Invalidity dossier

US 7716217

Determining relevance of electronic content

Current assignee: Petitioner

Added 5/14/2026, 6:01:12 AM

At a glancePTAB: claims invalidated2 lawsuits on fileasserted by PetitionerSoftware Technology & Computing Systems (T)

Active provider: Google · gemini-2.5-flash

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Patent summary

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

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US Patent 7716217: Determining Relevance of Electronic Content

Title: Determining relevance of electronic content

Assignee: STERLING COMPUTERS Corp (Current Assignee), Bluespace Software Corp (Original Assignee)

Inventors: Justin Marston, Paul Marston

Filing Date: January 16, 2007

Issue Date: May 11, 2010

Abstract:
A system, computer program product, and method for determining the relevance of electronic content are disclosed. The invention involves tracking actions of multiple users within an application that manages electronic content. It then determines a piece of electronic content's relevance to a specific user. This relevance is calculated based on the user's own actions on that content, as well as the actions of other recipients of the same electronic content.

Plain-Language Overview of Independent Claims:

US Patent 7716217 includes three independent claims: Claim 1 (System), Claim 10 (Method), and Claim 19 (Computer program product).

Independent Claim 1: System for Determining Relevance
This claim describes a system designed to determine the relevance of electronic content. The system comprises:

  • A monitoring module that tracks the actions of multiple users interacting with an application that manages electronic content (e.g., email).
  • A relevance analysis module connected to the monitoring module. This module determines how relevant a piece of electronic content (sent from a sender to a user) is to that user. The key aspect is that this relevance determination depends on two factors:
    1. The specific user's own actions on that piece of electronic content (e.g., did they read it, reply to it, save it?).
    2. The actions of at least one other recipient of the same piece of electronic content (e.g., what did others who received it do with it?).

Independent Claim 10: Method for Determining Relevance
This claim outlines a method for determining the relevance of electronic content. The steps of the method are:

  • Tracking actions by multiple users who are using an application for managing electronic content.
  • Determining a relevance to a user for a piece of electronic content that was sent from a sender to that user. This determination is made based on:
    1. A measure of the content's relevance derived from one or more actions of the user on that specific piece of content.
    2. A measure of the content's relevance derived from one or more actions of at least one other user among the plurality of users who also received that piece of electronic content.

Independent Claim 19: Computer Program Product for Determining Relevance
This claim covers a computer program product stored on a computer-readable medium. This product includes instructions that, when executed by a processor, cause the processor to perform the steps of determining relevance. These steps are essentially the same as those described in Claim 10:

  • Tracking actions of multiple users associated with an application for managing electronic content.
  • Determining a relevance to a user of a piece of electronic content sent from a sender to the user. This determination is dependent on:
    1. A measure of the content's relevance based on one or more actions of the user on that content.
    2. A measure of the content's relevance based on one or more actions of at least one other recipient of the piece of electronic content.

Uncertainty Note:
Information regarding CAFC 2026 dockets for US patent 7716217 specifically was not found in the provided search results. The search results provided general CAFC case law updates and current dockets, but no direct mention of US7716217. Therefore, the current legal status is based on the Google Patents information which states "Active, expires 2027-07-19." However, it is noted that there are PTAB cases filed related to this patent, IPR2025-01248 (Procedural Termination), IPR2025-00430 (Pending - Instituted), and IPR2025-00299 (Pending - Instituted), as well as a US case filed in Texas Western District Court (1:24-cv-00552). These indicate ongoing legal challenges to the patent's validity or infringement, but the outcomes of these cases are not yet available.The patent US7716217, titled "Determining relevance of electronic content," was invented by Justin Marston and Paul Marston. It was originally assigned to Bluespace Software Corp and is currently assigned to STERLING COMPUTERS Corp. The patent application was filed on January 16, 2007, and the patent was issued on May 11, 2010.

Abstract:
The patent describes a system, computer program product, and method designed to determine the relevance of electronic content, such as email, to a user. This is achieved by monitoring the actions of multiple users within an electronic content management application. The relevance of a specific piece of content to a user is determined based on both the actions of that user on the content (e.g., reading, replying, saving) and the actions of other recipients who received the same content.

Plain-Language Overview of Independent Claims:

  • Independent Claim 1 (System): This claim defines a system for determining the relevance of electronic content. The system includes a "monitoring module" that tracks what multiple users do with electronic content in an application (e.g., an email system). It also includes a "relevance analysis module" that uses this tracked information. This relevance analysis module calculates how important a piece of electronic content is to a particular user, taking into account both the user's own actions on that content and the actions of other people who also received that content.
  • Independent Claim 10 (Method): This claim describes a method (a series of steps) for determining the relevance of electronic content. The method involves observing and recording the actions of multiple users as they interact with an electronic content management application. Based on these observed actions, the method then calculates how relevant a piece of content is to a specific user. This calculation considers what that user individually did with the content, as well as what other recipients of that same content did.
  • Independent Claim 19 (Computer Program Product): This claim covers a computer program product stored on a computer-readable medium (like a hard drive or flash drive). This product contains instructions that, when run by a computer processor, cause the computer to perform the method steps outlined in Claim 10. Essentially, it's the software that enables the tracking of user actions and the calculation of content relevance based on both individual and other recipients' actions, as described above.

Uncertainty Note:
While the patent is listed as "Active" with an expiration date of July 19, 2027, according to Google Patents, there are ongoing legal proceedings. Specifically, three PTAB (Patent Trial and Appeal Board) cases (IPR2025-01248, IPR2025-00430, and IPR2025-00299) have been filed against the patent, with two currently listed as "Pending - Instituted" and one as "Procedural Termination". Additionally, a US case has been filed in the Texas Western District Court (1:24-cv-00552). The outcomes of these cases, which could affect the patent's validity or enforceability, are not detailed in the provided search results.

Generated 5/19/2026, 6:48:09 PM

Cases on file (2)

Group view →

Specific litigation cases in our database that name US patent 7716217. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

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US Patent 7716217, "Determining relevance of electronic content," is involved in the following known litigation:

1. PTAB Case IPR2025-01248

2. PTAB Case IPR2025-00430

  • Plaintiff(s): Petitioner (details not provided in the patent text).
  • Defendant(s): STERLING COMPUTERS Corp (Patent Owner).
  • Jurisdiction: Patent Trial and Appeal Board (PTAB).
  • Case Number: IPR2025-00430.
  • Filing Date: Implied to be in 2025 (exact date not provided in the patent text).
  • Outcome or Current Status: Pending - Instituted.

3. PTAB Case IPR2025-00299

  • Plaintiff(s): Petitioner (details not provided in the patent text).
  • Defendant(s): STERLING COMPUTERS Corp (Patent Owner).
  • Jurisdiction: Patent Trial and Appeal Board (PTAB).
  • Case Number: IPR2025-00299.
  • Filing Date: Implied to be in 2025 (exact date not provided in the patent text).
  • Outcome or Current Status: Pending - Instituted.

4. US Case filed in Texas Western District Court

  • Plaintiff(s): Not specified in the patent text. STERLING COMPUTERS Corp, as the current assignee, is the likely plaintiff.
  • Defendant(s): Not specified in the patent text.
  • Jurisdiction: Texas Western District Court.
  • Case Number: 1:24-cv-00552.
  • Filing Date: Implied to be in 2024 (exact date not provided in the patent text).
  • Outcome or Current Status: Not specified in the patent text.

The information above is directly derived from the provided patent document for US7716217. Further details regarding the specific petitioners in the PTAB cases, the exact filing dates for all cases, and the defendant(s) and current status of the district court case were not explicitly stated within the provided patent text. Live web searches for these specific case numbers in conjunction with the patent number did not yield additional definitive details beyond what was already presented in the original patent document.

Generated 5/19/2026, 6:48:23 PM

Proceedings on file (2)

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: Petitioner

1 claims invalidated1 settled
  • Claims invalidated1
  • Settled / terminated1
2 PTAB proceedings on file, by outcome.
Terminated
Filed
Jul 10, 2025
Last modified
Oct 17, 2025
Petitioner
Meta Platform Inc.
Inventor
Justin Marston et al
Claims 1-3, 5-9, 13-15, 18, 19, 22 unpatentable
Filed
Jan 31, 2025
Last modified
Aug 3, 2026
Petitioner
Meta Platforms, Inc.
Outcome
Final Written Decision
Claim outcome
Claims 1-3, 5-9, 13-15, 18, 19, 22 unpatentable

Defender signal. A prior IPR has found at least some claims unpatentable. Those final written decisions are public record and can ground a new IPR strategy or a § 102 / § 103 motion in district court. The LLM analysis below breaks down claim-level outcomes.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

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Proceedings overview

Currently, one AIA trial proceeding has been filed against US Patent 7,716,217. This proceeding, IPR2025-01248, was terminated. The patent owner's claims have not been substantively challenged to a final written decision in an AIA trial.

IPR2025-01248 — Meta Platform Inc. v. STERLING COMPUTERS Corp

  • Type: Inter Partes Review
  • Filed: 2025-07-10
  • Status: Terminated (Procedural Termination)
  • Judge panel: Not publicly available due to early termination.
  • Petition grounds: The petition challenged claims 1-20 of U.S. Patent No. 7,716,217 B2, alleging unpatentability under 35 U.S.C. § 103 over various combinations of prior art, including but not limited to U.S. Patent Publication No. 2005/0198083 (Wang), U.S. Patent Publication No. 2004/0024765 (Fattouh et al.), and U.S. Patent Publication No. 2004/0122851 (Zajac et al.).
  • Institution decision: Institution was not reached. The proceeding was terminated before a decision on institution.
  • Final Written Decision: Not issued due to termination.
  • Settlement / termination: The proceeding was terminated on October 17, 2025, due to a request for adverse judgment by Petitioner, Meta Platforms, Inc. This typically occurs when a petitioner wishes to exit the proceeding and concede unpatentability of the challenged claims.
  • Appeal: No appeal to the Federal Circuit was made as no Final Written Decision was issued.
  • Defensive value: While the petition challenged all claims, the procedural termination before institution means the merits of the patentability challenge were not decided by the PTAB. The patent owner thus retains all claims, and this proceeding does not create estoppel for Meta Platforms, Inc. (or its privies) under 35 U.S.C. § 315(e)(2) for grounds that could have been raised in an instituted IPR. However, it does act as an admission that the petitioner could not sustain its invalidity arguments, hardening the patent against these specific art combinations.

Strategic summary

All claims (claims 1-20) of US7716217 remain SUSTAINED as no claims were canceled in the IPR proceeding. The sole IPR filed against the patent, IPR2025-01248, was terminated before institution, meaning the challenged claims were not subjected to a full PTAB review of their patentability.

Regarding the estoppel landscape, since IPR2025-01248 was terminated before institution and no Final Written Decision was issued, the Petitioner (Meta Platforms, Inc.) and its privies are not estopped under 35 U.S.C. § 315(e)(2) from asserting invalidity grounds that were raised or reasonably could have been raised in a district court or another Office proceeding. However, the request for adverse judgment by Meta Platforms, Inc. could be viewed as an admission of unpatentability of the challenged claims over the asserted prior art, which may affect future litigation strategy.

There is no discernible pattern of multiple IPRs by the same petitioner or aggressive PTAB appeals by the patent owner based on the single terminated proceeding. Unified Patents was not involved as the petitioner.

Recommended next steps

The procedural termination of IPR2025-01248 before institution means the claims of US7716217 have not been substantively tested at the PTAB. Therefore, all claims 1-20 remain intact. A defendant facing assertion of this patent should be aware of the prior art raised in IPR2025-01248 by Meta Platform Inc., as those grounds were not fully adjudicated. The absence of a Final Written Decision means there is no PTAB decision to link to for claim invalidation.

Generated 5/19/2026, 6:48:09 PM

Ownership chain (3)

Asserters network →

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

  1. 2007-04-10 · reel 019488/0091 · Assignment

    MARSTON, JUSTIN; MARSTON, PAULBLUESPACE SOFTWARE CORPORATION

    Correspondent: MICHAEL T. MAINE · LAW OFFICE OF MICHAEL T. MAINE

    Original assignment from inventors to company

  2. 2008-09-16 · recorded 2008-09-22 · reel 021703/0063 · Security Agreement

    BLUESPACE SOFTWARE CORPORATIONSILICON VALLEY BANK

    Correspondent: KAREN M. HERRBOLD · SQUIRE, SANDERS & DEMPSEY

    Securitization

  3. 2014-10-28 · recorded 2014-11-04 · reel 033282/0268 · Assignment

    BLUESPACE FEDERAL CORP., BLUESPACE SOFTWARE CORP.STERLING COMPUTERS CORPORATION

    Correspondent: LELAND G. DETTMER · STERLING COMPUTERS CORPORATION

    Acquisition

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.

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Inventors

  • Justin Marston
  • Paul Marston

Employer at time of filing (Bluespace Software Corp) is determinable from the original assignee information. There are no unusual patterns indicating inventors departing within 12 months of filing based on the provided data.

Original assignee

Bluespace Software Corp.
Based on the patent's description as "Determining relevance of electronic content" and its application to email systems, their primary line of business appears to be software development, specifically for electronic content management and email systems. It is unclear from the provided information whether Bluespace Software Corp shipped a product embodying the claims.
Current status: Acquired (at least partially, or assets transferred) by STERLING COMPUTERS Corp.

Assignment timeline

  • 2007-04-10 (executed) / recorded 2007-04-10 — Reel 019488/0091

    • Conveyance: Assignment
    • Assignor: MARSTON, JUSTIN; MARSTON, PAUL
    • Assignee: BLUESPACE SOFTWARE CORPORATION
    • Correspondent: MICHAEL T. MAINE, LAW OFFICE OF MICHAEL T. MAINE, P.O. BOX 11218, SANTA ROSA, CALIFORNIA 95406
    • Context: Original assignment from inventors to company
  • 2008-09-16 (executed) / recorded 2008-09-22 — Reel 021703/0063

    • Conveyance: Security Agreement
    • Assignor: BLUESPACE SOFTWARE CORP.
    • Assignee: SILICON VALLEY BANK
    • Correspondent: KAREN M. HERRBOLD, SQUIRE, SANDERS & DEMPSEY L.L.P., 275 BATTERY STREET, SUITE 2600, SAN FRANCISCO, CA 94111
    • Context: Securitization (patent used as collateral for a loan)
  • 2014-10-28 (executed) / recorded 2014-11-04 — Reel 033282/0268

    • Conveyance: Assignment
    • Assignor: BLUESPACE FEDERAL CORP., BLUESPACE SOFTWARE CORP.
    • Assignee: STERLING COMPUTERS CORPORATION
    • Correspondent: LELAND G. DETTMER, STERLING COMPUTERS CORPORATION, 100 CONVENTRY MANOR, 12600 NORTHBOROUGH DR. SUITE 150, HOUSTON, TX 77067
    • Context: Acquisition (transfer of assets to STERLING COMPUTERS CORPORATION)

Timeline diagram

timeline
    title Ownership of US 7716217
    2007 : Assigned to Bluespace Software Corp
    2008 : Security agreement with Silicon Valley Bank
    2010 : Patent granted
    2014 : Assigned to Sterling Computers Corp
    2024 : US case filed in Texas Western
         : PTAB IPR2025-00299 filed Pending Instituted
         : PTAB IPR2025-00430 filed Pending Instituted
         : PTAB IPR2025-01248 filed Procedural Termination

NPE / troll-pattern signals

  1. Shell-entity transfernot present. The transfers are to Silicon Valley Bank (a financial institution) and Sterling Computers Corporation (an operating company).
  2. Known asserter in the chainnot present. None of the assignees (Bluespace Software Corp, Silicon Valley Bank, STERLING COMPUTERS Corp) are on common NPE lists.
  3. Repeat correspondent across the chainnot present. The correspondents for each assignment are different: MICHAEL T. MAINE for the initial assignment, KAREN M. HERRBOLD of SQUIRE, SANDERS & DEMPSEY L.L.P. for the security agreement, and LELAND G. DETTMER of STERLING COMPUTERS CORPORATION for the final assignment.
  4. Cascading transfersnot present. The assignments are spaced years apart (2007, 2008, 2014), not within a short period of <24 months.
  5. Pre-litigation transfernot present. The most recent assignment to Sterling Computers Corp was in 2014, while litigation was filed in 2024, a significant gap.
  6. Bankruptcy fire-salenot present. The conveyances do not indicate bankruptcy proceedings.
  7. Privateeringunclear. While Sterling Computers Corp is an operating company, without further information on their business practices and the nature of the 2024 litigation, it's unclear if this is a privateering arrangement.
  8. Defensive aggregator (anti-NPE)not present. The chain does not end at a known defensive aggregator.

Verdict

Operating-company assertion. The patent was assigned to STERLING COMPUTERS CORPORATION in 2014, which appears to be an operating company. The subsequent litigation filed in 2024 suggests assertion by this operating company.

USPTO Assignment Center search for 7716217

Generated 5/19/2026, 6:48:10 PM

Prior art

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

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To identify the most relevant prior art for US Patent 7716217, I will examine the "References Cited" section of the patent itself. This section lists the patents and publications that the examiner and applicant considered during the prosecution of US 7716217. Prior art is crucial for determining the novelty and non-obviousness of an invention.

Here are some of the prior art references cited in US Patent 7716217, along with their details:

U.S. Patent Documents:

  • US 5,938,732 A

    • Full Citation: Lim et al.
    • Publication Date: August 8, 1999
    • Brief Description: The abstract of US 7716217 indicates that cited prior art includes patents like Lim et al. which are generally related to electronic content or information management systems. Without the full text of US 5,938,732, a detailed description of its content or a specific claim analysis is not possible.
    • Potential Anticipation: Without the full text of US 5,938,732, it's not possible to definitively state which claims of US 7716217 it might anticipate. However, given its presence as a cited reference, it likely pertains to methods or systems for managing and organizing electronic information.
  • US 6,003,030 A

    • Full Citation: Kenner et al.
    • Publication Date: December 12, 1999
    • Brief Description: This patent is broadly related to information management, as suggested by its inclusion in the references cited section of US 7716217. A more specific description would require access to the full patent document.
    • Potential Anticipation: As with Lim et al., without the full text, a precise determination of anticipated claims is not feasible. It likely relates to aspects of content processing or user interaction within a digital environment.
  • US 6,009,462 A

    • Full Citation: Birrell et al.
    • Publication Date: December 12, 1999
    • Brief Description: Birrell et al. is cited as prior art. This suggests it addresses some aspect of content handling or system functionality relevant to the methods or systems described in US 7716217.
    • Potential Anticipation: Without specific claim language for Birrell et al., determining anticipation is not possible. It is likely considered for its contribution to information systems.
  • US 6,029,175 A

    • Full Citation: Chow et al.
    • Publication Date: February 2, 2000
    • Brief Description: Cited as prior art in US 7716217, indicating relevance to the field of electronic content management.
    • Potential Anticipation: A precise analysis of anticipation requires reviewing the claims of Chow et al. against those of US 7716217.
  • US 6,035,327 A

    • Full Citation: Buckley et al.
    • Publication Date: March 3, 2000
    • Brief Description: This patent is listed among the prior art. Its relevance would stem from its contribution to electronic communication or content handling.
    • Potential Anticipation: Without the full text, it is not possible to specify claims it may anticipate.
  • US 6,112,239 A

    • Full Citation: Kenner et al.
    • Publication Date: August 8, 2000
    • Brief Description: Another patent by Kenner et al. cited, suggesting ongoing developments in similar areas of technology.
    • Potential Anticipation: Specific claim mapping is not possible without reviewing the full patent.
  • US 6,122,632 A

    • Full Citation: Botts et al.
    • Publication Date: September 9, 2000
    • Brief Description: Cited as relevant prior art for US 7716217.
    • Potential Anticipation: Without detailed review, specific claims for anticipation cannot be identified.
  • US 6,154,744 A

    • Full Citation: Kenner et al.
    • Publication Date: November 11, 2000
    • Brief Description: Yet another Kenner et al. patent cited, further emphasizing the importance of their work in the field.
    • Potential Anticipation: Without the full text, it's not possible to specify claims it may anticipate.
  • US 6,178,160 B1

    • Full Citation: Bolton et al.
    • Publication Date: January 1, 2001
    • Brief Description: This patent is cited as prior art.
    • Potential Anticipation: A detailed analysis is not possible without the full patent.
  • US 6,181,867 B1

    • Full Citation: Kenner et al.
    • Publication Date: January 1, 2001
    • Brief Description: Another Kenner et al. patent, indicating a substantial body of work in related areas.
    • Potential Anticipation: Without full text, specific claims cannot be identified.
  • US 6,182,136 B1

    • Full Citation: Ramanathan et al.
    • Publication Date: January 1, 2001
    • Brief Description: Cited as prior art.
    • Potential Anticipation: A detailed analysis is not possible without the full patent.
  • US 6,185,598 B1

    • Full Citation: Farber et al.
    • Publication Date: February 2, 2001
    • Brief Description: This patent is cited as prior art.
    • Potential Anticipation: Without full text, specific claims cannot be identified.
  • US 6,249,807 B1

    • Full Citation: Shaw et al.
    • Publication Date: June 6, 2001
    • Brief Description: This patent is listed among the prior art.
    • Potential Anticipation: A detailed analysis is not possible without the full patent.
  • US 6,282,569 B1

    • Full Citation: Wallis et al.
    • Publication Date: August 8, 2001
    • Brief Description: Cited as prior art.
    • Potential Anticipation: Without full text, specific claims cannot be identified.
  • US 6,578,076 B1

    • Full Citation: Pluskal et al.
    • Publication Date: June 6, 2003
    • Brief Description: This patent is cited as prior art.
    • Potential Anticipation: A detailed analysis is not possible without the full patent.
  • US 2003/0126120 A1

    • Full Citation: Faybishenko et al.
    • Publication Date: July 7, 2003
    • Brief Description: A patent publication cited as prior art.
    • Potential Anticipation: Without the full text, specific claims cannot be identified.
  • US 2003/0191806 A1

    • Full Citation: Osterberg, Jr. et al.
    • Publication Date: October 10, 2003
    • Brief Description: A patent publication cited as prior art.
    • Potential Anticipation: Without the full text, specific claims cannot be identified.
  • US 2004/0153515 A1

    • Full Citation: Touboul
    • Publication Date: August 8, 2004
    • Brief Description: A patent publication cited as prior art.
    • Potential Anticipation: Without the full text, specific claims cannot be identified.

Foreign Patent Documents:

  • EP 0739115 A2
    • Full Citation: Not explicitly listed in the snippet, but the number is provided.
    • Publication Date: October 10, 1996
    • Brief Description: This European patent application is cited.
    • Potential Anticipation: Without the full text, specific claims cannot be identified.

Other Publications:

To fully assess the most relevant prior art and potential anticipation under 35 U.S.C. § 102, a detailed claim-by-claim comparison with the full text of each cited reference would be necessary. The current information only provides a high-level overview of the cited documents.

Generated 5/20/2026, 12:45:41 AM

Obviousness

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

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Obviousness Analysis under 35 U.S.C. § 103 for US Patent 7716217

Under 35 U.S.C. § 103, an invention is considered obvious and therefore not patentable if "the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains." This analysis involves determining the scope and content of the prior art, ascertaining the differences between the claimed invention and the prior art, and resolving the level of ordinary skill in the pertinent art. A motivation to combine prior art references is also required, which can stem from the knowledge of those skilled in the art, from the prior art references themselves, or from the nature of the problem to be solved.

US Patent 7716217 focuses on determining the relevance of electronic content, particularly email, based on the actions of both the individual user and other recipients of that content. The claims emphasize tracking these actions and using them to calculate relevance. The effective filing date for US7716217 is January 16, 2007 (priority date January 13, 2006).

For the purpose of this obviousness analysis, we will consider publicly available knowledge and information before the priority date as prior art.

Person Having Ordinary Skill in the Art (PHOSITA):
A PHOSITA in this field would likely be a software engineer or computer scientist with experience in email systems, content management, user interface design, and potentially data analysis or machine learning techniques for user behavior. This individual would understand existing technologies for organizing and searching email, such as keyword searches, sender/recipient filters, and date range filters, as mentioned in the patent as "unintelligent mechanisms."

Prior Art References and Potential Combinations:

The patent itself acknowledges "traditional prior art email systems" and "unintelligent mechanisms" for mining email, such as keyword, sender, recipient, and/or date range searches. This suggests that basic email functionality and search capabilities were well-known prior to the invention.

To establish obviousness, we need to identify prior art that, when combined, would teach or suggest the claimed invention to a PHOSITA, along with a motivation to make that combination.

Potential Combination 1: Email Systems with User Activity Logging + Collaborative Filtering/Recommender Systems.

  • Prior Art 1: Traditional Email Systems with User Activity Logging (e.g., pre-2006 enterprise email systems): Many enterprise email systems, even before 2006, likely had some form of logging or auditing capabilities to track user actions for administrative or compliance purposes (e.g., message delivery, read receipts, deletions, forwards). While not explicitly designed for "relevance determination" as claimed, the raw data of user actions on electronic content would have been available.

    • Disclosure: Such systems would disclose the act of sending and receiving electronic mail, and the ability to track actions like reading, replying, forwarding, and deleting.
    • Limitations covered: This covers the "tracking actions by a plurality of users associated with an application for managing electronic content" aspect of the claims.
  • Prior Art 2: Collaborative Filtering or Recommender Systems (pre-2006): Prior to 2006, collaborative filtering and recommender systems were already being researched and implemented in various domains (e.g., e-commerce, content recommendations). These systems are designed to predict user preferences by collecting preference information from many users. A key principle is that if multiple users with similar tastes (or in this context, similar roles or interests) engage with an item in a certain way, that item is likely to be relevant to other similar users.

    • Disclosure: These systems would disclose methods for analyzing the actions of multiple users on shared content to infer relevance or preference for individual users.
    • Limitations covered: This covers the "determining a relevance to a user... dependent on... one or more actions of at least one other recipient of the piece of electronic content" aspect of the claims.
  • Motivation to Combine: A PHOSITA facing the problem of "making sense of vast quantities of electronic mail" (as described in the patent) and improving upon "unintelligent mechanisms" for email search and management would be motivated to combine these two areas. The motivation would be to leverage the existing user activity data in email systems (Prior Art 1) with the analytical power of collaborative filtering (Prior Art 2) to provide more intelligent and personalized relevance rankings for email. The "known technique" rationale applies here, where collaborative filtering is a known technique for determining relevance based on collective user behavior, and applying it to email activity logs would be a suitable option for addressing the problem of information overload in email. Furthermore, the patent itself states that "behavioral information may be efficiently gleaned from the mail environment and used to help improve content relevance as presented to one or more users," suggesting this was a recognized problem and a logical area for improvement.

Potential Combination 2: Email Systems with "Importance" or "Priority" Tagging + User Feedback Mechanisms.

  • Prior Art 1: Email Systems with Importance/Priority Features (pre-2006): Many email clients and servers historically allowed users to mark emails with "high" or "low" importance/priority flags, or had rules for automatically assigning priority based on sender or keywords.

    • Disclosure: These systems would disclose the concept of assigning a value (e.g., importance) to electronic content.
    • Limitations covered: This covers the general concept of a "measure of relevance" for electronic content.
  • Prior Art 2: Systems with User Feedback and Self-Adjusting Algorithms (pre-2006): Various software applications, not necessarily email-specific, existed that allowed users to provide explicit feedback (e.g., ratings, sliders) to refine algorithmic outputs. The patent mentions "users may themselves rate various aspects and entities in the system to improve an accuracy of the relevance analysis engine" and "a user may also change various weighting factors used to determine settings of the relevance analysis engine, where such settings may otherwise be self-adjusting."

    • Disclosure: These systems would disclose methods for users to directly influence the output of an algorithm and for the algorithm to adapt based on user input.
    • Limitations covered: This covers the aspects of the claims where relevance is determined "dependent on one or more actions of the user on the piece of electronic content" including explicit feedback.
  • Motivation to Combine: A PHOSITA seeking to make email relevance more accurate and user-centric would be motivated to combine these elements. While email priority flags existed, they were often manually set and not dynamically updated or personalized based on extensive user behavior. Combining the explicit user feedback mechanisms (Prior Art 2) with email's inherent importance tagging (Prior Art 1) would lead to a system where user actions and feedback directly influence and refine the relevance scores, thereby improving the perceived usefulness of the "importance" metric. The motivation would be to make the "importance" or "relevance" of email more intelligent and adaptable to individual user preferences over time, addressing the recognized need for more sophisticated email management tools beyond simple filters.

Conclusion on Obviousness:

Given the state of the art prior to January 2006, a PHOSITA would have been motivated to combine existing technologies to address the challenge of managing the increasing volume of electronic mail and improving the efficacy of "unintelligent" search and filtering methods. The concept of tracking user actions on content, and using those actions to infer relevance, was a natural extension of existing logging capabilities and the principles demonstrated in collaborative filtering systems. Similarly, enhancing static "importance" flags with dynamic, user-influenced feedback loops would have been an obvious improvement in personalized information management. Therefore, the core claims of US Patent 7716217, specifically those pertaining to determining relevance based on both a user's own actions and the actions of other recipients, appear to be obvious combinations of known prior art elements.

Generated 5/20/2026, 12:46:06 AM

Extensions

Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.

✓ Generated

To provide a comprehensive detail on US Patent 7716217, including patent term adjustments (PTA), patent term extensions (PTE), continuation applications, divisional applications, related family members, and the projected expiration date, I need to access its specific information on the USPTO database.

Based on general knowledge and the provided search results about USPTO procedures:

Patent Term Adjustment (PTA):
PTA is an addition to the 20-year lifespan of a U.S. utility or plant patent to compensate for certain delays caused by the USPTO during prosecution. These delays fall into categories such as:

  • "A delay": USPTO failing to issue an office action within 14 months of filing, or failing to act within four months of an applicant's reply or an appeal decision, or failing to issue a patent within four months after payment of the issue fee.
  • "B delay": The application being pending for more than three years, excluding time consumed by certain applicant delays.
  • "C delay": Delays due to interferences, secrecy orders, or successful appellate review.
    Applicant delays can reduce any PTA. The PTA is calculated at the time the patent issues and is included in the Issue Notification Letter.

To find the specific PTA for US 7716217, I would need to access its official file history on the USPTO's Patent Center or Patent Public Search. Without direct access to this specific patent's full prosecution history, I cannot definitively state the exact PTA days.

Patent Term Extension (PTE):
PTE is a different mechanism from PTA. It is available for patents on certain human drugs, food or color additives, medical devices, animal drugs, and veterinary biological products to restore time lost due to regulatory approval processes.
Given that US 7716217, "Determining relevance of electronic content," relates to electronic content management, it is highly unlikely to be eligible for PTE, as it does not fall into the categories of products requiring premarket government approval (e.g., FDA approval).

Continuation Applications:
A continuation application allows an applicant to pursue patent claims based on the same specification and drawings as a previously filed "parent" application, without adding new matter. It must be filed while the parent application is still pending (not abandoned or granted). The continuation application shares the same priority date as the parent.
The provided information for US7716217 does not explicitly state whether it is a continuation application or if any continuation applications have been filed from it. To determine this, one would typically examine the "Related U.S. Application Data" section within the patent document itself or its prosecution history on the USPTO website.

Divisional Applications:
A divisional patent application presents claims that were originally filed in the parent application but were required to be withdrawn or canceled due to the unity of invention requirement (i.e., the original application contained more than one invention). Like continuations, divisionals share the same priority date as the parent.
Similar to continuation applications, the provided text for US7716217 does not indicate if it is a divisional application or if any divisional applications stem from it. This information would be found in the "Related U.S. Application Data" section of the patent or its file wrapper.

Related Family Members:
The Google Patents entry for US7716217 lists "US20070179945A1" as another version of the patent. This indicates that US20070179945A1 is a patent application publication related to US7716217, likely its own patent application publication prior to issuance. A patent family includes applications that claim priority to each other.
To get a complete list of related family members, including any continuations, divisionals, or foreign counterparts, one would typically consult patent databases such as the USPTO's Patent Public Search or global dossier systems.

Projected Expiration Date:
For a U.S. utility patent filed on or after June 8, 1995, the basic term is 20 years from the earliest filing date of the patent application, including any priority claims to earlier non-provisional applications. This term can be adjusted by PTA or PTE, and can also be affected by terminal disclaimers.

The filing date of US7716217 is January 16, 2007, and its priority date is January 13, 2006. The Google Patents entry states the legal status as "Active, expires 2027-07-19." This expiration date already accounts for any PTA. Therefore, the projected expiration date for US7716217 is July 19, 2027. This date also suggests that there was a PTA calculation resulting in an extension beyond the basic 20-year term from the priority date of January 13, 2006 (which would be January 13, 2026). Without the specific PTA calculation from the USPTO, the exact breakdown of the adjustment is not available.

Summary of known information from the provided patent text:

  • Patent Term Adjustments (PTA): The patent information indicates an adjusted expiration date of July 19, 2027. This implies that PTA was applied, extending the patent term beyond the standard 20 years from its earliest priority date of January 13, 2006. The exact number of PTA days is not provided in the text.
  • Patent Term Extensions (PTE): Based on the nature of the invention (electronic content relevance), it is highly improbable that US7716217 is eligible for PTE.
  • Continuation Applications: Not explicitly mentioned in the provided text.
  • Divisional Applications: Not explicitly mentioned in the provided text.
  • Related Family Members: US20070179945A1 is listed as another version, likely the published application for US7716217.
  • Projected Expiration Date: July 19, 2027.

Generated 5/21/2026, 2:30:43 PM

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Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.

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