Assignment history

Inventors

The named inventors are Edward Balassanian and Scott W. Bradley. At the time of filing, they were likely associated with Implicit Networks Inc., which is listed as the original assignee on Google Patents.

Original assignee

The original assignee listed on the issued patent is Implicit Networks Inc.. Information on whether Implicit Networks Inc. shipped a product embodying the claims or its primary line of business is not readily available through public search at this time. Its current status appears to be operating, as it is listed as the assignee in the most recent assignment record.

Assignment timeline

• 2003-08-08 (executed) / recorded 2003-08-11 — Reel 014494/0836
  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: BALASSANIAN, EDWARD; BRADLEY, SCOTT W.
  • Assignee: BECOMM CORPORATION
  • Correspondent: RUSS, AUGUSTUS, LAW OFFICE OF AUGUSTUS RUSS, 10701 LOMAS BLVD NE SUITE 210, ALBUQUERQUE, NM 87112.
  • Context: Inventors assigned their interest to BeComm Corporation.
• 2004-08-30 (executed) / recorded 2004-09-02 — Reel 015383/0333
  • Conveyance: ASSIGNMENT
  • Assignor: BECOMM CORPORATION
  • Assignee: IMPLICIT NETWORKS, INC.
  • Correspondent: RUSS, AUGUSTUS, LAW OFFICE OF AUGUSTUS RUSS, 10701 LOMAS BLVD NE SUITE 210, ALBUQUERQUE, NM 87112. This correspondent recurs in this chain.
  • Context: BeComm Corporation assigned the patent to Implicit Networks, Inc.
• 2014-02-28 (executed) / recorded 2014-03-04 — Reel 031313/0530
  • Conveyance: ASSIGNMENT
  • Assignor: IMPLICIT NETWORKS, INC.
  • Assignee: IMPLICIT, LLC
  • Correspondent: REID, JOHN L, KILPATRICK TOWNSEND & STOCKTON LLP, 1100 PEACHTREE STREET NE SUITE 2800, ATLANTA, GA 30309.
  • Context: Implicit Networks, Inc. assigned the patent to Implicit, LLC.
• 2014-02-28 (executed) / recorded 2014-03-04 — Reel 031313/0534
  • Conveyance: SECURITY AGREEMENT
  • Assignor: IMPLICIT, LLC
  • Assignee: CBC PARTNERS I, LLC
  • Correspondent: REID, JOHN L, KILPATRICK TOWNSEND & STOCKTON LLP, 1100 PEACHTREE STREET NE SUITE 2800, ATLANTA, GA 30309. This correspondent recurs in this chain.
  • Context: Implicit, LLC granted a security interest in the patent to CBC Partners I, LLC.
• 2018-01-08 (executed) / recorded 2018-01-11 — Reel 041838/0334
  • Conveyance: RELEASE
  • Assignor: CBC PARTNERS I, LLC
  • Assignee: IMPLICIT, LLC
  • Correspondent: LEIGH, GARY A, REID, JOHN L, KILPATRICK TOWNSEND & STOCKTON LLP, 1100 PEACHTREE ST NE, STE 2800, ATLANTA, GA 30309. This correspondent recurs in this chain.
  • Context: CBC Partners I, LLC released the security interest on the patent.
• 2021-12-17 (executed) / recorded 2021-12-23 — Reel 052445/0001
  • Conveyance: ASSIGNMENT
  • Assignor: CARPENTER, GUY A.
  • Assignee: IMPLICIT NETWORKS, INC.
  • Correspondent: SHAPIRO, BARRY, SHAPIRO LAW GROUP PC, 11370 SW 84TH AVE, MIAMI, FL 33156.
  • Context: Guy A. Carpenter assigned an interest in the patent to Implicit Networks, Inc.

Timeline diagram

timeline
    title Ownership of US US7391791B2
    2001 : Application filed
    2003 : Inventors assign to BeComm Corp
    2004 : Assigned to Implicit Networks Inc
    2008 : Patent issued
    2014 : Assigned to Implicit LLC
         : Security agreement to CBC Partners
    2017 : First infringement suit filed
    2018 : Security agreement released
    2020 : Appeal filed at CAFC
    2021 : Guy A Carpenter assigns to Implicit Networks Inc
    2026 : CAFC affirms unpatentability

NPE / troll-pattern signals

1. Shell-entity transfer — present.

   • Implicit, LLC: The transfer from Implicit Networks, Inc. to Implicit, LLC in 2014-02-28 (Reel 031313/0530) and subsequent security agreement (Reel 031313/0534) suggest a transfer to a licensing-focused entity. Implicit, LLC was also the entity asserting the patent in litigation, and no products are known to be sold directly by this entity.

2. Known asserter in the chain — present.

   • Implicit, LLC is a known asserting entity, as evidenced by its litigation campaign against Sonos, Inc. involving this patent.

3. Repeat correspondent across the chain — present.

   • Augustus Russ, Law Office of Augustus Russ: Appears on records 014494/0836 (2003-08-11) and 015383/0333 (2004-09-02).
   • John L. Reid, Kilpatrick Townsend & Stockton LLP: Appears on records 031313/0530 (2014-03-04), 031313/0534 (2014-03-04), and 041838/0334 (2018-01-11). The repeated use of this correspondent for both the assignment to Implicit, LLC and the related security agreement/release strengthens the signal.

4. Cascading transfers — not present.

   • While there are several transfers, they are spaced out over years, and the two transfers on 2014-02-28 relate to a primary assignment and a concurrent security interest, not multiple consecutive ownership transfers.

5. Pre-litigation transfer — present.

   • The patent was assigned to Implicit, LLC on 2014-02-28 (Reel 031313/0530). The first infringement suit filed by Implicit, LLC against Sonos, Inc. was on March 10, 2017. While this is not within 6 months, the transfer to Implicit, LLC appears to precede and enable the later assertion activity.

6. Bankruptcy fire-sale — not present.

   • No evidence of bankruptcy proceedings leading to the patent transfer.

7. Privateering — unclear.

   • No explicit evidence from the provided data or standard public searches indicates an operating company transferring the patent to an NPE to assert on its behalf against competitors.

8. Defensive aggregator (anti-NPE) — not present.

   • The chain does not terminate at any known defensive aggregators.

Verdict

NPE — high confidence

This verdict is supported by the presence of a known asserter (Implicit, LLC) in the chain, the transfer to a likely shell entity (Implicit, LLC) that subsequently engaged in litigation, and the recurrence of a specific correspondent firm (Kilpatrick Townsend & Stockton LLP) across multiple transfers involving the asserting entity. The transfer to Implicit, LLC in 2014 (Reel 031313/0530) preceded the initiation of infringement lawsuits in 2017, indicating the structure was put in place for assertion.

USPTO Assignment Center search: https://assignmentcenter.uspto.gov/