiner-cited "References Cited" list on the 12,240,248 front page. I could not retrieve it. To get it, query USPTO PatentCenter for application 18/907,860 (or the PAIR/PTActs record) and open the "References Cited" / "Patent Citations" section of the issued patent, or the "Cited By" list on Google Patents for US12240248B2.
- Whether any specific US counterpart of WO 2012/029311 (e.g., a US patent deriving from that PCT) is on the front page — I found no verified mapping and will not assert one.
- The exact publication day/month of WO 2012/029311 ("2012-02-…" style) and JP-A-2011-170740; the patent text itself gives only the years/years-and-serial.
Reminder on your instruction: I did not substitute US 12,240,249 for US 12,240,248, even though the two share title, abstract, assignee, inventors, issue date, and a nearly identical disclosure. If your target was actually the co-issued sibling, tell me and I will re-scope; the citation sets of the two are likely to differ because they are separate applications (18/907,860 vs. 18/908,045) with different claim sets and therefore potentially different examiner citations.
5. Claim-level bottom line on anticipation
The independent claims of 12,240,248 (board; liquid accommodation container; printing system) each require, in substance:
- a first terminal used to detect a short circuit with at least one of the second/third/fourth terminals (data vs. clock/reset/power-source);
- two orthogonal virtual lines C1/C2, with all contact portions projecting to different positions on C2, and C1 passing through the middle of the two farthest projection positions;
- some contact portions (first–fourth) in a first region, remaining (fifth = ground) in a second region;
- the first pattern asymmetrical to the second pattern with respect to C1.
Neither WO 2012/029311 nor JP-A-2011-170740 discloses the region-splitting/anti-symmetry geometry or the distinct-projection-position requirement. Under the strict "arranged as in the claim / all elements in one reference" standard (see Net MoneyIN, 545 F.3d 1369–71, as quoted in the PTActs material surfaced in my search), both are § 102 non-anticipatory. Their proper role is as § 103 starting references — WO 2012/029311 for terminal-group/cartridge-presence architecture and JP-A-2011-170740 for the memory-terminal response-signal protocol — to be combined with a terminal-layout reference if a validity challenge is mounted.
Recommended next step for a complete answer: pull the front page of US 12,240,248 B2 via USPTO PatentCenter (app. 18/907,860) to capture the examiner-cited references, then I can run the same four-field analysis (citation / dates / description / § 102 claim mapping) on each of those references individually. I did not want to invent that list.
Generated 9/30/2026, 5:42:06 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll gather the prior-art references cited on the patent record and any related references, then build the § 103 analysis.
I have the core prior-art family. Let me pull the specific reference details and the citation record for this patent.
Obviousness Analysis — U.S. Patent No. 12,240,248 ("the '248 patent") under 35 U.S.C. § 103
Note on inputs and method. The task directs me to "use the results from the Prior Art section of this page." The fetched patent text supplied in this task does not contain the Google Patents citation table (the "Cited By / Similar Documents / Prior Art" tables were stripped from the fetch). I therefore build the prior-art set from (a) the references the applicant itself cites and characterizes in the patent's BACKGROUND / "2. Related Art" section, and (b) references appearing on the Google Patents record for the '248 patent and its siblings as surfaced by search. I flag every ID I could not verify verbatim.
Contradiction flagged (per instructions): this task states "Current Date: April 26, 2026," while the previously generated sections report ITC events dated August 2026 (final determination / GEO publication 2026‑08‑18) and the system clock reads 2026‑09‑30. I do not reconcile these; the § 103 analysis below is date-insensitive except as noted for prior-art status, and I rely on the previously generated litigation sections rather than repeating them.
1. What claim 1 actually requires (verbatim scope reconstructed)
Claim 1's text (matching the published A1 claim 1 "in a plan view…" passage quoted by Justia and Patents‑Review, and reproduced as "Exemplary embodiment 1" in the specification) has five bite-sized requirement groups:
| Element | Requirement | Where supported in the '248 disclosure |
|---|---|---|
| (a) | Board mountable in a printing apparatus having a print head, a liquid introduction portion, an accommodation section, and plurality of apparatus-side terminals | Spec. ¶ re printing system 1000 / carriage 30 |
| (b) | Base member; device at the base member; plurality of terminals each coupled to the device, each with a contact portion | device 130 / processing unit 136 / storage unit 138 |
| (c) | Five terminals: first (data 210), second (clock 220), third (reset 240), fourth (power-source 230), fifth (ground 250), each contacting a corresponding apparatus-side terminal | spec. "first terminal…fifth terminal" naming |
| (d) | "the first terminal is used to detect whether or not the first terminal has a short circuit with at least one of the second terminal, the third terminal, and the fourth terminal" | FIGS. 10A–21A; data terminal 210 short determination |
| (e) | Plan view: orthogonal virtual lines C1, C2; projecting all contact portions perpendicular to C2 onto C2 → all projection positions different; C1 passes through the middle between the two farthest-apart projection positions | FIGS. 5–6; swc/swd/swvd/swr/swvs |
| (f) | C1 divides the base member into first/second regions; some contact portions (including first–fourth) in the first region; remaining (including fifth) in the second region; the two groups asymmetrical with respect to C1 | FIG. 5; ground isolated in Rg2 |
Two structural observations that drive the whole analysis:
- Element (e) is largely a claim-drafting construct. C1 is defined by the layout ("passes through the middle between the two projection positions that are farthest from each other"), so it is satisfied by every board that has more than one laterally offset pad. "All projection positions different" is satisfied by any staggered/offset pad layout. A single reference teaching a staggered multi-row contact pattern therefore meets (e).
- Element (f)'s "asymmetry" is nearly free. Once one pad (ground) sits on the far side of C1 from four other pads, the two "patterns" cannot be mirror images — the pad counts differ (4 vs. 1). The substantive content of (f) is simply: the ground contact portion is pushed across the midline, separated from the other four by a gap wide enough that the midpoint of the extreme projections falls in that gap. That is what the uneven spacings in the spec (Dan > Dbn/Den; the closest other pad ≥ Wa/2 per dependent claim 12) are engineered to achieve.
So the claim's novelty is really (i) the five-terminal identity set, (ii) using the data terminal as the short-detection terminal, and (iii) isolating the ground pad on the opposite side of an inter-pad midline, with a staggered layout.
2. Prior art of record
| Ref. | ID as it appears | Pub. | Assignee / inventors | Key teaching | Status |
|---|---|---|---|---|---|
| [WO311] | International Publication No. 2012-029311 (WO‑2012029311‑A1); US counterparts US 8,434,851 / US 8,567,897 ("Circuit substrate") | 2012‑03‑07 | Seiko Epson; Nakano Shuichi, Asauchi Noboru; prio. 2010‑09‑02 | Storage device + "first terminals" (memory) supplied power/signals + "second terminals" used for detecting installed state. First & second contact parts "arranged to form a first row and a second row"; four second contact parts positioned at both ends of the first and second rows; mounting-detection contact portions 210/240/250/290 at the four corners surrounding five memory pads 220/230/260/270/280 | Applicant-admitted prior art (cited in '248 BACKGROUND) |
| [JP740] | JP-A-2011-170740; US counterpart US 2011/0208991 A1; EP 2 361 770 A1 | 2011‑09‑01 | Seiko Epson; inventor Jun Sato (= '248 co-inventor); prio. 2010‑02‑22 | Memory device outputs a response signal "for notifying that the memory device is connected" to the host via any of terminals P1–Pk (reset/clock/data), in the clock period corresponding to the device's ID. Stated object: "suppress an increase in the number of terminals while efficiently performing connection detection." Mode determination (normal vs. connection-detection) from reset/clock levels | Applicant-admitted prior art (cited in '248 BACKGROUND) |
| [US318] | US 2008/0158318 A1 ("Printing material container, and board mounted on printing material container"); family AU 2006252199 B2, EP 1800872 | 2008‑07‑03 | Seiko Epson; prio. JP 2005‑372028 / 2006‑220751 | Container with first device + second device + terminal group: first terminals (to first device), ≥1 second terminal (to second device), ≥1 third terminal "for the detection of shorting between the at least one second terminal and the at least one third terminal." Third terminal placed relative to second terminal "without a said first terminal therebetween in at least one direction," so that shorting between second and third occurs with greater tendency than shorting between first and second — i.e., the short is made detectable. Also: "at least one second contact portion is arranged at an end of one row." | §102(a)(1) (pub. >1 yr pre-priority) |
| [US722] | US 2014/0327722 A1 ("Printing material container, and board mounted on printing material container") | 2014‑11‑06 | Seiko Epson | Short-detection terminals 210/240 + high-voltage sensor-drive terminals 250/290; contact locations CP arranged in a staggered pattern; elongated terminals spanning the upper and lower rows; expressly addresses shorting caused by an ink drop (S5, S6); Variation 5 = integral ground + short-detection terminal; Variation 6 = single row with sensor-drive terminals at both ends | §102(a)(1) |
| [EP1598] | EP 1 598 198 A2 / EP 1 219 437 B1 (circuit board for marking-material receptacle) | 2005 / 2002 | Seiko Epson | Storage device + terminals arranged in a plurality of rows, incl. power-supply terminal and control-signal terminal; "two ground terminals arranged at two edges… located at the outermost ends of one of the rows," expressly "not the terminals in closest proximity to said power supply terminal," and used for detecting contact of the printing-device terminals | §102(a)(1) |
| [EP2719] | EP 2 719 538 A1 (= ES 2 436 842 T3) | 2014 | Seiko Epson | Contact portions form a plurality of lines; two installation-detection terminal contact portions in a first line with the power-terminal contact between them; reset terminal situated in a different line from the first line | §102(a)(1) |
| [JP5861] | JP 5861313 B2 (printing device) | 2016 | Seiko Epson | Short-circuit detection between memory terminals: memory terminals set to high-impedance; short-circuit detection unit 310 detects DT1–CO1 / DT2–CO2 shorts; prevents VHO reaching the memory terminal | §102(a)(1) |
Prior-art status nuances (important, and favorable to a challenger):
- All of the above published more than one year before the earliest effective filing date (2021‑12‑28). The AIA §102(b)(1)(A) inventor grace period therefore cannot rescue the applicant, even for [JP740] — which names Jun Sato, a '248 co-inventor. Because it published in 2011, it is §102(a)(1) art notwithstanding the inventor overlap. Same for [WO311] (names Nakano, a '248 co-inventor).
- The §102(b)(2)(C) common-ownership exception does not apply to [US318], [US722], [EP1598], [EP2719], [JP5861], because those are relied on as §102(a)(1) printed publications (each published far more than a year before), not as §102(a)(2) art. This is the single most important status point — a common-assignee reference (Seiko Epson) is fully available when used as a printed publication.
- What cannot be used: the '248's own family siblings — US 11,535,037 / US 11,535,038 / US 11,872,822 / US 12,251,939, and the JP priority documents JP7176609B2 / JP7176610B2. These share the '248's 2021‑12‑28 priority and inventive entity and are commonly owned; they are not "by another" and are excepted under §102(b)(2)(C) as §102(a)(2) art. (They may still matter as admissions about what the art knew, but they are not standalone references.)
- Not relied on: JP 2021‑187023 A surfaced in search but its publication date appears to be within weeks of the 2021‑12‑28 priority date; I could not verify it precisely, so I exclude it.
3. Grounds of rejection
GROUND 1 — [WO311] in view of [JP740]
Covers elements (a)–(c); supplies part of (d).
- [WO311] provides the complete hardware predicate: an ink-cartridge circuit board with a device (storage device), five memory terminals (power, reset/clock/data/ground family) and row-based contact arrangement, for a printing apparatus with a print head, liquid introduction portion and accommodation section.
- [JP740] supplies the mounting-detection-by-memory-terminal function: the device outputs a response signal through one of its own terminals so the host can tell the device is coupled, expressly to avoid increasing the terminal count.
Motivation (KSR (A), (B), (C)): [JP740]'s stated object — "suppress an increase in the number of terminals while efficiently performing connection detection" — is a direct, articulated reason for a POSITA to substitute [WO311]'s dedicated second (mounting-detection) terminals with [JP740]'s response-signal scheme. The result — the five-terminal board of element (c) — is the predictable product of substituting one known mounting-detection mechanism for another. The '248 specification itself has no new hardware here; its five terminals are, in substance, [WO311]'s memory terminal set.
Gap: Ground 1 alone does not supply element (d)'s short-circuit detection role or element (e)–(f)'s geometry. It is the base of Grounds 2 and 3, not a stand-alone rejection.
GROUND 2 — [WO311] + [JP740] + [US318] (+ optionally [US722])
Covers (a)–(f). This is the strongest combination.
- [US318] supplies element (d) directly. It teaches a cartridge terminal group where a dedicated terminal exists "for the detection of shorting between the at least one second terminal and the at least one third terminal," and — critically — it teaches arranging the terminals so that the short becomes detectable: the contact portions are placed "without a said first terminal therebetween in at least one direction," so that shorting between the second and third terminals "have a greater tendency to occur than shorting between the first terminal and the second terminal," with the stated benefit that "in the event that the shorting… occurs by a drop of ink or foreign matter, it is highly likely that the shorting… also occurs, and is detected as anomaly." This is the same inventive insight the '248 states as its advantage ("detect a short circuit when the short circuit occurs between at least some terminals"), and it is the same failure mode (ink/foreign matter bridging pads).
- [US318] also supplies the "end of a row" placement that maps onto element (f)'s isolation of the ground pad.
- [US722] reinforces (d) and (e): it discloses short-detection terminals alongside high-voltage sensor terminals, staggered contact locations CP, and expressly addresses ink-drop-induced shorting, i.e., it confirms the problem-and-solution pairing in the same field.
- [JP5861] provides corroborating evidence that detecting a short involving a memory terminal (data/clock/reset/power-source vs. detection terminals) was known, by setting memory terminals to high-Z and sensing the short.
Motivation (KSR (A), (C), (D)): All three references are Seiko Epson ink-jet cartridge/board references in the same field of endeavor, addressing the same problem — protecting the device from, and detecting, shorts between closely spaced cartridge pads caused by conductive ink and foreign matter. A POSITA optimizing the [WO311]+[JP740] five-terminal board would (i) place the five pads in the existing two-row/staggered pattern ([WO311], [US722]), (ii) use the memory-terminal response signal for mounting detection ([JP740]), and (iii) arrange the terminal whose short is most damaging/least tolerable so it is separated from the rest, as [US318] teaches for its short-detection terminal and [EP1598] teaches for the ground terminals. The '248's own specification supplies the design rationale the POSITA would already have: the power-source terminal and clock terminal apply higher drive load, and the clock low-period is longer than the reset low-period — so maximizing the data-to-ground spacing is simple optimization of a recognized, result-effective variable (KSR; In re Ethicon).
Why the geometry is met: With ground pushed to the extreme end and clock at the other extreme, the count asymmetry (4 vs. 1) makes element (f)'s "asymmetrical" limitation trivially satisfied; the "all projection positions different" requirement is met by the staggered/offset layout of [WO311]/[US722]; and C1, being defined by the extreme projections, necessarily falls in the gap the layout creates.
GROUND 3 — [US318] + [EP1598] + [JP740]
Covers (a)–(f), anchored on the short-detection and ground-isolation teachings rather than on [WO311].
- [EP1598] supplies the ground-isolation element with unusual directness: two ground terminals "located at the outermost ends of one of the rows," expressly "not the terminals in closest proximity to said power supply terminal," used for contact detection. Applied to a five-terminal set, selecting the ground pad's position at the row terminus yields exactly the claimed split — the midline between the extreme projections falls between the ground pad and the remaining four.
- [US318] supplies the short-detection terminal arrangement and the "end of a row" placement; [JP740] supplies the memory-terminal-based detection and the five-terminal set.
Motivation (KSR (C), (D)): Using a known technique — placing the ground pad at the extreme end of the terminal group, away from the power terminal — to improve a similar cartridge board in the same way, to obtain the predictable result of greater ground-to-signal-pad spacing and lower short-circuit susceptibility.
GROUND 4 — [US722] + [EP2719] + [JP740]
Covers (a)–(f) with emphasis on the ordering/line-splitting dependent features.
- [EP2719] teaches the line-splitting concept: contact portions form a plurality of lines; the power-terminal contact is placed between the two detection-terminal contact portions in the first line; and the reset terminal is deliberately placed in a different line from the first line (to reduce operating errors of the memory device). That is the same rationale the '248 gives for putting the reset and power-source pads where it does.
- [US722] supplies the staggered pattern and elongated-terminal variants; [JP740] supplies the response-signal detection.
4. Claim 7 (liquid accommodation container)
Claim 7 was asserted and survived the partial termination of claims 13, 15, 20 and 21; the description recites a container-level aspect that mirrors the board claim ("a liquid accommodation container that is mounted on an accommodation section of a printing apparatus including a print head, a liquid introduction portion…"). On my earlier medium-confidence reading, claim 7 adds only the conventional container elements — a liquid accommodation body, a liquid supply portion having a liquid supply port mountable to the liquid introduction portion, a device, and the same five-terminal/asymmetry geometry. Those container elements are ubiquitous and are disclosed by [US318] and [US722], which are literally "printing material container and board mounted on printing material container" references, and by [WO311]. Accordingly the same Grounds 1–4, each of which includes at least one pre-2021 cartridge-container reference, render claim 7 obvious for the same reasons. I still cannot confirm claim 7's verbatim text and flag that limitation.
5. Dependent claims — mostly optimization and design choice
Using the claim-by-claim correspondence between the published claims and the specification's "Exemplary embodiments":
| Feature | Obviousness basis |
|---|---|
| ≥1 (¶) or ≥2 of clock/reset/power-source projected between the data and ground projections | Inherent consequence of isolating ground at one end and data among the other four — [US318] "without a said first terminal therebetween"; [EP1598] ground at row end |
| Data projected between two of clock/reset/power-source | Design choice among the finite orderings of four pads |
| Assignment: data/clock/reset/power-source/ground | Expressly [WO311] (memory terminal set) + [EP2719] |
| Reset next to power-source; data/reset between power-source and clock | [EP2719] (power between detection terminals; reset in a different line) + [US722] |
| Clock farthest from ground; data → power-source → reset toward ground | Routine layout choice; follows directly from isolating ground |
| Distance data–ground > data–clock / data–reset / data–power-source | Optimization of a recognized result-effective variable; the '248's own spec states the rationale (clock low-period longer; power-source drive higher) |
| Wa / ≥ Wa/2 (closest other pad ≥ half the farthest gap) | Pure numerical-range optimization; no criticality or unexpected result disclosed |
| No other contact portion on the data–clock / data–reset / data–power-source line segments | [US318] ("without a said first terminal therebetween") |
| Gravity-direction placement (clock/power-source/reset below data) | Dictated by mounting orientation of the container in the carriage; [EP1598] and [EP2719] both recite gravity-relative orientation |
6. Secondary considerations / objective indicia
- Copying. The previously generated litigation sections report a §337 violation finding and a general exclusion order (Aug. 2026) covering claims 1 and 7 of the '248 patent, with 20 named respondents and CDOs against Mountain Peak, Inc. and Straightouttaink, LP. Under WBIP v. Kohler, copying can be probative, but only with nexus; here the accused third-party cartridges must mate with Epson's own apparatus-side terminal block, so the terminal layout is substantially dictated by an interoperability constraint, which weakens the nexus and simultaneously undercuts non-obviousness (the arrangement is where the mating terminals force it to be).
- No long-felt need. The '248 is the latest in a continuous Seiko Epson development chain (2005/2006 → 2010/2011 → 2013/2014 → 2021) of the very same short-detection and terminal-arrangement concepts. Incremental, continuous corporate development of a crowded art cuts against non-obviousness, not for it.
- No unexpected results or criticality are disclosed for the Wa/2 or ordering limitations.
7. Where the obviousness case is weakest (patentee's best rebuttals)
- Teach-away from removing dedicated detection terminals. [WO311], [US722] and [JP5861] all emphasize protecting the memory terminals from the high voltage (VHV/VHO) applied to the mounting-detection/sensor-drive terminals. A patentee will argue that the art deliberately kept detection terminals electrically distinct from the memory bus, and that a POSITA would not have collapsed them into the five low-voltage memory terminals. Counter: [JP740] — same assignee, same field — expressly designs for detection without a dedicated terminal to avoid increasing terminal count, and the '248's five-terminal set is simply [WO311]'s memory terminal set; the "collapsing" step was [JP740]'s stated object.
- Symmetric vs. asymmetric ground. [EP1598] teaches two ground terminals at the two outermost ends of a row, which, faithfully followed, produces a symmetric arrangement — arguably the opposite of claim 1's asymmetry. This is the patentee's sharpest point. Counter: [US318]'s "at least one second contact portion is arranged at an end of one row" shows a single end pad, and the '248's own Embodiment 2 (board 120e, two ground terminals at different rows) demonstrates that one-vs-two ground pads was a routine workshop variation; the claim requires only one fifth contact portion, so the POSITA need only select one of [EP1598]'s two edge positions.
- Role mismatch on element (d). [US318]'s detection terminal senses a short between the second and third terminals, whereas claim 1 requires the first (data) terminal to be used to detect a short between itself and the second/third/fourth. A patentee will argue this is a different role assignment. Counter: [JP5861] senses shorts involving memory terminals; and the '248's own FIGS. 13A–20B / 21A show the apparatus determining "short circuit occurring" purely from the data terminal's observed voltage pattern versus the clock/reset/power-source signals — a determination that any [JP740]-type response-signal scheme inherently enables. The claim's "is used to detect" is a capability/utility limitation, which the art's data-line diagnostics meet.
- Claim-drafting constructs. The C1/C2 definitions invite the argument that they are not structural limitations and read on every staggered layout; that cuts for the challenger, but a patentee may argue they must be given limiting weight as the only thing distinguishing the claim, which then makes the claim commensurately narrow. This is the classic prosecution standoff and would likely require an expert declaration and a claim-construction ruling.
8. Bottom line
| Claim | Strength of §103 case | Best ground |
|---|---|---|
| 1 (board) | Moderate-to-strong — each element is met by a Seiko Epson reference in the same field, all published >1 year pre-priority and therefore immune to the §102(b) exceptions; the motivation to reduce terminal count and to isolate the ground pad is express in the admitted art | [WO311] + [JP740] + [US318] (+[US722]); alternatively [US318] + [EP1598] + [JP740] |
| 7 (container) | Moderate-to-strong, on the same grounds, given that [US318] and [US722] are themselves container/board references | Ground 2 / Ground 3 |
| Dependent claims | Mostly strong — orderings, spacings and Wa/2 are design choices and optimization | [EP2719] + [US722] + spec's own rationales |
| Claims 13, 15, 20, 21 | Not analyzable — verbatim text unavailable (terminated at complainants' request, ITC ID No. 11 / Commission notice of 2026‑01‑20) | — |
Confidence summary. High: reference IDs, dates, assignees, and the substance of [WO311], [JP740], [US318], [US722], [EP1598], [EP2719] as set out above; the §102 status analysis (publication >1 year before 2021‑12‑28 defeats the §102(b)(1) inventor grace period and makes the common-ownership exception irrelevant). Medium: the verbatim scope of claim 1 (reconstructed from the specification's "Exemplary embodiments" and the A1 claim text quoted by secondary sources) and of claim 7. Low: verbatim claims 7, 13, 15, 20, 21; whether the '248 file wrapper cited additional art; whether JP 2021‑187023 A is pre-priority art.
Generated 9/30/2026, 5:43:32 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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