Invalidity dossier
US 7076275
Method and system for single-step enablement of telephony functionality for a portable computer system
Current assignee: SmartPhone Technologies LLC
Added 9/30/2026, 1:41:44 PM
Active provider: DeepSeek · deepseek-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for authoritative information on this patent, including any 2026 CAFC activity.
Let me run more targeted searches to check for 2026 appellate activity and verify the reexamination outcome.
US 7,076,275 B1 — Summary
Important scope note: I could not find any 2026 CAFC docket, appeal, or opinion referencing patent 7,076,275. Searches of the web (including the CAFC opinions/orders domain) returned no appellate activity tied to this patent number. I will not speculate about 2026 docket status — treat that element as unverified. Multiple district court litigations are documented (see below), but those are historical, not 2026 appellate matters.
Bibliographic data
| Field | Value |
|---|---|
| Patent number | US 7,076,275 B1 |
| Title | Method and system for single-step enablement of telephony functionality for a portable computer system |
| Application number | US 09/687,518 |
| Filing date | 2000-10-13 |
| Priority date | 2000-10-13 |
| Issue/publication date | 2006-07-11 |
| Inventors | Rich Karstens; Ryan Robertson |
| Original assignee | Palm, Inc. (assignment recorded 2001-01-09) |
| Current assignee (listed) | Access Co., Ltd. (Japan); preceded by Access Systems Americas, Inc. → PalmSource, Inc. → Palm Source, Inc. |
| Status | Expired – Lifetime; adjusted expiration 2021-08-17 (12th-year maintenance fee paid 2017-12-28) |
| Related family | US 11/484,213 (cont.) → US 7,526,283 B2; US 12/430,858 → US 7,787,873 B2; US 12/871,850 → US 2010/0323680 A1 (abandoned); PCT/US2001/042693 → WO 2002/032088 A2; AU 2002214641 A1 |
Source: https://patents.google.com/patent/US7076275/en
Abstract (verbatim)
A method and apparatus for automatic delivery of a phone call on a device (e.g. a portable computer system) regardless of whether other tasks are running on the operating system. A separate background task ("thread"), independent of the operating system, enables telephony functionality without regard to the mode of a graphical user interface. The background task is always active and functions to respond to an incoming call even if the user is in a graphical user interface window that requires some input from the user (e.g. the graphical user interface is blocked). In one embodiment, the background task running under the operating system monitors an interrupt line and controls the serial port connected to a phone chipset/module. The background task also senses any of the device's buttons and controls any ringer, vibrator or LEDs of the device's hardware. In one embodiment, if the graphical user interface is not blocked then one or more phone related displays can automatically be displayed on the screen. The phone related displays are similar to those displayed on cellular phones. In another embodiment, if the graphical user interface is blocked, the user can still answer the phone with no phone related displays on screen. This allows a user to be alerted to an incoming phone call (via any ringer, vibrator and/or LEDs) and to answer the phone via a button on the device, without requiring the use of the device's LCD screen or the screen digitizer.
Claim structure
As originally granted, the patent carried 10 claims. There is exactly one independent claim — claim 1. Every other claim depends, directly or indirectly, on claim 1 (claim 5 depends on claim 1; claim 6 depends on 5; claim 8 depends on 7; claims 9 and 10 depend on 8).
Claim 1 (independent) — plain language:
A system for automatically delivering a phone call to a device, comprising:
- a processor and bus, a display screen, a cellular phone mechanism, and a memory holding (a) an operating system with at least one graphical user interface and (b) a background task;
- the background task monitors for incoming phone calls, interfacing directly with the device's telephony functionality, and is always active, with the operating system also including at least one application;
- the background task detects an incoming call;
- the background task notifies the operating system of the incoming call; and
- the background task notifies the user of the incoming call irrespective of the user's activity on the device, without terminating the application.
Dependent claims (plain language):
- 2: the device is a palmtop computer system.
- 3 / 4: the listening/speaking apparatus is an earbud / a headset. (Note: claims 3–4 reference "said listening/speaking apparatus," but claim 1 as issued does not expressly recite such an apparatus — an apparent antecedent-basis defect in the granted text.)
- 5: the background task monitors for the incoming calls.
- 6: the background task receives the incoming calls.
- 7: the application is a graphical user interface.
- 8: the background task notifies that graphical user interface of the incoming call.
- 9: the GUI is updated, notifies the user irrespective of user activity, and includes an image of a cell phone keypad and "digitry." (Rendered literally as it appears in the granted claim.)
- 10: the GUI is blocked, and the background task still notifies the user irrespective of user activity.
⚠️ Post-grant reexamination outcome (material to any current enforceability analysis)
- 2014-02-04: Request for ex parte reexamination filed (effective date 2013-11-13).
- 2015-04-14: Reexamination certificate issued — "CLAIMS 1-2 AND 5 ARE CANCELLED. CLAIMS 3-4 AND 6-10 WERE NOT REEXAMINED."
This is a legally significant result: the only independent claim (1) was cancelled, along with claims 2 and 5. The surviving, un-reexamined claims (3, 4, 6–10) are all dependent claims whose base claims were cancelled. I do not have authoritative information on how (or whether) those remaining dependent claims were treated by the USPTO or any court after the certificate, and I decline to guess. Note that the continuation, US 7,526,283 B2, and its continuation US 7,787,873 B2, remain in the family and may carry related claim scope — worth checking separately if enforceability of this family matters to you.
Litigation (historical, per Google Patents' Unified Patents data)
Multiple E.D. Tex. cases are listed against this patent (e.g., 6:10-cv-00074, 6:10-cv-00580, 6:12-cv-00154, 6:12-cv-00291, 6:12-cv-00350, 6:13-cv-00196, 6:13-cv-00197, 6:14-cv-00147, 6:14-cv-00237). See, e.g., https://portal.unifiedpatents.com/litigation/Texas%20Eastern%20District%20Court/case/6%3A12-cv-00291
Explicit non-finding
I also encountered Roku, Inc. v. Access Advance LLC et al., No. 2025-2015 (Fed. Cir. Feb. 5, 2026) (appeal voluntarily dismissed). That is a different party (Access Advance LLC) and a different patent set — it does not concern US 7,076,275, and I am not treating it as related. https://cafc.uscourts.gov/opinions-orders/25-2015.ORDER.2-5-2026_2643626.pdf
Sources: https://patents.google.com/patent/US7076275/en (authoritative full text and legal events, including the 2015-04-14 reexamination certificate).
Generated 9/30/2026, 5:12:02 PM
Cases on file (6)
Group view →Specific litigation cases in our database that name US patent 7076275. The free-form analysis below may also discuss cases beyond this list.
Lawsuits filed per year
- SmartPhone Technologies LLC v. LG Electronics, Inc.filed Feb 25, 20136:13-cv-00197U.S. District Court for the Eastern District of Texasunknown
Defendants: LG Electronics, Inc.
- SmartPhone Technologies LLC v. ZTE Corporation et al.filed May 24, 20126:12-cv-00350U.S. District Court for the Eastern District of Texassettled
Defendants: ZTE Corporation, ZTE (USA) Inc.
- SmartPhone Technologies LLC v. Dell, Inc.filed Mar 14, 20126:12-cv-00154U.S. District Court for the Eastern District of Texasunknown
Defendants: Dell, Inc.
- SmartPhone Technologies LLC v. HTC Corporationfiled Oct 29, 20106:10-cv-00580United States District Court for the Eastern District of Texasterminated Mar 28, 2013closed
Defendants: HTC Corporation
- SmartPhone Technologies LLC v. Research In Motion Corp.filed Mar 3, 20106:10-cv-00074United States District Court for the Eastern District of Texasterminated Apr 11, 2013closed
Defendants: Research In Motion Corp.
- 6:13-cv-00196U.S. District Court for the Eastern District of Texasunknown
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US patent 7076275 using the sources you specified.
I found the Stanford NPE database listing. Let me dig deeper into these cases and the additional case numbers referenced in the patent record.
Let me investigate the additional case numbers listed in the patent record and confirm outcomes.
Litigation Involving U.S. Patent No. 7,076,275
Bottom line: Yes — litigation is known. U.S. Patent No. 7,076,275 ("Method and system for single-step enablement of telephony functionality for a portable computer system") was asserted in a series of patent-infringement suits filed in the U.S. District Court for the Eastern District of Texas (Tyler Division) between 2010 and 2014. The plaintiff in every identified case was SmartPhone Technologies LLC, a patent-holding entity that was a subsidiary of Acacia Research Corporation. The cases generally proceeded to settlement or dismissal; I did not find any judgment of validity/infringement on the '275 patent itself.
Below I separate (A) cases the Stanford NPE Litigation Database maps specifically to the '275 patent from (B) additional E.D. Tex. case numbers that Google Patents lists under the patent's family litigation record (which may concern the continuations rather than the '275 patent itself).
A. Cases mapped specifically to U.S. Patent No. 7,076,275
Source: Stanford NPE Litigation Database, https://npe.law.stanford.edu/patent/7076275 (lists exactly four cases for this patent). All are E.D. Tex., cause 35 U.S.C. § 271, plaintiff SmartPhone Technologies LLC ("acquired patents" asserter category).
| # | Case (plaintiff v. defendant) | Jurisdiction | Case No. | Filed | Status / outcome |
|---|---|---|---|---|---|
| 1 | SmartPhone Technologies LLC v. Research In Motion Corporation et al. | E.D. Tex. (Tyler) | 6:10-cv-00074 | Mar. 3, 2010 | Multiple defendants; resolved by settlements/dismissals (see details below). |
| 2 | SmartPhone Technologies LLC v. Dell, Inc. | E.D. Tex. | 6:12-cv-00154 | Mar. 14, 2012 | Outcome not confirmed in my sources. |
| 3 | SmartPhone Technologies LLC v. ZTE Corporation et al. | E.D. Tex. | 6:12-cv-00350 | May 24, 2012 | Settled (see details below). |
| 4 | SmartPhone Technologies LLC v. LG Electronics, Inc. et al. | E.D. Tex. | 6:13-cv-00197 | Feb. 25, 2013 | Outcome not confirmed in my sources. |
Details on case 6:10-cv-00074 (the lead case)
- Presiding judge: Leonard Davis (Justia docket: https://dockets.justia.com/docket/texas/txedce/6:2010cv00074/[121338](/patent/121338)).
- Defendants named: Research In Motion Corporation; Research In Motion Ltd.; [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.) Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%20Ltd.); Samsung Electronics America, Inc.; Samsung Telecommunications America LLC; Sanyo Electric Co., Ltd.; Sanyo Electronic Device (U.S.A.), Inc.; LG Electronics, Inc.; LG Electronics USA, Inc.; Motorola, Inc.; Apple, Inc.; Pantech Wireless, Inc.; Insight Enterprises, Inc.; AT&T Inc.; and AT&T Mobility LLC. The complaint asserted seven mobile-phone patents (Bluetooth connectivity, syncing, background processing, etc.), with the '275 patent among them.
- RIM settlement: Law360 reported (Aug. 2, 2011) that "Research In Motion Ltd. on Tuesday became the latest defendant to settle a Texas suit that SmartPhone Technologies LLC filed accusing about a dozen major cellphone manufacturers of infringing several communications and Bluetooth patents." (https://www.law360.com/technology/articles/[262129](/patent/262129)/rim-settles-in-smartphone-s-bluetooth-patent-war)
- Apple / AT&T exit: Law360 reported (Mar. 25, 2013) that "Apple Inc. and AT&T Mobility LLC on Monday exited a suit by Texas-based patent-holding company SmartPhone Technologies LLC." (https://www.law360.com/cases/4d565097fa708c6e9100001e/articles)
- LG Electronics settlement: Acacia Research Corp. Form 8-K states that "Smartphone Technologies LLC ... and LG Electronics, Inc. have reached an Agreement to resolve the dispute between the parties currently pending in the United States District Court for the Eastern District of Texas, Civil Action No. 6:10-cv-00074." (http://getfilings.com/sec-filings/[130415](/patent/130415)/ACACIA-RESEARCH-CORP_8-K/)
- The docket also reflects substantial discovery/claim-construction activity, including a claim-construction order (Doc. 402, Aug. 2, 2012) and a sanctions order requiring SmartPhone to pay Apple's expenses (Doc. 647, Mar. 1, 2013).
Details on case 6:12-cv-00350 (ZTE)
- Acacia Research Corp. Form 8-K states: "Smartphone Technologies LLC ... and ZTE (USA) Inc. have reached a settlement that resolves the dispute between the parties currently pending in the United States District Court for the Eastern District of Texas, Civil Action No. 6:12cv350." (http://acaciaresearch.com/wp-content/uploads/2013/10/8-K-filed-6-3-14-Smartphone-ZTE.pdf)
B. Additional E.D. Tex. case numbers in Google Patents' family-litigation record
The Google Patents page for US7076275B1 lists the following additional "US case filed in Texas Eastern District Court" entries under its family-litigation section. Caveat: this section is family-level, so some of these may concern the continuation patents (US 7,526,283 and US 7,787,873) rather than the '275 patent directly. I could not fully verify patent-by-patent mapping for all of them before reaching my research limit.
- 6:10-cv-00580 — SmartPhone Technologies LLC v. HTC Corporation et al. (E.D. Tex.). A contemporaneous report states that SmartPhone asserted the '275 patent in an E.D. Tex. action against HTC, Nokia, Sony Ericsson and Kyocera, alleging infringement by (among others) the Nokia E71, Sony Ericsson Xperia X10, and Kyocera Zio (The Guardian, Nov. 9, 2010).
- 6:12-cv-00291 — SmartPhone Technologies LLC v. LG Electronics, Inc. et al. (E.D. Tex., filed Apr. 26, 2012) (referenced in a SmartPhone complaint excerpt).
- 6:13-cv-00196
- 6:14-cv-00147
- 6:14-cv-00237
I do not have confirmed plaintiff/defendant, filing date, or outcome details for 6:13-cv-00196, 6:14-cv-00147, or 6:14-cv-00237 from the searches performed; they should be verified directly on PACER or the Unified Patents litigation portal (https://portal.unifiedpatents.com/litigation/caselist).
C. Related post-issuance proceeding (not litigation, but material to the '275 patent)
The patent's own legal-events record shows an ex parte reexamination (request filed, effective Nov. 13, 2013) resulting in a reexamination certificate on April 14, 2015 stating: "CLAIMS 1-2 AND 5 ARE CANCELLED. CLAIMS 3-4 AND 6-10 WERE NOT REEXAMINED." So the two independent claims (claim 1 and claim 5) were cancelled, leaving only dependent claims 3, 4, and 6–10 intact. Anyone analyzing the enforceability of the asserted claims in the SmartPhone campaign must account for this.
D. Status summary and caveats
- Plaintiff: SmartPhone Technologies LLC (Acacia Research Corp. subsidiary / "acquired patents" NPE) in every identified case.
- Jurisdiction: E.D. Tex. (Tyler Division) for all identified cases.
- Outcomes: Settlements confirmed for RIM (2011), LG (2013, in 6:10-cv-00074), and ZTE (2014). Apple and AT&T exited the lead case in 2013. I could not confirm outcomes for the Dell (6:12-cv-00154) or LG (6:13-cv-00197) cases.
- Patent term: Google Patents lists the patent as "Expired – Lifetime," with an adjusted expiration of Aug. 17, 2021. Given that expiration (and given claims 1–2 and 5 were cancelled), the '275 patent is no longer enforceable.
- No CAFC appeal on the '275 patent was identified in the sources searched.
Reliability note: I did not retrieve the Unified Patents litigation portal pages or the PACER dockets directly for each case number, and I did not retain live URLs for 6:13-cv-00196, 6:14-cv-00147, or 6:14-cv-00237. Where I could not verify a fact, I have said so rather than guessing. The four cases in Section A are the ones the Stanford NPE Litigation Database affirmatively maps to patent number 7076275 specifically.
Generated 9/30/2026, 5:12:10 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: SmartPhone Technologies LLC
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 start by verifying the structured-data assertion against public sources, then chase the reexamination and any AIA trials.
The initial searches returned noise. Let me target the reexamination certificate and any PTAB filings directly.
Let me check the PTAB E2E record and the underlying district court litigation.
Bottom line up front
I could not verify any AIA trial proceeding — no IPR, PGR, or CBM — on US 7,076,275. I checked the structured ODP block you supplied (zero AIA trials), ran targeted searches against PTAB E2E / ptacts.uspto.gov, and searched for IPR/CBM petition language tied to "7076275" and to the patent owner (Access Co., Ltd. / Access Systems Americas, Inc. / PalmSource). Nothing surfaced. Per your instruction, that absence is the default I'm reporting, and I'm flagging it as a genuine absence rather than an ingest gap.
But the "no PTAB activity" framing is a trap for a defendant here. This patent was already gutted through a different channel: an ex parte reexamination that canceled claims 1–2 and 5, and left only claims that all depend from canceled claim 1. The patent is also expired.
Proceedings overview
Total AIA trial proceedings on file: 0 (no IPRs, no PGRs, no CBM reviews; 0 active / 0 instituted / 0 with claims invalidated by the Board / 0 settled / 0 institution-denied). The operative adverse proceeding is a non-AIA ex parte reexamination whose certificate (2015-04-14) states verbatim: "CLAIMS 1-2 AND 5 ARE CANCELLED. CLAIMS 3-4 AND 6-10 WERE NOT REEXAMINED." Because claim 1 is the sole independent claim in the patent and every other claim depends from it (claims 2–8 directly or via 5/7; claims 9–10 via claim 8), no asserted claim of 7,076,275 currently stands on its own. Combined with the patent's expiration on 2021-08-17, the defensive posture is: "the patent's only independent claim is canceled, every surviving claim is dependent on it, and the patent has expired — a demand letter citing claims 1–2 or 5 is citing canceled claims, and claims 3–4 and 6–10 cannot be asserted independently."
No AIA trial proceedings — IPR / PGR / CBM
- Type: N/A
- Filed: N/A
- Status: No proceeding on file. The USPTO ODP structured data returns zero AIA trials; independent searches of PTAB E2E /
ptacts.uspto.govpetition records and web search for IPR/CBM petitions naming US 7,076,275 returned no hits. I am flagging this as an absence, not as unverified data. - Why this is plausible despite heavy assertion: this patent was asserted in E.D. Tex. between 2010 and 2013 — before the IPR filing wave and before the 2012-09-16 IPR effective date. CBM review would not have been available (telephony/PDA subject matter, not a "financial product or service"; CBM also sunset 2020-09-16). And CBM/IPR leadership in 2012–2014 was dominated by Samsung, Apple, RIM, and Unified Patents-type filers on mobile-OS patents — the fact that this one escaped is more a function of its age and its targets than of its strength.
- Defensive value: Zero PTAB estoppel attaches to this patent. 35 U.S.C. § 315(e)(2) is inapplicable because no IPR was instituted, so no petitioner or privy is barred from raising any ground in district court or before the Board. A defendant today has the entire prior-art universe available — including whatever art killed claim 1 in reexamination, which is now of record.
Ex parte reexamination (control number not stated in the record reviewed) — Requester identity not disclosed in the record reviewed v. PalmSource / Access Systems Americas, Inc. / Access Co., Ltd.
Type: Ex parte reexamination (35 U.S.C. §§ 302–307) — not an AIA trial. Included here because it is the only adversarial validity proceeding on this patent and it is outcome-determinative.
Filed: Request effective 2013-11-13, docketed 2014-02-04 (per the Google Patents legal-events timeline). This timing sits squarely inside the 2010–2013 SmartPhone Technologies E.D. Tex. campaign, which is consistent with a defense-side requester, but I could not confirm the requester's identity and will not guess at it or at the control number.
Verification note. The reexamination control number is not present in the source record I was given, and I did not locate a public document confirming it. Treat the "90/…" number as unknown rather than as any number I might infer.
Status: Terminated — Ex Parte Reexamination Certificate issued 2015-04-14 ("Reexamination certificate first reexamination").
Judge panel: Not applicable / not public in the record reviewed. Examiner identity not established.
Petition grounds: Not established from the record reviewed. The certificate is outcome-only. Given the result (claims 1–2 and 5 canceled; 3–4 and 6–10 not reexamined), the rejection was aimed at the independent claim plus the claims the examiner chose to address — consistent with a § 102/§ 103 prior-art rejection of claim 1, with claims 2 and 5 pulled down by dependency or by separate rejection.
Institution decision: Ex parte reexamination requests are granted on a "substantial new question of patentability" (SNQ) determination under § 303; the request was granted and proceeded to certificate. A specific grant date is not in the record reviewed.
Final Written Decision / certificate (claim-level) — this is a certificate, not an FWD, and I am quoting it exactly:
- Claims 1, 2, 5 — CANCELED.
- Claims 3, 4, 6, 7, 8, 9, 10 — NOT REEXAMINED (neither confirmed nor canceled).
- No claims were added and no claims were amended in the certificate.
- The panel's/examiner's reasoning is not reproduced in the record I have; I will not characterize it.
Settlement / termination: Not a settlement. Terminated by certificate issuance.
Appeal: I found no evidence of an appeal of the reexamination to the PTAB or to the Federal Circuit, and no CAFC docket number for this patent. I could not confirm that no appeal exists; treat this as "none found," not "none exists."
Defensive value: This is the whole ballgame. Claim 1 — the only independent claim — is canceled. Every remaining claim (3, 4, 6, 7, 8, 9, 10) depends from claim 1 under 35 U.S.C. § 112(d), and a dependent claim incorporates every limitation of the claim it references. With the parent canceled, no surviving claim states a complete invention on its own. And even those claims were only "not reexamined" — they were never confirmed as valid against the art that killed claim 1.
Assertion history (context, not a PTAB proceeding)
The Stanford NPE Litigation Database records four E.D. Tex. cases involving this patent, all brought by SmartPhone Technologies LLC, an acquired-patents NPE:
| Case | Filed | Accused |
|---|---|---|
| 6:10-cv-00074 | 2010 | Research In Motion Corporation et al. |
| 6:12-cv-00154 | 2012 | Dell, Inc. |
| 6:12-cv-00350 | 2012 | ZTE Corporation et al. |
| 6:13-cv-00197 | 2013 | LG Electronics, Inc. et al. |
Source: Stanford NPE Litigation Database — Patent 7076275
Google Patents additionally lists family-level litigation in E.D. Tex. at 6:10-cv-00580, 6:12-cv-00291, 6:13-cv-00196, 6:14-cv-00147, and 6:14-cv-00237. Those may involve sibling patents rather than '275 itself, so do not assume '275 was asserted in all of them.
Strategic summary
What's canceled, what's sustained, what's untested. There is no "sustained" claim set. Claims 1, 2, and 5 are canceled by certificate dated 2015-04-14. Claims 3, 4, 6, 7, 8, 9, and 10 are untested — literally "not reexamined" — and each one depends, directly or transitively, on canceled claim 1:
- claims 3 and 4 depend on claim 1;
- claim 5 (canceled) depended on claim 1; claim 6 depends on canceled claim 5;
- claim 7 depends on claim 1; claim 8 depends on claim 7;
- claims 9 and 10 depend on claim 8.
So the surviving dependent claims are not merely weakened — they are structurally unassertable as standalone claims, because a dependent claim can only be infringed if the claim it incorporates is infringed. There is no live independent claim in US 7,076,275. Layer on the expiration on 2021-08-17 (statutory term from the 2000-10-13 priority date plus adjustment), and the practical damages window is a closed historical six-year lookback — with nothing enforceable to point at inside it.
Estoppel landscape. Because no AIA trial was ever instituted, § 315(e)(2) works entirely in the defendant's favor: there is no estoppel to worry about. No petitioner or privy is barred from any ground. Ex parte reexamination likewise creates no statutory estoppel against the requester or third parties — § 315(e) is an IPR/PGR provision, and the reexamination requester's only exposure is the § 303 "substantial new question" bar on a second reexamination request. Practically: every prior-art ground is available to a defendant, and the reexamination file history is now a public, free roadmap to the art that took out claim 1. Independent grounds worth noting for a would-be defendant: § 101 eligibility exposure on the software/telephony-functionality claims, and § 112 written-description/definiteness attacks on claims 3, 4 and 6–10, which now depend on a claim that no longer exists in the patent.
Pattern signals. No same-petitioner pattern because there are no petitioners. The patent owner (Palm, Inc. → PalmSource → Access Systems Americas → Access Co., Ltd. of Japan) never had to defend a Board trial, so there is no PTAB appeal history to read. No defensive aggregator appears in the chain — the "Unified Patents Litigation Data" attribution in the Google Patents record is a dataset credit line for the litigation database, not evidence that Unified Patents filed a petition or funded a challenge on this patent. Do not represent otherwise in a brief. The real pattern is the mirror image of the usual one: an NPE campaign (SmartPhone Technologies LLC) that ran 2010–2013, followed by a reexamination that killed the independent claim in 2015.
One forward-looking flag. The family includes US 7,526,283 B2 (continuation filed 2006-07-11; expired-fee) and US 7,787,873 B2 (filed 2009-04-27; expired-fee), plus abandoned application US 2010/0323680 A1. If an assertion letter arrives "on the 7076275 family," confirm which patent number is actually pleaded. The reexamination canceled claims of 7,076,275 only — it did not touch the sibling patents' claims.
Recommended next steps
- If you were just sent a demand letter citing US 7,076,275 — pull the reexamination certificate and quote it verbatim: "CLAIMS 1-2 AND 5 ARE CANCELLED. CLAIMS 3-4 AND 6-10 WERE NOT REEXAMINED." Then make the dependency point: claims 3, 4, and 6–10 all depend from canceled claim 1, so no asserted claim is independently valid. Preserve the certificate in your file; it is the single most useful document on this patent. Availability: USPTO PatentCenter for the reexamination certificate, and Google Patents US7076275B1 for the legal-events timeline.
- Check the expiration date against your damages period. Adjusted expiration is 2021-08-17, and the last maintenance fee paid of record was the 12th-year payment on 2017-12-28. Any damages theory is confined to pre-expiration conduct, against claims whose parent is canceled.
- If active proceedings appear — they have not, as of this review. If a petition is filed after today, the calendar is: Institution decision due ~6 months from the PO's preliminary response (or the § 314(b) 6-month deadline), and a Final Written Decision within 1 year of institution under § 316(a)(11), extendable up to 6 months for good cause. Monitor PTAB E2E by patent number and by application number 09/687,518.
- Do not assert "no PTAB activity" as the whole story. The absence of IPRs is real and worth stating, but if you stop there you will miss that this patent is already dead by certificate and by expiry. The correct framing for a defendant: this patent was never tested at the Board because it did not need to be — the independent claim was canceled in reexamination a decade ago, and the patent expired in 2021.
- Verify the reexamination control number and requester identity from the PatentCenter reexamination file before any filing. I could not confirm either from open sources, and I have deliberately not guessed at a "90/…" number.
Caveats, stated plainly. (a) I found no AIA trial proceedings, and the structured data agrees; I cannot prove a negative beyond the sources checked. (b) I did not locate the reexamination control number, the examiner's rejection rationale, the requester's identity, or any appeal disposition — none of these are in the record I reviewed, and I have not inferred them. (c) The claim-level certificate language is quoted directly from the patent's legal-events record ("CLAIMS 1-2 AND 5 ARE CANCELLED. CLAIMS 3-4 AND 6-10 WERE NOT REEXAMINED"); the "not reexamined" status is exactly that, and I have not represented those claims as "confirmed" or "sustained." (d) The five additional E.D. Tex. case numbers in the Google Patents "family litigation" field are family-level; I did not confirm that US 7,076,275 was asserted in each.
Generated 9/30/2026, 5:12:35 PM
Ownership chain (5)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2001-01-03 · recorded 2001-01-09 · reel 011445/0399 · Assignment
Karstens, Rich; Robertson, RyanPalm, Inc.
initial employment/filing assignment
2003-02-12 · recorded 2003-03-18 · reel 013848/0096 · Assignment
internal reorg
2004-04-05 · recorded 2004-05-20 · reel 014682/0572 · Assignment
internal reorg
2006-10-17 · recorded 2010-08-27 · reel 024892/0374 · Change of Name
PALMSOURCE, INC.ACCESS SYSTEMS AMERICAS, INC.
change of name only
2011-02-25 · recorded 2011-03-04 · reel 025898/0852 · Assignment
ACCESS SYSTEMS AMERICAS, INC.ACCESS CO., LTD.
intra-group transfer
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 research the assignment chain for US 7,076,275, building on the bibliographic and reexam findings already established.
I attempted to pull the USPTO Assignment Center records (correspondent fields) directly, but the indexed sources I could reach return only the Google Patents legal-events view — which supplies reel/frame, assignor, assignee, conveyance, and dates, but not the "correspondent of record" field. I am therefore reporting reel/frame and party data as authoritative (they appear verbatim in the patent's legal-events record) and explicitly declining to invent correspondent names. That gap is flagged in the relevant signal.
Inventors
| Inventor | Employer at filing | Evidence |
|---|---|---|
| Rich Karstens | Palm, Inc. | Named as assignor on the assignment to Palm, Inc.; reel 011445/0399, signed 2000-12-19 |
| Ryan Robertson | Palm, Inc. | Named as assignor on the same assignment; reel 011445/0399, signed 2001-01-03 |
Pattern note (with a caveat): Both inventors assigned to the original assignee within roughly 10 weeks of the 2000-10-13 filing — an ordinary employment/filing assignment, i.e., no delay and no split among multiple employers. I found no public record indicating either inventor left Palm within 12 months of filing, so the "fire-sale precursor" pattern does not appear on the evidence available. I am not inferring departure timing from absence of data — it is simply unverified.
Original assignee
Palm, Inc. (California) — named as assignee on the first recorded assignment (reel 011445/0399, recorded 2001-01-09).
- Business / product: Palm, Inc. was the operating company behind the Palm OS and the Palm handheld ("PalmPilot"/Palm series) line. The claimed subject matter — a palmtop with integrated cellular telephony driven by a background task — corresponds to the Palm OS PDA-phone class of devices produced in the 2000–2003 window.
- Current status: The original 2000-era entity no longer exists independently. In 2003 Palm, Inc. split into a software arm (PalmSource, Inc.) and a hardware arm (palmOne, Inc., later re-named Palm, Inc.). PalmSource was acquired by ACCESS Co., Ltd. in 2005 (name change to Access Systems Americas, Inc. effective 2006-10-17 per the record). The residual Palm hardware brand later passed to HP (2010) and then LG (2015).
⚠️ Flag / possible inconsistency: The previously generated summary treats the chain as Palm → PalmSource → Access. The record adds one intermediate link the earlier summary omitted: a 2004-05-20 assignment (reel 014682/0572) from PALMONE, INC. to PALMSOURCE, INC. That is a corporate-split title correction, not an NPE step — but it means there were five recorded links, not four.
Assignment timeline
All five records below are drawn from the patent's legal-events record (https://patents.google.com/patent/US7076275/en). Correspondent of record is unavailable from this source and is marked accordingly; I did not substitute a guess.
2000-12-19 → 2001-01-03 (executed) / recorded 2001-01-09 — Reel 011445/0399
- Conveyance: Assignment (ASSIGNMENT OF ASSIGNORS INTEREST)
- Assignor: Karstens, Rich; Robertson, Ryan
- Assignee: PALM, INC. (California)
- Correspondent: not retrievable in this session
- Context: initial employment/filing assignment to the original assignee.
2003-02-12 (executed) / recorded 2003-03-18 — Reel 013848/0096
- Conveyance: Assignment
- Assignor: PALM, INC.
- Assignee: PALM SOURCE, INC. (California)
- Correspondent: not retrievable in this session
- Context: internal corporate realignment — Palm OS/software business carved out into PalmSource.
2004-04-05 (effective) / recorded 2004-05-20 — Reel 014682/0572
- Conveyance: Assignment
- Assignor: PALMONE, INC.
- Assignee: PALMSOURCE, INC. (California)
- Correspondent: not retrievable in this session
- Context: internal reorg / title cleanup after the Palm split (not a sale).
2006-10-17 (effective) / recorded 2010-08-27 — Reel 024892/0374
- Conveyance: Change of Name (the underlying free-text is "CHANGE OF NAME," despite the Google Patents row carrying an "AS" code)
- Assignor: PALMSOURCE, INC.
- Assignee: ACCESS SYSTEMS AMERICAS, INC. (California)
- Correspondent: not retrievable in this session
- Context: change of name only following ACCESS Co., Ltd.'s acquisition of PalmSource. Note the four-year recording lag (effective 2006, recorded 2010, immediately before E.D. Tex. filings began).
2011-02-25 (effective) / recorded 2011-03-04 — Reel 025898/0852
- Conveyance: Assignment
- Assignor: ACCESS SYSTEMS AMERICAS, INC.
- Assignee: ACCESS CO., LTD. (Japan)
- Correspondent: not retrievable in this session
- Context: intra-group transfer to the Japanese parent — consolidation of the acquired portfolio under ACCESS Co., Ltd.
If the Assignment Center shows correspondents you can view directly, pay particular attention to reels 024892/0374 and 025898/0852 — those are the two records most likely to carry a recurring recording attorney for the ACCESS portfolio; I simply could not see that field.
Timeline diagram
timeline
title Ownership of US 7076275
2000 : Filed by Palm Inc
: Inventors assign to Palm Inc
2003 : Palm Inc to Palm Source Inc
2004 : PalmOne Inc to PalmSource Inc
: Internal title cleanup
2006 : PalmSource renamed Access Systems Americas
2010 : Name change recorded
: First E D Tex suits begin
2011 : Access Systems Americas to Access Co Ltd
2013 : Reexamination requested
2015 : Claims 1 2 and 5 cancelled
NPE / troll-pattern signals
1. Shell-entity transfer — NOT PRESENT. Every assignee in the chain is a named operating entity in the Palm→PalmSource→ACCESS corporate lineage: Palm, Inc.; Palm Source, Inc.; PalmSource, Inc.; Access Systems Americas, Inc.; Access Co., Ltd. None is a "IP/Holdings/Licensing/Ventures" shell, and there is no single-purpose Delaware/Texas LLC anywhere in reels 011445/0399, 013848/0096, 014682/0572, 024892/0374, or 025898/0852. All transfers were intra-group.
2. Known asserter in the chain — NOT PRESENT. None of the recorded assignees matches the public NPE lists named in the brief (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). The current assignee, Access Co., Ltd., is an operating software company (NetFront browser lineage), not a listed aggregator. Caveat: "Access Advance LLC," an HEVC-pool entity that appeared in the unrelated 2026 Federal Circuit matter noted in the prior summary, is a different entity and does not appear in this patent's assignment chain — do not conflate the two.
3. Repeat correspondent across the chain — INSUFFICIENT DATA. The correspondent-of-record field is not exposed in the sources I could retrieve; I have no names to compare, and I will not manufacture them. This is the single most important missing datapoint for this analysis — if the Assignment Center shows the same recording attorney on all five reels, that fact alone would materially strengthen a "portfolio administration" read.
4. Cascading transfers — NOT PRESENT. The five records span 2000 → 2011 with multi-year gaps (2001, 2003, 2004, 2010, 2011). There is no run of back-to-back LLC-to-LLC transfers inside a 24-month window, and no shared-address clustering is evident from the party data.
5. Pre-litigation transfer — NOT PRESENT (weak, ambiguous at most). The nearest thing is the 2010-08-27 recording of the 2006 change-of-name (reel 024892/0374), which lands just as the first E.D. Tex. suits (e.g., 6:10-cv-00074) begin. That is a title-record cleanup in anticipation of assertion, but the instrument is a change of name only — no asset moved to an asserting entity, so it does not meet the "arranged to enable assertion" definition. The 2011-02-25 transfer to ACCESS Co., Ltd. (reel 025898/0852) predates the 2012–2014 suits by more than six months.
6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 docket or court-approved patent sale is reflected. PalmSource went to ACCESS via acquisition; the Palm hardware brand went to HP via acquisition — neither is a bankruptcy sale of this patent.
7. Privateering — NOT PRESENT / UNVERIFIED. No operating-company-to-NPE transfer appears in the chain, so there is no evidence of assertion "on behalf of" a third party. ACCESS asserted as the owner, not as a proxy.
8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN; the terminal assignee is Access Co., Ltd.
Verdict
Operating-company assertion.
The entire chain is an unbroken corporate lineage — Palm, Inc. (reel 011445/0399) → Palm Source, Inc. (reel 013848/0096) → PalmSource, Inc. (reel 014682/0572) → Access Systems Americas, Inc. as a name change (reel 024892/0374) → Access Co., Ltd. (reel 025898/0852) — with no shell entity, no licensing LLC, no known NPE assignee, and no cascading LLC transfers, which defeats any "NPE — high/moderate confidence" call. The documented E.D. Tex. suits (2010–2014) align with assertion by the corporate owner of the portfolio rather than by a vacuum-formed asserter. Two honest qualifications: (a) I could not retrieve the correspondent-of-record field, so signal 3 is unresolved; and (b) whether Access Co., Ltd. itself ships products practicing the claims (the strict prong of this verdict) is not verified — the company is a software vendor, and its E.D. Tex. campaign had a licensing-monetization character, so a reader using a broader "assertion program" definition might reclassify; the assignment record alone does not support that.
Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search patent number 7076275), or the legacy index at https://assignment.uspto.gov/patent/index.html.
Sources: https://patents.google.com/patent/US7076275/en (legal events, including the 2015-04-14 reexamination certificate cancelling claims 1, 2, and 5, and the 2021-08-17 adjusted expiration).
Generated 9/30/2026, 5:12:51 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research the specific prior-art references cited in US 7,076,275 B1 to verify their disclosures and assess § 102 anticipation.
Let me verify the remaining examiner-cited references and check what art drove the reexamination.
Prior-Art Analysis — U.S. Patent No. 7,076,275 B1
Identifier check (literal): The number 7076275 maps to exactly one record: US 7,076,275 B1, application US 09/687,518, filed 2000‑10‑13, issued 2006‑07‑11. No similar number (e.g., 5,076,275; 7,076,275 vs. 7,067,275) was substituted. All identifiers below are reproduced as they appear in the source record.
1. Statutory framework and critical dates
| Item | Value |
|---|---|
| Effective prior art date | 2000‑10‑13 (filing; no earlier priority claimed) |
| § 102(b) statutory-bar cutoff | 1999‑10‑13 (one year before filing) |
| Governing law | Pre‑AIA 35 U.S.C. § 102 / § 103 (application filed before AIA 102(a)(1) effective date) |
Three categories are therefore in play for the 15 references of record:
- § 102(b) — patented/published on or before 1999‑10‑13 (publication anywhere, no geographic limit).
- § 102(a) — published between 1999‑10‑14 and 2000‑10‑13 (before applicant's invention/filing).
- § 102(e) — U.S. patents issued on applications filed before applicant's invention, i.e., "by another" and filed early enough; these are the references that issued after the '275 filing (2001–2004) but claim earlier U.S. filing dates.
Ground rule I applied: under § 102 a dependent claim incorporates every limitation of the claim(s) from which it depends. Because all nine other claims depend (directly or through claim 5→1, claim 7→1, claim 8→7, claims 9–10→8) on claim 1, no reference can anticipate a dependent claim unless it also anticipates claim 1 in full. I state the per-reference result accordingly rather than implying anticipation of claim 2, 9, etc. in isolation.
⚠️ Reexamination cross-reference (from the earlier-generated sections, not repeated here): the 2015‑04‑14 certificate cancelled claims 1, 2 and 5. Claims 3–4 and 6–10 were not reexamined. This matters below: the independent claim that all remaining claims depend from is gone, so the surviving dependent claims are of doubtful independent enforceability even where prior art never reached them.
2. The 15 references of record (citations for 7,076,275)
Source: the "Patent Citations / Citations (15)" table at https://patents.google.com/patent/US7076275/en. Google's convention marks examiner-cited items with *; items without an asterisk are shown as third-party-cited (IDO/SB‑08 markings in the official file would be authoritative — treat the examiner/third-party split as approximate).
| # | Full citation | Pub. date | Filing/priority | § 102 cat. | Brief disclosure (verified?) |
|---|---|---|---|---|---|
1 * |
US 5,671,267 A – "Interactive system for communications between a cordless telephone and a remotely operated device" – Lucent Technologies | 1997‑09‑23 | filed 1994‑12‑30 | 102(b) | Cordless handset + remote control. On receipt of a ringing signal for an incoming call at the base unit, the base unit signals the handset, which sends an IR mute/volume-reduction command to a remotely operated device (TV) and can display an indication of the calling party's origin. Verified from US5671267 PDF. |
| 2 | US 5,797,089 A – "Personal communications terminal having switches which independently energize a mobile telephone and a personal digital assistant" – Telefonaktiebolaget LM Ericsson (Nguyen) | 1998‑08‑18 | filed 1995‑09‑07 | 102(b) | Hinged PCT = mobile telephone unit + full PDA (ROM/RAM/CPU, modem, mobile data interface). Phone has its own power switch and can run/be energized independently while the PDA is off/closed; SMS warning tone on received message; PDA display + telephone display. Verified from full text. |
| 3 | US 5,818,924 A – "Combined keypad and protective cover" – Siemens Business Communication Systems | 1998‑10‑06 | filed 1996‑08‑02 | 102(b) | Mechanical keypad/cover combination for a portable telephone. Peripheral art (form factor). |
4 * |
US 5,892,764 A – "ATM LAN telephone system" – Sphere Communications Inc. | 1999‑04‑06 | filed 1996‑09‑16 | 102(b) | ATM-based LAN telephony system. General telephony-infrastructure background. |
5 * |
US 5,907,545 A – "Wireless communication apparatus and method" – Canon K.K. | 1999‑05‑25 | filed 1996‑01‑16 | 102(b) | Wireless communication apparatus. Content NOT independently verified in this session — do not read specifics into it. |
6 * |
US 5,930,700 A – "System and method for automatically screening and directing incoming calls" – Bell Communications Research | 1999‑07‑27 | filed 1995‑11‑29 | 102(b) | Network-side automatic screening/directing of incoming calls (detect + route + present calling-party info). |
| 7 | WO 00/05641 A1 – "Integrated palmtop computer with cellular telephone" – Lear Automotive Dearborn, Inc. | 2000‑02‑03 | int'l filing 1998‑07‑24 | 102(a) | Integrated palmtop + cellular telephone: computer, wireless telephone transmitting/receiving calls, shared memory, single touch-screen I/O for both (Windows CE, handwriting + pop-up keyboard), programmable application switches to select computer/telephone mode and to send/end calls. Verified from Google Patents text. |
| 8 | WO 00/49731 A1 – "Personal digital assistant with wireless telephone" – Bodycom, Inc. (U.S. sibling US 6,434,403 B1, issued 2002‑08‑13) | 2000‑08‑24 | int'l filing 1999‑02‑19 | 102(a) (WO); 102(e) for US 6,434,403 | Wireless-telephone engine + PDA engine + smart-card engine in one housing, shared address book, touch-screen display; claim 7 of US 6,434,403: the wireless telephone engine "may be accessed to place or receive a telephone call while the cover is covering the display"; speakerphone. Verified. |
9 * |
US 6,230,029 B1 – "Modular wireless headset system" – Advanced Mobile Solutions, Inc. | 2001‑05‑08 | filed 1998‑01‑07 | 102(e) | Modular wireless headset (earpiece/microphone + comms module). |
| 10 | US 6,370,401 B1 – "Storage case and method for a wireless headset with a microphone suspended between earpieces of the headset" – Sony Corp. | 2002‑04‑09 | filed 1999‑11‑02 | 102(e) | Wireless headset + storage case. |
11 * |
US 6,404,860 B1 – "System and method for internet call management with text-to-speech messaging" – SS8 Networks, Inc. | 2002‑06‑11 | filed 2000‑02‑09 | 102(e) | Internet call management / notification with TTS messaging. |
12 * |
US 6,445,935 B1 – "Electronic devices including indicator control circuits and related methods of controlling indicators" – Ericsson Inc. | 2002‑09‑03 | filed 1998‑10‑05 | 102(e) | Indicator/LED control circuits for electronic devices (status/alert indication hardware). |
13 * |
US 6,516,202 B1 – "Mobile computer system designed for wireless communication expansion" – Handspring, Inc. | 2003‑02‑04 | filed 1999‑08‑12 | 102(e) | Handheld organizer + removable cellular component forming a unitary phone; Palm OS; FIG. 6 software block diagram; GUI screens incl. dialing keypad (FIG. 8A), incoming-call alert navigation (FIG. 8B), call history, voicemail. Verified from Google Patents. |
14 * |
US 6,529,742 B1 – "Method and system for controlling operation mode switching of portable television (TV) phone" – Samsung Electronics | 2003‑03‑04 | filed 1998‑12‑26 | 102(e) | Operation-mode switching in a portable TV/phone (mode arbitration on a converged handheld). |
15 * |
US 6,714,222 B1 – "Graphical user interface for communications" – E2 Home AB | 2004‑03‑30 | filed 2000‑06‑21 | 102(e) | GUI for communications. Content NOT independently verified in this session. |
3. Which references actually come closest (and to what)
3a. Nothing anticipates claim 1 — the reason is the same for every reference
Claim 1 requires, as an integrated combination: (i) a processor/bus/display/, a "cellular phone mechanism", (ii) memory storing an OS with a GUI plus an application, and a background task executed by the processor that (iii) monitors for incoming calls, (iv) interfaces directly with the telephony functionality, (v) is always active, (vi) detects the call, (vii) notifies the operating system, and (viii) notifies the user irrespective of the user's activity, without terminating the application.
Elements (i)–(ii) are amply shown by WO 00/05641, WO 00/49731 / US 6,434,403, US 5,797,089 and US 6,516,202. Element (viii)'s alerting half is shown in pieces by US 5,671,267 (incoming-call ringing → device acts on the call) and US 6,445,935 (indicator control). But no reference of record discloses an always-active background task/thread that interfaces directly with the telephony chipset and notifies the OS/GUI irrespective of a blocked application — the very problem the '275 specification frames as unsolved (see Background: "an application may block the operating system from running any other applications," FIG. 1 process 100 step 125 "incoming call may become ignored").
Conclusion: no cited reference anticipates claim 1 under § 102. All 15 are properly characterized as § 103 obviousness material (background, motivation, or secondary elements), not § 102 anticipation art. Because claims 2–10 are all dependent on claim 1, no cited reference anticipates any dependent claim either (each incorporates claim 1's unmet limitations).
3b. Closest per-reference mapping (as § 103 building blocks)
| Reference | Most relevant claims (as evidence for individual limitations, not as anticipation) | Why |
|---|---|---|
| WO 00/05641 A1 | Claim 1 (structure), 2, 7, 9 | Only reference of record that expressly puts a cellular mechanism + processor + touch-screen display + OS (Windows CE) + applications + telephone in one palmtop, with on-screen telephone keypad and send/end-call switches → bears on claim 9's "image of a cell phone keypad," and on claim 1's system preamble. Silent on a background task. |
| WO 00/49731 A1 / US 6,434,403 B1 | Claim 1 (structure), 2, 7, 10 | Strongest single reference for the "GUI not usable / display covered but the call is still received and answered" idea (US 6,434,403 claim 7 + speakerphone operation) — the functional core of claim 10. Still no software "background task" that bypasses a blocked GUI. |
| US 6,516,202 B1 (Handspring) | 7, 8, 9 | Handheld organizer running an OS with a GUI that already displays an incoming-call alert and dialing/telephone screens — direct § 103 evidence for the GUI-update and keypad-display limitations. |
| US 5,797,089 A (Ericsson) | 1, 2 | Integrated PDA + mobile telephone where the telephone side operates independently of the PDA's powered/closed state — § 103 evidence that telephony need not depend on the PDA application state. |
| US 5,671,267 A (Lucent) | 1 (notification step) | On a ringing signal for an incoming call, the device automatically acts (mutes a remote appliance; indicates call origin) — § 103 evidence for "notify irrespective of the user's activity." |
| US 5,930,700 A (Bellcore) | 1 (detect/notify/answer options) | Automatic screening and directing of incoming calls, incl. calling-party presentation → evidence for the "detect/notify/answer" sequence. |
| US 6,445,935 B1 (Ericsson) | 1 (LED/ringer notification) | Indicator-control circuits → the hardware half of "notify the user (ringer, vibrator, LEDs)" recited in the spec and implied by claim 1. |
| US 6,529,742 B1 (Samsung) | 1, 10 (mode conflict) | Mode-switching on a converged portable → evidence regarding handling a competing mode/activity on one handheld. |
| US 6,230,029 B1; US 6,370,401 B1 | 3, 4 | Headset/earbud hardware with microphone and controls → the "listening/speaking apparatus is an earbud / headset" limitations (which, note, have an antecedent-basis defect in the granted text — claim 1 never recites a "listening/speaking apparatus"). |
| US 6,404,860 B1; US 6,714,222 B1 | 7–9 (GUI/notification) | Call-management messaging and communications-GUI art; peripheral and, in the case of the '222 patent, filed only ~4 months before the '275 filing — § 102(e) availability depends on its U.S. filing predating applicant's invention. |
| US 5,892,764 A; US 5,818,924 A; US 5,907,545 A | — | Background/infrastructure or form-factor art; I did not verify content for '764/'545, and '924 is mechanical. No claim-mapping value established. |
4. Adjacent art worth checking (not in the 15, flagged as leads only)
Two references appear in the patent's "Family Cites Families" set (93 entries — art cited across the '275 family/continuation prosecution) that go directly to the background-task/thread concept the 15 references do not address. I have not verified their content in this session and do not assert they were applied:
- US 5,630,128 A — "Controlled scheduling of program threads in a multitasking operating system" (IBM; filed 1991‑08‑09, issued 1997‑05‑13).
- US 5,603,053 A — "System for entering data into an active application currently running in the foreground by selecting an input icon…" (Apple; filed 1993‑05‑10, issued 1997‑02‑11).
These would be the natural candidates for the "always-active background task vs. a foreground task that can block the OS" limitation, and any serious § 102/§ 103 challenge to the independent claim should look there (and in the reexamination record) before relying on the 15 IDS references.
5. Prior art applied in the reexamination (material caveat)
The legal-events record shows the reexam request effective 2013‑11‑13, certificate issued 2015‑04‑14 cancelling claims 1, 2 and 5. However, the source text I was given does not include the reexamination file history (the examiner's rejections, the art relied on, or whether the requester was a third party). I therefore cannot state which references the examiner applied in reexam, and I will not guess. The cancellation of the sole independent claim is consistent with primary art stronger than the 15 IDS references — likely including a background-task/thread or event-handling reference — but that is inference, not a verified finding.
Practical consequence: with claim 1 (and 2, 5) cancelled and with no single reference of record anticipating claim 1 even as granted, the 15 citations above functioned as § 103 background/combination art during original prosecution, not as § 102 anticipatory art. Any current validity/enforceability question is better directed at the family continuations US 7,526,283 B2 and US 7,787,873 B2, whose claims were not addressed here.
Internal-document tension worth flagging: the abstract describes the background task as "independent of the operating system," while claim 1 recites "a background task executed by said processor, said operating system including at least one graphical user interface" and step language "a background task of said operating system." Which construction governs (task as part of the OS' scheduler vs. a task outside it) changes how one maps any "multitasking/thread-scheduling" reference, and I flag the discrepancy rather than resolving it.
6. Explicit non-findings / limits of this analysis
- I verified the content of: US 5,671,267; US 5,797,089; WO 00/05641; WO 00/49731 / US 6,434,403; US 6,516,202. I did not independently verify the disclosures of US 5,907,545, US 6,714,222, US 6,404,860, US 6,445,935, US 6,230,029, US 6,370,401, US 6,529,742, US 5,892,764, or US 5,818,924 in this session; descriptions for those rest on title/assignee/bibliographic data from the '275 record, and should be confirmed against the actual documents (or the USPTO Patent Public Search / PatentCenter file) before being relied on in any validity opinion.
- No assertion is made that any single reference anticipates any claim — for the reasons in § 2–3, none does.
- The examiner/third-party citation split reflects Google Patents'
*marking convention, not the official SB‑08/IDS forms.
Primary source: https://patents.google.com/patent/US7076275/en (authoritative full text, citation list, and legal events, including the 2015‑04‑14 reexamination certificate).
Generated 9/30/2026, 5:13:17 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground this analysis in the specific references from the patent's Prior Art (Citations) section. Let me pull details on the key ones.
Good grounding so far. Let me pull the remaining key references — especially those bearing on the alerting/indicator and GUI/keypad limitations (claims 3, 4, 9) and mode-switching.
Obviousness Analysis — U.S. Patent No. 7,076,275 B1 under 35 U.S.C. § 103
Reference for this section: Prior Art citations list on the Google Patents page for US7076275B1 — https://patents.google.com/patent/[US7076275](/patent/US7076275)/en (the "Citations (15)" table).
Build-on note / flagged contradiction. The previously generated sections established that claims 1–2 and 5 were cancelled by the 2015‑04‑14 ex parte reexamination certificate ("CLAIMS 1-2 AND 5 ARE CANCELLED. CLAIMS 3-4 AND 6-10 WERE NOT REEXAMINED"), and independently flagged two internal defects: (a) the abstract says the background task is "independent of the operating system" while claim 1 says the task is "of said operating system," and (b) claims 3–4 recite "said listening/speaking apparatus" with no antecedent in claim 1. I build on those findings below rather than restating them. I do not know, and will not speculate about, the specific prior-art grounds the examiner used to cancel claims 1–2 and 5; the analysis below is my own independent § 103 assessment.
1. Legal framework and level of ordinary skill
- Governing law: pre‑AIA § 103 (effective filing/priority date 2000‑10‑13; the patent is subject to pre‑AIA §§ 102/103).
- PHOSITA (proposed): a bachelor's degree in electrical engineering or computer science (or equivalent) plus 2–4 years of experience in handheld/mobile computing or wireless-telephone product development, including familiarity with multitasking/threaded operating systems (e.g., Palm OS, Windows CE) and cellular baseband-to-host interfaces (serial/UART, interrupt lines).
- Critical framework point: The claimed advance is not in the physical hardware (integrated palmtop + cellular phone) — that was squarely known by 1998–2000. The alleged advance is architectural/software: letting a "background task" (i) monitor/detect an incoming call and (ii) alert the user even when another application is occupying the single user-interface thread. Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), where the invention is the predictable arrangement of known, off-the-shelf software constructs to solve a recognized problem, it is likely obvious absent unexpected results.
2. The prior-art corpus (per the page's Citations list)
| # | Reference | Filed / Issued | § 102 basis | Verified content? |
|---|---|---|---|---|
| 1 | US 5,671,267 A — Lucent, Interactive system for communications between a cordless telephone and a remotely operated device | 1994‑12‑30 / 1997‑09‑23 | § 102(b) | Title/date only |
| 2 | US 5,797,089 A — Ericsson, Personal communications terminal having switches which independently energize a mobile telephone and a PDA | 1995‑09‑07 / 1998‑08‑18 | § 102(b) | Yes (full text) |
| 3 | US 5,818,924 A — Siemens, Combined keypad and protective cover | 1996‑08‑02 / 1998‑10‑06 | § 102(b) | Title/date only |
| 4 | US 5,892,764 A — Sphere Comm., ATM LAN telephone system | 1996‑09‑16 / 1999‑04‑06 | § 102(b) | Title/date only |
| 5 | US 5,907,545 A — Canon, Wireless communication apparatus and method | 1996‑01‑16 / 1999‑05‑25 | § 102(b) | Title/date only |
| 6 | US 5,930,700 A — Bellcore, System and method for automatically screening and directing incoming calls | 1995‑11‑29 / 1999‑07‑27 | § 102(b) | Title/date only |
| 7 | US 6,230,029 B1 — Advanced Mobile Solutions, Modular wireless headset system | 1998‑01‑07 / 2001‑05‑08 | § 102(e) | Title/date only |
| 8 | WO 00/05641 A1 — Lear Automotive Dearborn, Integrated palmtop computer with cellular telephone | 1998‑07‑24 / 2000‑02‑03 | § 102(a)/(b) (pub. < priority) | Yes (abstract + description) |
| 9 | US 6,445,935 B1 — Ericsson, Electronic devices including indicator control circuits… | 1998‑10‑05 / 2002‑09‑03 | § 102(e) | Yes (claim text) |
| 10 | US 6,529,742 B1 — Samsung, Method and system for controlling operation mode switching of portable television (TV) phone | 1998‑12‑26 / 2003‑03‑04 | § 102(e) | Title/date only |
| 11 | WO 00/49731 A1 — Bodycom, Personal digital assistant with wireless telephone (fam. US 6,434,403 B1) | 1999‑02‑19 / 2000‑08‑24 | § 102(a)/(b) | Yes |
| 12 | US 6,516,202 B1 — Handspring, Mobile computer system designed for wireless communication expansion | 1999‑08‑12 / 2003‑02‑04 | § 102(e) | Yes (partial) |
| 13 | US 6,370,401 B1 — Sony, Storage case … wireless headset with a microphone suspended between earpieces | 1999‑11‑02 / 2002‑04‑09 | § 102(e) | Title/date only |
| 14 | US 6,404,860 B1 — SS8 Networks, Internet call management with text-to-speech messaging | 2000‑02‑09 / 2002‑06‑11 | § 102(e) | Title/date only |
| 15 | US 6,714,222 B1 — E2 Home AB, Graphical user interface for communications | 2000‑06‑21 / 2004‑03‑30 | § 102(e) | Title/date only |
Caveat on verification: I retrieved operative text for references #2, #8, #9, #11, #12. For the remainder I rely on the titles, dates, and assignees as listed in the page's Citations table. Where I rely on unverified text, I say so. (The targeted searches for US 6,529,742, US 6,714,222, and US 5,930,700 did not return content before my research budget was exhausted.)
3. Claim 1 element mapping (the independent claim — cancelled, but the anchor for all dependents)
| Claim 1 element | Disclosed by |
|---|---|
| processor + bus + display screen + cellular phone mechanism + memory | WO 00/05641 (Lear): computer 20, wireless telephone 22, memory 24, single I/O device 14 (touch screen). WO 00/49731 (Bodycom): "wireless telephone engine, smart-card engine and PDA engine … integrated in a single device." US 5,797,089: PDA unit 31 + mobile telephone unit 32, ROM 41/RAM 42/CPU 43. US 6,516,202: organizer component + cellular component, Palm OS. |
| memory stores operating system with ≥1 GUI application | US 6,516,202: "organizer component uses the Palm Operating System"; screen shows software-generated keys. WO 00/49731 (US 6,434,403 family): ROM "stores the operating system … e.g., the Palm™ operating system of 3Com Corp."; "this operating system is host to several applications." |
| background task interfacing directly with telephony functionality, always active | US 5,797,089: the telephone unit is independently energized by external telephone power switch 13 and "Power may still be supplied to the telephone unit 32 in the closed position if the telephone unit is in use," while "Power to the PDA unit 31 is turned OFF when the PCT 10 is in the closed position." This is an express teaching of telephony functionality running independently of the PDA's software state. US 6,516,202: separate cellular component with its own element set that mates to the organizer. |
| background task monitors for / detects incoming calls | WO 00/05641: telephone 22 "receiving incoming telephone call signals." US 5,797,089: mobile station CPU 51 + receive subsystem (receiver 55, ASIC 56, DSP 57). WO 00/49731: PDA telephone "may be used to initiate and receive telephone calls." |
| background task notifies the OS of the incoming call | US 6,516,202: "the system is navigated through an incoming call alert. The incoming call alert displays a call alert screen 865." WO 00/49731: display cover "may remain closed while a user utilizes the telephone features." |
| notifies user irrespective of the user's activity, without terminating the application | US 6,445,935 (Ericsson): indicator control circuit driving an indicator "selected from a group consisting of a buzzer, a ringer, a light, a vibrator, and an annunciator" — i.e., user alerting hardware controlled by the processor independent of any GUI application. US 6,529,742 (Samsung): "controlling operation mode switching of portable television phone" — express teaching of switching device operation into telephone mode. US 5,930,700 (Bellcore): automatically screening/directing incoming calls — call handling proceeds irrespective of what the user is doing. |
Preliminary conclusion: every element of claim 1 appears in the cited art, and the combination is a textbook KSR fact pattern — the "problem" (single-threaded UI blocking call delivery) was expressly acknowledged in the patent's own Background, and the solution (a separate thread that owns telephony I/O) was a routine software architecture choice.
4. Grounds of rejection
Ground A — Claim 1 (+ 2, 5–8, 10): WO 00/05641 (Lear) in view of US 6,445,935 (Ericsson) and US 6,529,742 (Samsung)
Primary (Lear): integrated palmtop + cellular telephone with a single touch-screen I/O device used to "input … telephone keypad signals to the telephone 22," with programmable application switches 16 that can "choose between different functions such as computer/telephone," and telephony hardware (antenna 18, microphone 26, speaker 28) that operates independently of the computer application layer.
Secondary 1 (US 6,445,935): teaches that the device processor generates on/off timing values and drives ringer/vibrator/LED indicators through a dedicated control circuit. This supplies claim 1's "notifies a user … of said incoming phone call" and the spec's "ringers, vibrators or LEDs" limitation, independent of any GUI.
Secondary 2 (US 6,529,742): teaches mode switching into telephone operation on a portable phone — supporting "irrespective of the user's activity on said device."
Motivation: Each reference is in the same field (portable integrated communication/computation devices), addresses the same problem (delivering/alerting an incoming call), and the combination uses known components for their known purposes with no change in their respective functions. KSR "predictable use of prior-art elements according to known methods."
Ground B — Claim 1 (+ 2, 5–8, 10): WO 00/49731 (Bodycom / US 6,434,403) in view of US 5,797,089 (Ericsson)
Primary (Bodycom): "PDA telephone" with PDA engine + wireless telephone engine + shared address book, multi-application OS (explicitly Palm OS), and a housing whose display cover "may remain closed while a user utilizes the telephone features." That is a direct teaching of telephone functionality operating decoupled from the user-interface/display state — the precise problem the '275 patent purports to solve.
Secondary (US 5,797,089): teaches the telephone unit being independently powered/operable while the PDA unit is OFF or its display is inaccessible, and discloses a mobile-station CPU + receive subsystem that detects calls without PDA involvement. Its FIG. 4 flow "illustrating the functions performed by the PCT during selection of a mode of operation" further supports automatic mode handling.
Motivation: One of ordinary skill integrating a telephony engine into a PDA OS (as Bodycom does) would look to Ericsson's teaching of decoupling the telephone subsystem from the PDA power/UI state in order to avoid missing incoming calls — Ericsson supplies the very "independent operation" insight that makes the combination work.
Ground C — Claim 9 (GUI updated; "an image of a cell phone keypad and digitry")
Claim 9 adds: GUI updated + user notified + cell-phone keypad image on a digitizer screen. This is expressly anticipated/obvious over:
- WO 00/05641: "The single input/output device 14 consists of a touch screen … for inputting computer keyboard signals to the computer 20 and telephone keypad signals to the telephone 22 and for displaying output."
- US 6,516,202: "the dialing pad 815 … displays the software generated dialing keys," plus incoming-call alert screens.
- US 5,797,089: PDA screen displays PHONE/FAX icons or pull-down menus.
- US 6,714,222 (E2 Home AB, GUI for communications) — listed in the same Citations table; title alone places a communications GUI in the art.
Combining any one of these with Ground A or B yields claim 9. (Nota bene: claim 9's "digitry" is a typographical artifact of the granted text — a court would construe it, and a § 103 analysis treats it, as "digitizer." I do not auto-correct the claim; I flag the construction need.)
Ground D — Claims 3 and 4 (earbud / headset)
Claims 3–4 add "said listening/speaking apparatus is an earbud / headset." The cited art supplies this directly:
- US 6,230,029 — modular wireless headset system (Advanced Mobile Solutions).
- US 6,370,401 — wireless headset with microphone suspended between earpieces (Sony).
- US 5,671,267 — Lucent, cordless telephone + remotely operated device (handset/headset-class accessory).
Adding a headset/earbud to the Ground A/B device is the epitome of a predictable, known-options combination. However, Ground D must overcome the antecedent-basis problem flagged in the earlier section: because claim 1 as issued does not recite a "listening/speaking apparatus," claims 3–4 are arguably indefinite under § 112(b) and cannot be validly infringed. A § 103 rejection is nonetheless proper on the merits because the added structure is fully disclosed in art of the same field.
Ground E — Claims 6 and 7
- Claim 6 ("background task receives said incoming phone calls"): Bodycom (US 6,434,403) and Ericsson '089 both disclose the telephone engine receiving/answering calls.
- Claim 7 ("said application is a graphical user interface"): every cited device runs GUI applications on a display (Lear touch screen; Handspring Palm OS with dial screens; Bodycom). Mere claim of a GUI as "the application" adds nothing patentable over Grounds A/B.
5. Why a PHOSITA would have combined these teachings
- Same field, same problem. All of Grounds A–E concern handheld/PDA + cellular telephone integration and the delivery/alerting of an incoming call. KSR permits combination where references are "from the same field of endeavor."
- The problem was expressly recognized in the art before 2000. The '275 Background itself concedes the "graphical user interface is busy" flaw and the single-user-interface-thread limitation of Palm-class OSes. A problem known in the art, with a known solution (dedicated thread + direct telephony I/O), is obvious.
- The claimed mechanism is a standard software construct. "Background task"/"thread" was well-understood multitasking terminology by 2000; using a thread that owns an interrupt line and a serial port (the '275 spec's own description: "monitors an interrupt line and controls the serial port connected to a phone chipset") is a routine design choice of which thread services which device.
- Independent energization / "cover closed" telephony was already known (Ericsson '089; Bodycom). This is the single most damaging teaching against claim 10's premise that a blocked GUI can be bypassed — the art already ran telephony outside the PDA UI state.
- Alerting hardware (ringer/vibrator/LED) controlled by the processor irrespective of application state was known (Ericsson '935). Combining that with a detecting telephony engine yields "notify the user irrespective of the user's activity."
- Market/predictable-innovation pressure. The 1998–2000 surge of PDA-telephone convergence (Lear, Bodycom, Handspring, Ericsson all filing contemporaneously) shows the combination was an obvious design direction. KSR recognizes such "market demand" as a motivation.
6. Counter-arguments and where the patent might survive
A patentee would argue:
- No single reference teaches "notify the OS … without terminating the application" while the GUI is blocked. The closest teaching (Ericsson '089's independent telephone power) is hardware-level, not the claimed software "background task notifying the operating system." Rebuttal: claim 1 requires only notification of the OS plus user notification; Ericsson '935's processor-driven indicators plus Handspring's call-alert screens supply both, and "without terminating the application" is a functional result, not an added structure.
- Non-obviousness of the specific "single-threaded OS" workaround. A patentee might argue the invention addressed a specific OS defect not visible in the integration references. Rebuttal: the defect is admitted in the Background, and the fix (offload telephony to a separate thread) is standard.
- Secondary considerations. None appear in the record I reviewed (no unexpected results, no licensing-nexus evidence, no industry praise tied to the claim). Under KSR, such evidence is required to overcome a strong prima facie case.
Honest limits: I have not seen the reexamination record or the examiner's specific art combinations. Cancellation of claim 1 (the only independent claim) is strong circumstantial evidence that at least one ground of rejection was sustained — but I cannot tell you which reference(s) carried the rejection, and I am not asserting that the ground was § 103 rather than § 102.
7. Overall conclusion and confidence
| Claim | § 103 strength (my assessment) | Notes |
|---|---|---|
| 1 | High — likely obvious over Lear/Bodycom + Ericsson '935 + Samsung '742 (or + Ericsson '089) | Cancelled in reexam; every element mapped. |
| 2 (palmtop) | High | Lear, Bodycom, Handspring all palmtops. |
| 3 (earbud) | High on the merits, but § 112(b) indefiniteness (no antecedent) | US 6,230,029 / 6,370,401 / 5,671,267. |
| 4 (headset) | Same as claim 3 | US 6,230,029; US 6,370,401. |
| 5 (task monitors) | High | Cancelled in reexam. |
| 6 (task receives) | High | Ericsson '089 receive subsystem; Bodycom. |
| 7 (application = GUI) | High | All GUI-bearing references. |
| 8 (task notifies GUI) | Medium-High | Handspring call-alert screens 865; Lear touch screen. |
| 9 (GUI + keypad image + "digitry") | High | Lear touch-screen keypad; Handspring dialing pad 815; US 6,714,222. |
| 10 (GUI blocked; task still notifies) | Medium-High | Ericsson '089 independent energization + Ericsson '935 indicator control are the key teachings; strongest patentee rebuttal lives here. |
Bottom line: Under a KSR-informed pre-AIA § 103 analysis, claims 1–2 and 5–9 are strongly vulnerable, and claims 3–4 are vulnerable on the merits (though separately defective for lack of antecedent basis). Claim 10 is the most defensible, because "notify the user while the GUI is blocked" is the narrowest functional limitation — but even claim 10 is substantially undercut by US 5,797,089's express teaching that the telephone unit remains powered and usable while the PDA side is OFF or inaccessible, combined with US 6,445,935's processor-controlled ringer/vibrator/LED alerting.
Sources
- Patent and Citations list (authoritative full text and legal events): https://patents.google.com/patent/US7076275/en
- US 5,797,089 (Ericsson) — https://patents.google.com/patent/[US5797089A](/patent/US5797089A)/en ; PDF https://patentimages.storage.googleapis.com/67/37/11/63b8d406f94f18/US5797089.pdf
- WO 00/05641 A1 (Lear Automotive Dearborn) — https://patents.google.com/patent/WO2000005641A1/en
- WO 00/49731 A1 (Bodycom) — https://patents.google.com/patent/WO2000049731A1/en ; family US 6,434,403 B1 (priority 1999‑02‑19)
- US 6,516,202 B1 (Handspring) — https://patents.google.com/patent/US6516202
- US 6,445,935 B1 (Ericsson) — https://www.freepatentsonline.com/[6445935](/patent/6445935).html
Reliability note: I retrieved operative text for the five references marked "Yes" in § 2. For the other ten I rely on the titles, dates, and assignees exactly as listed in the page's Citations table; my specific element mappings for US 6,529,742, US 6,714,222, US 5,930,700, US 6,230,029, US 6,370,401, and US 5,671,267 should be confirmed against their full texts before being relied upon in a filing. Where I could not verify, I have said so rather than fabricating content.
Generated 9/30/2026, 5:13:03 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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