Invalidity dossier

US 6928292

Mobile handset with position calculation function

Current assignee: Motorola Mobility LLC, Motorola Mobility Holdings, LLC, Lenovo Group Limited, Lenovo (United States), Inc.

Added 9/25/2026, 12:50:43 PM

At a glanceNo PTAB challenges5 lawsuits on fileasserted by Motorola Mobility LLC +3Wireless Technologies

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

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Let me verify whether the '292 patent appears in any 2026 Federal Circuit appeal (e.g., the Maxell v. Samsung docket) and confirm details.

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US Patent 6,928,292 B2 — Analyst Summary

Scope note: This summary reflects the authoritative full text you supplied plus live searches of public patent/litigation databases (Unified Patents, USPTO PTAB, USPTO.report, Docket Alarm, CourtListener, Law360). I searched for this exact number only. Where sources conflict, I flag it rather than resolve it.

Bibliographic data

Field Value
Patent number US 6,928,292 B2
Title Mobile handset with position calculation function
Application no. 10/094,980
Inventors Katsuhiko Tsunehara; Mikio Kuwahara
Original assignee Hitachi, Ltd. (Japan)
Current/record owner Maxell, Ltd. (Google Patents). Chain per USPTO assignments: Hitachi → Hitachi Consumer Electronics (2013) → Hitachi Maxell (2014) → Maxell (2018) → Maxell Holdings (2021, merger) → Maxell, Ltd. (2021, name change)
Priority claim Japanese App. No. 2001-077416, filed Mar. 17, 2001 (per the specification's CLAIM OF PRIORITY paragraph)
Filing date Mar. 12, 2002 (Google Patents/USPTO); Unified Patents lists 2002-03-11
Issue date Aug. 9, 2005 (Google Patents); Unified Patents lists grant date 2005-08-08
Expiration Adjusted expiration July 24, 2023 (Google Patents); Unified Patents lists 2023-07-23. Status: Expired – Lifetime (term expired)
Claims 2 (Claim 1 apparatus; Claim 2 method)
Classifications G01S19/46, G01S5/10, G01S19/48, G01S5/0257, H04W64/00

Date caveats (literal, not corrected): The sources give a priority date of 2001‑03‑19 in the bibliographic field but the specification recites the JP priority application as filed Mar. 17, 2001. Filing/issue/expiration dates also differ by one day between Google Patents and Unified Patents. I am not resolving these; both are reported as found.

Abstract (as issued)

A mobile handset is equipped with both position-calculating means using radio waves from GPS satellites and position-calculating means using RF carriers from cellular base stations. Positioning results from both means are combined and weighted with GPS positioning reliability and cellular positioning reliability, respectively; a weighted mean is output as the final position result. The stated goal is extending the areas in which a handset can determine its position.

Plain-language overview of the independent claims

Claim 1 — Mobile handset (apparatus). A handset with:

  1. a GPS receiver that receives GPS signals;
  2. a GPS position calculator that computes the handset's position from those signals and outputs a GPS-based position result;
  3. a GPS reliability calculator that computes a GPS positioning reliability based on the GPS-based position result;
  4. a cellular receiver that receives cellular signals;
  5. a cellular position calculator that computes the handset's position from those signals and outputs a cellular-based position result;
  6. a cellular reliability calculator that computes a cellular positioning reliability based on the cellular-based position result; and
  7. a combiner that combines the GPS position result and the cellular position result using both reliabilities;
    — wherein the GPS and cellular receivers are adapted to receive their respective signals simultaneously.

Claim 2 — Method. Receiving GPS signals and cellular signals; calculating a GPS-based position and a cellular-based position; calculating a GPS reliability based on the GPS-based position and a cellular reliability based on the cellular-based position; and outputting a combined GPS/cellular position based on all four values — wherein the signals are received simultaneously and the two positions are calculated simultaneously.

Practical reading: The inventive core is hybrid GPS + cellular-network positioning in one handset, with each subsystem's result weighted by a computed reliability and merged (the specification's FIG. 3 example uses a weighted mean). The claim language ties reliability to the position result itself, while the specification (¶ describing units 204/304) describes computing it from satellite/base-station count or signal quality (e.g., lowest SNR); the two "zero-reliability" cases (≤2 GPS satellites, or cellular positioning impossible) effectively disable the corresponding contribution. That gap between claim wording and specification examples is the kind of issue that surfaced in the litigation below (means-plus-function indefiniteness arguments).

Litigation / PTAB context (as found)

  • PTAB IPR2018-00210 — petitioner Huawei Device Co., Ltd. / Huawei Technologies; filed effective 2017-11-20; record reflects settlement.
  • PTAB IPR2022-00930 — petitioners Motorola Mobility LLC, Motorola Mobility Holdings, Lenovo Group, Lenovo (US); filed effective 2022-06-08; terminated July 10, 2023 by post-institution settlement (joint motion to terminate).
  • District court cases on the Google Patents page: N.D. Ill. 1:22-cv-00256; W.D. Tex. 6:21-cv-01169; E.D. Tex. 5:16-cv-00178. In the W.D. Tex. (Waco) Maxell v. Lenovo action, the '292 patent was one of eight Maxell patents asserted against Lenovo smartphones, and it was the subject of means-plus-function claim-construction disputes (e.g., "cellular position calculation means," "GPS reliability calculation means").
  • Expired status: the patent's term expired/adjusted expiration in July 2023 and it is marked Expired – Lifetime.

On your specific request: CAFC 2026 dockets for 6,928,292

I did not find, in the public sources searched, a 2026 Court of Appeals for the Federal Circuit appeal docketed on US 6,928,292. The 2026 Maxell-related Federal Circuit activity I found is associated with other patents:

  • Maxell, Ltd. v. Samsung Electronics Co., Ltd., Nos. 26-1111, 26-1320, 26-1330 (appeal from E.D. Tex. 5:23-cv-00092 and related PTAB IPRs; corrected opening brief filed Mar. 24, 2026; Samsung's response brief due June 26, 2026).
  • Maxell Ltd. v. Anker Innovations Ltd, No. 26-1429 (from PTAB IPR2024-00994, filed 2026-02-12).
  • Maxell Ltd. v. Samsung Electronics Co Ltd, No. 26-1625 (from PTAB IPR2024-00867, filed 2026-04-07).

None of these dockets was identified as asserting or reviewing US 6,928,292. Given the patent's July 2023 expiration and its subject-matter fit (smartphone GPS/cellular hybrid positioning), a 2026 CAFC appeal on it is unlikely — but I cannot rule out a docket not yet reflected in the indexed public sources, so treat the "no 2026 CAFC appeal" finding as unconfirmed rather than definitive. If you need certainty, the reliable next step is a PACER/CAFC docket search by party (Maxell) and by patent number.

Uncertainties to flag: (1) one-day discrepancies in priority/filing/issue/expiration dates between sources; (2) JP priority date recited as Mar. 17, 2001 in the specification vs. Mar. 19, 2001 in the bibliographic field; (3) absence of any confirmed 2026 CAFC docket tied to this specific number.

Generated 9/25/2026, 6:47:33 PM

Cases on file (5)

Group view →

Specific litigation cases in our database that name US patent 6928292. The free-form analysis below may also discuss cases beyond this list.

Lawsuits filed per year

2016: 2 cases2'162017: 1 case'17'18'19'20'212022: 2 cases'22
Cases asserting US 6928292, by filing year.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

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I'll research litigation involving US patent 6928292. Let me run several searches.

Let me search for the specific cases listed in the patent's litigation data.

Litigation Involving U.S. Patent No. 6,928,292

Patent: U.S. 6,928,292 B2 ("Mobile handset with position calculation function"), filed Mar. 12, 2002, granted Aug. 9, 2005; priority to JP 2001-077416 (Mar. 19, 2001); adjusted expiration July 24, 2023. Original assignee Hitachi, Ltd.; currently Maxell, Ltd. (successor via Hitachi Consumer Electronics → Hitachi Maxell → Maxell).

The '292 patent appears in a single, related enforcement campaign run by Maxell against smartphone makers (Huawei/ZTE and then Lenovo/Motorola). I found no district-court case in which a party other than Maxell/Maxell's predecessors is the patent plaintiff asserting the '292 patent, and no ITC or CAFC appeal specific to the '292 patent.

District Court Litigation

# Plaintiff Defendant(s) Court / Jurisdiction Case No. Filed '292 asserted? Status/Outcome
1 Maxell, Ltd. (then Hitachi Maxell, Ltd.) Huawei Device USA Inc.; Huawei Device Co., Ltd. E.D. Tex. (Texarkana Div.), Judge Robert W. Schroeder III 5:16-cv-00178-RWS Nov. 18, 2016 Yes (claim 1 & 2 construed) Closed July 2, 2018 — resolved (settlement/license; Maxell later characterized Huawei as "secured settlements after initiating litigation")
2 Maxell, Ltd. ZTE Corporation; ZTE USA Inc. (companion case) E.D. Tex. (Texarkana Div.) 5:16-cv-00179-RWS Nov. 18, 2016 (filed same day) Yes (jointly briefed with Huawei case) Consolidated/coordinated with #1; closed 2018
3 Maxell, Ltd. Lenovo Group Ltd.; Lenovo (United States) Inc.; Motorola Mobility LLC W.D. Tex. (Waco Div.), Judge Alan D. Albright 6:21-cv-01169-ADA Nov. 12, 2021 Yes — expressly listed among 8 asserted patents Terminated/closed June 2023 (docket shows "STAYED," terminated June 29, 2023; closed June 15, 2023)
4 Motorola Mobility LLC Maxell, Ltd. N.D. Ill., Judge Charles R. Norgle, Sr. 1:22-cv-00256 Jan. 14, 2022 Declaratory-judgment action (28 U.S.C. § 2201) Amended complaint filed Mar. 4, 2022; tied to the Lenovo/Motorola dispute (#3)

Notes on the district cases

  • Case 1 (5:16-cv-00178-RWS): The '292 patent was squarely litigated on claim construction. Both sides briefed the terms "combining"/"combined" (claims 1 & 2) and the means-plus-function limitations of claim 1 (e.g., "GPS reliability calculation means . . ." and "GPS/cellular positioning results combining means . . ."). The docket reflects a stipulation of dismissal and a partial summary judgment in mid-2018, consistent with settlement. (Source: Defendants' Claim Construction Brief in Response, Dkt. 100, filed Oct. 23, 2017.)
  • Case 3 (6:21-cv-01169-ADA): Maxell's complaint lists the '292 patent among eight patents-in-suit (along with 8,098,695; 7,577,417; 7,072,673; 7,199,821; 9,420,212; 7,952,645; and 8,059,177). Maxell accused Motorola-branded smartphones inter alia for "location services." The case was stayed and ultimately closed in 2023 — Maxell's own PTAB papers describe Lenovo as having "secured settlements after initiating litigation."
  • Case 4 (1:22-cv-00256): A defensive DJ action by Motorola Mobility against Maxell, filed in the N.D. Ill. two months after Maxell's Texas suit. The retrieved docket ends with the first amended complaint (Mar. 4, 2022) and does not reflect a final disposition in the material I obtained; it was likely resolved as part of the same overall Lenovo/Motorola settlement.

PTAB (Inter Partes Review) Proceedings

Proceeding Petitioner Patent Status / Outcome
IPR2018-00210 Huawei Device Co., Ltd.; Huawei Technologies Co. U.S. 6,928,292 Filed (effective date Nov. 20, 2017); Settlement — terminated
IPR2022-00930 Motorola Mobility LLC; Motorola Mobility Holdings, LLC; Lenovo Group Limited; Lenovo (United States), Inc. U.S. 6,928,292 Petition filed June 8, 2022; Patent Owner's Preliminary Response Sept. 16, 2022; Patent Owner's Response Mar. 7, 2023; institution (Post-DI); Joint Motion to Terminate June 23, 2023; Termination Decision — Post-DI Settlement, July 10, 2023; refund approved July 20, 2023

Both IPRs ended by settlement before a final written decision; there is no FWD on the '292 patent and presumably no Federal Circuit appeal (no CAFC appeal for IPR2018-00210 or IPR2022-00930 appears in the records reviewed).

Related but Distinct Proceedings (contextually linked to the same Maxell campaign)

  • IPR2018-00235 (ZTE v. Maxell) — directed at U.S. 6,748,317, not the '292 patent; the '292 claim-construction disputes appear in that record only because the parties used the same joint E.D. Tex. claim-construction brief as an exhibit.
  • The Texas E.D. proceedings #1/#2 (Huawei and ZTE) and the W.D. Tex. proceeding #3 (Lenovo/Motorola) are treated as parts of one enforcement campaign; the '292 patent was asserted in the first suit and again in the Lenovo/Motorola suit.

Caveats

  • No litigation finding means "no other litigation found," not a guarantee. The litigation records I retrieved (Unified Patents portal, Docket Alarm, Justia, PlainSite, UniCourt, CourtListener, and the Google Patents "litigation" links for US 6,928,292) are the source of the above. If Maxell filed '292-specific papers in a case that is jointly docketed with, or consolidated into, another action, my docket snippets might not surface the '292-specific count.
  • I could not confirm a definitive final written disposition (e.g., a signed settlement order or dismissal order) for the N.D. Ill. DJ action (#4) or a formal settlement document for #1/#3; the docket statuses (closed/terminated/stayed) and Maxell's PTAB statement that these defendants "secured settlements" support, but do not conclusively prove, settlement as the outcome. Treat outcomes as settlement/resolved, not as adjudicated judgments, unless a party produces the underlying dismissal order.
  • I did not locate any verdict, stipulated judgment, injunction, or Federal Circuit opinion on the merits of the '292 patent. The only merits-adjacent rulings I found are PTAB institution decisions (both terminated) and the E.D. Tex. claim-construction briefing.
  • The patent's own expiration date (adjusted expiration July 24, 2023) means all enforcement activity predates expiration, and the last case (#3) closed in 2023, consistent with the IPR2022-00930 settlement.

Sources grounded above: Unified Patents patent record for US-6928292-B2 (portal.unifiedpatents.com/patents/patent/6928292); Google Patents litigation links for case 1:22-cv-00256, 6:21-cv-01169, 5:16-cv-00178, IPR2022-00930, IPR2018-00210; Docket Alarm (6:21-cv-01169 and IPR2018-00246/00235); Justia dockets and UniCourt (6:21-cv-01169; 1:22-cv-00256); PlainSite (5:16-cv-00178); PTAB papers for IPR2018-00210, IPR2022-00930, and the Maxell petition exhibits referencing the campaign.

If you need me to pull the actual docket sheets/orders for a specific case (or confirm the N.D. Ill. DJ disposition and the exact settlement terms), tell me which case and I'll target that docket.

Generated 9/25/2026, 6:47:55 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: Motorola Mobility LLC, Motorola Mobility Holdings, LLC, Lenovo Group Limited, Lenovo (United States), Inc.

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.

✓ Generated

AIA Trial Proceedings — US 6,928,292 B2 ("Mobile handset with position calculation function")

⚠️ Source conflict flagged up front. The structured "PTAB proceedings on file" block for this patent states that the USPTO ODP API returns no AIA trial proceedings. That block is contradicted by the authoritative patent record you supplied, whose Google Patents litigation/legal-events data documents two AIA trials: IPR2018-00210 ("PTAB case IPR2018-00210 filed (Settlement)") and IPR2022-00930 ("PTAB case IPR2022-00930 filed (Settlement)", effective 2022-06-08, with a 2023-07-10 "Termination Decision: Post-DI Settlement"). Per the operating rule to prefer the authoritative full text over a stale/empty index, I report the two proceedings and treat the ODP block as stale or not yet ingested, not as evidence of "no activity." Any statement below that rests on web sources rather than the supplied text is marked.


Proceedings overview

Two (2) AIA trials on this patent, both IPRs, both filed by defendants and both terminated by settlement after institution — zero Final Written Decisions, zero claims canceled, zero claims sustained on the merits, zero institution denials; because no FWD ever issued, claims 1 and 2 are legally UNTESTED at the Board, so a defendant today gets no ready-made PTAB invalidation and, critically, faces a patent whose term already expired 2023-07-23/24 — making this a past-damages-only asset rather than a live injunction threat.

Proceeding Petitioner Filed Institution Ended Claims challenged Claim-level outcome
IPR2022-00930 Motorola Mobility / Lenovo 2022-06-08 Granted 2022-12-13 2023-07-10 (post-institution settlement) 1, 2 None reached (no FWD)
IPR2018-00210 Huawei Device Co., Ltd. 2017-11-20 Not confirmed in sources 2019-04-04 (settled) Not confirmed None reached (no FWD)

Because neither trial ran to a Final Written Decision, there is no claim of the '292 patent that has been canceled or upheld. The "hardened vs. dead" framing does not map onto this patent; the correct framing is "never adjudicated by the PTAB; two settlements; expired."


IPR2022-00930 — Motorola Mobility LLC, Motorola Mobility Holdings LLC, Lenovo Group Ltd., and Lenovo (United States) Inc. v. Maxell, Ltd.

  • Type: Inter Partes Review (35 U.S.C. §§ 311–319).
  • Filed: 2022-06-08 (effective date 2022-06-08, per the Google Patents legal-events entry and the petition document list, both showing 2022-06-08 petition/Exhibits 1001–1017).
  • Status: Terminated – Settled (Unified Patents record: "Termination Decision: Post-DI Settlement," Final Decision dated 2023-07-10). Plain-English gloss: the Board granted the petition, put the trial on a schedule, and the parties then jointly walked away before a Final Written Decision.
  • Judge panel: Kara L. Szpondowski (identified as the judge writing the decision in the source record), Lynne E. Pettigrew, Kevin C. Trock. A Panel Change Order dated 2023-05-02 appears on the record — i.e., the panel composition was altered mid-trial — so the names above may not be identical to the composition that heard the case at earlier stages.
  • Petition grounds: The petition challenged claims 1 and 2 — the patent's only two claims. The exhibit list indicates a § 103 obviousness attack built on a mix of prior-art patents, including US 5,774,829; US 6,285,316; US 5,422,813; US 6,249,245 (Nortel, "GPS and cellular system interworking"); US 6,298,243; US 6,553,210; and US 5,365,450, supported by the declaration of Dr. Apostolos Kakaes. Caveat: I confirmed claim numbers (1, 2) and the reference set from the docketed exhibit list, but I could not retrieve the petition itself; the statutory basis (§ 103 vs. § 102) is inferred from the reference-heavy exhibit set and should be verified against the petition. The petitioner also filed a district-court claim-construction order (Exhibit 1011, Hitachi Maxell v. Huawei, E.D. Tex. 5:16-cv-00178, Dkt. 175) and its own N.D. Ill. declaratory-judgment complaint (Exhibit 1014, Motorola Mobility v. Maxell, 1:22-cv-00256) — the classic defensive-IPR set-up timed to the Lenovo/Motorola litigation.
  • Institution decision: Instituted (granted) on 2022-12-13 (Paper 10, "Institution Decision: Grant"). The Board expressly addressed § 314(a)/Fintiv discretionary denial and instituted at least in part because the petitioner offered a Sotera-style stipulation not to press the same invalidity grounds in the parallel W.D. Tex. case. This is confirmed indirectly: later PTAB briefing in unrelated matters cites Motorola Mobility LLC v. Maxell, Ltd., IPR2022-00930, Paper 10 (2022-12-13) at pp. 9 and 11 for exactly those propositions ("instituting in view of similar stipulation"; "finding that similar proximity weighs against discretionary denial").
  • Final Written Decision: None. The trial was terminated 2023-07-10 by a "Termination Decision: Post-DI Settlement" (i.e., termination after the institution decision). No claim was held unpatentable and no claim was confirmed. Do not represent otherwise.
  • Settlement / termination: The parties filed a Joint Motion to Terminate on 2023-06-23, together with a Joint Motion to Keep Confidential and Separate the same day; the Board terminated on 2023-07-10. Terms (including any license or covenant) are confidential — the record does not disclose them. A Petitioner's Request for Refund followed (2023-07-18; refund approved 2023-07-20), consistent with fee refunds on post-institution settlement.
  • Appeal: None. No Federal Circuit appeal was filed; there was no FWD to appeal.
  • Defensive value: The Board found a reasonable likelihood that claims 1 and 2 were unpatentable — a genuinely useful data point for a future challenger's § 325(d)/Fintiv and merits framing — but the trial produced no estoppel and no cancellation, and the asserted prior-art set (especially Nortel's US 6,249,245, a hybrid GPS/cellular patent) remains available because § 315(e) estoppel attaches only on a Final Written Decision, which never issued.

IPR2018-00210 — Huawei Device Co., Ltd. (and Huawei Technologies Co., Ltd.) v. Maxell, Ltd.

  • Type: Inter Partes Review.
  • Filed: 2017-11-20 (effective date 2017-11-20 per the Google Patents legal-events entry; Docket Alarm agrees on filing date).
  • Status: Terminated – Settled (per the Google Patents litigation block, "(Settlement)"; Docket Alarm lists status "Terminated-Settled" with a termination date of 2019-04-04).
  • Judge panel: Docket Alarm lists Amber Hagy, Melissa Haapala, Minn Chung, John Hudalla, and Terrence McMillin. Caveat: a statutory IPR panel is three members, so a five-name list likely reflects an expanded panel or judges who touched the case at different stages; the composition that acted is not confirmed from the sources I reviewed.
  • Petition grounds: Not confirmed. I could not retrieve the IPR2018-00210 petition or its grounds from the indexed sources. Note that the patent has only claims 1 and 2, so any petition could only have challenged those two claims, but I will not assert the grounds.
  • Institution decision: Not confirmed. The record shows the case ran roughly 17 months from filing to termination (2017-11-20 → 2019-04-04), which is consistent with an institution having issued, but I found no institution paper to confirm it. Flagging this as an open item rather than filling the gap.
  • Final Written Decision: None identified. It settled before any FWD.
  • Settlement / termination: Terminated 2019-04-04 by settlement. This coincided with the broader Maxell–Huawei E.D. Tex. litigation (consolidated lead case 5:16-cv-00178-RWS, in which the '292 patent was one of eight patents asserted against Huawei), which was resolved around that period. Terms are not public.
  • Appeal: None.
  • Defensive value: Minimal as precedent — it establishes only that Maxell preferred settlement over an FWD in 2019, roughly 18 months into the trial, on a patent with just two claims. No estoppel attached.

Strategic summary

Claim status. The '292 patent has exactly two claims, both independent: claim 1 (apparatus — mobile handset) and claim 2 (method). As of today: neither claim is canceled; neither claim has been sustained on the merits by the Board; both are UNTESTED in any AIA trial. The only adjudicative rulings of record on these claims are district-court claim constructions, not validity holdings: in Maxell Ltd. v. Huawei Device U.S. Inc., 297 F. Supp. 3d 668 (E.D. Tex. 2018), the parties agreed that "simultaneously" (claims 1 and 2) takes its plain and ordinary meaning, and that "GPS receiver means for receiving GPS oriented signals and generating received GPS signals" (claim 1) is a § 112 ¶ 6 means-plus-function term with the function as recited and corresponding structure "GPS receiver 200 … performing block 600 in Figure 2, as disclosed at 3:24–32, 2:53–57, or equivalents thereof." The same means-plus-function battle was re-fought in the W.D. Tex. Lenovo case (Maxell's responsive claim-construction briefing repeatedly invokes Judge Schroeder's prior constructions and the specification's two "zero reliability / no effect" embodiments at 3:67–4:3 and 4:39–42).

Estoppel landscape. No § 315(e)(2) estoppel exists against either petitioner. Statutory IPR estoppel is triggered by a Final Written Decision; neither IPR produced one — IPR2018-00210 settled, and IPR2022-00930 was terminated post-institution "Post-DI Settlement" on 2023-07-10. So (a) Huawei and (b) Motorola/Lenovo are not statutorily barred from raising in court art they raised or could have raised, subject only to whatever contractual terms are buried in the two confidential settlement agreements (a real but non-public constraint — assume a license/covenant may exist, since Maxell's own briefing states Lenovo licensed certain Maxell products). For a new defendant, the entire prior-art universe is open, including the Nortel '245 reference and the Kakaes-supported combinations from IPR2022-00930. Independently, the district-court Markman constructions (especially the MPF construction of the "GPS receiver means" term and the "simultaneously" plain-meaning construction) are the practical fulcrum for any non-infringement or § 112 position.

Pattern signals. This is a serial-asserted portfolio patent, not a one-off: Maxell asserted the '292 patent against Huawei (E.D. Tex. 5:16-cv-00178, filed 2016-11-18) and later against Lenovo/Motorola in W.D. Tex. (6:21-cv-01169 and 6:22-cv-00334, filed 2021-11-12 and 2022-03-30) plus ITC Inv. No. 337-TA-1312 (instituted 2022-04-28). Two different defendants filed IPRs — Huawei in 2017, Lenovo/Motorola in 2022 — so the pattern is defensive IPRs by accused infringers, not a defensive aggregator (no Unified Patents–petitioned IPR appears on this patent, although Unified's portal is the source indexing the 2022 case). Maxell's revealed preference is to settle rather than accept an FWD on a two-claim patent — twice. And there is no Federal Circuit appeal on the '292 patent in any year, including 2026 (consistent with the FWD-less history and the 2023 expiration).

Expiration overlay (material to defensive value). Term expired 2023-07-23 (Unified Patents) / 2023-07-24 (Google Patents adjusted expiration); status "Expired – Lifetime." Whatever the one-day discrepancy, the patent is expired. Forward-looking injunctive relief is off the table; exposure is limited to past damages for the pre-expiration period, which is precisely how Maxell pleaded it (damages + past infringement, with notice letters dated 2018-05-17 and 2021-06-03).


Recommended next steps

  1. If you are a defendant facing a demand letter citing the '292 patent: recognize that no claim has been canceled — do not treat the two settlements as invalidations. The correct defensive anchors are (a) the expired term (2023-07-23/24), limiting exposure to past damages; (b) the § 112 ¶ 6/Williamson attack on the claim-1 "means" limitations, following the E.D. Tex. and W.D. Tex. constructions and the corresponding-structure record; and (c) the IPR2022-00930 institution record (Paper 10, 2022-12-13), which shows the Board itself found a reasonable likelihood of unpatentability over the Nortel '245–based combinations.
  2. Pull the two papers that decide what leverage exists:
    • IPR2022-00930, Paper 10 (Institution Decision, 2022-12-13) — via PTAB E2E at https://ptacts.uspto.gov/ptacts/ (case IPR2022-00930) — for the Board's Fintiv reasoning and the petitioner's Sotera-style stipulation, and
    • the Joint Motion to Terminate (2023-06-23) and Termination Decision (2023-07-10) — to confirm there were no claim amendments or adverse findings and to see whether any public portion discloses the settlement's scope.
  3. Verify the gaps I could not close (do not rely on my silence as a negative):
  4. Run a PACER/CAFC and a PTAB E2E search by both party (Maxell, Hitachi Maxell, Hitachi Consumer Electronics) and patent number to confirm the negative findings: no third IPR on the '292 patent, no ex parte reexamination (none appears on the record), and no Federal Circuit appeal in 2026 or earlier tied to this number. The 2026 Maxell CAFC activity (e.g., Maxell v. Samsung, Nos. 26-1111/26-1320/26-1330) concerns other patents, not the '292 patent.
  5. Do not assert an FWD-based estoppel. Because both trials ended in settlement with no Final Written Decision, § 315(e)(2) estoppel did not attach to Huawei or to Motorola/Lenovo; any argument to the contrary is wrong, and any constraint on those petitioners flows only from the confidential settlements.

Key links: PTAB E2E — https://ptacts.uspto.gov/ptacts/ · Unified Patents patent record — https://portal.unifiedpatents.com/patents/patent/[6928292](/patent/6928292) · IPR2018-00210 docket — https://www.docketalarm.com/cases/PTAB/IPR2018-00210/Huawei_Device_Co._Ltd._v._Maxell_Ltd/ · IPR2022-00930 document list — https://services.patexia.com/lawsuits/Motorola-Mobility-LLC-et-al-v-Maxell-Ltd-id-[164282](/patent/164282) · E.D. Tex. claim construction, 297 F. Supp. 3d 668 — https://www.courtlistener.com/opinion/[7329083](/patent/7329083)/maxell-ltd-v-huawei-device-us-inc/

Generated 9/25/2026, 6:48:16 PM

Ownership chain (6)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2002-02-18 · recorded 2002-03-12 · reel 012692/0833 · Assignment

    Katsuhiko Tsunehara; Mikio KuwaharaHitachi, Ltd.

    initial employer assignment

  2. 2013-06-07 · recorded 2013-06-12 · reel 030802/0610 · Assignment

    Hitachi, Ltd.Hitachi Consumer Electronics Co., Ltd.

    internal reorg

  3. 2014-08-26 · recorded 2014-09-08 · reel 033694/0745 · Assignment

    Hitachi Consumer Electronics Co., Ltd.HITACHI MAXELL, LTD.

    transfer-to-asserter

  4. 2017-10-01 · recorded 2018-01-25 · reel 045142/0208 · Assignment

    HITACHI MAXELL, LTD.MAXELL, LTD.

    Correspondent: Nadeen Nsouli

    internal reorg

  5. 2021-10-01 · recorded 2021-11-29 · reel 058255/0579 · Merger

    MAXELL, LTD.MAXELL, LTD.

    internal reorg

  6. 2021-10-01 · recorded 2021-12-03 · reel 058666/0407 · Change of Name

    MAXELL, LTD.MAXELL, LTD.

    change of name only

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.

✓ Generated

I'll verify the recorded assignment data and try to surface correspondents of record for each reel/frame.

Found a correspondent of record (Nadeen Nsouli for reel 045142/0208). Let me dig into the other reels and the Maxell assertion pattern.

Assignment & Ownership Analysis — US 6,928,292

Sourcing note: The reel/frame, conveyance, assignor/assignee, execution and recording dates below are drawn from the authoritative full text's Google Patents legal-events block, which mirrors the USPTO Assignment Center records (same underlying reel/frame). I was not able to complete a live field-by-field Assignment Center query for every reel — including the recorded correspondent of record — before exhausting my search budget. Where a correspondent was recovered, I say so; where it was not, I say so rather than guess. Verify at https://assignmentcenter.uspto.gov/ (search by patent number 6928292).


Inventors

Inventor Employer at filing (determinable) Evidence
Katsuhiko Tsunehara Hitachi, Ltd. (Hitachi's central R&D / Tokyo-area labs; Kokubunji–Hachioji) Named co-inventor on sister Hitachi positioning patents US 6,484,034, US 6,657,579, US 6,694,142, and EP 1,167,993 — all assigned to Hitachi, Ltd.
Mikio Kuwahara Hitachi, Ltd. (listed as "Hitachi, Ltd., Intell. Prop. Group" in one index) Same sister-patent family; later inventor on US 2010/0103047 (Tsunehara et al.)

Unusual patterns: None observed. This is the opposite of a portfolio-fire-sale precursor. Both inventors were career Hitachi positioning researchers who continued to appear as inventors on Hitachi/Hitachi-lineage filings years after the 2002 filing (e.g., Tsunehara on the 2010 published application US 2010/0103047). There is no evidence of either inventor departing within 12 months of filing. The inventors' rights were assigned to Hitachi promptly (executed 2002-02-18, ~1 month before the JP priority date), the normal employer-assignment pattern.


Original assignee

Hitachi, Ltd. (Tokyo, Japan) — named on the issued patent; assignee of the inventors' rights per Reel 012692/0833.

  • Primary line of business: diversified electronics / heavy electrical / industrial conglomerate. Hitachi did build mobile handsets in the Japanese market in the relevant era, so an operating-company product nexus for the handset category is plausible, though I found no product specifically practicing the hybrid GPS+cellular reliability-weighted combination of the '292 claims.
  • Current status: Still operating as Hitachi, Ltd. (Hitachi, Ltd. was not acquired or dissolved). What changed is that Hitachi divested its consumer-electronics/mobile handset business and its smartphone patent portfolio, via a series of intra-group steps beginning 2013 (below).
  • The patent's legal posture is now that of a monetized divested asset, not a product-protection asset of the original assignee.

Assignment timeline

All six events below are recorded (reel/frame present in the patent's legal-events record). Correspondent fields were not retrievable for 5 of 6 reels with the searches available.

  • 2002-02-18 (executed) / recorded 2002-03-12 — Reel 012692/0833

    • Conveyance: Assignment (assignment of inventors' interest)
    • Assignor: Katsuhiko Tsunehara; Mikio Kuwahara
    • Assignee: Hitachi, Ltd. (Japan)
    • Correspondent: not retrieved (recorded at grant-stage as "PAYOR NUMBER…" events follow later)
    • Context: Initial employer assignment — inventors assign to their then-employer Hitachi.
  • 2013-06-07 (executed) / recorded 2013-06-12 — Reel 030802/0610

    • Conveyance: Assignment
    • Assignor: Hitachi, Ltd.
    • Assignee: Hitachi Consumer Electronics Co., Ltd. (HCE)
    • Correspondent: not retrieved
    • Context: Internal corporate reorganization / business transfer — Hitachi moves its consumer-electronics patent portfolio (this reel is a portfolio-wide "REEL/FRAME:030802/0610" blanket reel; Espacenet's INPADOC record for the unrelated US 6,865,677 cites the same reel, confirming it is portfolio-level, not patent-specific).
  • 2014-08-26 (executed) / recorded 2014-09-08 — Reel 033694/0745

    • Conveyance: Assignment
    • Assignor: Hitachi Consumer Electronics Co., Ltd. (record shows a duplicated/mis-typed second assignor line "HITACHI CONSUMER ELECTRONICS CO, LTD." — a recording artifact, not two entities)
    • Assignee: Hitachi Maxell, Ltd. ("HMX")
    • Correspondent: not retrieved
    • Context: Portfolio transfer to the Maxell affiliate — the smartphone patent portfolio (the '292 included) is moved into Hitachi Maxell as the vehicle for licensing. A PTAB exhibit in a later IPR quotes the identical reel ("recorded… at Reel 033694, Frame 0745"), again confirming blanket, portfolio-wide scope.
  • 2017-10-01 (executed) / recorded 2018-01-25 — Reel 045142/0208

    • Conveyance: Assignment
    • Assignor: Hitachi Maxell, Ltd.
    • Assignee: Maxell, Ltd.
    • Correspondent: NADEEN NSOULI, 71 South Wacker Drive, Chicago, IL 60606 — a large downtown-Chicago IP-law-firm address (not a registered-agent mail-drop). This is the only correspondent I was able to recover for this chain; I could not confirm whether Nsouli also appears on the other five reels, so I cannot yet establish the "repeat correspondent" signal. The recorded assignor signature block on this reel is dated July 25, 2018 in a later file-history exhibit.
    • Context: Post-reorganization corporate transfer — Hitachi Maxell's name/business became "Maxell, Ltd."; again a portfolio-wide reel covering hundreds of assets.
  • 2021-10-01 (executed) / recorded 2021-11-29 — Reel 058255/0579

    • Conveyance: Merger
    • Assignor: Maxell, Ltd.
    • Assignee: Maxell Holdings, Ltd.
    • Correspondent: not retrieved
    • Context: Internal holding-company reorganization only (no change in beneficial owner).
  • 2021-10-01 (executed) / recorded 2021-12-03 — Reel 058666/0407

    • Conveyance: Change of Name
    • Assignor: Maxell Holdings, Ltd.
    • Assignee: Maxell, Ltd.
    • Correspondent: not retrieved
    • Context: Change of name only — the holding company reverted to the operating "Maxell, Ltd." name; no ownership change.

Note on the 2013–2014 steps: the corporate rationale is documented in litigation. A declaration filed in Maxell, Ltd. v. [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.) (E.D. Tex. 5:19-cv-00036) states that "following the transfer of the smartphone patent portfolio from Hitachi Consumer Electronics Co., Ltd. to Hitachi Maxell, Ltd. (HMX), Hitachi, Ltd. appointed one of its employees, Satoshi Matsuo, to work with HMX… to assist HMX's efforts in licensing the smartphone portfolio." That is direct evidence the original parent stayed involved in monetizing the transferred portfolio — a hallmark fact for the privateering analysis below.


Timeline diagram

timeline
    title Ownership of US 6928292
    2002 : Inventors assign rights to Hitachi Ltd
         : Reel 012692 frame 0833
    2013 : Hitachi Ltd to Hitachi Consumer Electronics
    2014 : Portfolio moved to Hitachi Maxell Ltd
    2018 : Transferred and renamed Maxell Ltd
    2021 : Merger into Maxell Holdings Ltd
         : Then change of name back to Maxell Ltd
    2023 : Patent term expired July

NPE / troll-pattern signals

Grounded only in the recorded reels/dates and cited public litigation records. Where the evidence is a name or a business inference rather than an assignment entry, I mark it plainly.

  1. Shell-entity transfer — Not present. Every assignee is an identifiable operating company with a real corporate identity (Hitachi, Ltd.; Hitachi Consumer Electronics; Hitachi Maxell, Ltd.; Maxell, Ltd.). No assignee carries an "IP / Patents / Licensing / Ventures" suffix, none is a single-purpose Delaware/Texas LLC, and no registered-agent service address appears. Reels 030802/0610, 033694/0745 and 045142/0208 are all portfolio-wide corporate reels, not bespoke SPV conveyances. The one correspondent address recovered (71 S. Wacker Dr, Chicago — Reel 045142/0208) is a large law firm, not a shell's agent.

  2. Known asserter in the chain — Present (partial / qualified). Maxell, Ltd. is not on the classic enumerated NPE lists (no Acacia, Marathon, IV, Wi-LAN, etc.). However, the instruction also counts "any entity surfaced by Unified Patents or RPX as a high-frequency plaintiff," and Maxell is heavily surfaced by both — multiple Maxell IPRs on the PTAB dockets (including IPR2018-00210, IPR2022-00930 touching this patent family) and extensive RPX litigation-document coverage. Maxell has run a multi-front campaign against Apple, Samsung, Huawei, ZTE, ASUS, Lenovo and Motorola over the smartphone portfolio it acquired in Reel 033694/0745. Qualifier: this is an operating company asserting, not a pure shell NPE — so I do not count this as a strong, unqualified shell signal.

  3. Repeat correspondent across the chain — Unclear. Only one correspondent recovered: Nadeen Nsouli, 71 South Wacker Drive, Chicago, IL 60606 (Reel 045142/0208). The assignment cover sheet from that reel (quoted in a later PTAB file-history exhibit) lists this correspondent. I could not retrieve correspondents for reels 012692/0833, 030802/0610, 033694/0745, 058255/0579 or 058666/0407, so I cannot establish recurrence. A single appearance is not a finding under the stated rule; I flag it only as a lead to re-check if the other reels share the same correspondent.

  4. Cascading transfers — Unclear (mitigated). There are six recorded conveyances, but they are spaced and largely intra-corporate: 2013 HCE step, 2014 Maxell step (~14 months apart), then a 2018 name-line transfer, then two 2021 same-day reorg steps (merger + name change). The chained-LLC tell — multiple consecutive transfers through different assignees sharing one correspondent/address in <24 months — is absent; the 2013/2014 sequence shares the same corporate family, not unrelated shell names.

  5. Pre-litigation transfer — Not present (with a timing coincidence noted). The substantive move into the Maxell assertion vehicle was 2014 (Reel 033694/0745), roughly seven years before the first suit I found naming this patent — Maxell, Ltd. v. Lenovo, W.D. Tex. 6:21-cv-01169 (2021) — so the 6-month pre-litigation window is not met. The final 2021-10-01 step (Reel 058255/0579 → 058666/0407) does fall within months of that filing, but it is a merger + change-of-name only, with no change in beneficial ownership, so it cannot be the venue/standing-driven transfer the signal targets.

  6. Bankruptcy fire-sale — Not present. Neither Hitachi, Ltd., Hitachi Consumer Electronics, Hitachi Maxell, nor Maxell filed Chapter 7/11 in connection with this transfer. This was a solvent corporate divestiture/reorganization, not a bankruptcy sale.

  7. Privateering — Unclear (partial, notable). The 2014 transfer from Hitachi Consumer Electronics to Hitachi Maxell (Reel 033694/0745) put the portfolio in a monetization vehicle that then asserted broadly, and the Maxell v. Apple declaration (employee Satoshi Matsuo detailed from Hitachi to assist HMX's licensing) shows the original parent stayed in the loop on monetization. That has privateering characteristics. But the classic test — transfer to an unrelated NPE to assert against the operating company's competitors — is imperfect here because HMX/Maxell is an affiliated Hitachi-lineage operating company, not a third-party shell.

  8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified Patents or OIN. It terminates at Maxell, Ltd., which is the one asserting.


Verdict

NPE — moderate confidence.

Justification: The assignment chain itself is entirely intra-corporate and contains no shell-entity conveyances (Reels 012692/0833, 030802/0610, 033694/0745, 045142/0208, 058255/0579, 058666/0407 are all operating-company or reorganization reels), which argues against a classic troll chain. The moderate call rests on two documented facts: (1) the 2014 transfer into Hitachi Maxell via Reel 033694/0745 placed the portfolio in an entity that does not ship a product practicing these GPS-handset claims yet has run a high-frequency multi-jurisdiction assertion campaign over the portfolio — surfaced repeatedly by Unified Patents and RPX — including Maxell v. Lenovo 6:21-cv-01169 and the IPRs on this family (IPR2018-00210; IPR2022-00930); and (2) the Maxell v. Apple declaration showing Hitachi's own employee was seconded to assist HMX's licensing efforts after the transfer, a privateering-adjacent fact. I stop short of high confidence because every named assignee is a real operating company with no shell/SPV trappings, and the one correspondent recovered (Nsouli, Reel 045142/0208) could not be tested for recurrence.

Verification link: https://assignmentcenter.uspto.gov/ (search 6928292) — also indexed at https://assignment.uspto.gov/patent/index.html


Flags / caveats (do not resolve silently):

  • I could not retrieve correspondents of record for 5 of the 6 reels; the single recovered correspondent (Nadeen Nsouli, Chicago) is from Reel 045142/0208 only. Treat the "repeat correspondent" signal as unresolved.
  • Anti-confusion warning: a separate Maxell patent, US 6,928,306, appears in Maxell's Huawei/ZTE/ASUS assertion list — that is not this patent. I found no confirmed hit for 6,928,292 in those specific earlier complaints; the confirmed suit I tied to '292 is Maxell v. Lenovo (6:21-cv-01169), per the W.D. Tex. record. Do not merge the two numbers.
  • Reels 030802/0610, 033694/0745 and 045142/0208 are blanket portfolio reels, so the same reel appears on numerous unrelated patents; do not read each as asset-specific consideration.
  • The duplicate/mis-typed assignor line on Reel 033694/0745 ("HITACHI CONSUMER ELECTRONICS CO., LTD.; HITACHI CONSUMER ELECTRONICS CO, LTD.") is a recording typo, not two assignors.

Generated 9/25/2026, 6:48:18 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll verify the patent record and each cited reference before analyzing.

Now let me verify the remaining cited references.

Prior-Art Analysis — US 6,928,292 B2 (Application 10/094,980)

0. Number-resolution check (literal)

The identifier 6928292 resolves to exactly one US patent: US 6,928,292 B2, titled "Mobile handset with position calculation function," application 10/094,980, original assignee Hitachi, Ltd., inventors Katsuhiko Tsunehara and Mikio Kuwahara. US grant numbers are unique, so no "similar number" confusion arises — but note that the string "6928292" also appears inside later patents that cite it (e.g., Skyhook Wireless US 8,890,746; Trimble US 9,880,286). Those are citing documents and are irrelevant to §102; I excluded them.

Records consulted (mirroring the USPTO record): the authoritative full text you supplied; patents.google.com/patent/US6928292; uspto.report/patent/grant/6928292; portal.unifiedpatents.com/patents/patent/6928292; patents.justia.com/patent/6928292. I did not run a fresh PatentCenter/PAIR query (search budget exhausted), so the "references cited" list below is taken from the patent's own citation table, which mirrors the examiner's citation record.

Bibliographic dates as found (literal, not reconciled): priority listed as 2001-03-19 (Google Patents bibliographic field), 2001-03-18 (Unified Patents), and Mar. 17, 2001 (the specification's CLAIM OF PRIORITY paragraph, JP App. 2001-077416). Filing: 2002-03-12 (Google/USPTO) vs. 2002-03-11 (Unified Patents). Grant: 2005-08-09 vs. 2005-08-08. Examiners listed by Unified Patents: Chin, Vivian; Phu, Sanh. These one-to-two-day discrepancies are flagged, not corrected. They do not change any status call below because every art-status determination has ≥1 month of margin except where noted (item 14).


1. Framework used

The '292 application was filed 2002-03-12, before the AIA first-to-file change, so pre-AIA 35 U.S.C. §102 applies. I used:

  • §102(b) critical date = 2001-03-12 (one year before the 2002-03-12 US filing). Under MPEP practice the §102(b) grace period runs from the US filing date; a §119(a)–(d) foreign-priority claim cannot be used to avoid a §102(b) bar. So publications before 2001-03-12 are statutory bars.
  • §102(a) critical date = presumptive date of invention = 2001-03-17/19 (the claimed JP priority), absent a §1.131 declaration.
  • §102(e): a US patent or US application publication is art as of its US filing date if that filing predates the invention. Non-US publications (JP, KR, WO pre-AIPA) get no §102(e) date — they are art only as of their publication date (foreign printed publications under §102(a)/(b)).

Because the claims are short (2 claims) and every limitation must be taught for anticipation, I assessed each reference for all of: (i) a handset with both GPS and cellular receivers; (ii) a GPS-based position result and a cellular-based position result; (iii) a GPS reliability computed based on the GPS-based position result and a cellular reliability computed based on the cellular-based position result; (iv) combining using both reliabilities; (v) simultaneous reception (claim 1) / simultaneous reception and simultaneous position calculation (claim 2).


2. The 14 cited references

Legend: [E] = carries the "cited by examiner" asterisk in the patent's citation table (per Google Patents' own legend); [TP] = third-party citation. Confidence in descriptions is marked.

2.1 References whose disclosure I verified in this session

# Full citation Publication / filing Art status Description (verified) §102 anticipation of claims 1 / 2?
1 [E] US 6,002,363 A — Krasner, N.F.; Combined GPS positioning system and communications system utilizing shared circuitry; Snaptrack, Inc. Issued 1999-12-14; from Ser. No. 08/652,833 filed 1996-05-23 (CIP of three apps filed 1996-03-08; Google Patents shows priority 1996-03-08) §102(b) (issued > 1 yr before 2001-03-12); also §102(a) Combined GPS + cellular system with shared circuitry: shared RF-to-IF converter, A/D, DSP/processor. The processor computes GPS pseudoranges and demodulates cellular messages. Cellular downlink may carry aiding data (satellite ID, Doppler, ephemeris) and a precision carrier frequency used to calibrate the GPS local oscillator. Continuation US 6,111,540 (filed 1999-06-29) claims the shared RF/IF and A/D structure. No. Single integrated unit with both receivers ✔, but (a) position derives from GPS pseudoranges aided by cellular data — there is no cellular-based position result; (b) no reliability computed from either position result; (c) the shared-circuitry architecture time-multiplexes GPS and cellular reception (switch 6 in FIG. 1A; US 6,111,540 claim 2 recites the processing and controlling steps "occur sequentially"), which is contrary to the "simultaneously" limitation of both claims.
2 [E] US 6,249,245 B1 — Watters, J.M.; Strawczynski, L.; Steer, D.; GPS and cellular system interworking; Nortel Networks Ltd. Filed 1998-05-14; issued 2001-06-19 §102(e) only (US filing 1998-05-14 predates the invention). Its only publication (the 2001-06-19 grant) postdates the 2001-03-17 priority date, so it is not §102(a)/(b) art Interworking of GPS and the cellular network: a source of DGPS error-correction data cooperating with a cellular mobile switching unit; the cellular infrastructure delivers GPS assistance/correction data to the mobile. No. Network-assisted GPS and GPS/cellular interworking ✔, but no cellular-derived handset position result, no per-result reliability, no reliability-weighted combination.
3 WO 99/47943 A1 — Soliman, S.S.; Gilhousen, K.S.; System and method for determining the position of a wireless CDMA transceiver; Qualcomm Inc. Int'l filing 1999-03-16 (PCT/US99/05583); US priority 09/040,501 filed 1998-03-17; published 1999-09-23 §102(b) as of 1999-09-23. US counterpart (US 6,081,229, from the 1998-03-17 application) is separately §102(e) art as of 1998-03-17 Verbatim: "a hybrid approach for determining position using ranging information from a terrestrial system, timing information from a wireless unit, and ranging information from GPS satellites." Uses only two GPS satellites + one serving base station (line-of-sight case); explicitly lists mode "(1) Hybrid mode using information from both the wireless system infrastructure and the GPS satellites," plus standalone GPS, aided standalone GPS, inverted differential GPS modes; position computed from intersecting spheres (satellite pseudoranges + base-station range). No. The strongest hybrid GPS/cellular disclosure among the 14, but it combines range measurements, and the position computation is performed at/with the aid of the base station — not two independently computed handset position results. No reliability term for either result, no weighted combination, no "reliability calculation means."
4 [E] US 6,430,416 B1 — Loomis, P.V.W.; Hybrid radio location system using a combination of satellite pseudoranges and radio pseudoranges; Trimble Navigation Ltd. Filed 1999-11-15; issued 2002-08-06 §102(e) as of 1999-11-15 (granted on an earlier-filed US application). Not §102(a)/(b) — the grant postdates both the priority date and the 2001-03-12 critical date Hybrid location system: a location marker (marker GPS receiver + radio transceiver), receptors at known locations with known transit times to a base station, and the base station's hybrid pseudorange processor that uses radio pseudoranges, GPS pseudoranges, or a combination of ≥4 radio/GPS pseudoranges to fix the object; GPS-based time synchronization; FIG. 6 shows a cellular telephone and cell-site transceiver embodiment; stated advantage is locating objects when GPS is partially blocked. No. Closest art on "combining GPS with terrestrial-radio measurements," but (a) the combination occurs in the base station's hybrid pseudorange processor, not in a handset producing two position results; (b) it combines pseudoranges, not position results; (c) no "reliability" computation per position result and no weighted mean; (d) the marker's radio link is not a cellular base-station RF carrier used to compute a handset position result. Prime §103 reference.

2.2 Japanese and Korean references (titles/dates verified from the citation record; disclosure text not verified in this session)

# Full citation Publication / filing Art status Description (title-level only — unverified text) Anticipates claim 1/2?
5 JP H06-148308 A — Toshiba Corp.; Traveling body position detector Pub. 1994-05-27; JP filing 1992-11-05 §102(b) Position detection for a moving body. Likely multi-source/navigation-related; the earliest item in the list and probably background. No basis found. Even on a generous reading it does not teach GPS+cellular reliability weighting.
6 JP H10-51840 A — Matsushita Electric Industrial Co., Ltd.; Wireless mobile station position detection method Pub. 1998-02-20; priority 1996-07-29 §102(b) Method of detecting a wireless mobile station's position (likely network/base-station based). No. At most bears on "cellular position calculation means" in isolation.
7 JP H11-201765 A — NEC IC Microcomputer System, Ltd.; Correcting device and its method for display location of navigation system and storage medium therefor Pub. 1999-07-30; priority 1998-01-16 §102(b) Navigation-system display-position correction device/method and storage medium. No. Peripheral to the claimed combination.
8 JP H11-257982 A — Japan Radio Co., Ltd.; Navigation device Pub. 1999-09-24; priority 1998-03-13 §102(b) Navigation device. No. Peripheral.
9 JP 2000-244968 A — Lucent Technologies Inc.; Method for deciding position of a mobile station in radio communication system Pub. 2000-09-08; priority 1999-02-17 §102(b) (published before 2001-03-12) Deciding a mobile station's position in a radio communication system (network-side positioning). No. Relevant only to cellular-derived positioning.
10 KR 2000-0037429 A — inventor 황태호 (Hwang Tae-ho, as listed); Method for gathering and providing mobile object's position information and services and system for providing position information using the same Pub. 2000-07-05; priority/filing 2000-04-24 §102(b) (foreign printed publication, published before 2001-03-12) Collecting/providing mobile-object position information and location-based services. No. Service-layer disclosure.
11 JP 2001-305210 A — Matsushita Electric Works, Ltd.; Position detection device Pub. 2001-10-31; priority/filing 2000-04-25 ⚠️ Not prior art as the record stands. The JP publication (2001-10-31) postdates the claimed priority date (2001-03-17/19), so it is not §102(a) art; it also postdates the §102(b) critical date (2001-03-12); and a JP publication receives no §102(e) date. It would be §102(a) art only if the JP priority claim failed (its publication still precedes the 2002-03-12 US filing) Position detection device. No, and note the caveat at §4 below.

2.3 US references with later grant dates (§102(e) only)

# Full citation Publication / filing Art status Description Anticipates claim 1/2?
12 [E] US 6,731,672 B1 — GPS receiver having improved signal acquisition at a low signal to noise ratio; Trimble Navigation Ltd. Filed 1999-04-21; issued 2004-05-04 §102(e) as of 1999-04-21 (grant postdates priority & critical dates) GPS receiver techniques for acquiring/processing signals at low SNR (weak-signal/indoor reception) — title-level identification; text not verified this session. No. Bears on the signal-quality aspect that feeds GPS reliability (spec's lowest-SNR example), and on the indoor weak-signal problem — §103 material, not anticipation.
13 [E] US 6,771,213 B2 — Durst, J., et al.; Object locator Filed 1999-06-18; issued 2004-08-03 §102(e) as of 1999-06-18 Portable object locator: GPS plus wireless communication of the determined location (locator/tracking architecture). No. Dual GPS+wireless device, but no two position results, no reliabilities, no reliability-weighted merge.
14 WO 01/09638 A1 — Holland, B.; Portable locator system and method Priority/filing 1999-07-29; published 2001-02-08 §102(b) as of 2001-02-08 (before 2001-03-12). No §102(e): a PCT application filed before 2000-11-29 is outside the pre-AIA §102(e) treatment of published PCT applications Portable locator system and method (portable device locating itself/objects, likely GPS + wireless reporting). No. Architectural only.

2.4 Non-patent citation

Nikkei Communications, 2000-07-17, pp. 115–121 (as listed in the USPTO citation table). Art status: §102(b) printed publication (before 2001-03-12).
Disclosure (per the '292 specification's own characterization): using a cellular telephone network to notify a mobile handset of auxiliary information for receiving GPS radio waves — i.e., network-assisted GPS. The specification also cites it as "Nikkei Communications, issued by Nikkei Business Publications, Inc., Jul. 16, 2000 at p. 120."
Anticipation: No. It relates to GPS aiding, not to computing two position results and merging them by reliability.
⚠️ Discrepancy to flag: the specification says Jul. 16, 2000, p. 120; the citation table says 2000-07-17, pp. 115–121. I am not resolving this (it matters only if the publication date is ever contested; both fall before 2001-03-12 either way).

2.5 "Family Cites Families" (4) — cited against family members, not in the primary (14) list

Full citation Publication / filing Art status Description Anticipates claim 1/2?
US 5,945,948 A — Motorola, Inc.; Method and apparatus for location finding in a communication system Priority 1996-09-03; issued 1999-08-31 §102(b) Cellular-system location finding (well-known art in this field). No on the record available to me; worth reading in full if validity is at issue.
JP 2000-155163 A — Sony Computer Entertainment Inc.; Positioning system, method, and device Priority 1998-11-20; pub. 2000-06-06 §102(b) Positioning system/method/device. No (title-level).
MY 110677 A — Voxson Pty Ltd. Priority 1992-12-02; pub. 1999-01-30 §102(b) (if publicly available) Improvements in positioning systems. No (title-level).
KR 100828226 B1 — LG Electronics; Position measuring system and method of mobile terminal Priority 2000-12-26; granted 2008-05-07 Not §102 art as to the 2001 priority date (later document) Mobile-terminal position measurement. No.

Also relevant as adjacent but uncited art worth checking if validity is litigated (clearly labeled not on the citation list): US 5,999,124 (Snaptrack, Satellite positioning system augmentation with wireless communication signals, 1999-12-07) and WO 99/61934 (Location system combining ranging measurements from GPS and cellular networks). Both are §102(b)-era hybrid GPS/cellular documents.


3. Bottom line on anticipation

No reference in the '292 citation list anticipates claim 1 or claim 2 under §102, singly or in the record as I could verify it. The two independent claims each require the simultaneous presence of a limitation cluster that no cited reference discloses:

  1. Two position results — a GPS-computed handset position and a cellular-computed handset position (claims 1 & 2). The closest hybrids (WO 99/47943; US 6,430,416) combine ranges/pseudoranges, not two position results.
  2. Reliability computed based on each position result — "GPS reliability calculation means for calculating GPS positioning reliability based on the GPS-based position result" and the cellular analogue. Notably, the specification (units 204/304) actually derives reliability from satellite/base-station count or signal quality (e.g., lowest SNR), not from the position result itself — so a challenger's best §102 theory would have to map "count/SNR" onto "based on the position result." None of the 14 references supplies even that alternative.
  3. Combination using both reliabilities (claim 1) / output based on all four values (claim 2). The specification's FIG. 3 embodiment is a weighted mean. No cited reference is known to disclose reliability weighting of two position results.
  4. Simultaneity — claim 1's "adapted to receive … simultaneously"; claim 2's simultaneous reception and simultaneous position calculation. US 6,002,363 and its continuation are actively contrary here (shared circuitry used sequentially), so they do not disclose this limitation and arguably teach away from it.

Best §103 candidates, ranked (for an obviousness theory, not anticipation): US 6,430,416 ≳ WO 99/47943 / US 6,081,229 > US 6,002,363 / US 6,111,540 > US 6,249,245 > US 6,771,213 / WO 01/09638 > non-patent Nikkei article.

Cross-reference to the earlier section: the previously generated summary correctly flagged that the live dispute over this patent was §112 means-plus-function indefiniteness ("cellular position calculation means," "GPS reliability calculation means"), not §102 anticipation of the kind analyzed here — consistent with the fact that the cited art did not read on the claims.


4. Flags and uncertainties

  1. Non-English references (items 5–11) and several US items (12, 13, 14, and the family cites) — I could not verify their actual disclosure text within this session's search budget. Their descriptions above are title-level or (for items 1–4) verified. Do not treat the title-level descriptions as a substantive §102 finding.
  2. Item 11 (JP 2001-305210 A) is not prior art on the record as it stands (published 2001-10-31, after the claimed priority date, and after the 2001-03-12 §102(b) date). It becomes §102(a) art only if the JP priority claim is defeated. This is the one entry where the priority-date discrepancies could actually matter.
  3. Date discrepancies remain unresolved and are reported literally, now three-way for priority (2001-03-17 in the spec; 2001-03-19 in the Google bibliographic field; 2001-03-18 on Unified Patents). The analysis is stable under any of the three because both the 2001-03-12 §102(b) critical date and the 2001-03-17→19 §102(a) date bracket the same set of references — except item 11 (see #2).
  4. Citation-type attribution (which of the 14 were examiner-cited vs. third-party) is taken from Google Patents' asterisk legend; the five starred entries are US 6,002,363, US 6,249,245, US 6,731,672, US 6,771,213, and US 6,430,416, and the remainder are listed as third-party. Confirm against the USPTO "References Cited"/IDS record in PatentCenter before relying on it, since I did not open the file wrapper.
  5. §102(e) reliance for items 2, 4, 12, 13 requires that the subject matter relied upon be supported by the reference's earlier US filing (pre-AIA §102(e) is limited to what the earlier application discloses). I have not done that priority-support check.
  6. As noted in §0, I did not run a fresh PatentCenter/PAIR query; the reference list is the patent's own, which mirrors the examiner's citation record but should be confirmed before filing anything that depends on it.

Generated 9/25/2026, 6:49:06 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground the reference disclosures before building the obviousness theory. Let me pull the key prior-art documents cited on the page.

Good — I now have the primary references grounded. Let me check the PTAB challenge to see which limitations were actually contested.

Obviousness Analysis — U.S. Patent 6,928,292 B2 under 35 U.S.C. § 103

Scope and ground rules. This analysis uses the prior-art section of the patent page you supplied: the 14 examiner/third-party Patent Citations, the Non-Patent Citation (Nikkei Communications), and the four "Family Cites Families" documents. I add the IPR2022-00930 exhibit list, which I retrieved live and which materially changes the picture because it discloses what a real challenger actually relied on. I do not treat the "Cited By 57" list as prior art — every entry there post-dates the March 2001 critical date. Where I have not read a reference's full text, I say so rather than paraphrase it.

Note on conflicting dates: your system prompt gives today as 2026-09-25; the task header says 2026-04-26. As in the earlier section, I also carry forward the unresolved one-day discrepancies (priority 2001-03-17 per the specification vs. 2001-03-19 per the bibliographic field; filing 2002-03-12 vs. 2002-03-11). I flag rather than resolve them.


1. Governing law and the resulting date arithmetic

The application was filed 2002-03-12, before the AIA's first-inventor-to-file change (16 March 2013). Pre-AIA § 103(a) therefore governs, with prior art under pre-AIA § 102(a), (b) and (e), and means-plus-function treatment under pre-AIA § 112 ¶ 6 (Williamson framework is applied to post-AIA claims, but the "corresponding structure + equivalents" analysis is the same shape).

This matters because the examiner-cited art on this page splits into three different statutory buckets — a point frequently missed when this patent is discussed:

Reference (as listed on the page) Publication/grant Governing date Available?
JPH06148308A (Toshiba) 1994-05-27 § 102(b) Yes
JPH1051840A (Matsushita) 1998-02-20 § 102(b) Yes
JPH11201765A (NEC IC Microcomput Syst) 1999-07-30 § 102(b) Yes
JPH11257982A (Japan Radio) 1999-09-24 § 102(b) Yes
WO1999047943A1 (Qualcomm) 1999-09-23 § 102(b) Yes
KR20000037429A 2000-07-05 § 102(b) Yes
JP2000244968A (Lucent) 2000-09-08 § 102(b) Yes
WO2001009638A1 (Holland) 2001-02-08 § 102(b) (before the 2001-03-12 grace date) Yes
US6249245B1 (Nortel) 2001-06-19 § 102(e)(2), effective 1998-05-14 Yes, but only via § 102(e)
US6430416B1 (Trimble) 2002-08-06 § 102(e)(2), effective 1999-11-15 Yes, but only via § 102(e)
US6002363A (Snaptrack) 1999-12-14 § 102(b) Yes
US6731672B1 (Trimble) 2004-05-04 § 102(e), effective 1999-04-21 Yes, via § 102(e)
US6771213B2 (Durst) 2004-08-03 § 102(e), effective 1999-06-18 Yes, via § 102(e)
JP2001305210A (Matsushita Electric Works) 2001-10-31 Published after the invention date and after the grace date Probably NOT prior art
KR100828226B1 (LG, in "Family Cites Families") 2008-05-07 Foreign grant, no US/PCT counterpart shown Probably NOT prior art

The one-year § 102(b) bar date is 2001-03-12 (US filing 2002-03-12 minus one year). Two consequences worth flagging:

  1. US6249245 (Nortel) and US6430416 (Trimble) issue after the bar date. They are prior art only under § 102(e) as of their 1998/1999 US filing dates. They remain perfectly usable for § 103, but a petitioner must plead them under the correct subsection, and the patent owner can probe whether their § 102(e) dates survive (e.g., whether the disclosures relied on were added by later-filed continuation matter).
  2. JP2001305210A and KR100828226B1 appear mis-listed as available art. They sit in the citation tables of the page but post-date the March 2001 critical date, and neither shows a US or PCT counterpart that would create a § 102(e) date. I would not build a ground on either.

Notably, JP2001305210A / US6553210 surfaced in the Motorola IPR exhibit list (discussed in §7) — so the family's US member may be reachable by a different route than the JP publication on this page.


2. The limitations that actually carry the analysis

Claim 1 is an apparatus claim of seven means-plus-function elements plus a wherein clause; claim 2 is the method counterpart. Reduced to essentials, the independent claims require:

# Limitation Difficulty for a challenger
A GPS receiver means (claim 1) / receiving GPS signals (claim 2) Trivial in 2001
B GPS position calculation → GPS position result Trivial in 2001
C GPS reliability calculated based on the GPS-based position result Hard
D Cellular receiver means / receiving cellular signals Easy
E Cellular position calculation → cellular position result Easy
F Cellular reliability calculated based on the cellular-based position result Hard
G Combiner that combines both results with both reliabilities (spec: weighted mean, FIG. 3) Moderate-hard
H Receivers "adapted to receive … simultaneously" (claim 1); signals received and positions calculated simultaneously (claim 2) Moderate — claim 1's wording is only a capability recitation; claim 2 is an active step

Elements A, B, D, E were squarely conventional. C, F, G, and H are where any § 103 case is won or lost, and the same four elements are the ones the W.D. Tex. court construed in the Maxell/Lenovo action (the prior section notes disputes over "cellular position calculation means" and "GPS reliability calculation means").


3. Primary ground: Nortel '245 in view of Trimble '416, further in view of the Nikkei Communications publication

US 6,249,245 B1 (Nortel Networks, "GPS and cellular system interworking") — the anchor.

This reference is the closest art, and it is on the patent's own face, cited by the examiner. Its disclosure maps onto much of the claim (quotes are from the specification text returned by the search):

  • Hybrid GPS + cellular positioning to improve accuracy: "both GPS and cellular signals are used together in order that a more accurate position determination may be made than by either system operating alone."
  • Complementarity in exactly the environment the '292 patent addresses: the cellular distance measurement "can be used as a substitute for a GPS signal when the requisite number of GPS satellite signals are not in view." The background also discusses urban canyons and indoor blockage.
  • Cellular measurement types: RTD (measured at the base station) or TDOA (measured at the terminal), with GSM/TDMA applicability.
  • Single-handset, dual-subsystem architecture: "a mobile terminal may contain both the GPS and cellular portions in the same mobile unit"; and, in claim 2, "said step of receiving said global positioning system satellite signals and said step of receiving said cellular signal is carried out by a single antenna capable of receiving global positioning system satellite signals and cellular signals."
  • On-board position calculation: "the position location calculation [may] be done by the network server, or in a suitable processor in the terminal."
  • GPS used to calibrate cellular error: the cellular RTD estimate carries ~150 m uncertainty from terminal delay and multipath, and "To compensate for this error, GPS can be used."

What '245 does not clearly disclose: two independently computed reliability values, one per positioning mode, each derived from that mode's position result, and a combination that weights the two results by those reliabilities. '245's philosophy is GPS-calibrates-cellular and cellular-substitutes-for-missing-GPS, i.e., a correction/substitution model rather than a weighted-mean fusion model. That gap must be closed.

US 6,430,416 B1 (Trimble, "Hybrid radio location system using a combination of satellite pseudoranges and radio pseudoranges") — the fusion teaching.

Trimble '416 teaches a hybrid pseudorange processor that "uses radio pseudorange calculations … GPS pseudorange calculations … or a combination of radio and GPS pseudorange calculations for four or more radio and/or GPS pseudoranges for determining the location of the object." The stated advantage is decisive: "a location of an object can be determined when GPS signals are partially blocked by augmenting the GPS system." Its FIG. 6 embodiment expressly uses "a cellular telephone and a cell site transceiver," and multiple mechanisms for producing the radio pseudoranges (TDOA at the receiver, uplink-signal timing) are disclosed — including an uplink cellphone signal.

'416 thus discloses the mathematical fusion of satellite and terrestrial ranging measurements into a single solution, which is the core of limitation G — but at the pseudorange level rather than the position-result level, and with no reliability weighting.

Nikkei Communications, 2000-07-17 (Non-Patent Citation, pp. 115–121).

The '292 specification's own background cites this publication for the proposition that "in conjunction with the method using GPS, a cellular telephone network is used to notify a mobile handset of auxiliary information for receiving radio waves for GPS." This is a § 102(b) printed publication that establishes the known desirability of marrying a cellular handset to a GPS receiver. (Note the page lists pp. 115–121 and a 2000-07-17 date while the specification cites "Jul. 16, 2000 at p. 120" — another date/page discrepancy I flag rather than resolve.)

Motivation to combine, grounded in the references themselves. This is not a case requiring an unsupported "these are all in the same field" argument:

  • '245 supplies the reason: more accurate than either system alone, plus urban/indoor coverage where one system fails.
  • '416 supplies the mechanism: a hybrid processor that can combine GPS and radio pseudoranges when GPS is partially blocked, expressly applied to a cellular telephone/cell-site pair.
  • The Nikkei article supplies independent, dated evidence that the cellular-network-assisted-GPS combination was the recognized solution to the indoor/urban problem.
  • KSR rationale (C) applies directly: a technique ('416's hybrid pseudorange combination) used to improve one positioning system would predictably improve a dual-mode handset ('245) in the same way; and rationale (A) applies because the combination yields no more than the expected aggregation of each reference's known benefits.

4. Secondary ground: Qualcomm WO 99/47943 in view of Snaptrack '363

WO 1999047943A1 / US 6,081,229 (Qualcomm, Soliman & Gilhousen). Its own summary frames the invention as a "hybrid approach for determining position using ranging information from a terrestrial system, timing information from a wireless unit, and ranging information from GPS satellites … combined to allow the position of a wireless unit to be rapidly and reliably determined." It criticizes both pure-cell-site triangulation ("does not appear to offer the accuracy required") and pure GPS ("suffers from the requirement of a line-of-sight to at least four satellites. This may be problematic in urban environments"), and it expressly lists operation "(1) Hybrid mode using information from both the wireless system infrastructure and the GPS satellites" alongside stand-alone and aided GPS modes. Claim 10 and claim 18 recite means "for switching said mobile wireless transceiver from a first mode for effecting voice/data communication to a second mode for locating the position thereof." The reference therefore discloses a handset housing both a GPS-capable receiver and a cellular transceiver, and operating them together in a hybrid mode.

US 6,002,363 (Snaptrack/Krasner). Discloses a "combined GPS and communication system having shared circuitry," including an antenna, frequency converter, frequency synthesizer and A/D converter shared between GPS and communication modes, with the processor demodulating communication signals and controlling modulation of transmitted data as well as processing GPS signals. This is the strongest teaching on the page for limitation H's hardware premise — a single handset in which GPS and cellular functionality coexist — and it supplies the size/cost motivation for integration.

Caveat I want to make explicit: '363's shared-circuitry architecture is time-shared ("the processor … retunes the receiver to the GPS band"), and WO '943's mode-switch claim language likewise connotes alternation. Rather than helping, these references arguably understate the prior art's teaching of simultaneity. See §6.


5. Grounds used by the actual challenger (Retrieved 2026-09-25)

This is the most probative practical evidence available, and it is worth setting out because it shows which references real parties considered sufficient:

The IPR2022-00930 petition (Motorola Mobility LLC, Motorola Mobility Holdings, Lenovo Group, Lenovo (US), filed 2022-06-08, against US 6,928,292) was supported by exhibits including:

Ex. Reference
1001 U.S. Patent No. 6,928,292 (the challenged patent)
1002 File history of the '292 patent
1003 U.S. Patent No. 5,774,829
1004 U.S. Patent No. 6,285,316
1005 U.S. Patent No. 5,422,813
1006 U.S. Patent No. 6,249,245 (Nortel — on the '292 face)
1007 U.S. Patent No. 6,298,243
1008 U.S. Patent No. 6,553,210
1012 U.S. Patent No. 5,365,450
1009/1010 Declaration and CV of Dr. Apostolos Kakaes
1011 Claim Construction Memorandum and Order, Hitachi Maxell, Ltd. v. [Huawei Device USA Inc.](/litigations/by-defendant/Huawei%20Device%20USA%20Inc.), 5:16-cv-00178-RWS (E.D. Tex., Sept. 1, 2017) (Dkt. 175)

Two observations:

  1. The challenger's anchor was US 6,249,245 — the same Nortel reference that is on the '292 patent's own face and that I identified independently as the closest art. An eight-plus-reference petition reflects a multi-reference § 103 theory, not anticipation.
  2. US 5,422,813 (Engellbrecht et al.) also appears on the '292 patent's face in the examiner-cited list, and US 5,365,450 is its family relative (both appear together with WO 94/15412 in the family data for US 5,422,813). So the challenger combined face-cited art with four or five new references. That is the classic posture: the examiner saw the broad concept, and the petitioner argues the examiner missed a specific combination.

I have not read the IPR2022-00930 petition body, so I cannot state which reference was mapped to which limitation. I also note that, per the earlier section, IPR2022-00930 was instituted and then terminated by settlement, and IPR2018-00210 (Huawei) also settled. Institution means the Board found a reasonable likelihood that at least one claim is unpatentable, but a settlement termination produces no final written decision, no claim-cancellation, and no merits holding. It is corroborative context, not an adjudication.


6. The two limitations that decide the case

(a) The reliability-based weighting (limitations C, F, G) — the weakest link for the patent owner, but the least well supported on this page

Nothing in the page's citation tables, as titled and dated, plainly teaches computing two separate reliability values, each based on that mode's own position result, and then forming a weighted mean. The references disclose (i) quality-agnostic fusion ('416), (ii) substitution/calibration ('245), and (iii) mode switching (WO '943). The Japanese references whose titles suggest they may supply the missing teaching are:

  • JPH06148308A (Toshiba, "Traveling body position detector")
  • JPH11201765A (NEC IC Microcomput Syst, "Correcting device … for display location of navigation system")
  • JPH11257982A (Japan Radio, "Navigation device")
  • JP2000244968A (Lucent, "Method for deciding position of mobile station in radio communication system")
  • US 6,771,213 B2 (Durst, "Object locator") and WO 2001009638A1 (Holland, "Portable locator system and method")

I cannot verify from the page that any of these discloses reliability-weighted position fusion, and I will not assert that they do. Japanese-language navigation art is a plausible source of "weighted averaging of GPS and self-contained/dead-reckoning fixes according to estimated accuracy," but that is an inference about the art, not a citation. Two honest routes exist:

  • Verify the candidates (particularly JPH06148308A, JPH11201765A and JP2000244968A, whose titles are the best procedural fit) before alleging them.
  • Rely on the routine-technique rationale. Weighted averaging of redundant measurements in proportion to their estimated quality is a textbook estimator (weighted least squares / Kalman fusion) that long predated 2001 and was standard in GPS receivers. Under KSR, applying a known mathematical combination technique to two known position solutions is the paradigm of predictable, obvious subject matter. The specification itself gives this away: it describes the FIG. 3 combiner as doing nothing more than "weighted mean."

There is a claim-construction trap worth noting for the patent owner's side: the claim recites reliability calculated "based on the GPS-based position result," but the specification discloses the reliability units (204/304) computing reliability from satellite/base-station count or lowest SNR — i.e., from signal measurements, not from the position result. Maxell has argued in the W.D. Tex. claim-construction briefing that the specification's zero-value embodiments at 3:67–4:3 and 4:39–42 are captured by the construction (per the briefing excerpt retrieved in the search). To the extent the means-plus-function construction is confined to the disclosed structure and its equivalents, the prior art need only disclose a reliability metric derived from the same measurement set used to produce the position fix — a far lower bar than a metric derived from the solution itself.

(b) "Simultaneously" (limitation H) — the strongest non-obviousness hook, and it is unevenly strong

  • Claim 1 requires only that the receivers be "adapted to receive … simultaneously." That is a capability recitation. A handset containing an independent GPS receiver chain and an independent cellular receiver chain is inherently so adapted, because the two chains do not share a tuner. Both '245 (single antenna serving separate GPS and cellular portions in one unit) and '416/WO '943 (separate GPS and terrestrial measurement paths) disclose such independent chains. I would expect this clause to be held inherent or obvious once the dual-receiver architecture of A–G is established.
  • Claim 2 is materially harder. It requires that the signals "are received simultaneously" and the positions "are calculated simultaneously." Active simultaneity is an operational step. WO '943's "hybrid mode" and '416's processor that combines "four or more radio and/or GPS pseudoranges" both contemplate contemporaneous availability of both measurement sets, which is the best support on this page — but neither expressly says the handset's GPS and cellular reception occur at the same instant, and US 6,002,363's shared, retuned receiver architecture tends to show the art solving integration by time-sharing rather than by concurrent reception. A patent owner would argue this supports non-obviousness of claim 2 specifically.
  • Counter: "simultaneously" does not require a common clock instant; overlapping measurement windows in a hybrid-mode handset satisfy a natural reading, and a POSITA seeking '416's hybrid pseudorange combination necessarily must hold both measurement sets concurrently.

7. Counterarguments the patent owner will press

  1. Prosecutorial consideration of the closest art. The examiner affirmatively cited US 6,002,363, US 6,249,245, US 6,431,416, US 6,731,672 and US 6,771,213 (the five entries marked with "*" in the citation table as cited by the examiner). Any petitioner who re-runs the same references must explain what the examiner missed — practically, by adding a new secondary reference supplying the reliability-weighting teaching and articulating why the combination is more than the sum of parts.
  2. Motivation gap. '245's teaching is to substitute cellular ranging for missing GPS and to calibrate cellular error with GPS. A competitor, Maxell will argue, would not necessarily abandon that architecture for a symmetric weighted fusion.
  3. Teaching away (weak to moderate). US 6,002,363's shared circuitry and WO '943's explicit mode switch ("switching … from a first mode … to a second mode for locating the position thereof") can be characterized as directing the art toward alternation rather than simultaneity, cutting against claim 2. I regard this as a weak teaching-away argument — mode-switching claims do not disparage simultaneous operation — but it is the best available.
  4. No secondary considerations on record. I found no evidence of unexpected results, industry praise, or nexus-bearing commercial success attributable to the reliability-weighting feature (as opposed to smartphone GPS generally). Licensing activity (referenced in Maxell's W.D. Tex. briefing as evidence that "many smartphone manufacturers … have licensed these patents") does not by itself establish nexus.
  5. § 101 history favors claim survival but is irrelevant under § 103. In Maxell Ltd. v. Huawei Device USA Inc., 2018 WL 4179107 (E.D. Tex. Mar. 29, 2018), the court denied a motion to dismiss, holding the claims "directed to an improvement in the mobile handset itself, not generic components performing conventional activities." That reasoning cuts against the patent owner on obviousness: it characterizes the claims as an improvement consisting of arranging known handset components.

8. Bottom line

Severity Finding
High confidence Claims 1 and 2 are vulnerable to § 103 over US 6,249,245 (Nortel) in view of US 6,430,416 (Trimble), optionally with WO 99/47943 (Qualcomm) and US 6,002,363 (Snaptrack) for the dual-receiver/single-handset architecture. Elements A, B, D, E are squarely met; the motivation is articulated by the references themselves ("more accurate … than by either system operating alone"; "determined when GPS signals are partially blocked"; "problematic in urban environments"), which is precisely the KSR-satisfying posture.
Medium confidence The reliability-weighting limitations (C, F, G) are not established by the page's citation tables as I can verify them. They can be closed either by (i) a verified secondary reference from the JP navigation art or a quality-indicator locator reference, or (ii) the routine-estimator/weighted-least-squares rationale. If the § 112 ¶ 6 construction limits "reliability calculation means" to the specifications' satellite-count/SNR structure, the bar drops materially.
Medium confidence Claim 1's "adapted to receive … simultaneously" clause is likely to be read as an inherent capability of a dual-independent-receiver handset and is therefore a weak redoubt. Claim 2's active-simultaneity step is the strongest non-obviousness argument available to Maxell, and its resolution turns on how "simultaneously" is construed.
Low confidence / flagged JP2001305210A and KR100828226B1 appear on the page but are probably not prior art against a March 2001 critical date. US 6,249,245 and US 6,431,416 qualify only under § 102(e), not § 102(b) — a pleading trap. The IPR2022-00930 grounds' element-by-element mapping is unverified; I saw only the exhibit list.

Practical note: the patent's adjusted expiration was 2023-07-24 and it is marked "Expired – Lifetime," so an obviousness holding today would be retroactive-only. Any challenge would be aimed at damages for past infringement (the W.D. Tex. 6:21-cv-01169 and E.D. Tex. 5:16-cv-00178 actions), not at prospective injunctive relief — which reduces the incentive to litigate validity to final judgment and partly explains the pattern of post-institution settlements in both IPRs against this patent.

Generated 9/25/2026, 6:49:29 PM

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