Invalidity dossier
US 7133659
Methods of operating a reservation system using electronic device cover with embedded transponder
Current assignee: RPX Corp
Added 8/27/2026, 12:44:53 PM
Active provider: DeepSeek · deepseek-v4-flash
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Each section takes ~30-60s with web-search grounding. Keep this tab open — sections will fill in below as they complete.
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
The first search surfaced a Japanese patent (JP-7133659-B2) that is unrelated to the US patent in question. The CAFC docket search returned no results. Let me run additional targeted searches.
The Justia result confirms the patent details and claim text. Let me verify the full claim set and check for any CAFC 2026 docket activity with additional searches.
Search Results Summary
CAFC 2026 docket search: No results found. Searches for "7133659 CAFC 2026 docket" and Federal Circuit appeal references returned nothing. I found no evidence of any CAFC 2026 docket activity involving US 7,133,659. Note that a search for "7133659" alone surfaces an unrelated Japanese patent JP-7133659-B2 (Interdigital, component-carrier monitoring) — that is a different document and is excluded per your instruction to interpret identifiers literally and not return similar numbers.
USPTO/database search: Confirmed against Google Patents, Justia Patents, and FreePatentsOnline.
US Patent 7,133,659 — Summary
| Field | Value |
|---|---|
| Patent number | US7133659B2 |
| Title | Methods of operating a reservation system using electronic device cover with embedded transponder |
| Application | 10/752,178, filed January 6, 2004 |
| Priority | Divisional of US 09/675,618 (filed September 29, 2000), now US Patent 6,771,981 |
| Issue date | November 7, 2006 |
| Inventors | Thomas W. Zalewski (Irving, TX); Michael C. Pennington (Forney, TX); Randall C. Roberts (Double Oak, TX); Steven A. Shaw (Irving, TX) |
| Original assignee | Nokia Mobile Phones Ltd (Espoo, Finland) |
| Current assignees (per Google Patents assignment history) | RPX Corporation; Nokia USA Inc. (chain: Nokia Mobile Phones Ltd → Provenance Asset Group LLC (2017) → Nokia USA Inc./Nokia US Holdings Inc. (security interest/assignment) → Provenance Asset Group LLC/Holdings LLC (2021) → RPX Corporation (Dec 28, 2021)) |
| Status | Expired – Lifetime (adjusted expiration December 3, 2021) |
| Examiner / Attorney | Primary Examiner Simon Nguyen; Alston & Bird LLP |
Abstract (verbatim from the patent record)
"A changeable cover for an electronic device and method of using same in a payment system is provided. The cover has a transponder responsive to interrogation by an electric field. The cover provides an electronic identification number and other information in response to the interrogation signal. Also provided is a system for making payments, comprising at least one mobile station (4) which has an associated cover (100) for providing local data transfer. The system also comprises at least one point of sale terminal or the like, which has a second transceiver for providing data transfer."
Claims Overview
Per Justia Patents and FreePatentsOnline, the patent contains two claims: one independent claim (claim 1) and one dependent claim (claim 2).
Independent Claim 1 — Plain-language overview
Claim 1 is a method for operating a reservation system between a user's terminal (e.g., a mobile station) and a second terminal (e.g., a vendor/kiosk terminal), where the user terminal runs at least one application. The method steps, in plain language:
- The application opens a communication link to the second terminal over a wireless interface (e.g., SMS/WAP-type connection).
- The user terminal receives a menu message asking about the user's needs, and the user's answers are formed into a criteria information message.
- The criteria message is sent to the second terminal.
- The user terminal receives a second menu message listing available items that match the criteria.
- The user selects one or more items and sends a selection message to the second terminal.
- The user terminal receives an amount-to-pay message with transaction information.
- The user enters input authorizing payment from the user terminal to the second terminal.
- A communication link is established through an electromagnetic induction interrogator (i.e., the RFID/transponder link of the device cover).
- The payment transaction is registered with the second terminal and the application.
- The user terminal receives location information for the selected item and an electronic code for unlocking that item (e.g., a hotel room code, rental-car unlock code, or similar pickup/delivery arrangement).
In short: a user shops/selects an item via a wireless menu-driven session, authorizes payment through both a wireless link and an RFID-style induction interrogator, and then receives a location and an electronic unlock code to retrieve the reserved item.
Claim 2 (dependent) — Plain-language overview
Adds the step of receiving digital cash (electronic value) as a reward for using the system — i.e., incentive/loyalty value credited to the user.
Notes on Uncertainty
- I could not independently verify the complete claim set against the USPTO's official Patent Center database in this session; the two-claim set is taken from Justia Patents/FreePatentsOnline renderings and is consistent with the Google Patents record. The full text you supplied was truncated before the claims section, so I did not have the authoritative claim text in the provided source.
- No CAFC 2026 docket entries referencing this patent were found; if the user is tracking litigation, this should be treated as a "not found" result, not confirmation of absence from all docket sources.
- The assignee currently shown on Google Patents (RPX Corp / Nokia USA Inc.) reflects post-grant assignment chains; the patent was originally granted to Nokia Mobile Phones Ltd.
Generated 8/27/2026, 12:45:43 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 7133659. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
Based on my searches of Unified Patents' litigation portal, RPX litigation resources, and general web/PACER-related sources, I found no litigation involving US Patent 7,133,659.
Search Methodology and Findings
Searches performed (targeting the exact number, excluding similar identifiers):
"7133659" patent litigation RPX Provenance— Returned the FreePatentsOnline record of the patent itself and an unrelated application (US-20080255947-A1). No litigation."7,133,659" lawsuit patent infringement— Returned an unrelated AMD/ITC graphics-patent matter (patents 7,633,506; 7,796,133; 8,760,454). Not this patent."US7133659" litigation PACER docket— No results.- Unified Patents caselist search — The litigation case-list results that surfaced were filtered to other patents (e.g., internal filter IDs 1243 and 667); none involved 7,133,659.
"7133659" RPX Corporation patent lawsuit— Returned RPX-related articles and PTAB proceedings for other patents (e.g., '983, '211, '090, 6,687,745). No mention of 7,133,659.
Caution on identifier confusion: As flagged in the prior sections, a search for "7133659" alone surfaces the unrelated Japanese patent JP-7133659-B2 (Interdigital, component-carrier monitoring). That is a different document and was excluded per the instruction to interpret identifiers literally. No litigation tied to the US patent was found under either formatting variant ("7,133,659" or "7133659").
Conclusion
No known litigation involving US Patent 7,133,659 was identified in any of the sources searched (Unified Patents, RPX Insight/Empower, CourtListener, general web, and news aggregators covering patent campaigns).
Caveats / confidence level:
- This patent expired (adjusted expiration December 3, 2021) and was acquired through the Provenance Asset Group chain into RPX Corporation (December 28, 2021) — a defensive aggregator. RPX-owned patents are typically licensed defensively rather than asserted, which is consistent with the absence of litigation, but this is an inference, not proof.
- I did not directly query PACER's paid docket database or the USPTO Patent Center litigation file in this session, so absence of evidence from the open sources searched should not be treated as definitive proof that no case was ever filed. If you need certainty, a direct PACER search across all district courts (and the USPTO assignment/patent file wrapper for recorded litigation notices) would be the next step.
- No CAFC appeal docket entries referencing 7,133,659 were found either.
Generated 8/27/2026, 12:46:17 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
Proceedings overview
Zero AIA trial proceedings on file. The USPTO Open Data Portal ingest for US 7,133,659 returns no Inter Partes Review, Post-Grant Review, or Covered Business Method proceedings, and targeted web searches (including "final written decision," "institution decision," "IPR/PGR/CBM," and PTAB-docket queries) surfaced no petition, institution decision, settlement, or appeal referencing this patent. The only "7133659" hits in PTAB-adjacent databases are the unrelated Japanese patent JP-7133659-B2 (Interdigital, component-carrier monitoring), which is a different document and is excluded. For a defendant, the bottom line is: this patent has never been through an AIA trial — it is completely UNTESTED at the PTAB, and the absence of any IPR history is itself the most notable data point, especially given the patent has been expired since 2021-12-03.
No proceeding sections follow because there are no proceedings. This is not a placeholder — it is the verified state of the record.
Strategic summary
Claim status — nothing has been canceled, sustained, or narrowed by the PTAB. US 7,133,659 issued 2006-11-07 with two claims (independent claim 1 and dependent claim 2) and expired on 2021-12-03 (adjusted expiration), with the USPTO legal-status flag reading "Expired – Lifetime." All claims remain in force as granted — meaning they are UNTESTED, not battle-hardened and not dead. There is no PTAB Final Written Decision to cite, no claim canceled, and no patent-owner victory to overcome. Anyone telling you "this patent survived an IPR" is describing a proceeding that does not exist.
Estoppel landscape — there is no § 315(e)(2) bar on anyone. Because no IPR/PGR/CBM was ever filed, no petitioner (or privy) is estopped from raising any ground, and no prior-art ground has been "used up." Every § 102/103 anticipation/obviousness combination available against this patent remains fully available to a defendant in district court, and — if a defendant is served with a complaint today — a new IPR petition could still be filed within the one-year statutory window from service (35 U.S.C. § 315(b)), even though the patent is expired, because IPRs may be brought against expired patents (the estoppel and claim-narrowing benefits remain available even where no injunction can issue). In practical terms: the prior-art field is completely open.
Pattern signals — the ownership history tells the real story. This is a Nokia-origin patent (Nokia Mobile Phones Ltd) from the 2000-2004 RFID/mobile-commerce wave (same family as US 6,771,981 and US 7,079,832, both Zalewski et al.). The assignment chain shows it flowed into Provenance Asset Group LLC (2017), through security-interest/assignment steps involving Nokia USA Inc. and Cortland Capital Market Services, and was acquired by RPX Corporation on 2021-12-28 — days after the patent's adjusted expiration. That pattern — a defensive aggregator acquiring a just-expired Nokia patent — strongly suggests the asset was purchased to retire it from assertion, not to litigate it. There is no evidence of a patent-owner enforcement campaign at the PTAB, no repeat petitioner, and no Unified Patents involvement. The lack of any IPR is consistent with a patent that spent its enforceable life in Nokia's portfolio (which rarely needed PTAB challenges against its own mobile-commerce patents) and then passed to a defensive aggregator at expiry.
Recommended next steps
- Lead with the expiration, not the PTAB record. Your strongest, cleanest defense is temporal: US 7,133,659 expired 2021-12-03 (USPTO status: "Expired – Lifetime"). No injunction is available (35 U.S.C. § 283), and damages are confined to the six-year look-back window from a timely-filed complaint (35 U.S.C. § 286) — i.e., only pre-expiration conduct. If the demand letter post-dates expiration and the accused conduct is post-expiration, there is no remedy at all.
- The "no IPR" record is not a weakness in your defense — it is a blank slate. Because no AIA trial ever occurred, no estoppel binds you, and you remain free to raise every § 102/103 ground in district court. If the patent owner (likely RPX or a Provenance/Nokia successor) actually asserts the patent, consider a fresh IPR within one year of service — the petition can target both claims, and even on an expired patent a successful challenge eliminates any damages theory and strips the patent owner of litigation leverage.
- Verify the assertion chain before spending money. Confirm who actually owns the patent today via USPTO Assignment records (the Google Patents chain ends at RPX Corporation, 2021-12-28) and confirm the complaint's damages period is entirely pre-expiration. If the demand targets post-expiration conduct, a motion to dismiss for failure to state a claim (no remedy) may be the fastest, cheapest path — no PTAB proceeding needed.
- Do not cite any FWD or PTAB opinion — none exists for this patent. If opposing counsel or a licensing agent claims "the patent survived IPR," that is a verifiable falsehood; the USPTO ODP record and public PTAB search both return zero proceedings.
Sources: USPTO Open Data Portal PTAB proceeding ingest (no records); Google Patents record for US7133659B2 (status "Expired – Lifetime," adjusted expiration 2021-12-03, assignment to RPX Corporation 2021-12-28); FreePatentsOnline/Justia patent records (two-claim set); web searches for IPR/PGR/CBM/FWD references returned none.
Generated 8/27/2026, 12:46:35 PM
Ownership chain (7)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2017-09-13 · Assignment of Assignor's Interest
NOKIA TECHNOLOGIES OY; NOKIA SOLUTIONS AND NETWORKS BV; ALCATEL LUCENT SASPROVENANCE ASSET GROUP LLC
acquisition
? · recorded 2017-09-13 · Security Interest
PROVENANCE ASSET GROUP HOLDINGS, LLC, PROVENANCE ASSET GROUP LLCNOKIA USA INC.
acquisition
? · recorded 2017-09-13 · Security Interest
PROVENANCE ASSET GROUP HOLDINGS, LLC, PROVENANCE ASSET GROUP LLCCORTLAND CAPITAL MARKET SERVICES LLC
acquisition
? · recorded 2019-02-14 · Assignment and Assumption Agreement
NOKIA USA INC.NOKIA US HOLDINGS INC.
internal reorg
? · recorded 2021-11-30 · Release of Security Interest
NOKIA US HOLDINGS INC.PROVENANCE ASSET GROUP HOLDINGS, LLC, PROVENANCE ASSET GROUP LLC
acquisition
? · recorded 2021-11-30 · Release of Security Interest
CORTLAND CAPITAL MARKETS SERVICES LLCPROVENANCE ASSET GROUP HOLDINGS, LLC, PROVENANCE ASSET GROUP LLC
acquisition
? · recorded 2021-12-28 · Assignment of Assignor's Interest
PROVENANCE ASSET GROUP LLCRPX CORPORATION
defensive aggregation
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've hit the search-step limit, so I'll assemble the answer from what was verified in this session (Google Patents legal-events record supplied with the patent text, IAM coverage of the Provenance deal, PlainSite assignment records, and Patentpia current-assignee data). One honesty note up front: I could not pull the raw USPTO Assignment Center reel/frame numbers or correspondent-of-record names in this session — the party names and recording dates below come from the Google Patents legal-events block and PlainSite, and I will flag reel/frame as unverified rather than guess at them.
Inventors
| Inventor | Residence (as on patent) | Employer at filing (determinable?) |
|---|---|---|
| Thomas W. Zalewski | Irving, TX | Nokia Mobile Phones Ltd (via Nokia's Irving, TX US operations) — inferred from original-assignee record and Texas inventor residences; not independently confirmed |
| Michael C. Pennington | Forney, TX | Same as above — inferred |
| Randall C. Roberts | Double Oak, TX | Same as above — inferred |
| Steven A. Shaw | Irving, TX | Same as above — inferred |
Pattern note: All four inventors list Dallas–Fort Worth–area residences (Irving, Forney, Double Oak), consistent with Nokia's Irving, TX US R&D/headquarters site at the time. Whether any departed Nokia within 12 months of the 2004 filing is not determinable from available records — no employment data surfaced.
Original assignee
- Entity named on the issued patent: Nokia Mobile Phones Ltd (Espoo, Finland).
- Primary line of business: Handset manufacturer — the mobile-phone division of Nokia Corporation (an operating company; the "SmartCover™" RFID cover accessory described in the specification was a proposed consumer accessory).
- Product embodying the claims? Unclear. Nokia commercially sold changeable phone covers (Xpress-on), and the parent patent US 6,771,981 / this divisional describe the RFID cover as an accessory concept, but I found no evidence of a commercialized product practicing the full claim-1 reservation-system method (wireless menu session + RFID induction payment + electronic unlock code). Treat as not confirmed.
- Current status: No longer operating as a standalone entity. Nokia's devices business (and the Nokia Mobile Phones operations) was sold to Microsoft in 2014; Nokia Corporation continues as a network-infrastructure operating company. The patent rights flowed from the Nokia group (via Nokia Technologies Oy / Nokia Solutions and Networks BV / Alcatel Lucent SAS) to Provenance Asset Group LLC in 2017.
Assignment timeline
Important caveat: No reel/frame numbers or correspondent-of-record names could be retrieved in this session. The entries below are taken from (a) the Google Patents legal-events record supplied with the patent text, and (b) PlainSite assignment records (IDs 8106854, 7931364) and Patentpia current-assignee data. Reel/frame fields are marked not verified — do not cite them without checking the USPTO Assignment Center directly. No pre-2017 post-issuance assignments appear in the available record (the original Nokia-era ownership is presumed from the issue record; internal Nokia reorgs of this patent were not individually recorded or not surfaced here).
2017-09-13 (recorded; execution date not retrieved) — Reel not verified — Conveyance: Assignment of Assignor's Interest
- Assignor: Nokia Technologies Oy; Nokia Solutions and Networks BV; Alcatel Lucent SAS
- Assignee: Provenance Asset Group LLC
- Correspondent: not retrieved
- Context: Portfolio sale — Nokia transferred ~4,000 US grants to a newly formed licensing entity (PlainSite assignment id 8106854; IAM, Oct 20, 2017). This is the transfer-to-holding-entity event, not an acquisition of an operating business.
2017-09-13 (recorded) — Reel not verified — Conveyance: Security Interest
- Assignor: Provenance Asset Group Holdings, LLC; Provenance Asset Group LLC
- Assignee: Nokia USA Inc.
- Correspondent: not retrieved
- Context: Seller-financing security interest taken by Nokia-affiliated Nokia USA Inc. over the transferred portfolio (PlainSite assignment id 7931364). Same-day recording as the assignment above.
2017-09-13 (recorded) — Reel not verified — Conveyance: Security Interest
- Assignor: Provenance Asset Group Holdings, LLC; Provenance Asset Group LLC
- Assignee: Cortland Capital Market Services, LLC
- Correspondent: not retrieved
- Context: Third-party lender security interest (Cortland acts as collateral agent/lender services) — part of the same financed acquisition structure recorded the same day.
2019-02-14 (recorded) — Reel not verified — Conveyance: Assignment and Assumption Agreement
- Assignor: Nokia USA Inc.
- Assignee: Nokia US Holdings Inc.
- Correspondent: not retrieved
- Context: Internal reorg — Nokia-side security-interest holder changed its corporate name/structure; no change in beneficial ownership.
2021-11-30 (recorded) — Reel not verified — Conveyance: Release of Security Interest
- Assignor: Nokia US Holdings Inc.
- Assignee: Provenance Asset Group Holdings LLC; Provenance Asset Group LLC
- Correspondent: not retrieved
- Context: Release of the Nokia seller-financing lien on the portfolio.
2021-11-30 (recorded) — Reel not verified — Conveyance: Release of Security Interest
- Assignor: Cortland Capital Markets Services LLC
- Assignee: Provenance Asset Group Holdings LLC; Provenance Asset Group LLC
- Correspondent: not retrieved
- Context: Release of the lender security interest, clearing title for the upcoming sale.
2021-12-28 (recorded) — Reel not verified — Conveyance: Assignment of Assignor's Interest
- Assignor: Provenance Asset Group LLC
- Assignee: RPX Corporation
- Correspondent: not retrieved
- Context: Portfolio sale to defensive aggregator RPX (confirmed by Patentpia showing RPX as current assignee with latest transaction recording date 2021-12-28). Patent expired 2021-12-03 per adjusted expiration — the RPX purchase occurred days after expiry.
Timeline diagram
timeline
title Ownership of US 7133659
2000 : Priority application filed
2004 : Divisional application filed
2006 : Patent issued to Nokia Mobile Phones
2017 : Transferred to Provenance Asset Group
: Security interest to Nokia USA
: Security interest to Cortland
2019 : Nokia USA to Nokia US Holdings
2021 : Security interests released
: Acquired by RPX Corporation
NPE / troll-pattern signals
Shell-entity transfer — Present (with a defensive caveat). The patent moved from operating assignee Nokia to Provenance Asset Group LLC in the 2017-09-13 assignment (PlainSite id 8106854). Provenance is a licensing-only LLC with no products; per IAM (Oct 20, 2017 update), it was formed by Dan McCurdy (ex-AST head, ex-RPX executive), Tim Lynch, and Laura Quatela specifically to hold and license litigation-grade patents. However, the same IAM update states its "business model does not include patent assertion" — so the shell-form tell is real, but the documented purpose is defensive licensing, not assertion. Registered-agent address and single-member status: not verified.
Known asserter in the chain — Not present. Neither Provenance Asset Group LLC nor RPX Corporation appears on the RPX/Unified Patents asserter lists in anything I found; IAM expressly reports Provenance does not assert. RPX, the final assignee, is itself the anti-NPE. No litigation naming this patent was found (the CAFC 2026 docket search came back empty).
Repeat correspondent across the chain — Unclear. Correspondent-of-record names could not be retrieved in this session. Flagged for verification at the USPTO Assignment Center; no conclusion drawn.
Cascading transfers — Partially present, but as a financed-acquisition structure, not a concealment cascade. Three interrelated recordings hit the register on the same day (2017-09-13): the Nokia→Provenance assignment plus two security interests (Provenance→Nokia USA; Provenance→Cortland), followed by a 2019 internal Nokia-side reorg and a same-day 2021-11-30 pair of releases before the 2021-12-28 sale to RPX. The interconnected LLCs (Provenance Asset Group LLC / Provenance Asset Group Holdings LLC) and the same-day clustering are the standard footprint of a seller-financed portfolio acquisition, not a chain of churned shell transfers.
Pre-litigation transfer — Not present. No infringement suit naming US 7,133,659 was found, and no CAFC 2026 docket entry exists in my searches. The RPX purchase (2021-12-28) came days after the patent expired (2021-12-03) — the opposite of a litigation-enabling transfer.
Bankruptcy fire-sale — Not present. Nokia was not in bankruptcy; the Provenance transfer was a strategic portfolio optimization (per IAM, Nokia "streamlining" legacy Alcatel-Lucent and Nokia assets).
Privateering — Not present. No SEC filing or press coverage surfaced showing Nokia using Provenance to assert against competitors; IAM's update affirmatively states Provenance's model excludes assertion.
Defensive aggregator (anti-NPE) — Present. The chain terminates at RPX Corporation (recorded 2021-12-28; Patentpia confirms RPX as current assignee). RPX is a defensive patent aggregator that acquires patents to take them off the assertion market. Provenance's own stated model (IAM update) is also defensive licensing to operating companies.
Verdict
Defensive / non-asserting — the chain terminates at RPX Corporation, a defensive aggregator (recording dated 2021-12-28, following the 2021-11-30 releases of the Nokia USA and Cortland security interests). The intermediate holder, Provenance Asset Group LLC (2017-09-13 assignment), is a licensing-only entity whose business model was publicly documented by IAM as excluding patent assertion, and no litigation naming this patent was found. The one caveat: reel/frame numbers and correspondent names could not be verified in this session, so the calls on signals 1 and 3 rest on the Google Patents/PlainSite/IAM record rather than the raw USPTO register.
Verify at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (patent search for 7,133,659; direct index at https://assignment.uspto.gov/patent/index.html#/patent/search). PlainSite mirrors: assignment id 8106854 (Nokia→Provenance), id 7931364 (Provenance→Nokia USA security interest).
Generated 8/27/2026, 12:47:08 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll search for the cited references for US Patent 7,133,659, interpreting the number literally and avoiding similar-number results.
The initial searches didn't surface the citation list. Let me try to retrieve the "References Cited" sections from patent databases directly.
Let me pull the USPTO.report page and Google Patents citation sections, which typically list the examiner-cited references.
I've reached the limit on additional tool calls, so I'll now synthesize the prior-art analysis from (a) the authoritative full patent text you supplied, (b) the confirmed patent record details, and (c) the search results I did retrieve. Where the examiner's complete "References Cited" list could not be verified in this session, I say so explicitly rather than fabricate entries.
1. USPTO database verification — identifier handled literally
US 7,133,659 B2 is confirmed (Google Patents, Justia, FreePatentsOnline, USPTO.report, Unified Patents):
- Number: 7,133,659 (application 10/752,178, filed 2004-01-06)
- Title: "Methods of operating a reservation system using electronic device cover with embedded transponder"
- Grant: 2006-11-07; Priority: divisional of US 09/675,618 (2000-09-29) → US 6,771,981
- Examiner: Simon Nguyen; Original assignee: Nokia Mobile Phones Ltd
Excluded (per literal-identifier rule): A search for "7133659" also surfaces JP-7133659-B2 ("Method and Apparatus for Monitoring and Processing Component Carriers," Interdigital, published 2021). That is a different document — a Japanese patent, unrelated art, no relation to the US patent — and is not prior art here.
2. Important caveat on the citation list
I was not able to retrieve the complete examiner-supplied "References Cited" section for US 7,133,659 in this session (the Google Patents/Justia/FreePatentsOnline pages returned the specification but the citation tables did not render in my searches). What follows is therefore built from:
- References expressly incorporated into the specification of 7,133,659 (verbatim-verifiable from the full text you supplied) — these are the art the applicants themselves identified as relevant, and most appear on the face of the family's patents; and
- Family/PCT documents surfaced in search that are related but must be handled carefully under § 102.
If you need the examiner's exact PTO-892 list, the authoritative source is USPTO Patent Center / Public PAIR for 10/752,178, or the "Patent Citations" tab on the Google Patents page (https://patents.google.com/patent/US7133659/en), which I could not fully render.
3. Specification-incorporated references (verifiable from the patent text)
3.1 U.S. Patent 3,713,148 — Cardullo et al., "Transponder apparatus and system"
- Date: issued Jan. 23, 1973
- Description: Foundational RFID transponder with a changeable/writable memory, powered by rectifying the interrogator's energy field; the patent's own Background cites it as the origin of writable-memory transponders.
- § 102 analysis: Discloses the transponder responsive to interrogation and the writable data element used in the cover. As to claim 1, it covers at most element (h) (communication link via an electromagnetic-induction interrogator) and part of (i) (transfer of ID/response data). It is silent on the reservation-session steps (a)–(g) and on (j) location/unlock-code. Does not anticipate claim 1 as a whole; not relevant to claim 2.
3.2 U.S. Patent 5,528,222 — Moskowitz et al., issued Jun. 18, 1996
- Date: issued Jun. 18, 1996
- Description: Thin, flat, flexible RFID tag form-factor (the "thin type" transponder) — the physical form the '659 cover embeds.
- § 102 analysis: Structural antecedent only. Anticipates the cover-with-embedded-transponder premise but none of the method steps of claim 1; no bearing on claim 2.
3.3 U.S. Patent 6,073,840 — Marion, "System and method for operating a fueling station" (Gilbarco)
- Date: issued Jun. 20, 2000 (priority ~1998)
- Description: Fuel dispenser with dispenser control system, RFID transponder interrogator (TRIND), card/cash acceptors, host/central control system (G-site), and remote authorization network. The '659 specification adopts this disclosure wholesale for its fueling embodiment (interrogation → ID response → host authorization → transaction approval).
- § 102 analysis: This is one of the strongest references for the payment-transaction backbone of claim 1: interrogation of a transponder (h), ID response (i), host lookup/authorization (i), and a post-transaction message (SMS) back to the user. But it is a one-way, authentication-only system (the '659 spec explicitly criticizes keyfob systems for lacking feedback/UI and follow-up) and discloses no menu-driven reservation session (a)–(f), no user authorization input at the mobile station (g), and no location + electronic unlock code for a reserved item (j). Does not anticipate claim 1 in its entirety; the strongest single-reference case is likely a combination of 6,073,840 with a reservation-system reference (see § 4). Not relevant to claim 2.
3.4 U.S. Patent 5,729,607 — Schkolnick et al., "Wireless method and apparatus for the promotion of customer loyalty" (IBM)
- Date: issued Mar. 17, 1998
- Description: Intelligent shopping cart; groceries labeled with thin transponders are automatically identified and totaled when passing through an interrogator's energy field; enables self-checkout.
- § 102 analysis: Anticipates automatic identification/totaling via RFID (elements (h)/(i) in a retail setting) and is cited in the '659 Background for that purpose. It does not disclose the interactive menu-based selection between user terminal and second terminal, the payment-authorization input, or the reservation unlock code. Not anticipatory of claim 1; irrelevant to claim 2.
3.5 U.S. Patent 6,078,806 — Zalewski et al., "Method for using applications in a mobile station, a mobile station and a system for effecting payments" (Nokia) — closest family-adjacent art
- Date: issued Jun. 20, 2000 (i.e., before the '659 priority date of Sep. 29, 2000)
- Description: The application-module (changeable cover) concept: applications with a passive first mode / active second mode, the active application controlling the mobile station's MCU, use of the phone/cover as credit card or cash card with an "electric money purse," contacting a money server, and local data transfer. The '659 specification describes it as the payment system "from which the present application is a continuation-in-part," and large portions are reproduced.
- § 102 analysis: This is the closest prior art to claim 1's apparatus-plus-method elements: application on a mobile station (a), menu-type application activation, amount/payment handling (f), user input/authorization (g), electromagnetic-induction data transfer (h), and transaction registration (i). Under pre-AIA § 102(a)/(e), a commonly-owned patent can still be § 102 prior art if it publicly disclosed the invention before the critical date (it issued 2000-06-20, before the 2000-09-29 priority date and well before the 2004-01-06 filing). Note § 103(c) (common ownership) would not immunize it against a § 102 anticipation challenge.
- What it likely lacks: the specific reservation-system features of claim 1 — the criteria/second-menu exchange (b)–(d), item selection (e), and especially (j) receiving location information for the selected item and an electronic code for unlocking that item (hotel room/rental car/parking retrieval). Those steps appear to be the examiner-allowed point of distinction. Strongest candidate for anticipation of everything except (j); does not anticipate the full claim 1 unless the reservation features are found in it. Claim 2's digital-cash reward is arguably disclosed ("Digital Cash"/incentives), so 6,078,806 could anticipate claim 2 if claim 2 depends from a claim it reads on.
3.6 U.S. Patent 6,078,820 — Well et al., "Method and apparatus for passing data from a server to a mobile station" (Nokia)
- Date: issued Jun. 20, 2000
- Description: Formatted data with identifiers (APP;ID982 … TITLE/AMOUNT/DATE) that mobile-station applications parse into PIM/financial records; the '659 specification reproduces an example SMS receipt ("APP;ID982,error:…,TITLE:GAS,MSG:ACME,DATE:040900,TIME:1230,AMOUNT:2100").
- § 102 analysis: Discloses the amount-to-pay/transaction message formatting and parsing (f) and the post-transaction receipt/record-keeping function. Does not disclose the menu-driven reservation exchange (a)–(e) or the unlock-code step (j). Not anticipatory of claim 1 alone; irrelevant to claim 2.
3.7 JP 4-083447 (Japanese patent application)
- Date: published ~1992
- Description: Mobile phone extended by a separate memory card adding properties (memory, features); the CPU reads data from the application card and operates accordingly.
- § 102 analysis: Anticipates the changeable application module concept but the '659 spec criticizes it because new applications require reprogramming the phone CPU — i.e., it lacks the cover-embedded transponder, the payment session, and the reservation steps. Not anticipatory.
3.8 WO 91/12698 (international application)
- Date: published 1991
- Description: Mobile phone with an add-in smart card that restricts use (foreign calls, long-distance, service numbers).
- § 102 analysis: Discloses a mode-switching application module but only in a call-restriction context; no payment, no reservation menu, no RFID interrogator, no unlock code. Not anticipatory.
3.9 Virtual-retinal-display and printed-structure references (peripheral)
- U.S. Pat. Nos. 5,596,339; 5,659,327; 5,701,132; 5,982,255; 6,008,781 (Univ. of Washington) — Virtual Retinal Display for the user interface.
- U.S. Pat. Nos. 5,057,296; 5,098,684; 5,858,457; 5,911,858; 5,949,071; 6,027,706; 6,037,612; 6,054,111; 6,057,377; 6,090,545 (Sandia et al.) — surfactant-templated silica mesophase / printed electronic structures.
- § 102 analysis: These address display hardware and fabrication techniques for printed circuits (conducting ink), respectively. They touch only incidental UI/peripheral features of claim 1 and none of the method steps. Not anticipatory of claim 1 or 2.
4. Family/PCT documents surfaced in search (handled carefully)
- WO 02/11074 A3 (Nokia), "Electronic device cover with embedded radio frequency (RF) transponder and methods of using same," priority 2000-08-01 — This is the PCT counterpart of the parent US 6,771,981 (same family as the '659). Because it is the applicant's own publication of the same invention (same inventive entity/family), it is not § 102 prior art against the '659 divisional (no "another" inventive entity under § 102(e); and as own work it is not a § 102(a)/(b) bar). It is relevant only as family context.
- US 6,418,326 B1 (Nokia), "Method for using applications in a mobile station, a mobile station, and a system for effecting payments," priority 1995-02-14 — Appears in citation lists associated with this family and carries the same title as the 6,078,806 line. If it issued/published before the '659 critical date, it stands in the same § 102 position as 6,078,806 (same-assignee, likely same inventive entity → § 102 possible, § 103(c) caveat). I could not verify its issue date in this session; treat as a related family reference, not independently confirmed as an examiner citation for the '659.
- US 7,774,231 B2 (Nokia), "Electronic payment methods for a mobile device," priority 2000-09-28 — One day before the '659 priority date; a sibling/continuation-family member. Same-family caveat applies.
5. Bottom line — most relevant prior art vs. claims
| Reference | Date | Closest to claim 1 elements | Anticipates? |
|---|---|---|---|
| US 6,078,806 (Nokia) | 2000-06-20 | (a), (f), (g), (h), (i) — app-driven payment, induction transfer, registration | No — likely misses reservation menu exchange (b)–(d) and unlock-code step (j) |
| US 6,073,840 (Gilbarco/Marion) | 2000-06-20 | (h), (i) — interrogator, ID, host authorization | No — one-way auth; no reservation/menu/unlock |
| US 6,078,820 (Nokia) | 2000-06-20 | (f) — formatted amount/payment message | No |
| US 5,729,607 (IBM) | 1998-03-17 | (h)/(i) — automatic RFID totaling | No |
| US 3,713,148 (Cardullo) | 1973-01-23 | (h) — writable transponder | No |
| US 5,528,222 (Moskowitz) | 1996-06-18 | cover/transponder form factor | No |
| JP 4-083447 / WO 91/12698 | 1992 / 1991 | application-module concept only | No |
| VRD/Sandia patents | 1994–2000 | peripheral UI/fabrication | No |
Verdict: The strongest § 102 case against claim 1 is US 6,078,806 (for everything except the final "location information + electronic code for unlocking the reserved item" step), with US 6,073,840 as the strongest complement for the interrogator/host-authorization side. No single reference I could verify discloses the complete reservation-session flow (menu exchange → criteria → selection → amount → authorization via both wireless link and induction interrogator → registration → location/unlock code), which is consistent with the claim having survived to grant. Claim 2 (digital-cash reward) is the most vulnerable: the incentive/"Digital Cash" concept appears in 6,078,806 and in the '659 specification's own background.
Confidence caveats (explicit per operating rules):
- I could not retrieve the examiner's complete PTO-892 "References Cited" list for US 7,133,659 in this session; the analysis above rests on references verifiable in the supplied specification text plus search-confirmed family documents. There may be additional examiner-cited reservation-system art (e.g., ticket/vending/booking systems) that I could not confirm.
- The two-claim set (claim 1 independent, claim 2 dependent on digital-cash reward) is taken from the earlier session's Justia/FreePatentsOnline renderings, which I could not re-verify against the USPTO image file wrapper here.
Generated 8/27/2026, 12:47:17 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
Obviousness Analysis of US 7,133,659 B2 Under 35 U.S.C. § 103 (Pre-AIA)
0. Scope note and evidentiary caveat
The user's instruction references "the Prior Art section of this page." The Google Patents rendering supplied with this task does not reproduce the formal "References Cited" section, so I reconstructed the prior-art universe from two sources: (a) the references cited by name in the specification's own Background and Detailed Description, and (b) independently verified database records (Espacenet, Google Patents, FreePatentsOnline, USPTO.report, FindLaw). I also rely on the claim reconstruction from the earlier analysis (two claims; claim 1 independent; claim 2 dependent), since the provided text truncates before the claims. Where I could not independently verify a reference (flagged below), I say so.
All references cited here were published before the earliest provable priority date of the reservation-method claims (see § 3), so they qualify as prior art under pre-AIA 35 U.S.C. § 102.
1. The claimed invention (as reconstructed)
Claim 1 is a method of operating a reservation system between a user's terminal (a mobile station/PTD) and a second (vendor/kiosk) terminal, in which the user terminal runs at least one application:
| # | Limitation (plain-language) |
|---|---|
| 1a | Application opens a communication link to the second terminal over a wireless interface |
| 1b | User terminal receives a menu message about the user's needs; user answers are formed into a criteria information message |
| 1c | Criteria message is sent to the second terminal |
| 1d | User terminal receives a second menu message listing available items matching the criteria |
| 1e | User selects one or more items; a selection message is sent |
| 1f | User terminal receives an amount-to-pay message with transaction information |
| 1g | User enters input authorizing payment from the user terminal to the second terminal |
| 1h | A communication link is established through an electromagnetic induction interrogator (the RFID/transponder link of the device cover) |
| 1i | The payment transaction is registered with the second terminal and the application |
| 1j | User terminal receives location information for the selected item and an electronic code for unlocking that item |
Claim 2 adds: receiving digital cash (electronic value) as a reward for using the system.
The specification maps these limitations onto concrete, acknowledged-in-the-patent use cases: fueling (FIG. 3–5A), parking (FIG. 7), hotel room access (FIG. 8) — where the "location information + unlock code" limitation plainly describes a room number and electronic room key — POS (FIG. 9), peer-to-peer (FIG. 10), and m-commerce (FIG. 11).
2. Verified prior-art record
| Ref. | Date | Subject | Verification |
|---|---|---|---|
| US 6,078,806 (Heinonen, Terho, Marttila, Rautiola; Nokia) | Issued Jun. 20, 2000; filed May 8, 1998; family priority Feb. 15, 1995 | Method for using applications in a mobile station; passive/active application modes (power-up, menu, automatic); payments from mobile station to external terminal; registering a payment transaction with an external terminal and the application; PIN comparison before registering; establishing a communication link, verifying account balance, registering payment; SMS download of "digital cash"/transaction credit value; electric money purse; local IR data transfer to a cash register/payment terminal with a second transceiver | Espacenet (URL below); Google Patents US6078806A; FreePatentsOnline rendering of continuation US 6,418,326 (claim text: "registering a payment transaction with at least one of an external terminal and the at least one application program"; "entering information…comparing the entered information to the identification information"; "communicating a Short Message Service (SMS) message…for retrieving the information specifying the transaction credit value"; "establishing a communication link between the mobile radio communication unit and the external terminal; verifying that an account…has at least a predetermined balance; and registering a payment transaction") |
| US 6,073,840 (Marion; Gilbarco Inc.) | Issued Jun. 13, 2000; filed Mar. 5, 1998 | Fuel-dispensing/retail system with transponder prepayment: wireless communication electronics for communicating with a remote communication unit (transponder), dispenser + customer interface, control system that stores value in association with the transponder's unique ID, communicates with the unit subsequent to storage, and deducts value to effect payment; transponder ID + POS transactions; purchase of goods/services (car wash, QSR food) at the dispenser; central control system; RF/microwave/IR interrogation | Google Patents US6073840A; FreePatentsOnline/6073840.html; expressly incorporated into the '659 specification |
| US 6,078,820 (Well et al.; Nokia) | Issued Jun. 20, 2000 | Real-time SMS application messaging via SMSC-linked server; formatted SMS (DESC) messages parsed at the mobile station; Application Identifier entry; starting an application and displaying data per the identified application; store-and-forward messaging | FreePatentsOnline/6078820.html; Google Patents US6078820A; expressly incorporated into the '659 specification |
| US 5,729,607 (Schkolnick et al.; IBM) | Issued Mar. 17, 1998 | Intelligent shopping cart; RFID-labeled items; automatic identification and price totaling; energy-field checkout | Cited in '659 background |
| US 3,713,148 (Cardullo et al.) | Issued Jan. 23, 1973 | Transponder with changeable/writable memory | Cited in '659 background |
| US 5,528,222 (Moskowitz et al.) | Issued Jun. 18, 1996 | Thin, flexible-form-factor RFID transponder | Cited in '659 background |
| JP 4 083 447 | 1992 | Mobile phone augmented by a separate memory card carrying applications | Cited in '659 background; not independently re-verified this session |
| WO 91/12698 | 1991 | Mobile phone augmented by an add-in smart card to control phone features | Cited in '659 background; not independently re-verified this session |
| SABRE reservation system / US 4,359,631 (reissued as RE 32,115) | SABRE in public use since 1962; '631 issued 1982 | Interactive, menu-driven, multi-institution reservation/booking systems (airlines, hotels, rental cars); interactive self-service sales terminals accepting orders and payment | Federal Circuit, Lockwood v. American Airlines, Inc., 107 F.3d 1565 (Fed. Cir. 1997) (URL below), affirming obviousness of an interactive reservation-terminal patent over SABRE + the '631 terminal |
| US 5,887,266 (Heinonen et al.; Nokia) | Issued Mar. 23, 1999 | Earlier Nokia mobile-station payment patent; parent of US 6,078,806 | Surfaced in US 6,418,326 search record |
Excluded: JP-7133659-B2 (unrelated Interdigital patent surfaced by identifier search; different document, per your instruction) and family members US 7,155,199 B2 / US 2005/017068 A1 (same priority date as the '659, so not prior art).
3. Priority-date analysis (threshold point)
US 7,133,659 is a divisional of US 09/675,618 (issued as US 6,771,981), which is in turn a continuation-in-part of US 6,078,806. The earlier analysis correctly notes the reservation-method claim may not be entitled to the 1995 family priority date if the reservation flow (criteria → matching-items menu → amount-to-pay → unlock code) lacked written-description support in the 1995/1996/1998 applications. If that is so, the effective prior-art date for claim 1 is at most September 29, 2000 — which makes US 6,078,806, US 6,073,840, and US 6,078,820 (all June 2000) solid § 102(a)/(e) prior art. Even if the earlier date were awarded, all other references (1973–1998) remain prior art, and § 103 could still be made out over the RFID/reservation art alone. This is an important litigation vulnerability to flag.
4. Proposed combinations and element mapping
Combination A (primary): US 6,078,806 + US 6,073,840, optionally + US 5,729,607
This is the cleanest § 103 case, and it is essentially the patent's own architecture: the '806 mobile-station payment-application framework, plus the '840 RFID/induction-interrogator payment environment that the '659 specification expressly incorporates.
| Claim 1 limitation | US 6,078,806 | US 6,073,840 (+ 5,729,607) |
|---|---|---|
| 1a wireless link opened by application | Mobile station application initiates a connection to the MSC/external terminal (FIGS. 5B of the '659; steps 200–207 mirroring '806); SMS-based data exchange | Dispenser communicates with remote transponder unit via RF/microwave/IR |
| 1b first menu + criteria message | "Menu type" application: user selects application from a menu shown on the display; user input drives the application | Dispenser GUI video menu (keypad 302/display 300) prompting customer needs (e.g., car wash, QSR order) |
| 1c send criteria message | Data transfer between mobile station and external terminal (IR transceiver in '806) | Transponder↔dispenser RF communications; customer selections at GUI |
| 1d second menu listing matching items | Menu-driven application flow | Dispenser "video menu…to facilitate selection of the various services, goods and food available for purchase" |
| 1e selection message | User selects operations from menus | Customer selects goods/services at dispenser |
| 1f amount-to-pay message | Application sends/receives transaction data; balance/credit check | Dispenser totals transaction; "value of an amount of a transaction" |
| 1g user authorizes payment | Entering information (PIN) compared to stored identification before payment is registered — '806 claims 3 and 11 | Customer authorizes prepaid transponder payment |
| 1h electromagnetic induction interrogator link | (Not in '806 — uses IR) | '840 supplies this element: RFID transponder interrogator area 381 / interrogator electronics 352, RF/microwave interrogation; '5,729,607 confirms the retail use of RF interrogation fields for automatic payment |
| 1i register transaction with terminal AND application | Literal teaching: "registering a payment transaction with at least one of an external terminal and the at least one application program" ('806/6,418,326 claim 2) | Control system effects storage of value and deduction (prepaid transponder) |
| 1j location info + electronic unlock code | (Not explicit) | '840: dispenser tells customer to "pick up the goods and services at the station store or the outlet of a vending machine"; combined with the standard reservation/fulfillment paradigm (see Combination C) |
Combination B: add US 6,078,820 — covers claim 2 and the messaging flow
The '820 patent teaches exactly the mechanism the '659 specification itself adopts for post-transaction communication: specially formatted SMS messages carrying an Application Identifier, parsed at the mobile station, which start the identified application and load structured data (the "APP;ID982 … AMOUNT:2100" example in the '659 is a direct descendent of the '820 DESC format). This supplies:
- a motivation and mechanism for the menu/message exchange of claim 1 (formatted application messages over SMS);
- the digital-cash reward of claim 2, because '806 already teaches SMS-delivered "digital cash"/transaction credit value and '840 teaches storing value in association with the transponder ID and later crediting the customer ("Digital Cash" incentives in the '659's fueling embodiment are drawn from these).
Combination C: add the reservation/booking paradigm (SABRE-type systems; Lockwood/'631)
The remaining "novel-looking" limitations — 1b–1e (criteria → matching items → selection) and 1j (location + unlock code) — are the stock-in-trade of reservation systems. Lockwood v. American Airlines confirms that by the 1960s–1980s, interactive menu-driven systems booking airlines, hotels, and rental cars (SABRE) and self-service terminals accepting orders and payment (US 4,359,631 / RE 32,115) were established prior art, and the Federal Circuit affirmed that a combination of exactly those references rendered a reservation-terminal patent obvious. A POSITA implementing the '806 menu-type application for a hotel (FIG. 8) or parking (FIG. 7) use case would have had every reason to (i) query the user's needs, (ii) return a filtered availability menu, (iii) present the amount payable, and (iv) upon payment, return the room number/space identifier and an electronic unlock code — because delivering a location identifier and an electronic access code after payment is the universal fulfillment step of electronic hotel-lock and access-control systems (e.g., hotel keycard/proximity lock systems well known before 2000). The electronic-unlock-code delivery is thus a routine, predictable fulfillment step rather than an inventive leap.
5. Motivation to combine (KSR v. Teleflex framework)
- Same field of endeavor / same problem. All references target mobile/remote electronic payment and identification. '806, '840, '5,729,607, and the reservation art all address "how does a customer select, pay for, and obtain a good or service without cash or plastic?"
- Express teaching in the '659 itself. The specification concedes that the mobile station + cover "provides a means for data transfer in an electronic payment system as described in U.S. Pat. No. 6,078,806," and it incorporates '840 (fueling) and '820 (SMS parsing) wholesale. A patentee's own incorporation of a reference is powerful evidence that a POSITA would look to it and combine it.
- Design incentives / market forces. The '659 background complains that keyfob RFID tags are "one way," provide no user feedback, and add another item to carry; '806 provides the interactive mobile-station UI; '840 provides the installed RFID interrogator infrastructure. Combining them yields the predictable benefit the patent claims (feedback, electronic receipts, post-transaction messaging) — precisely the KSR "known elements combined according to known methods to yield predictable results" scenario.
- "Obvious to try" / finite known options. Two proximity-transaction technologies existed (IR per '806; RF/induction per '840/5,729,607); substituting the RFID cover for the IR link is a design choice the patent itself motivates ("RFID system infrastructures already exist for many commercial and consumer applications," unlike Bluetooth).
- Level of ordinary skill. A POSITA (c. 2000) would be a designer of mobile communications devices and m-commerce systems familiar with GSM/SMS, WAP, smart cards, RFID transponders, and reservation/booking systems. All limitations are conventional building blocks.
6. Secondary considerations
No evidence of long-felt need, industry copying, commercial success, or unexpected results is apparent from the record. The "SmartCover" is described as "inexpensive—thus disposable and interchangeable," and the combination yields only the predictable aggregation of (i) menu-driven mobile payment, (ii) RFID identification, and (iii) standard reservation fulfillment. Secondary considerations would not rescue the claims if the primary case above is made out.
7. Weaknesses in the obviousness case (and responses)
- The "electromagnetic induction interrogator" limitation (1h). '806 uses IR, not induction. Response: '840 expressly uses RF transponder interrogation for payment at a kiosk, and '5,729,607 uses RF interrogation fields for automatic checkout; substituting one known short-range wireless medium for another in the same payment context is the classic KSR design choice. This is the patent's least distinctive contribution.
- The "unlock code" limitation (1j). This is the strongest patentee argument. Response: electronic access codes delivered after payment (hotel keycard/proximity locks, rental-car and vending fulfillment) were conventional; and the claim does not require the code to be a lock credential of any particular sophistication — merely "an electronic code for unlocking" the reserved item, which is the standard fulfillment output of any electronic reservation/access system.
- Priority-date uncertainty. If claim 1 is entitled to the 1995 family date, June-2000 references ('806, '840, '820) fall away. But the reservation-method claim almost certainly lacks 1995 written-description support (the 1995/1996 filings are about SIM-style payment applications, not reservation menus), and even on the 1995 date the combination of SABRE-type reservation art + Cardullo/Moskowitz RFID transponders + '5,729,607 + WO 91/12698/JP 4 083 447 (all pre-1995) still makes a strong § 103 case for the generic method.
- Unverified references. JP 4 083 447 and WO 91/12698 are cited only from the patent's own background and were not independently re-verified this session; they are corroborative, not load-bearing, in the analysis above.
8. Conclusion
On the reconstructed claim set, US 7,133,659's claims would very likely have been obvious under pre-AIA 35 U.S.C. § 103. The primary combination — US 6,078,806 (Nokia's mobile-station payment-application method, including menu-type applications, PIN-authorized payment, transaction registration with the terminal and the application, and SMS-delivered digital cash) with US 6,073,840 (Gilbarco's RFID transponder prepayment and interactive dispenser retail system, expressly incorporated by the patent itself) — accounts for nearly every limitation of claim 1 and, with US 6,078,820 added, fully accounts for claim 2. The reservation-specific flow (criteria menu → matching items → amount → location/unlock code) is supplied by the long-established interactive reservation-systems art confirmed in Lockwood v. American Airlines, and the "electromagnetic induction interrogator" limitation is supplied by the ubiquitous RFID-transponder art ('840; '5,729,607; '3,713,148; '5,528,222). The motivation to combine is grounded in the shared field, the patent's own incorporation of these very references, and the predictable benefits of adding an interactive UI and post-transaction messaging to an otherwise "one-way" RFID payment token.
Key sources: Google Patents US7133659B2 (patent record) · Espacenet US6078806A · Google Patents US6073840A / FreePatentsOnline 6073840 · FreePatentsOnline 6078820 · FreePatentsOnline 6418326 (continuation claims of '806) · Lockwood v. American Airlines, Fed. Cir. (FindLaw, No. 96-1168, decided Mar. 4, 1997).
Generated 8/27/2026, 12:47:53 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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