Invalidity dossier
US 7421188
Information edition device, information edition method, information edition program, and information recording medium
Current assignee: LG Electronics, Inc., LG Electronics U.S.A., Inc.
Added 9/28/2026, 6:05:17 PM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for authoritative records on this patent, including any 2026 appellate docket activity.
Let me check the litigation/appellate posture and confirm the enforcement history.
Let me do one final check for any 2026 appellate activity specifically tied to this patent.
US Patent 7,421,188 — Analyst Summary
Note on scope of docket search: I searched for records tied specifically to the number 7,421,188. I did not find any Court of Appeals for the Federal Circuit docket in 2026 involving this patent. The only 2026 Federal Circuit Maxell-related activity surfaced in my searches was Mondis Technology Ltd. v. LG Electronics (Fed. Cir. No. 23-2116, decided Aug. 2025), which concerns a different patent family (US 6,549,970 / 6,513,088 / 7,435,180 / 7,475,180 / 7,089,342 — display communication patents), not the '188 patent. I state that explicitly as a negative finding rather than asserting there is none.
1. Bibliographic Data
| Field | Value |
|---|---|
| Patent number | US 7,421,188 B2 |
| Title | Information edition device, information edition method, information edition program, and information recording medium |
| Application no. | US 10/506,515 |
| Filing date | 2003-03-04 (via PCT/JP2003/002509) |
| Priority | JP 2002-107158, filed 2002-03-05 (JP 2002-107158A) |
| Pre-grant publication | US 2005/0152672 A1, 2005-07-14 |
| Issue date | 2008-09-02 |
| Inventors | Yuichi Kanai; Yoshihiro Hori; Ryoji Ohno; Takeo Ohishi; Kenichiro Tada; Akihiro Tozaki; Tatsuya Hirai |
| Original assignees (joint) | Hitachi, Ltd.; Pioneer Corp.; Sharp Corp.; Sanyo Electric Co., Ltd.; Victor Company of Japan, Ltd. |
| Current assignee (per Google Patents) | Maxell, Ltd. |
| Status | Expired – Lifetime; adjusted expiration 2025-05-28 |
| Classification | G11B27/034, G11B27/34, G11B27/326, G11B27/329, H04N5/91, G11B2220/20 |
Assignment chain (as recorded, literal): Hitachi/Pioneer/Sharp/Sanyo/JVC (2004) → JVC Kenwood (2012, merger) → Hitachi Consumer Electronics (2013) → Hitachi Maxell (2014) → Maxell, Ltd. (2018) → Maxell Holdings (2021 merger) → Maxell, Ltd. (2021 name change). Pioneer's interest passed to Onkyo (2019) and then back to Maxell (2019).
2. Abstract (verbatim)
"An information editing apparatus is provided which can prevent a thumbnail image, which shows the contents of recorded information recorded on an information recording medium, from being accidentally changed by a misoperation of the user. The information editing apparatus includes a deciding device 8 for deciding whether a thumbnail image can be changed or not based on change permission information, which indicates whether a change can be made on the thumbnail image showing the contents of recorded information recorded on a recording medium 1. When the deciding device 8 decides that a change is not permitted, a change of the thumbnail image is prohibited."
3. Independent Claims — Plain-Language Overview
The patent has three independent claims (1, 4, 7), each with two dependent claims (2–3, 5–6, 8–9).
Claim 1 — Information editing apparatus (the core claim)
An apparatus that edits how recorded information (which includes at least image information) on a recording medium is played back. It has two parts:
- a "deciding device" that looks at "change permission information" — a flag indicating whether the thumbnail image (a picture representing what the recorded content is) may be changed — and decides accordingly; and
- a "change prohibiting device" that blocks the change when the deciding device says changes are not permitted.
Editing is performed on the reproduced form of the recorded information. In plain terms: a protected thumbnail can't be overwritten.
Claim 4 — Information editing method
The method counterpart: a deciding process (checking the change permission information to determine whether the thumbnail can be changed) plus a change prohibiting process that blocks the change when the decision is "not permitted," with editing performed on the reproduced form of the recorded information.
Claim 7 — Computer-readable recording medium encoded with a program
A storage medium carrying instructions that, when run on a computer inside an information editing apparatus for editing a reproduced form of recorded information including at least image information, cause the computer to function as:
- a deciding device that decides whether the thumbnail can be changed based on change permission information; and
- a change prohibiting device that prohibits changing the thumbnail when the deciding device decides a change is not permitted.
Note: Claim 7 as printed is grammatically garbled — its preamble reads "…in an information editing apparatus for editing a reproduced form of recorded information which includes at least image information apparatus…," and the second element is introduced as "an information editing program for causing the computer serving as the deciding device to act as a change prohibiting device…." I am reporting the claim text literally; the malformed phrasing is in the patent as published, and I am not correcting it.
Dependent claims (plain language):
- Claim 2 (from 1): adds a generating circuit that produces a display signal showing a warning that the thumbnail cannot be changed, when changes are not permitted.
- Claim 3 (from 1): adds a changing device that actually changes the thumbnail when the deciding device says changes are permitted.
- Claims 5 and 6 (from 4): the method counterparts of claims 2 and 3 (warning-generating process; changing process).
- Claims 8 and 9 (from 7): the program-medium counterparts of claims 2 and 3 (generating device producing a warning signal; changing device).
4. Technical Context (from the specification)
The embodiment is an information recording apparatus that records AV information (MPEG-2 transport stream) onto a portable hard disk and edits it. The logical format defines vendor-definition and user-definition thumbnail images, program lists, and program sets. The "change permission information" is the field designated REL within attribute information (DTT/PTT/ITT) of representative-image structures — e.g., initial program set representative image information (FIG. 2), vendor program list representative image information, and index representative image information (FIG. 5). Per the specification's stated convention, REL = "0" means resetting is permitted and REL = "1" means resetting is not permitted. The controller 8 acts as both the deciding device and changing device; the OSD 20 (with adding circuit 21) generates the warning display. Workflows are described in FIGS. 10 (user thumbnail setting), 12 (reset-permitted decision flow) and 14 (setting the unresettable bit).
Internal inconsistency worth flagging: the FIG. 8 narrative contradicts the field-level convention above. It states: "[w]hen '0' is written, a change of the thumbnail image is prohibited… When '0' is written, since a change is permitted, the thumbnail image is changed." These two sentences cannot both be right. This is a specification-side drafting error that a court or the PTAB would need to reconcile — and a plausible claim-construction vulnerability. I note it as an observation, not a legal conclusion.
5. Enforcement / Litigation and PTAB Posture (verified from docket-derived sources)
- District court: Maxell, Ltd. v. LG Electronics Inc., No. 5:24-cv-04972 (N.D. Cal.), originally filed Dec. 29, 2023 in E.D. Tex. as No. 5:23-cv-00152, transferred to N.D. Cal. on July 1, 2024. The '188 patent was one of nine asserted patents (with 6,856,760; 6,973,334; 7,199,821; 10,244,284; 8,339,493; 8,736,729; 9,818,449; 10,199,072). LG moved for judgment on the pleadings / JMOL that the '188, '072, '449 and '760 patents are invalid under 35 U.S.C. § 101 as directed to the abstract idea of "recording, manipulating, and displaying data." Maxell's opposition papers (including the Eslamimehr declaration, Dkt. #108) specifically argued that claims 4–5 recite a concrete, improved user-interface behavior keyed to the "change permission information."
- Resolution: The parties gave notice of a prospective settlement in late April 2025, and the action was dismissed with prejudice under Rule 41(a)(1)(A)(ii), each side bearing its own costs. The § 101 motion was apparently never decided.
- PTAB: LG Electronics, Inc. v. Maxell, Ltd., IPR2025-00519, filed Jan. 21–22, 2025, challenging the '188 patent. The proceeding was terminated pursuant to settlement (35 U.S.C. § 317(a); 37 C.F.R. § 42.74); the IPR tracker records a close date of 07/09/2025 and status "Terminated–Settled." LG's exhibit list cites prior art including JP2001211421A (Yoshida), JP2000307994A (Terashita), US 6,292,273 (Dow), JP2002033986A (Murakami), JPS61101850A (Tezuka), JP2001169231A (Miyasaka), JPH11275512A (Shioji), JPH0983925A (Miyamoto), JPH0993527A (Hongo), US 2002/0067923 A1 (Fujimura), US 2003/0011683 A1 (Yamasaki), and WO 01/57683 A1 (Flamini).
- Appellate: No 2026 CAFC docket tied to the '188 patent was found. Because both the district-court case (with prejudice) and the IPR (by settlement) were resolved consensually, an appeal on the '188 patent appears unlikely — but I cannot exclude one.
Sources: Google Patents (https://patents.google.com/patent/US7421188/en); Justia (https://patents.justia.com/patent/7421188); CourtListener Dkt. #108 in 5:24-cv-04972 (https://www.courtlistener.com/docket/69032831/108/maxell-ltd-v-lg-electronics-inc/); PTAB joint motion to terminate in IPR2025-00519 (https://ai-lab.exparte.com/case/ptab/IPR2025-00519/doc/6); Docket Alarm IPR2025-00519 record (https://www.docketalarm.com/search/PTAB/dockets/); MLex/Law360 settlement report (https://www.mlex.com/mlex/articles/[2332346](/patent/2332346)/); PatSnap litigation summary (https://www.patsnap.com/de/resources/blog/litigation/maxell-v-lg-electronics-9-patent-smartphone-dispute-dismissed-patsnap/); Fish & Richardson 2026 award note re: Mondis v. LG (https://www.fr.com/news/fish-richardson-recognized-by-managing-ip-with-impact-case-of-the-year-award-04-10-2026/).
6. Explicit Uncertainty Flags
- Current ownership: Google Patents lists Maxell, Ltd. as current assignee. I did not independently verify this against USPTO Assignment records; the chain is reconstructed from the recorded assignments shown on the patent page.
- Legal status: The record shows "Expired – Lifetime" with adjusted expiration 2025-05-28. I am reporting that status literally and not drawing a legal conclusion about enforceability or term.
- CAFC 2026 dockets: My searches did not return any appellate proceeding for the '188 patent in 2026. I cannot rule out a docket that is not indexed in the sources I searched.
- Claim 6 / Claim 7 phrasing: Both contain textual irregularities (claim 6 says "when the deciding device decides, instead of the change prohibiting device, that a change is permitted"; claim 7's preamble/element structure is malformed). These are reproduced literally from the authoritative patent text and were not auto-corrected.
- The § 101 challenge to the '188 patent was briefed but, per the record found, never adjudicated — so there is no authoritative merits ruling on eligibility to report.
Generated 9/28/2026, 6:11:45 PM
Cases on file (2)
Group view →Specific litigation cases in our database that name US patent 7421188. The free-form analysis below may also discuss cases beyond this list.
- LG Electronics, Inc. et al. v. Maxell, Ltd.filed Jan 21, 2025IPR2025-00519USPTO Patent Trial and Appeal Boardterminated Jul 9, 2025terminated — settled
Defendants: Maxell, Ltd.
- Maxell, Ltd. v. LG Electronics Inc. et al.filed Dec 29, 20235:23-cv-00152; 5:24-cv-04972U.S. District Court for the Eastern District of Texas (originally); transferred to U.S. District Court for the Northern District of Californiaterminated Jul 2, 2025transferred; closed/dismissed (settlement)
Defendants: LG Electronics Inc., LG Electronics U.S.A., Inc.
Other patents asserted: 8736729, 6856760, 6973334, 7199821, 10244284, 8339493, 9818449, 10199072
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US patent 7421188 using multiple targeted searches.
I found two proceedings. Let me gather more details on each and check for additional cases.
Let me verify whether the '188 patent appears in any other Maxell campaigns (Samsung, Amazon, Coretronic, etc.) and confirm the ITC angle.
Litigation Involving U.S. Patent No. 7,421,188
Based on my searches of patent-litigation sources (Unified Patents PTAB portal data as surfaced via Google Patents, Docket Alarm, RPX, CourtListener/PACER docket data, MLex/Law360, and PTAB filings), I identified two proceedings that specifically involve U.S. Patent No. 7,421,188 ("'188 patent"). The '188 patent is titled Information edition device, information edition method, information edition program, and information recording medium (priority date 2002‑03‑05; filed 2003‑03‑04; granted 2008‑09‑02; original assignees Hitachi/Pioneer/Sharp/Sanyo/Victor; current owner Maxell, Ltd.; adjusted expiration 2025‑05‑28).
I did not find the '188 patent asserted in any other district court case, ITC Section 337 investigation, or Federal Circuit appeal. Specifically, the Maxell ITC actions I located (337‑TA‑1338 against VIZIO; 337‑TA‑1420 against TCL) assert other Maxell patents (e.g., 8,549,109; 8,170,394; 10,958,971; 11,017,815; 11,451,860; 11,924,502) — not the '188 patent.
1. District Court Litigation
Case: Maxell, Ltd. v. [LG Electronics Inc.](/litigations/by-plaintiff/LG%20Electronics%20Inc.) and LG Electronics U.S.A., Inc.
| Item | Detail |
|---|---|
| Plaintiff | Maxell, Ltd. (Kyoto, Japan) |
| Defendants | LG Electronics Inc.; LG Electronics U.S.A., Inc. |
| Jurisdiction / Court | Originally filed in the U.S. District Court for the Eastern District of Texas; transferred (28 U.S.C. § 1404(a) motion granted July 1, 2024) to the U.S. District Court for the Northern District of California (San Jose Division) |
| Case Number | E.D. Tex. original docketing referenced as Case No. 5:23‑cv‑00152; N.D. Cal. number 5:24‑cv‑04972‑NW‑SVK |
| Filing Date | December 29, 2023 (original complaint, E.D. Tex.); re-docketed in N.D. Cal. August 9, 2024 |
| Judge | Originally Hon. Eumi K. Lee; reassigned Feb. 24, 2025 to Hon. Noël Wise |
| Asserted Patent Count | Nine patents total, including 7,421,188 (also 6,856,760; 6,973,334; 7,199,821; 10,244,284; 8,339,493; 8,736,729; 9,818,449; 10,199,072) |
| Outcome / Status | Settled and dismissed WITH PREJUDICE. The parties filed a stipulation of dismissal under Rule 41(a)(1)(A)(ii) dismissing all claims and counterclaims with prejudice, each party bearing its own costs/fees. Case closed (docket reflects closure ~July 2, 2025). |
Notes on this case:
- Maxell's complaint identified the accused instrumentalities as a broad range of LG smartphones (G, K, Q, Stylo, V families), LG Gram laptops, and other telecommunications products (LG V60 ThinQ 5G cited as a representative example).
- Before settlement, LG filed an October 2024 motion (fully briefed, hearing set for May 13, 2025, but not ruled upon) seeking judgment as a matter of law that a subset of the asserted patents — including 7,421,188 — were invalid under 35 U.S.C. § 101 as directed to the abstract idea of "recording, manipulating, and displaying data."
- On April 29, 2025, the parties notified Judge Wise of a "prospective" settlement. The §101 issue regarding the '188 patent was left unresolved by the with‑prejudice dismissal.
- Source references: MLex summary ("Maxell, LG give notice of settlement in California patent row," April 29, 2025, https://www.mlex.com/mlex/articles/[2332346](/patent/2332346)/); PatSnap litigation write‑up citing PACER Case 5:24‑cv‑04972; CourtListener docket for 5:24‑cv‑04972 (https://www.courtlistener.com/docket/69032831/); Joint Case Management Statement identifying the nine asserted patents (Exhibit 2002, IPR2025‑00393).
2. PTAB — Inter Partes Review
Proceeding: LG Electronics, Inc. and LG Electronics U.S.A., Inc. v. Maxell, Ltd.
| Item | Detail |
|---|---|
| Petitioners | LG Electronics, Inc.; LG Electronics U.S.A., Inc. |
| Patent Owner | Maxell, Ltd. |
| Forum | USPTO Patent Trial and Appeal Board |
| Case Number | IPR2025‑00519 |
| Patent at Issue | U.S. 7,421,188 (all claims 1–9 challenged) |
| Filing Date | January 21, 2025 (some dockets show January 22, 2025) |
| Grounds | Obviousness: (1) Yoshida (JP2001211421A) in view of Terashita (JP2000307994A); (2) Dow (U.S. 6,292,273); (3) Dow in view of Murakami (JP2002033986A) |
| Outcome / Status | Terminated — Settled (no institution decision, no final written decision). The parties filed a Joint Motion to Terminate Proceeding (dated July 1, 2025) following a settlement agreement (filed as confidential Ex. 1022 under 35 U.S.C. § 317 and 37 C.F.R. § 42.74). The proceeding was closed July 9, 2025. |
| Panel | Administrative Patent Judges Jason W. Melvin, Kevin C. Trock, Monica S. Ullagaddi |
The IPR ran in parallel with the district court action above (LG filed a coordinated set of IPRs covering the seven asserted patents, including IPR2025‑00519 against the '188 patent). LG's bid to stay the district court case pending PTAB institution decisions was denied by Judge Wise on April 25, 2025.
- Source references: Docket Alarm (IPR2025‑00519, LG Electronics, Inc. v. Maxell, Ltd., Patent 7421188); PTAB Joint Motion to Terminate (https://ai-lab.exparte.com/case/ptab/IPR2025-00519/doc/6); ex parte PTAB case page showing status "Terminated‑Settled," close 07/09/25; Google Patents family‑litigation entry for the '188 IPR.
Summary Table
| # | Case | Type | Case No. | Filed | Outcome/Status |
|---|---|---|---|---|---|
| 1 | Maxell, Ltd. v. LG Electronics Inc. et al. | District court (E.D. Tex. → N.D. Cal.) | 5:24‑cv‑04972‑NW‑SVK | Dec 29, 2023 | Settled; dismissed WITH PREJUDICE (closed ~July 2025) |
| 2 | LG Electronics, Inc. et al. v. Maxell, Ltd. | PTAB Inter Partes Review | IPR2025‑00519 | Jan 21, 2025 | Terminated — Settled (closed July 9, 2025); no FWD |
Caveats
- No litigation is known against any party other than LG Electronics involving the '188 patent based on the sources searched. The '188 patent does not appear in the Maxell ITC complaints (VIZIO and TCL smart‑TV investigations) or in the Maxell v. Samsung litigations, nor in the Maxell v. Coretronic/Optoma case (5:24‑cv‑00088, E.D. Tex.).
- The '188 patent's term expired (adjusted expiration May 28, 2025), which likely contributed to the early resolution of both proceedings without a merits ruling.
- If you need the precise E.D. Tex. docket number and the exact dismissal-order date, those should be pulled directly from PACER/CourtListener, as the original E.D. Tex. docket number is inconsistently reported across secondary sources (I have seen it cited both as a 2023 E.D. Tex. filing — e.g., "5‑23‑cv‑00152" in LG's IPR exhibit list — and the case briefly re-docketed in N.D. Cal. on Aug. 9, 2024). I could not independently confirm a single consistent original docket number from the sources retrieved.
Generated 9/28/2026, 6:12:04 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
Current assignee: LG Electronics, Inc., LG Electronics U.S.A., Inc.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll research this patent's PTAB history, starting with the proceeding number flagged on the patent record.
Found a live proceeding the ODP data didn't index. Let me dig into the details and check for any others.
Let me confirm the adjacent petition's target patent and pin down the termination details.
PTAB proceedings overview
One AIA trial proceeding has been filed against US 7,421,188 — IPR2025-00519 (LG Electronics v. Maxell), which was terminated by pre-institution settlement on 2025-07-09 (status: Terminated-Settled). No claims were invalidated, none were sustained, and no Final Written Decision ever issued.
⚠️ Data-integrity flag: the structured "PTAB proceedings on file" block in this prompt states the USPTO ODP API returns no AIA trial proceedings for this patent. That is factually incorrect as of today — the patent's own Google Patents record lists "PTAB case IPR2025-00519 filed (Settlement)," and the ODP legal-events feed on that same page carries the 2025-04-01 IPR entry (Trial No. IPR2025-00519). The ODP ingest supplied to you is stale or incomplete. Treat the proceeding below as on file.
Bottom-line defensive posture: This is not a hardened patent and not a dead one — it is an untested one. All nine claims (1–9) survived to expiry without a single patentability adjudication, because LG settled before the Board decided whether to institute. Two facts dominate the defense calculus: (1) the patent expired 2025-05-28 on its adjusted term, so any live assertion is a past-damages claim only; and (2) although an earlier challenger's precise §103 grounds are not estopped (no FWD ⇒ no §315(e)(2) estoppel), a fresh petitioner will now have to fight through the Director's 2025 "settled expectations / expired patent" discretionary-denial line that Maxell has been actively wielding against Samsung and others.
IPR2025-00519 — LG Electronics, Inc. and LG Electronics USA, Inc. v. Maxell, Ltd.
- Type: Inter Partes Review (35 U.S.C. §§ 311–319); Tech Center 2600. Case page: PTAB case IPR2025-00519 (mirror of PTAB E2E docket); Docket Alarm docket entry
- Filed: 2025-01-21 (docket and PTAB-based aggregators agree; one district-court joint case management statement — citing the LG petitions — gives 2025-01-22. I report 2025-01-21 as the docket date and flag the one-day discrepancy.)
- Status: Terminated-Settled (verbatim). Gloss: the parties settled before the Board reached an institution decision ("Settlement Prior to Institution of Trial, 37 C.F.R. § 42.74"), so the case closed with no institution ruling, no trial, and no FWD.
- Judge panel: Administrative Patent Judges Jason W. Melvin, Kevin C. Trock, and Monica S. Ullagaddi — the same three-judge panel assigned to LG's companion petitions filed the same day (see Pattern signals below). Panel assignment is public via the PTAB docket.
- Petition grounds (all challenges against claims 1–9, i.e., every claim of the patent, on § 103 obviousness):
- Ground 1 — Claims 1–9 obvious over Yoshida (JP 2001-211421 A) in view of Terashita (JP 2000-307994 A). LG mapped Yoshida's image-protect status to the claimed "change permission information," and used Terashita's prohibition message to reach the claim 2 "warning" limitation.
- Ground 2 — Claims 1–9 obvious over Dow (U.S. Patent No. 6,292,273), asserted as a single-reference anticipation-style obviousness theory.
- Ground 3 — Claims 1–9 obvious over Dow in view of Murakami (JP 2002-033986 A).
- The petition asserted additional grounds beyond the three above; the exhibit list (LG-1005 through LG-1021) includes Tezuka (JPS61101850A), Miyasaka (JP2001169231A), Shioji (JPH11275512A), Miyamoto (JPH0983925A), Hongo (JPH0993527A), Fujimura (US 2002/0067923 A1), Yamasaki (US 2003/0011683 A1), Flamini (WO 01/57683 A1), Masahiro (JPH08205014A), and Nobuhide (JPH114405A). I cannot confirm from the public record how those exhibits map to specific numbered grounds, and I am not going to guess.
- Source for grounds: third-party petition analysis for IPR2025-00519 (secondary source, AI-generated summary of the filed petition); the underlying papers are at PTAB E2E.
- Institution decision: None issued. The Board never reached a § 314(a) determination. A "Notice filing date accorded" issued 2025-03-10; Patent Owner filed mandatory notices on 2025-02-11. Because the case settled pre-institution, there is no institution decision, no panel reasoning on the merits, and nothing to appeal. (Do not let anyone tell you this IPR "denied institution" — it did not; it never got there.)
- Final Written Decision: None. No claim of US 7,421,188 has ever been canceled, confirmed, or otherwise adjudicated by the PTAB. Claims 1–9 all remained standing (and the patent then expired).
- Settlement / termination: On 2025-07-01 LG and Maxell filed a Joint Motion to Terminate Proceeding under 35 U.S.C. § 317(a) and 37 C.F.R. § 42.74, stating they "have reached a settlement" resolving their disputes by written agreement, with the confidential agreement filed for "Board and Parties Only" plus a joint request to treat it as business confidential. Termination motion: Joint Motion to Terminate, IPR2025-00519. The Board entered its Termination Decision: Settlement Prior to Institution on 2025-07-09; LG requested a refund of post-institution fees on 2025-07-22 (approving the inference that no institution fees were ever incurred). The settlement terms are confidential.
- Appeal: None. With no institution and no FWD, no appealable PTAB decision existed; no CAFC docket stems from this proceeding.
- Defensive value: Mixed, and slanted toward the accused infringer. The upside for a defendant is that the patent is completely untested at the PTAB — there is no adverse FWD precedent, no Board claim construction, and no § 315(e)(2) estoppel binding LG or any privy, because estoppel attaches only after a final written decision. LG's petition papers (Yoshida/Terashita, Dow, Dow/Murakami and the ten-plus additional Japanese/Korean/U.S. references) are public roadmap material for the next challenger. The downside is that the "well-trodden IPR" defense does not exist here: an accused infringer must build its own invalidity case or argue § 101, and must reckon with the patent's expiry (see below).
Strategic summary
Claim status: every claim is UNTESTED. Because IPR2025-00519 settled before institution, claims 1, 2, 3, 4, 5, 6, 7, 8, and 9 are neither canceled nor sustained. There is no IPR-narrowed claim set to point to and no surviving-claims list to compile — all nine claims stand as issued. The patent's status on Google Patents is Expired – Lifetime with adjusted expiration 2025-05-28 (priority 2002-03-05; filed 2003-03-04), meaning the asserted property right ran out before the IPR itself was even terminated. Practically: injunction exposure is nil, and the damages window is the § 286 six-year lookback (roughly 2019-09-28 forward, subject to the usual marking/notice analysis) plus any pre-expiry accrual. Notably, the patent expired on 2025-05-28 while the IPR was still pending — a fact that would have been front-and-center in any institution analysis.
Estoppel landscape. There is no statutory estoppel arising from IPR2025-00519: § 315(e)(1) (PTAB-side) and § 315(e)(2) (district-court-side) both require a final written decision, and none issued. LG (and its privies) therefore remain free to raise Yoshida/Terashita, Dow, Dow/Murakami, and the rest of the petition art in any future litigation, and so does the rest of the world. The corollary for a new defendant being asserted against today: (a) the full universe of prior art is procedurally available, including the entire LG exhibit set, which is a free invalidity roadmap; but (b) any IPR you file will be met with Maxell's now-standard discretionary-denial playbook, which leans on patent age / settled expectations and petitioner delay. Maxell has been pressing exactly these arguments — see its brief in the Samsung v. Maxell '417 Patent IPR invoking Dabico Airport Solutions v. AXA Power (IPR2025-00408, Paper 21), Amgen v. Bristol-Myers Squibb (IPR2025-00601, Paper 9), Intel v. Proxense (IPR2025-00327, Paper 12), Google v. SoundClear (IPR2025-00344, Paper 15), and Samsung v. Mobile Data Techs. (IPR2025-00535, Paper 16). A 2002-priority patent with an expired term is about as strong a "settled expectations" fact pattern as that line of authority gets.
Pattern signals. The same petitioner filed a coordinated volley on 2025-01-21: IPR2025-00519 against the '188 patent, plus IPR2025-00520 against U.S. Patent No. 10,244,284 (claims 18–20) — both assigned to Judges Melvin, Trock, and Ullagaddi, both challenged on § 103 grounds, and both terminated by pre-institution settlement on the same day, 2025-07-09. LG had filed at least seven IPRs or petitions against Maxell patents in that window (spanning the '188, '072, '449, '760, '493, '729, and '284 patents), all tied to the same infringement campaign. The settlement that killed this IPR was part of a global peace: in Maxell, Ltd. v. LG Electronics Inc. et al., No. 5:23-cv-00152 (E.D. Tex., filed 2023-12-29; refiled/transferred as No. 5:24-cv-04972 (N.D. Cal.)) — where the '188 was one of nine asserted patents — the parties filed a stipulation of dismissal under Rule 41(a)(1)(A)(ii) dismissing all claims and counterclaims WITH PREJUDICE, each side bearing its own fees. No defensive aggregator intervened: Unified Patents appears in this chain only as a data-source portal (the Google Patents "litigation" link points to Unified's public PTAB/litigation data), not as a petitioner in IPR2025-00519. LG Electronics, Inc. and LG Electronics USA, Inc. were the sole real parties in interest. Maxell, for its part, has litigated hard but settled broadly — it also settled ITC Inv. No. 337-TA-1338 (VIZIO) and 337-TA-1420 (TCL) on different patents, and its N.D. Cal. case against Coretronic/OpTima (No. 5:24-cv-00088) proceeded with a final election of asserted claims that notably did not include the '188.
Recommended next steps
- If you are a defendant facing the '188 today, the first call is damages, not validity. The patent expired 2025-05-28. Confirm the asserted-claim set and the accused product's sales window, then run the § 286 six-year limit and marking analysis. Any demand letter premised on ongoing royalties or injunctive relief after that date is wrong on its face.
- Do not expect a short-cut from IPR2025-00519. Because the Board never instituted and never issued an FWD, there is no disposition to point to and no estoppel to invoke. Quote the docket instead: Joint Motion to Terminate (2025-07-01) → Board Termination Decision: Settlement Prior to Institution (2025-07-09). The confidential settlement agreement is filed "Board and Parties Only" and is not a public tool.
- Mine LG's petition art. LG's trial exhibits LG-1005 to LG-1021 (Yoshida JP2001211421A; Terashita JP2000307994A; Dow US 6,292,273; Murakami JP2002033986A; plus Tezuka, Miyasaka, Shioji, Miyamoto, Hongo, Fujimura, Yamasaki, Flamini, Masahiro, Nobuhide) are public and represent a curated invalidity set assembled by sophisticated counsel. That is the most efficient starting point for your own § 102/§ 103 work.
- Preserve the § 101 theory. In the LG case, LG challenged the '188 (with U.S. 10,199,072, 9,818,449, and 6,856,760) as patent-ineligible under § 101 — the MLex-reported characterization is a motion for judgment as a matter of law filed in October 2024, briefing complete with a hearing set; the N.D. Cal. court never ruled on it before the with-prejudice dismissal. That means a § 101/Alice attack on these claims remains untested and unadjudicated, and is not subject to any IPR estoppel. The '188 claims (a "deciding device" and a "change prohibiting device" keyed to change-permission information) are a plausible Alice target on the "abstract idea of recording, manipulating, and displaying data" framing LG used.
- If you are contemplating an IPR, move carefully on timing. You will face a strong Dabico/GenghisComm/Amgen-style discretionary-denial argument given the patent's 2002 priority and post-expiry status, and the practical value of a PTAB win on an expired patent is low. Weigh PTAB cost against a district-court § 101/§ 102/§ 103 strategy where you can use the now-public LG art without exhaustion risk.
- Verify against primary sources before filing anything. The claim-level and ground-level details above are drawn partly from third-party petition-analysis summaries; the authoritative documents are the PTAB E2E / PTACTS filings for IPR2025-00519 (Petition, Exhibit 1005–1021, Joint Motion to Terminate, and the 2025-07-09 Termination Decision) and the N.D. Cal. docket in No. 5:24-cv-04972. Also re-query the USPTO ODP API for this patent — the ingest relied on here is demonstrably missing a proceeding that Google Patents already reflects.
Generated 9/28/2026, 6:12:23 PM
Ownership chain (11)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2004-08-27 · recorded 2004-09-03 · reel 016294/0223 · Assignment
Kanai, Yuichi; Hori, Yoshihiro; Ohno, Ryoji; Ohishi, Takeo; Tada, Kenichiro; Tozaki, Akihiro; Hirai, TatsuyaSanyo Electric Co., Ltd.; Pioneer Corporation; Hitachi, Ltd.; Victor Company of Japan, Limited; Sharp Corporation
initial assignment
2010-07-06 · recorded 2014-12-09 · reel 034545/0798 · Change of Address
Pioneer CorporationPioneer Corporation
change of address only
2011-10-01 · recorded 2012-04-06 · reel 028000/0001 · Merger
Victor Company of Japan, Ltd.JVC Kenwood Corporation
internal reorg
2013-06-07 · recorded 2013-06-12 · reel 030668/0719 · Assignment
Hitachi, Ltd.Hitachi Consumer Electronics Co., Ltd.
internal reorg
2014-08-26 · recorded 2014-09-08 · reel 033694/0745 · Assignment
Hitachi Consumer Electronics Co., Ltd.Hitachi Maxell, Ltd.
internal reorg
2017-03-03 · recorded 2017-03-10 · reel 041537/0167 · Assignment of Assignors' Interest
Sanyo Electric Co., Ltd.; Sharp Corporation; JVC Kenwood CorporationHitachi Maxell, Ltd. and Pioneer Corporation
consolidation
2017-10-01 · recorded 2018-01-25 · reel 045142/0208 · Assignment
Hitachi Maxell, Ltd.Maxell, Ltd.
internal reorg
2019-04-01 · recorded 2019-04-08 · reel 048813/0878 · Assignment
Pioneer CorporationOnkyo Corporation
divestiture
2019-04-04 · recorded 2019-04-08 · reel 048813/0908 · Assignment
onward transfer
2021-10-01 · recorded 2021-11-29 · reel 058255/0579 · Merger
holdco reorg
2021-10-01 · recorded 2021-12-03 · reel 058666/0407 · Change of Name
change of name only
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll check the live assignment/ownership records and asserter directories before writing.
Let me try to surface the recorded correspondent/attorney of record for these reels.
I hit my tool-call budget while chasing the correspondent field, so I'll be explicit about what I could and could not verify. Everything below is grounded in the reel/frame data in the patent record itself and the live enforcement sources I did retrieve.
Assignment & Ownership Reconstruction — US 7,421,188
Critical source note up front: The USPTO Assignment Center UI (https://assignmentcenter.uspto.gov/ / assignment.uspto.gov) is not machine-readable with the tools I have here. The reel/frame, conveyance-type, assignor/assignee and execution/recordation dates below are taken from the USPTO assignment records as mirrored in the Google Patents "Legal Events" table for this patent, and they do carry the REEL/FRAME: strings verbatim.
One field the task specifically wanted is missing from every source I could reach: the correspondent of record (recording attorney/firm). Google Patents' legal-events mirror does not carry it, and I did not reach the raw assignment abstracts. I am not filling that field in from inference. Signal #3 (repeat correspondent) is therefore reported as unclear, not clean — a genuinely important gap given that this is the single most useful NPE tell. Verifying it requires pulling the five post-2004 abstracts directly in Assignment Center.
Inventors
| # | Inventor | Employer at filing |
|---|---|---|
| 1 | Yuichi Kanai | Not determinable from the record |
| 2 | Yoshihiro Hori | Not determinable from the record |
| 3 | Ryoji Ohno | Not determinable from the record |
| 4 | Takeo Ohishi | Not determinable from the record |
| 5 | Kenichiro Tada | Not determinable from the record |
| 6 | Akihiro Tozaki | Not determinable from the record |
| 7 | Tatsuya Hirai | Not determinable from the record |
Patterns worth flagging:
- The 2004-09-03 assignment (Reel 016294/0223) lists all seven inventors assigning jointly to five corporations simultaneously — Sanyo Electric, Pioneer, Hitachi, Victor Company of Japan (JVC), and Sharp. This is not a single-employer filing. A seven-inventor, five-co-assignee US filing with a single shared recording is the signature of a cross-company joint-development arrangement (a Japanese CE consortium-style filing), not a lone-company R&D project. The assignment abstract does not break out which inventor worked for which of the five, so I will not guess.
- Signature dates run 2004-07-29 → 2004-08-27, i.e., the inventors signed roughly 2½ years after the JP priority date (2002-03-05) and 17 months after the 2003-03-04 PCT filing — normal for a national-phase entry.
- No "inventor exodus" signal is available. I found no evidence of inventors leaving the original assignees within 12 months of filing, and equally no evidence they stayed. That data point is simply absent from every source I reached. Do not read the blank as benign.
Original assignee
The patent issues with five co-assignees — no single "original assignee":
| Entity | Line of business (then) | Product embodying the claims shipped? | Status today |
|---|---|---|---|
| Hitachi, Ltd. | Consumer electronics / HDD-DVD recorders | Not established for these claims | Operating conglomerate |
| Pioneer Corporation | HDD/DVD recorders, AV | Not established for these claims | Operating, narrowed to car electronics; TV exited; DJ business sold to KKR 2020 |
| Sharp Corporation | Consumer electronics | Not established | Operating; Hon Hai/Foxconn-controlled since 2016 |
| Sanyo Electric Co., Ltd. | Consumer electronics | Not established | Consumer business absorbed into Panasonic after 2008–2011 acquisition; brand largely retired |
| Victor Company of Japan, Ltd. (JVC) | Consumer AV | Not established | Merged into JVC Kenwood (recorded 2012-04-06) |
All five were active manufacturers of the class of device the spec describes (an HDD recorder that records MPEG-2 transport streams and edits thumbnail/representative images) during the 2002–2008 window. But the record I have does not tie this specific claim set to any commercial model, and Maxell's later pleadings do not identify the '188 as a product-embodying patent. I am recording that as "not established," not as "no."
Assignment timeline
Eleven recorded events across 2004–2021. All reel/frame values verbatim from the record.
2004-07-29 / 2004-08-27 (executed) / recorded 2004-09-03 — Reel 016294/0223
- Conveyance: Assignment
- Assignor: Kanai, Yuichi; Hori, Yoshihiro; Ohno, Ryoji; Ohishi, Takeo; Tada, Kenichiro; Tozaki, Akihiro; Hirai, Tatsuya (the seven inventors)
- Assignee: Sanyo Electric Co., Ltd.; Pioneer Corporation; Hitachi, Ltd.; Victor Company of Japan, Limited; Sharp Corporation (joint)
- Correspondent: not in the record I retrieved
- Context: initial inventor→corporate assignment establishing a five-way co-ownership consortium.
2011-10-01 (executed) / recorded 2012-04-06 — Reel 028000/0001
- Conveyance: Merger
- Assignor: Victor Company of Japan, Ltd.
- Assignee: JVC Kenwood Corporation
- Correspondent: not retrieved
- Context: internal reorg — JVC's corporate identity folded into JVC Kenwood.
2013-06-07 (executed) / recorded 2013-06-12 — Reel 030668/0719
- Conveyance: Assignment
- Assignor: Hitachi, Ltd.
- Assignee: Hitachi Consumer Electronics Co., Ltd.
- Correspondent: not retrieved
- Context: internal reorg — carve-out of consumer product IP into the HCE division (Maxell's own pleadings confirm this: "in 2009 Hitachi, Ltd. assigned much of its consumer product-facing IP to Hitachi Consumer Electronics Co., Ltd.").
2014-08-26 (executed) / recorded 2014-09-08 — Reel 033694/0745
- Conveyance: Assignment
- Assignor: Hitachi Consumer Electronics Co., Ltd.
- Assignee: Hitachi Maxell, Ltd.
- Correspondent: not retrieved
- Context: internal reorg — HCE IP consolidated into Hitachi Maxell.
2010-07-06 (executed) / recorded 2014-12-09 — Reel 034545/0798
- Conveyance: Change of Address
- Assignor: Pioneer Corporation
- Assignee: Pioneer Corporation
- Correspondent: not retrieved
- Context: change of name/address only — no ownership movement. Note the 4½-year gap between execution and recording; this is an administrative cleanup, not a transfer.
2017-01-23 → 2017-03-03 (executed) / recorded 2017-03-10 — Reel 041537/0167
- Conveyance: Assignment of Assignors' Interest
- Assignor: Sanyo Electric Co., Ltd.; Sharp Corporation; JVC Kenwood Corporation
- Assignee: Hitachi Maxell, Ltd. and Pioneer Corporation (two assignees on one reel)
- Correspondent: not retrieved
- Context: consolidation — three of the five original co-owners exit, collapsing the five-way ownership into two owners.
2017-10-01 (executed) / recorded 2018-01-25 — Reel 045142/0208
- Conveyance: Assignment
- Assignor: Hitachi Maxell, Ltd.
- Assignee: Maxell, Ltd.
- Correspondent: not retrieved
- Context: internal reorg — IP aligned with the renamed operating subsidiary.
2019-04-01 (executed) / recorded 2019-04-08 — Reel 048813/0878
- Conveyance: Assignment
- Assignor: Pioneer Corporation
- Assignee: Onkyo Corporation
- Correspondent: not retrieved
- Context: divestiture — Pioneer's interest transferred to Onkyo.
2019-04-04 (executed) / recorded 2019-04-08 — Reel 048813/0908
- Conveyance: Assignment
- Assignor: Onkyo Corporation
- Assignee: Maxell, Ltd.
- Correspondent: not retrieved
- Context: onward transfer three days later — same reel block (048813), adjacent frames (0878 vs 0908), same recording date. This mid-chain hop is structurally a chain, and the shared reel/frame block is concrete evidence the Pioneer→Onkyo→Maxell legs were recorded as one coordinated filing by one filer. It is the only multi-hop sequence in the chain.
2021-10-01 (executed) / recorded 2021-11-29 — Reel 058255/0579
- Conveyance: Merger
- Assignor: Maxell, Ltd.
- Assignee: Maxell Holdings, Ltd.
- Correspondent: not retrieved
- Context: holdco reorg.
2021-10-01 (executed) / recorded 2021-12-03 — Reel 058666/0407
- Conveyance: Change of Name
- Assignor: Maxell Holdings, Ltd.
- Assignee: Maxell, Ltd.
- Correspondent: not retrieved
- Context: name change only — closes the loop; the surviving name is Maxell, Ltd.
Net effect: ownership ends at Maxell, Ltd. (Kyoto, Japan), consistent with Google Patents' stated current assignee. Consolidation into a single entity completed in 2019 (Reel 048813/0908), i.e. ~4½ years before the first suit I can find asserting the '188 (LG, December 2023).
Timeline diagram
timeline
title Ownership of US 7421188
2004 : Inventors assign to five Japanese firms
2012 : Victor Company merged into JVC Kenwood
2013 : Hitachi Ltd to Hitachi Consumer Elec
2014 : Hitachi Consumer Elec to Hitachi Maxell
: Pioneer records change of address
2017 : Sanyo Sharp JVC Kenwood to two owners
2018 : Hitachi Maxell to Maxell Ltd
2019 : Pioneer to Onkyo
: Onkyo to Maxell Ltd in same week
2021 : Maxell Ltd merged into Maxell Holdings
: Maxell Holdings renamed Maxell Ltd
NPE / troll-pattern signals
1. Shell-entity transfer — NOT PRESENT.
Every assignee across all eleven recordings is a named, publicly accountable Japanese operating corporation: Hitachi, Pioneer, Sharp, Sanyo, JVC/JVC Kenwood, Hitachi Consumer Electronics, Hitachi Maxell, Onkyo, Maxell. There is no LLC, no "IP Holdings/Ventures/Licensing" suffix in the ownership chain, no registered-agent address, no single-purpose vehicle. The two "Holdings" events (Reel 058255/0579, 058666/0407) are a genuine holdco merger + name change of an operating listed company, not a patent-holding shell.
2. Known asserter in the chain — PARTIALLY PRESENT (high-frequency-plaintiff prong only).
Maxell does not appear on the enumerated NPE list (Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation, Spangenberg). But it is surfaced by RPX as a tracked, high-frequency plaintiff — e.g. RPX Empower entries for Maxell v. Coretronic (E.D. Tex. 5:24-cv-00088) and Coretronic v. Maxell IPR of the '580 (IPR2025-00474) (https://litigation.rpxcorp.com/litigation/txedce-[231403](/patent/231403)-maxell-v-coretronic). Maxell's own complaints describe a notice letter listing 200+ patents to Samsung and a 119-patent follow-up to Lenovo, and the LG assertion spanned nine patents against 60+ product families. So: present as a volume asserter; not present as a classic NPE. Decisive distinction — Maxell is an operating company, not a non-practicing one.
3. Repeat correspondent across the chain — UNCLEAR (data gap).
The correspondent field is absent from every source I reached. I can note one structural substitute, but it is not the same evidence: Reels 048813/0878 and 048813/0908 share a reel block and were recorded the same day, tying the Pioneer→Onkyo and Onkyo→Maxell legs to a single filer. That is consistent with one correspondent handling both, but I will not name a firm I have not seen. This needs to be pulled from Assignment Center.
4. Cascading transfers — WEAKLY PRESENT.
Two clusters: (a) Pioneer → Onkyo → Maxell, executed 2019-04-01 and 2019-04-04, recorded 2019-04-08, same reel block 048813 — two hops in three days; and (b) the 2013-06 → 2014-08 Hitachi→HCE→Hitachi Maxell pair (~14 months). Cluster (a) is the only one that looks chain-like on its face, and even it reads as a corporate divestiture sequence (Pioneer shedding non-core IP; Onkyo immediately stepping aside), not an NPE cascade. No shared-principal or common-address evidence exists anywhere in the record.
5. Pre-litigation transfer — NOT PRESENT.
The last ownership-moving event is the 2019-04-04 Onkyo→Maxell assignment (Reel 048813/0908); the last recording of any kind is the 2021-12-03 name change (Reel 058666/0407). The earliest suit I can find asserting the '188 is Maxell v. LG Electronics, E.D. Tex. 5:23-cv-00152, filed 2023-12-29 (transferred to N.D. Cal. as 5:24-cv-04972 on 2024-07-01). That is ~4.7 years after the terminal assignment — well outside the 6-month window. Caveat: I could not confirm the complete set of pre-2023 assertions of this specific patent; the joint case management statement in the LG case identifies only the '760, '493 and '729 as having prior E.D. Tex. suits (Huawei 5:16-cv-178; ZTE 5:16-cv-179).
6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 proceeding appears in the chain. Sanyo (Panasonic acquisition), Pioneer (restructuring, DJ-unit sale), Sharp (Foxconn) and JVC (Kenwood merger) all restructured, but none of these recorded transfers is a bankruptcy-court sale. The 2017 consolidation (Reel 041537/0167) is a negotiated co-owner buy-out, not a distressed sale.
7. Privateering — NOT PRESENT.
Classic privateering is operating company → NPE → assertion against the operating company's competitors. Here the operating company kept title and asserted its own patents through 2023–2025 against LG, Samsung, Apple, TCL, VIZIO, Lenovo/Motorola, Coretronic and Optoma. There is no NPE intermediary standing between Maxell and the defendants.
8. Defensive aggregator — NOT PRESENT.
The chain ends at Maxell, Ltd., an active litigant. No RPX, AST, LOT, Unified or OIN link.
Additional flag on the patent record itself: the Google Patents "Family has litigation" panel prints "Petitioner: 'Unified Patents PTAB Data' by Unified Patents is licensed under a Creative Commons Attribution 4.0 International License." That is a data-license attribution line, not the identity of the petitioner. The actual petitioner in IPR2025-00519 is LG Electronics, Inc. (with LG Electronics U.S.A., Inc.), per the Docket Alarm PTAB record and the parallel IPR2025-00520 joint motion to terminate. Do not read Unified Patents into this chain — it is not an assignee, not a petitioner, and not a defensive aggregator here.
Verdict
Operating-company assertion — with a legacy-portfolio-monetization caveat.
There is no shell entity anywhere in the chain: eleven recordings, all between named Japanese operating corporations, ending at Maxell, Ltd. (a listed manufacturer of batteries, storage media, projectors and wireless-charging products), and the assertions are brought by Maxell itself against genuine competitors — LG, Samsung, Apple, TCL, VIZIO, Coretronic (Reel 048813/0908; N.D. Cal. 5:24-cv-04972). The only multi-hop sequence, Pioneer→Onkyo→Maxell executed 2019-04-01/04-04 and recorded 2019-04-08 on a shared reel block 048813, reads as a divestiture and title-consolidation, not an NPE cascade, and it sits ~4.7 years before the first assertion of this patent.
The caveat matters, and I want it on the record: the claims of the '188 (thumbnail change-permission flag in a hard-disk AV recorder) are Hitachi-era legacy IP and are not shown by any source to be embodied in a current Maxell product. Maxell is therefore an operating company that, with respect to this particular patent, behaves like a licensor/NPE. If a rubric requires affirmative product embodiment of the asserted claims, the honest characterization is a hybrid — operating-company assertion of a non-practiced legacy patent — rather than a clean "operating company defending its own market."
Verify at: https://assignmentcenter.uspto.gov/ (search patent 7,421,188) — request the correspondent of record for Reels 016294/0223, 028000/0001, 030668/0719, 033694/0745, 034545/0798, 041537/0167, 045142/0208, 048813/0878, 048813/0908, 058255/0579 and 058666/0407. That single field is the outstanding gap in this analysis.
Generated 9/28/2026, 6:12:37 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research the cited prior art references for US 7,421,188. Let me run several searches in parallel.
I found the IPR petition with its prior-art grounds. Let me gather more detail on the remaining cited references.
US Patent 7,421,188 — Prior-Art Citation Analysis
Scope and method. I pulled the citation list that appears on the face of US 7,421,188 from the patent record mirror at Google Patents, which reproduces the USPTO "References Cited" data (https://patents.google.com/patent/US7421188/en). I cross-checked against the PTAB petition and exhibit list in IPR2025-00519 (LG v. Maxell), which re-ran the prior art against the same claims (https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1557333](/patent/1557333)/download-documents). Data-source caveat: I did not run a separate live query in USPTO Patent Public Search (PPUBS); the citations below are those recorded on the face of the patent and in the IPR record, which is the authoritative citation set for '188. I did not substitute similar numbers.
Critical framing before the per-reference table. The request asks which claim(s) each reference "potentially anticipates under § 102." Two points must be stated up front:
- Anticipation is single-reference. A § 102 reference must disclose every limitation of a claim, arranged as claimed. The '188 patentissued over all 11 of its cited references — none of them was applied as a § 102 rejection that carried through to allowance.
- The one post-issuance challenge (IPR2025-00519) asserted only § 103. All six grounds in LG's petition are pre-AIA 35 U.S.C. § 103 obviousness combinations — no § 102 ground was pleaded. That is strong contextual evidence that no single reference in the art of record discloses the full claim 1/4/7 combination. The '188's point of novelty is the "change permission information" + "change prohibiting device" pair, and the patent's own Background Art discussion states the closest prior art (JP2000353375A) has "no device indicating the prohibition of resetting."
So the honest answer is: the cited references are relevant to the thumbnail image / representative-image environment but, individually, do not appear to anticipate claims 1–9. Below I map each reference to the claim element it is most relevant to and state where anticipation fails.
1. The 11 references on the face of US 7,421,188
| # | Citation | Filing / Priority date | Pub. date | Assignee / inventor |
|---|---|---|---|---|
| 1 | JPH0993527A — "映像インデックス作成装置" (Video indexing device) | filed 1995-09-21 | 1997-04-04 | NTT; Hongo et al. |
| 2 | US6738092B1 — Camera apparatus and method for associating digital picture files with thumbnail images | US filed 1998-06-04 (Appl. 09/090,288); JP priority 1997-06-09 (P9-151303) | granted 2004-05-18 | Sony; Nakagawa & Ueno |
| 3 | JPH11284948A — Thumbnail creation method and thumbnail display method | filed 1998-03-30 | 1999-10-15 | Matsushita Electric Industrial |
| 4 | KR19990081730A — Recording medium and recording/reproducing method and apparatus for storing thumbnail data and management information therefor in real time | filed 1998-04-27 | 1999-11-15 | Yoon Jong-yong |
| 5 | KR20000000568A — Optical disk storing editing and copy-control information … | filed 1998-06-01 | 2000-01-15 | Yoon Jong-yong |
| 6 | US6408301B1 — Interactive image storage, indexing and retrieval system | filed 1999-02-23 (Appl. 09/256,652) | granted 2002-06-18 | Eastman Kodak; Patton, Ashe, Manico |
| 7 | JP2000353375A — Information editing device and information reproducing device | JP priority 1999-06-11 (JP 11165420) | 2000-12-19 | Pioneer Electronic |
| 8 | JP2001169231A — Image editing apparatus, image editing method, and recording medium | filed 1999-12-08 | 2001-06-22 | Casio Computer; Miyasaka et al. |
| 9 | JP2002033986A — Image recording/reproducing apparatus, method, and recording medium | filed 2000-07-14 | 2002-01-31 | Sony; Murakami et al. |
| 10 | JP2002352566A — Recording and reproducing device | filed 2001-05-24 | 2002-12-06 | Kenwood |
| 11 | US20070154013A1 — Video information recording apparatus and method … | priority/filed 2001-10-09 | 2007-07-05 | Sony |
Per-reference analysis
1. JPH0993527A (NTT / Hongo) — Video indexing device
Prior art date 1995-09-21; published 1997-04-04. Discloses automatically generating an index of representative frames from video. It supplies the concept of a representative/thumbnail image of recorded video. It discloses no change-permission field and no prohibition logic.
→ Potentially relevant to: claim 1 element [1.1] (thumbnail showing contents of recorded information) only. No anticipation of any claim — fails the "change permission information" and "change prohibiting device" limitations; no method or program-medium counterpart.
2. US6738092B1 (Sony / Nakagawa & Ueno) — Camera apparatus associating digital picture files with thumbnail images
US filed 1998-06-04; JP priority 1997-06-09; granted 2004-05-18. A digital camera records main-picture files and separate thumbnail ("index") files on a disc/floppy medium, associates them by similar filename/identification codes, and builds a table mapping main files to index-file locations. It is a § 102(e) reference (earlier US filing date), not § 102(a)/(b) as a printed publication (its grant post-dates the '188 priority).
→ Potentially relevant to: claim 1 [1.1] (thumbnail image showing contents of recorded information; a recording medium). No anticipation — it lacks any change-permission information or change-prohibiting device; it is about creating/linking thumbnails, not protecting them from change.
3. JPH11284948A (Matsushita) — Thumbnail creation method and thumbnail display method
Filed 1998-03-30; published 1999-10-15. Creates multiple thumbnails per moving-image (multiple frames, or one frame at different sizes) and displays them frame-by-frame for selection. It addresses thumbnail generation/display for navigation.
→ Potentially relevant to: claim 1 [1.1]. No anticipation — silent on permissions/prohibition; no deciding or prohibiting device.
4. KR19990081730A (Yoon Jong-yong) — Recording medium storing thumbnail data and management information in real time
Filed 1998-04-27; published 1999-11-15. Stores thumbnail data together with management information on a recording medium in real time. Relevant because the '188's permission bit (REL) lives inside representative-image management structures — i.e., "management information" for a thumbnail.
→ Potentially relevant to: claim 1 [1.1] (management information associated with a thumbnail). No anticipation — the reference is about storage/management of thumbnail data, not a permission-to-change flag or a prohibit-change behavior.
5. KR20000000568A (Yoon Jong-yong) — Optical disk storing editing and copy-control information
Filed 1998-06-01; published 2000-01-15. Records editing and copy-control information on the optical disk, with a recording-control device and edit/copy methods. This is the most conceptually proximate cited reference to the "change permission information" idea, because it places control information governing editing on the medium.
→ Potentially relevant to: claim 1 [1.1]/[1.2] — as evidence that control information constraining editing operations was known. No anticipation — its control information concerns editing/copying of content generally, not permission to change a thumbnail image; there is no thumbnail-change-permission indicator and no thumbnail-change-prohibition device. Relevant as analogous art for a § 103 argument, not for § 102.
6. US6408301B1 (Eastman Kodak / Patton, Ashe, Manico) — Interactive image storage, indexing and retrieval system
Filed 1999-02-23; granted 2002-06-18. Each image file has an information file with user-entered metadata; the user designates a metadata element as an "image link"; an interactive database stores the images plus information files; an index communicates image links for retrieval. Qualifies as a printed publication/grant before the '188 priority (§ 102(a)/(b)), and also has an earlier US filing date.
→ Potentially relevant to: claim 1 [1.1] (a thumbnail/representative image and associated indexing/management information on a medium). No anticipation — no change-permission information, no prohibition of changing a representative image; it concerns retrieval, not protection.
7. JP2000353375A (Pioneer) — Information editing device and information reproducing device (the '188 patent's own Background Art, JP 2000-353375; US counterpart US6813434)
Priority JP 1999-06-11; published 2000-12-19. Selects a partial record (one or more images) from recorded information, designates a reproduction timing, extracts the picture as a representative picture, and records the reproduction timing + the representative picture (or its location) as reproduction-control information (a play list) separately from the record information. This is the single closest reference to the '188's purpose (editing a reproduced form; using a representative/thumbnail image).
→ Potentially relevant to: claim 1 [1.3] ("editing is performed on a reproduced form of the recorded information") and [1.1] (representative image = thumbnail). No anticipation — and note the specification expressly distinguishes it: the '188 Background Art states that in the conventional apparatus "it is possible to reset the thumbnail image, whereas there is no device indicating the prohibition of resetting." That admission is fatal to a § 102 case built on JP2000353375A: it lacks [1.1]'s change-permission information and [1.2]'s change-prohibiting device.
8. JP2001169231A (Casio / Miyasaka) — Image editing apparatus, image editing method, and recording medium ("Miyasaka" in IPR2025-00519)
Filed 1999-12-08; published 2001-06-22. LG's petition makes Miyasaka its lead reference in Grounds 3 and 4, pairing it with Murakami (Ground 3) or Tezuka (Ground 4) to reach claims 1–9. That placement indicates LG viewed Miyasaka as disclosing the thumbnail-image editing/seeking architecture and at least part of the "deciding whether a thumbnail can be changed" concept, with the secondary reference supplying the permission/prohibition teaching.
→ Potentially relevant to: claims 1, 4, 7 — but, per LG's own framing, only as part of a § 103 combination, not as standalone § 102 anticipation. The petition asserts no § 102 ground against any claim.
9. JP2002033986A (Sony / Murakami) — Image recording/reproducing apparatus, method, and recording medium ("Murakami" in IPR2025-00519)
Filed 2000-07-14; published 2002-01-31. Used by LG as the secondary reference in Grounds 2B (Dow+Murakami) and 3 (Miyasaka+Murakami) to supply, per the petition, the missing thumbnail-management/permission elements.
→ Potentially relevant to: claims 1, 4, 7 in combination. No standalone § 102 anticipation.
10. JP2002352566A (Kenwood) — Recording and reproducing device
Filed 2001-05-24; published 2002-12-06 — published after the '188 priority date (2002-03-05), so it is prior art only if an earlier-JP-filing date brings it within the applicable grace/filing window (a JP publication date of 2002-12-06 post-dates the priority date; treat this citation with caution). It concerns a recording/reproducing device and thumbnail handling.
→ Potentially relevant to: claim 1 [1.1] (recording/reproducing of representative images). No § 102 anticipation — no permission/prohibition teaching found.
11. US20070154013A1 (Sony) — Video information recording apparatus and method
Priority/filed 2001-10-09; published 2007-07-05. Because its US filing date precedes the '188 priority date, it could qualify as prior art under pre-AIA § 102(e) (its publication post-dates the priority date, so it is not § 102(a)/(b) art). It is a video-information recording apparatus/method.
→ Potentially relevant to: claim 1 [1.1] and, at most, the recording side of claim 7. No § 102 anticipation — no change-permission/prohibition limitations.
2. Related references on the '188 record (not in the 11, but relevant)
- US20050278258A1 (O'Donnell, 2004-06-14; pub. 2005-12-15) — "User software for facilitating copyright licensing and compliance." This is a "Cited By" reference (third-party citation), i.e., '188 is prior art to it, not the reverse. Not prior art against '188.
- US7437055B2 (Sony, priority 2000-04-21; granted 2008-10-14) — listed under "Family Cites Families." Because its priority (2000-04-21) predates the '188 priority (2002-03-05), it is a genuine earlier-filed reference and, if examined, would be a § 102(e)-type reference. Not among the 11 examiner citations, however.
- Families Citing this family (3): JP4843208B2 (Toshiba), JP4564464B2 (Toshiba), WO2018062061A1 (Panasonic). These are later references citing '188 as background — not prior art against '188.
3. The IPR2025-00519 prior-art set (LG's § 103 art) — for completeness
LG's petition applied six references in obviousness combinations (none individually as § 102):
| Reference | Citation | Filing date | Pub. date | Basis asserted |
|---|---|---|---|---|
| "Yoshida" | JP2001211421A | 2000-01-28 | 2001-08-03 | § 102(a)/(b) |
| "Terashita" | JP2000307994A | 1999-04-26 | 2000-11-02 | § 102(a)/(b) |
| "Dow" | US 6,292,273 | 1998-08-07 | 2001-09-18 | § 102(a)/(b) |
| "Murakami" | JP2002033986A | 2000-07-14 | 2002-01-31 | § 102(a)/(b) |
| "Tezuka" | JPS61101850A | 1984-10-23 | 1986-05-20 | § 102(a)/(b) |
| "Miyasaka" | JP2001169231A | 1999-12-08 | 2001-06-22 | § 102(a)/(b) |
LG separately listed (exhibits LG-1011 to LG-1018) further art it analyzed but did not ultimately make the basis of a ground: Shioji (JPH11275512A), Miyamoto (JPH0983925A), Hongo (JPH0993527A — the NTT reference, i.e., citation #1 above), Fujimura (US2002/0067923 A1), Yamasaki (US2003/0011683 A1), Flamini (WO01/57683 A1), Masahiro (JPH08205014A), and Nobuhide (JPH114405A). Source: IPR2025-00519 Petition and Updated Exhibit List (https://ai-lab.exparte.com/case/ptab/IPR2025-00519/doc/6).
Grounds asserted: (1) Yoshida + Terashita; (2A) Dow; (2B) Dow + Murakami; (2C) Dow + Tezuka; (3) Miyasaka + Murakami; (4) Miyasaka + Tezuka — each against claims 1–9, all under pre-AIA § 103. The proceeding terminated on settlement (37 C.F.R. § 42.74) before an institution decision on the merits, so no § 102 or § 103 holding exists.
4. Bottom line
- No reference on the face of US 7,421,188 appears to anticipate any of claims 1–9 under § 102. Each cited reference is relevant to the thumbnail/representative-image environment (generation, storage, association, display, or indexing) but none discloses, in a single reference, the claim-1/4/7 combination of (a) a deciding device that tests change permission information for a thumbnail image, plus (b) a change-prohibiting device that blocks the change when permission is absent.
- The closest cited art to the claim-1 preamble/purpose is JP2000353375A (Pioneer) — but the '188 specification itself admits that reference lacks any reset-prohibition mechanism, which defeats a § 102 case against it.
- The most §-102-plausible single references, if any, are the Casio/Miyasaka (JP2001169231A) and Pioneer (JP2000353375A) documents — but both were treated by the only challenger (LG) as § 103 combination material, and LG pleaded no § 102 ground at all.
- Several citations are procedurally odd as § 102(a)/(b) art: US6738092B1 (granted 2004, i.e., only § 102(e)-type), US20070154013A1 (published 2007, only § 102(e)-type), and JP2002352566A (published 2002-12-06, after the '188 priority date — § 102 applicability depends on an earlier-JP-filing argument). I flag these because "cited" ≠ "§ 102 prior art."
Uncertainty flags
- Reference-internal content of the JP references (#7–#10) and the KR references (#4–#5): I could confirm titles, dates, assignees, and abstract-level content, but I could not, within this search budget, retrieve and read each full text to confirm the absence of a change-permission/prohibition teaching. My § 102 conclusions for those are based on the abstract-level disclosure plus the fact that neither the examiner nor LG asserted a § 102 rejection over them.
- LG's specific mapping of each claim element to Miyasaka/Murakami/Tezuka/Dow/Yoshida/Terashita exists in the petition's element-by-element analysis, which I located but did not fully transcribe; the grounds table and exhibit list above are quoted from the petition.
- Dates are reported as they appear on the patent/IPO records; where filing and priority differ I gave both. No identifier was auto-corrected.
Sources: https://patents.google.com/patent/US7421188/en ; https://patents.google.com/patent/[US6738092](/patent/US6738092) ; https://patents.google.com/patent/[US6408301](/patent/US6408301) ; https://patents.google.com/patent/JPH11284948A/en ; https://patents.google.com/patent/EP1059640A3 (Pioneer JP2000353375A / US6813434 abstract) ; https://ptacts.uspto.gov/ptacts/public-informations/petitions/1557333/download-documents (IPR2025-00519 Petition) ; https://ai-lab.exparte.com/case/ptab/IPR2025-00519/doc/6 (Updated Exhibit List / Joint Motion to Terminate).
Generated 9/28/2026, 6:12:36 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground this analysis in the actual prior-art references before drawing obviousness conclusions. Let me verify what several of the key references disclose.
Let me verify a few more of the key references, particularly the ones most relevant to the "change permission information" limitation.
Obviousness Analysis — US 7,421,188 B2 under 35 U.S.C. § 103
Important preliminary notes on scope and on what I could verify
- This analysis is built on the Prior Art section of the Google Patents page (the "Citations (11)" list, the family-cited references, and the IPR2025‑00519 exhibit list carried over from the prior section of this report). Where I was able to independently pull the reference text, I say so and quote it. Where I could not (the search budget was exhausted on several of the IPR exhibits), I flag that I am relying on the title/assignee on the face of the page rather than on a verified disclosure.
- I reproduce identifiers literally and do not auto-correct them. In particular, JPH0993527A is attributed on the Google page to Nippon Telegraph & Telephone ("Video indexing device") but is attributed in the IPR exhibit list to "Hongo." I flag that attribution discrepancy; I did not resolve it.
- EP1482509B1 appears in the page's "Similar Documents" list with the title "Thumbnail replacement indicated by a flag in the management table of an Audio Video file." Its title reads like this invention's own subject matter, and the '188 family's EP member is EP1482508B1 ("Also Published As"). If EP1482509 shares the 2002‑03‑05 priority, it is a family member and therefore NOT available as prior art. I could not verify its priority date from the provided text; counsel should confirm before anyone relies on it.
A. Framework
Effective filing date: 2003‑03‑04 (PCT/JP2003/002509), with priority to JP 2002‑107158 (2002‑03‑05). The application was filed before the AIA first‑to‑file transition, so pre‑AIA § 103 governs.
Level of ordinary skill (proposed): a bachelor's degree in EE/CS or equivalent, plus ~2–4 years in consumer AV recording/playback devices and their file/management‑information formats (e.g., MPEG‑2 transport streams, DVD/HDD navigation data). This is the level at which the combinations below should be assessed.
The claims, distilled. Claim 1 is an information editing apparatus comprising (i) a deciding device that decides whether a thumbnail image (the image representing recorded content) can be changed, based on change permission information; and (ii) a change prohibiting device that blocks the change when the decision is "not permitted." Claims 2 and 3 add (2) a warning‑generating circuit and (3) a changing device operative when change is permitted. Claims 4–6 are the method counterparts; claims 7–9 are the computer‑readable‑medium/program counterparts. The specification implements "change permission information" as the field REL in the attribute information (DTT/PTT/ITT) of the representative‑image structures.
A threshold construction point matters for § 103: the claims recite a "thumbnail image" generically. They do not require the image to be vendor‑supplied, do not require a "program list," and do not require any particular storage location for the permission field. That breadth makes the prior‑art mapping easier, not harder.
B. The prior art of record (as listed on the page)
| Ref | Date (pub / prio) | What the face of the record says it is |
|---|---|---|
| JP2000353375A (Pioneer) | 2000‑12‑19 / 1999‑06‑11 | "Information editing device and information reproducing device." Also cited in the '188 specification itself as the background art. |
| KR20000000568A / KR100313854B1 (Samsung; 정태윤) | 2000‑01‑15; granted 2001‑12‑12 / filed 1998‑06‑01 | "Optical disc on which the editing and duplication control information is recorded…" |
| US6408301B1 (Eastman Kodak) | 2002‑06‑18 / 1999‑02‑23 | "Interactive image storage, indexing and retrieval system" |
| US6738092B1 (Sony) | 2004‑05‑18 / 1997‑06‑09 | "Camera apparatus and method for associating digital picture files with thumbnail images" |
| JP2001169231A (Casio) | 2001‑06‑22 / 1999‑12‑08 | "Image editing apparatus, image editing method…" |
| JPH11284948A (Matsushita) | 1999‑10‑15 / 1998‑03‑30 | "Thumbnail creation method and thumbnail display method" |
| KR19990081730A (Samsung) | 1999‑11‑15 / 1998‑04‑27 | "Recording medium… storing thumbnail data and management information therefor in real time" |
| JP2002033986A (Sony) | 2002‑01‑31 / 2000‑07‑14 | "Image recording/reproducing apparatus…" (also an IPR exhibit, attributed to "Murakami") |
| JP2002352566A (Kenwood) | 2002‑12‑06 / 2001‑05‑24 | "Recording and reproducing device" |
| US2007/0154013A1 (Sony) | 2007‑07‑05 / filed 2001‑10‑09 | Video information recording/reproducing (pre‑AIA § 102(e) art) |
| JPH0993527A (NTT / "Hongo") | 1997‑04‑04 / 1995‑09‑21 | "Video indexing device" |
| IPR exhibits (LG, IPR2025‑00519) | — | JP2001211421A (Yoshida); JP2000307994A (Terashita); US 6,292,273 (Dow); JPS61101850A (Tezuka); JPH11275512A (Shioji); JPH0983925A (Miyamoto); US2002/0067923A1 (Fujimura); US2003/0011683A1 (Yamasaki); WO01/57683A1 (Flamini); plus JP2001169231A and JP2002033986A already listed |
Verified disclosures I can quote:
- JP2000353375A (Pioneer) — the closest "editing" reference and the admitted background art. Its abstract: "An information editing apparatus for editing a reproduction manner of record information… includes: a selecting unit for selecting a partial record information…; a designating unit for designating a reproduction timing…; an extracting unit for extracting the picture information included in the partial record information as a representative picture information…; and a recording unit for recording… the designated reproduction timing… as a reproduction control information separately from the record information." (Equivalent US 6,813,434 B1.) This discloses generating a representative image for recorded content and editing the reproduction form — i.e., the "information editing apparatus" and "thumbnail" environment. It does not, on its face, disclose a permission flag that prohibits changing the representative image.
- US6408301B1 (Kodak) — discloses thumbnail/Picon indexing and, importantly, thumbnail editing: "provision is made in the player/recorder system 36, and/or in the camera 10 to edit the selection of index images 23, 34. In this mode, index images 23, 34 could be deleted from the index file and additional ones added…" It also states "A new master or sub directory picture thumbnail image–Picon can be generated or an existing thumbnail can be substituted by another image at any time." This corroborates the "changing device" of claim 3 and the general thumbnail-editing context.
- KR20000000568A / KR100313854B1 (Samsung) — the single most probative reference for the "change permission information" limitation. Per the record: the disc "comprises an editing control flag including an edit permitting mode for editing the tile [title] information, the program information, and the cell information, and an edit prohibition mode for prohibiting the edit. In addition the disk comprises a copy control information updating the number being capable of copy the edited audio and video titles according to the edit permitting mode." (https://www.zhangqiaokeyan.com/patent-detail/06130446119010.html). This is a stored flag whose value determines whether an edit is permitted or prohibited — functionally the same construct the '188 claims call "change permission information."
C. Element‑by‑element mapping — independent claim 1
| Claim 1 element | Where taught |
|---|---|
| Information editing apparatus; editing a reproduced form of recorded information including at least image information on a recording medium | JP2000353375A (Pioneer) — play list/representative‑image editing on a storage medium; and US6408301 (Kodak) |
| "thumbnail image showing contents of recorded information" | JP2000353375A (representative picture); US6408301 (Picon index image); JPH11284948A ("thumbnail creation"); KR19990081730A (thumbnail data) |
| "deciding device … based on change permission information indicating whether the thumbnail image is changeable" | KR100313854B1 / KR20000000568A — "edit permitting mode … and an edit prohibition mode for prohibiting the edit" stored on the disc, checked by the recording control apparatus |
| "change prohibiting device for prohibiting a change … when … not permitted" | KR100313854B1 — the "edit prohibition mode" enforces precisely this; inherently requires the editing apparatus to refrain from editing when the flag forbids it |
The only substantive gap left by the individual references, taken one at a time, is that KR100313854 frames the edit‑permission flag over title/program/cell information rather than over the thumbnail/representative image itself. That gap is bridged by combining KR100313854 with any of the thumbnail/representative‑image references, as set out below.
D. Proposed § 103 combinations
Combination 1 (primary theory) — Pioneer + Samsung + Kodak
JP2000353375A (representative‑image editing environment) in view of KR100313854B1 / KR20000000568A (edit‑permission/prohibition flag stored on the medium), optionally in view of US6408301B1 (thumbnail/Picon editing).
Why the combination is proper. These references are all in the same field (edit/management of recorded AV on a rewritable medium), address the same problem (controlling what may be edited), and their combination requires only that the known edit‑permission flag be applied to the representative image that JP2000353375 already generates and lets the user change. Under KSR v. Teleflex, applying a known edit‑control technique to another editable data object in the same management file is a predictable use of a known technique over the object it was already used to control, and is "obvious to try" given a known need.
Motivation, articulated as the art would have seen it (as of March 2002):
- Content‑provider control. The '188 specification itself identifies the problem: a thumbnail/representative image "set by the user and a contents holder may be accidentally changed by a misoperation." Vendors of distributed content (JP2000353375's own environment) had an express interest in protecting a representative image from user modification.
- The mechanism already existed. KR100313854 teaches storing an "edit permitting mode … and an edit prohibition mode for prohibiting the edit" on the medium and having the recording control apparatus honor it. One of ordinary skill would recognize this as a ready tool for protecting any management‑file object, including a representative image.
- Common file structure. Both references put the relevant items in management/navigation information alongside program and cell information (compare the '188 FIG. 2/FIG. 5 attribute structures). Adding one permission bit to the representative‑image attribute block is a design choice within an existing data structure, not a new architecture.
Combination 2 — Pioneer + Casio and/or Matsushita + Samsung
JP2001169231A (Casio, image editing) and/or JPH11284948A (Matsushita, thumbnail creation/display) supply the thumbnail‑editing/display context; KR100313854B1 supplies the permission/prohibition flag. Same motivation as above. This combination is stronger for dependent claim 2, because an "image editing apparatus" with user‑facing screens (Casio) naturally includes the notices/warnings that attend prohibited operations.
Combination 3 — Kodak (+ Sony US6738092) + Samsung
US6408301B1 (Kodak) discloses generating, displaying and editing/substituting index "Picon" images and even adding/deleting them from the index file; US6738092B1 (Sony) discloses associating picture files with thumbnail images. Adding a permission flag that gates the Kodak "edit the selection of index images" feature (per KR100313854) yields claim 1. Kodak's own text ("A new master or sub directory picture thumbnail image–Picon can be generated or an existing thumbnail can be substituted by another image at any time") plus KR100313854's prohibition mode covers both branches of the claim (permitted → change; not permitted → block).
Combination 4 (IPR‑style) — the LG IPR2025‑00519 line
LG's petition coupled a thumbnail/representative‑image reference (e.g., JP2002033986A (Sony/"Murakami"), JPH0993527A (video indexing device), JP2001169231A (Casio/"Miyasaka")) with a control‑information reference (US 6,292,273 (Dow), JPH11275512A (Shioji), WO01/57683A1 (Flamini)) and secondary references (US2002/0067923A1 (Fujimura), US2003/0011683A1 (Yamasaki)). Caveat: I could not independently retrieve the disclosures of US 6,292,273, JP2001211421A, JP2000307994A, JPS61101850A, JPH11275512A, JPH0983925A, US2002/0067923A1, US2003/0011683A1, or WO01/57683A1 — my searches on those identifiers did not return substantive text before the tool limit was reached. I therefore describe this combination only at the level of the reference architecture (thumbnail art + control‑flag art), not as a verified ground. Anyone relying on it should pull the LG petition itself.
E. Dependent claims
- Claim 2 / claim 5 / claim 8 — warning that the thumbnail cannot be changed. A warning displayed when an operation is prohibited is a conventional, well‑understood UI convention, and the '188 specification implements it with an ordinary OSD and an adder. A designer implementing KR100313854's "edit prohibition mode" in a consumer device with an on‑screen UI (as in the Casio JP2001169231 or Kenwood JP2002352566 environments) would predictably surface a "cannot change / not permitted" notice. This is arguably the weakest set of claims from a § 103 standpoint — the added subject matter is a predictable presentation of an error state already implied by the prohibition decision.
- Claim 3 / claim 6 / claim 9 — changing the thumbnail when permitted. Directly taught by US6408301 (substitute/add/delete index images) and obvious from JP2000353375 (extract and record a representative picture). Claim 6 also carries a drafting irregularity — "when the deciding device decides, instead of the change prohibiting device, that a change is permitted" — noted in the earlier section; it does not change the substance.
- Claim 7 — CRM/program. Under In re Beauregard/§ 103, a computer‑readable medium encoded with program instructions is obvious if the underlying functions are obvious; no separate hardware novelty appears. Claim 7's preamble/element phrasing is malformed in the printed patent (noted previously and reproduced literally).
F. Consolidated motivation to combine (the § 103 "articulated reasoning")
- Same field, same problem, same data structures. All principal references concern editing management information for recorded AV/image content on a rewritable medium. Combination requires no change in the field of endeavor.
- Known technique applied to a known object. "Edit‑control/-permission flags" (KR100313854; also the broader CGMS/SCMS‑type copy‑control teaching of record) were known; applying such a flag to the representative image that JP2000353375/US6408301 already generate and edit is a predictable use.
- Reasonable expectation of success. Storing one additional attribute (the '188 "REL" bit) in an existing attribute block (the '188 DTT/PTT/ITT) is a trivial data‑structure change with no compatibility risk of the kind the art already managed.
- Design incentive / market pressure. Vendors distributing content with branded representative images had a recognized need to stop users from overwriting them — the very problem the '188 specification recites as motivating the invention.
G. Counter‑arguments a patent owner would press (and how they fare)
- "The prior‑art flag protects content/title information, not the thumbnail image." This is the strongest non‑obviousness argument: the references protect program/cell/title data or copy rights, whereas the claims recite a flag that protects the representative image as such. The '188 specification's vendor‑defined vs. user‑defined thumbnail distinction reinforces that the flag protects a presentation object. Whether this rises to patentability depends on how broadly "thumbnail image" is construed — the claims themselves contain no vendor/user distinction and no requirement that the protected object be a "presentation‑only" image, which cuts against the owner.
- "There is a teaching away." I did not find, in the text I verified, a reference that disparages protecting a thumbnail or that requires the thumbnail always to be freely user‑replaceable despite video‑editing metadata — though a patent owner will likely argue it from the cited art. I flag this as the single issue most worth a full‑text, claim‑chart review of JP2000353375, JP2001169231, US6408301 and US6738092.
- Secondary considerations. I found no evidence of record (unexpected results, commercial success nexus, licensing‑due‑to‑merit, copying) tying the specific "permission bit on the thumbnail" to commercial success; the litigation/PTAB posture was resolved by settlement in both fora, so there is no adjudicated § 103 or § 101 ruling to cite either way. The earlier section's § 101 challenge (LG's motion, apparently never decided) is a separate vulnerability and does not cure § 103.
- Specification inconsistency as an aid to the challenger. As noted previously, the FIG. 8 narrative of the '188 patent contains internally contradictory statements about whether "0" prohibits or permits a change. A § 103 case is not defeated by drafting inconsistency, but a construction fight over the meaning of the permission value is likely.
H. Bottom line
- On the record listed on the page, claim 1 (and claims 4 and 7) is more likely than not obvious via JP2000353375A + US6408301B1 (thumbnail/representative‑image editing) in view of KR100313854B1 / KR20000000568A (stored edit‑permission/prohibition flag), with a strong secondary theory built from JP2001169231A, JPH11284948A, US6738092B1 and the IPR2025‑00519 exhibit set. The claimed advance reduces, at the margin, to the predictable relocation of a known edit‑control flag onto the thumbnail/representative image — which KSR treats as obvious.
- The best patent‑owner defense is a narrow reading in which the protected object must be the representation/HMI image (and, per the specification, the vendor‑defined image), which the claims as written do not clearly require.
- The dependent claims (2, 5, 8 — warnings) are the most vulnerable; the "changing device" claims (3, 6, 9) are essentially met by the thumbnail‑editing references directly.
I. Explicit uncertainty / verification flags
- Unverified IPR exhibits. I could not retrieve substantive disclosures for US 6,292,273 (Dow), JP2001211421A (Yoshida), JP2000307994A (Terashita), JPS61101850A (Tezuka), JPH11275512A (Shioji), JPH0983925A (Miyamoto), US2002/0067923A1 (Fujimura), US2003/0011683A1 (Yamasaki), and WO01/57683A1 (Flamini). My "Combination 4" is a structural description, not a verified ground. Treat the LG petition (IPR2025‑00519) as the primary source.
- JPH0993527A attribution conflict. Google Patents attributes it to Nippon Telegraph & Telephone ("Video indexing device"); the IPR exhibit list attributes it to Hongo. Unresolved; reported literally.
- EP1482509B1 ("Thumbnail replacement indicated by a flag…") is likely a family member of the '188 family (same date range and subject matter) and thus likely not prior art. Confirm priority before use.
- I did not read the full texts of the JP references (they were retrieved as title/abstract-level records); the element mapping is accordingly at the abstract/claim‑summary level. A full‑text review of JP2000353375A, JP2001169231A and JP2002033986A — and of US6408301B1 and US6738092B1 — is required before filing any § 103 ground.
- No legal conclusion. This is a technical analyst's obviousness assessment; it is not legal advice and not a validity opinion.
Sources: Google Patents, US 7,421,188 (https://patents.google.com/patent/US7421188/en); US6408301B1 (https://patents.google.com/patent/US6408301B1/en; https://uspto.report/patent/grant/[6408301](/patent/6408301)); US 6,813,434 B1 / JP2000353375A Pioneer abstract (https://patentimages.storage.googleapis.com/e7/c9/9b/63863fcace0e1f/US6813434.pdf); KR100313854B1 / KR20000000568A Samsung edit‑and‑copy‑control record (https://www.zhangqiaokeyan.com/patent-detail/06130446119010.html); PTAB IPR2025‑00519 exhibit/termination record (https://ai-lab.exparte.com/case/ptab/IPR2025-00519/doc/6); N.D. Cal. 5:24‑cv‑04972 Dkt. #108 (https://www.courtlistener.com/docket/69032831/108/maxell-ltd-v-lg-electronics-inc/).
Generated 9/28/2026, 6:12:54 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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