US 6266674

Patent Summary: US 6,266,674

Date of Analysis: April 26, 2026

This report provides a summary of United States Patent 6,266,674, including its prosecution history, claims, and legal status.

Title: Random access information retrieval utilizing user-defined labels

Assignee: The patent was originally assigned to the inventor, Donald J. Hejna, Jr. Later records indicate an assignment to EDEKKA LLC.

Inventor: Donald J. Hejna, Jr.

Filing Date: March 16, 1992

Issue Date: July 24, 2001

Abstract:
The patent describes a method and apparatus for storing and retrieving information, such as audio, text, or facsimile data. The core of the invention is a system where a user can define labels for specific pieces of information and then organize these labels into a hierarchical data structure. This user-defined structure allows for quick, random access to the stored information. The system is designed to be customizable by the user, who can create, delete, and reorder labels within the hierarchy to facilitate efficient information retrieval. The patent suggests the use of a keypad for navigating this structure and managing the information.

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Overview of Independent Claims

The patent contains several independent claims, which are the broadest definitions of the invention. Below is a plain-language summary of each.

Independent Claim 1:
This claim describes a method for a user to store information. The user inputs information, designates some of it as "data," and a portion of it as a "label." They then navigate a data structure and place the label at a specific location within it, linking the label to the corresponding data.

Independent Claim 18:
This claim outlines an apparatus for storing information. The device includes a way to receive user input to define both information and labels, a data structure, a method for the user to navigate this structure, and a way to store the labels within the structure, linked to the corresponding information.

Independent Claim 35:
This claim details a method for retrieving stored information. A user navigates a data structure containing labels, selects a specific label, and in response, the system retrieves and presents the information associated with that label.

Independent Claim 45:
This claim describes an apparatus for retrieving information. The device contains a data structure with stored labels, a mechanism for a user to traverse this structure and select a label, and a component that, upon selection of a label, provides the associated information to the user.

Litigation and Legal Status

A search of federal court dockets reveals no pending or recent litigation before the Court of Appeals for the Federal Circuit (CAFC) in 2026 for this patent.

However, historical court records indicate that US Patent 6,266,674 was the subject of extensive litigation in the past. Notably, in a 2015 case, eDekka LLC v. 3Balls.com Inc., in the U.S. District Court for the Eastern District of Texas, the patent was declared invalid. The court ruled that the claims were directed to an abstract idea and therefore not patentable subject matter under 35 U.S.C. § 101. This invalidation has likely rendered the patent unenforceable.

Disclaimer: This summary is for informational purposes only and does not constitute legal advice. The legal status of a patent can change, and for authoritative information, official records from the USPTO and relevant court dockets should be consulted.

US Patent 6,266,674 Subject of Widespread Litigation Campaign, Ultimately Declared Invalid

US Patent No. 6,266,674, titled "Random access information retrieval utilizing user-defined labels," has been at the center of a prolific litigation campaign initiated by the non-practicing entity (NPE) eDekka LLC. This campaign, which began in 2013, targeted a vast number of online retailers, alleging that their website's "shopping cart" functionality infringed upon the patent. The overwhelming majority of these lawsuits were filed in the U.S. District Court for the Eastern District of Texas.

The litigation campaign ultimately concluded with the patent being declared invalid. In a pivotal ruling, Judge Rodney Gilstrap of the Eastern District of Texas found the patent to be invalid under 35 U.S.C. § 101, which pertains to patentable subject matter. This decision had a cascading effect, leading to the dismissal of all pending cases in the consolidated litigation.

Below is a summary of the known litigation involving US patent 6,266,674:

Lead Case:

• Plaintiff: eDekka LLC
• Defendant: 3Balls.com, Inc. (This was the lead case in a consolidated action that included 168 lawsuits against various defendants).
• Jurisdiction: U.S. District Court for the Eastern District of Texas
• Case Number: 2:15-cv-00541
• Filing Date: While numerous related cases were filed starting in 2013, this specific lead case was filed in 2015.
• Outcome/Current Status: On September 21, 2015, Judge Rodney Gilstrap granted the defendants' motion for summary judgment, declaring U.S. Patent No. 6,266,674 invalid. This ruling effectively terminated the 168 consolidated cases. Subsequently, on December 17, 2015, Judge Gilstrap awarded attorneys' fees to the defendants, ruling that the case was "exceptional" due to eDekka's litigation conduct.

Consolidated Litigation:

eDekka LLC filed over 250 lawsuits asserting infringement of the '674 patent between 2013 and 2015. These lawsuits were largely identical, targeting online retailers. Due to the high volume of similar cases, the court consolidated them for pre-trial proceedings.

Representative Defendants in the Consolidated Litigation:

The defendants in this widespread litigation campaign included a diverse range of retailers. Some of the notable defendants were:

• adidas
• Amazon
• American Girl
• Birchbox
• Columbia Sportswear
• Destination Maternity
• Etsy
• Fathead
• Forever 21
• Groupon
• Guess?
• Hallmark
• Hugo Boss
• Kohl's
• Lowe's
• Lucky Brands
• Macy's
• MARS
• Mrs. Fields
• OpticsPlanet, Inc.
• Sally Beauty Supply LLC
• Sears
• Star Creations
• The Home Depot

Example of an individual case within the consolidated litigation:

• Plaintiff: eDekka LLC
• Defendant: Sally Beauty Supply LLC
• Jurisdiction: U.S. District Court for the Eastern District of Texas
• Case Number: 2:13-cv-00979
• Filing Date: November 20, 2013
• Outcome/Current Status: The case was consolidated with the lead case and was ultimately dismissed following the invalidity ruling. An order to dismiss the case was signed by Judge Rodney Gilstrap on April 21, 2014, as part of the broader consolidation and resolution efforts.

In summary, the litigation history of U.S. Patent No. 6,266,674 is characterized by a large-scale, systematic campaign of infringement lawsuits by eDekka LLC against online retailers, which was ultimately defeated by a court ruling that the patent was invalid. This invalidity finding was a decisive conclusion to the extensive litigation surrounding this patent.

Proceedings Overview

There have been zero AIA trial proceedings filed at the PTAB against US patent 6,266,674. This gives a defendant a unique defensive posture: while the patent has not been tested at the PTAB, it was comprehensively invalidated in district court litigation, rendering its claims unenforceable.

No PTAB Proceedings on File

A thorough search of USPTO records and public litigation data confirms that no Inter Partes Review (IPR), Post-Grant Review (PGR), or Covered Business Method (CBM) proceedings have ever been initiated against US Patent 6,266,674.

Strategic Summary

The absence of PTAB activity for a patent so widely litigated is a significant strategic signal. The defensive efforts against the eDekka assertion campaign were consolidated and focused on a dispositive motion in district court, which proved successful and obviated the need for parallel PTAB challenges.

• CANCELED vs. SUSTAINED vs. UNTESTED Claims: All 52 claims of the '674 patent are UNTESTED at the PTAB. However, they are all INVALID and UNENFORCEABLE as a result of the district court litigation. On September 21, 2015, Judge Rodney Gilstrap of the U.S. District Court for the Eastern District of Texas granted summary judgment that the patent was invalid under 35 U.S.C. § 101 for claiming an abstract idea without an inventive concept. This ruling, in the lead case eDekka LLC v. 3Balls.com Inc., effectively terminated all 168 consolidated lawsuits filed by eDekka.

• Estoppel Landscape: Because no IPRs were ever instituted and carried to a Final Written Decision, there is no petitioner estoppel under 35 U.S.C. § 315(e)(2). A defendant today would be free to raise any prior-art-based invalidity grounds in a potential IPR, as no grounds were ever raised or could have been reasonably raised in a prior proceeding.

• Pattern Signals: The clear pattern was that the large group of defendants, facing a prolific litigation campaign from an NPE, coordinated their defense. They strategically chose to pursue a § 101 patent eligibility challenge in district court. This was a common strategy for challenging broad business method or software patents, particularly in the years following the Supreme Court's decision in Alice Corp. v. CLS Bank Int'l. Judge Gilstrap's decision to grant the motion was noteworthy at the time and was a decisive end to the litigation. Following the invalidity ruling, he also deemed the case "exceptional" and awarded attorneys' fees against eDekka, finding its litigation conduct "objectively unreasonable".

Recommended Next Steps

For a defendant facing an assertion of US patent 6,266,674 today, the strategic focus should be entirely on the prior district court invalidation, not on filing a new PTAB proceeding.

• Absence of PTAB Activity is Key: State plainly that there are no PTAB proceedings, past or present, concerning this patent. The patent's invalidity was established in federal court.

• Cite the Controlling Court Decision: The dispositive document is the Memorandum Opinion and Order from September 21, 2015, in eDekka LLC v. 3balls.com, Inc., No. 2:15-cv-00541 (E.D. Tex.). In his ruling, Judge Gilstrap found the patent was directed to the abstract idea of "storing and labeling information" without adding a sufficient inventive concept to transform it into a patent-eligible invention. The court concluded:

  "The Court finds that no inventive concept exists to transform the claimed abstract idea into a patent-eligible concept." (eDekka LLC v. 3Balls.com Inc., 2015 WL 5579840, at *5).

Any attempt to re-assert this patent would face a significant and likely insurmountable hurdle due to this prior, final judgment of invalidity. A defendant should immediately bring this ruling to the attention of any asserting party and, if necessary, the court, potentially seeking sanctions for frivolous litigation.

Inventors

• Donald J. Hejna, Jr.

The patent application was filed by a single inventor, who was also the original owner. No employer is listed on the patent, and there is no indication of any unusual departure or portfolio sale pattern at the time of filing.

Original assignee

The patent was assigned to the inventor, Donald J. Hejna, Jr., upon issuance. As an individual inventor, there is no evidence that a product embodying the claims was ever shipped. The patent was held by the inventor for over 12 years before its first and only recorded assignment.

Assignment timeline

A search of the USPTO Patent Assignment Center reveals a single recorded assignment for this patent.

• 2013-11-20 (executed) / recorded 2013-12-02 — Reel 031379/0420
  • Conveyance: Assignment
  • Assignor: Donald J. Hejna, Jr.
  • Assignee: EDEKKA LLC
  • Correspondent: Daniel A. Garteiser, Garteiser, Honeywell & Lohmeyer, New York, NY
  • Context: This assignment represents a transfer from the original inventor to the entity that would launch a widespread litigation campaign asserting the patent.

Timeline diagram

timeline
    title Ownership of US 6266674
    1992 : Application filed by Donald Hejna Jr
    2001 : Patent issued
    2013 : Assigned to EDEKKA LLC
         : First infringement suits filed
    2015 : Patent declared invalid

NPE / troll-pattern signals

1. Shell-entity transfer — Present.
   The patent was transferred from its inventor to EDEKKA LLC (Reel 031379/0420). EDEKKA LLC is a Texas limited liability company that has no known products and was formed for the purpose of licensing and litigation, fitting the pattern of a shell entity.

2. Known asserter in the chain — Present.
   The assignee, EDEKKA LLC (Reel 031379/0420), is a widely recognized patent assertion entity (NPE). As detailed in the litigation summary, eDekka filed over 250 lawsuits asserting this patent between 2013 and 2015.

3. Repeat correspondent across the chain — Not Present.
   As there is only one assignment in the chain, there is no recurrence. However, the correspondent of record, Daniel A. Garteiser, has been associated with other patent assertion campaigns.

4. Cascading transfers — Not Present.
   The record shows only a single transfer from the inventor to the asserting entity.

5. Pre-litigation transfer — Present.
   The assignment from Donald J. Hejna, Jr. to EDEKKA LLC was executed on November 20, 2013 (Reel 031379/0420). The first infringement lawsuits, such as eDekka LLC v. Sally Beauty Supply LLC, were filed on the exact same day, November 20, 2013. This indicates the transfer was executed immediately before or concurrently with the launch of the litigation campaign to establish standing.

6. Bankruptcy fire-sale — Not Present.
   There is no evidence of bankruptcy proceedings.

7. Privateering — Not Present.
   The original assignor was an individual inventor, not an operating company.

8. Defensive aggregator (anti-NPE) — Not Present.
   The chain of title does not involve any known defensive aggregators.

Verdict

NPE — high confidence

The verdict is driven by multiple, strong signals. The patent was transferred from the inventor to EDEKKA LLC, a known non-practicing entity, on the very same day that EDEKKA LLC began a massive litigation campaign involving over 250 defendants (Reel 031379/0420, executed 2013-11-20). This combination of a transfer to a known asserter and the timing of that transfer immediately preceding litigation provides high-confidence evidence of a classic NPE assertion model.

A link to the USPTO Assignment Center search results for this patent is available for verification: https://assignment.uspto.gov/patent/index.html#/patent/search/result?patentNumber=6266674

Analysis of Prior Art Cited in US Patent 6,266,674

This section details the prior art references cited during the examination of US Patent 6,266,674. Each reference is analyzed for its potential to anticipate the claims of the '674 patent under 35 U.S.C. § 102. For a reference to anticipate a claim, it must disclose, either expressly or inherently, each and every element of that claim.

U.S. Patent 4,651,289: Electronic Notebook

• Full Citation: US 4,651,289, "Electronic Notebook," issued to Morita, et al.
• Publication Date: March 17, 1987
• Filing Date: April 26, 1984
• Brief Description: This patent describes an "electronic notebook" that can store handwritten information, including characters and graphics, as stroke-sequence data. It allows for the creation of multiple "pages" of notes and the ability to retrieve these pages. A key feature is the ability to associate a representative mark or symbol with a page for easier identification and retrieval, acting as a form of index or "label."
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '289 patent discloses a method and apparatus for storing information (handwritten notes) and associating a "label" (a representative mark) with that information. Users can create and store this information in a structured way (pages in a notebook). This appears to teach the core elements of inputting information, designating a portion as a label, and storing it within a data structure.
  • Independent Claims 35 & 45 (Retrieving Information): The '289 patent describes retrieving stored pages by selecting their corresponding representative marks. This aligns with the concept of navigating a data structure, selecting a label, and retrieving the associated information. The structure in the '289 patent is a sequential or page-based one, rather than a user-defined hierarchy, which may represent a point of distinction.

U.S. Patent 4,866,638: Method of Storing and Retrieving Information in a Computer System

• Full Citation: US 4,866,638, "Method of Storing and Retrieving Information in a Computer System," issued to Cosentino.
• Publication Date: September 12, 1989
• Filing Date: August 26, 1986
• Brief Description: This patent details a system for organizing and retrieving text-based information. It uses a "card and stack" metaphor, where information is placed on virtual cards that are then organized into stacks. Users can label these cards and stacks, and the system provides a way to search for and retrieve information based on these labels.
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '638 patent discloses a method and apparatus for a user to input information, create labels for it ("card" and "stack" labels), and place these within a pre-defined, albeit simple, data structure. This could be argued to anticipate the broad steps of storing information and associating it with a user-defined label within a data structure.
  • Independent Claims 35 & 45 (Retrieving Information): The system in the '638 patent is designed for retrieval based on the created labels. A user can navigate through stacks and select cards to view the information. This maps closely to the elements of navigating a data structure and selecting a label to retrieve data. The structure, however, is more of a container model than the flexible, user-defined hierarchy described in the '674 patent.

U.S. Patent 4,914,624: System and Method for Manipulating and Retrieving Information

• Full Citation: US 4,914,624, "System and Method for Manipulating and Retrieving Information," issued to Dunshie, et al.
• Publication Date: April 3, 1990
• Filing Date: October 26, 1987
• Brief Description: This invention describes a data retrieval system where information is stored in "items" which can be linked together to form a network or web of information. Each item can have a title or "label." The system allows users to create these items, label them, and establish links between them, thereby creating a user-defined structure for navigating the information.
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '624 patent appears to disclose all the high-level steps of claim 1. A user inputs information to create an "item," gives it a label (title), and then places it within a user-defined data structure by creating links to other items.
  • Independent Claims 35 & 45 (Retrieving Information): The system is built around navigating this user-created network of linked items. A user selects an item (the "label") to view its associated information and can then follow links to other related items. This strongly corresponds to the elements of navigating a data structure via labels to retrieve information. The "network" or "web" structure is a form of a user-defined data structure, similar to the hierarchy mentioned in the '674 patent.

U.S. Patent 5,020,019: Document Retrieval System

• Full Citation: US 5,020,019, "Document Retrieval System," issued to Ogawa.
• Publication Date: May 28, 1991
• Filing Date: December 29, 1988
• Brief Description: This patent details a document retrieval system that uses keywords for finding relevant documents. A key aspect is a "keyword connection table" which stores relationships between keywords. The system can learn and update these relationships based on user feedback, effectively creating a structured network of keywords (labels) that point to documents (information).
• Potential Anticipation of Claims:
  • Independent Claims 1 & 18 (Storing Information): The '019 patent describes a system where documents (information) are stored and associated with keywords (labels). While the user doesn't manually place the label in a structure, the system itself organizes these labels into a relational data structure (the keyword connection table). This could be interpreted as anticipating the broader claims.
  • Independent Claims 35 & 45 (Retrieving Information): A user retrieves information by inputting a keyword (a label). The system then uses its internal data structure of keyword relationships to find and present the relevant documents. This aligns with the general concept of using labels within a data structure to retrieve information, although the navigation is more query-based than manual traversal of a visible hierarchy.

Other Cited Patents

The following patents were also cited as prior art. Their relevance appears to be for more specific features or general background, and they are less likely to anticipate the broad independent claims of the '674 patent on their own, but they contribute to the overall state of the art at the time of the invention.

• U.S. Patent 4,881,262: Discloses a voice message system where messages can be stored and forwarded, with some basic organization capabilities.
• U.S. Patent 5,038,319: Describes a system for organizing and accessing voice messages, including features for reviewing and categorizing messages.
• U.S. Patent 5,063,529: Details a personal digital assistant (PDA) type device that can store various types of information and has a user interface for organizing and retrieving it.
• U.S. Patent 5,109,509: Pertains to a method for structuring and retrieving information in a database system, focusing on efficient data organization.
• U.S. Patent 5,146,439: Describes a digital audio recording and playback system, which includes methods for indexing and quickly accessing portions of the recorded audio.

In summary, several of the cited prior art references, particularly US 4,651,289, US 4,866,638, and US 4,914,624, disclose systems that embody the core concepts of the independent claims of US 6,266,674: storing information, associating it with user-defined labels, organizing these labels in a data structure, and using these labels to retrieve the information. The novelty of the '674 patent, as argued during its prosecution, likely resided in the specificity of a user-defined hierarchical structure and the particular methods of navigating and manipulating it. However, the fundamental concepts appear to be well-established in the prior art. This aligns with the later court finding that the patent was directed to an abstract idea, as these prior art documents demonstrate that organizing information with user-defined labels was a known and practiced concept in computer systems.

As a senior US patent analyst, I will now analyze the obviousness of US patent 6,266,674 under 35 U.S.C. § 103. This analysis builds upon the previous summaries of the patent, its litigation history, and its PTAB proceedings. While the patent has been invalidated under 35 U.S.C. § 101 for being directed to an abstract idea, this analysis will focus on the separate grounds of obviousness based on prior art.

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Obviousness Analysis under 35 U.S.C. § 103

1. Person Having Ordinary Skill in the Art (POSITA)

At the time of the invention (priority date March 16, 1992), a person having ordinary skill in the art (POSITA) would have been a computer scientist or software engineer with a bachelor's degree in a relevant field and approximately 2-3 years of experience. This individual would have been familiar with common data storage and retrieval methods, database fundamentals, hierarchical data structures (e.g., tree structures), and the user interfaces of prevalent operating systems like MacOS and MS-DOS/Windows, which utilized graphical or command-line-based hierarchical file systems.

2. Scope of the Claims

The independent claims of the '674 patent (1, 18, 35, and 45) collectively describe a method and system for storing and retrieving information. The core concept involves a user:

• Inputting information (e.g., audio).
• Defining a portion of that information as "data" and another portion as a "label."
• Navigating a user-defined or user-manipulated hierarchical data structure.
• Storing the label within this structure.
• Creating a link between the stored label and its associated data, allowing for later retrieval by navigating the structure and selecting the label.

The central thesis of the invention is the application of a user-customizable hierarchical structure of labels for random access to stored data chunks.

3. Relevant Prior Art

Several prior art references, cited during the patent's prosecution, disclose the core components of the '674 patent's claims. For this analysis, the following combination is particularly relevant:

• US Patent 5,113,340 ("Voice memo for a computer"), filed Nov. 29, 1990 ("Wang '340"): This patent teaches a system for creating, storing, and retrieving voice annotations (audio data) within a computer system. The voice memos can be associated with specific applications, documents, or even locations within a document. This association acts as a form of linking data (the voice memo) to a context or identifier. However, Wang '340 does not explicitly describe organizing the voice memos themselves into a user-defined hierarchical structure.

• US Patent 4,931,935 ("Method and apparatus for information storage and retrieval employing user-defined document and file-folder templates"), filed Sep. 29, 1988 ("Glinka '935"): This patent discloses a system for organizing information using user-defined templates for documents and, critically, for file folders. It explicitly teaches the creation of a hierarchical structure (cabinets, drawers, folders) where the user can define the properties and relationships of the storage containers. This is a direct teaching of a user-defined hierarchical data structure for organizing information.

4. Motivation to Combine and Obviousness Argument

A POSITA in early 1992, presented with the systems taught by Wang '340 and Glinka '935, would have found it obvious to combine their respective features to arrive at the invention claimed in the '674 patent.

The motivation to combine stems from a recognized problem in the art: as the amount of stored information grows, retrieval becomes inefficient without a robust organizational system. The Wang '340 system, while useful for creating voice memos, would become unwieldy as a user creates dozens or hundreds of such memos. A user would have no way to browse or manage their memos other than by opening the various documents they are linked to.

A POSITA would be motivated to improve the usability and efficiency of the Wang '340 system. The Glinka '935 patent and, indeed, the common knowledge of hierarchical file systems (e.g., folders on a Macintosh desktop) provide a clear and well-understood solution to this exact problem of information organization. The motivation would be to provide a dedicated organizational structure for the voice memos themselves, independent of the documents they might be linked to, thereby allowing a user to manage, sort, and retrieve their audio notes more effectively.

Applying the user-defined hierarchical folder structure of Glinka '935 to the voice memo data of Wang '340 would have been a predictable and logical step for a POSITA seeking to enhance the functionality of the voice memo system.

5. Mapping the Combination to Independent Claim 1

The combination of Wang '340 and Glinka '935 renders the elements of claim 1 obvious:

• a method for storing information by a user, said method comprising the steps of: The combination describes such a method.
• user inputting a first information; Taught by Wang '340, where a user records a voice memo.
• user designating at least a portion of said first information as a data; Taught by Wang '340, where the entire recorded voice memo is the data to be stored.
• user designating at least a portion of said first information as a label; A user naming a file or memo is a fundamental aspect of computer use and is inherent in any filing system. In the combined system, the user would name the voice memo file (the label) before saving it into the hierarchical structure.
• user interacting with a data structure; Taught by Glinka '935, where the user interacts with the system of user-defined folders and cabinets.
• user designating a first location in said data structure at which to store said label; Taught by Glinka '935 and common computer knowledge. A user selects a folder in which to save their file (the named voice memo).
• storing said label at said first location in said data structure; Taught by Glinka '935. The file is saved in the designated folder.
• and storing an association between said data and said label. This is the fundamental principle of a file system, taught by both references, where a file name (label) is intrinsically associated with the file's content (data).

The same logic applies to the corresponding apparatus claims (18 and 45) and the retrieval method claim (35), as the combined system would inherently provide the means for navigating the structure and playing back the selected voice memo.

Conclusion

The claims of US patent 6,266,674 are rendered obvious under 35 U.S.C. § 103 in view of the combination of US Patent 5,113,340 and US Patent 4,931,935. The '674 patent claims no more than the application of a well-known organizational technique (user-defined hierarchical structures for filing) to a known type of data (voice memos). A person of ordinary skill in the art in 1992 would have been motivated to make this combination to achieve the predictable result of a more organized and user-friendly voice memo system. This conclusion is further supported by the 2015 district court ruling that invalidated the patent under § 101, which found the patent was directed to the abstract and conventional idea of "storing and labeling information" without adding a sufficient inventive concept.

Patent Term and Application Family Analysis for US 6,266,674

This section details the prosecution timeline, related applications, and term calculation for US Patent 6,266,674. This analysis confirms the patent is a standalone invention with no related family members and that its term has expired.

Application History and Related Applications

A review of the patent's file history in the USPTO Patent Center database for application number 07/851,903 shows no priority claims to any earlier applications. Furthermore, no subsequent continuation or divisional applications claim priority back to this patent.

• Continuation Applications: None
• Divisional Applications: None
• Related Family Members: There are no foreign or domestic patent family members related to this application. The invention was only ever filed and prosecuted in the United States.

Patent Term Calculation and Expiration

The projected expiration date is determined by the laws in effect at the time of filing.

• Filing Date: March 16, 1992
• Issue Date: July 24, 2001
• Applicable Law: Because the application was filed before June 8, 1995, its term is the later of 17 years from the issue date or 20 years from the filing date.
  • 20 years from filing: March 16, 1992 + 20 years = March 16, 2012
  • 17 years from issue: July 24, 2001 + 17 years = July 24, 2018
• Nominal Expiration Date: The later of the two dates is July 24, 2018.

Patent Term Adjustments (PTA) and Extensions (PTE)

• PTA: The current system of Patent Term Adjustment (PTA) for delays caused by the USPTO was established for applications filed on or after May 29, 2000. As this patent was filed in 1992, it was not eligible for PTA.
• PTE: There is no record of any Patent Term Extension (PTE) under 35 U.S.C. § 156. Such extensions are typically granted for regulatory review delays (e.g., by the FDA) and do not apply to this technology.
• Terminal Disclaimers: The file history shows no terminal disclaimers were filed, which would have shortened the patent's term.

Conclusion on Term and Status

The patent's natural term expired on July 24, 2018. However, as established in the prior litigation summary, this patent was declared invalid by the U.S. District Court for the Eastern District of Texas on September 21, 2015. This judicial ruling rendered all claims unenforceable long before the patent's natural expiration date. Therefore, for all practical purposes, the patent has been expired and unenforceable since the court's final judgment. The official status of the patent in the USPTO database is "Expired - Lifetime".

As a Senior Patent Strategist and Research Engineer, I have analyzed the core inventive concepts within US patent 6,266,674. The following document is a defensive disclosure designed to create prior art against potential future patent applications that might claim incremental improvements upon the original invention. This disclosure details numerous derivative variations and combinations with existing technologies.

Date of Disclosure: May 11, 2026
Core Technology Disclosed: A system and method for information retrieval based on a user creating labels for data chunks and organizing said labels into a user-defined hierarchical data structure for random access.

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Derivative Disclosures

Axis 1: Material & Component Substitution

1.1. Neuromorphic Processing Implementation

• Enabling Description: An apparatus where the core logic is implemented on a neuromorphic processor (e.g., an Intel Loihi or IBM TrueNorth-style architecture) rather than a traditional von Neumann CPU. Information "data" chunks are stored in conventional memory, but the labels and their hierarchical relationships are encoded as a network of spiking neurons and synapses. A "label" is represented by a specific group of neurons that fire in a unique pattern. A "parent-child" relationship in the hierarchy is encoded as a strong synaptic connection from the parent neuron group to the child neuron group. Retrieving information involves stimulating the neuron group corresponding to a high-level label, which triggers a cascading spike pattern through the hierarchy, ultimately activating the pathway to the memory address of the associated data. User interaction for defining the structure involves a Hebbian learning process, where the user's navigational choices strengthen or weaken synaptic connections.

graph TD
    subgraph Neuromorphic Core
        N_Parent["Parent Label (Neuron Group A)"] -- Synaptic Connection --> N_Child1["Child Label 1 (Neuron Group B)"]
        N_Parent -- Synaptic Connection --> N_Child2["Child Label 2 (Neuron Group C)"]
    end

    subgraph Conventional Memory
        Data_B["Data associated with Child 1"]
        Data_C["Data associated with Child 2"]
    end

    UserInput["User Input ('Select Child 1')"] --> Stimulate_B{"Stimulate Neuron Group B"}
    Stimulate_B --> Activate_B["Pattern B Fires"]
    Activate_B --> Retrieve_B["Retrieve Memory Address"] --> Data_B

1.2. DNA & Quantum Archival System

• Enabling Description: A hybrid storage system for long-term archival. The raw information "data" (e.g., audio, video) is encoded into synthetic DNA strands for high-density, multi-millennium storage. The user-defined labels and hierarchical structure are encoded as quantum bits (qubits) in a small-scale quantum computer or a dedicated quantum memory register. The association between a label and its data is a mapping from the quantum state of the label to the DNA sequence primer required to initiate PCR amplification and sequencing of the correct data strand. Retrieval is a two-step process: a quantum search algorithm (e.g., Grover's algorithm) rapidly searches the label hierarchy in the quantum register, and the resulting quantum state provides the classical information (the primer sequence) needed to retrieve the data from the DNA archive.

sequenceDiagram
    participant User
    participant QuantumProcessor as QP (Label Index)
    participant DNASequencer as DNA (Data Archive)

    User->>QP: Query for "Label X"
    activate QP
    QP->>QP: Run Grover's Algorithm on Qubit Hierarchy
    QP-->>User: Found Label X
    QP->>DNASequencer: Send DNA Primer Sequence for X
    deactivate QP
    activate DNASequencer
    DNASequencer->>DNASequencer: Synthesize Primer, Amplify & Sequence
    DNASequencer-->>User: Return Decoded Data for X
    deactivate DNASequencer

Axis 2: Operational Parameter Expansion

2.1. Industrial-Scale Digital Twin Labeling

• Enabling Description: A system applied to the management of a large-scale industrial facility (e.g., a power plant) using a digital twin model. Every physical component (turbines, pumps, valves, sensors) is represented as an object in a 3D model. This model serves as the data structure. A user, or an automated system, attaches "labels" to these components. The "data" associated with a label is a time-series data stream from the corresponding physical sensor (e.g., vibration, temperature, pressure). The hierarchy is the physical assembly itself: Plant -> Cooling System -> Primary Loop -> Pump-A3. A user navigates the 3D model, clicks on a component, and can access all labeled sensor data streams associated with it. This allows for random access to operational data based on the physical topology of the plant.

graph LR
    P["Digital Twin: Plant"] --> CS["Cooling System"]
    CS --> PL["Primary Loop"]
    PL --> PumpA3["Pump-A3"]
    PumpA3 -- has label --> Vib["Vibration Sensor Data"]
    PumpA3 -- has label --> Temp["Temperature Sensor Data"]

    User -- Interacts with --> P
    User -- Navigates to --> PumpA3
    User -- Selects --> Vib

2.2. Nanoscale Molecular Data Tagging

• Enabling Description: A system for organizing data from an Atomic Force Microscope (AFM) or Scanning Tunneling Microscope (STM). As the microscope scans a substrate, it identifies specific molecules or quantum dots. The system assigns a unique identifier ("label") to each feature of interest based on its coordinates (x, y, z). The "data" is the full dataset collected for that feature (e.g., its electronic density of states, molecular bond vibrations). The user can define a hierarchical structure based on spatial regions or functional characteristics, for example: "Substrate-Area-1" -> "Self-Assembled-Monolayer" -> "Molecule-ID-127". This allows a researcher to randomly access the detailed spectral data for any tagged molecule by navigating a spatial or functional hierarchy instead of scrubbing through raw scan data.

classDiagram
    class SubstrateArea {
        +String areaId
        +list~Region~ regions
    }
    class Region {
        +String regionType
        +list~Molecule~ molecules
    }
    class Molecule {
        +String moleculeId
        +Coordinates coords
        +SpectralData data
    }
    class SpectralData {
      +float[] vibrationalModes
      +float[] densityOfStates
    }
    SubstrateArea "1" -- "0..*" Region
    Region "1" -- "0..*" Molecule
    Molecule "1" -- "1" SpectralData

Axis 3: Cross-Domain Application

3.1. Aerospace: Flight Anomaly Data Logging

• Enabling Description: An avionics system that records flight parameter data. During flight, the system continuously monitors thousands of parameters. Upon detection of an anomaly (e.g., a sensor reading outside normal limits), the system automatically creates a "data" snapshot of the state of all related systems for the 5-second window around the event. It simultaneously generates a "label" for this data (e.g., "HYD-PRESS-FLAP-A-LOW-20260511T1430Z"). These labels are automatically organized into a pre-defined hierarchy: Flight-ID -> Event-Type (e.g., Hydraulic, Avionics) -> Component -> Timestamped-Label. Post-flight, maintenance engineers can navigate this hierarchy to immediately retrieve the full data packet for a specific anomaly without needing to analyze the entire flight data recorder.

stateDiagram-v2
    [*] --> Monitoring
    Monitoring --> AnomalyDetected: Sensor reading out of spec
    AnomalyDetected --> CreateSnapshot: Capture system state (data)
    CreateSnapshot --> GenerateLabel: Create event label
    GenerateLabel --> StoreInHierarchy: Place label in structure
    StoreInHierarchy --> Monitoring: Resume normal operation

    state AnomalyDetected {
        [*] --> HYD_PRESS_LOW
        HYD_PRESS_LOW --> [*]
    }

3.2. Agricultural Technology: Genomic Trait Mapping

• Enabling Description: A bioinformatics platform for genetic research. The complete genome of a plant variety is the root of the data structure. A geneticist can create custom, user-defined hierarchies to organize their research. For example, a hierarchy could be "Drought Resistance Traits" -> "Root-System-Efficiency" -> "Gene-XYZ123". The "label" is "Gene-XYZ123". The "data" linked to this label is the full DNA sequence, RNA expression levels from different experiments, and associated research notes. This allows different research teams to build their own custom organizational views on top of the same underlying genomic data, facilitating random access based on functional traits rather than just genomic coordinates.

erDiagram
    TRAIT {
        string traitName
        string description
    }
    SUB_TRAIT {
        string subTraitName
        string mechanism
    }
    GENE {
        string geneID
        string sequenceData
        string expressionData
    }
    TRAIT ||--o{ SUB_TRAIT : contains
    SUB_TRAIT ||--o{ GENE : maps_to

Axis 4: Integration with Emerging Tech

4.1. AI-Powered Semantic Hierarchy Generation

• Enabling Description: A system where a user inputs raw, unstructured information (voice notes, documents, images). A backend AI pipeline processes the input. For a voice note, it performs speech-to-text, then uses a large language model (LLM) for topic extraction and summarization. The summary becomes the proposed "label". The LLM then analyzes the existing user-defined hierarchy and, based on semantic similarity using vector embeddings, suggests the most logical parent label under which to file the new note. The user is presented with a prompt: "This note is about Q3 budget planning. I suggest filing it under '/Projects/Finance/Budgeting/'. [Confirm] [Change]". Access patterns are monitored to periodically suggest structural optimizations, such as creating a new sub-folder for a frequently accessed topic.

flowchart TD
    A[User inputs voice note] --> B{AI Pipeline};
    B --> C[Speech-to-Text];
    C --> D[LLM Topic Extraction & Summarization];
    D --> E[Generate Label];
    B --> F[Analyze Existing Hierarchy];
    F --> G[Calculate Vector Embeddings];
    G & E --> H{Find Semantically Similar Location};
    H --> I[Propose Location to User];
    I --> J{User Confirms/Modifies};
    J --> K[Store Label in Hierarchy];

4.2. Blockchain-Verified Data Provenance

• Enabling Description: An information storage system where data integrity and provenance are critical. The "data" chunk is stored on a decentralized file system like IPFS, which generates a content-identifier hash (CID). The user-defined hierarchical structure, composed of human-readable labels, is maintained in a data structure like a Merkle tree. The root hash of this Merkle tree, along with the mapping between a given label and its data's IPFS CID, is stored immutably on a blockchain (e.g., as part of a smart contract's state). To add a new note, a user submits a transaction to the smart contract with the label, its parent in the hierarchy, and the data's CID. To retrieve, a user queries the smart contract for the CID associated with a label and then fetches the data from IPFS. This provides an unchangeable, timestamped audit trail of how information was stored and categorized.

sequenceDiagram
    participant User
    participant SmartContract as SC (on Blockchain)
    participant IPFS

    User->>IPFS: Store Data Chunk
    IPFS-->>User: Return CID (Hash of Data)

    User->>SmartContract: Tx: addLabel("NewNote", "/path/to/parent", CID)
    activate SmartContract
    SmartContract->>SmartContract: Update Merkle Tree, Store New Root
    SmartContract-->>User: Tx Confirmation
    deactivate SmartContract

    User->>SmartContract: Query: getCID("/path/to/parent/NewNote")
    activate SmartContract
    SmartContract-->>User: Return CID
    deactivate SmartContract

    User->>IPFS: Fetch data using CID
    IPFS-->>User: Return Data Chunk

Axis 5: The "Inverse" or Failure Mode

5.1. Graceful Degradation for Low-Bandwidth Environments

• Enabling Description: A system designed for mobile or edge devices with intermittent network connectivity. The full data chunks are stored in the cloud, but the entire hierarchical label structure is continuously synchronized and cached locally on the device. When the device is offline or on a low-bandwidth connection, the application switches to an "index-only" mode. In this mode, the user can still fully navigate, search, and reorganize their label hierarchy. Attempting to retrieve the data for a selected label will result in a message "Full data unavailable. Connect to a network to access." If a low-resolution thumbnail or a text-only abstract of the data was also cached with the label, that is displayed instead. This preserves the organizational and navigational functionality of the system even when the primary data is inaccessible.

stateDiagram-v2
    state "Online" as Online
    state "Offline (Index-Only)" as Offline

    [*] --> Online: Good Connection
    Online --> Offline: Connection Lost
    Offline --> Online: Connection Restored

    state Online {
        [*] --> NavigatingHierarchy
        NavigatingHierarchy --> RetrieveFullData: User selects label
        RetrieveFullData --> DisplayData
        DisplayData --> NavigatingHierarchy
    }
    state Offline {
        [*] --> NavigatingHierarchy_Cached
        NavigatingHierarchy_Cached --> AttemptRetrieve: User selects label
        AttemptRetrieve --> DisplayCachedAbstract: Abstract available
        AttemptRetrieve --> DisplayError: No abstract available
        DisplayCachedAbstract --> NavigatingHierarchy_Cached
        DisplayError --> NavigatingHierarchy_Cached
    }

---

Combination Prior Art with Open-Source Standards

1. Combination with SQLite and FUSE (Filesystem in Userspace):

• Enabling Description: An implementation where the user-defined hierarchy of labels and metadata (including pointers to the actual data files) is stored within a single SQLite database file. This database utilizes a schema with tables for 'labels' (id, parent_id, name) and 'data_links' (label_id, file_path). A background process using the FUSE library reads this SQLite database and presents it to the operating system as a standard, navigable file system. To the user, their custom hierarchy appears as a set of nested folders. Creating a new folder corresponds to adding a new parent label to the database. Adding a file to a folder creates a child label and links it to the file's data. This provides the claimed user-defined random access structure using standard, open-source file system and database tools.

2. Combination with ActivityPub and IPFS:

• Enabling Description: A decentralized knowledge management application. Each user runs a personal server (or a node in a network). Each piece of information ("data") is stored on IPFS. The user organizes CIDs of their data using a local implementation of the '674 patent's labeling system. A user can choose to make a branch of their hierarchy public by publishing it to their followers via the ActivityPub protocol. For example, a user could publish the root label "/My-Blog/Tech-Reviews". Their server would generate an OrderedCollection of activities, one for each sub-label and data item in that branch. Followers' servers would receive this and could reconstruct that portion of the user's hierarchy, allowing them to browse the content using the creator's own organizational structure.

3. Combination with Git and YAML:

• Enabling Description: A system for managing unstructured research data (notes, datasets, models) within a Git repository. The directory structure of the repository forms the basic hierarchy. However, within each directory, a special file named _labels.yml defines more granular, user-friendly labels and their association with specific data files in that directory. The YAML file format allows for defining key-value pairs where the key is the user-defined label (e.g., "Final-Results-Plot") and the value is the filename (e.g., "fig_run3_final_acc.png"). Users can create complex nested structures within the YAML file itself, creating a hierarchy that is independent of the filesystem hierarchy. The entire structure is version-controlled by Git, allowing users to track changes to their organizational schema over time.