Invalidity dossier
US 6473031
Position privacy in an electronic device
Current assignee: Northstar Systems LLC
Added 9/28/2026, 6:32:48 AM
Active provider: DeepSeek · deepseek-v4-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for the specific patent number and any related litigation, then summarize.
Let me check specifically for litigation/docket activity and confirm the assignment chain.
US Patent 6,473,031 — Summary
Caveat on sources: The authoritative text below comes from the full patent document supplied in this task (Google Patents copy of US6473031B1, fetched 2026‑09‑28). I searched for the patent number and for litigation/docket activity. My searches did not return any USPTO proceeding, district‑court docket entry, or CAFC 2026 appellate docket naming US 6,473,031 specifically. I therefore cannot confirm any 2026 Federal Circuit activity for this patent, and I will not assert any. Note also that searches for a bare "6473031" string are dominated by unrelated hits (e.g., a Quantum/Prism FC420 document number), so I restricted attention to the patent‑specific results.
Bibliographic data (per the patent record)
| Field | Value |
|---|---|
| Patent number | US 6,473,031 B1 |
| Title | Position privacy in an electronic device |
| Application number | US 09/690,001 |
| Filing date | 2000‑10‑16 |
| Priority date | 2000‑10‑16 |
| Issue/publication date | 2002‑10‑29 |
| Inventor | Scott C. Harris (listed residence Rancho Santa Fe, CA in related family records) |
| Original assignee | Individual (Scott C. Harris) |
| Current assignee | Northstar Systems LLC (Texas) |
| Claims | 12 (claims 1, 3, 6, 7, 8, 9, 10, 11, 12 independent; 2, 4, 5 dependent) |
| Legal status | Expired – Lifetime; anticipated expiration 2020‑10‑16 |
| CPC classes | G01S5/0009, G01S5/0018, G01S5/0036, G01S5/0045, G01S5/0054; H04L67/04, H04L67/52 |
Assignment chain (as recorded): Harris → Virginia Innovative Technology LLC (2007) → corrected/renamed Virginia Innovative Technologies LLC (2010/2011) → Platt Technology Investments LLC (2011) → Gula Consulting LLC via merger (2015) → Intellectual Ventures Assets 138 LLC (2019/2020) → Northstar Systems LLC (2020). Maintenance fees were paid at 4, 8, and 12 years.
Family note (do not conflate): This patent sits atop a large family claiming the 2000‑10‑16 priority date, including US 6,700,534 B2, US 7,327,312 B1, US 7,551,128 B2, US 7,642,955 B2, US 7,817,085 B2, US 8,717,231 B1, US 8,805,416 B2, and US 9,625,269 B2. Some search results I retrieved returned claim text belonging to US 2003/0001774 A1 (an abandoned continuation of this patent) rather than to US 6,473,031 itself — its claims recite "prevent … from determining its position" and "manual actuating mechanism," which are not the claims of US 6,473,031. Treat those as a different document.
Abstract (verbatim)
"A privacy enhancement device for electronic device such as a cellular telephone. In one mode, the cellular telephone operates in its normal mode, whereby its position can be detected by either wap techniques or by GPS techniques. In a second mode of operation, the wap/GPS operation is overridden, so that the position cannot be detected."
Problem addressed
Cellular/WAP phones and GPS‑equipped devices automatically determine and report position to a base station or server (e.g., for E911). The specification notes the countervailing concern that such reporting can be used to track a user surreptitiously, including via a manufacturer "back door" or a faked emergency call. The invention provides user‑controlled position privacy while leaving voice communications functional.
Plain‑language overview of each independent claim
Claim 1 — Apparatus with a passive blocking override.
An electronic device with a position‑detection module that determines its position and reports it to a remote object. An "override control" can be actuated to stop that reporting while other parts of the device keep working. Critically, the override is a passive blocking element physically attached to a portion of the device to block the position module's reception of information.
Claim 3 — Apparatus with an active jamming override.
Same device/reporting setup, but the override is an actuating mechanism producing a signal state that blocks reporting until de‑actuation. The override includes a jamming element that produces interference with the position module when actuated and stops producing it when de‑actuated. (Claims 4–5 add that the jamming information may be false data, and that the jammer may draw power from the device.)
Claim 6 — Apparatus with a privacy self‑test function.
Device with position module and reporting; an override control prevents reporting while preserving other functions; plus a privacy detection element that tests whether the position module will nonetheless report unauthorized information when requested. The privacy detection element includes an update function so it can adopt different test techniques over time.
Claim 7 — Method using a passive blocker.
A two‑mode operating method: mode one permits automatic position reporting; mode two prevents it. Mode two is implemented by attaching a passive reception‑blocking device to the electronic device.
Claim 8 — Method using active jamming.
A first mode permits automatic position reporting; a manual actuation of an actuating mechanism disables automatic reporting so position cannot be reported. The second mode is implemented by actively jamming a position‑detection operation.
Claim 9 — Method with testing and updating the test.
Operate a cellular phone in a first mode where position can be auto‑reported; on a user action of a specific type, enter a second "privacy enhanced" mode in which calls can still be placed/received but position cannot be auto‑reported. Then test the phone in the privacy mode to determine whether privacy is actually achieved, and update the way the testing is carried out.
Claim 10 — Portable telephone with manual override + jamming signal.
A portable telephone with (1) telephone electronics for communication, (2) a position detection module producing a determined position, and (3) a reporting device that reports that position to a remote object. A manually operable override control prevents reporting any information indicative of the determined position while letting the telephone electronics keep operating; the override includes a jamming element producing a jamming signal that prevents such reporting.
Claim 11 — Cellular telephone method with satellite positioning + jamming.
First mode: automatic position reporting and communication with a cellular base station are both allowed. On manual actuation, a second mode prevents any automatic position reporting while still allowing base‑station communications. The first mode uses satellite positioning; the second mode prevents the module from detecting position via satellite and interferes with the satellite positioning circuitry via jamming.
Claim 12 — Method with an external blocking device.
Operate a cellular phone in a first mode where position can be auto‑reported; on a user action of a specific type, enter a second privacy‑enhanced mode in which calls can still be made/received but position cannot be auto‑reported — where the user action is attaching an external blocking device to the cellular phone.
Claim‑drafting observations
- The claim set is unusually independent‑heavy (9 of 12 claims independent), splitting into three thematic buckets: electronic/software override (claims 1, 3, 10), method‑of‑operation (claims 7, 8, 11, 12), and privacy verification (claims 6, 9).
- Claims 1/7 and 12 are directed to passive/external blocking (metal or RF‑absorbing cover over the GPS antenna, per FIGS. 3A–3B); claims 3/8/10/11 to active jamming (broad‑spectrum noise carrying false satellite information at short range, per FIG. 4); claim 6/9 to the test‑module/subscription‑update concept (FIG. 2, elements 250/255/260/270).
- Notable drafting artifacts in the granted text: claim 1's "wherein" clause and claim 8's reference to "said second mode of operation" appear without a clean antecedent; claim 3's preamble omits "as in claim 1." These are in the record as granted.
Litigation / docket status (what I could and could not find)
- I found no docket or order specifically identifying US 6,473,031. Northstar Systems LLC (corporate parent Alpha Alpha Intellectual Partners LLC per its Rule 7.1 statements) ran an E.D. Tex. assertion campaign in 2020–2022 against defendants such as Shenzhen OnePlus (2:20‑cv‑00385), Best Buy (2:22‑cv‑00138), Honda (2:22‑cv‑00143), and Broadcom (2:22‑cv‑00144), under Judge Rodney Gilstrap. The Stanford NPE database links family member US 8,805,416 to the Honda and MediaTek suits — i.e., related‑family patents, not US 6,473,031.
- I have no authoritative information regarding any CAFC 2026 appeal involving US 6,473,031. Given the patent's anticipated expiration of 2020‑10‑16, a 2026 appeal would have to arise from a case filed and tried years earlier; I could not verify such a case and will not speculate. If you need this verified, the reliable sources would be PACER/CM‑ECF for the relevant district docket and the Federal Circuit's own docket (CM/ECF) searched by patent number or by party name, plus the USPTO Patent Center assignment and reexamination/PTAB records for US 09/690,001.
Bottom line: Everything in the bibliographic and claim sections above is grounded in the authoritative patent text supplied; the "no 2026 CAFC activity found" statement is a negative search result, not proof of absence.
Generated 9/28/2026, 12:54:15 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 6473031. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll run targeted searches across patent-litigation sources for US 6,473,031 specifically.
Let me dig into the litigation-database sources directly with several targeted queries.
Let me check the litigation-database and docket aggregators more directly.
Bottom line
No litigation naming US Patent 6,473,031 is known. I searched the sources you identified — the Unified Patents litigation portal, CourtListener/PACER-derived docket aggregators, and general litigation databases — and found no district-court case, ITC Section 337 action, or Federal Circuit appeal in which US 6,473,031 was asserted or otherwise at issue. I am not returning any case as "litigation involving '031," because none of the candidates I surfaced actually carriers that patent number.
Note the date discrepancy to be aware of: your task heading says current date April 26, 2026, while the patent-file fetch in this matter is stamped 2026‑09‑28. That does not change the result, but it is worth pinning down if you are computing any § 286 or § 315(b) clock.
What I searched and what came back
| Source queried | Result for "6,473,031" / "6473031" |
|---|---|
Unified Patents litigation portal (portal.unifiedpatents.com/litigation/caselist) |
No docket hits keyed to '031. The portal returned the NorthStar campaign (e.g., NorthStar Systems LLC v. Kohl's, 2:20-cv-00404) but not this patent. |
| CourtListener / PACER-derived docket aggregators | No docket or opinion for '031. Bare-number searches were dominated by noise (see below). |
| General patent-litigation searches | No pleading, order, or judgment citing '031 as an asserted patent. |
| Google Patents "Similar Documents" / citation traffic for '031 | Citation traffic only (Enovsys/Mundi Fomukong, X One, Curio RFID, etc.) — citations, not litigation. |
Search noise to discard (do not treat as '031 cases):
- Quantum/Prism FC420 manual, document PN 6473031 — an equipment part number, not a patent, and explicitly not a litigation hit.
- Chinese docket identifiers beginning with the string
6473031…(e.g.,(2023)沪0106民初29774号,(2022)粤0118民初8063号) — these are case-ID strings, not US patent assertions, and are unrelated. US 10165059 B2(X One) and similar hits — different patents.
The one thing that may be confusing the question — and it is not '031
The patent family born from the 2000‑10‑16 priority date is the likely source of any "isn't this patent in suit?" impression. The recorded owner, NorthStar Systems LLC, did assert patents from this family — but as best I can find, the asserted member was a continuation, not '031 itself:
- In NorthStar Systems, LLC v. Hyundai Motor Co. (E.D. Tex., 2:22-cv-00495, Judge Rodney Gilstrap), the reported patents-in-suit were US 8,478,527 B2; US 6,898,432 B1; US 8,014,943 B2; US 8,032,297 B2; and US 8,805,416 B2 — terminated by voluntary dismissal with prejudice (each party bearing its own costs). US 8,805,416 B2 is a § 120 family member of '031, not '031.
- Other retrievable NorthStar dockets I saw — v. Target (2:20-cv-00405), v. Kohl's (2:20-cv-00404), v. Lenovo Group (2:22-cv-00267, voluntary dismissal) — likewise do not show '031 on the face of the materials retrieved.
Because '031 reached its anticipated expiration on 2020‑10‑16 ("Expired – Lifetime" per the file), there is also a structural reason a 2020–2022 campaign would have run on the longer-lived continuations rather than on '031: asserting an expired patent yields only back damages inside § 286's window and no injunction.
Caveat, stated plainly: I could not open every complaint in the NorthStar campaign this session, so I am reporting this as "no '031 assertion found," not as an affirmative negative. The family-member confound is real and is the most likely explanation for any report that this "family" was litigated.
Honest statement of the negative (and how to certify it)
My "no known litigation" finding rests on (a) the patent's own legal-events record supplied in this matter, which shows only assignments and maintenance-fee events — no litigation, no § 337, no PTAB, no CAFC entry — and (b) the searches above, which returned nothing keyed to '031. It is a high-confidence negative, not a certified one. To convert it into something you can state in a brief without hedging, run these free checks and record the date/time of each:
- Unified Patents litigation portal —
https://portal.unifiedpatents.com/litigation/caselist(search patent 6,473,031), and the per-patent page at the/patents/patent/6473031form. - CourtListener —
https://www.courtlistener.com/→ RECAP docket search by patent number 6473031; also search party "NorthStar Systems." - USPTO OCE Patent Litigation Cases API — the Data.gov "OCE – Patent Litigation Cases (Version 1)" dataset, queryable by patent number, which is the cleanest way to sweep all district-court filings at once.
- USPTO Patent Center for application 09/690,001 (Patent No. 6,473,031) — confirm there is no § 337/§ 298 litigation-notice entry, no disclaimer, and no reissue.
- PACER for the E.D. Tex. NorthStar campaign dockets (start with 2:22-cv-00495 Hyundai/Kia and 2:20-cv-00403 lead case) if you need to prove that the asserted numbers exclude '031.
If you do need "any case touching '031" for completeness
Under a broad "patent-cited-in-a-court-document" definition, the only court-related appearances of '031 I can ground are prior-art and citation references, not assertions of '031:
- '031 appears as a cited reference in the "References Cited" front-page data of later patents (e.g., it is listed in the patent-family/citation listings for US 8,717,231 and appears in the "Cited By" chain on the Google Patents record).
- '031 is cited as prior art / background in family-member prosecution (it is the parent in the § 120 chain to US 6,700,534; US 7,327,312; US 7,551,128; US 7,642,955; US 7,817,085; US 8,717,231; US 8,805,416; US 9,625,269).
Neither of those is "litigation involving US 6,473,031," and I am listing them only so nothing in the record gets mistaken for a case.
Requested table (empty, by design)
| Plaintiff(s) | Defendant(s) | Jurisdiction | Case No. | Filing date | Outcome / status |
|---|---|---|---|---|---|
| — | — | — | — | — | No case identified in which US 6,473,031 is the patent-in-suit or otherwise at issue. |
Carry-forward caveat (unchanged from prior sections)
The prior sections established the chain of title (Harris → Virginia Innovative Technologies → Platt → Gula → Intellectual Ventures Assets 138 → NorthStar Systems LLC), the NPE verdict, and the 2020‑10‑16 expiration of '031. Those findings are consistent with — and in fact help explain — today's result: an expired, individually-originated patent whose monetization ran through its continuations. If a demand letter you are handling names '031, the two facts to lead with are (1) expiration 2020‑10‑16 and (2) no litigation of record on this patent; if it names a family member such as US 8,805,416 B2 or US 9,625,269 B2, the analysis shifts to those continuity patents, which have different (later) expiration dates and a documented NorthStar assertion history.
Generated 9/28/2026, 1:01:05 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll verify the "no PTAB activity" default against public sources before writing.
Let me run a few more targeted checks to make the negative finding as solid as I can.
PTAB / AIA Trial Report — US 6,473,031 B1
Patent: "Position privacy in an electronic device" · App. 09/690,001 · filed & priority 2000-10-16 · issued 2002-10-29 · anticipated expiration 2020-10-16 (expired)
Owner of record: Northstar Systems LLC (reel 054666/0104, recorded 2020-12-16)
Report date: 2026-09-28
Sourcing note (read first). The canonical source for this section is the structured "PTAB proceedings on file" block in the prompt, which reflects the USPTO Open Data Portal's AIA-trial ingest for this patent. It returns no proceedings. I ran independent web searches to try to falsify that default — looking for IPR/PGR/CBM numbers naming 6,473,031, for NorthStar-systems PTAB activity, and for any Federal Circuit appeal of the patent. Nothing contradicted the ODP result. I could not complete direct queries against PTAB E2E / Patent Center / CourtListener for the patent number because my tool calls were exhausted; the negative finding below is therefore well supported but not exhaustively verified. I state where the verification gap bites rather than papering over it. Every proceeding number appearing in this report is reproduced as retrieved; I have invented none.
Proceedings overview
Total AIA trial proceedings on US 6,473,031: 0 — zero active, zero claims invalidated, zero claims sustained, zero settled, zero institution denials. No IPR, PGR, or CBM has ever been filed against this patent, which means its claims have never been tested at the Board and the patent as granted stands exactly as issued on 2002-10-29.
Bottom-line defensive posture — this is the unusual case where "no PTAB history" is not a "hardened patent" story. Two facts break the analogy to a hardened NPE patent:
- The patent is expired (2020-10-16). There is no forward-going infringement exposure. A demand letter in 2026 citing US 6,473,031 can only reach acts within the six-year damages lookback (i.e., 2020-09-28 → 2020-10-16, a roughly three-week window), and § 286's lookback cannot resurrect acts performed after expiration. Expiration is a stronger and cheaper defense than any IPR outcome.
- No PTAB proceeding means no claim-level validity adjudication in either direction, and no statutory estoppel. Unlike a defendant facing a patent that "survived two IPRs," you inherit no canceled claims to point at and no § 315(e)(2) estoppel protecting anyone — but you also inherit no adverse FWD. The claims are simply untested.
The practical translation: do not build a defense budget around an IPR on the '031 patent. There is no plausible economic reason to file one (the patent is expired and unexploitable for future conduct), and if a demand letter cites the '031 patent's claims 1–12, the primary response is expiration plus a lookback-quantum challenge, not a prior-art attack.
Proceedings on this patent
None to report. The requested per-proceeding template (type, filed date, status, judge panel, grounds, institution decision, FWD at claim-level granularity, settlement, appeal, defensive value) has no entries, because no proceeding exists. I will not manufacture a proceeding to fill the template.
Adjacent proceedings a defendant will encounter — and why they are not on this patent
These are the PTAB proceedings that surface in any search of this patent family and owner. None names US 6,473,031 as the challenged patent. I list them because the most common analytical error in this family is confusing the '031 patent with its longer-lived continuations (a misattribution already flagged in the earlier sections of this analysis, and worth repeating at the PTAB stage).
| Proceeding | Challenged patent | Petitioner v. PO | Relevance to US 6,473,031 |
|---|---|---|---|
| IPR2023-00890 | one of NorthStar's five asserted navigation patents | BMW of North America, LLC et al. v. NorthStar Systems LLC | Not '031 |
| IPR2023-00934 | same campaign | same | Not '031 |
| IPR2023-01017 | same campaign | same | Not '031 |
| IPR2023-01049 | US 8,805,416 B2 | same | Not '031 — but see below |
| IPR2023-01190 | same campaign | same | Not '031 |
| IPR2023-01191 | US 8,805,416 B2 | same | Not '031 |
Grounded facts from the retrieved record: Finnegan's own case page and press release (finnegan.com, dated 2024-04-03) state that BMW of North America filed six IPRs "on all claims for all 5 patents asserted by NorthStar," and that the matter ended in a royalty-free covenant not to sue covering NorthStar's present and future portfolio after six favorable institution decisions. The five asserted patents, per the Volkswagen and Hyundai/Kia docket reporting, were US 8,478,527; US 6,898,432; US 8,014,943; US 8,032,297; and US 8,805,416 — all of which are later family members / campaign patents, not the '031 patent. The Finnegan page names the IPR panel judges as Droesch, Flax, Petravick, Wood.
The one genuinely interesting cross-reference — the '031 patent appears as evidence, not as the target
In IPR2023-01049 (BMW v. NorthStar, on the '416 patent), the petitioner's exhibit list includes:
- Exhibit 1014 — "File History of U.S. Patent Application No. 09/690,001" — i.e., the prosecution file of the application that issued as US 6,473,031
- Exhibit 1016 — "File History of U.S. Patent Application No. 09/682,600" — the CIP that issued as US 6,700,534
- Exhibit 1002 — "File History of U.S. Patent No. 8,805,…" (truncated in the retrieved record)
Why this matters, and its limit. Application 09/690,001 has a 2000-10-16 filing date, which precedes the '416 patent's 2008-02-14 filing by ~7 years, making the '031 patent (issued 2002-10-29) a candidate § 102(e) / § 102(a)(2) reference against the '416 claims, and making its prosecution history relevant to written-description/enablement and priority arguments. That is a use of the '031 patent as prior art and file-history evidence against a sibling patent — the mirror image of a PTAB challenge to '031. It is not a validity adjudication of the '031 claims, creates no estoppel as to '031 under § 315(e)(2), and does not change the "zero proceedings" count.
Also worth noting from the same campaign: the Board declined to deny institution under § 314(a)/Fintiv in IPR2023-01017, Paper 12 (2023-12-08) notwithstanding a Sotera stipulation — retrieved via a JD Supra summary. This is a § 314(a) discretionary-denial data point about the '416 patent and its siblings, not about '031.
Federal Circuit activity
None found involving US 6,473,031. No appeal docket naming the patent appeared in any search. Since no AIA proceeding on '031 reached an FWD, there is no § 319 appeal to look for, and since the prior sections found no district court case naming '031, there is no § 1295 appeal source either. I could not run a direct CourtListener/CM-ECF query for the patent number before tool exhaustion, so treat this as a strong negative rather than a certified one.
Strategic summary
Claim status — all 12 claims are UNTESTED at the PTAB; none canceled, none sustained. Claims 1, 3, 6, 7, 8, 9, 10, 11, and 12 are independent; claims 2, 4, and 5 are dependent. Because no AIA trial was ever instituted, the full granted claim set — including the passive-blocking claims (1, 2, 7, 12), the active-jamming claims (3, 4, 5, 8, 10, 11), and the privacy-self-test claims (6, 9) — remains in force as issued, subject only to the expired term. A defendant whose demand letter cites claim 1 or any other claim cannot claim "the claim is dead at the Board"; conversely, the patent owner cannot point to any Board affirmance of patentability. There is nothing to link to and nothing to quote, because no Final Written Decision on this patent exists.
Estoppel landscape — there is effectively no AIA estoppel in this family's vicinity, and certainly none on '031. Section 315(e)(2) estoppel requires an IPR "that results in a final written decision under section 318(a)." The BMW IPRs did not reach FWDs — the campaign terminated by covenant not to sue (announced 2024-04-03), not by judgment, and NorthStar's district court exits were voluntary dismissals with prejudice (Volkswagen, 2:22-cv-00486, dismissal accepted 2024-04-04; Hyundai/Kia, 2:22-cv-00495) with no merits ruling. Consequently: (a) BMW/Finnegan and their privies are not § 315(e)(2)-estopped as to the '031 patent at all, and (b) no other party has IPR estoppel running against them on this patent. For a defendant today, every prior-art ground is formally available — but the strategic point is that you would be spending IPR money to invalidate claims that can no longer be asserted against your future conduct. The available grounds only matter if the demand is framed around the narrow pre-expiration lookback window, in which case a district court invalidity defense is far more efficient than an IPR.
Pattern signals. (i) Same petitioner, multiple IPRs: yes — BMW filed six IPRs attacking all claims of all five asserted NorthStar patents in one coordinated campaign, with a ranking notice filed under the Consolidated Trial Practice Guide for the two petitions against the '416 patent (IPR2023-01049 and IPR2023-01191). But none of those six petitions targeted '031, so there is no serial-attack pattern on this patent. (ii) Patent owner pursuing PTAB appeals aggressively: no evidence found of any NorthStar appeal to the Federal Circuit from an FWD; the campaign resolved by covenant and voluntary dismissal rather than by appeal. (iii) Defensive aggregator in the chain: no. The prior sections established this chain terminates at Northstar Systems LLC (a plaintiff-side NPE, parent Alpha Alpha Intellectual Partners LLC), with no RPX/AST/LOT/Unified/OIN anywhere in title. I found no Unified Patents IPR on the '031 patent — and note that Unified Patents' own description of NorthStar as "an NPE and subsidiary of Alpha Alpha Intellectual Partners, LLC" identifies NorthStar as the target class, not a defensive aggregator. (My attempt to query the Unified Patents litigation portal for patent 6473031 did not complete before tool exhaustion — flagged as unverified, not as confirmed absent.)
One caveat carried forward, and it now cuts in a specific direction. The patent's anticipated expiration of 2020-10-16 means the window in which a competitor would have had both standing and economic motive to file an IPR closed roughly six years ago. The absence of ANY PTAB activity on a patent that (a) sat in the Intellectual Ventures divestiture pipeline, (b) was acquired by a purpose-built NPE, and (c) belonged to a family that was IPR'd in 2023, is best explained by the patent being too old and too near end-of-life to be worth asserting — the family's assertion value ran through the longer-lived continuations, principally US 8,805,416 B2 (a '031-family continuation that the Stanford NPE database links to the Honda and MediaTek suits). If you are being pitched '031 as a live threat, the pitch is probably a family mix-up.
Recommended next steps
If you are a defendant receiving a demand citing US 6,473,031:
- Lead with expiration, not prior art. Cite the anticipated expiration of 2020-10-16 and compute the § 286 lookback. For conduct in 2026, there is no actionable period. Demand the plaintiff articulate the specific pre-2020-10-16 accused acts and the damages theory supporting them. This is the highest-value, lowest-cost response available and it requires no PTAB filing.
- Verify the patent number on the face of the letter. The most likely defect in an '031 demand is that the plaintiff means a different family member. Check whether the letter's claim chart actually maps to '031's claims (passive blocking element / jamming element / privacy detection element with an update function) or to the "prevent … from determining its position" language of the abandoned continuation US 2003/0001774 A1, or to US 8,805,416 B2. Prior sections flagged exactly this conflation.
- If the letter does assert '031 and refuses to withdraw, you can independently confirm the "zero proceedings" finding before responding: PTAB E2E search by patent number at
https://ptacts.uspto.gov/ptacts/; PTAB decisions athttps://www.uspto.gov/patents/ptab/decisions; Federal Circuit docket via CourtListener athttps://www.courtlistener.com/?q=%226%2C473%2C031%22. Because no FWD exists, there is no opinion to link or quote — say that affirmatively rather than implying one exists. - Do not file an IPR. With no forward exposure, an IPR on '031 would burn $250k+ through FWD to cancel claims nobody can assert prospectively, and § 315(b)'s one-year bar may not even be the constraint compared to the plain absence of business justification. If validity must be litigated, do it in the district court as an invalidity defense tied to the lookback period.
- If you are advising on the family generally rather than on '031, the operative proceedings are the six BMW/NorthStar IPRs (IPR2023-00890, -00934, -01017, -01049, -01190, -01191), all resolved by covenant not to sue announced 2024-04-03 with no FWD and no fee payment per Finnegan's own account. Finnegan's case page:
https://www.finnegan.com/en/work/experience/northstar-systems-llc-v-bmw-et-al-222-cv-00486-ed-tex-623-cv-00456-wd-tex-ipr2023-01190-01017-00890-00934-01049-01191-ptab.html; press release:https://www.finnegan.com/en/firm/news/finnegan-and-bmw-group-successfully-demolish-non-practicing-entity-northstars-efforts.html.
Milestone note: because there are no pending proceedings, there are no institution-decision deadlines, oral hearings, or one-year FWD due dates to track for US 6,473,031. If you become aware of a newly filed petition, the statutory clock is: institution decision within 3 months of the preliminary response (or its due date) under § 314(b), and FWD not later than 1 year from institution, extendable up to 6 months for good cause under § 316(a)(11).
Constraint acknowledgment: no FWD, institution decision, or appeal exists for this patent, so none is described, quoted, or characterized. The absence of PTAB activity on US 6,473,031 is the finding, and it is a signal in its own right — a patent this old, in a family this heavily litigated, that never drew a single petition, for an asset that expired on 2020-10-16.
Generated 9/28/2026, 1:01:19 PM
Ownership chain (7)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2007-08-07 · recorded 2007-08-08 · reel 019658/0962 · Assignment
HARRIS, SCOTT C.VIRGINIA INNOVATIVE TECHNOLOGY, LLC
transfer-to-asserter
2007-08-07 · recorded 2011-03-25 · reel 026026/0268 · Corrective Assignment
HARRIS, SCOTT C.VIRGINIA INNOVATIVE TECHNOLOGIES, LLC
change of name only
2007-08-08 · recorded 2010-08-02 · reel 024776/0212 · Corrective Assignment
HARRIS, SCOTT C.VIRGINIA INNOVATIVE TECHNOLOGIES, LLC
change of name only
2011-03-30 · recorded 2011-04-14 · reel 026128/0396 · Assignment
VIRGINIA INNOVATIVE TECHNOLOGIES, LLCPLATT TECHNOLOGY INVESTMENTS LLC
transfer-to-asserter
2015-08-26 · recorded 2015-12-18 · reel 037328/0060 · Merger
PLATT TECHNOLOGY INVESTMENTS LLCGULA CONSULTING LIMITED LIABILITY COMPANY
internal reorg
2019-12-20 · recorded 2020-01-03 · reel 051412/0726 · Assignment
GULA CONSULTING LIMITED LIABILITY COMPANYINTELLECTUAL VENTURES ASSETS 138 LLC
transfer-to-asserter
2019-12-30 · recorded 2020-12-16 · reel 054666/0104 · Assignment
INTELLECTUAL VENTURES ASSETS 138 LLCNORTHSTAR SYSTEMS LLC
transfer-to-asserter
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll start by pulling the assignment-record specifics that the patent text doesn't include — particularly correspondents of record — then cross-check against the NPE directories.
Found a Harris-related assignee with a named correspondent. Let me dig into the specific chain entities and correspondents.
US 6,473,031 B1 — Assignment Record Reconstruction & NPE Pattern Analysis
Method note / data provenance. The bibliographic and recorded-assignment data below come from the authoritative full text supplied in this task (Google Patents legal-events block for US6473031B1, fetched 2026-09-28), which reproduces the USPTO assignment reel/frame, conveyance type, assignor, assignee, execution ("effective") date and recording date for every post-issuance recording. What the Google Patents legal-events block does not reproduce is the correspondent of record. I attempted targeted lookups against the exact reel/frame strings for this chain; my retrievals returned no correspondent data for this patent's reels before my tool budget was exhausted. I therefore report Correspondent: not retrieved rather than guessing, and I flag one adjacent (not-confirmed) correspondent finding below.
Inventors
| Inventor | Residence / correspondence | Employer at filing |
|---|---|---|
| Scott C. Harris (sole named inventor) | Correspondence address of record on the Harris portfolio: P.O. Box 927649, San Diego, CA 92192; family records list residence as Rancho Santa Fe, CA | None of record. The issued patent's "Original Assignee" is "Individual." There is no employer-inventor assignment anywhere in the record. |
Pattern note (unusual, but not a red flag in itself): Because this was filed by an unaffiliated individual, the classic "all inventors departed the assignee within 12 months of filing" precursor to a portfolio fire-sale cannot occur here — there was never a corporate assignee to depart from. The relevant analogue is that Harris held the patent personally for roughly seven years (issue 2002-10-29 → first recorded assignment executed 2007-08-07) and then began a sustained sell-down. Harris appears as the individual applicant/prosecutor-of-record on a large personal portfolio; in an IPR exhibit for a different Harris patent, Public PAIR is described as listing "the inventor" as the attorney of record — i.e., pro se prosecution was his practice, which is consistent with the '031 file but is not proof of it for this patent.
Original assignee
"Individual" — i.e., Scott C. Harris personally. No company, product line, or operating business is named on the face of the patent.
- Product embodying the claims: No. The specification is written as a conceptual disclosure ("The present application defines a device which enhances privacy in such a system") with block-diagram figures only; there is no evidence the inventor manufactured or sold a privacy clip, jammer module, or self-test product.
- Primary line of business at issue date: individual inventor / later patent-licensing activity.
- Current status: the original assignee (an individual) is not an entity with a corporate status; the patent has passed out of his hands entirely (see chain below).
This matters for the NPE analysis: the "operating company → licensing LLC" step that the shell-entity signal asks about never happened. The correct characterization is individual inventor → first-generation licensing entity, which is a weaker but still real form of the signal.
Assignment timeline
All seven recorded events below are reproduced from the authoritative assignment block. Reel 019658/0962 etc. = reel 019658, frame 0962.
1. 2007-08-07 (executed) / recorded 2007-08-08 — Reel 019658/0962
- Conveyance: Assignment
- Assignor: HARRIS, SCOTT C.
- Assignee: VIRGINIA INNOVATIVE TECHNOLOGY, LLC (Virginia)
- Correspondent: not retrieved — see signal 3.
- Context: transfer-to-asserter — first move of the patent out of individual ownership into a name-suffixed IP holding LLC.
2. 2007-08-08 (effective) / recorded 2010-08-02 — Reel 024776/0212
- Conveyance: Corrective Assignment — "to correct the assignee name from VIRGINIA INNOVATIVE TECHNOLOGY, LLC to VIRGINIA INNOVATIVE TECHNOLOGIES, LLC"
- Assignor: HARRIS, SCOTT C.
- Assignee: VIRGINIA INNOVATIVE TECHNOLOGIES, LLC (as corrected)
- Correspondent: not retrieved
- Context: change of name only / record-correction. Note the ~3-year gap between the 2007 transaction and the 2010 correction.
3. (effective 2007-08-07) / recorded 2011-03-25 — Reel 026026/0268
- Conveyance: Corrective Assignment — same name correction, re-filed with a revised effective date string
- Assignor: HARRIS, SCOTT C.
- Assignee: VIRGINIA INNOVATIVE TECHNOLOGIES, LLC
- Correspondent: not retrieved
- Context: change of name only. Two separate corrective filings (2010 and 2011) of the same 2007 transaction, with inconsistent effective dates (2007-08-08 on the first, 2007-08-07 on the second) — a drafting artifact in the record, not two transfers.
4. 2011-03-30 (executed) / recorded 2011-04-14 — Reel 026128/0396
- Conveyance: Assignment
- Assignor: VIRGINIA INNOVATIVE TECHNOLOGIES, LLC
- Assignee: PLATT TECHNOLOGY INVESTMENTS LLC (Delaware)
- Correspondent: not retrieved
- Context: transfer-to-asserter / internal reorg between licensing vehicles — note this executed only 5 days after the final name-correction recording (2011-03-25), i.e., the 2007–2011 tidy-up was done in order to hand a clean chain to Platt.
5. 2015-08-26 (executed) / recorded 2015-12-18 — Reel 037328/0060
- Conveyance: Merger
- Assignor: PLATT TECHNOLOGY INVESTMENTS LLC
- Assignee: GULA CONSULTING LIMITED LIABILITY COMPANY (Delaware)
- Correspondent: not retrieved
- Context: internal reorg by merger — the classic mechanism for moving a portfolio between aggregator shells without a taxable "assignment" characterization.
6. 2019-12-20 (executed) / recorded 2020-01-03 — Reel 051412/0726
- Conveyance: Assignment
- Assignor: GULA CONSULTING LIMITED LIABILITY COMPANY
- Assignee: INTELLECTUAL VENTURES ASSETS 138 LLC (Delaware)
- Correspondent: not retrieved
- Context: transfer to a documented aggregator — the IV entry point into the chain.
7. 2019-12-30 (executed) / recorded 2020-12-16 — Reel 054666/0104
- Conveyance: Assignment
- Assignor: INTELLECTUAL VENTURES ASSETS 138 LLC
- Assignee: NORTHSTAR SYSTEMS LLC (Texas)
- Correspondent: not retrieved
- Context: transfer-to-asserter. Two features worth flagging: (a) executed 10 days after the IV Assets 138 acquisition (2019-12-20 → 2019-12-30), i.e., a pass-through, not a hold; and (b) recorded nearly twelve months later, on 2020-12-16 — two months after the 2020-10-16 anticipated expiration. Northstar's record title was therefore perfected post-expiration.
Cross-reference note on reels: each of these recordings is a multi-patent instrument (covers Harris-family siblings such as US 6,700,534, US 7,327,312, US 7,551,128, US 7,642,955, US 7,817,085, US 8,717,231, US 8,805,416, US 9,625,269). Expect the same reel/frame to appear on the sibling patents — that is a useful verification cross-check, not a separate event.
Timeline diagram
timeline
title Ownership of US 6473031
2000 : Filed by Scott C Harris
2002 : Patent issues to individual inventor
2007 : Assigned to Virginia Innovative Technology LLC
2010 : Corrective assignment recorded
2011 : Name corrected to Virginia Innovative Technologies LLC
: Assigned to Platt Technology Investments LLC
2015 : Merged into Gula Consulting LLC
2019 : Assigned to Intellectual Ventures Assets 138 LLC
: Reassigned to Northstar Systems LLC
2020 : Northstar recording filed
: Patent term expires
(Timeline reflects recorded events only. The 2007 transfer is the first recording; there is no assignment at issue because the patent issued to the individual inventor.)
NPE / troll-pattern signals
1. Shell-entity transfer — PRESENT.
Concrete basis: (a) the chain contains four consecutive name-suffixed IP-holding entities — Virginia Innovative Technology LLC (reel 019658/0962), Platt Technology Investments LLC (reel 026128/0396), Gula Consulting LLC (reel 037328/0060), Intellectual Ventures Assets 138 LLC (reel 051412/0726); (b) no record, and no product literature, shows any of them shipping goods or services; (c) the final hop is to a Delaware "Assets 138" vehicle, and the SCU law-review study of Intellectual Ventures (retrieved) documents 1,276 IV-associated shell companies, 954 of which hold recorded patents. Limit on the finding: I could not retrieve registered-agent addresses or Delaware/Texas single-member LLC filings (e.g., for Northstar Systems LLC) within this session, so the "registered-agent service address / single-purpose LLC" half of the signal is supported by naming and behavior, not by a corporate-registry document. The signal rests on the recorded chain, not on the names alone.
2. Known asserter in the chain — PRESENT.
Intellectual Ventures appears by name in the record: Intellectual Ventures Assets 138 LLC is the assignee on reel 051412/0726 (executed 2019-12-20). That is a direct match against the requested list, not an inference. Northstar Systems LLC (reel 054666/0104) is additionally the current assignee and, per the previously generated sections of this analysis, is a documented E.D. Tex. patent plaintiff with corporate parent Alpha Alpha Intellectual Partners LLC. Note the IV paper trail is privity-of-record, not merely reputational.
3. Repeat correspondent across the chain — UNCLEAR (unable to verify; single adjacent, unconfirmed lead).
The legal-events block supplied does not expose correspondents, and my targeted lookups on reels 019658/0962, 026128/0396, 037328/0060, 051412/0726 and 054666/0104 returned no correspondent data. I therefore will not assert a repeat correspondent.
Adjacent finding — different patent, treat as a lead only: an IPR exhibit in IPR2017-02043 (US 9,047,586) records the correspondent for a Harris → BARTeX RESEARCH, LLC assignment (assignee address 2775 Villa Creek Drive, Dallas, Texas 75234) as Richard B. Megley, Jr., 181 W. Madison Street, Niro, Scavone, Haller & Niro, Chicago, IL 60602. That is the only named correspondent I surfaced anywhere in the Harris portfolio. It is not confirmed for the '031 chain. Action item: pull reel 019658/0962 and 026128/0396 on Assignment Center and check whether Megley/Niro (or a successor firm) is the correspondent — if it is, the signal flips to PRESENT and is a strong one, because it would tie the 2007 sell-off and the 2011 Platt transfer (and the Bartex line) to one filer.
4. Cascading transfers — PRESENT.
Basis: five transfers in twelve years, three of them inside 24 months of each other, ending in a 10-day cascade: Gula → IV Assets 138 executed 2019-12-20 (reel 051412/0726), then IV Assets 138 → Northstar executed 2019-12-30 (reel 054666/0104). A ten-day hold by an IV "Assets" vehicle is a pass-through structure, and the two recordings share the same one-year window. The 2007→2011→2015 hops (reels 019658/0962 → 026128/0396 → 037328/0060) confirm the pattern rather than being isolated.
5. Pre-litigation transfer — UNCLEAR (dates line up suggestively, but no complaint verified).
No suit naming US 6,473,031 was found in the previously generated litigation section. However, the Northstar acquisition executed 2019-12-30 sits immediately before the Northstar assertion wave described earlier (E.D. Tex. campaign running 2020–2022, e.g. Northstar v. Shenzhen OnePlus, 2:20-cv-00385). I could not verify that '031 was among the asserted patents in any of those complaints, and the patent expired 2020-10-16, so I am not calling this signal present. Verification path: read the complaints in the 2020 E.D. Tex. Northstar cases and match patent numbers.
6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 proceeding, receivership, or judicial sale appears anywhere in the chain. The transfers are voluntary recorded assignments and one statutory merger (reel 037328/0060). This is not a Kodak/Nortel/Polaroid fact pattern.
7. Privateering — NOT PRESENT in the strict sense; functional analogue PRESENT.
Strict privateering requires an operating company to hand patents to an NPE that asserts against that company's competitors (usually surfaced via SEC filings or EFF/Patent Progress coverage). Here the transferor at every step was a non-operating IP vehicle, and the original source was an individual inventor, not a product company. What is present is the equivalent downstream structure — aggregator (IV) → dedicated assertion vehicle (Northstar/Alpha Alpha). I list it under this heading for completeness but score it as the strict signal being absent. I found no SEC 10-K/8-K disclosure tying this patent to a corporate transferor, consistent with there being no operating company in the chain.
8. Defensive aggregator (anti-NPE) — NOT PRESENT.
The chain terminates at Northstar Systems LLC, an asserting entity, not at RPX, AST, LOT Network, Unified Patents, or OIN. No defensive-aggregator recording appears on any of the seven events. (Consistent with the earlier finding in this analysis that there are zero AIA trials on '031 and no defensive-aggregator challenge.)
Summary score: 3 present (1, 2, 4) + 1 structural (7, aggregator→asserter) + 2 unclear (3, 5) + 2 not present (6, 8).
Verdict
NPE — high confidence
Justification. Two strong signals plus a cascade are documented on the face of the record, not inferred from names: (i) the patent left an individual inventor for a chain of four successive IP-holding vehicles — Virginia Innovative Technology LLC (reel 019658/0962, exec. 2007-08-07), Platt Technology Investments LLC (reel 026128/0396, exec. 2011-03-30), Gula Consulting LLC (reel 037328/0060, merger exec. 2015-08-26), and Intellectual Ventures Assets 138 LLC (reel 051412/0726, exec. 2019-12-20) — with no product or operating business anywhere in the chain; and (ii) a named entity on the NPE list, Intellectual Ventures, appears directly in the record as assignee on reel 051412/0726, with the patent passed in 10 days to Northstar Systems LLC (reel 054666/0104, exec. 2019-12-30, recorded only 2020-12-16, after the 2020-10-16 expiration). Persistence of the chain after the patent expired 2020-10-16 further shows this was an assertion-stage asset, not a technology transfer.
Caveat. The verdict is strong on ownership-chain evidence. Two data points I could not obtain in this session — the correspondent of record on each reel/frame and confirmation of registered-agent/single-member details for the assignee LLCs — are exactly the items that would let me name the lawyer running the chain, which is the single most useful tell when the LLC names look unrelated. I have not fabricated them.
Verification (public, free):
- USPTO Assignment Center — search patent number 6473031: https://assignmentcenter.uspto.gov/
- Legacy index (same underlying records): https://assignment.uspto.gov/patent/index.html
- USPTO Patent Center for application 09/690,001 (assignment tab + prosecution history): https://patentcenter.uspto.gov/
- Confirm the correspondents on reels 019658/0962, 026128/0396, 037328/0060, 051412/0726, 054666/0104, and specifically test the Megley/Niro lead from IPR2017-02043 against the 2007 and 2011 recordings.
Cross-reference flags for the earlier sections of this analysis (no contradictions; two reinforcements):
- Nothing in the assignment record contradicts the earlier findings or the "no PTAB proceedings / no litigation naming '031" conclusions.
- Reinforcing detail the earlier sections could not see: the Northstar recording (reel 054666/0104) was made 2020-12-16, i.e. after expiration, and the underlying transfer was executed 2019-12-30 — which tightens the "historical-damages-only, § 286-limited" posture set out in the strategic summary, and makes the already-flagged Northstar v. Broadcom (2:22-cv-00144) patent-number check more, not less, worth doing.
Generated 9/28/2026, 1:01:32 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll verify the patent record and then dig into each cited reference. Let me run several targeted searches.
Let me pin down the remaining cited references.
Prior Art Analysis — US 6,473,031 B1
Builds on the prior sections (bibliographic, litigation, PTAB, assignment). Those sections are not repeated. The one cross-reference I carry forward: the earlier section noted that prosecution materials for application 09/690,001 included "an examiner reference to Herring" — that is US 6,069,570 (inventor Herring, Russell M.), which appears on the front page and is discussed below. The two are the same reference; no contradiction.
0. Target confirmation (no similar-number substitution)
| Field | Value | Source |
|---|---|---|
| Patent | US 6,473,031 B1 | Google Patents record supplied |
| Application | 09/690,001 | same |
| Title | Position privacy in an electronic device | same |
| Filed / priority | 2000-10-16 | same |
| Granted | 2002-10-29 | same |
| Claims | 12 (independent: 1, 3, 6, 7, 8, 9, 10, 11, 12; dependent: 2, 4, 5) | same |
| Inventor | Scott C. Harris | same |
Nothing below is a "similar number." Where a family member is discussed (e.g. US 8,805,416, US 9,625,269, US 2003/0001774 A1) it is flagged as a different document, consistent with the earlier sections.
Scope limitation, stated up front. The patent's public record — as supplied — lists 10 U.S. patent citations on the face of '031 (the "References Cited" block) and 0 non-patent-literature citations. I treat those 10 as the answer to "each patent citation for 6473031." I also include a second tier of 8 references that Google Patents reports under "Family Cites Families (8)" — these were cited in sibling applications sharing the 2000-10-16 priority date, not on the '031 front page. I include them because three of them are the most dangerous prior art on the override/privacy concept and an analyst who ignores them will understate the risk. I could not open the '031 file wrapper itself in this session, so the front-page list is authoritative-as-supplied, not certified against Patent Center.
Do not confuse these with prior art: the "Cited By (15)" block, the "Similar Documents" block, and WO 2002/033939 A2 "Position privacy in an electronic device" are later documents or the Harris family's own PCT — they are not prior art against '031.
1. Tier 1 — the 10 references cited on the face of US 6,473,031
| # | Patent | Title | Filed | Published/Issued | Assignee | §102 basis |
|---|---|---|---|---|---|---|
| 1 | US 5,731,785 | System and method for locating objects including an inhibiting feature | 1994-05-13 | 1998-03-24 | Lemelson, Jerome H. | §102(b) |
| 2 | US 6,069,570 | Asset location system | 1997-09-18 (prov. 1996-09-20) | 2000-05-30 | ATX Technologies, Inc. (Herring) | §102(a)/(e) |
| 3 | US 6,049,718 | Telephone system and method with background location response capability | 1997-07-29 | 2000-04-11 | Stewart, Gordon M. | §102(a)/(e) |
| 4 | US 6,085,090 | Autonomous interrogatable information and position device | 1997-10-20 | 2000-07-04 | Motorola, Inc. | §102(a)/(e) |
| 5 | US 6,107,960 | Reducing cross-interference in a combined GPS receiver and communication system | 1998-01-20 | 2000-08-22 | Snaptrack, Inc. | §102(a)/(e) |
| 6 | US 5,301,368 | System for controlling operations of GPS receiver unit and radio telephone unit for automotive vehicle | 1989-10-27 | 1994-04-05 | Nissan Motor Company, Ltd. | §102(b) |
| 7 | US 5,940,753 | Controller for cellular communications system | 1990-03-19 | 1999-08-17 | Celsat America, Inc. | §102(b) |
| 8 | US 5,222,245 | GPS receiver | 1990-03-20 | 1993-06-22 | Pioneer Electronic Corporation | §102(b) |
| 9 | US 5,751,373 | Television function selection method, television receiver and remote commander for television receiver | 1995-03-31 | 1998-05-12 | Sony Corporation | §102(b) |
| 10 | US 6,222,484 | Personal emergency location system | 1999-06-16 | 2001-04-24 | Seiple, Ronald L. | §102(e) only |
Note on #10: US 6,222,484 issued after the '031 filing date, so it cannot be §102(a) or §102(b) art; it qualifies only as a §102(e) reference as of its 1999-06-16 filing. This is the one date trap in the list.
Reference-by-reference
1. US 5,731,785 — Lemelson, "System and method for locating objects including an inhibiting feature"
- Citation: US 5,731,785 A; filed 1994-05-13; granted 1998-03-24; inventor Jerome H. Lemelson. URL:
https://patents.google.com/patent/US5731785 - Description (verified): A portable/concealable coded-signal device (GPS + RF) carried by a person, vehicle or object that, on remote or local coded command, transmits identifying and location data to a monitor station; the station tracks the object. The title's "inhibiting feature" is a control that inhibits the locating/reporting function (the disclosure includes a PIN-match activation gate — the unit activates only when an input matches a PIN stored in memory).
- Why the examiner cited it: it is the closest art on the user-controlled inhibit concept — i.e., a locating device whose position-reporting function can be suppressed.
- §102 assessment — claims potentially anticipated: It does not anticipate any claim as a whole. It is best read as an element-level §102(b) disclosure for the preamble of claims 1 and 3 ("electronic device having a position detection module … that reports information indicative of said position … to a remote object") plus a gating control on that reporting, and as a §103 base for the "override control" concept of claims 1, 3, 6, 8, 10. It discloses no passive blocking element (claims 1, 2, 7, 12) and no jamming element (claims 3, 4, 5, 8, 10, 11). That is the express gap.
2. US 6,069,570 — ATX Technologies (Herring), "Asset location system" — the earlier section's "Herring" reference
- Citation: US 6,069,570 A; filed 1997-09-18 (provisional 60/026,408, 1996-09-20); granted 2000-05-30; assignee ATX Technologies, Inc., San Antonio TX; inventor Russell M. Herring. URL:
https://patents.google.com/patent/US6069570 - Description (verified): Pager + signal/control processor + GPS receiver + cellular telephone module. Asset sits in low-power sleep; a call center pages it; the processor matches the page to the asset, energizes the GPS receiver, obtains lat/long, and the cellular module transmits location/status to a remote monitoring center, then deactivates the GPS and returns to sleep. Claims 1, 10 recite explicit "means for de-activating" / "deactivating said GPS receiver."
- Why the examiner cited it: it discloses a position-detection module that is selectively activated and deactivated and that reports position to a remote object — the '031 preamble — and does so in a phone-bearing, battery-powered unit.
- §102 assessment — claims potentially anticipated: No whole-claim anticipation. Strong §102(a)/(e) element disclosure for the preamble of claims 1, 3 and the reporting architecture of claim 10; useful §103 art against claims 1, 3, 6, 10. No passive blocker, no jammer, no privacy purpose (its activation/deactivation is power management, not privacy) — so it cannot reach claims 2, 4, 5, 7, 8, 11, 12.
3. US 6,049,718 — Stewart, "Telephone system and method with background location response capability"
- Citation: US 6,049,718 A; filed 1997-07-29; granted 2000-04-11; inventor Gordon M. Stewart. URL:
https://patents.google.com/patent/US6049718 - Description (verified): A portable telephone with a position locator (GPS); on an incoming location request signal the phone routes that request to the locator and transmits a location signal back without ringing/alerting the user — i.e., "background" location reporting — while normal voice calls are handled as usual. Notably, claim 10 recites "a switch which allows a user to select whether or not a location signal is provided in response to a location request signal during operation of the telephone."
- Why the examiner cited it: this is the most on-point Tier-1 reference for the user-operable override that suppresses location reporting while the telephone keeps working.
- §102 assessment — claims potentially anticipated: The claimed "switch … whether or not a location signal is provided … during operation of the telephone" maps very closely onto the override control element of claims 1, 3, 6, 10 and onto the two-mode concept of method claims 7, 8, 11, 12. It nonetheless does not anticipate any of those claims as issued, because every one of claims 1, 7 and 12 requires a passive blocking element attached to a portion of the device and claims 3, 8, 10, 11 require a jamming element — neither appears in '718. Treat it as the primary §103 reference against the override concept, and as §102(a)/(e) art for the preamble elements.
4. US 6,085,090 — Motorola, "Autonomous interrogatable information and position device"
- Citation: US 6,085,090 A; filed 1997-10-20; granted 2000-07-04; assignee Motorola, Inc. URL:
https://patents.google.com/patent/US6085090 - Description (verified): A geo-location device (GPS receiver) that "determine[s] its absolute positional location without revealing its location external to the device" / "without allowing external detection of said positional location," coupled to a satellite-communications device and a control processor; the device monitors position and, in response to an interrogation message, generates a response message containing positional location.
- Why the examiner cited it: the express "without revealing its location external to the device" language is the closest Tier-1 statement of a position-privacy objective, plus it has the interrogate-and-report architecture.
- §102 assessment — claims potentially anticipated: Good §102(a)/(e) element art for the position-detection-and-report preamble of claims 1, 3; strong §103 art for the privacy-purpose framing of claims 1, 3, 6, 9. It does not disclose a user-actuated override, a passive blocker, a jammer, or a self-test/update function, so it cannot anticipate claims 1–12 as issued.
5. US 6,107,960 — Snaptrack, "Reducing cross-interference in a combined GPS receiver and communication system"
- Citation: US 6,107,960 A; filed 1998-01-20; granted 2000-08-22; assignee Snaptrack, Inc. URL:
https://patents.google.com/patent/US6107960 - Description (verified): Methods/apparatus for reducing cross-interference between a GPS receiver and a co-located communication system in a combined unit; estimates characteristics of a stronger signal and subtracts/avoids its interference in the weaker GPS correlation outputs.
- Why the examiner cited it: it establishes that a GPS receiver and a cellular/AI comms system can be combined in one device and that the two interfere — background for both the shared-unit architecture (FIG. 1 of '031) and the notion that interference can impair position detection.
- §102 assessment — claims potentially anticipated: Element-level §102(a)/(e) art for the "combined GPS + communication" environment underlying claims 2, 10, 11. It is anti-interference art — it teaches removing interference, not creating it — so it is not a §102 reference against the jamming claims (3, 4, 5, 8, 10, 11); at most it is cited-and-distinguishable background.
6. US 5,301,368 — Nissan, "System for controlling operations of GPS receiver unit and radio telephone unit for automotive vehicle"
- Citation: US 5,301,368 A; filed 1989-10-27; granted 1994-04-05; assignee Nissan Motor Company, Ltd. URL:
https://patents.google.com/patent/US5301368 - Description (to the level I can verify; confidence: medium): A controller for a vehicle unit combining a GPS receiver and a radio telephone, governing their operations relative to one another — i.e., selectively controlling when the GPS receiver operates versus when the telephone operates. I did not retrieve the full text this session; the title and the '031 citation context indicate it is cited for selectively disabling/controlling GPS-receiver operation while the telephone remains usable.
- Why the examiner cited it: it is the earliest cited art for the proposition that a position-detection function can be turned off/controlled independently of the communication function — precisely the "allows other parts of said electronic device to operate" clause.
- §102 assessment — claims potentially anticipated: Element-level §102(b) art for the "prevent the position module from operating/reporting but keep other parts operating" element of claims 1, 3 and the two-mode structure of claims 7, 8, 11. No passive blocker, no jammer, no privacy purpose. Cannot anticipate any claim as a whole. (Medium-confidence as to specific disclosure — verify against the '368 text before relying on it in a brief.)
7. US 5,940,753 — Celsat America, "Controller for cellular communications system"
- Citation: US 5,940,753 A; filed 1990-03-19; granted 1999-08-17; assignee Celsat America, Inc. URL:
https://patents.google.com/patent/US5940753 - Description (confidence: medium): A controller for a cellular/satellite communications system governing communications between the system and mobile units. This is the weakest-relevance reference in the set; it appears to be cited as general background for a cellular system controller that interacts with mobile stations' location/registration.
- Why the examiner cited it: background on the carrier/base-station side of the FIG. 1 architecture ("may also communicate with the server 140, such as to a base station").
- §102 assessment — claims potentially anticipated: Background/analogous-art citation only. No meaningful §102 case against any of claims 1–12. I flag this as the reference where I have the least direct textual verification; do not rely on it without pulling the document.
8. US 5,222,245 — Pioneer, "GPS receiver"
- Citation: US 5,222,245 A; filed 1990-03-20; granted 1993-06-22; assignee Pioneer Electronic Corporation. URL:
https://patents.google.com/patent/US5222245 - Description (confidence: medium): A GPS receiver, cited as basic art for the position-detection module itself (receiver architecture, satellite-signal processing, and — plausibly — selective enablement/power control of the receiver).
- Why the examiner cited it: elementary GPS-receiver background underpinning the "position detection module" element common to all apparatus claims.
- §102 assessment — claims potentially anticipated: §102(b) art for the "satellite positioning system module" element of claim 2 and the satellite-positioning element of claim 11, considered alone. It discloses no reporting-to-remote, no override, no blocker, no jammer — no whole-claim anticipation of any claim 1–12.
9. US 5,751,373 — Sony, "Television function selection method, television receiver and remote commander for television receiver"
- Citation: US 5,751,373 A; filed 1995-03-31; granted 1998-05-12; assignee Sony Corporation. URL:
https://patents.google.com/patent/US5751373 - Description (confidence: medium): A method for selecting/limiting which functions are available on a television receiver, and a remote commander for making that selection.
- Why the examiner cited it: this is an analogous-art citation — it shows a user-operable control that selects among functions/modes of an electronic device, i.e., the conceptual ancestor of a user button that puts a device into a restrictive "privacy mode" while the device otherwise keeps working.
- §102 assessment — claims potentially anticipated: §102(b) art only for the "actuation mechanism … which allows other parts of said electronic device to operate" element of claims 1, 3. It is in a different field (television), so it is a §103/analogous-art reference at best and does not anticipate any '031 claim.
10. US 6,222,484 — Seiple, "Personal emergency location system"
- Citation: US 6,222,484 B1; filed 1999-06-16; granted 2001-04-24; inventor Ronald L. Seiple. URL:
https://patents.google.com/patent/US6222484 - Description (confidence: medium): A personal emergency location system — a portable, person-carried unit with position determination and emergency signaling to a remote party.
- Why the examiner cited it: portable, person-carried GPS + remote-reporting art, and art on the emergency-vs-privacy tension the '031 specification itself discusses (the "dials 911" passage).
- §102 assessment — claims potentially anticipated: §102(e) only (its grant postdates the '031 filing). Element-level art for the satellite-positioning/portable-device elements of claims 2, 11. No override, no blocker, no jammer, no test function — no whole-claim anticipation.
2. Tier 2 — "Family Cites Families (8)": the references that matter most
These were cited in sibling applications sharing the 2000-10-16 priority date (per the Google Patents family block), not on the '031 front page. I list them because three are more material to "position privacy" than anything on the '031 face. All require file-wrapper verification for the '031 application specifically — if they were never before the '031 examiner, they are "art the examiner did not consider," which cuts in a defendant's favor.
| Patent | Title | Earliest date shown | Issued | Assignee | §102 relevance |
|---|---|---|---|---|---|
| US 6,505,048 B1 | Location privacy feature for wireless mobile stations and method of operation | 1999-12-30 | 2003-01-07 | Samsung Electronics Co., Ltd. | §102(e) — most on-point |
| US 6,675,017 B1 | Location blocking service for wireless networks | 2000-06-30 | 2004-01-06 | Bellsouth Intellectual Property Corp. | §102(e) |
| US 6,687,504 B1 | Method and apparatus for releasing location information of a mobile communications device | 2000-07-28 | 2004-02-03 | Telefonaktiebolaget L.M. Ericsson | §102(e) |
| US 6,311,069 B1 | System and method for alerting a mobile subscriber being positioned | 1999-03-18 | 2001-10-30 | Ericsson Inc. | §102(e), background |
| US 5,894,276 | Communication device with programmable function button and method of operation | 1996-12-23 | 1999-04-13 | Motorola, Inc. | §102(b) — the user-operable button element |
| US 6,121,922 | Tracking system using miniaturized concealable communications module | 1994-10-12 | 2000-09-19 | Veridian Erim International, Inc. | §102(b), background |
| US 5,334,974 | Personal security system | 1992-02-06 | 1994-08-02 | Simms, James R. | §102(b), background |
| US 5,491,745 | Method and apparatus for a dual mode keypad permitting one-touch telephone number dialing | 1991-02-20 | 1996-02-13 | Uniden America Corporation | §102(b) — mode-selection user interface |
Why these matter, grouped by claim bucket:
- Claims 1, 3, 6, 8, 9, 10, 11, 12 (the override/privacy-mode bucket): US 6,505,048 ("Location privacy feature for wireless mobile stations") is a direct, pre-'031-priority disclosure of a privacy mode governing whether a wireless mobile station's location is provided — materially closer than anything on the '031 front page. US 6,675,017 (location blocking) and US 6,687,504 (releasing location information) are the same theme from the network side. If any reference in this portfolio supports a §102 attack on the override control concept, it is US 6,505,048. It still does not supply the passive blocking element or jamming element that claims 1, 3, 7, 8, 10, 11, 12 require.
- Claim 1 / claim 3 ("actuating mechanism," a button): US 5,894,276 (programmable function button on a communication device) and US 5,491,745 (dual-mode keypad) are §102(b) element art for a user-operable actuation mechanism on a phone.
- Dates: US 6,505,048 (1999-12-30), US 6,675,017 (2000-06-30) and US 6,687,504 (2000-07-28) each predate 2000-10-16 in earliest-priority terms and thus can be §102(e) art — but §102(e) runs from the actual U.S. filing date, so confirm each one's non-provisional filing date in Patent Center before asserting it.
3. Claim-by-claim §102 matrix (against all cited art, both tiers)
| Claim | Topic | Any single cited reference that anticipates the claim as issued? | Strongest cited art |
|---|---|---|---|
| 1 | Device + reporting + override + passive blocking element | No — no cited reference discloses a passive blocker attached to the device | §103: US 6,049,718 / US 5,731,785 / US 6,505,048 + US 5,894,276 |
| 2 | Satellite positioning + antenna blocking | No — no cited reference blocks a GPS antenna | US 6,107,960, US 5,222,245 (element only) |
| 3 | Override signal state + jamming element | No — no cited reference discloses jamming for position privacy | US 6,049,718 (switch) + background |
| 4 | Jamming with false information | No | none |
| 5 | Jammer powered from the device | No | none |
| 6 | Privacy detection element + update function | No | US 6,085,090 (privacy framing only) |
| 7 | Method + attach passive reception blocker | No | none |
| 8 | Method: manual actuation + active jamming | No | US 6,049,718 (manual switch) + background |
| 9 | Method: test privacy + update the testing | No | none |
| 10 | Portable telephone + manual override + jamming signal | No | US 6,049,718, US 6,069,570 (architecture) |
| 11 | Cellular method + satellite positioning + jamming | No | US 5,301,368, US 6,107,960 (elements) |
| 12 | Method + attach external blocking device | No | none |
4. Bottom line
No reference cited on the face of US 6,473,031 anticipates any of claims 1–12 as issued. The reason is structural, not accidental: every independent claim is tied to one of two physical mechanisms — a passive blocking element attached to the device (claims 1, 2, 7, 12) or an active jamming element (claims 3, 4, 5, 8, 10, 11) — and the ten cited references disclose neither. The one claim set that hangs entirely on a non-physical concept (privacy self-test + update, claims 6 and 9) is likewise untethered to any cited reference.
The cited art is best characterized as §103 material and element-level §102 art. The four references that carry real weight are:
- US 6,049,718 (Stewart) — the single best §103 springboard: a portable telephone with a user switch selecting whether a location signal is returned, while the phone otherwise operates normally.
- US 5,731,785 (Lemelson) — the closest "inhibiting feature" on a locating device; note the title itself is uncomfortably close to the override concept.
- US 6,085,090 (Motorola) — the express "without revealing its location external to the device" privacy framing.
- US 6,069,570 (ATX/Herring) — the selective activation/deactivation of a GPS receiver that reports to a remote center, i.e., the '031 preamble.
Plus US 5,301,368 (Nissan) for "GPS off while the phone works," and US 5,751,373 (Sony) for a user mode-selecting control.
The most dangerous prior art is not on the '031 front page. US 6,505,048 (Samsung), "Location privacy feature for wireless mobile stations," filed 1999-12-30 — together with US 6,675,017 (BellSouth) and US 6,687,504 (Ericsson) — goes directly to the privacy-override concept and appears only in the family-citation block. If the '031 examiner never saw them, they are unconsidered art and should be the first thing a validity challenge develops.
Date discipline required. In the cited set, only US 6,222,484 is a §102(e)-only reference (granted 2001-04-24, after the '031 filing). In the family set, US 6,505,048 / US 6,675,017 / US 6,687,504 are likewise §102(e)-only and must be dated by their actual U.S. filing dates, not the priority dates shown in the family table.
5. Verification steps I could not complete (stated rather than papered over)
- I did not open the '031 file wrapper (Office actions, examiner's statement of references, IDS) — I worked from the face-of-patent citation list as supplied. The examiner's actual rejections and the art actually applied are not in the excerpt I hold.
- US 5,301,368 (Nissan), US 5,222,245 (Pioneer), US 5,940,753 (Celsat), US 5,751,373 (Sony), and US 6,222,484 (Seiple) were described from title, dates, assignee and citation context at medium confidence; my full-text retrievals of these five did not complete. The descriptions above are flagged accordingly and should be checked against the documents before being quoted in any filing.
- US 6,049,718, US 6,069,570, US 6,085,090, US 5,731,785, and US 6,107,960 were verified directly against retrieved text (Google Patents / uspto.report / EveryPatent), and the quoted claim language (e.g. '718 claim 10's switch, '570 claim 1's "means for de-activating," '090's "without revealing its location") is reproduced as retrieved.
- To close this out: pull the '031 References Cited / IDS and the examiner's Notice of References Cited from Patent Center for 09/690,001, and confirm whether US 6,505,048, US 6,675,017 and US 6,687,504 were ever before the '031 examiner. That single check determines whether the strongest privacy art is "considered" or "unconsidered."
Generated 9/28/2026, 1:01:57 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the analysis in the actual content of the cited references before mapping them onto the claims.
Good grounding on the core references. Let me pin down the Lemelson "inhibiting feature," the active-jamming/cross-interference references, and the concealable-hardware reference.
Obviousness Analysis — US 6,473,031 under 35 U.S.C. § 103
Scope note. This builds on the prior sections (bibliographic data, litigation, PTAB, assignment). I do not repeat them. One date discrepancy carries forward unchanged and matters for any clock you compute: the task heading says April 26, 2026, while the patent-file fetch used here is stamped 2026-09-28. I use neither date substantively below.
Governing law for this patent. '031 has an effective filing date of 2000-10-16, so pre-AIA § 102/§ 103 apply. That matters in one specific way I use below: pre-AIA § 102(e) makes a U.S. patent available as prior art as of its filing date, which is how the Samsung and Bellsouth references qualify despite issuing in 2003 and 2004 respectively.
Prior sections established the decisive posture: all 12 claims live and untested, patent expired 2020-10-16, no estoppel in either direction. So the § 103 question here is not "can we get a stay" — it is "if this were tried on paper today, would the claims fall."
1. Level of ordinary skill in the art (Graham factor 1)
The '031 specification and the cited art define the field narrowly: combined GPS-receiver/cellular-telephone devices, plus the RF-antenna and mode-control engineering that makes them coexist. A PHOSITA in October 2000 would have:
- an undergraduate degree in EE/CS (or equivalent) and 2–3 years in wireless handset design or GPS receiver integration;
- working knowledge of co-located GPS/cellular interference — including that a handset transmitter can jam its own GPS front end (this is the express subject of US 5,301,368 to Nissan);
- familiarity with user-selectable handset mode controls (menus, keypad code entry, hardware buttons with indicator lamps); and
- ordinary skill in RF shielding practice — that enclosing or covering an antenna with metal or RF-absorbing material prevents reception. This is not an inventive insight; it is a design-room commonplace.
The specification supports this: it concedes that "each separate telephone type will have a GPS antenna 300 placed in a specified location" and that "there are relatively few telephone types in common use, usually less than 50 types" — i.e., the applicant himself treats antenna location as a routine, catalogable design fact, not a discovery.
2. Prior-art status of the references (Graham factor 2)
Drawn from the ten examiner-cited references and the eight family-cited references on the patent's own record (https://patents.google.com/patent/US6473031/en):
| Reference | Filing / priority | Status vs. 2000-10-16 | Principal teaching |
|---|---|---|---|
| US 5,301,368 (Nissan) | filed 1990-10-26; issued 1994-04-05 | § 102(b) | GPS receiver unit + radio telephone unit with an operation control unit that sets the GPS receiver circuit inoperative during on-call mode and alternates the two; discusses the telephone transmitter as a "jammer signal" source against the GPS receiver |
| US 5,731,785 (Lemelson) | filed 1994-05-13; issued 1998-03-24 | § 102(b) | GPS-based locating/tracking system "including an inhibiting feature"; coded control signals and PINs used to activate and/or override the inhibiting feature |
| US 6,505,048 B1 (Samsung) | filed 1999-12-30; issued 2003-01-07 | § 102(e) | Wireless mobile station with GPS; location privacy flag user-settable via keypad menu; when set, transmissions go out without lat/long; voice service unaffected; also discloses a network-transmitted code that overrides the privacy feature |
| US 6,675,017 B1 (Bellsouth) | filed 2000-06-30; issued 2004-01-06 | § 102(e) | User-controlled location blocking for a wireless network tracking location/identity for E911; location originates either from a device GPS or a network triangulation system; user signals either device or network; block operates "regardless of any requests for location information from external sources" |
| US 6,687,504 B1 (Ericsson) | filed 2000-07-28 | § 102(e) | Releasing/holding location information of a mobile device |
| US 6,311,069 B1 (Ericsson) | filed 1999-03-18 | § 102(e) | Alerting a mobile subscriber being positioned |
| US 6,107,960 (Snaptrack) | filed 1998-01-20 | § 102(b) | Reducing cross-interference in a combined GPS receiver and communication system |
| US 6,085,090 (Motorola) | filed 1997-10-20 | § 102(b) | Autonomous interrogatable information and position device |
| US 6,049,718 (Stewart) | filed 1997-07-29 | § 102(b) | Telephone system with background location response capability |
| US 6,222,484 B1 (Seiple) | filed 1999-06-16 | § 102(e)/102(b) | Personal emergency location system |
| US 5,221,245 (Pioneer); US 5,940,753 (Celsat); US 6,069,570 (ATX); US 5,751,373 (Sony); US 6,121,922 (Veridian ERIM); US 5,491,745 (Uniden); US 5,334,974 (Simms) | all pre-2000 | § 102(b) | GPS receiver; cellular controller; asset location; multi-mode function selection with indicator/remote commander; miniaturized concealable tracking module; dual-mode keypad; personal security system |
Two status cautions, stated plainly:
- US 2002/0077127 A1 (Motorola, "Method for masking the location of a mobile subscriber") appears in the "Cited By" list on the same page, but its priority date is 2000-12-19 — after '031's filing. It is not prior art to '031 and I do not use it. (It is potentially relevant only to the later-expiring § 120 continuations, which is a separate analysis.)
- I could not open the full texts of US 6,107,960, US 6,121,922, US 6,085,090, or US 5,751,373 in this session; I rely on their titles and on the examiner's citation of them. Any element in a chart below that depends on their contents rather than their titles is flagged.
One point favorable to a challenger: the two references most squarely on the "user-selectable location-privacy mode" concept — US 6,505,048 (Samsung) and US 6,675,017 (Bellsouth) — appear on this page only in the "Family Cites Families" block (cited in later family applications), and are not among the ten references cited on the face of '031. I cannot assert from this record that they were before the '031 examiner. If they were not, there is no "already considered" rebuttal available to the patent owner, which is why '031 issued with an unusual nine independent claims.
3. The three claim families and the single gap in each
Prior analysis mapped the claims into three buckets. § 103 purposes, only one limitation per bucket is genuinely load-bearing:
| Family | Claims | The one limitation the art must supply | Difficulty |
|---|---|---|---|
| A. Passive / external blocking | 1, 2, 7, 12 | A passive blocking element attached to the device that blocks reception | Moderate — the "attached" limitation is the crux |
| B. Active jamming | 3, 4, 5, 8, 10, 11 | A jamming element producing interference, and (cl. 4) false information | Low (cl. 3, 5, 8, 10, 11) / Moderate (cl. 4) |
| C. Privacy self-test + update | 6, 9 | A test for unauthorized reporting plus an update function for the test | Highest — but the applicant's own specification supplies the motivation |
Everything else in these claims — electronic device, GPS position module, reporting to a remote object, override, other functions remaining operable, manual actuation, satellite positioning — is disclosed by US 6,505,048 alone, or by US 6,675,017 alone.
4. Combination-by-combination analysis
4.1 Family B first (it is the cleanest): claims 3, 8, 10, 11 over Nissan + Samsung
Claim 3 recites: device with position module + reporting; an override control with an actuating mechanism producing a signal state that prevents reporting until de-actuation, other parts still operable; and a jamming element producing information that interferes, stopping on de-actuation.
| Claim 3 element | US 5,301,368 (Nissan) | US 6,505,048 (Samsung) |
|---|---|---|
| Electronic device + position module | GPS receiver unit 2 with GPS signal receiver circuit 8 and GPS antenna 10 | Wireless mobile station with global positioning system 260 |
| Reports position remotely | — | Transmits lat/long to the network |
| Override control with actuating mechanism, reporting stopped until de-actuation | Operation control unit 6 with microcomputer 68 and ON/OFF switch 28; OFF state "disables the GPS signal receiver circuit 8 to receive the GPS signal through the GPS antenna 10"; operation is alternating and reversible | Location privacy flag 272 set by the user via keypad 250 / on-screen menu; user can later re-set it to "yes" |
| Other parts of the device still operable | Telephone unit 4 continues to transmit/receive — the point of the reference | Voice service unaffected |
| Jamming element producing interference, ceasing on de-actuation | Yes — the reference's own telephone transmitter produces a "jammer signal" at the GPS antenna (it computes the jammer level P_J against the GPS level and derives that "these signals jam the receiving GPS signal"), and the control unit switches that condition | — |
Why a PHOSITA would combine. Nissan supplies the mechanism and the physical phenomenon: a handset transmitter that jams its own GPS front end, plus a control unit that can force the GPS receiver into and out of operation on command. Samsung supplies the purpose: a user-actuated control that stops location from leaving the handset while leaving the phone usable. Putting the purpose onto the mechanism is not a leap; it is repurposing a switch the reference already has, to a new end that a different reference in the same field already declares desirable. That is the KSR "known technique, obvious to try" case, and it is a same-field, same-problem combination — both references are combined GPS/cellular devices, so analogous-art is not even in dispute.
Claim 11 is the same combination with the limitations spelled out: satellite positioning in mode one (Nissan's GPS satellites), mode two preventing the module from detecting position via satellite (Nissan's switch 28 OFF), and interference with the satellite positioning circuitry via jamming (Nissan's express jammer-signal analysis), while base-station communication continues (Samsung's flag teaches non-interference with voice; Nissan's alternating operation teaches the telephone working while GPS does not).
Claim 8 (method, manual actuation, active jamming) and claim 10 (portable telephone + manual override + jamming element) add only "manual" and "portable telephone," both squarely met by a handset keypad/button — Samsung's keypad 250 and menu, or US 5,751,373's multi-mode function selection with indicator.
Claim 5 (jammer powered from the device) is an obvious design choice. Nissan's operation control unit 6 is already "electrically connected between the GPS signal receiver circuit 8 and the telephone transmitter circuit 38" inside one vehicle installation, drawing vehicle power; locating the jamming element's power source on the host device is a predictable rearrangement with no new result (MPEP 2144.04).
Claim 4 (the jamming information includes false information) is the weakest limitation in the family and I flag it as such. The best support on this record is US 5,731,785 (Lemelson), which discloses a locating system with an inhibiting feature whose activation/override is controlled by coded signals and PINs — establishing that the information reaching a locating system is deliberately controllable — combined with the ordinary knowledge that GPS position is derived from broadcast signals and can therefore be made to yield a false fix. I would not present claim 4 as a strong single-combination case without a dedicated GPS-spoofing reference, which is not in the record before me. Note the irony the record creates: the patent's own specification describes the FIG. 4 jammer as transmitting "broad spectrum noise, which includes information indicative of three satellites" — so the applicant treats false-position injection as an implementation detail of the jammer, which cuts toward obviousness of the added limitation once the jammer itself is obvious.
4.2 Family A: claims 1, 2, 7, 12
Claim 1 differs from the Family B claims in exactly one respect: the override is a "passive blocking element which is attached to a portion of said electronic device to block reception of information by said position detection module." Everything else is met:
- device + position module + reporting to a remote object → Samsung (or Bellsouth, or US 6,049,718 Stewart's background location response);
- override actuated to prevent reporting, other parts still operating → Samsung's location privacy flag, verbatim in function;
- in the alternative, US 6,675,017 (Bellsouth) expressly teaches a user blocking location information regardless of external requests while identity and voice service continue, and expressly contemplates that the location originates from a device-based GPS;
- and US 5,731,785 (Lemelson) supplies the genus — a locating system with an inhibiting feature at the object.
The gap is the passive, physically attached character. US 5,301,368 closes it as a substitution: Nissan already teaches preventing the GPS receiver from receiving through the GPS antenna by switching the antenna path out. Substituting a passive RF-absorbing/reflective element placed over the GPS antenna for an electrical switch in the GPS antenna path is the textbook substitution of one known element for another to obtain the same result — no GPS fix. The result is predictable to the point of triviality: interposing an RF barrier between a satellite and its antenna denies reception. The motivation is also supplied by the applicant's own framing of the benefit — a hardware block is immune to the firmware "back door" the specification worries about, which is a reason to prefer the passive variant, not a reason to think it unexpected.
Claim 2 narrows to a satellite positioning module and an element that blocks the antenna. Nissan discloses precisely a "GPS antenna 10" and a receiver circuit that is disabled "to receive the GPS signal through the GPS antenna 10." The limitation is drawn to exactly the structure Nissan identifies, so claim 2 is, if anything, a stronger obviousness case than claim 1 because it drops the requirement that the blocker be passive — "an element which blocks an antenna … from receiving said information" reads on Nissan's switch 28 directly.
Claims 7 and 12 are the method counterparts and are the hardest in the patent to attack on this record. Claim 7 requires mode two to comprise "attaching a passive reception blocking device to said electronic device"; claim 12 requires the user action to be "attaching an external blocking device to said cellular phone." I have no reference in this record that expressly discloses a clip-on or externally attachable RF shield for a handset GPS antenna. The obviousness case is therefore built from (a) Nissan's teaching that GPS reception is prevented by denying the antenna path, (b) the commonplace RF-shielding knowledge reflected in the field (including the "concealable" housing of US 6,121,922 and the hidden-housing locating unit of US 5,731,785), and (c) the specification's own admission that antenna placement is a known per-model fact. That is a respectable but not overwhelming case; a patent owner would argue that "attaching a passive blocker" was a specific, non-routine physical act, and without a printed reference on the attachable shield, the defense rests largely on the "known technique / obvious to try" branch of KSR. I would rate claims 7 and 12 as the claims most likely to survive among Family A.
4.3 Family C: claims 6 and 9 — the self-test and the update
Claim 6 adds a privacy detection element that tests whether the position module will report unauthorized information when requested, including an update function so the element can adopt different test techniques.
Claim 9 adds, to the two-mode privacy method, testing the phone in privacy mode to determine whether privacy is actually enhanced, and updating the way that testing is carried out.
The § 103 case here is different in kind, and I want to be candid that it is the weakest of the three families — but it is not empty, for three reasons:
- The vulnerability the test checks is disclosed in the art. US 6,505,048 (Samsung) expressly discloses a network-transmitted code that overrides the location privacy flag so the mobile station transmits its location even though the flag is set. The specification's stated concern — that "law-enforcement officials might use this system to keep track of someone without their knowledge" or that a manufacturer's "back door" could be exploited — is therefore a known property of the prior art system, and a PHOSITA who has designed that override has every reason to verify whether it has been triggered. Motivation is not speculative; it is in the reference.
- The "update function" is admitted prior art by the applicant. The specification says the test module's software layer "can be updated via channel 270, e.g., over the Internet," and that this "may be carried out as a subscription service, in a similar way to the operations currently done to update virus definitions." That sentence is an admission that remote, subscription-based updating of a security test's techniques was known practice at the relevant time. Under § 103, applying a known update architecture to a new test is the paradigm of combining familiar elements with predictable results.
- The pre-suit near-simultaneity in the art generally (Samsung 1999-12-30, Bellsouth 2000-06-30, Ericsson 2000-07-28 — all before Harris's 2000-10-16 filing) shows the location-privacy feature was a recognized field-wide problem being solved from multiple independent directions at the same moment.
Weakness to acknowledge: claim 6's "privacy detection element" and claim 9's "testing … to determine whether privacy is actually enhanced" are drafted broadly enough to read on conventional diagnostic/self-test routines, but the record before me does not contain a single reference that performs a privacy audition of a location-reporting device and reports a privacy assessment. I would litigate these claims on a KSR "improvement of a known device using a known technique (the admitted virus-definition update model)" theory plus the Samsung override disclosure, and I would expect to need additional art not cited on this patent to make claims 6 and 9 a clean win. That is a research gap, not a conclusion that the claims are valid.
5. Motivation to combine — the four rationales I would actually brief
- Known problem in the field, solved from the same direction. US 6,675,017's background recites the FCC E911 Phase I/II mandate forcing carriers to track and transmit subscriber location; Samsung's background recites the user-privacy reaction to that same mandate. Both were filed before '031. The "problem" '031 states in its Background was thus already the articulated problem of at least two unrelated major manufacturers, one of which (Samsung) patented the solution four months earlier. KSR step: the improvement is the predictable next step, not an unexpected one.
- Substitution of a known element to achieve the same result (claims 1/2 vs. Nissan's switch), and location of a power supply with the host device (claim 5).
- Teaching/suggestion/motivation within the references themselves. Nissan's own background supplies the S/T/M for controlling the interaction between the telephone transmitter and the GPS receiver — it teaches that the transmitter jams the receiver and that the receiver can be forced inoperative. That is the exact technical predicate of the "jamming element" limitation. No external motivation is needed for Family B.
- Design incentive supplied by the patent's own specification. The applicant states the reason a user wants a hardware block: firmware "back doors" may be exploited. That rationale is a design-choice rationale available to any PHOSITA once the privacy control itself is known — and it is therefore evidence of obviousness of the passive variant, not of nonobviousness.
Teaching away — and why it does not save the claims. The best teaching-away argument is that Nissan's entire purpose is to keep GPS working while the phone operates, i.e., the reference manages and avoids jamming rather than desiring it. That argument is weak after KSR: a reference teaches away only by criticizing, discrediting, or discouraging the claimed approach. Nissan neither disparages deliberate denial of GPS reception nor suggests it would fail; it simply has a different objective, and the same control unit it discloses is the vehicle for the different objective. A contrary-obviousness argument built on "different purpose" fails where the structure and the switch are the same and the art is in the same field.
Claims 1/7/12 and the "attached" limitation. The genuinely defensible positions for a patent owner are (a) that a passive, physically attached blocker was not shown in a printed reference, and (b) that Nissan's switch is internal and electrical, so its substitution by an external shield is not a "substitution of equivalents" but a change in kind. I do not consider (b) persuasive — the claimed result (denial of reception at the antenna) is identical and the mechanism is the simplest known way to achieve it — but a court construing "attached to" under Phillips (available because the patent is expired) would likely require actual physical attachment, which is where the Family A fight would be fought.
6. Objective evidence (Graham factor 4)
No secondary-considerations evidence appears in the record, and two objective indicia run against the patent owner:
- Simultaneous independent development. At least three unrelated entities addressed location privacy in wireless handsets within ten months before '031's filing — Samsung (1999-12-30), Bellsouth (2000-06-30), Ericsson (2000-07-28) — plus Ericsson's earlier US 6,311,069 (1999-03-18). Simultaneous independent invention is a recognized objective indicator that a solution was the natural next step.
- Admissions in the specification. The virus-definition update analogy and the cataloging of antenna placements are the applicant's own concessions of what the art already did.
I found no evidence of industry praise, licensing-due-to-merits, copying, or a long-felt-but-unsolved need. The absence of any such evidence in the record is not fatal to the patent owner, but it means Family A's survival would rest entirely on the "attached" narrowing, not on objective indicia.
7. Ranked bottom line
| Rank | Claims | Strongest combination | Confidence | Residual risk to the defense |
|---|---|---|---|---|
| 1 | 3, 5, 8, 10, 11 | US 5,301,368 (jammer signal; switchable inoperative GPS receiver) + US 6,505,048 / US 6,675,017 (user privacy mode) | High | Low — Nissan is the jamming element |
| 2 | 2 | US 5,301,368 alone + US 6,505,048 for the reporting/override context | High | Low |
| 3 | 1 | Same + substitution of passive shield for Nissan's switch | Moderate-High | "Attached … passive" construction |
| 4 | 9 | Samsung's override disclosure (motivation to test) + admitted virus-definition update model | Moderate-Low | No reference performs a privacy audition |
| 5 | 7, 12 | US 5,301,368 + RF-shielding common knowledge + spec's antenna-catalog admission | Low-Moderate | No reference shows an attachable external shield |
| 6 | 4 | US 5,731,785 (coded/PIN-controlled inhibit) + known GPS spoofing knowledge | Low | No false-information reference in the record |
| 7 | 6 | Same as 9 | Low | Same gap as 9 |
Practical read. Claims 3, 5, 8, 10, 11 (and secondarily 2) are vulnerable now on art already on this patent's face plus one family-cited reference. Claims 1 and 9 are vulnerable with a modest evidentiary addition. Claims 4, 6, 7, 12 need prior art not in this record before I would call them obvious — which is a statement about my search coverage today, not about their ultimate validity.
8. Verification gaps I will not paper over
- Four references unopened. US 6,107,960, US 6,121,922, US 6,085,090, and US 5,751,373 were retrieved by title only. US 6,107,960 (Snaptrack, cross-interference in a combined GPS/communication system) and US 6,121,922 (a concealable tracking module) are both likely to strengthen the reach of the Family A and Family B charts and should be read in full — the "concealable" framing in particular may bear directly on the "attached" limitation.
- Prosecution history not examined. I do not know what the '031 examiner actually considered, or what the applicant argued. The most on-point privacy references appear only in the family citation block. The '031 file wrapper (Patent Center, application 09/690,001) should be read before any argument that the art was "not considered."
- § 102(e) dates. US 6,505,048 shows a priority of 1999-12-30 on one source and 1999-12-29 on another; US 6,675,017 shows 2000-06-30 and 2000-06-29. Both are safely before 2000-10-16, so the discrepancy does not change the analysis, but the face of each patent should be confirmed.
- Date conflict carried forward. The task heading says April 26, 2026; the patent-file fetch is stamped 2026-09-28. Pin this down before computing any § 286 window — it does not affect the § 103 analysis but it does affect damages math in any demand you are answering.
Generated 9/28/2026, 1:02:36 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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