US 12406284

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

Let me search for litigation/docket information and the claim text.

Let me search for the claim text and the litigation docket specifics.

US 12,406,284 B2 — Analyst Summary

Source of record: https://patents.google.com/patent/US12406284/en (fetched 2026‑09‑18). I treated the patent number as literal: US 12,406,284 B2, application US 18/652,765. I did not match against similar numbers (e.g., the USPTO application 12/600,284 appearing in search noise is a different, unrelated file — a polyester-composition appeal — and is not this patent).

Bibliographic data (from the patent record)

Assignment history (reported literally, not reconciled): 2025‑07‑02 — assigned to INTERACTIVE GAMES LLC (assignor CFPH, LLC); 2025‑10‑02 — assigned to CFPH, LLC (assignors: Lutnick, Alderucci, Papageorgiou, Gelman, Miller, Burman). These two entries run in opposite directions as published; I flag this as an apparent inconsistency in the record rather than correcting it.

Abstract

I do not have authoritative abstract text for this patent. The Google Patents snapshot I retrieved was truncated at the end of the description and does not include the ABSTRACT section, and my searches did not return a verbatim abstract from an independent source. I will not reconstruct one. To obtain it verbatim, pull the front page from USPTO PatentCenter/Patent Public Search (application 18/652,765) or the US 2024/0281851 A1 publication.

Independent claims — plain‑language overview

I cannot give a reliable, claim‑by‑claim overview, and I am flagging this as a hard limitation rather than guessing. The authoritative full text I retrieved ends mid‑sentence inside the description ("…the retail server may display an indication of the promotion to a repres‑") and does not include the claims section at all. I also did not locate the granted claim set through search. Inventing claim scope here would be exactly the kind of fabrication you asked me to avoid.

What the record does support, at lower confidence:

• The claimed subject matter sits in the CFPH/Lutnick promotional‑advertising family (priority 2009‑02‑13). The disclosed embodiments concern a casino server coordinating promotions to mobile gaming devices, with proximity detection between a mobile device and stationary devices (slot machines, displays, POS terminals), and with devices near a player being enlisted to co‑present a promotion.
• The examiner/indexing keywords "low priority," "priority data," "player," "mobile phone," "promotion" suggest the independent claims are directed to delivering/formating promotional content to a mobile device based on priority data (e.g., ranking or selectively transmitting content according to a priority designation), combined with proximity tracking — consistent with the title's "selective content delivery and formatting."
• That keyword‑based inference is not a substitute for the claim text. Anyone relying on claim scope should read the granted claims directly.

Litigation / court dockets

• District court (not CAFC): A US case was filed in the Massachusetts District Court — Interactive Games LLC v. DraftKings, Inc., 1:26‑cv‑11544. Per CourtListener, the complaint (filed 2026‑04‑02) attaches "Exhibit U.S. Patent No. 12,406,284" (Document #1, Attachment #7). The Google Patents record links this case via Unified Patents' litigation dataset. The patent record also carries a Darts‑IP flag for "First worldwide family litigation filed" (family 42560723).
• Related but separate: Interactive Games LLC v. FanDuel, Inc., 2:26‑cv‑03514 (D.N.J., complaint filed 2026‑04‑02, naming Betfair Interactive US, LLC and FanDuel, Inc.) appears in the same enforcement wave; I could not confirm that '284 is asserted there.
• CAFC 2026 dockets: I found no Federal Circuit 2026 docket entry specifically for US 12,406,284. The Interactive Games Federal Circuit activity I located (e.g., appeal 22‑1516 against DraftKings; 19‑1523 v. FanDuel) concerns other patents (e.g., US 8,956,231 B2) and IPR appeals resolved by Rule 36 affirmances. A CAFC appeal from 1:26‑cv‑11544 would be premature as of the record date, since that case was only filed in April 2026.

Confidence and caveats

• High confidence: patent number, title, application number, filing/issue dates, priority date, inventor list, assignee, publication numbers, CPC classes, and the existence of D. Mass. 1:26‑cv‑11544 with '284 attached as an exhibit.
• Not verified / unavailable to me: the abstract text; the granted independent and dependent claim language; the CAFC 2026 docket status for this patent; the exact nature of the 2025‑07‑02 vs. 2025‑10‑02 assignment entries.
• Search noise caveat: queries for "12406284" returned several unrelated hits (a Czech contract registry ID, a PTAB application 12/600,284, etc.). None of those is US 12,406,284.

I'll search for litigation specifically involving US 12,406,284.

Now let me check the FanDuel case and any PTAB proceedings involving '284.

Let me verify whether '284 appears in the FanDuel case, and check the Unified Patents litigation portal.

Litigation involving US 12,406,284 B2

I searched for the literal number 12,406,284 and excluded similar numbers (e.g., the PTAB application 12/600,284; the Czech registry ID that surfaced as noise). One (1) litigation is known in which this patent is asserted. It is a pending, early-stage district-court case. No PTAB/IPR challenge and no Federal Circuit appeal specific to '284 were found.

Case 1 — Interactive Games LLC v. DraftKings, Inc. (the only known assertion of '284)

Corroborating source notes. DraftKings' Form 10-Q describes this case under the heading "Interactive Games II" and lists the fifth asserted patent verbatim as "U.S. Patent No. 12,406,284, entitled 'Mobile device proximity tracking for selective content delivery and formatting'" — matching our title of record. It states "The Company has not yet responded to the complaint."

What the '284 claim chart tells us (new since the earlier summary). Asserted claims are identified as claims 1–4, 8, 10–14, 16–23, and 25–28, with Claim 1 reciting a "mobile phone comprising" at least one computer processor executing a mobile application, a touch-screen UI, "low priority data," a "player prevention alert" displayed and wagering prevented "based on a determination that the mobile phone is not in a gaming area," user input to remove the alert, and enabling play. Claim 2 recites the "edge of an area where gambling is allowed" basis for the low-priority data; Claim 3 recites repeatedly sending location data. This partially validates the prior section's keyword-based inference (the record's "low priority / priority data" keywords correspond to actual claim language) and supplies the claim-scope detail the earlier section explicitly lacked.

Cases that do NOT involve '284 (checked and excluded)

• Interactive Games LLC v. FanDuel, Inc. / Betfair Interactive US, LLC, D.N.J. 2:26-cv-03514-KMW, complaint filed April 2, 2026 — the parallel enforcement-wave case. The complaint asserts five different patents (abbreviated in the briefing as the '181, '226, '302, '138, and '515 patents, e.g., U.S. Patent No. 12,397,226). '284 is not among them. This resolves the open item in the prior summary: '284 could not be confirmed in the FanDuel case because it is not asserted there.
• Earlier Interactive Games / CG Technology v. DraftKings and v. FanDuel matters (the 2016 Nevada/IG-Tech wave; D. Del. 1:17-cv-01041; D. Del. 19-1105-RGA; and the associated IPRs) concern other patents (e.g., 8,956,231; 8,974,302; 8,616,967; 9,430,901; RE39,818; 8,771,058; 9,306,952; 9,355,518, etc.). '284 issued September 2, 2025, long after those disputes arose, so it cannot have been asserted in them.
• PTAB: No IPR/PGR against '284 was found. The Interactive Games PTAB docket is limited to IPR2020-01107/01108/01109/01110 (DraftKings) and IPR2017-01333/01491/01532 (FanDuel), all directed to other patents.
• Federal Circuit: No 2026 appeal concerning '284 exists; as noted previously, any appeal of 1:26-cv-11544 would be premature.

Flags / caveats

1. Date inconsistency (important). You state the current date is April 26, 2026, but the records I retrieved include docket activity dated May 27, 2026 and a docket note that it "was last retrieved on May 27, 2026," plus a PatSnap item referencing a 2026 Federal Circuit decision dated May 15, 2026. Either the stated current date is stale, or these sources are post-dated. I am reporting the records as retrieved, with their own dates, and flagging rather than silently reconciling.
2. The Google Patents record itself carries a family-level Darts-IP "First worldwide family litigation filed" flag (family 42560723) and links the Unified Patents litigation entry for "Massachusetts District Court, case 1:26-cv-11544." No foreign litigation against '284 specifically was identified.
3. Google Patents' generic litigation link appears to be a family/patent-level flag, so it does not by itself prove which family member was asserted — the attachment and claim-chart evidence above does that independently.
4. Nothing found suggests any second defendant or second case asserting '284; per the record, the 1:26-cv-11544 case names DraftKings, Inc. alone, and the later FanDuel complaint omits '284.

Bottom line: one known litigation — Interactive Games LLC v. DraftKings, Inc., D. Mass. 1:26-cv-11544-WGY, filed April 2, 2026, pending, with a § 101 partial motion to dismiss that does not currently target '284.

I'll research the single identified proceeding and check for anything the structured block may not include.

Let me search for the specific proceeding and any related PTAB docket activity.

Let me try to locate the proceeding's docket page and any petition details.

Proceedings overview

One AIA trial proceeding is on file against US 12,406,284 — a single IPR (IPR2026‑00493, DK Crown Holdings Inc. et al., filed 2026‑09‑17) that is one day old: no institution decision, no FWD, no cancellation, no settlement, no estoppel. Because nothing has been decided on the merits, the defensive posture is "the patent has been attacked but is completely unbriefed — the challenge is a live but unproven threat," not "hardened" and not "dead." For a defendant facing assertion today, this means (i) no claim of '284 has been canceled or even reviewed, (ii) no § 315(e)(2) estoppel has attached to anyone, and (iii) the entire prior-art space remains available to you — but you will be litigating in parallel with a co-defendant who is already at the PTAB.

⚠️ Correction to the previously generated sections. The litigation summary stated: "No PTAB/IPR challenge … specific to '284 were found" and that the Interactive Games PTAB docket was "limited to IPR2020‑01107/01108/01109/01110 (DraftKings) and IPR2017‑01333/01491/01532 (FanDuel)." That is now superseded. Per the canonical USPTO Open Data Portal list in this prompt, IPR2026‑00493 exists and was filed 2026‑09‑17. The earlier statement was true as of the earlier research cut-off; it is stale as of 2026‑09‑18. Likewise, the earlier sections flagged a date inconsistency (task date "2026‑04‑26" vs. May 2026 docket activity); with today's date of 2026‑09‑18, that flag is resolved — the April/May 2026 docket entries are simply in the past.

IPR2026‑00493 — DK Crown Holdings Inc. et al. v. Interactive Games LLC

• Type: Inter Partes Review (IPR), 35 U.S.C. §§ 311–319. Not a PGR, not a CBM (CBM is unavailable for a patent with a 2009 priority date — the transitional CBM program covered only certain financial-services patents and has been closed to new petitions since 2020‑09‑16).

• Filed: 2026‑09‑17 (structured data, verbatim). This is one day before the analysis date.

• Status: Pending — verbatim from the structured data. Plain-English gloss: petition filed and accorded a filing date; no Patent Owner Preliminary Response is due yet; no institution decision has issued; the proceeding has not been instituted, so it is not yet a "trial."

• Judge panel: Not public. Under the AIA, a three-APJ panel is designated only when the Director's delegate decides institution (37 C.F.R. § 42.4 / § 42.108). Because no institution decision exists, no panel has been announced. Any names here would be fabrication.

• Petition grounds: Not determinable from the available record. The structured feed does not carry grounds, challenged claims, or assigned art, and my searches did not surface the petition PDF or the PTAB docket page body for IPR2026‑00493. I will not guess. Two things I can state:

  • The patent carries a 2009‑02‑13 earliest priority date and is a continuation filed 2024‑05‑01 (app. 18/652,765). If the challenged claims are entitled to that 2009 priority, the pre‑AIA §§ 102/103 framework would apply — but that is a priority-dependent inference, not a fact I can confirm for the petition as filed.
  • The district-court defendant has charted the patent against DK apps only (DraftKings Sportsbook & Casino, DK Fantasy Sports, DK Casino Real Money, DK Horse Racing & Betting, Golden Nugget Online Casino, DraftKings Pick6) and asserts claims 1–4, 8, 10–14, 16–23, and 25–28 (D. Mass. Dkt. 1‑12, "Exhibit 10 – Initial Infringement Claim Chart"). A defendant's IPR is typically co-extensive with the asserted set for Sotera/stipulation reasons — but I have no confirmation that IPR2026‑00493 challenges that set, and I am not asserting it.

• Institution decision: None yet. Statutory deadline under 35 U.S.C. § 314(b) is 6 months from the petition filing date, which projects to on or about 2027‑03‑17 (projection based on the statute, not a docketed date). Patent Owner's preliminary response would ordinarily be due about 3 months after notice of filing, i.e., on or about 2026‑12‑17 (37 C.F.R. § 42.107(b)) — again a projection.

• Final Written Decision: None — legally impossible at this stage. An FWD cannot issue before institution, and the statutory FWD deadline is 12 months from the institution date (§ 316(a)(11)). If institution occurs near 2027‑03‑17, an FWD would be due near 2028‑03‑17. No claims of '284 have been canceled and no claims have been sustained in any AIA trial to date.

• Settlement / termination: None. No termination, no adverse judgment, no request for adverse judgment, no joinder, no motion to amend.

• Appeal: None, and premature. There is no FWD to appeal. Separately, and on a different patent, the same petitioner family has recent Federal Circuit exposure in this space: DK Crown Holdings Inc. v. AG 18, LLC, No. 2024‑2078 (Fed. Cir. May 6, 2026) (nonprecedential) — https://law.justia.com/cases/federal/appellate-courts/cafc/24-2078/24-2078-2026-05-06.html — where the court affirmed the Board's refusal to let DK add a new ground against claim 18 of U.S. Patent No. 9,978,205 in a reply footnote, and rejected DK's collateral-estoppel theory. That decision does not involve '284 and does not bind or dispose of anything here.

• Defensive value: Because nothing has been decided, this proceeding invalidates no claim and creates no estoppel. Its practical value to you today is intelligence and timing: it tells you the primary accused party has committed to (or is at least attempting) a PTAB track, that a co-pending district case exists in D. Mass., and that your own § 315(b) one-year clock is running from your service date. It also creates a risk of redundancy and of a discretionary-denial fight under § 314(a)/§ 325(d) if you file a me-too petition without a distinct ground or a stipulation.

Strategic summary

Claim status: everything is UNTESTED. No claim of US 12,406,284 has been canceled, confirmed, or even instituted for review. The complete set of claims currently in play anywhere is the district-court asserted set — 1–4, 8, 10–14, 16–23, and 25–28 — charted in D. Mass. Dkt. 1‑12 (https://www.courtlistener.com/docket/73132799/1/12/interactive-games-llc-v-draftkings-inc/). Representative claim 1, as described in that chart, recites a mobile phone with at least one computer processor executing a mobile application, a touch-screen UI, "low priority data," a "player prevention alert" displayed with wagering prevented "based on a determination that the mobile phone is not in a gaming area," user input to remove the alert, and then enabling play; claim 2 ties the low-priority data to the "edge of an area where gambling is allowed," and claim 3 recites repeatedly sending location data. Treat all of that as the patent owner's characterization of claim scope in an unadjudicated complaint exhibit — not as a construction. Anyone needing the true scope must pull the granted claims from the patent itself (Google Patents record: https://patents.google.com/patent/US12406284/en — note that the copy previously retrieved was truncated before the claims; the USPTO PatentCenter record for app. 18/652,765 is the reliable source).

Estoppel landscape: nothing has attached and nothing is blocked. Section 315(e)(2) estoppel arises only after a final written decision, and there is no FWD — indeed no institution. So DK is not estopped, Interactive Games is not benefited, and you are not estopped from anything. Two clocks and one election doctrine do matter to you: (1) § 315(b) bars an IPR petition filed more than one year after you are served with a complaint alleging infringement — DK was served 2026‑04‑03 and filed its petition 2026‑09‑17, comfortably inside its deadline (bar date would be about 2027‑04‑03); (2) § 315(a)(1) bars a petitioner who previously filed a civil action challenging validity of the patent — DK's pending partial Rule 12(b)(6)/§ 101 motion in D. Mass. targets only U.S. Patent Nos. 12,409,382, 8,974,302, and 12,548,404, not '284 or '518 (Dkt. 36, https://archive.org/download/gov.uscourts.mad.[298441](/patent/298441)/gov.uscourts.mad.298441.36.0.pdf), and in any event a § 101 merits motion is not the same thing as a § 315(a)(1) affirmative validity action; and (3) § 315(e)(1) estoppel before the Office also requires an FWD. Bottom line: the entire §§ 102/103 prior-art universe against '284 remains available to any petitioner, including you.

Pattern signals. DraftKings/DK Crown Holdings is a serial IPR petitioner in the mobile-gaming space, and this is not its first brush with this patent family: earlier filings include IPR2020‑01107, ‑01108, ‑01109, and ‑01110 (DraftKings v. Interactive Games, directed to other Interactive Games patents, e.g., the '302 patent) and IPR2022‑01446 (the AG 18 '205 patent, which generated the May 2026 Federal Circuit decision). So the presence of an IPR here is a competitor-defendant behavior pattern, not unified-patents-style aggregator activity — I found no evidence of a defensive aggregator (e.g., Unified Patents, RPX) in the chain for '284; the only Unified Patents artifact in the record is its litigation-data link to the D. Mass. case, not a filed petition. On the patent-owner side, Interactive Games appears willing to litigate broadly (parallel D.N.J. suit against FanDuel/Betfair, 2:26‑cv‑03514, filed 2026‑04‑02 — which does not assert '284) but has not, at this stage, had to defend a PTAB challenge to '284.

Recommended next steps

• Defendant asserting / threatened on '284 — you have nothing to point to yet. There is no FWD to link to and no canceled claim to quote. Do not build a non-infringement or invalidity narrative on the assumption that claims 1–4, 8, 10–14, 16–23, 25–28 are dead or weakened; they are not. If a demand letter cites those claims, the correct posture is a full invalidity work-up, not a "the troll has no case" argument.
• Monitor these trial-stage milestones on IPR2026‑00493 (all projections from the statutory framework, not docketed dates): Patent Owner Preliminary Response ~2026‑12‑17; institution decision due by ~2027‑03‑17 (§ 314(b), 6 months from filing); if instituted, FWD due within 12 months of institution (~2028‑03‑17 at the latest) (§ 316(a)(11)). Watch in particular for (a) a § 314(a) discretionary-denial request keyed to the D. Mass. case and whether DK files a Sotera-type stipulation, and (b) any § 325(d) argument that the art was already before the examiner — both are the most likely early dispositive events. Docket source of record: USPTO PTAB Center / P‑TACTS, https://ptacts.uspto.gov (search PTAB E2E for IPR2026‑00493).
• If you are a co-defendant or a downstream accused party, decide your IPR posture now, on your own § 315(b) clock. Because no FWD exists, estoppel has not attached and every ground is open — but if you file a follow-on petition, expect a discretionary-denial fight against the earlier DK petition unless you (i) assert materially different art or grounds, (ii) file a Sotera-style stipulation that you will not pursue in litigation any ground you raise or reasonably could have raised in the IPR, and (iii) show you are not simply duplicating the first filer. Also confirm which entity is the real party in interest — the structured feed lists the petitioner as "DK Crown Holdings Inc. et al.," which signals multiple RPIs, and RPI identification is a routine denial target.
• Coordinate the § 101 track with the PTAB track. DK's pending partial motion to dismiss under § 101 covers only three of the five asserted patents and expressly excludes '284. If you are defending '284 on eligibility, note both (a) that the § 101 arguments in the D. Mass. briefing lean on Beteiro v. DraftKings and generic-computer framing, and (b) that "geolocation compliance / player-prevention alert" subject matter has an arguable technological hook that makes eligibility a closer call than for the other asserted patents. That is a merits argument, not a prediction.
• Do not over-read the AG 18 decision. It is useful only as a procedure lesson for the petitioner side — grounds omitted from a petition will not be rescued by a reply footnote, and collateral estoppel cannot be manufactured by stitching limitations from separately invalidated claims together. It says nothing about the validity of any claim of '284.
• Explicitly flagged unknowns (stated so they are not mistaken for findings): challenged claim numbers, asserted art, statutory basis, lead/back-up counsel, RPI list, panel members, and any Director-level discretionary action in IPR2026‑00493. All are unavailable on the current record. If you need them immediately, obtain the petition and its exhibits from PTAB Center / P‑TACTS for IPR2026‑00493 and confirm the FWD/decision history at the USPTO PTAB Decisions page.

I'll research the assignment chain for US 12,406,284 across USPTO Assignment Search, Google Patents legal events, and SEC/corporate sources.

I have the assignment events from the record. Now let me find the specific reel/frame numbers and correspondent details.

I have the assignment events. Let me try to pin down reel/frame numbers and the correspondent of record.

Inventors

Six named inventors. All six are members of the CFPH, LLC / Cantor Fitzgerald inventor group (they are the same six names that appear across the 2006–2009 "mobile gaming device" family), and all six assigned their rights to CFPH, LLC, the Cantor Fitzgerald IP-holding affiliate — evidenced by the recorded assignment of 2025‑10‑02 discussed below, in which every named inventor appears as assignor to CFPH, LLC.

Unusual-pattern check — no inventor-departure signal. The 12‑month-departure tell is not present here; the opposite pattern appears. This is a late-filed continuation (filed 2024‑05‑01, app. 18/652,765) naming the same 2009-era inventor group, and the inventors affirmatively executed a root-of-title assignment to CFPH, LLC that was recorded post-grant. The only personnel-flavored anomaly is corporate, not inventor-level: Lutnick resigned from Interactive Games/Cantor and divested his Cantor business interests upon becoming Commerce Secretary (2025), and the CFPH → Interactive Games conveyance was recorded 2025‑07‑02 — i.e., contemporaneously with that divestiture/ethics-driven corporate housekeeping. I would characterize that as governance timing, not a fire-sale precursor.

Original assignee

Two different entities must be distinguished, and the Google Patents header is misleading on this point.

• Root of title (the true "original assignee"): CFPH, LLC (New York, NY) — Cantor Fitzgerald's IP-holding affiliate. CFPH is the entity whose name appears as applicant/assignee on the sibling family members (e.g., US 11,501,606 "METHOD AND APPARATUS FOR ADVERTISING ON A MOBILE GAMING DEVICE," Applicant: CFPH, LLC, New York, NY), and it is the assignee of record from the inventors. Notably, the Google Patents bibliographic block for '284 lists "Original Assignee: Interactive Games LLC," which does not match the recorded chain — it appears to reflect the assignee of record at grant, because the CFPH → Interactive Games recording (2025‑07‑02) predates the 2025‑09‑02 issuance. Flagging this as a metadata artifact, not a second original assignee.

• Assignee at issuance / current owner: Interactive Games LLC — a Nevada-registered LLC described by Reuters (citing Nevada business records) as a Cantor Fitzgerald affiliate, and by the plaintiff's own filings as successor to the defunct Cantor Gaming.

  • Primary line of business: patent holding/licensing and assertion. It is not a sportsbook operator. The operating business was a separate entity — Cantor Gaming, later renamed CG Technology Development LLC (the entity that sued DraftKings/FanDuel in the 2016 Nevada wave) — and the prior-litigation record shows the two being used distinctly (e.g., the 2016 Nevada case lists 9,355,518 as held by "Interactive Games LLC" while 8,771,058 and 9,306,952 were held by "CFPH, LLC"). So the Cantor family has a long-standing practice of holding patents in a non-operating affiliate and asserting them separately from the operating subsidiary.
  • Did it ship a product embodying the claims? No evidence that Interactive Games LLC (as distinguished from Cantor Gaming/CG Technology) ever operated a product. Cantor Gaming did operate Nevada sportsbooks and a mobile wagering app built on this technology family in the 2009–2014 era.
  • Current status: operating as an active patent-assertion entity, not dissolved. It is the named plaintiff in the live enforcement wave: D. Mass. 1:26‑cv‑11544-WGY (DraftKings, filed 2026‑04‑02) and D.N.J. 2:26‑cv‑03514-KMW (FanDuel/Betfair, filed 2026‑04‑02 — which does not assert '284). The operating business (Cantor Gaming → CG Technology) is defunct as an independent concern; Cantor Fitzgerald itself remains an operating financial-services firm.

Assignment timeline

Important limitation, stated up front so it is not mistaken for a finding: I could not retrieve the USPTO Assignment Center reel/frame numbers, execution dates, or the recorded correspondent for either conveyance on '284's chain. The Google Patents legal-events feed for the patent exposes only the recording dates, the conveyance type, and the assignor/assignee names; the PATENT ASSIGNMENT SEARCH / Assignment Center record (which is where reel/frame and correspondent live) was not reachable for this number within my research window. I am not going to invent reel/frame numbers. The two entries below are what the record actually shows; the reel/frame and correspondent fields must be pulled directly from Assignment Center.

Recorded conveyances on US 12,406,284: exactly two (per the Google Patents legal-events feed for this patent). Family-level Google Patents "reassignment" entries are mirrored here; I found no third conveyance, no security interest, no license, and no change-of-name record.

• 2025‑07‑02 (recorded) — Reel/Frame not retrieved (Assignment Center lookup required)

  • Conveyance: Assignment ("ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignor: CFPH, LLC
  • Assignee: INTERACTIVE GAMES LLC
  • Correspondent: Not retrieved. Flag: this is the single highest-value field to pull next, because it is the one that would expose a repeat NPE-recording attorney across the Interactive Games / CFPH portfolio — see Signal 3 below.
  • Context: transfer-to-asserter / intra-Cantor consolidation. Moves the patent out of the R&D-holding affiliate (CFPH) into the Cantor affiliate that actually asserts it. Recorded before the 2025‑09‑02 grant.

• 2025‑10‑02 (recorded) — Reel/Frame not retrieved (Assignment Center lookup required)

  • Conveyance: Assignment ("ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignors: LUTNICK, HOWARD W.; ALDERUCCI, DEAN P.; PAPAGEORGIOU, ANTONIO; GELMAN, GEOFFREY M.; MILLER, MARK; BURMAN, KEVIN
  • Assignee: CFPH, LLC
  • Correspondent: Not retrieved.
  • Context: root-of-title inventor assignment — the ordinary employment/invention assignment to the corporate IP holder.

⚠️ Cross-reference to the earlier sections (this resolves their open item). The Patent-Summary and Litigation-Summary sections flagged the two Google Patents entries as running "in opposite directions as published" and listed the exact nature of the 2025‑07‑02 vs. 2025‑10‑02 entries as unverified. That flag is now resolved: these are two separate conveyances, not a contradictory pair — (i) inventors → CFPH, LLC (the root assignment), and (ii) CFPH, LLC → Interactive Games LLC (the assertion-vehicle transfer). The only genuine oddity is recording order: the downstream transfer was recorded 2025‑07‑02, roughly three months before the upstream root assignment was recorded 2025‑10‑02. That is a classic late/late-recorded root assignment, but it does mean that as of the 2025‑09‑02 grant date the recorded chain of title did not yet include the inventors' assignment to CFPH — worth verifying the execution dates, since a standing challenge in litigation would attack exactly this.

Timeline diagram

timeline
    title Ownership of US 12406284
    2009 : Priority application filed
    2024 : Continuation filed by CFPH
    2025 : CFPH conveys rights to Interactive Games
         : Patent issues to Interactive Games
         : Inventors convey rights to CFPH
    2026 : First suit asserting the patent

NPE / troll-pattern signals

1. Shell-entity transfer — PRESENT (qualified). The patent moved from CFPH, LLC to Interactive Games LLC, and the record for 2025‑07‑02 is the concrete evidence. It is qualified because the classic name-suffix tell ("IP / Patents / Licensing / Holdings / Ventures") is absent (the entity is "Interactive Games LLC"), and I did not confirm a registered-agent-only address. What is concretely supported: (a) Interactive Games LLC is not the operating business — the operating affiliate was Cantor Gaming / CG Technology Development LLC, a separate entity (see the 2016 Nevada case listing, where CFPH, LLC and Interactive Games LLC hold different patents while CG Technology Development LLC is the operating plaintiff); (b) the entity's asserted function is holding and asserting, evidenced by its role as plaintiff in 1:26‑cv‑11544 (filed 2026‑04‑02). So: a corporate single-purpose assertion affiliate, not a disguised anonymous shell.

2. Known asserter in the chain — PRESENT (qualified). Interactive Games LLC does not match the enumerated classic-NPE roster (no Acacia, Marathon, IV, IPNav, Wi‑LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or Spangenberg entity appears in this chain — those are not present). However, the signal definition expressly includes "any entity surfaced by Unified Patents or RPX as a high-frequency plaintiff," and Interactive Games LLC is surfaced by Unified Patents (its litigation dataset links the D. Mass. case) and carries a 26-case / 84-patent plaintiff profile on third-party docket trackers, with continuous assertion activity from 2016 through 2026. Marking present on that prong only.

3. Repeat correspondent across the chain — UNCLEAR (could not be assessed). This is the one signal I cannot responsibly score, because I did not retrieve the recorded correspondent for either conveyance. The Google Patents entries name the assignee entity itself (Interactive Games LLC; CFPH, LLC) as the party on the conveyance, which is not the same as the attorney/agent of record. Do not treat the absence of a finding here as a negative finding — obtain the correspondent from Assignment Center for both reel/frame entries and check it against the NPE-assertion correspondent lists. One adjacent observation, offered as context and expressly not as a finding under this signal: the litigation-side counsel of record for Interactive Games is Sterne Kessler Goldstein & Fox (Michael Joffre, Chandrika Vira, Daniel Block, William Milliken, Richard Crudo) — the same firm that represented Interactive Games/CG Technology in the earlier 2016-era wave (e.g., the D. Del. 19‑1105‑RGA filings by Daniel Silver). A repeat assertion-side firm across a decade is relevant to the overall picture, but it is not the same as a repeat recording correspondent, and I am not conflating them.

4. Cascading transfers — NOT PRESENT. Only two recorded conveyances exist, both in 2025, roughly three months apart, and both are intra-family (inventors → CFPH → Cantor affiliate). There is no chain of successive LLC-to-LLC assignments inside 24 months, and no evidence of shared correspondent addresses or common principals outside the single Cantor corporate family.

5. Pre-litigation transfer — UNCLEAR (leaning present on substance, failing the literal test). The conveyance to the asserting entity was recorded 2025‑07‑02; the first suit naming '284 was filed 2026‑04‑02 — approximately 9 months, which fails the literal "within 6 months" test. But execution dates were not retrieved, and if the assignment was executed in late 2025 or early 2026 the 6-month window would be met. Additionally, the transfer sits squarely inside a coordinated enforcement wave (both the DraftKings and FanDuel complaints were filed on the same day, 2026‑04‑02), which is the substantive pattern this signal is trying to capture. Retrieve the execution date at Assignment Center to convert this to a firm call.

6. Bankruptcy fire-sale — NOT PRESENT (no evidence). Nothing in the record shows '284 being conveyed through a Chapter 7/11 proceeding or a § 363 sale. Contextual note only: Cantor's operating gaming subsidiary (Cantor Gaming → CG Technology) exited the market and its business was absorbed/disposed of, but that is a sale of an operating business, not a bankruptcy conveyance of this patent, and I found no filing evidencing a judicial sale of the CFPH/Interactive Games portfolio.

7. Privateering — PRESENT (qualified). The assertion entity is a corporate affiliate of the firm whose R&D generated the technology, and it is suing the competitors of the divested operating business (DraftKings, FanDuel, and Golden Nugget Online Casino as an accused app). That is the privateering shape. It is qualified because the classic privateering fact pattern assumes a still-operating company spinning patents to an unrelated troll; here the operating business (Cantor Gaming/CG Technology) is defunct, and the assertion vehicle is a Cantor subsidiary rather than an arm's-length purchaser. Treat as a corporate assertion program run through a wholly owned affiliate, which is functionally privateering but not anonymized.

8. Defensive aggregator — NOT PRESENT. The chain terminates at Interactive Games LLC, an active plaintiff. No RPX, AST, LOT Network, Unified Patents, or OIN entity appears anywhere in the chain.

Verdict

NPE — high confidence (corporate-affiliate assertion entity). Two-plus signals are independently supported: (i) the 2025‑07‑02 recorded conveyance of CFPH, LLC → INTERACTIVE GAMES LLC transfers the patent out of the R&D-holding affiliate into a non-operating Cantor affiliate that holds and asserts rather than sells products — with the operating business being a demonstrably different entity (Cantor Gaming / CG Technology Development LLC, per the 2016 Nevada case); (ii) that same entity is a high-frequency plaintiff surfaced by Unified Patents (26 cases; plaintiff in D. Mass. 1:26‑cv‑11544 filed 2026‑04‑02, in which '284 is asserted); and (iii) the arrangement is privateering-shaped, with the affiliate asserting against the former operating business's competitors. The 2025‑10‑02 recording (all six inventors → CFPH, LLC) supplies the clean root of title that makes the downstream transfer coherent. The one caveat that keeps this from being a classic troll call: the NPE is a named, solvent subsidiary of an identifiable corporate parent, not an anonymous shell, and I could not retrieve the reel/frame or correspondent fields to test the "same lawyer runs every LLC" hypothesis — that test is still open and is the single most valuable next lookup.

Verification links (search by patent number 12406284):

• USPTO Assignment Center — https://assignmentcenter.uspto.gov/
• USPTO Patent Assignment Search (same underlying records) — https://assignment.uspto.gov/patent/index.html
• Google Patents legal events for this patent — https://patents.google.com/patent/US12406284/en

Open items I am explicitly flagging as unverified: reel/frame numbers for both conveyances; execution (signing) dates; recorded correspondent of record for both; whether any third (unindexed) security interest, license, or change-of-name record exists; and the exact Nevada organizational history/registered-agent address of Interactive Games LLC.

I'll research the prior-art citations for US 12,406,284 B2. Let me run several targeted searches.

Let me search specifically for the cited-references section of this patent.

Bottom line first: I could not retrieve the (56) "References Cited" list for US 12,406,284 B2, and I am not going to invent it

You asked me to "look at each patent citation for 12406284" and map each to a § 102 claim. I could not obtain the actual citation list in this research window. The Google Patents snapshot already in this file was truncated on the front page (the earlier sections flagged that it cut off before the claims), and my searches for the citation block returned unrelated material — a Czech contract registry ID "12406284" (smlouvy.gov.cz), the STMicroelectronics MOSFET datasheet STP12NM50 (an "STP12406284" string match), the PTAB application 12/600,284 ("Ex Parte Mulholland"), and other noise. None of that is US 12,406,284 B2's citation list.

Therefore I am not going to produce a fabricated table of "cited references with § 102 mappings." That would be exactly the failure mode you told me to avoid. What follows is (a) what the record does support, (b) the correct legal framework for the § 102 analysis, (c) a clearly-labeled candidate prior-art landscape that is my own analysis, not the examiner's citations, and (d) exactly how to pull the authoritative list.

Date note: your task header says April 26, 2026; the system date for this analysis is 2026-09-18, and '284 issued 2025-09-02. I flag the discrepancy and proceed on the working date of 2026-09-18, consistent with the earlier sections' resolution of this same flag. Nothing in this deliverable depends on which of the two dates controls.

1. What the record actually supports about '284's prior art

Source of record: https://patents.google.com/patent/US12406284/en (the truncated snapshot supplied in this file); family/sibling corroboration from search.

Important interpretive point about the "prior art keywords" field. In Google Patents that field is auto-extracted from the patent's own text, not from the examiner's IDS. So "low priority / priority data / player / mobile phone / promotion" tells us what vocabulary the patent uses, not what the examiner cited. Treating it as a citation proxy would be a category error — and the earlier sections already correctly flagged it as an inference, which the litigation claim chart later partially validated (claim 1 does recite "low priority data").

Claim scope in play (from the D. Mass. claim chart, Dkt. 1-12, not from any construction): asserted claims 1–4, 8, 10–14, 16–23, 25–28; claim 1 recites a mobile phone with at least one computer processor executing a mobile application, a touch-screen UI, "low priority data," a "player prevention alert" displayed and wagering prevented "based on a determination that the mobile phone is not in a gaming area," user input to remove the alert, and then enabling play; claim 2 ties the low-priority data to the "edge of an area where gambling is allowed"; claim 3 recites repeatedly sending location data. This is geofenced wagering-compliance + selective content subject matter, which is narrower and different in character from the promotional-advertising description in the truncated specification. That gap matters for the prior-art search: the disclosure you have is about casino advertising; the claims are about location-gated wagering. Anyone doing a validity search must search the claims as granted, not the spec.

2. The § 102 framework that governs this patent (do this before mapping any reference)

This determines whether a candidate reference is even legally available, and it is the step most often botched:

• Pre-AIA vs. AIA. '284 claims priority to 2009-02-13 — before the 2013-03-16 AIA change. If every asserted claim is fully supported by the 2009 priority application (written description + enablement under § 112), the pre-AIA §§ 102/103 framework applies: prior art is § 102(a) (known/used/patented/published before the invention date), § 102(b) (more than one year before the 2009-02-13 filing → anything published before 2008-02-13 is statutory bars-grade art), § 102(e) (U.S. patents/publications by filing date), and § 102(g). There is no 102(a)(1) "otherwise available to the public" catch-all.
• The critical trap. Because this is a 2024-filed continuation, the priority claim must be tested, not assumed. Any claim limitation not supported by the 2009 disclosure gets its effective filing date moved forward to 2024-05-01, which (i) switches that claim to AIA § 102(a)(1)/(a)(2), and (ii) massively expands the available art. The phrase "player prevention alert" and the "not in a gaming area" wagering-prevention framing are the most likely candidates for a priority challenge — that vocabulary does not obviously appear in the 2009-era advertising disclosure. This is the single highest-leverage validity question on this patent, and it is also the natural thrust of DK Crown's pending IPR2026-00493.
• § 102(b) date math for the 2009 case: anything publicly available before 2008-02-13 is a printed-publication bar on the claims entitled to 2009 priority.
• No pre-AIA § 102(e) for foreign filings. Under pre-AIA law a foreign patent application publication did not count as § 102(e) art; it is only § 102(a)/(b) art as of its publication date. Post-AIA § 102(a)(2) removes that asymmetry. Another reason the priority determination controls the whole analysis.

3. Candidate prior-art landscape — MY candidates, NOT the examiner's citations

Read the following as an analytical starting point for a validity work-up, explicitly flagged as unverified against '284's actual IDS. I am not representing that any of these appear on the '284 face. I ground each in something I could actually retrieve.

3A. References I retrieved and can cite from primary documents (search-grounded)

3B. Art classes you must search (I could not verify specific numbers — do not cite numbers you have not pulled)

• Geolocation-gated wagering / "player prevention": pre-2008 art on determining whether a mobile device is inside a permitted gaming jurisdiction before permitting a wager. This is the weakest novelty position on '284 — Nevada's and the UIGEA-era federal treatment of mobile/remote wagering, plus the 2006–2007 Cantor Gaming mobile-wagering filings, all predate 2008-02-13. Search the pre-2008 art on geofenced wagering authorization and you will likely find § 102(b) art against the "player prevention alert" limitations. I flag this as the highest-probability § 102 attack surface.
• "Low priority data": this is an unusual, claim-defining phrase. Search it verbatim across the pre-2008 corpus (USPTO full-text, Espacenet, Google Patents, and prior-art databases) in combination with "mobile" and "location." A verbatim-phrase search is the highest-yield first step and I was unable to complete it.
• Proximity-triggered content push to a mobile device (2004–2008): Haberman-type systems (per-location broadcast, stored preference profile, privileged action on match) are the classic § 102(e)/102(b) family here — they appeared as EX1004 in PTAB proceedings I retrieved, but I did not verify the Haberman patent number and will not state one.
• In-family (non-prior-art) references you will see on the face and must NOT treat as prior art unless the priority breaks: the CFPH / Interactive Games "mobile gaming device" family (e.g., US 11,501,606 B2, "Method and apparatus for advertising on a mobile gaming device," applied for by CFPH, LLC). Same-family documents share the 2009 priority and are not § 102 art against claims entitled to that date; they become relevant only if the priority claim fails.

4. How to obtain the authoritative citation list (do this — it is a two-minute lookup)

The (56) block is on the front page of the granted patent. Pull it from any of these, then map each reference to § 102 using the framework in § 2 above:

1. USPTO Patent Public Search / PatentCenter — search 12,406,284; open the granted patent PDF, front page, "(56) References Cited." This is the reliable source (the copy previously retrieved was truncated). Application 18/652,765.
2. USPTO Open Data Portal / PatentsView API — patent/12406284 returns structured citedBy/cited arrays, including examiner-cited vs. applicant-cited flags.
3. Google Patents — https://patents.google.com/patent/US12406284/en → "Patent Citations," "Non-Patent Citations," "Cited By." (The snapshot in this file omits it.)
4. Espacenet — https://worldwide.espacenet.com → publication US12406284 (B2) → "Cited documents" / "Citing documents" (this is where the foreign-language X/Y references will show up).
5. FreePatentsOnline / Justia — FPO's "References Cited" tab for 12406284.

Then, for each retrieved reference, the § 102 mapping requires exactly four facts: (i) the reference's § 102 category (a / b / e / g, pre-AIA, or (a)(1)/(a)(2) post-AIA); (ii) its date measured against 2008-02-13 (§ 102(b)) and the invention date (§ 102(a)); (iii) whether the priority claim to 2009-02-13 holds for the claim at issue; and (iv) element-by-element correspondence to the claim as granted — not to the specification. A reference can only anticipate if it discloses every limitation, including the touch-screen input, the alert-removal-on-input step, and the enable-play step in claim 1.

5. Explicit unknowns — stated so they are not mistaken for findings

• The actual (56) References Cited list for US 12,406,284 B2: NOT RETRIEVED. This is the core deliverable you asked for and I could not produce it without fabricating.
• Whether any specific reference anticipates any specific claim: NOT DETERMINED. I have not seen the granted claims in full, only the patent owner's characterization in an unadjudicated complaint exhibit.
• Whether the 2009 priority claim holds for the asserted claims: NOT DETERMINED — and this is dispositive of the entire § 102 analysis.
• The identity of the examiner and the examiner's search history / classification searches: NOT RETRIEVED.
• Non-patent literature cited (if any): NOT RETRIEVED. For a 2009-priority financial/gaming case, NPL (e.g., trade press, Nevada/Gaming Laboratory standards, UIGEA-era materials) is often where the real § 102(b) art lives.
• Consistency flag: the earlier sections stated the truncated copy "does not include the claims section" — the same truncation removed the front-page (56) block, which is why I cannot fulfil this task from the supplied text. This is a limitation of the source, not a contradiction in the earlier sections' findings.

If you paste the front page (or the (56) block, or the granted claim set) into this thread, I will do the full citation-by-citation § 102 mapping — reference, date, disclosure, and the specific claim(s) each anticipates — immediately.

I'll start by trying to locate the prior-art material for this patent, since the "Prior Art section" referenced in the task was not included in the text I was given.

Let me try to locate the patent's cited references and its family/priority documents directly.

Let me verify a few candidate references and try to locate the application/claim text.

Obviousness Analysis — US 12,406,284 B2 under 35 U.S.C. § 103

0. Threshold flags (read before the analysis)

Flag 1 — The "Prior Art section of this page" is not in my source material. The material I was given for this task contains the patent's bibliographic block, the (truncated) description, the class list, and one field that is part of the record's own prior‑art apparatus: the Google Patents "Prior art keywords" line — player; mobile phone; low priority; promotion; priority data. There is no examiner citation list, no "References Cited" section, no IDS, and no search‑report content in the supplied text. I will not invent one. What follows uses (a) that keyword field, (b) the claims metadata already established in the earlier sections of this analysis (the D. Mass. infringement chart's characterization of claim 1 and the asserted claim set), and (c) prior‑art references I could independently retrieve and date in this session. Every reference I map is identified with its number, date, and source, and I mark which ones I have read the text of versus only the title/date record of.

Flag 2 — Date. The task header says "Current Date: April 26, 2026." The system date on this run is 2026‑09‑18, and the earlier PTAB section of this analysis already documented an event (IPR2026‑00493, filed 2026‑09‑17) that post‑dates the task header. I proceed on 2026‑09‑18 and treat the April 2026 date as stale. This matters because the § 103 analysis is date‑driven in two places: the one‑year § 102(b) window relative to 2009‑02‑13, and the AIA/pre‑AIA question.

Flag 3 — I do not have the granted claim text. As the earlier sections established, the Google Patents copy retrieved is truncated before the claims, and the abstract is absent. The claim scope I use below is the patent owner's own characterization in an unadjudicated complaint exhibit (D. Mass. Dkt. 1‑12, "Exhibit 10 – Initial Infringement Claim Chart") as reported in the earlier litigation section — claims 1–4, 8, 10–14, 16–23, 25–28, with claim 1 reciting a mobile phone comprising at least one computer processor executing a mobile application, a touch‑screen UI, "low priority data," a "player prevention alert" displayed with wagering prevented "based on a determination that the mobile phone is not in a gaming area," user input to remove the alert, and thereafter enabling play; claim 2 tying low‑priority data to the "edge of an area where gambling is allowed"; claim 3 reciting repeatedly sending location data. Every mapping below is conditioned on that characterization being accurate. If the granted claims differ — especially if they contain a specific ordering, a specific attribution of the "low priority data" to a particular device, or a "formatting" limitation with structural specifics — the analysis must be re‑run against the real text.

1. The framework, and why the priority date is the whole ballgame

Two possible statutory regimes, and they are not close calls in practical effect.

• If the '284 claims are entitled to the 2009‑02‑13 priority date (as the record asserts, via app. 12/147,005 → US 8,688,517 and its continuation chain), then pre‑AIA §§ 102/103 govern, because the application contains claims with pre‑2013‑03‑16 effective filing dates and AIA § 3(n)(1) does not reach it. The prior‑art universe is then capped at material published/patented before 2009‑02‑13, i.e., roughly the 2006–2008 window, and:

  • Art qualifying only under § 102(e), (f), or (g) that was commonly owned with the '284 invention at the time it was made is disqualified for § 103 by pre‑AIA § 103(c).
  • § 102(a) publications (published before the invention date, but less than one year before the filing date) are not removed by § 103(c) — and the patent owner can additionally attempt to swear behind § 102(a) art under 37 C.F.R. § 1.131 with an earlier invention date (and there is a plausible parent‑family date of 2006‑12‑06 to reach for).

• If any '284 claim is NOT so entitled (a § 112 written‑description / priority attack on the 2009 specification), then the application becomes an AIA application: § 102(a)(1)/(a)(2) art, with essentially everything published or filed before the 2024‑05‑01 filing date available, including the entire CFPH family's own publications (US 2008/0102957, US 2008/0139306, US 2010/0211431, US 2015/012359, US 2018/0189839, US 11,501,606, US 12,456,345) and the whole pre‑2024 mobile‑sportsbook geolocation ecosystem. In that regime, this patent's obviousness exposure is materially greater and § 103(c) disappears entirely (AIA § 102(b)(2)(C) common‑ownership exception applies only to § 102(a)(2) art and is the analogue, but the pre‑2024 publication space is vast).

Practical consequence: the strongest § 103 position is a two‑track position — argue obviousness on third‑party art that predates 2009‑02‑13 (Track A, immune from § 103(c) and largely immune from a § 1.131 swearing‑behind if it is § 102(b) art), and plead, in the alternative, that if the claims are not entitled to the 2009 date the same and additional art renders them obvious under AIA § 103 (Track B). A defendant that builds only on CFPH's own family publications invites a § 103(c) fight it may lose.

Note on § 103(a)'s basic questions, as I will apply them: (i) scope/content of the prior art; (ii) differences between the art and the claims; (iii) PHOSITA level; (iv) motivation to combine with a reasoned rationale and a reasonable expectation of success (KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007)); and (v) objective indicia.

Stated PHOSITA: an engineer or system architect with 3–5 years of experience in networked wagering/gaming systems and mobile application development as of February 2009, familiar with casino floor systems, wireless/Wi‑Fi and GPS/network location determination, TITO/player‑tracking, and ad‑serving to mobile handsets. That is the level at which the motivations below are assessed.

2. Decomposition of representative claim 1 (as characterized in the chart)

Dependent claims as characterized: claim 2 — low‑priority data based on "the edge of an area where gambling is allowed" (i.e., a geofence boundary); claim 3 — repeatedly sending location data (i.e., periodic/continuous location polling).

E1–E2, E4–E7 are individually old and largely conventional as of 2009. The inventive weight, if any, sits in the combination of E3 (priority‑tagged content) with E5 (zone‑based wagering prevention) inside one mobile application on a phone, and — if "formatting" in the title maps to a claim limitation — in the formatting of the content to the handset.

3. Verified prior art I can put on the table

Confidence key: [TEXT] = I read substantive disclosure text this session; [REC] = I have the number, title, and date from a citation record but have not read the specification — element mapping for these is predictive and must be confirmed from the document itself.

3.1 The A1 disclosure, verbatim (the single most on‑point passage I could verify)

From the published specification of A1 (US 2008/0102957 A1 / the '741 family text, paragraphs and figures as reproduced at the sources above):

• On zone‑based deactivation of gambling: "It is noted that, by practice or by law, certain areas within a casino may be unavailable for gaming. The portable terminal may implement such restrictions using its location sensor. If a portable terminal is outside of a predetermined area, the gaming functions may be deactivated, and, for example, be replaced with non‑gaming functions. For example, a similar program may be activated which does not permit betting, but otherwise allows play."
• On the legal criterion: "The criterion may be, for example, whether the location is within a pre‑defined area in which gaming is permitted by law."
• On continuous/repeated location checks (claim 3): "In connection with any of the location determination methods, the gaming system may periodically update the location determination information. This may be done, for example, during a gaming session, at pre‑defined time intervals to ensure that movement of the gaming communication device to an unauthorized area is detected during play, and not just upon login or initial access."
• On the boundary construct (claim 2's "edge of an area where gambling is allowed"): "[G]eo‑fencing may be used to enable gaming via device 56 but disable or limit or control features of gaming via devices 54 and 55." And: "Triangulation may be used to identify whether a device … is located in a specific spot where gambling is unauthorized."
• On handheld/phone implementation: the disclosure expressly lists handsets, and describes per‑zone allowed activities with the device's functionality limited "to the set of allowed activities for the zone in which the device is located," with re‑determination as the device moves between zones/sub‑zones.
• On location‑dependent advertising: "A location of the gaming communication device on the property is used to alter a game play function, such as a bet option, wager, graphic overlay, permission, or to provide location‑dependent advertising or embedded advertising."

This is, in substance, E5 plus claim 2 plus claim 3 — in a pre‑2009 document — including the exact "not permitted to bet where you are" construct.

4. Ground 1 — Claim 1 obvious over A2 (gaming/non‑gaming zones) in view of A3 (cell‑phone location & identity restrictions), further in view of A5 (targeted content delivery to wireless devices)

Why A2 as primary. A2's very title — mobile gaming devices for use in a gaming network having gaming and non‑gaming zones — places the claimed "gaming area" concept and wagering restriction by zone in the art. A2 is third‑party, published 2008‑03‑27, and (in Track B) unassailable.

Why A3 as the "mobile phone" complement. A3 expressly addresses cell phones with location and identity restrictions on remote gaming — supplying E1's handset framing and reinforcing E5's verification architecture.

Why A5 supplies E3 and the "selective delivery" hook. A5 (2007‑04‑19, § 102(b)) teaches delivery of pre‑selected advertisement content to wireless devices under stored profiles/rules — the natural antecedent for "low priority data" as a priority/selection attribute of deliverable content, and for the title's "selective content delivery."

Motivation to combine (articulated, KSR‑compliant).

1. Same field of endeavor and same problem. All three are directed to controlling what a portable wagering device does, and what it shows, as a function of where it is. A2 and A3 are directed to the wagering‑legality problem; A5 to the content‑delivery problem on the same class of device.
2. Known technique applied to a known device to yield predictable results. Zone‑based access control and priority/profile‑based ad selection were both well‑known techniques by 2008; combining them on one handset (a device both references already contemplate) yields nothing more than their expected aggregate — play is gated when out of zone, and appropriately‑ranked content is delivered when in zone.
3. Regulatory compulsion. Nevada‑style location verification for mobile wagering was a legal precondition to mobile sportsbook/wager operation (the family's own filings cite Nevada A.B. 471 and location‑verification requirements; see US 2008/0102957 ¶¶ 1–66). A POSITA building an operable compliant app in 2009 had a strong, concrete incentive to include exactly this zone gate — a motivation strengthened by KSR's "design incentives/market forces" rationale rather than weakened by it.
4. Anticipation of the obvious alternative and the "obvious to try" dimension. Where a regulator requires out‑of‑zone blocking, the spectrum of solutions (deactivate gambling, deactivate wagering only, show a message/alert and require acknowledgment) was small, fully enumerated in the art, and the '741‑family text already says the design choice is between "gambling functions … deactivated" and "a similar program … which does not permit betting, but otherwise allows play." Picking the alert‑plus‑acknowledgment variant is a predictable, finite selection.

Reasonable expectation of success. High. Each element (zone determination, gate, alert rendering on a touchscreen, acknowledgment gating) is a routine engineering step with no unbounded variables; the references supply the hardware architecture, the location technique (RSSI/TDOA/triangulation/GPS/geofence), and the content selection mechanism.

5. Ground 2 — Claims 2 and 3 (and the geofence‑boundary and repeated‑location features)

• Claim 2 ("edge of an area where gambling is allowed"): directly disclosed by A1 ("geo‑fencing may be used to enable gaming via device 56 but disable … devices 54 and 55"; "triangulation … to identify whether a device … is located in a specific spot where gambling is unauthorized") and by A2 (gaming vs. non‑gaming zones), with A3 supplying identity‑plus‑location restrictions. Motivation: the boundary is inherent in any zone‑based control; nothing more is needed than "identify the boundary so you know which side of it the phone is on."
• Claim 3 (repeatedly sending location data): squarely disclosed by A1 ("periodically update the location determination information … at pre‑defined time intervals to ensure that movement … to an unauthorized area is detected during play, and not just upon login or initial access"). Motivation: movement during play is the threat model; a single check at login is inadequate, and the art states the reason. This is a strong, low‑risk § 103 position.

6. Ground 3 — The "priority data / selective content delivery and formatting" strand (E3 and the title's "formatting")

If E3 ("low priority data") is construed as content carrying a priority/ranking attribute used to select what is delivered and how it is formatted, then:

• A5 (Levkovitz, § 102(b)) teaches pre‑stored, pre‑selected, content‑served material organized by application and delivered to wireless devices — the selection‑by‑attribute concept.
• A6 (Aufricht, 2006) and A7 (Oberberger, 2006) both teach interactive/filtered ad delivery to mobile devices — the mobile presentation layer and the filtering layer.
• A10 (Lutnick, US 2008/0139306 A1, pub. 2008‑06‑12) — the family's own earlier publication — expressly describes the priority attribute and the formatting constraints: the promotion database stores "data describing the priority of a promotion (e.g., promotion with higher priorities may be presented before or in place of promotions with lower priorities)" and "data describing the place or medium where a promotion should be featured," and the disclosure devotes a section to "[r]eformatting an advertisement that was meant for a big slot machine screen for a mobile device screen" and to publishing size/time constraints for each medium.

Motivation: a single system serving both big screens and handsets had an obvious need to store per‑promotion priority and per‑medium format constraints so the right creative could be selected and re‑rendered for the right device — the ordinary, predictable engineering of any ad‑serving system of the era, and expressly taught in A10.

Caveat: Ground 3 is where I am least comfortable, for the reason in §7.3 below: I cannot see the actual "low priority data" limitation, and if it is tied to a specific state machine (e.g., "low priority data is transmitted to the mobile phone only while the mobile phone is within X of the edge of the gaming area"), the combination must be re‑built on that specific trigger.

7. The patent owner's best rebuttals, and how strong each is

7.1 § 103(c) / common ownership (only bites on the CFPH‑family references)

A1 and A10 are CFPH/Wagering‑family documents. If the '284 invention and those documents were commonly owned or subject to an obligation of assignment to the same person at the time the invention was made, then to the extent they are prior art only under § 102(e), (f), or (g), pre‑AIA § 103(c)(1) disqualifies them for § 103. The counter‑counter: § 103(c) does not disqualify § 102(a) art, and both A1 (pub. 2008‑05‑01) and A10 (pub. 2008‑06‑12) pre‑date the asserted 2009‑02‑13 invention date, which makes them § 102(a) art if they are "by others." Because the inventive entities overlap but are not identical to '284's six‑name entity, the "by others" question is contestable, and the patent owner will also argue (i) that the "invention" was made no later than the parent filings (Dec. 2006), which would push A1/A10 outside § 102(a) as well, and (ii) § 1.131 swearing‑behind. Practical conclusion: do not make a CFPH‑family reference the primary reference. Use A2/A3/A4 as the primary structure and A1 as a secondary teaching only if its § 102(b) status can be established (see §7.2).

7.2 The one‑year window problem

The best CFPH publications (A1, A10) sit less than one year before 2009‑02‑13, so they are not § 102(b) art and are exposed to a § 1.131 swearing‑behind and to the "invention date" fight. A4 (US 7,222,354 B2, 2007‑06‑12), A5 (US 2007/0088852 A1, 2007‑04‑19), A6 (2006‑02‑16), and A7 (2006‑11‑09) are more than one year before 2009‑02‑13. Those are the references a challenger should lead with, because § 102(b) art cannot be sworn behind, and § 103(c) has no application to it at all (whatever the ownership).

7.3 Claim construction of "low priority data," "player prevention alert," and "gaming area"

These are the terms most likely to be narrowed. Expect the patent owner to argue:

• "player prevention alert" is not any message but a specific pre‑play interdiction UI; and
• "low priority data" is a particular data class the mobile application receives when it is near/at the boundary — a construction that could pull the claim away from a generic priority‑ranked ad server.
• "gaming area" may be argued to mean a legally authorized wagering zone (which favors the challenger, because A1's text uses exactly the "pre‑defined area in which gaming is permitted by law" formulation) rather than a mere casino floor region.

If "gaming area" means the legally authorized zone, A1 and A4 become very close to anticipating, not merely rendering obvious. If it means any casino‑designated zone, A2 supplies it. Either way the challenger has an answer — which is the point of using both.

7.4 Objective indicia

Anticipate these, and their vulnerabilities:

• Regulatory approval / industry adoption (Cantor Gaming's mobile sportsbook). Nexus is the problem: the claimed advance is a compliance gate, so the "success" is attributable to the regulatory requirement, not the claimed combination. KSR-style "market forces" logic also tends to convert regulatory‑driven adoption into evidence for obviousness.
• Long‑felt need. Weak here: the art (A1, A2, A3, A4) shows the need was recognized and being solved by 2006–2008, i.e., before the asserted date.
• Copying. Watch for it in the D. Mass. case; note the procedural lesson from DK Crown Holdings Inc. v. AG 18, LLC, No. 2024‑2078 (Fed. Cir. May 6, 2026) — grounds and theories not properly presented will not be rescued late. That case does not involve '284 and says nothing about its validity.
• Unexpected results. None apparent from the description; the description itself frames the zone‑gating as a compliance option, not a surprising technical effect.

7.5 The § 101 shadow (worth noting because it shapes strategy)

The claim's "technological hook" — real‑time location verification gating a regulated wagering transaction, with an interlock — is a better eligibility story than the other asserted patents (the partial § 101 motion in D. Mass. targets the '382, '302, and '404 patents, not '284). That means the challenger should not expect the § 101 track to dispose of '284, and should invest in the § 103 track, where the art is dense.

8. Track B — if priority fails (in the alternative)

If '284's claims are not supported by the 2006/2009 specifications (a § 112 ¶ 1 attack that is worth pleading, given the record's own internal inconsistency: the recital of a "mobile phone" and a "mobile application" where the 2009 disclosure's operative term is "mobile gaming device," and the recital of "low priority data" where the 2009 text speaks of "data describing the priority of a promotion"), then:

• The application is an AIA application. § 102(a)(1)/(a)(2) reach every publication and application filing before 2024‑05‑01.
• That brings in the entire family — including US 11,501,606 B2 (Nov. 15, 2022), US 10,373,424, US 10,957,151, US 2018/0189839, US 2015/012359, US 2010/0211431 — as § 102(a)(2) art of the same corporate owner, subject only to the AIA § 102(b)(2)(C) common‑ownership exception. If the chain of title is clean (it appears to run CFPH → Interactive Games, all within the Cantor family per the earlier assignment section), that exception may exclude them; but the pre‑2024 third‑party ecosystem (the mobile‑sportsbook geolocation art, in‑game advertising art, and geofencing art accumulated from 2009–2023) remains fully available and is far richer than the 2006–2008 window.
• Also relevant to Track B: the "first worldwide family litigation" (Darts‑IP family 42560723) and the enormous continuation practice evidenced by the family tree (this same specification has issued at least nine times with different claims across 2006‑2024) mean the Office and the courts have seen this disclosure repeatedly; a § 325(d) argument may be available to the patent owner in the pending IPR2026‑00493 context, which is a reason a challenger would prefer art not already in the file.

9. Bottom line

1. On the claim‑1 architecture as characterized (mobile phone + app + touchscreen + zone‑based wagering prevention + alert + acknowledgment), a § 103 challenge is strong. The zone‑based play restriction with the legally‑authorized‑area criterion, the geofence boundary, and the repeated‑during‑play location check are all disclosed in pre‑2009 art, including express passages in US 2008/0102957 A1 ("gambling functions may be deactivated"; "a similar program … which does not permit betting, but otherwise allows play"; "periodically update … to ensure that movement … to an unauthorized area is detected during play"; "geo‑fencing may be used to enable gaming via device 56 but disable … devices 54 and 55") and in third‑party references such as US 2008/0076572 A1 (gaming and non‑gaming zones), US 7,437,147 (cell‑phone gaming with location and identity restrictions), and US 7,222,354 B2 (restricting wagering access).

2. The single biggest legal risk to that challenge is pre‑AIA § 103(c) if the primary reference is a CFPH document. Lead with the third‑party, more‑than‑one‑year‑old art (A4, A5, A6, A7) and use the CFPH publications only as corroborating secondary teachings — that avoids § 103(c) and swearing‑behind fights entirely for the § 102(b) references.

3. On the "priority data / selective content delivery and formatting" strand, the challenge is good but less certain, precisely because I cannot see the claim language. Levkovitz (US 2007/0088852 A1, § 102(b)) plus Aufricht (2006) and Oberberger (2006) supply mobile content selection/delivery; the family's own US 2008/0139306 A1 supplies the express "priority" attribute and ad reformatting. If "low priority data" is narrower than a generic priority tag, the combination must be rebuilt on that specific trigger.

4. What I could not do, and what must be done first: (a) obtain the granted claims (PatentCenter/Public Search for app. 18/652,765) and the abstract; (b) run the analysis against the examiner's actual citation list — the "Prior Art section" the task references was not in my material and may contain art I have not seen (including any U.S./foreign patent documents and NPL); (c) pull the full text of A2, A3, A4, A5, A6, A7, A8, A9 and A12 to confirm the element mapping I have labeled [REC]; (d) confirm the execution date of the 2025‑07‑02 CFPH → Interactive Games conveyance and the parent‑chain execution dates, because §§ 102(b)(2)(C)/103(c) turn on ownership "at the time the invention was made"; and (e) obtain the IPR2026‑00493 petition (grounds unknown) to avoid duplicate‑ground/§ 325(d) exposure if a follow‑on petition is contemplated.

One explicit non‑finding: nothing above is a prediction of the outcome of IPR2026‑00493 or of the D. Mass. case. The claims are unadjudicated; no claim of '284 has been reviewed, instituted, or canceled. The § 103 positions described are, in my assessment, the strongest available on the record as I can see it — and the record I can see does not include the claim text or the examiner's prior‑art list.