US 6195564

I'll search for authoritative information on this patent, including any CAFC 2026 docket activity.

Let me search more specifically for CAFC 2026 activity and litigation history.

US Patent 6,195,564 — Analyst Summary

Search caveat up front: I searched USPTO-oriented sources and the CAFC 2026 opinion/order set. I found no CAFC 2026 docket activity, appeal, or Federal Circuit proceeding involving U.S. Patent No. 6,195,564 specifically. The only 2026 CAFC items my searches surfaced involving Ericsson (e.g., General Access Solutions, Ltd. v. T-Mobile USA, Inc., Ericsson, Inc., Nos. 2026-1756, 2026-1914, dismissed June 30, 2026) concern different patents and should not be attributed to the '564 patent. I did not locate any assertion, IPR, or litigation of the '564 patent; consistent with its expired status (anticipated expiration 2017-09-19), it appears dormant. Treat "no litigation found" as a negative search result, not affirmative proof of absence.

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Bibliographic Data

Minor date discrepancies (flagging, not resolving): Google Patents lists filing/priority as 1997-09-19 and issue as 2001-02-27, while Unified Patents' portal shows priority 1997-09-18, grant 2001-02-26, and expiration 2017-09-18. These are one-day offsets typical of time-zone/anniversary calculations; the authoritative Google Patents record (the source provided) governs here. Also note the USPTO Assignment record gives an invention effective date of 1997-09-09 within Reel/Frame 008813/0738.

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Abstract (verbatim)

A first wireless link between a communication device and a wireless modem is automatically established, so that electronic messages can be easily and automatically transferred between the communication device and a data network via the first wireless link and a second link between the wireless modem and the data network. Each of the communication device and the wireless modem can automatically determine whether an electronic message is to be transferred. When one of the communication device and the wireless modem determines that an electronic message is to be transferred, the determining one of the communication device and the wireless modem sends a page signal to the other one of the communication device and the wireless modem. When the other one of the communication device and the wireless modem receives the page signal and responds, the first wireless link is established. The electronic message is then transferred between the communication device and the data network via the first wireless link and the second link. The communication device can be a portable computer such as a laptop computer, and the wireless modem can reside in a cellular or personal communication system (PCS) phone or the like.

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Independent Claims — Plain-Language Overview

The patent has 26 claims, of which three are independent: claims 1, 18, and 26.

Claim 1 — Method for transferring electronic messages (the base method)

A two-device messaging method where a personal computer and a wireless phone (or equivalent) can each listen for a paging signal from the other. During listening, both devices sit in a standby state that is symmetric — i.e., neither device is designated the "master" or "slave," and both behave the same way toward each other. Upon receiving the page, the devices activate the first wireless link between them, then perform the messaging transaction: at least one electronic message moves between the first device and a data network via the activated first wireless link plus a second link (the phone's network link) to the data network. The symmetry of the standby/monitoring behavior is the emphasized point of novelty.

Claim 18 — System for transferring messages (the apparatus counterpart)

A system with two communication devices, each containing "monitoring means" (means-plus-function language) that detects a paging signal and establishes the first wireless link in response. The messaging transaction is then carried out over that link and a second link from the second device to the data network. As in claim 1, the monitoring means must operate symmetrically with respect to the two devices. This is essentially claim 1 recast as a system/apparatus claim.

Claim 26 — Method, computer + mobile phone, user-initiated email check (the narrowest, most specific independent claim)

A method with the same symmetric-monitoring/symmetric-standby framework, but with a specific user-driven scenario:

1. Both the computer and the mobile phone monitor for a paging signal from the other, each in a symmetric standby state.
2. In response to a command from the user, the mobile phone calls an Internet service provider to check for email pending for the computer.
3. It determines whether at least one email is pending at the ISP for the computer.
4. Only if email is pending, the phone automatically pages the computer to activate the wireless link, and then transfers the pending email from the ISP to the computer via the phone and the wireless link.

Claim 26 captures the specification's practical example (the traveler who leaves a laptop in the hotel room, uses the cell phone to check email, and has messages auto-pushed to the laptop), and its "only if messages are pending, then page" step is a meaningful narrowing relative to claims 1 and 18.

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Dependent-Claim Highlights (brief)

• Determining/sending (claims 2–3): At least one device itself decides a transaction is needed and sends the page; paging may be repeated until acknowledged (claim 3).
• Trigger conditions (claims 4–5, 16–17, 22): Determination and monitoring can be periodic or based on user-specified conditions.
• Link setup/teardown (claims 6–7): Link is activated on the paged device's response, and optionally terminated after the transaction.
• Message types/link types (claims 8–13): Messages may be stored on the first device; the second link may be a PSTN or a third wireless link; messages may be email, voice mail, video mail, or fax; the second device may be a wireless modem (claim 13) or a phone (claim 14); first device may be a laptop (claim 15).
• Check-only transactions (claim 12): A "messaging transaction" can be a mere query of whether messages exist, consistent with the spec's note that a transaction may occur with no messages transferred.

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Prior Art Cited and Family Context

Eleven references were cited, the most notable being Qualcomm's US 5,862,474 ("Programmable wireless modem", 1999) and Motorola's US 5,538,019 ("Packet data in an analog cellular radiotelephone system", 1996), plus US 5,876,038 (Motorola), US 5,716,943 (Motorola "Radio data interface device"), US 5,726,893 (Stanford Telecom), US 5,596,318 (Microsoft, two-way messaging battery life), EP 0748139 A2 (Nokia), and DE 19614925 A1. International Search Report dated Dec. 16, 1998.

The patent has been widely cited (165+ citing documents per Google's cited-by list), fanning out largely into the Helferich/Wireless Science paging-messaging family and the Flexiworld Technologies wireless-output family — but those are subsequent citing patents, not evidence of litigation against the '564 patent itself.

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Uncertainty Statement

• No authoritative record of any 2026 CAFC proceeding for US 6,195,564 was found. I cannot confirm litigation that does not appear in my searches; I also cannot prove a universal negative, so if a specific 2026 docket number was expected, I could not corroborate it.
• One-day date discrepancies exist between Google Patents and Unified Patents (see table note). I did not auto-correct either; both are reported as found.
• Claim interpretation above is my plain-language reading of the issued claim text; it is not a legal claim construction and carries no legal effect beyond the expired patent's term.

I'll search for litigation involving US patent 6195564 across patent litigation databases and court sources.

Let me search more targeted litigation databases.

Let me check litigation-specific databases directly.

Litigation Search Results: US Patent No. 6,195,564

Bottom Line

I found no litigation involving US Patent No. 6,195,564. No district court case, ITC investigation, or Federal Circuit appeal asserting or otherwise involving this patent appears in the sources I searched.

What I Searched and What Was Returned

Important Caveats

1. The "'564" hits I saw are false positives. Both DISH v. Vidgo and the Pantech/OnePlus matters reference "the '564 Patent" — but those are shorthand for entirely different patent numbers (and different technology: video streaming, not wireless modems). Do not attribute those cases to 6,195,564.
2. Search coverage was not exhaustive. My access was limited (a step cap was reached during the session), so I could not run every query against PACER directly, Darts-IP, Lex Machina, or the full ITC EDIS. It remains possible a case exists that these free sources don't index — particularly older (1997–2017) enforcement activity, which predates broad free docket indexing.
3. Practical context suggesting low/no litigation: The patent expired 2017-09-19 (per the record), and its assignee history shows Ericsson Inc./Telefonaktiebolaget LM Ericsson as owner throughout — no evidence of transfer to a monetization entity (NPE/PAE) that would typically drive assertion campaigns. Its PVIX/RNIX/SVIX litigation-risk metrics on Unified are all 0, and Lifetime Renewal Fees are listed as $0.

Recommendation for Definitive Confirmation

To close the gap with certainty, I would recommend running the number through:

• Lex Machina / Darts-IP (comprehensive district court + ITC),
• PACER Case Locator (case-number search on "6:195,564"),
• Stanford NPE Litigation Database, and
• USPTO Patent Center / Assignment reels to confirm no ownership transfer to an asserting entity.

Consistent with the STRICT RULE: the patent is interpreted literally as US 6,195,564 B1 (Application 08/933,982). I found no litigation for that exact patent. If you want, I can attempt a fresh targeted pass against one of the paid databases above if you can provide access or a specific index to query.

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

No PTAB hits surfaced in the first pass. Let me run more targeted checks, including litigation context and any post-grant challenges.

Let me do two final confirmatory checks — docket databases and the family's broader validity history.

Proceedings overview

There are zero AIA trial proceedings on file for US 6,195,564. The structured USPTO ODP block states the API returns no AIA trials (IPR/PGR/CBM) for this patent, and three targeted web checks (PTAB docket mirrors, claim+filing-date searches, and the Unified Patents portal entry for US-6195564-B1) surfaced no petition, no institution decision, no Final Written Decision, and no appeal. All 26 claims therefore stand exactly as issued on 2001-02-27 — nothing has been canceled, narrowed, or even construed by the Board. Because the count is zero, the per-proceeding template below is inapplicable and I will not manufacture proceeding numbers to fill it.

The bottom-line defensive posture is not the "survived two IPRs and is hardened" story — it is that there is no live assertion target at all: the patent's 20-year term ran from the 1997-09-19 filing date and it expired 2017-09-19 (Google Patents, legal status "Expired – Lifetime"; the Unified Patents portal lists expiration 2017-09-18, a one-day discrepancy that is immaterial). That is almost certainly why no IPR was ever filed — no rational petitioner spends ~$300k–$500k invalidating a dead patent. The absence of PTAB activity here is not a signal of patent strength; it is a signal that the patent went unchallenged because it was never worth challenging.

No proceedings to detail — what I checked instead

Statutory note (not a holding — just framing): the patent has a 1997 effective filing date, so it is pre-AIA. Post-Grant Review was unavailable (PGR reaches only patents with effective filing dates on/after 2013-03-16), and CBM review would have failed § 18(a)(1)(E)'s "financial product or service" gate because the claims are directed to wireless link establishment and messaging, not financial services. IPR was the only realistic AIA vehicle, and no one used it.

Strategic summary

Claim status. All 26 claims are intact as issued, but "intact" ≠ "assertable." Claims 1, 18, and 26 are the three independent claims (method / system / method); claims 2–17, 19–25 depend from them. There is no FWD cancelling any claim, so there is nothing for me to quote — I will not invent a disposition. The controlling fact is the calendar: the patent expired 2017-09-19. For a suit filed today (2026-09-30), the § 286 six-year damages lookback reaches back only to 2020-09-30 — entirely after expiration. There is no window of recoverable damages on this patent. If a demand letter cites claims 1–5, the correct response is that the patent was dead before the relevant conduct window opened, not merely that the claims are weak.

Estoppel landscape. Because no IPR/PGR/CBM was ever instituted, § 315(e)(2) estoppel does not exist against anyone. No petitioner, real party in interest, or privy is barred from raising any ground. Technically, an IPR could still be filed against an expired patent (claims construed under Phillips), so nothing has been foreclosed — but there is no economic reason to do so. The practical takeaway for a defendant is that the PTAB is not the battleground; the expiration date is.

Pattern signals. No petitioner filed anything, so there is no repeat-petitioner pattern. No PTAB appeal exists, so there is no evidence of aggressive patent-owner appellate strategy at the Board. I found no Unified Patents (or other defensive aggregator) institution in the chain — the Unified portal entry is a monitoring page only. Owner is Ericsson Inc. (original assignee; parent Telefonaktiebolaget LM Ericsson per the Unified portal). This is a 1997 Ericsson R&D patent that (a) issued in 2001, (b) was maintained through the year-12 fee (2012-08-27 per the legal events), and (c) was never asserted in any AIA-track proceeding I can find.

Recommended next steps

1. Do not build a PTAB strategy — build a calendar defense. The single dispositive fact is expiration on 2017-09-19. Ask opposing counsel to identify the date of the accused conduct the demand relies on. If it post-dates 2017-09-19, there is no infringement and no recoverable damages.
2. Verify the assertion target is actually this patent. Confirm the patent number and the claims quoted in the demand against the Google Patents text. All 26 claims as issued should match verbatim; if the demand quotes claim language that doesn't appear there, it's citing a different patent or a family member.
3. Sweep the family, not the US patent. The § 371/Paris family includes EP1016302B1, JP2001517914A, KR100538198B1, CN1126415C, AU748111B2, BR9812354A, IL134821A, and MY119651A (family data from the Google Patents page). The US patent is expired; foreign counterparts may have different terms, and Google's legal-status field for JP2001517914A shows "active – Pending," which looks stale and should be independently verified. If the demand letter is part of a multinational campaign, the enforceability question in Japan/EPO is separate from anything in this analysis.
4. If you want belt-and-suspenders invalidity. With no § 315(e)(2) estoppel anywhere, an IPR on an expired patent is legally available. But note three things: (a) it buys nothing for post-2017 conduct; (b) you would be filing against an expired claim set with no exclusivity left to defeat; and (c) the far cheaper move is a § 282 invalidity position or a Rule 12 motion predicated on expiration. The only scenario justifying a petition is if you need an estoppel-generating or res judicata-adjacent ruling for a parallel dispute on a live family member.
5. Confirm the null result before relying on it. I found no PTAB activity via ODP plus web checks, but ODP ingest can lag. Before filing anything, pull the docket directly from USPTO PTAB E2E and run the patent number through PACER/Docket Navigator for co-pending district court litigation. If any IPR exists that ODP has not yet indexed, the analysis above changes materially — most importantly, a petitioner's § 315(e)(2) estoppel could exist and would be a distinct defensive asset.

Confidence statement. I am highly confident there are no AIA trial proceedings on this patent — the structured ODP data and independent searches agree. I am not able to verify litigation history (PACER/Docket Navigator were not accessible within my search budget), so I make no claim about district court assertions or ex parte reexamination. The expiration date and the resulting damages-window analysis rest on the 1997-09-19 filing date shown on the face of the patent and are the load-bearing conclusions here; verify them against the USPTO Patent Center fee/expiration record before relying on them adversarially.

I'll verify the assignment record against live sources before reconstructing the chain.

The searches surface a Unified Patents portal entry but no post-issuance assignment chain. Let me confirm whether any later transfers or litigation exist.

Inventors

Both inventors assigned their rights to Ericsson Inc. by the original assignment (see timeline). No "departure" data is available for either inventor from the assignment record, PEDS/ODP, or the sources checked — I did not find evidence of a rapid inventor exodus, and I will not infer one. Unusual patterns: none determinable. The inventors are not named in any later assignment, because there are none.

Original assignee

Ericsson Inc. (North Carolina corporation; ultimate parent Telefonaktiebolaget LM Ericsson (publ), Stockholm, Sweden).

• Primary line of business: Telecommunications network infrastructure and mobile telephony / wireless equipment — a large operating company, not a holding entity. Google Patents' current-assignee field lists Ericsson Inc.; the Unified Patents portal lists "Parent Company: Telefonaktiebolaget Lm Ericsson," "Original Assignee: Ericsson Inc."
• Product embodying the claims: Ericsson is a major manufacturer of cellular/PCS network and handset technology, and its wireless-modem / cellular data product line is the direct commercial context of the patent (the specification describes a cellular phone hosting a wireless modem linking a laptop to a data network). Ericsson also monetizes its patent portfolio broadly through FRAND licensing.
• Current status: Operating. No bankruptcy, dissolution, or portfolio fire-sale is associated with this patent or with Ericsson. Ericsson remains an active patent filer (per the patents-review assignee profile of Telefonaktiebolaget LM Ericsson, ~16,977 grants) and an active patent plaintiff. The patent itself reached anticipated expiration 2017-09-19 and Google Patents status is "Expired – Lifetime."

Assignment timeline

The Assignment Center record for this patent contains only the original inventor→company assignment; there are no post-issuance assignments, no security interests, no name changes, and no transfers to any third party.

• 1997-09-09 (executed) / recorded 1997-09-19 — Reel 008813 / Frame 0738
  • Conveyance: Assignment
  • Assignor: Nils Rydbeck; Thomas M. Croft (individually and jointly)
  • Assignee: Ericsson Inc. (North Carolina)
  • Correspondent: Not surfaced in the record text reviewed. The Google Patents legal-events entry names the owner ("ERICSSON INC., NORTH CAROLINA") and the assignors (RYDBECK, NILS; CROFT, THOMAS M.) with reel 008813/0738, effective date 19970909, but does not list a correspondent attorney or recording firm. No correspondent can be cited without fabricating one.
  • Context: Ordinary employee-inventor assignment to the operating company at filing — i.e., the standard pre-issuance corporate assignment, not a fire-sale, securitization, or transfer-to-asserter.

No further recorded assignment exists. Subsequent Google Patents "legal events" are maintenance-fee payments only (4th year 2004, 8th year 2008, 12th year 2012), which confirms the patent stayed with the original owner through expiration.

Note on a common mix-up: Several Ericsson/Apple FRAND filings reference an Ericsson "'556 patent." In those documents (e.g., the Eastern District of Texas counterclaims) the '556 patent is U.S. 6,301,556 — "Reducing Sparseness in Coded Speech Signals" — not US 6,195,564. I found no infringement suit naming US 6,195,564 in the sources checked. Do not conflate the two.

Timeline diagram

timeline
    title Ownership of US 6195564
    1997 : Filed by Ericsson Inc
         : Inventors assign rights Reel 008813 Frame 0738
    2001 : Patent granted
    2017 : Patent expired

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. The only recorded assignment runs from the two inventors to Ericsson Inc., an operating telecom manufacturer (reel 008813/0738, executed 1997-09-09). No licensing-only LLC appears anywhere in the chain.

2. Known asserter in the chain — Not present. Current assignee is Ericsson Inc. / Telefonaktiebolaget LM Ericsson. No match against Acacia, Marathon, Intellectual Ventures, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Round Rock, etc. The inventors, assignee, and parent are all Ericsson.

3. Repeat correspondent across the chain — Not present. There is only one lien in the chain, and the record reviewed does not name a correspondent. A single link cannot establish recurrence, and no correspondent name is available to compare against Unified Patents / RPX lists. No finding.

4. Cascading transfers — Not present. Zero post-issuance transfers; nothing cascading, and no chained LLCs sharing an address or attorney.

5. Pre-litigation transfer — Not present. No assignment and no litigation naming this patent were found, so the 6-month pre-suit window cannot be triggered.

6. Bankruptcy fire-sale — Not present. No Chapter 7/11 filing is associated with Ericsson Inc. or LM Ericsson, and no bankruptcy-sale assignment is recorded for this patent.

7. Privateering — Not present. The patent never left Ericsson; there is no operating-company→NPE transfer for an NPE to assert on Ericsson's behalf. (Ericsson's own FRAND litigation campaigns assert Ericsson-owned patents directly, which is the opposite configuration.)

8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. Unified Patents appears only as an indexing/portal source, not as an assignee.

Verdict

Insufficient data — in the specific sense used here: the Assignment Center contains only the original assignment (inventors → Ericsson Inc., reel 008813/0738, executed 1997-09-09, recorded 1997-09-19), with no post-issuance chain to analyze for NPE signals. All eight NPE/privateering patterns are not present; the patent remained with its operating-company originator until it expired on 2017-09-19 (Google Patents "Expired – Lifetime"). There is no evidentiary basis for any NPE characterization — no shell-entity transfer, no known asserter, no cascading LLC chain, no litigation naming this patent.

Verification: USPTO Patent Assignment Search — search by patent number 6195564 (also reachable via assignmentcenter.uspto.gov); companion owner listing at Google Patents US6195564B1 and Unified Patents portal US-6195564-B1.

Caveat on sourcing: live queries for the Assignment Center record did not return reel/frame data beyond the single original assignment cited above. I have not fabricated any reel/frame, assignee, or correspondent. If you need the correspondent attorney name for reel 008813/0738, it must be pulled directly from the Assignment Center detail page, which was not retrievable in this session.

I'll research the specific patent and each cited reference to ground the prior-art analysis.

Let me research the remaining cited references to complete the prior-art picture.

Prior-Art Analysis — US Patent 6,195,564 B1

Assumption flagged before I begin: This task states "Current Date: April 26, 2026," while the system/context date is 2026-09-30. That is a contradiction in the inputs. I proceed on the technical analysis (which is date-agnostic); note the discrepancy but do not resolve it. This also does not disturb the earlier "no CAFC 2026 activity" finding — consistent with the patent being expired since 2017-09-19.

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1. Patent-number search confirmation

I searched specifically for 6195564 and did not substitute similar numbers. Two independent records match the exact number:

• Google Patents — US6195564B1, "Method for automatically establishing a wireless link between a wireless modem and a communication device" (the authoritative text supplied).
• Unified Patents portal — US-6195564-B1, Application No. 08933982, examiners Hunter, Daniel S. and Gantt, Alan T., original assignee Ericsson Inc, parent Telefonaktiebolaget LM Ericsson.

No search result caused me to substitute a neighboring number. The record at both sources is the same patent described in the previously generated summary. (Minor one-day offsets between the two sources were already flagged in the summary and are not repeated here.)

Sources:

• https://patents.google.com/patent/[US6195564B1](/patent/US6195564B1)/en
• https://portal.unifiedpatents.com/patents/patent/US-6195564-B1

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2. The cited prior art set (11 references)

Per the Google Patents citation list, 7 are examiner-cited (marked* in the record: US5537097, US5628379, US5714943, US5726893, US5596318, US5862474, US5878038) and 4 appear from the International Search Report / IDS stream (US5533019, EP0748139, WO1997024829, DE19614925). The ISR was dated Dec. 16, 1998.

A short methodological note on §102: anticipation requires a single reference disclosing every element of a claim, including all elements of any independent claim it is used against. A dependent claim is anticipated only if the same reference discloses both the independent-claim elements and the added limitation. Because the '564 patent's stated point of novelty is the symmetric standby/monitoring state plus the paging-activated short-range link between a computer and a wireless modem/phone, most listed references are better characterized as element-level art (relevant to isolated limitations) than as full anticipants. I say so explicitly where that is the case rather than overstating.

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3. Reference-by-reference analysis

3.1 US 5,533,019 A — "Packet data in an analog cellular radiotelephone system"

• Assignee: Motorola, Inc. · Filed: 1994-01-31 · Issued: 1996-07-02 · §102(b) (issued >1 yr before the 1997-09-19 filing).
• Description: Packet-data transport over an analog cellular radiotelephone system — one of the foundational CDPD-era references. It concerns getting packet data across the cellular air interface, i.e., the wireless-modem-to-network leg.
• Potential anticipation: Relevant at most to the "second link" limitations — e.g., claim 9 ("second link comprises a public switched telephone network") and claim 10 ("second link comprises a third wireless link") and the general claim 13 "wireless modem" context. It does not disclose a first communication device paging a second device over a short-range wireless link, nor symmetric standby. It cannot anticipate claims 1, 18, or 26.

3.2 US 5,537,097 A — "Method for transferring messages in a one-way communication system"

• Assignee: Televerket · Filed: 1990-02-02 · Issued: 1996-07-16 · §102(b). (Examiner-cited.)
• Description: Message transfer in a one-way communication system. The very premise (one-way) is the opposite of the '564 patent's symmetric two-way paging/link negotiation.
• Potential anticipation: None of the independent claims. It lacks two-way monitoring and a symmetric standby state entirely. It may touch the generic concept of message delivery, but that is not a claimed element in isolation.

3.3 EP 0 748 139 A2 — "Radio telephone text transmission system"

• Assignee: Nokia Mobile Phones Ltd. · Filed: 1995-06-05 · Published: 1996-12-11 · §102(a) (published before the filing/invention date, but within one year, so not §102(b)).
• Description: Text/messaging transmission over a radio telephone. Relevant background to conveying messages through a wireless phone, and possibly to claim 11 (message types) only at the level of "text messages."
• Potential anticipation: None of claims 1, 18, 26; it does not disclose paging a companion computer to activate a short-range wireless link, nor a symmetric standby state.

3.4 US 5,596,318 A — "Method for operating a two-way messaging system to extend battery life"

• Assignee: Microsoft Corporation · Filed: 1995-01-12 · Issued: 1997-01-21 · §102(a)/(e). (Examiner-cited.)
• Description (from the record): A priority-based two-way paging protocol that reduces pager transmissions by piggybacking acknowledgments and by classifying messages by priority; sequence-number counting and periodic "ping" packets are used to detect missing messages, extending battery life.
• Potential anticipation: This is the reference most relevant to the low-power standby and acknowledgment concepts in the specification (the spec's "low power standby state … periodically … listens for page signals" and claim 3's "repeatedly sending the paging signal … until … acknowledges"). It could bear on claim 3 (repeat-until-acknowledged) and the standby concept discussed in claim 1, but it is a single-pager-to-network two-way system — there is no first/second local device pair, no short-range link between a computer and a wireless modem, and no symmetric device-to-device standby. It does not anticipate claims 1, 18, or 26.

3.5 US 5,628,379 A — "Single track vehicle"

• Inventor/assignee: Watkins, Jonathan · Filed: 1990-11-28 · Issued: 1997-05-13 · §102(b). (Examiner-cited.)
• Description: Its title — a single-track vehicle — is mechanical, with no evident communication-system subject matter.
• Potential anticipation: None. On its face this appears to be a citation of record only (or an artifact of examiner search history), not substantive art on any claim of the '564 patent. I flag it as apparently non-analogous; I could not identify any relationship to the claimed subject matter.

3.6 WO 1997/024829 A1 — "Concatenated error detection coding and packet numbering for hierarchical ARQ schemes"

• Assignee: Telefonaktiebolaget LM Ericsson · Filed: 1995-12-29 · Published: 1997-07-10 · §102(a).
• Description: Error-detection coding and packet numbering for ARQ — a link-layer/lower-layer reliability reference from the same assignee.
• Potential anticipation: None of claims 1, 18, 26. No paging, no link activation, no device-pair standby. Background/technical-area art only.

3.7 DE 196 14 925 A1 — "Mobile telephone for signal transmission to relay station"

• Inventor: Konrad Reuther · Filed: 1996-04-16 · Published (Offenlegungsschrift): 1997-10-23.
• ⚠ Date anomaly — flagged, not corrected: This reference published 1997-10-23, after the US filing/priority date of 1997-09-19. On its face it therefore cannot be §102(a) or §102(b) art against this application. It appears to have entered the citation set via the International Search Report stream (ISR dated 1998-12-16) rather than an examiner §102 rejection. The related granted member (DE 196 14 925 C2, 2001-10-25) is titled "Mobile telephone and method for transmitting electrical signals" (Google's DE69838726T2 page cross-lists it).
• Description: A mobile telephone/relay-station concept for transmitting signals to a relay station.
• Potential anticipation: None that I can substantiate, and its date disqualifies it from the ordinary §102(a)/(b) bases for the US filing date as given. Any use would require an earlier-proven public availability; I found none.

3.8 US 5,714,943 A — "Radio data interface device"

• Assignee: Motorola, Inc. · Inventor: Rasor, Gregg Edward · Priority: 1992-07-20 · Issued: 1998-02-03 · §102(e) (granted on an earlier-filed application). (Examiner-cited.) — Note: one secondary source (idiyas) lists an actual filing of 1994-12-13 with priority 1992-07-20, i.e., a continuation; I report both without reconciling.
• Description (from patent text): A radio data interface device bridging a paging/selective-call receiver and a network interface (with an integrated modem and PSTN connection), maintaining a dynamic registry of messaging subscribers and communicating selective-call messages to messaging subscribers. Includes address correlation and battery-saver "sleep" mode for the selective call receiver.
• Potential anticipation: Relevant element-level art for a paging receiver + network interface + message delivery architecture and for power-saving paging reception. But it is a network-side interface device (server/pager infrastructure), not a computer that pages a wireless modem to establish a local wireless link. It does not disclose the claimed first wireless link between two local devices, nor symmetric standby. No anticipation of claims 1, 18, 26.

3.9 US 5,726,893 A — "Cellular telephone with voice-in-data modem"

• Assignee: Stanford Telecommunications, Inc. · Inventors: Schuchman et al. · Filed: 1992-12-17 (CIP/continuation chain) · Issued: 1998-03-10 · §102(e). (Examiner-cited.)
• Description (from patent text): A GPS position-determination system that embeds a data channel in a 600 Hz notch of a cellular voice channel ("data-in-voice" modem) to carry GPS/satellite data without degrading voice intelligibility; used notably for vehicle position reporting/theft reporting.
• Potential anticipation: It is about in-band data-over-voice signaling and GPS, not messaging between a computer and a phone. It could at most be background for "data over a cellular channel." It does not disclose automatic device paging, a computer–phone short-range wireless link, or symmetric standby. No anticipation of claims 1, 18, 26.

3.10 US 5,862,474 A — "Programmable wireless modem" ← closest architecture

• Assignee: Qualcomm Incorporated · Filed: 1996-08-08 · Issued: 1999-01-19 · §102(e). (Examiner-cited.)
• Description (from patent text): A computer coupled to a wireless modem whose data stream is parsed into modem commands (Hayes/AT) and radiotelephone commands (NAM parameters, system preference, etc.). The modem connects to a base station, through a Mobile Switching Center (MSC) to the PSTN, reaching a remote computer. The computer–modem coupling may be a serial port, direct processor-bus, or an infrared connection.
• Potential anticipation: This is the reference that most closely matches the patent's architecture — computer + wireless modem + base station + MSC + PSTN + remote data host — and it is plausibly why it was cited. It could be argued against isolated limitations: claim 9 (second link over PSTN), claim 13 (second device is a wireless modem), and the general "computer ↔ wireless modem ↔ data network" topology underlying claim 1's second-link element.
  But it does not disclose the dispositive elements of the independent claims: (i) monitoring at each of two devices for a page from the other; (ii) a standby state symmetric with respect to both devices; and (iii) activating a first wireless link between the computer and the modem in response to a paging signal — in the '474 the computer–modem coupling is essentially a fixed/attached connection (serial/bus/IR), not a paging-negotiated link between two mutually-listening devices. Therefore it does not anticipate claims 1, 18, or 26, and its use against them would be under §103 (obviousness) rather than §102.
• Source: https://patentimages.storage.googleapis.com/d3/2e/67/86d49cec3ccd60/US5862474.pdf

3.11 US 5,878,038 A — "Method in a wireless code division multiple access communication system for delivering a message to a mobile communication unit"

• Assignee: Motorola, Inc. · Filed: 1997-02-28 · Issued: 1999-03-02 · §102(e). (Examiner-cited.)
• Description: Delivering a message to a mobile unit in a CDMA system — i.e., the network-side paging/messaging delivery function.
• Potential anticipation: Background for message delivery over a wireless network (arguably relevant to claim 12's "data network → first communication device" direction only indirectly). It lacks any computer–phone local wireless link, any device-to-device paging, and any symmetric standby. No anticipation of claims 1, 18, 26.

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4. Composite §102 conclusion

• No single cited reference discloses all elements of independent claim 1, claim 18, or claim 26. In particular, none of the eleven discloses the combination of (a) two mutually monitoring devices, (b) a standby state symmetric with respect to both, and (c) activation of a short-range first wireless link between them in response to a paging signal, followed by (d) message transfer to the data network via a second link. This is consistent with the claims having issued with that symmetry limitation as the emphasized point of novelty.
• Most substantive references are US 5,862,474 (closest architecture: computer + wireless modem + PSTN), US 5,714,943 (closest paging/message-delivery + battery-saver), and US 5,596,318 (closest two-way paging / acknowledgment). These are the references most plausibly combined in an obviousness attack, not used alone for anticipation.
• Best claimant-specific mappings (element-level, not full anticipation):
  • Claim 9 (PSTN second link) → US 5,862,474; US 5,533,019.
  • Claim 13 (second device is a wireless modem) → US 5,862,474.
  • Claim 3 (repeat page until acknowledged) and the low-power standby concept → US 5,596,318.
  • Claim 11 message types → EP 0 748 139 A2 (general text messaging).
• Apparently non-analogous / citation-only: US 5,628,379 ("Single track vehicle") and WO 1997/024829 (ARQ error coding), and the date-problematic DE 196 14 925 A1.
• §102 basis split: §102(b) — US 5,533,019, US 5,537,097, US 5,628,379. §102(a) — EP 0 748 139 A2, WO 1997/024829 (and US 5,596,318 additionally qualifies on §102(a) if shown to predate invention). §102(e) — US 5,714,943, US 5,726,893, US 5,862,474, US 5,878,038, and US 5,596,318. DE 196 14 925 A1 does not qualify on a pre-filing basis on the dates given.

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5. Uncertainties, contradictions, and limits of this analysis

1. Date contradiction in the inputs: task date (2026-04-26) vs. context date (2026-09-30). Flagged, not resolved.
2. I could not open the prosecution file history. Therefore I cannot tell you which of these references the examiner actually applied in a §102 rejection versus merely listed. My anticipation assessments are based on the reference disclosures as I found them and on the claim text; they are analytic, not a reconstruction of the examiner's rejections.
3. US 5,714,943 filing date is reported inconsistently by secondary sources (1992-07-20 priority vs. 1994-12-13 filing). I report both and did not auto-correct.
4. DE 196 14 925 A1 published one month after the US filing date; I could not confirm any earlier public-availability date that would make it §102(a)/(b) art, so I cannot support it as anticipating any claim.
5. Unretrieved details: my searches for US 5,533,019, US 5,537,097, EP 0 748 139 A2, and US 5,878,038 returned only identification-level data (title/date/assignee) before my search budget was exhausted; their descriptions above are therefore at the title/abstract level, and I have not verified specific column/line disclosures for them. Any §102 use of these four would require reading the full specifications.
6. Negative results are negative results: "Not found" here means my searches did not surface it, not proof of nonexistence — the same caveat already stated for the 2026 CAFC question in the prior section.

Sources cited: https://patents.google.com/patent/US6195564B1/en (authoritative full text) · https://portal.unifiedpatents.com/patents/patent/US-6195564-B1 · https://patentimages.storage.googleapis.com/d3/2e/67/86d49cec3ccd60/US5862474.pdf · https://patents.google.com/patent/US5726893 · https://patents.google.com/patent/US5714943 · https://patents.google.com/patent/[US5596318A](/patent/US5596318A) · https://patents.google.com/patent/DE69838726T2/en (family/citation cross-reference)

I'll ground this obviousness analysis in the actual cited references before building the § 103 combinations. Let me verify the key references.

Let me verify the remaining key references, especially the paging-initiation art and Motorola/Microsoft battery-saving art.

Obviousness Analysis — U.S. Patent No. 6,195,564 B1 under 35 U.S.C. § 103

Builds on the prior Patent summary, Litigation summary, and the Prior Art section of the record. Not repeated here: bibliographic table, abstract, claim-by-claim overview, or the cited-reference list (all embodied above).

Minor inconsistency flagged (per instructions): the task prompt states "Current Date: April 26, 2026," whereas the session operating rule states today is 2026-09-30. This does not affect the § 103 analysis (the patent expired 2017-09-19), but the two dates conflict and neither is auto-corrected here.

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0. Framework and Assumptions

Governing law. Priority/filing is 1997-09-19, well before the AIA first-inventor-to-file change (2013-03-16). Accordingly pre-AIA § 103 applies, and prior art is measured under pre-AIA §§ 102(a), (b), and (e). The patent is expired, so this is a validity/defensive assessment only.

Graham/KSR. Obviousness asks whether the differences between the claims and the prior art would have been obvious to a POSITA at the time of invention, considering (i) scope/content of the prior art, (ii) differences, (iii) PHOSITA level, and (iv) secondary considerations. KSR Int'l v. Teleflex confirms that a combination of known elements is obvious where a POSITA would have had a reason to combine them with a reasonable expectation of success, and that "[i]f a technique has been used to improve one device… a person of ordinary skill in the art would recognize that it would improve similar devices in the same way."

PHOSITA (proposed). A person with a bachelor's degree in electrical/computer engineering or computer science and 2–4 years of experience designing wireless data/messaging systems, cellular/PCS telephony, and portable-computer data communications, or equivalent. This is a mature, incremental art.

Claim construction assumptions (plain meaning).

• "paging signal" = a short signaling message (e.g., an access code of the paged device, per the spec) used to alert/awaken the other device, not limited to any particular paging network.
• "standby state that is symmetrical" = neither device is fixed as master/initiator; both monitor for the other's page using the same standby behavior. This is the claimed point of novelty.
• "messaging transaction" (claim 12 confirms) includes a query-only transaction where no message is actually transferred.

Admissions in the specification (Applicant Admitted Prior Art, AAPA). The Background section itself admits: (a) PCMCIA wireless modems in portable computers; (b) automatic retrieval/batch transmission of queued e-mail/voicemail; (c) software that automatically and periodically checks for new mail; (d) a direct-connect cable between computer and phone; and (e) commercially available IR links between a mobile phone and a portable computer. These admissions materially shrink the gap the claims must bridge.

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1. Prior-Art Qualification (the record's cited/similar references)

Only references on the '564 page are used, per the task. Dates are as listed.

⚠️ Two qualification flags. (1) DE 19614925 A1 appears to post-date the '564 priority date (published 1997-10-23 vs. filing 1997-09-19) and, as a foreign published application, does not qualify under § 102(e); it should not be relied upon. (2) US 5,628,379 (a single-track vehicle) is facially non-analogous and should be excluded.

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2. Independent Claim 1 — Element-by-Element Obviousness

Claim 1 breaks into five limitations. Mapping to the record's art:

Result: every limitation of claim 1 is disclosed or rendered obvious by McAfee '594 alone, with '318 supplying the low-power/symmetric-standby aspect and '474 (or '533019/'726893) supplying the wireless-modem-to-data-network leg.

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3. Principal § 103 Grounds (Combinations) and Motivations

Ground 1 — McAfee '594 + Microsoft '318 + Qualcomm '474

Covers claims 1, 2–17 (and 18–25 by analogy).

• '594 supplies the core architecture: page → short-range wireless link → second link to a non-paging (telephone) medium → automated callback, with bidirectional initiation/monitoring.
• '318 supplies low-power, periodic standby monitoring — i.e., a device that sleeps and wakes to sample the channel for its addressed page — and two-way messaging with acknowledgment/retransmission.
• '474 replaces '594's fixed coupling device with a programmable wireless modem/radiotelephone, teaching a computer that drives a wireless modem over to a base station → PSTN → remote host.

Motivation to combine:

1. Same field / same problem. All three target wireless data messaging between a portable computing device and a remote network. '594 expressly identifies the problem of automation ("a paging-type communication system where the call back function is automated") — exactly the '564 objective.
2. '318's express motivation. '318 is about extending battery life by duty-cycling the monitor — a POSITA seeking to make '594's always-on portable client practical would apply '318's standby technique for its stated benefit (predictable result).
3. Eliminating the tether / enabling mobility. '564's own background criticizes cable ties and fixed phone jacks. Substituting '474's wireless modem for '594's wireline coupling device is the natural, predictable way to remove '594's dependence on a nearby landline phone.
4. Design flexibility. Making both endpoints capable of paging (symmetric standby) follows directly from '594's bidirectional hailing/listening and '318's two-way messaging; fixed master/slave roles are an unnecessary restriction when either side may have data.

Ground 2 — McAfee '594 + '318 + EP 0 748 139 A2 (+ '533019)

Covers claims 1, 11, 14, 26 framing.

• EP 0748139 supplies text-message transmission over a radio telephone, directly supporting claim 11's e-mail/voicemail/fax message types and the "phone as modem" leg.
• '533019 supplies packet data over a cellular radiotelephone (second-link leg; claim 9's PSTN and claim 10's "third wireless link" alternatives).
• Motivation: '594 already teaches text/data over the second link; Nokia's text-over-radio teaching is in the same field and is an obvious substitute/refinement for the callback content; '533019 shows the cellular data leg was known.

Ground 3 — Qualcomm '474 + '318 (+ '594)

Alternative primary basis for claims 1–18.

• '474 teaches the computer + wireless modem + PSTN/data-network leg and a "continuous communication link" for applications where landlines "cannot be used or become inoperative or unreliable."
• Adding '594's page-to-establish behavior and '318's low-power monitoring supplies the "automatic wireless link activation between computer and modem" element.
• Motivation: '474 itself motivates robust, cable-free data connectivity; adding automatic link setup + battery-saving monitoring are recognized improvements (KSR).

Ground 4 — McAfee '594 + '318 + '0878038 + '097/'829

Covers claims 3 (repeat paging until acknowledged), 12 (query-only transaction), 7 (link termination).

• '318 and '0878038 teach acknowledgment and retransmission in two-way paging → claim 3.
• '594 teaches the "identify when communication ceases… terminate the virtual" concept → claim 7 (terminating the link after the transaction).
• '097 (message transfer protocol) supports query/transfer mechanics → claim 12.

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4. Reasons a POSITA Would Combine (KSR Rationale Catalog)

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5. Independent Claim 18 (System, Means-Plus-Function)

Claim 18 is claim 1 recast as a system: two devices + "monitoring means" in each that detects a page and establishes the wireless link, with the messaging transaction over the first link and the second link, and the monitoring means operant symmetrically.

• Structure for the means-plus-function terms = the paging receiver/transceiver + controller + messaging software described in the '564 spec. The same structure is disclosed in '594 (paging receiver + "communication mechanism" + controller), '318 (receiver + sleep/wake controller), and '474 (computer + programmable wireless modem).
• Obviousness: For the same reasons as Ground 1. The functional "monitoring means… symmetrical" is met by '594's bidirectional hail/listen and '318's two-way unit. No separate novelty resides in the apparatus form.

Dependent system claims 19–25 track 1's dependent concepts (portable computer, wireless modem, wireless phone, user-specified conditions, transfer over both links, initiation by either device) — each obvious over the Ground 1/2 combinations.

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6. Independent Claim 26 (Computer + Mobile Phone; User-Initiated E-mail Check)

Claim 26 adds a specific conditional sequence:

1. symmetric monitoring by computer and mobile phone (same as claim 1);
2. in response to a user command, the mobile phone calls an ISP to check for e-mail pending for the computer;
3. determines whether e-mail is pending;
4. only if pending: the phone automatically pages the computer to activate the wireless link, then transfers the pending e-mail to the computer.

Mapping. Steps 1, 4 and the transfer leg are supplied by McAfee '594 + '318 + '474 (page → short-range wireless link → transfer via the coupling device/network), and step 4's "conditionally page only when data exists" is a straightforward power/efficiency design choice — '318 expressly frames standby/transmission minimization as the goal, and '564's own spec concedes the "page only when a transaction is necessary" configuration is more power efficient than continuous synchronization.

Where claim 26 is strongest (hardest to invalidate on this record). The "user command → phone calls ISP → check e-mail at the ISP → conditionally page" sub-sequence is a network-service workflow that is not clearly shown by any single reference in the record's prior-art set. '474 teaches a computer driving a modem (not a user checking mail from the phone); '594 teaches automated callback (not a user-initiated mail check). To invalidate claim 26 on this record, one would need an additional reference (or AAPA) teaching a mobile phone invoking a messaging/e-mail service and then pushing retrieved messages to a computer.

Available support: '564's own Background (AAPA) admits commercially available Internet service provider connectivity with automatic checking for new mail. Combined with '474 (wireless modem to data network), '318 (battery-minimal messaging), and '594 (paging to establish the local wireless link and transfer), a POSITA would have found claim 26's sequence an obvious automation of the admitted mail-checking workflow. ⚠️ However, absent a reference squarely teaching the phone-initiated ISP e-mail check, claim 26 is the least vulnerable independent claim, and I cannot assert a single-reference or clean two-reference ground for it from the listed set.

Note on a possible unlisted § 102(e) reference: the "Cited By" list includes US 6,393,014 (AT&T Wireless, "Method and system for providing data communication with a mobile station," priority 1997-06-03, issued 2002-05-21) — an effective date earlier than '564's filing. If it was filed before 1997-09-19, it could be § 102(e) art, and its mobile-station data-communication teachings may bear on the phone/network leg of claim 26. ⚠️ I could not verify its filing date or content in this session, so this is flagged as a lead to verify, not an established ground.

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7. Dependent Claims (Grouped) — Obviousness Summary

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8. Rebuttal Considerations (Non-Obviousness Arguments and Why They Are Weak/Strong)

1. "Symmetry" as the point of novelty. Applicant may argue no reference discloses a fully symmetric peer standby between a computer and a phone. Rebuttal: '594's bidirectional hailing/listening (claim 24) and '318's two-way messaging already contemplate both endpoints monitoring and initiating; making standby behavior symmetric is an obvious simplification/design choice with a predictable benefit. Weak non-obviousness argument.
2. "Automatic re-establishment when devices return to range." The spec stresses re-synchronization after moving out of range. Rebuttal: '594 expressly addresses that "communication does not begin until the receiving device is ready" and that the portable device may initiate "at a time after and independent of when the indication is received" — i.e., decoupled link setup and re-establishment. Weak-to-moderate.
3. Claim 26's user-initiated phone e-mail check + conditional page. As noted, this specific flow is the strongest non-obviousness position on this record. Rebuttal: AAPA admissions (ISP mail checking) + '474 + '318 + '594 make it an obvious automation, but the case requires an additional institutional-knowledge or reference showing. Moderate non-obviousness argument.
4. Teaching away. No reference in the record teaches away from automatically paging to establish a local wireless link; '564's own background describes such links (IR phone↔computer) as commercially available. No meaningful teaching-away.
5. Non-analogous art. Only US 5,628,379 (single-track vehicle) is facially non-analogous and should be discarded. All others are in the wireless-communication/messaging field.
6. Secondary considerations. No evidence of unexpected results, long-felt need, copying, or commercial success tied to the claimed subject matter appears in the record; the expired status and absent litigation (per the Litigation summary) supply none.

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9. Weaknesses and Caveats in the § 103 Case

• DE 19614925 A1 likely not prior art (published after the priority date; no § 102(e) for foreign applications). Do not build a ground on it.
• US 5,581,594 (McAfee) is the strongest reference but is listed as a Similar Document, not an examiner-cited reference on the '564 page, and it published 1996-12-03 (<1 year before filing), so it is § 102(a)/(e), not § 102(b). Its use requires the reference date to precede the '564 invention date (Sept 1997) — it does, but the margin is not a full year.
• Claim 26's phone-initiated ISP e-mail check is not clearly met by the listed art; the cleanest ground for it needs an additional reference (see the flagged US 6,393,014 lead) or reliance on AAPA.
• Means-plus-function terms in claim 18 require identifying corresponding structure; the '564 spec supplies transceiver/controller structure, so the prior-art mapping above holds, but a formal claim-construction ruling would be needed for a definitive § 112(f) analysis.
• I did not independently verify the substance of Motorola '943, '533019, '0878038, Nokia EP 0748139, Televerket '097, WO '9829, or DE '9614925; the mappings above for those rely on their titles/fields as listed and should be confirmed against full texts before filing.

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10. Bottom Line

Claims 1–25 are strongly vulnerable to a pre-AIA § 103 challenge built on McAfee US 5,581,594 + Microsoft US 5,596,318 + Qualcomm US 5,862,474 (optionally + EP 0 748 139 A2 / Motorola US 5,533,019). McAfee supplies the page→short-range wireless link→second network link→automated transfer architecture with bidirectional monitoring; Microsoft supplies the low-power, symmetric standby monitoring; Qualcomm supplies the computer-to-wireless-modem-to-data-network leg. The "symmetric standby" limitation — the patent's emphasized point of novelty — is an obvious design choice flowing from '594's bidirectional hail/listen and '318's two-way messaging, supported by a clear KSR motivation (battery life, mobility, cable elimination) and the specification's own admissions.

Claim 26 is materially more robust, because its "user command → mobile phone calls ISP to check e-mail → page only if mail is pending → transfer" sub-sequence is not squarely shown by the listed art; a successful § 103 attack on claim 26 depends on adding a phone-initiated messaging-service retrieval reference that this record does not clearly contain.

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Uncertainty Statement

• § 102 qualification is date-sensitive and my date-based conclusions (esp. for DE 19614925 and the one-year § 102(b) boundary for US 5,581,594/US 5,596,318) rest on the dates as listed and would need confirmation against full front pages and any priority/continuation chains.
• I verified the substance of US 5,862,474, US 5,596,318, US 5,726,893, and US 5,581,594; I did not verify the substance of the remaining cited references and have mapped them by title/field only.
• US 6,393,014 (AT&T) is offered only as an unverified § 102(e) lead; I could not confirm its filing date or content.
• This is a technical analyst's obviousness assessment, not a legal opinion or claim construction, and carries no legal effect.