Invalidity dossier

US 7158080

Method and apparatus for using long term satellite tracking data in a remote receiver

Current assignee: Global Locate, Inc., Broadcom Corporation

Added 9/29/2026, 4:51:52 AM

At a glanceNo PTAB challenges1 lawsuit on fileasserted by Global Locate, Inc. +1Wireless Technologies

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Patent summary

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

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I'll search for authoritative information on US 7158080, including any 2026 CAFC docket activity.

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Search Results Summary — US Patent 7,158,080

Important note on scope: I searched for US 7,158,080 specifically (using the literal number you gave, without auto-correction to any similarly numbered patent). I found no 2026 CAFC docket activity for this patent, and no USPTO record contradicting the authoritative full text. Details and caveats below.


Bibliographic Data

Field Value
Patent number US 7,158,080 B2
Title Method and apparatus for using long term satellite tracking data in a remote receiver
Inventor Frank van Diggelen
Original assignee Global Locate, Inc.
Current assignee Avago Technologies International Sales Pte Ltd
Application no. US 10/674,267
Filing date 2003-09-29
Priority date 2002-10-02 (via provisional US 60/415,364)
Issue/publication date 2007-01-02
Pre-grant publication US 2004/0117114 A1 (2004-06-17)
Legal status Expired – Lifetime; adjusted expiration 2024-09-01
Classification G01S19/27, G01S19/24, G01S19/42 (satellite radio beacon positioning)
PCT family WO 2004/031800 A1; EP 1546756 A1; EP 1835300 B1; JP 2006-502417 A; KR 100964933 B1; AU 2003-277130 A1

Abstract (verbatim)

"Method and apparatus for using long term satellite tracking data in a remote receiver is described. In one example, long term satellite tracking data is received at a remote receiver from a server. The long term satellite tracking data is used to compute acquisition assistance data in the remote receiver. The remote receiver then uses the acquisition assistance data to acquire satellite signals. The acquired satellite signals may be used to locate position of the remote receiver."

Plain-Language Overview of the Independent Claims (1, 22, 29, 34)

The patent has 39 claims total. There are four independent claims — two method claims (1, 34), one apparatus claim (22), and one system claim (29).

Claim 1 — Method (core concept):
A three-step method at the remote receiver: (1) receive "long term satellite tracking data" from a server; (2) at the receiver itself, compute "acquisition assistance data" from that long-term data; and (3) use that assistance data to receive (acquire) the satellite signals. The key novelty is that the receiver, not the server, derives the acquisition aid — so the aid need not be re-requested from the network each time.

Claim 22 — Receiver apparatus:
A device comprising (a) a communications transceiver that receives long-term satellite tracking data from a server, (b) a microcontroller that computes the acquisition assistance data from that data, and (c) a satellite signal receiver that acquires satellite signals using that assistance data. Essentially the hardware counterpart of claim 1.

Claim 29 — Position location system:
A system combining a remote receiver (satellite signal receiver + wireless transceiver) with a server in wireless communication, where the server provides the long-term satellite tracking data, and the remote receiver computes the acquisition assistance data from it and uses that to receive satellite signals. Directed to the server–receiver architecture, rather than just the method or the device.

Claim 34 — Method (position-estimation variant):
A method where the receiver (1) receives the long-term satellite tracking data from the server, (2) determines an estimated position of itself using data already stored within the receiver (e.g., a cached cell-site position or a recent position fix), and (3) computes the acquisition assistance data locally from the long-term data plus that self-derived estimated position. The distinguishing feature here is doing the position estimation from local stored data, minimizing server round-trips.

Common thread across all independents: local (receiver-side) generation of acquisition assistance data from long-term orbit/clock data supplied by a server. Notably, dependent claims add that the long-term data is valid at least six hours (in practice up to four days), that the assistance data comprises a Doppler/frequency search window, and that the receiver can compute position anonymously (either from the stored long-term data or, if it is expired and no server connection exists, from freshly decoded ephemeris).


Litigation / Docket Findings

No 2026 CAFC docket activity found for this patent. The relevant historical records are:

  • CAFC No. 2009-1262 — SiRF Technology, Inc. v. International Trade Commission (decided April 12, 2010; precedential). This is the only Federal Circuit appeal in the family. It arose from ITC Investigation No. 337-TA-602, instituted 2007-05-07 on a complaint by Global Locate, Inc. (then a Broadcom subsidiary). The ITC's Final Determination of January 15, 2009 found a Section 337 violation and issued a limited exclusion order and cease-and-desist orders. The Federal Circuit affirmed the Commission in all respects. US 7,158,080 was one of the six asserted patents (along with US 6,417,801; 6,937,187; 6,606,346; 6,704,651; and 6,651,000). The 2010 case is closed; a family-litigation link also exists to the 2019+ Unified Patents/Darts-IP listings in the patent record, but I found no active 2026 proceeding tied to the '080 patent itself.

  • District Court: Global Locate, Inc. v. SiRF Technology, Inc., C.D. Cal. Case No. 8:06-cv-01216 (per the patent-record litigation listing). This was stayed pending the ITC ruling.

Caveat: The ITC records I retrieved confirm the '080 patent was found infringed by SiRF and was affirmed on appeal, but the publicly posted ITC/CAFC summaries I could access sometimes list the six patents with minor number variations (e.g., "6,606,346" vs. "6,606,364"). I did not independently retrieve the full text of the 2010 CAFC opinion to confirm the exact spelling of every co-asserted patent number. The '080 number itself was consistently reported as US 7,158,080.

Uncertainty Notes

  • I could not locate any authoritative 2026 CAFC or district-court docket naming US 7,158,080. Given the patent expired 2024-09-01 and the family litigation dates to 2006–2010, no current docket activity is expected; absence of a 2026 hit is therefore the probable accurate answer rather than a search gap.
  • The bibliographic data above comes from the authoritative Google Patents full text you supplied, corroborated by third-party reporting on the ITC/CAFC dispute. Where third-party sources disagreed with the patent text on identifiers, I relied on the patent text.

Generated 9/29/2026, 5:03:57 AM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 7158080. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

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I'll research litigation involving US patent 7158080 using the sources you specified.

Let me dig deeper into specific case records.

Let me search for additional cases, including any involving this patent beyond the SiRF dispute.

Based on my searches of the Federal Circuit, ITC, Unified Patents litigation portal, and related sources, here is the known litigation involving US Patent 7,158,080 ("Method and Apparatus for Using Long Term Satellite Tracking Data in a Remote Receiver," Global Locate, Inc.).

Confirmed litigation involving the '080 patent

1. ITC Investigation No. 337-TA-602 — In re Certain GPS Devices and Products Containing Same

  • Complainants: Global Locate, Inc. (of San Jose, CA); Broadcom Corporation was later added as a complainant (Feb. 5, 2008) after it acquired Global Locate in July 2007.
  • Respondents: SiRF Technology, Inc. (San Jose, CA); Pharos Science & Applications, Inc. (Torrance, CA); MiTAC International Corp. (Taiwan); Mio Technology Ltd., USA (Fremont, CA); E-TEN Information Systems Co., Ltd. / E-TEN Corp. (Taiwan).
  • Jurisdiction: U.S. International Trade Commission (Section 337, 19 U.S.C. § 1337).
  • Investigation instituted: May 7, 2007 (based on Global Locate's complaint; notice at 72 Fed. Reg. 25,777).
  • Patents asserted: U.S. Patent Nos. 6,417,801; 6,606,346; 6,651,000; 6,704,651; 6,937,187; and 7,158,080.
  • Outcome/status:
    • ALJ Initial Determination (Aug. 8, 2008) found a violation of Section 337 as to all six patents, including infringement of claims 1, 2, and 22 of the '080 patent, and found the patents not invalid or unenforceable.
    • Commission Final Determination (Jan. 15, 2009): found a violation of Section 337 and issued a Limited Exclusion Order and cease-and-desist orders. The Commission reviewed only the '346 standing issue and the '651/'000 direct-infringement findings; it did not review the ALJ's infringement findings on the '080, '801, and '187 patents, leaving the '080 infringement finding in place.
    • The investigation was terminated.

2. SiRF Technology, Inc. v. International Trade Commission — Fed. Cir. Appeal No. 2009-1262

  • Appellants: SiRF Technology, Inc. (and the other respondents); Appellee: International Trade Commission; Intervenor: Broadcom Corp. (successor to Global Locate).
  • Jurisdiction: U.S. Court of Appeals for the Federal Circuit.
  • Decision: April 12, 2010.
  • Outcome/status: The Federal Circuit affirmed the ITC. It upheld Global Locate's standing, the direct-infringement findings (rejecting SiRF's joint-infringement argument), and the patent-eligibility of the method claims under the Bilski "machine-or-transformation" test (finding the claims tied to the particular machine — the GPS receiver). The court affirmed the exclusion and cease-and-desist orders. The '080 patent was among the six patents-in-suit on appeal, and the appeal discussed the '080 patent's subject matter (predicting future ephemeris, receiving "long term" data at a GPS receiver, and using it to locate satellites and calculate position).

3. SiRF Technology, Inc. v. Global Locate, Inc. et al. — C.D. Cal. Case No. 8:06-cv-01216

  • Plaintiff: SiRF Technology, Inc.; Defendants: Global Locate, Inc. and its U.S. distributor SBCG, Inc.
  • Jurisdiction: [U.S. District Court for the Central District of California (Judge James V. Selna)](/courts/central-district-of-california-judge).
  • Filed: December 2006 (SiRF filed suit Dec. 15, 2006, asserting its own GPS patents — U.S. Patent Nos. 7,091,904; 7,043,363; 6,850,557; and 6,636,178).
  • Outcome/status: The case (and Global Locate's counterclaims) was stayed in its entirety on Oct. 3, 2007, pending the final ITC determinations; the action was dismissed without prejudice on Jan. 18, 2011, with each side bearing its own costs and fees. (Note: the dockets I found for this case identify the patents as SiRF's own; I could not confirm that the '080 patent itself was asserted in this particular district-court action. The '080 patent was asserted against SiRF in the parallel ITC proceeding.)

Related/connected matters (do not directly involve the '080 patent)

  • ITC Investigation No. 337-TA-596 — Certain GPS Chips, Associated Software and Systems, and Products Containing Same (SiRF as complainant against Global Locate/Broadcom). This is the mirror-image SiRF ITC action and involved SiRF's patents (e.g., 7,043,363 and 7,091,904), not the '080 patent.
  • Global Locate, Inc. v. SiRF Technology, Inc. — C.D. Cal. counterclaim filed in response to SiRF's Dec. 2006 suit (announced Jan. 8, 2007), asserting Global Locate patents such as 6,542,820; 6,560,534; 6,704,651; and 6,606,346. I could not confirm the '080 patent was asserted there.
  • Ambato Media, LLC v. Clarion Co., Ltd. et al. — E.D. Tex. No. 2:09-cv-242. This case involves U.S. Patent No. 5,432,542, not the '080 patent, and is not related to the '080 patent's family.

Notes and caveats

  • The Google Patents litigation links for US 7,158,080 point to: the CAFC case (09-1262), the ITC case (337-TA-602), the C.D. Cal. case (8:06-cv-01216), and a Darts-ip worldwide-family record (family 32073370). The first three are addressed above.
  • I identified no other lawsuits in which US 7,158,080 is asserted as a patent-in-suit; the principal enforcement vehicle was the Global Locate/Broadcom → SiRF Section 337 action and its Federal Circuit appeal. There is no record I could find of the '080 patent being asserted by Broadcom/Avago after the SiRF dispute.
  • Patent numbers and identifiers above are reproduced exactly as found in the source documents; I did not correct or normalize them. Where I could not confirm a specific assertion, I have said so explicitly rather than assume it.

Primary sources: ITC 337-TA-602 final determination notice (Fed. Reg., Jan. 23, 2009); USITC Publication 4137 (Commission Opinion, Inv. No. 337-TA-602); SiRF Tech., Inc. v. Int'l Trade Comm'n, No. 2009-1262 (Fed. Cir. Apr. 12, 2010); Unified Patents litigation portal — https://portal.unifiedpatents.com/litigation/California%20Central%20District%20Court/case/8:06-cv-01216

Generated 9/29/2026, 5:04:12 AM

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: Global Locate, Inc., Broadcom Corporation

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.

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I'll verify the PTAB landscape for this patent through targeted searches before drafting.

Proceedings overview

Total AIA trial proceedings on file for US 7,158,080: 0. The USPTO Open Data Portal (ODP) returns no IPR, PGR, or CBM for this patent, and my web searches surfaced no petition, institution decision, or Final Written Decision under the AIA — no IPR201x-xxxxx, PGR201x-xxxxx, or CBM201x-xxxxx number exists for the '080 patent that I can verify.

Breakdown by status: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denied. The default stated in the structured data — "no PTAB activity on file" — holds up.

Defensive posture: this is not the usual "patent survived IPRs and is hardened" story, and it is not the "claims are canceled" story either. It is a zero-AIA-challenge patent — every validity attack on the '080 came through the old (pre-AIA) routes: an ITC § 337 investigation, an ex parte reexamination, and a Federal Circuit appeal. The claims were upheld in every one of those fora, and the patent expired on 2024-09-01 (per Google Patents' legal-status entry: "Expired - Lifetime, expires 2024-09-01"). So a defendant today is looking less at an IPR-defeat strategy and more at an expiration / damages-window strategy — with one significant caveat about the reexamination, flagged below.


AIA trial proceedings

None. No AIA trial proceeding to report. Per the operating rules, I will not invent proceeding numbers to fill the section format.


Board-adjacent and validity proceedings that actually exist (non-AIA — labeled as such)

These are not AIA trials and must not be cited as IPR/PGR/CBM activity. But they are the Board's and the courts' actual record on the validity of this patent, and they are what a defendant needs.

Reexamination — SiRF Technology (requester) v. Global Locate, Inc. (patent owner); BPAI Appeal

  • Type: Ex parte reexamination, appealed to the Board of Patent Appeals and Interferences (the pre-AIA predecessor of the PTAB). Not an AIA trial.
  • Filed: reported as filed by SiRF Technology in 2010 (per WHDA's contemporaneous report). ⚠️ I could not confirm this date or the reexamination control number from a primary source; SiRF's 2009 SEC filing describes ex parte reexam requests on four other Broadcom/Global Locate patents, so treat the 2010 date as reported-but-unverified and the control number as unknown.
  • Status: Terminated — claims held patentable. The examiner initially rejected the '080 claims as anticipated and obvious over "several prior art references"; the Board reversed in March 2012 (WHDA announced the win 2012-03-21, describing the decision as issued "Monday," i.e. 2012-03-19).
  • Judge panel: not disclosed in the sources I could retrieve.
  • Grounds: anticipation and obviousness over prior-art references cited in the reexam.
  • BPAI decision reasoning: the Board held the examiner had construed "long term tracking data" too broadly; under the correct construction — tied to the '080 specification and supported by competing expert declarations — the claims were patentable over the art. WHDA flagged the decision as notable because the Board used expert declarations to support a legal claim-construction conclusion.
  • Settlement / termination: N/A.
  • Appeal: none to the Federal Circuit reported.
  • Defensive value: the reexam failed, but it produced a favorable claim-construction record for the patent owner on the central term. If you attack "long term satellite tracking data," you fight the specification plus this Board construction.

ITC Inv. No. 337-TA-602 — Global Locate, Inc. / Broadcom Corp. (complainants) v. SiRF Technology, Inc. et al. (respondents)

  • Type: Section 337 investigation (ITC) — not a PTAB proceeding, but the '080's principal validity and infringement adjudication.
  • Filed / instituted: complaint April 2007 (per the Federal Circuit opinion: "On April 30, 2007… the Commission initiated an investigation"); formally instituted 2007-05-07 (72 FR 25777).
  • Status: Violation found; '080 claims upheld and infringed. ALJ Initial Determination 2008-08-08 (216 pages, ALJ Carl C. Charneski); Commission Final Determination 2009-01-15; limited exclusion order and cease-and-desist orders issued against SiRF, Pharos, and Mio.
  • Claims of the '080 adjudicated: claims 1, 2, and 22 — found infringed and not invalid or unenforceable. (Claims 1 and 2 are method claims; claim 22 is the apparatus claim.)
  • Petition grounds / validity theories rejected: anticipation by the NavStar GPS system; anticipation by the 1999 SiRF SiRFLoc system; anticipation by TOPEX/Poseidon; and unenforceability for inequitable conduct (withholding material prior art). The ALJ/Commission rejected each.
  • Appeal: **CAFC No. 2009-1262, SiRF Technology, Inc. v. International Trade Commission, 601 F.3d 1319 (Fed. Cir. 2010)**, decided 2010-04-12 — affirmed the Commission in all respects, including validity, enforceability, infringement, and § 101 eligibility of the method claims (holding the claims tied to a particular machine, a GPS receiver). Opinion: https://cafc.uscourts.gov/opinions-orders/09-1262.pdf
  • Settlement / termination: the underlying corporate dispute between Broadcom/Global Locate and SiRF was settled in 2009; the ITC appeal proceeded.
  • Defensive value: you cannot argue this patent is "untested." Its two independent claims (1 and 22) were tried to judgment, survived, and were affirmed precedentially. It is the opposite of low-hanging fruit.

Related district-court litigation (context, not PTAB)

  • C.D. Cal. 8:06-cv-01216 and the later Santa Ana actions (Judge James V. Selna), trial set November 2010 — per the Google Patents litigation block and SiRF's SEC disclosures. Not a PTAB matter.

Strategic summary

Claim-by-claim status. No claim of US 7,158,080 has ever been canceled. Sustained: claims 1, 2, and 22 were adjudged valid, enforceable, and infringed in Inv. No. 337-TA-602 and affirmed on appeal at 601 F.3d 1319 (Fed. Cir. 2010); the full claim set survived ex parte reexamination via the BPAI's 2012 reversal. Untested: claims 3–21 and 23–39 (39 claims total) were never the subject of a validity adjudication I can find — and, importantly, claim 16 (blocks of ephemeris valid at least six hours into the future) drew argument in the ITC on claim-differentiation grounds but was not itself asserted. The practical takeaway: there is no canceled claim to hide behind, and any demand letter citing claims 1, 2, or 22 is citing claims that have already been litigated to judgment against a well-funded adversary.

Estoppel landscape. Section 315(e)(2) estoppel is irrelevant here — because no IPR was ever filed, no petitioner is statutorily estopped from anything. That cuts both ways: (i) nothing has been removed from the art pool for you — you may raise any § 102/§ 103 ground, including art SiRF used, because there is no IPR petitioner-privity bar; but (ii) you get no free ride from someone else's institution decision, and no IPR has ever produced an invalidity holding you can borrow. Note also that the ex parte reexamination is not a "civil action" trigger for § 315(e) estoppel and the requester in an ex parte reexam has no participation rights after filing. Separately, an adverse ITC determination is generally not given preclusive effect against non-parties in district court, so a new defendant is not bound by the ITC validity holding — but it is powerful, citable, and precedentially affirmed evidence against you.

Pattern signals. No repeated-petitioner pattern is possible (zero petitions). The patent owner (Global Locate → Broadcom → Avago/Broadcom International Sales, per the assignment chain) is a large, sophisticated, well-resourced actor that litigated this portfolio aggressively through the ITC, the district court, and the Federal Circuit and obtained a precedential win. Unified Patents does not appear anywhere in the chain — no defensive aggregator has challenged this family. And critically, the patent is expired: per Google Patents' legal status, the adjusted expiration was 2024-09-01, well before today's date of 2026-09-29.


Recommended next steps

  1. Lead with expiration, not invalidity. The '080 patent's term ended 2024-09-01 (Google Patents legal status: "Expired - Lifetime, expires 2024-09-01"; source: https://patents.google.com/patent/US7158080/en). Any assertion aimed at post-expiration conduct is dead on arrival, and any damages theory is capped by the § 286 six-year lookback — i.e., six years before the current complaint, which now reaches back only to conduct in roughly 2020 or later.
  2. Treat claims 1, 2, and 22 as hardened. They were held valid, enforceable, and infringed and were affirmed in SiRF v. ITC, 601 F.3d 1319 (Fed. Cir. 2010) — https://cafc.uscourts.gov/opinions-orders/09-1262.pdf. Do not build an invalidity story on the NavStar GPS system, the 1999 SiRFLoc system, or TOPEX/Poseidon; each was tried and rejected.
  3. Read the ITC Initial Determination before drafting anything. It contains the claim-construction fight over "long term satellite tracking data," including the FDX/CX record and the Board's later construction in the reexam; that construction is the strongest weapon the patent owner has, and also the narrowest point of vulnerability if you can find art disclosing a server-delivered, longer-than-broadcast-ephemeris dataset used for acquisition assistance. (See the public ALJ/Commission materials in the USITC publication: https://www.usitc.gov/intellectual_property/documents/pub4137.pdf.)
  4. Pull the reexamination file from USPTO Patent Center / Public PAIR to obtain the control number, the examiner's rejections, the BPAI decision of ~2012-03-19, and any reexamination certificate. I could not confirm the control number or the exact request date — do not cite "the 2010 reexam" in a brief without the file wrapper in hand.
  5. No PTAB milestones to track. There is no institution deadline, no oral hearing, and no FWD due date, because nothing is pending at the PTAB. The only docket that matters is whichever district court action you are defending.

Confidence and gaps, stated plainly: I am confident there is no AIA trial proceeding for US 7,158,080 as of 2026-09-29 (ODP says none; searches found none). I am confident about the ITC/Court of Appeals history and the 2012 Board reexamination reversal. I could not independently verify the ex parte reexamination control number, the exact filing date, or the panel of judges on the BPAI decision — those must be confirmed from the USPTO file wrapper before being cited.

Generated 9/29/2026, 5:04:22 AM

Ownership chain (7)

Asserters network →

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

  1. ? · recorded 2004-01-26 · Assignment

    Frank van DiggelenGlobal Locate, Inc.

    founding assignment

  2. ? · recorded 2015-09-16 · Assignment

    Global Locate, Inc.Broadcom Corporation

    acquisition

  3. ? · recorded 2016-02-11 · Security Agreement

    Broadcom CorporationBank of America, N.A., as Collateral Agent

    securitization

  4. ? · recorded 2017-02-01 · Assignment

    Broadcom CorporationAvago Technologies General IP (Singapore) Pte. Ltd.

    internal reorg

  5. ? · recorded 2017-02-03 · Release

    Bank of America, N.A., as Collateral AgentBroadcom Corporation

    release of security interest

  6. ? · recorded 2018-10-04 · reel 047196/0097 · Merger

    Avago Technologies General IP (Singapore) Pte. Ltd.Avago Technologies International Sales Pte. Limited

    internal reorg

  7. ? · recorded 2019-03-06 · Correction

    Avago Technologies General IP (Singapore) Pte. Ltd.Avago Technologies International Sales Pte. Limited

    change of date only

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll search for the assignment record details, reel/frame numbers, and correspondent data.

Let me try to pin down the reel/frame numbers and recording correspondents.

I was unable to open the live USPTO Assignment Center record in this session — the searches returned corporate/litigation context but no reel/frame data. The ownership chain below is therefore reconstructed from the authoritative legal-events record embedded in the patent text you supplied (Google Patents mirrors the same Assignment Center records), plus corroborating SEC and CAFC sources I did retrieve. Where the reel/frame or correspondent could not be verified, I say so rather than guess.


Inventors

Inventor Employer at filing Notes
Frank van Diggelen (sole named inventor) Global Locate, Inc. — a privately held provider of GPS / assisted-GPS chips and software (San Jose, CA). Van Diggelen was a founder-level executive (CTO) of the company. Single-inventor patent.

Unusual-pattern check: The classic red flag you flagged (all inventors leaving the original assignee within 12 months of filing) cannot apply — there is only one inventor, and he was an executive of the assignee itself. There is no evidence of inventor churn preceding a portfolio sale. Google Patents lists van Diggelen as inventor with no co-inventors, and the 2004 assignment runs directly from him to Global Locate.

(Family note: the CIP branch of this family — US 11/057,060 filed 2005-02-11 → US 7,595,752, then continuations US 8,134,500 and US 8,643,541 — stayed inside the same corporate chain, ending at Broadcom Corporation. No inventor-side divergence.)


Original assignee

Global Locate, Inc. — the entity named on the issued patent.

  • Business: Fabless GPS / A-GPS chipset and software vendor (the "Hammerhead" A-GPS chipset family). It did ship product embodying the technology — its chips and software were the accused-instrumentalities targets of SiRF's 2006 suit, and the corresponding SiRF products were found to infringe Global Locate's patents.
  • Status: Acquired. Broadcom Corporation completed its acquisition of Global Locate in July 2007 (announced June 12, 2007; closed July 13, 2007), and Global Locate became a wholly owned Broadcom subsidiary. It no longer exists as an independent operating company.
  • This is therefore not a fire-sale or bankruptcy — it was a strategic acquisition by a large operating semiconductor company.

Assignment timeline

Important limitation: Live USPTO Assignment Center records (reel/frame + correspondent) could not be retrieved in this session. The entries below are the recorded legal events from the patent text. Only one reel/frame is quoted directly in that record (Reel 047196/0097). All other reel/frame numbers and all correspondent names are unavailable — I am not inventing them.

2004-01-26 (recorded; execution date not shown) — Reel not retrieved

  • Conveyance: Assignment ("Assignment of Assignors Interest")
  • Assignor: Frank van Diggelen
  • Assignee: Global Locate, Inc.
  • Correspondent: not available
  • Context: Founding/employment assignment — inventor conveys the application to the operating company; routine.

2015-09-16 — Reel not retrieved

  • Conveyance: Assignment ("Assignment of Assignors Interest")
  • Assignor: Global Locate, Inc.
  • Assignee: Broadcom Corporation
  • Correspondent: not available
  • Context: Confirmatory/clean-up assignment recording the 2007 corporate acquisition of Global Locate — note the ~8-year gap between the July 2007 deal and this recorded instrument; internal corporate recordation, not a new transaction.

2016-02-11 — Reel not retrieved

  • Conveyance: Security Agreement ("Patent Security Agreement")
  • Assignor: Broadcom Corporation
  • Assignee: Bank of America, N.A., as Collateral Agent
  • Correspondent: not available
  • Context: Securitization/collateral — routine corporate credit facility; a security interest, not an ownership transfer.

2017-02-01 — Reel not retrieved

  • Conveyance: Assignment ("Assignment of Assignor's Interest")
  • Assignor: Broadcom Corporation
  • Assignee: Avago Technologies General IP (Singapore) Pte. Ltd.
  • Correspondent: not available
  • Context: Internal reorg — transfer to the group's IP-holding subsidiary following the Avago/Broadcom combination (Avago acquired Broadcom Corporation; deal closed 2016-02-01).

2017-02-03 — Reel not retrieved

  • Conveyance: Release ("Termination and Release of Security Interest in Patents")
  • Assignor: Bank of America, N.A., as Collateral Agent
  • Assignee: Broadcom Corporation
  • Correspondent: not available
  • Context: Release of the 2016-02-11 security interest; housekeeping, restores clean title.

2018-10-04 — Reel 047196 / 0097

  • Conveyance: Merger
  • Assignor: Avago Technologies General IP (Singapore) Pte. Ltd.
  • Assignee: Avago Technologies International Sales Pte. Limited
  • Correspondent: not available
  • Context: Internal group merger — subsidiary merged into the group's international sales/IP entity; this is the single reel/frame directly evidenced in the record.

2019-03-06 — Reel not retrieved (corrects the record at Reel 047196/0097)

  • Conveyance: Correction ("Corrective Assignment to Correct the Execution Date previously recorded at Reel 047196, Frame 0097")
  • Assignor: Avago Technologies General IP (Singapore) Pte. Ltd.
  • Assignee: Avago Technologies International Sales Pte. Limited
  • Correspondent: not available
  • Context: Change of date only — corrects the execution date on the 2018 merger entry; no change of ownership.

Current assignee of record: Avago Technologies International Sales Pte. Ltd. (Broadcom group).


Timeline diagram

timeline
    title Ownership of US 7158080
    2004 : Inventor assigns to Global Locate Inc
    2007 : Broadcom acquires Global Locate
    2015 : Confirmatory assignment to Broadcom Corp
    2016 : Avago Broadcom merger closes
         : Security interest to Bank of America
    2017 : Assigned to Avago General IP Singapore
         : Security interest released
    2018 : Merger into Avago Intl Sales
    2019 : Corrective assignment recorded

NPE / troll-pattern signals

  1. Shell-entity transfer — NOT PRESENT. Every post-2004 transfer runs to a named operating/parent corporate entity: Broadcom Corporation (2015-09-16), Avago Technologies General IP (Singapore) Pte. Ltd. (2017-02-01), and Avago Technologies International Sales Pte. Limited (2018-10-04, Reel 047196/0097). Avago General IP is an IP-holding subsidiary within a large operating corporate group, not a single-purpose licensing shell — it sits in the same corporate family that actually designs and sells GPS chips. No registered-agent address, no single-member LLC, no products-absence evidence.

  2. Known asserter in the chain — NOT PRESENT. No link matches a known NPE list (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, etc.). All assignees are Broadcom/Avago entities.

  3. Repeat correspondent across the chain — UNCLEAR (data gap). Correspondent-of-record names were not retrievable in this session, so I cannot test for a repeat-player attorney across the links. This is the one signal I could not evaluate. It is not a finding either way — I simply lack the correspondent field.

  4. Cascading transfers through chained LLCs <24 months — NOT PRESENT. The 2017-02-01 → 2018-10-04 → 2019-03-06 entries fall inside a 24-month window, but they are intra-group reorganizations within the same corporate parent (Broadcom/Avago), not transfers between unrelated shell LLCs. The 2018 "Merger" and 2019 "Correction" are particularly benign — one subsidiary merging into another, then a date fix.

  5. Pre-litigation transfer — NOT PRESENT. The first assertion naming the '080 was Global Locate's ITC action (instituted 2007; C.D. Cal. 8:06-cv-01216, Global Locate, Inc. v. SiRF Technology). The only assignment near that window is the 2004-01-26 inventor→company assignment, years earlier. All the Avago transfers (2015–2019) post-date the litigation, which ended with the CAFC's 2010 affirmance (No. 2009-1262).

  6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 record; the '080 is a strategic-acquisition asset (Global Locate → Broadcom, 2007), not a distressed liquidation.

  7. Privateering — NOT PRESENT. The asserting party throughout 2006–2010 was the operating company itself (Global Locate, then its parent Broadcom) suing a direct competitor (SiRF Technology), and Global Locate was itself sued by SiRF. Broadcom publicly litigated in its own name and carried the defense of SiRF's counterclaims — the opposite of a hidden proxy arrangement.

  8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. The current holder is a Broadcom/Avago operating-group entity.


Verdict

Operating-company assertion.

The entire chain runs inventor → Global Locate, Inc. (2004-01-26) → Broadcom Corporation (acquisition completed 2007; confirmatory assignment recorded 2015-09-16) → Avago Technologies General IP (Singapore) (2017-02-01) → Avago Technologies International Sales Pte. Limited (merger, Reel 047196/0097, 2018-10-04; date-corrected 2019-03-06). Every assignee is an operating semiconductor group; there is no licensing-only shell, no known-NPE link, no bankruptcy, and no pre-suit transfer. The '080 was asserted by the operating owner against a genuine competitor — SiRF was found to infringe it in ITC Inv. 337-TA-602, and the CAFC affirmed in SiRF v. ITC, No. 2009-1262 (Apr. 12, 2010) — which is textbook operating-company assertion, not NPE activity.

One genuine caveat / contradiction to flag: I could not independently verify any reel/frame except 047196/0097, nor any correspondent. The previously generated summary likewise found no 2026 docket activity, consistent with the patent expiring 2024-09-01. If you have Assignment Center access, pull the reel/frame + correspondent fields for the 2004-01-26, 2015-09-16, 2016-02-11, 2017-02-01, 2017-02-03, 2018-10-04, and 2019-03-06 records to close out signal #3 — that is the only open item.

Verification links:

Generated 9/29/2026, 5:04:30 AM

Prior art

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

✓ Generated

I'll ground this analysis with targeted USPTO-focused searches before assessing each cited reference.

Good grounding on the Global Locate and SnapTrack families. Let me verify the remaining notable citations before assessing them.

Prior Art Analysis — US 7,158,080 B2

0. USPTO Search Confirmation (literal number 7158080)

I searched for the literal number 7158080 (no auto-correction to similar numbers). The result is the correct patent:

  • US 7,158,080 B2, "Method and apparatus for using long term satellite tracking data in a remote receiver," Application No. 10/674,267, Inventor Frank van Diggelen, Assignee Global Locate, Inc. (now Avago), filed 2003-09-29, granted 2007-01-02, priority to provisional 60/415,364 (2002-10-02), pre-grant pub. US 2004/0117114 A1. Corroborated by the USPTO/PTO-downloadable grant PDF (patentimages.storage.googleapis.com/05/77/f3/27ea7edf866760/US7158080.pdf), whose front page lists the same assignee, examiner (Dao L. Phan), and 39 claims. No similarly-numbered patent was substituted.

Legal framework caveat: This application was filed 2003-09-29, i.e., before the AIA's first-inventor-to-file date (2013-03-16). Therefore pre-AIA 35 U.S.C. §102(a), (b), (e), and (g) govern. Also note the narrow point you asked about: anticipation under §102 requires a single reference disclosing every element of a claim. As shown below, most of the cited references are background/§103 obviousness references, not true anticipations. I flag explicitly where a §102 argument is plausible and where it is not. I also flag the significant problem that several "references" are the same-inventor/same-assignee family members expressly incorporated by reference into the '080 specification.


1. The cited reference set (from the authoritative record)

The grant lists 21 "Patent Citations." The four requested data points follow. Columns: Filing date / Publication date / Description / Claims potentially implicated under §102.

# Reference Filing Publication Brief description §102 candidate for
1 US 4,445,118 A — Taylor et al. (NASA) 1981-05-22 1984-04-24 "Navigation system and method." Sends Doppler information from a base/control station to a remote GPS unit to aid acquisition. Claim 1(c) (acquire using assistance); weak/partial only
2 US 4,894,662 A — Counselman (Western Atlas) 1982-03-01 1990-01-16 "Determining position on a moving platform (e.g., ship) using GPS." Classic GPS positioning background. None (background)
3 US 5,726,893 A — Schuchman et al. (Stanford Telecom) 1992-12-17 1998-03-10 "Cellular telephone with voice-in-data modem." Combo GPS + cellular data link. None (background)
4 US 5,673,256 A — Motorola 1995-07-25 1997-09-30 "Apparatus and method for sending data messages at an optimum time." Claim 21 (data delivered during low-traffic period)
5 US 6,064,336 A — Krasner (SnapTrack) 1995-10-09 2000-05-16 Collects almanac at a separate receiver, transmits it to a mobile; mobile computes expected Doppler to aid acquisition. Claim 1, 4, 5, 34 (closest core-art)
6 US 5,841,396 A — Krasner (SnapTrack) 1996-03-08 1998-11-24 Foundational A-GPS: Doppler/assistance transmitted to receiver via comm link. Claim 1 (partial; server computes aid)
7 US 6,215,441 B1 — Moeglein et al. (SnapTrack) 1997-04-15 2001-04-10 "Satellite positioning reference system and method." Reference network supplies assistance. Claims 22, 29 (architecture)
8 US 2002/0024461 A1 — Moeglein 1997-04-15 2002-02-28 Published counterpart of #7. Same as #7
9 US 6,256,475 B1 — Lucent 1997-09-11 2001-07-03 "Telecommunications-assisted satellite positioning system." Claims 19, 29
10 US 6,222,483 B1 — Nokia 1998-09-29 2001-04-24 "GPS location for mobile phones using the internet." Claims 20, 19 (network/Internet delivery)
11 US 6,134,483 A — Vayanos 1999-02-12 2000-10-17 "Efficient GPS assistance in a communication system." Claims 1, 22 (assistance delivery)
12 US 6,453,237 B1 — Fuchs et al. (Global Locate) 1999-04-23 2002-09-17 "Locating/providing services to mobile devices." Incorporated by reference into '080 as exemplary A-GPS receiver. Claims 22, 25 (receiver structure)
13 US 6,211,819 B1 — Motorola 1999-08-27 2001-04-03 "Mobile station location determination in a radio communication system." Claims 6–8, 36–38 (cell/site position estimate)
14 US 6,642,884 B2 — Sigtec Navigation 2000-05-08 2003-11-04 "Satellite-based positioning receiver for weak signal operation." Claim 1(c) (§102(e) art)
15 US 6,411,892 B1 — van Diggelen (Global Locate) 2000-07-13 2002-06-25 Wide-area reference network propagates ephemeris; search window computed at mobile receiver or central site. Incorporated by reference. Claims 1, 4, 5, 34 (see caveat)
16 EP 1 197 761 A2 — eRide 2000-10-11 2002-04-17 "Satellite navigation receiver and method." Receiver-side navigation processing. Claim 1 (§102(a)/(b))
17 US 2005/0003833 A1 — Younis et al. (Qualcomm) 2001-03-15 2005-01-06 "Time acquisition in a wireless position determination system." Claim 10 (time-of-day) (§102(e))
18 US 6,542,820 B2 — LaMance, Abraham, van Diggelen (Global Locate) 2001-06-06 2003-04-01 Generates and distributes long term satellite tracking data; claim 1 recites "providing long term satellite tracking data to a remote receiver." Incorporated by reference. Claims 1(a), 12–18 (LT-STD element)
19 WO 02/103383 A2 — Global Locate 2001-06-19 2002-12-27 "Distributing satellite tracking information." Claim 1(a) (distribution)
20 US 6,856,282 B2 — Qualcomm 2002-02-08 2005-02-15 "Directly acquiring precision (P/Y) code GPS signals." Claim 1(c) (§102(e))
21 US 2004/0203853 A1 — Sheynblat (Qualcomm) 2002-04-24 2004-10-14 "Position determination … hybrid position determination system." Claim 4 (est. position) (§102(e))

Non-patent citation: Copy of the International Search Report dated 2004-03-17 for PCT/US03/30872 (the '080 PCT). This is not prior art; it is cited as the search report for the family.


2. Detailed §102 assessment of the strongest candidates

A. US 6,064,336 (Krasner / SnapTrack) — the best standalone §102 argument against independent claim 1

The '080 specification's own §2013/0234888 family text characterizes this reference: "U.S. Pat. No. 6,064,336 … collects almanac data at a separate GPS receiver, then transmits the almanac data to a mobile receiver. The mobile receiver then uses the almanac data to compute the expected Doppler frequency of the satellite signal, thus aiding in initial signal acquisition."

Mapping to claim 1: (a) satellite orbit data transmitted to a remote receiver from an external source → arguably the "server"; (b) the remote receiver computes Doppler acquisition assistance; (c) it acquires satellite signals with that assistance. This is the only cited reference that places Doppler computation at the receiver, which is the '080 point of novelty.

  • Supports §102 against: claim 1 (arguably), claim 4/5 (estimated position + time-of-day → frequency window), and claim 34 if the almanac/delivery is read as "long term satellite tracking data."
  • Counterarguments (why it may fail §102): the almanac is a coarse orbit model, not "long term satellite tracking data" as the '080 describes it (claim 12/16/18 require ≥6 hours; the specification stresses almanac is too rough for position/yields code-delay uncertainty reduction only). A patentee would argue "long term satellite tracking data" was intended to exclude almanac. This is the crux of any §102 fight.

B. US 4,445,118 (Taylor / NASA) — acquisition-assist ancestor, but assistance is computed at the server

The ES-2373819 abstract I retrieved summarizes Taylor: Doppler information is transmitted from a control base station to a remote GPS unit so the remote can compensate Doppler in computing pseudoranges. It reduces acquisition time but the Doppler is server-generated and valid only briefly.

  • Supports §102 against: claim 1(c) (acquiring using assistance data) and the general "acquisition assistance" concept.
  • Does NOT anticipate claim 1/22/29/34 as a whole, because those claims require the assistance data to be computed at the remote receiver from long-term satellite tracking data. Taylor computes at the base station and its data is short-lived. Likely an obviousness (§103) reference instead.

C. US 6,411,892 (van Diggelen / Global Locate) — very close, but same-inventor + incorporated by reference

The EP 1 305 735 family text confirms this reference discloses computing a frequency and code-delay search window from ephemeris "either at the mobile receiver itself, or at the central processing site," then acquiring within that window.

  • Supports §102 against: claims 1, 4, 5 (search-window/acquisition-assistance computed at the receiver), and claim 34.
  • Serious caveats: (i) it is by the same inventor (van Diggelen) — pre-AIA §102(a) requires the reference be "by others," and §102(e)/(g) issues arise; (ii) it is expressly incorporated by reference into the '080 specification, which makes using it as §102 anticipatory art against the same patent highly problematic; (iii) it discloses ephemeris (2–4 h validity), not "long term" data. So while it is the closest technical disclosure of receiver-side acquisition-assistance generation, it is a poor anticipation reference and better framed as showing the state of the art.

D. US 6,542,820 (Global Locate; LaMance/Abraham/van Diggelen) — anticipates only the LT-STD element

Claim 1 of US 6,542,820: "A method for providing long term satellite tracking data to a remote receiver comprising: receiving satellite signals … producing long term satellite tracking data … transmitting at least a portion of the long term satellite tracking data to a remote receiver."

  • Supports §102 against: claim 1(a) "receiving long term satellite tracking data at a remote receiver from a server," and the dependent LT-STD-definition claims 12–18; it also describes multiple sequential 6-hour models (the "6N hours" concept of '080 FIG. 2).
  • Does NOT anticipate the full independent claims, because it is server-side and does not disclose the receiver computing acquisition assistance. It is, however, the single most relevant reference for the "long-term data" limitation. Same caveat: common inventorship (van Diggelen is a named inventor) and incorporation by reference limit its §102 effect.

E. Narrow-limitation references

  • US 5,673,256 (Motorola, 1997) — "sending data messages at an optimum time." Directly on point for claim 21 ("received … during a low traffic period") and for the FIG. 5 scheduling logic (busy/idle periods). Strong §102/§103 candidate for claim 21.
  • US 6,211,819 (Motorola, 2001) — mobile-station location determination. Anticipates the basestation-position-as-estimated-position limitations (claims 6–8, 36–38), particularly the "identify cell site → obtain its position" flow of FIG. 7 steps 702–704/714–716.
  • US 2005/0003833 (Younis / Qualcomm, filed 2001-03-15) — time acquisition; §102(e) prior art against claim 10 (estimated time of day from a clock).
  • US 6,222,483 (Nokia, 2001) — Internet delivery of GPS location assistance; §102(a)/(b) against claim 20 ("communication network") and claim 19.
  • US 6,856,282 (Qualcomm, filed 2002-02-08) and US 6,642,884 (Sigtec, filed 2000-05-08) — §102(e) art relevant to the acquisition step (claim 1(c), claim 22 "satellite signal receiver … using said acquisition assistance data"):
  • US 2004/0203853 (Sheynblat / Qualcomm, filed 2002-04-24) — §102(e) art for the estimated-position limitation of claims 4/34.
  • US 6,453,237 (Fuchs / Global Locate, 2002) — incorporated by reference as the exemplary A-GPS receiver; relevant to the receiver structure of claim 22.

3. Bottom line

  1. No single cited reference clearly anticipates all elements of independent claims 1, 22, 29, or 34. The distinguishing requirement everywhere is that the remote receiver itself computes the acquisition assistance data from long-term satellite tracking data. The cited art overwhelmingly has the server compute the aid (Taylor '118; SnapTrack '396/'441; Lucent; Nokia; Vayanis; eRide).
  2. The two most dangerous §102 references for independent claim 1 are:
  • US 6,064,336 (Krasner) — receiver-side Doppler computation, but from almanac (coarse, non-"long-term"); and
  • US 6,411,892 (van Diggelen) — receiver-side search-window computation, but from ephemeris, and disqualified/seriously weakened by common inventorship and incorporation by reference.
  1. US 6,542,820 best anticipates the "long term satellite tracking data … from a server" element (claim 1(a); claims 12–18), but only that element.
  2. Specific dependent claims have real §102 exposure: claim 21 (US 5,673,256); claims 6–8/36–38 (US 6,211,819); claim 10 (US 2005/0003833); claim 20 (US 6,222,483).
  3. The bulk of the list (US 4,445,118; 4,894,662; 5,726,893; 5,841,396; 6,215,441; 2002/0024461; 6,256,475; 6,134,483; WO 02/103383; EP 1 197 761; US 6,642,884; US 6,856,282; US 2004/0203853) functions as §103 background art establishing that receiving satellite/orbit data over a communication link and using it to aid acquisition was well known.

4. Explicit uncertainty notes (per operating rules)

  • Identifiers used literally. I did not auto-correct any number. Note the record itself shows two slightly different citation sets — a "Citations (20)" list and a "Patent Citations (21)" list. I analyzed the 21-reference set (it adds US 6,064,336 and WO 02/103383 A2, both material). Where the two lists differ, this is a source discrepancy in the record, not an error by me.
  • Live-search limits on the analysis of a few references. I confirmed the Global Locate family (US 6,542,820, US 6,411,892, WO 02/103383), the SnapTrack family (US 5,841,396, US 6,064,336, US 6,215,441), Taylor (US 4,445,118, via the ES-2373819 abstract), and the general A-GPS backdrop. My targeted searches for the full text of US 6,134,483 (Vayanos), US 6,642,884 (Sigtec), EP 1 197 761 (eRide), US 6,856,282 (Qualcomm), and US 2002/0024461 (Moeglein) did not complete before the search budget was exhausted, so the characterizations of those five are based on their titles, assignees, dates, and family context rather than retrieved text. I flag them as lower-confidence.
  • "Potentially anticipates" is used strictly. In most rows the honest answer is "does not anticipate; may support §103." I have said so rather than manufacturing §102 mappings, because each independent claim requires receiver-side computation from long-term data — a combination the cited art does not appear to show in a single reference.
  • Family/IP caveat. US 6,411,892, US 6,542,820, and US 6,453,237 share the '080 assignee (Global Locate) and inventor(s) and are incorporated by reference into the '080 specification; and US 11/057,060 is a continuation-in-part of the '080 application. Any real §102 challenge using these would have to overcome the "by others" and self-disclosure problems — a material limitation on the analysis above.

Generated 9/29/2026, 5:04:54 AM

Obviousness

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

✓ Generated

I'll ground a few points before drafting — specifically whether the Federal Circuit addressed §103 in the '080 appeal, and the content of the key SnapTrack reference.

Obviousness (35 U.S.C. § 103) — US 7,158,080 B2

Builds on the previously generated Prior Art section (21-reference set; two-list source discrepancy noted there) and does not repeat it. Where my analysis refines or contradicts that section, I flag it inline.


1. Threshold: this is a pre-AIA § 103 case, and two gates control everything

Which statute. App. No. 10/674,267 was filed 2003-09-29 (provisional 60/415,364, 2002-10-02). Pre-AIA § 103 governs. The controlling rubric is Graham v. John Deere (scope/content of art; differences; PHOSITA level; secondary considerations) as elaborated by KSR Int'l v. Teleflex, 550 U.S. 398 (2007) (a finite set of predictable solutions = "obvious to try"; a known technique applied to a known problem in the same way = obvious). PHOSITA here: a GPS/A-GPS systems engineer with ~3–5 years of experience in receiver signal processing and satellite orbit/clock modelling.

Gate 1 — § 102(category) status drives § 103 eligibility. Pre-AIA § 103(c)(1) removes from § 103 any art "developed by another person, which qualifies as prior art only under one or more of subsections (e), (f), and (g) of section 102," where that art and the claimed invention were commonly owned at the time of invention. This matters enormously here because the best "long term" reference is Global Locate's own:

Reference Grant/pub date § 102 category Usable for § 103?
US 6,542,820 (LaMance/Abraham/van Diggelen, Global Locate) 2003-04-01 (filed 2001-06-06) § 102(e) only (post-dates the 2002-10-02 invention date) No — knocked out by § 103(c) (commonly owned by Global Locate)
US 6,411,892 (van Diggelen, Global Locate) 2002-06-25 (filed 2000-07-13) § 102(a) and § 102(b) Yes — § 102(c) does not apply to (a)/(b) art
US 6,064,336 (Krasner, SnapTrack) 2000-05-16 (filed 1995-10-09) § 102(b) Yes
US 6,215,441 / US 2002/0024461 (Moeglein, SnapTrack) 2001-04-10 / 2002-02-28 § 102(b)/(a) Yes
US 6,256,475 (Lucent); US 6,222,483 (Nokia); US 6,211,819 (Motorola); US 6,134,483 (Vayanos); US 5,673,256 (Motorola) 1997–2001 § 102(b) Yes
EP 1 197 761 A2 (eRide) 2002-04-17 § 102(b) (pub. >1 yr before 2003-09-29) Yes
US 6,453,237 (Fuchs, Global Locate) 2002-09-17 § 102(a)/(b) Yes
WO 02/103383 A2 (Global Locate) 2002-12-27 Not § 102(a)/(b) (published after invention); potentially § 102(e) Problematic — § 103(c) exposure
US 2005/0003833 (Younis); US 2004/0203853 (Sheynblat); US 6,664,884→US 6,642,884 (Sigtec); US 6,856,282 (Qualcomm) 2003–2005 § 102(e) (filed pre-invention) Yes — not commonly owned, so § 103(c) inapplicable

Refinement of the Prior Art section (flagged): that section called US 6,411,892 a "poor anticipation reference" because of common inventorship and incorporation by reference. For § 103 the conclusion differs. Contrary to a common misconception, (i) incorporation by reference does not strip a document of prior-art status — it only governs whether the document's disclosure is treated as part of the host specification; and (ii) pre-AIA § 102(a)'s "by others" qualifier attaches to "known or used," not to "patented or described in a printed publication" (In re Katz, 687 F.2d 450 (CCPA 1982)). And most decisively, '892 is § 102(b) art, where the inventor's own work is prior art and § 103(c) has no purchase. So US 6,411,892 is a first-class § 103 combination reference even though it is a weak § 102 anticipation reference. That is the single most important recalibration in this section.

Gate 2 — claim construction of "long term satellite tracking data." Per the PTAB section, the BPAI reversed the reexamination rejection by holding the examiner had construed this term too broadly. Any § 103 case must therefore satisfy a construction tied to the specification: satellite orbit/clock data materially valid longer than broadcast ephemeris (2–4 hours), usable to predict satellite position (the CAFC's own gloss: "using certain algorithms to predict ephemeris data for satellites in the future, receiving that 'long term' data at a GPS receiver, and using it to locate satellites and calculate position" — 09-1262, slip op. at 3). Claim 1 itself does not recite "≥6 hours" (that is claims 12/16/18/26/28/31/33), so the independent claims are reachable if the data is "long term" in the patent's sense.

Record context. The CAFC appeal (No. 2009-1262) addressed standing, § 101 (Bilski machine-or-transformation), and divided infringement — it did not decide § 103. The validity findings came from the ITC (ALJ Charneski, ID 2008-08-08; Comm'n FD 2009-01-15; USITC Pub. 4137), which rejected system-level invalidity theories (NavStar GPS, the 1999 SiRFLoc system, TOPEX/Poseidon) and inequitable conduct. So the patent-level § 103 combinations built below from the SnapTrack/Global Locate/eRide art were not squarely adjudicated. That is the one genuine opening — but see § 9.


2. The claim-1 matrix (target of the § 103 case)

'080 claim 1 element Primary teaching Secondary teaching
(a) receiving long term satellite tracking data at a remote receiver from a server US 6,542,820 (if reachable) / US 6,064,336 (almanac, ~1 month validity, transmitted from basestation and stored in flash EEPROM) US 6,215,441, EP 1 197 761
(b) computing acquisition assistance data at the remote receiver from that data US 6,064,336 (mobile derives Doppler from received satellite data) US 6,411,892 (frequency+code-delay search window computed "either at the mobile receiver itself, or at the central processing site")
(c) receiving satellite signals using that assistance data US 6,411,892 (FIG. 7 search within the window); US 6,064,336 US 4,445,118 (Taylor/NASA)

The four independents (1, 22, 29, 34) add only apparatus/system framing and, for claim 34, where the position estimate comes from.


3. Combination A — the principal § 103 case against claim 1

US 6,064,336 (Krasner) + US 6,411,892 (van Diggelen) [+ US 6,542,820 if the § 103(c) exclusion is avoided]

What each teaches (grounded in retrieved text, not title inference):

  • US 6,064,336. The grant and its EP family members (EP 2 285 018 A3; EP 2 169 848 A1) disclose the exact flow: "at a mobile GPS receiver unit, receiving satellite data information and storing the satellite data information; determining an approximate time of day; determining an approximate receiver position utilizing a position of a cell of the mobile GPS receiver unit; and determining Doppler information for a plurality of satellites in view using the time of day, approximate receiver position, and satellite data information." The '336 specification adds that the satellite data "has good accuracy for long periods of time (e.g., a month…)," is stored in the mobile with a time stamp, and that the mobile determines whether the data is stale and re-acquires only if stale; alternatively "the basestation may determine whether to transmit satellite almanac data by keeping a list of the remote units which have been sent satellite almanac data and a time stamp." That is the '080's receiver-side acquisition-assistance computation from stored, long-validity satellite data, plus the '080's FIG. 5 / device-database-414 logic and claim 11.
  • US 6,411,892 (retrieved text via US 6,411,892 / US 6,703,972 / EP 1 305 735): the pseudo-range model "is calculated from the ephemeris, either at the mobile receiver itself, or at the central processing site," then applied "at the current time in the mobile device" to "form a frequency and code delay search window for each satellite," and the correlator searches within that window (FIG. 7, steps 702–718). The approximate mobile position is "determined from the known location of the radio tower last used by the device." This maps element-for-element onto '080 claims 1, 4, 5, 6, 34, 36.

Motivation to combine (KSR factors):

  1. Same field, same problem, same solution space. Both references target the identical problem the '080 background recites verbatim: reducing receiver search time/sensitivity loss during A-GPS acquisition. '892's own specification cites '336 as an "implementation" in the field — objective evidence the two are combinable from a single reference shelf, and that a Global Locate patent itself treated Krasner as prior art.
  2. "Long term" is the express design goal of the art. Krasner already touts month-long data validity and staleness-based refresh; '080's contribution is framed as extending validity (6 h to 4 days). Under KSR, extending a known data-validity window by using a more precise orbit/clock model is a predictable variation, not an inventive leap.
  3. Finite, identified solution set. For a mobile computing its own acquisition aid there were exactly two known loci — at the mobile, or at the server ('892 says so expressly; the '651 ITC record shows SiRF arguing the same). Choosing the mobile locus is obvious to try with predictable results (namely, no server round-trip and continued operation out of coverage — precisely the '080's stated object).
  4. Reasonable expectation of success. The '080 specification itself concedes that computing Doppler at an estimated position and time of day from ephemeris blocks "is performed in a conventional manner." An applicant admission of conventionality is powerful § 103 evidence.

Where the combination is vulnerable (this is a real weakness, not boilerplate):

  • The "long term" gap. Krasner's long-validity dataset is almanac, and the ITC record shows the '080's own family framing almanac as distinct from ephemeris for acquisition-assistance purposes (USITC Pub. 4137 construes "satellite ephemeris" and notes the '651/'080 specifications "clearly distinguish between almanac and ephemeris"). '892 supplies ephemeris, but the '080 (and the BPAI) treat 2–4 h ephemeris as not "long term." So the challenger must bridge: (Krasner's long-validity data) × ('892's ephemeris-precision data) = the '080's "long term satellite tracking data." The natural bridge is US 6,542,820 — the only cited reference that uses the very claim term ("providing long term satellite tracking data to a remote receiver," claim 1 of '820). And § 103(c) may remove '820. That is the crux of the entire § 103 case.
  • Reactions to the § 103(c) problem (state these up front in any petition/brief):
    (i) Argue the '080's claims are not entitled to the 60/415,364 provisional (priority/§ 112 support attack). This does not by itself rescue '820, but it changes the § 102(a) calculus for WO 02/103383 and matters for other art.
    (ii) Rely on '820's published/PCT embodiments only if they independently qualify under § 102(a)/(b) — they do not on the face of the record (WO pub. 2002-12-27 > invention date).
    (iii) Use '820 as evidence of the state of the art / PHOSITA knowledge rather than as § 103 prior art (permissible for the "level of ordinary skill" Graham factor, and for showing what the art understood "long term" to mean) — a weaker but legitimate use.
    (iv) Note the same-inventor overlap (van Diggelen on both) cuts against a § 103(c) safe harbor only if the entities are the same, not merely overlapping — see the standing/CIP history in 09-1262.

Candid probability: if '820 is reachable, claim 1 is a strong § 103 candidate. If § 103(c) excludes it, the case becomes a "long-validity data + receiver-side ephemeris computation" argument that must beat a construction-driven "almanac ≠ long term tracking data" rebuttal — roughly a coin-flip at the institution/jury stage, and weaker than the prior-art section's generally bullish tone implies.


4. Combination B — claim 34 (and claims 36–39)

Claim 34 = receive LT-STD + determine estimated position using data stored within the receiver + compute assistance data locally.

US 6,064,336 + US 6,411,892 + US 2004/0203853 (Sheynblat)

  • '336 expressly determines the approximate position "utilizing a position of a cell of the mobile GPS receiver unit" — i.e., a locally stored/derived cell-site position — and stores the satellite dataset with a timestamp in the mobile.
  • '892 independently discloses using "the known location of the radio tower last used by the device" as the approximate position and computing the frequency/code-delay window at the mobile.
  • US 6,211,819 (Motorola) teaches the cell-ID→cell-position lookup flow (claims 6–8, 36–38), matching '080 FIG. 7 steps 702–704/714–716.
  • Sheynblat '853 supplies the hybrid-network estimated-position limitation for claims 4/34 if '336/'892 are read narrowly.

Motivation: both '336 and '892 expressly motivate using a coarse, locally available position estimate (cell tower) because the induced Doppler uncertainty is tolerable — '892 quantifies it (3 km uncertainty vs. a 300 km code-epoch) and the '080 quantifies the same tradeoff (a "wide area" estimate still yields a usable ±3000 Hz window). A PHOSITA optimizing for minimal server transactions (KSR "design incentive") would predictably pick the local source over a server query.


5. Dependent-claim combinations

Claim(s) Limitation Combination Motivation
2, 30 Compute position using satellite signals + LT-STD '336 + '820 '336 discloses mobile-side position computation; '820 supplies the long-term orbit/clock data for future-time position
3 Decode ephemeris from signals; compute position '336 family (Method 2: "gather the satellite ephemeris… in the normal manner") Conventional fallback already described in the art
4, 5 Est. position + est. time of day → frequency search window; search within it '336 + '892 + US 2005/0003833 (Younis) '336 gives the time-of-day and cell-position inputs; '892 gives the window and the search; Younis supplies time acquisition
6, 7 Est. position = basestation position; obtained from locally stored table via ID US 6,211,819 (+ '336) Mobile-station/cell-ID positioning with a stored cell-position database
8 Send ID to server; receive basestation position US 6,211,819 + US 6,215,441 Server-side assistance delivery is the core SnapTrack teaching
9, 39 Est. position = previously computed position from a table ⚠ WEAKEST MAPPING — see § 8 —
10 Time of day from an internal clock US 2005/0003833 (Younis) Time acquisition in a wireless position system
11 Check validity; request/update new LT-STD US 6,064,336 (stale/not-stale determination; basestation list + time stamps) Literally disclosed in '336
12, 16, 18, 26, 28, 31, 33 "≥ six hours" / blocks of ephemeris '820 / WO 02/103383 (+ '080 spec.'s own admission that LT-STD "may be generated using blocks of satellite orbit and/or clock models, such as ephemeris data") The ≥6 h window is the express subject of '820
13, 14, 15, 17, 27, 32 Content of LT-STD (positions/velocities/accels; clock offsets/drifts; ephemeris; models) '820 Direct disclosure
19, 29 Wireless link / system architecture US 6,256,475 (Lucent); US 6,215,441 Telecom-assisted SPS; reference-network architecture
20 Communication network (Internet) delivery US 6,222,483 (Nokia) Internet delivery of GPS assistance
21 Received during a low traffic period US 5,673,256 (Motorola) "Sending data messages at an optimum time" — express teaching of load-aware scheduling
22, 24, 25 Receiver: transceiver + microcontroller + clock + window computation '336 + '892 + US 6,453,237 (Fuchs) + Younis '237 = exemplary A-GPS receiver structure; the rest as above

6. The KSR motivation spine (use these four, in this order)

  1. Same field of endeavor / analogous art. Every reference above is GPS or SPS acquisition-assistance art. No non-analogous-art fight.
  2. Known problem → known techniques. The '080 background is an admission of the problem (short-lived 2–4 h aid → repeated server transactions; loss of service out of coverage) and of the known techniques (send orbit/clock data "by some other means"; compute Doppler conventionally from ephemeris at an estimated position/time).
  3. Predictable variation / obvious to try. Extending the validity window of the aid, and moving the aid computation from server to receiver, are the two identified axes of the known design space. KSR: where there are "a finite number of identified, predictable solutions," and the variation is "the predictable use of prior art elements according to their established functions," the claim is obvious.
  4. Design incentive / market pressure. The ITC record itself shows the whole industry (SiRF, Qualcomm, eRide, SnapTrack) racing toward the same goal — "a need for a method and apparatus… in compact form" ('000 patent), reduced transactions, weak-signal acquisition. Industry-wide convergence on the same architecture is KSR motivation-of-design-incentive evidence (it also cuts the other way on secondary considerations — see § 7).

7. Secondary considerations (Graham factor 4) — these are the patentee's best material

Factor Evidence Weight
Prior adjudicated validity ITC found claims 1, 2, 22 of the '080 valid, enforceable, and infringed (ALJ ID 2008-08-08; Comm'n FD 2009-01-15); affirmed, 601 F.3d 1319 (Fed. Cir. 2010). Not a § 103 ruling, but strong citable evidence of non-obviousness. High
Survived ex parte reexamination Examiner rejected the '080 claims as anticipated/obvious; BPAI reversed (~2012-03-19) on a narrow construction of "long term tracking data." High, and it frames the construction fight
Commercial success Global Locate's "Hammerhead" A-GPS chipset; Broadcom's subsequent product line; the accused SiRFstarIII chips embody the complementary technique. Nexus must still be proven to the asserted claims. Medium
Industry adoption / copying The "Cited By"/family-citing record shows the entire industry moving to long-term orbit (LTO) data (Qualcomm's "extended SPS orbit information," Rx Networks' distributed orbit modelling, MediaTek, SiRF's "Determining position without current broadcast ephemeris"). Copying supports non-obviousness; independent parallel development instead supports obviousness. This cuts both ways and must be briefed carefully. Ambiguous
Long-felt need / failure of others The '080 background frames the need; the art had not solved the out-of-coverage problem. Medium-low

Practical consequence: any § 103 challenge must present art and combinations materially different from NavStar/SiRFLoc/TOPEX/Poseidon and must overcome the presumption of validity by clear and convincing evidence, with the BPAI's construction of "long term" as the controlling lens.


8. Honest gaps and residual uncertainty

  1. Claims 9 and 39 are the weakest § 103 rows. The "previously computed position" / "table of recently computed positions" limitation has no clean mapping within the 21-reference cited set. US 2004/0203915 ("position cache," van Diggelen) appears on the "Families Citing this family" list — i.e., it cites the '080 (priority 2003-01-22, after the '080 priority) and is not prior art. Do not treat it as such. Expect to argue this limitation on KSR "routine data management" grounds only, which is thin.
  2. Five references remain lower-confidence for the reasons stated in the Prior Art section (Vayanos '483, Sigtec '884, eRide EP 1 197 761, Qualcomm '282, Moeglein '001): characterizations rest on titles/assignees/dates rather than retrieved text. My reliance on them above is correspondingly light.
  3. § 103(c) is the pivotal, under-appreciated issue. I am confident in its doctrinal operation; I am not certain from the public record whether § 103(c) was ever litigated for this family, nor whether the parties stipulated to common ownership at the time of invention. That must be confirmed from the assignment records (see the Assignment section) before it is argued.
  4. The '080 reexamination file wrapper (control number unknown — flagged in the PTAB section) is essential; the BPAI's construction language is the fulcrum of the whole analysis and I have it only second-hand.
  5. Expiry. The patent expired 2024-09-01. § 103 therefore matters to an accused party only for pre-expiry conduct within the § 286 six-year lookback. A § 103 holding is a shield for past damages, not a future-practice clearance issue.

9. Bottom line

  • There is a coherent, evidence-grounded § 103 case against independent claims 1, 22, 29, and 34, built on US 6,064,336 (Krasner) + US 6,411,892 (van Diggelen) + a "long term" data reference (US 6,542,820), with US 6,215,441 / US 6,256,475 / US 6,222,483 / US 6,211,819 / US 6,064,336 / US 5,673,256 / US 2005/0003833 / US 2004/0203853 filling the dependent-claim elements. Motivation is strong: same field, an applicant-admitted conventional technique (receiver-side Doppler from ephemeris), a finite two-option design space, and an express design incentive to lengthen data validity and cut server transactions.
  • The case turns on two questions, not on the technology: (1) whether US 6,542,820 is available for § 103 notwithstanding pre-AIA § 103(c) (my analysis says it likely is not, absent a common-ownership challenge); and (2) whether the BPAI's construction of "long term satellite tracking data" excludes Krasner's month-valid almanac. Lose either and the case must be reconstructed.
  • This is a colorable, not a comfortable, invalidity theory — and it is measurably weaker than a superficial "Krasner computes Doppler at the mobile, so claim 1 falls" reading suggests, because of § 103(c) and the almanac/ephemeris distinction. The patentee also holds a precedential validity judgment (601 F.3d 1319) and a BPAI reexamination reversal on the central claim term. Treat this as a validity theory that must be briefed around those two gates, not as low-hanging fruit.

Primary sources used for this section: USITC Pub. 4137 (Comm'n Op., Inv. No. 337-TA-602), https://www.usitc.gov/intellectual_property/documents/pub4137.pdf; SiRF Tech., Inc. v. Int'l Trade Comm'n, No. 2009-1262 (Fed. Cir. Apr. 12, 2010), http://cafc.uscourts.gov/opinions-orders/09-1262.pdf; US 6,064,336 and its EP family members EP 2 285 018 A3 / EP 2 169 848 A1; US 6,411,892 / US 6,703,972 / EP 1 305 735 (receiver-side frequency & code-delay window); Google Patents full text of US 7,158,080 supplied above.

Generated 9/29/2026, 5:12:27 AM

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