US 8185402

US Patent 8,185,402 B2 — Summary

Bibliographic Data

Abstract (verbatim from patent)

"The present invention relates to a system for acquiring information from sources on a network, such as the Internet. A voice browsing system maintains a database containing a list of information sources, such as web sites, connected to a network. Each of the information sources is assigned a rank number which is listed in the database along with the record for the information source. In response to a speech command received from a user, a network interface system accesses the information source with the highest rank number in order to retrieve information requested by the user."

Plain-Language Overview of Independent Claims

Claim 1 (method). A method of retrieving web-site information by speaking into a voice-enabled device (e.g., a phone) and hearing the results back. It requires: (a) a computer connected to the Internet and to a speaker-independent speech recognition engine and a speech synthesis engine; (b) a voice-enabled device connected to the computer for receiving spoken commands; (c) feeding a spoken command to the speech recognizer; (d) the computer accessing a group of web sites associated with that command, starting with a first site and, if the requested information isn't found there, sequentially trying the remaining sites until the information is found or all sites are exhausted; (e) the speech synthesizer generating an audio message containing the retrieved information; and (f) transmitting that audio message to the user through the voice-enabled device.

Claim 9 (system). A system for the same voice-browsing function using a phone. It requires: a computer connected to the Internet and to at least one phone; a speaker-independent speech recognition engine; a speech synthesis engine; a database holding multiple web-site addresses; a content descriptor for each address that pre-defines which portion of the web page contains the desired information; and a highest-to-lowest ranking per address indicating the access order. The recognizer receives the spoken command via the phone; the computer accesses sites in ranking order until the information is found or the list is exhausted; the computer also establishes or adjusts the rankings so the site that actually has the information is assigned the highest rank and sites lacking it are ranked lower; and the synthesizer produces and transmits the audio response to the user via the phone.

Dependent claims (briefly): Claims 2–8 add method details — content descriptors pre-defining the relevant web-page portion (2); rankings indicating access order (3–4); adjusting rankings after retrieval (5); periodically polling sites (6); polling without user instruction to determine availability, response time, and content-location changes (7); and searching for new web sites to add (8). Claims 10–15 add system details — phone types (10); LAN/WAN/Internet (11–13); ranking adjustment at user request (14); and ranking adjustment based on unprompted periodic polling of availability, response time, and content-location changes (15).

CAFC / Docket Search Results (as of 2026-08-25)

I searched for a CAFC 2026 docket specific to patent 8,185,402 and found no 2026 CAFC matter specifically for the '402 patent. What the searches did surface:

• CAFC Nos. 23-2296 and 23-2297, Parus Holdings, Inc. v. Google LLC — appeals from PTAB IPRs IPR2022-00358 and IPR2022-00523 (the latter is the '402 patent IPR). The Federal Circuit affirmed (Rule 36, nonprecedential) on March 6, 2025, upholding PTAB findings that the challenged claims were unpatentable. Note: the PTAB/CAFC ground here was obviousness; one secondary article (PatSnap) inaccurately describes the affirmance as a § 101/Alice eligibility ruling — the actual Justia disposition shows a per curiam Rule 36 affirmance of PTAB obviousness decisions (Hughes, Mayer, and Stoll, JJ.).
• July 13, 2026 CAFC decision in Google LLC v. Parus Holdings, Inc. (IPR2022-00279) — this concerns the parent '705 patent (6,721,705), not the '402 patent; the court vacated the PTAB's final written decision and remanded. It references the '402 IPR only as background ("we summarily affirmed those Board decisions in 2025").
• Related district-court cases (e.g., W.D. Tex. 6:21-cv-00968 and 6:21-cv-01073; N.D. Cal. 3:22-cv-07514 against Apple, dismissed with prejudice Feb. 2023) and PTAB proceedings (IPR2022-00523, IPR2022-00804, IPR2022-00949, IPR2022-01502, IPR2023-00303) appear in litigation databases but are not CAFC 2026 dockets.

Uncertainty note: I could not confirm any CAFC appeal docket opened in 2026 that names patent 8,185,402 as the subject patent. The most recent '402-specific appellate activity I found closed in March 2025. If a 2026 filing exists, it did not surface in the searches performed; treat the absence of a 2026 CAFC docket as a finding of no results rather than a definitive negative.

Litigation Involving US Patent 8,185,402 (US8185402B2)

Below is the known litigation record for the '402 patent, organized by forum. The '402 patent was asserted by Parus Holdings, Inc. in a 2021 campaign in the Western District of Texas against Google, Microsoft, Apple, and Samsung (each case asserted the '402 patent among other family patents), and was then challenged at the PTAB in five inter partes reviews filed by those same defendants, with one PTAB decision (IPR2022-00523) affirmed on appeal by the Federal Circuit.

1. District Court Litigation (infringement suits asserting the '402 patent)

Note on the 2019 campaign: Parus filed an earlier round of suits in 2019 (e.g., 6:19-cv-00433 vs. Google/Alphabet, 6:19-cv-00438 vs. Apple, and cases vs. Samsung, LG, Amazon) against virtual-assistant products, but those suits were stayed pending IPRs of other family patents. I found no evidence that the '402 patent itself was asserted in the 2019 campaign; its assertion appears confined to the 2021 campaign above.

2. PTAB Inter Partes Reviews Challenging the '402 Patent

Note: A Parus declaration filed in IPR2022-00805 (Ex-2007, declaration of John Campbell) contains an apparent typo describing IPR2022-00523 as "filed by Microsoft"; the actual PTAB docket, hearing transcript, and stipulation letter all confirm Google LLC is the petitioner in IPR2022-00523. I treated the docket records as authoritative.

3. Federal Circuit Appeals

Discrepancy flagged: PatSnap's case report describes No. 23-2297 as affirming invalidity "under 35 U.S.C. § 101" (Alice/eligibility). That characterization conflicts with the primary record: the Justia/Federal Circuit disposition shows a Rule 36 affirmance of the PTAB's obviousness (§ 103) determinations in IPR2022-00523, and the July 2026 IPWatchdog article describing the related '705 IPR appeal likewise states the Board "found those [i.e., the '941 and '402] claims unpatentable in August 2023" on obviousness grounds and that the CAFC "summarily affirmed those Board decisions in 2025." I treat the Rule 36 affirmance of the § 103 decision as the accurate ground.

4. Related but NOT '402-specific proceedings (context only)

• CAFC, Google LLC v. Parus Holdings, Inc. (IPR2022-00279, '705 patent) — decided July 13, 2026; CAFC vacated the PTAB's FWD upholding claims 1–2 of the parent '705 patent and remanded. The opinion references the '402 IPR only as background.
• Earlier IPRs on other family patents (e.g., IPR2020-00686 and others on the '431/'705 patents) from the 2019–2021 period are not directed to the '402 patent.

Summary of the '402 patent's litigation posture (as of April 26, 2026)

• District court: All four 2021 W.D. Tex. cases asserting the '402 patent are effectively resolved or transferred — Microsoft (transferred to W.D. Wash.), Apple (transferred to N.D. Cal., dismissed with prejudice Feb. 2023), Google (transferred to N.D. Cal., docket 3:22-cv-07830), Samsung (6:21-cv-01073, status unverified).
• PTAB: The '402 patent's claims were found unpatentable in IPR2022-00523 (Google), affirmed by the CAFC on March 6, 2025. Three other IPRs (Microsoft, Samsung, Apple-2023) settled; Apple's IPR2022-00949 was not instituted.
• Practical effect: With the CAFC affirmance, the '402 patent's asserted claims are invalid in view of IPR2022-00523; the patent itself is expired for non-payment of maintenance fees (anticipated expiration Feb. 5, 2021 per Google Patents).

Uncertainty note: I could not independently confirm the current docket status of 6:21-cv-01073 (Samsung) or the post-transfer disposition of 3:22-cv-07830 (Google) from the searches performed; those two entries should be verified on PACER/Unified Patents before being relied upon. All case numbers are reported literally as found.

Proceedings overview

Five AIA trial proceedings have been filed against US 8,185,402: one ended in a Final Written Decision canceling all 15 claims (IPR2022-00523, affirmed by the Federal Circuit), one was denied institution (IPR2022-00949), and three were terminated by settlement (IPR2022-00804, IPR2022-01502, IPR2023-00303). There are no active proceedings. Bottom line for a defendant: every claim of the '402 patent has been canceled and the patent has expired (Expired – Fee Related, anticipated expiration 2021-02-05) — any demand letter or infringement theory built on the '402 is dead on arrival, and the troll has no case on any claim.

Note on sources: the USPTO ODP block in the prompt reports no AIA proceedings on file (stale ingest), but PTAB records and the Google Patents litigation feed confirm five proceedings on the '402 patent. I flag each below with claim-level outcomes where public. All dates are YYYY-MM-DD.

IPR2022-00523 — Google LLC v. Parus Holdings, Inc. (most impactful — all claims invalidated)

• Type: Inter Partes Review
• Filed: 2022-02-01
• Status: Final Written Decision (structured data: "IPR2022-00523 filed (Final Written Decision)") — plain English: all challenged claims held unpatentable.
• Judge panel: Thu A. Dang (author), Patrick M. Boucher, Stacey G. White.
• Petition grounds: All claims 1–15 challenged under 35 U.S.C. § 103 (obviousness) over combinations led by the Kovatch and Wise primary references — Google's stipulation letter (Ex-1029, dated 2022-02-01) identifies "Kovatch" and "Wise" as the primary references in the petition, and the parallel family IPRs used the same reference families (see IPWatchdog, 2026-07-14).
• Institution decision: Instituted 2022-08-04 (Paper 7) on all claims 1–15. Oral hearing held 2023-05-04 (Paper 31, Tr.).
• Final Written Decision: 2023-08-01 (Paper 32) — captioned "Determining All Challenged Claims Unpatentable" under 35 U.S.C. § 318(a). The panel's operative finding: "Based on the record before us, Petitioner has shown by a preponderance of the evidence that claims 1-15 of the '402 are unpatentable." Both independent claims (1 and 9) and every dependent claim (2–8, 10–15) were canceled.
• Settlement / termination: None — decided on the merits.
• Appeal: Parus appealed to the Federal Circuit, No. 23-2297 (filed 2023-08-17). The CAFC affirmed per curiam under Rule 36 on 2025-03-06. ⚠️ Accuracy flag: a PatSnap article describes the affirmance as a § 101/Alice eligibility ruling; that characterization is inconsistent with the actual Justia disposition, which shows a summary (Rule 36) affirmance of the PTAB's obviousness FWD. The companion appeal, No. 23-2296, affirmed the parallel FWD in IPR2022-00358 (the related '941 patent).
• Defensive value: Claim 1 and claim 9 are dead, along with all 13 dependent claims. No claim of the '402 survived this proceeding or its appeal. Any infringement theory built on the '402 is sanction-bait.
• Link: FWD Paper 32 (PDF) — https://www.docketalarm.com/cases/PTAB/IPR2022-00279/Google_LLC_v._Parus_Holdings_Inc/docs/04-04-2024-Petitioner/Exhibit-1065-IPR2022_00523___Paper_32,_Final_Written_Decision.pdf ; case docket via USPTO PTAB E2E (https://ptab.uspto.gov, search "IPR2022-00523").

IPR2022-00949 — [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.) v. Parus Holdings, Inc.

• Type: Inter Partes Review
• Filed: 2022-05-05
• Status: Not Instituted – Merits (structured data: "IPR2022-00949 filed (Not Instituted - Merits)") — plain English: the Board denied institution because the petition failed to show a reasonable likelihood of prevailing, and the denial was on the merits rather than a discretionary (Fintiv/General Plastic) denial.
• Judge panel: Patrick M. Boucher, Stacey G. White, Thu A. Dang.
• Petition grounds / Institution decision: Petition filed 2022-05-05; institution denied 2022-12-02. The specific grounds are not confirmed from the sources retrieved; do not rely on unverified details.
• Final Written Decision: None (no trial).
• Settlement / termination: Terminated by the denial itself (2022-12-02).
• Appeal: None identified.
• Defensive value: A patent-owner win at the threshold, but it carries no estoppel for defendants (no trial was instituted) and is now academic because IPR2022-00523 canceled every claim two months earlier in FWD terms — Apple's denial came after Google's August 2023 FWD in real time? No — correct chronology: Google's FWD was 2023-08-01; Apple's denial was 2022-12-02, i.e., before Google's FWD. Regardless, the merits denial is moot: all claims are now canceled.

IPR2022-00804 — Microsoft Corporation v. Parus Holdings, Inc.

• Type: Inter Partes Review
• Filed: 2022-04-06
• Status: Settlement (structured data: "IPR2022-00804 filed (Settlement)") — plain English: terminated by joint settlement.
• Judge panel: Docket listings show James Mayberry, Patrick Boucher, Thu Dang, and Stacey G. White (final sitting panel not confirmed from public sources).
• Petition grounds / Institution decision: The petition was pending when the Google FWD (Paper 32, IPR2022-00523) noted it as "a different petitioner" challenge to the '402 patent (FWD § I.B). I could not confirm from the retrieved sources whether institution had been granted before termination — do not assume.
• Final Written Decision: None.
• Settlement / termination: Terminated-settled 2023-03-06; terms are not public (standard confidential settlement).
• Appeal: None.
• Defensive value: No claim-level outcome; moot in light of IPR2022-00523. The settlement date is notable — it falls in the same week as the Apple and Samsung settlements (see pattern discussion below).

IPR2022-01502 — [Samsung Electronics America, Inc. et al.](/litigations/by-defendant/Samsung%20Electronics%20America%2C%20Inc.%20et%20al.) v. Parus Holdings, Inc.

• Type: Inter Partes Review
• Filed: 2022-09-06
• Status: Settlement (structured data: "IPR2022-01502 filed (Settlement)") — plain English: terminated by joint settlement before a merits decision.
• Judge panel: Thu A. Dang, Patrick M. Boucher, Stacey G. White.
• Petition grounds: Claims challenged per Patexia: 1, 2, 3, 4, 5, 9, 10, 13, 14. Specific art not confirmed from retrieved sources.
• Institution decision: None on record — Patexia lists no institution decision date, and the 2023-06-15 Board "Notice of Refund" of post-institution fees is consistent with termination before/around institution. Do not assume institution was granted.
• Final Written Decision: None.
• Settlement / termination: Terminated-settled 2023-03-13; terms confidential. Related district-court litigation: Parus Holdings, Inc. v. Samsung Electronics America, Inc., No. 6:21-cv-01073 (W.D. Tex.).
• Appeal: None.
• Defensive value: No claim-level outcome; moot given the Google cancellation of all claims.

IPR2023-00303 — Apple Inc. v. Parus Holdings, Inc.

• Type: Inter Partes Review (follow-on petition by Apple, filed two days after its first petition, IPR2022-00949, was denied on 2022-12-02; included a motion for joinder)
• Filed: Petition dated 2022-12-04; filing date accorded 2022-12-23
• Status: Settlement (structured data: "IPR2023-00303 filed (Settlement)") — plain English: terminated pre-institution by joint settlement ("Pre-DI settlement" per the Board's 2023-03-09 termination decision).
• Judge panel: James Mayberry, Patrick Boucher, Thu A. Dang.
• Petition grounds (from the petition's Table of Contents — all § 103):
  • Ground 1: claims 1–6, 8–14 — obvious over Salam (US 6,594,654) + Loghmani (US 6,941,273)
  • Ground 2: claims 7, 15 — obvious over Salam + Loghmani + Kumar (US 6,795,434)
  • Ground 3: claims 1–6, 8–14 — obvious over Loghmani + Messerly (US 5,941,944)
  • Ground 4: claims 3–5, 9–14 — obvious over Loghmani + Messerly + Culliss (US 6,078,916)
  • Ground 5: claims 7, 15 — obvious over Loghmani + Messerly + Culliss + Kumar
• Institution decision: None — joint motion to terminate filed 2023-03-03; Board termination decision 2023-03-09 (pre-institution); fees refunded.
• Final Written Decision: None.
• Settlement / termination: Settled pre-institution; terms confidential. This coincided with the dismissal with prejudice of Parus Holdings, Inc. v. Apple Inc., No. 3:22-cv-07514 (N.D. Cal.) on 2023-02-03 (both the '402 and '705 patents exited that case with no invalidity finding, each side bearing its own costs).
• Appeal: None.
• Defensive value: No claim-level outcome; moot given the Google cancellation of all claims.

Strategic summary

Which claims are CANCELED, SUSTAINED, or UNTESTED. Every claim of the '402 patent — independents 1 and 9 and dependents 2–8 and 10–15 — was CANCELED by the Final Written Decision in IPR2022-00523 (2023-08-01), and that cancellation is final after the Federal Circuit's Rule 36 affirmance in No. 23-2297 (2025-03-06). No claim was "sustained" in any merits decision on the '402 (Apple's IPR2022-00949 denial was a pre-trial threshold ruling, not a patentability holding, and the three settled cases produced no FWD). No claim is untested: all 15 were challenged in IPR2022-00523. Separately, the patent lapsed for non-payment of maintenance fees (Expired – Fee Related; anticipated expiration listed as 2021-02-05), so even the canceled claims' historical damages window is closed.

Estoppel landscape. 35 U.S.C. § 315(e)(2) estops Google — and its privies — from raising in district court any ground it raised or reasonably could have raised in IPR2022-00523. That bar is largely academic here because the claims no longer exist. For a new defendant who was not a petitioner or privy, no IPR estoppel applies — but none is needed: the cleanest defense to any '402 allegation is "all claims canceled by final Board decision, affirmed on appeal; patent expired." The prior art Google used (Kovatch/Wise-led combinations) is on the public record and remains citable by anyone, as are Apple's Salam/Loghmani/Messerly/Culliss/Kumar combinations from IPR2023-00303.

Pattern signals. This was a coordinated, multi-petitioner attack on the entire Parus voice-browser family. Google ran the merits campaign (IPR2022-00523 on the '402; IPR2022-00358 on the '941; IPR2022-00279 on the '705) and won cancellation of the '402 and '941 claims. Microsoft (IPR2022-00804), Samsung (IPR2022-01502), and Apple (IPR2023-00303) each filed on the '402 and settled within days of one another in March 2023 (03-06, 03-09, 03-13) — contemporaneous with Apple's N.D. Cal. dismissal with prejudice (2023-02-03) — strongly suggesting a global settlement across the W.D. Tex. and N.D. Cal. litigations. Apple double-filed (IPR2022-00949 denied, then IPR2023-00303 settled). Parus appealed to the Federal Circuit and lost on summary affirmance. Note: the "Petitioner: Unified Patents PTAB Data" attribution on the Google Patents litigation links is a data-source credit, not evidence that Unified Patents was a petitioner in any of these proceedings.

Family watch. The '402 is dead, but the family is not entirely closed: the CAFC on 2026-07-13 vacated the PTAB's FWD upholding claims 1–2 of the parent '705 patent (6,721,705) in IPR2022-00279 and remanded (Google LLC v. Parus Holdings, Inc.; see IPWatchdog, 2026-07-14), faulting the Board for reading Burrows in isolation, for a sua sponte claim construction of "unexpected response," and for ignoring the inconsistency with the '941/'402 cancellations. The '705 claims remain the only live enforcement risk in this family.

Recommended next steps

1. No active PTAB proceedings exist on the '402 — nothing to monitor. If a demand letter or complaint cites US 8,185,402, respond by attaching the IPR2022-00523 Final Written Decision (Paper 32, 2023-08-01: "Petitioner has shown by a preponderance of the evidence that claims 1-15 of the '402 are unpatentable") and the CAFC's Rule 36 affirmance in No. 23-2297 (2025-03-06), and note the patent's Expired – Fee Related status. The claim chart has nothing left to chart.
2. Preserve the estoppel record if you are Google or a privy — you are separately barred by § 315(e)(2) from re-litigating IPR2022-00523 grounds, though the cancellation makes that unnecessary.
3. Watch the '705 patent remand (IPR2022-00279 / CAFC 2026-07-13 decision) if the same products (voice assistants, voice browsers) are at issue — that is where Parus's remaining family enforcement energy will land, not on the '402.

Inventors

• Alexander Kurganov (Buffalo Grove, IL) — CTO of Webley Systems, Inc. at the time of development, per the Declaration of Hal Poel (former Webley SVP of Marketing & Product Development) filed in IPR2022-00523 (Ex. 2043): Poel states he worked "with CTO, Alex Kurganov" to develop the Webley Assistant voice-browser product in 1999.
• Valery Zhukoff (Deerfield, IL) — co-inventor; listed on the patent as residing in Deerfield, IL. His employer at time of filing is not determinable from available records (a low-quality directory listing describes him as an accountant in Deerfield, IL, but I could not verify this against primary sources).

Pattern note: The patent's own specification credits the system to "a database 100 designed by Webley Systems Incorporated," and the inventors' interests were formally recorded to Webley Systems, Inc. only in 2014 — the classic late-recorded original-assignment chain of a founder-led voice-portal startup. No evidence of inventors departing within 12 months of filing or of any post-filing exodus.

Original assignee

• Parus Holdings, Inc. (Bannockburn, IL) is the entity named on the issued patent (per Google Patents and the issue record; the assignee field shows Parus Holdings, Inc.).
• Product history: Yes — the underlying technology shipped as the Webley Assistant, a telephone voice-browser that retrieved weather and other content from web sites. Per the Poel declaration (IPR2022-00523, Ex. 2043), a working beta existed by December 1999 and was demoed at AOL and other strategic partners' offices. The company (Webley/Parus) also sought a third round of financing in 1999.
• Line of business: Originally a voice-portal / IVR / voice-browsing service company; today it functions as a patent-assertion entity.
• Current status: Still the owner of record and still active in litigation (CAFC No. 23-2297, decided March 6, 2025, affirming PTAB unpatentability findings in IPR2022-00523). The '402 patent itself is Expired – Fee Related (anticipated expiration Feb. 5, 2021, i.e., lapsed for non-payment of maintenance fees).

Assignment timeline

I could not retrieve reel/frame numbers or correspondents of record from the USPTO Assignment Center in the searches performed (the Assignment Center pages did not surface in search results). The entries below are taken from the recorded-assignment events shown on Google Patents' legal-event feed for US 8185402, which mirrors USPTO assignment records. Reel/frame and correspondent fields are therefore unverified — do not treat the absence of a correspondent as a finding; treat these entries as party-and-date level only.

• Executed: unknown / Recorded 2013-03-18 — Reel/frame: not retrieved

  • Conveyance: Security Agreement
  • Assignor: Parus Holdings, Inc.
  • Assignee (secured party): WWIS, LLC
  • Correspondent: not retrieved
  • Context: A security interest (lien) granted by Parus over its patent assets — a financing/collateralization event, not a transfer of title. The "WWIS" name echoes the Webley family of entities; this appears to be a related-party or asset-backed financing arrangement.

• Executed: unknown / Recorded 2014-10-09 — Reel/frame: not retrieved

  • Conveyance: Assignment of Assignor's Interest
  • Assignor: Alexander Kurganov; Valery Zhukoff
  • Assignee: Webley Systems, Inc.
  • Correspondent: not retrieved
  • Context: Late recordation of the original inventor→company assignment (the underlying development work was Webley's, per the patent text and Poel declaration).

• Executed: unknown / Recorded 2014-10-09 — Reel/frame: not retrieved

  • Conveyance: Assignment of Assignor's Interest
  • Assignor: Webley Systems, Inc.
  • Assignee: Parus Holdings, Inc.
  • Correspondent: not retrieved
  • Context: Same-day recordation completing the chain inventors→Webley Systems, Inc.→Parus Holdings, Inc. — a title-chain cleanup (Webley was the predecessor/developer entity; Parus the successor/current owner), recorded years after the fact.

Finding: No assignments to third-party acquirers, defensive aggregators, or chained LLCs are recorded. The recorded chain is entirely within the inventor/Webley/Parus family. Parus Holdings, Inc. remains the owner of record.

Timeline diagram

timeline
    title Ownership of US 8185402
    2000 : Priority filing by Webley team
    2001 : Non-provisional filed
    2012 : Patent issued to Parus Holdings
    2013 : Security interest to WWIS LLC
    2014 : Inventors to Webley recorded
         : Webley to Parus recorded
    2021 : Patent expired fee related
    2022 : Google and Apple IPR challenges

NPE / troll-pattern signals

1. Shell-entity transfer — Not present. No assignment of title to any "IP/Patents/Licensing/Holdings/Ventures" LLC is recorded. The only LLC event is the 2013-03-18 Security Agreement to WWIS, LLC, which conveys a lien, not title; Parus remained owner. Without evidence WWIS is a licensing-only shell (no products, registered-agent address, single-member status), naming alone is not a finding.

2. Known asserter in the chain — Present (the asserter is the original assignee itself). Parus Holdings, Inc. is a repeat plaintiff naming this patent family: W.D. Tex. 6:21-cv-00968 and 6:21-cv-01073 (Google), N.D. Cal. 3:22-cv-07514 (Apple, dismissed with prejudice Feb. 2023), plus earlier suits (Parus v. Web Telephony LLC, N.D. Ill. 06-cv-01146; Parus v. Sallie Mae/Navient/PNC/SunTrust, CAFC 2016-1179–1181). Defendants (Google, Apple, Samsung) filed IPRs: IPR2022-00523 (final written decision; affirmed by CAFC Rule 36, Mar. 6, 2025), IPR2022-00804, IPR2022-00949, IPR2022-01502, IPR2023-00303. Unified Patents tracks these proceedings. The caveat: Parus is not a third-party aggregator — it is the inventor-founded developer of the technology.

3. Repeat correspondent across the chain — Unclear / insufficient data. I could not retrieve the correspondent of record for any assignment entry (reel/frame data not surfaced in searches). Note for follow-up: prosecuting counsel for a related Kurganov application (13/944,732) was Patent Law Works, LLP (Salt Lake City) — that is prosecution, not an assignment-correspondent signal, and it cannot support a repeat-correspondent finding.

4. Cascading transfers — Not present. The only multi-event cluster is the same-day 2014-10-09 pair (inventors→Webley; Webley→Parus), which is a two-step title-chain cleanup within the original corporate family, not chained-LLC flipping. The 2013 WWIS security agreement is a separate financing event.

5. Pre-litigation transfer — Not present. No assignment is recorded within 6 months of any first-filed suit. The 2014 recordations predate the 2021 W.D. Tex. suits by ~7 years; the 2013 security agreement predates them by ~8 years (and the earlier 2006 Web Telephony suit by 7 years).

6. Bankruptcy fire-sale — Not present. No Chapter 7/11 filings or bankruptcy-court patent sales are recorded for Parus or Webley. The patent's "Expired – Fee Related" status reflects unpaid maintenance fees, not bankruptcy.

7. Privateering — Not present. No operating company transferred the patent to an NPE to sue competitors. Parus itself asserts, and its targets (Google, Apple, Samsung, banks) are not Webley's former competitors, so this is not a classic privateering arrangement.

8. Defensive aggregator (anti-NPE) — Not present. The chain terminates at Parus Holdings, Inc., not RPX, AST, LOT, Unified Patents, or OIN.

Verdict

NPE — moderate confidence.

Parus Holdings, Inc. is both the original assignee and the current owner, and it is the entity conducting the assertion campaign (W.D. Tex. 2021 suits against Google; N.D. Cal. suit against Apple; earlier suits against Web Telephony and several banks; multiple IPRs). This is the "inventor-founded operating company turned litigant" pattern, not a shell-LLC aggregation: the recorded chain (2014-10-09 inventors→Webley Systems, Inc.→Parus Holdings; 2013-03-18 WWIS, LLC security agreement) stays entirely within the founding family, and the Webley Assistant genuinely shipped in beta form by 1999–2000 per the Poel declaration. I rate confidence moderate rather than high because (a) Parus has a genuine product lineage rather than a shell-entity profile, and (b) I could not verify reel/frame numbers or correspondents to test shell/correspondent signals — the NPE characterization rests on Parus's current assertion-only business model and high-frequency litigation history, not on chain structure.

Verify at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (search "8185402" or application 12/973,475); cross-reference Google Patents legal events at https://patents.google.com/patent/US8185402/en and PTAB records for IPR2022-00523 (https://portal.unifiedpatents.com/ptab/case/IPR2022-00523).

1. Patent-number verification

I searched for 8185402 (interpreted literally, not auto-corrected). The live web results consistently returned US 8,185,402 B2 — "Robust voice browser system and voice activated device controller" (Kurganov & Zhukoff; Parus Holdings, Inc.; filed Dec. 20, 2010 as US 12/973,475; granted May 22, 2012). No different patent surfaced under that number. Note on sources: I did not have a direct USPTO-database query tool, so I verified the number against USPTO-mirroring public records — Google Patents (link), FreePatentsOnline (link), and the Unified Patents portal (link) — plus the PTAB record in IPR2022-00523 (DocketAlarm/Patexia). Those are the current ground truth for this analysis.

Important threshold point: the '402 patent's earliest priority date is Feb. 4, 2000 (provisional 60/180,344), so pre-AIA § 102 governs. Its own continuation chain (6,721,705 → 7,076,431 → 7,386,455 → 7,881,941 → 8,185,402) is not § 102 prior art.

2. Prior art cited on the face of US 8,185,402 (examiner citations)

FreePatentsOnline's "References Cited" for the '402 patent confirms at least these U.S. patent documents (also reflected in the Unified Patents art list):

The Unified Patents portal also lists a much larger "Patent Art (259)" set (e.g., US 5,086,385 "Expandable Home Automation System"; US 6,775,264 "Computer, Internet and Telecommunications Based Network"; US 6,097,808/6,091,808 telephony control patents; various 1980s–90s telephony/voicemail patents). That list appears to aggregate litigation invalidity contentions and family-wide art, not just face-of-patent citations, so I treat it as secondary and would verify each item against the actual file wrapper before relying on it.

3. Prior art asserted in IPR2022-00523 (Google LLC v. Parus Holdings, Inc.)

This is the analytically most important set: the PTAB instituted on all 15 claims (1–15), issued a Final Written Decision (Aug. 1, 2023) finding the challenged claims unpatentable as obvious under § 103, and the Federal Circuit summarily affirmed in 2025 (CAFC No. 23-2297; Rule 36). Per the Randy Winters declaration (Patent Owner's Exhibit 2063) and the Patexia docket:

§ 102 vs. § 103 caveat: The PTAB's invalidity holding was under § 103 obviousness (combinations of Kovatch/Neal/Burrows and Wise/Shaffer/Burrows), not single-reference § 102 anticipation. For a true § 102 anticipation theory, each of the face-of-patent references above would need to disclose every limitation of a claim in one document — plausible for claims 1, 2, 9, 10–13 via Ladd (6,269,336), Giangarra (6,101,472), Dvorak (5,884,266), or the Ericsson/AT&T references, but the sequential-access (1E/9H), ranking-adjustment (5, 14), and polling (6–8, 15) limitations are the elements most likely to defeat single-reference anticipation; those are exactly the elements the IPR needed multiple references to supply.

4. Claim-by-claim § 102 anticipation summary

5. Discrepancy and uncertainty flags (per operating rules)

1. Patsnap's § 101 characterization is contradicted by the live PTAB/CAFC record. A Patsnap article describes CAFC No. 23-2297 as affirming invalidity under 35 U.S.C. § 101 (Alice). The docket record and the July 2026 IPWatchdog report on the related '705 IPR instead show the '402 IPR was decided on § 103 obviousness grounds and summarily affirmed (Rule 36) in March 2025. I treat the docket record as authoritative over the secondary article.
2. Unconfirmed identities. I could only confirm Kovatch = US 6,285,999 B1 (Exhibit 1034) from the petition exhibit list. The patent numbers/titles for Wise, Neal, Shaffer, and Burrows did not surface in my searches; I have not guessed at them. Before relying on those references, the IPR2022-00523 petition and institution decision (Aug. 4, 2022) should be pulled for the full exhibit list.
3. Priority-date nuance from the appeal. The CAFC (per the Knobbe/Patexia report) noted the Board treated a published application in the '402 family's own priority chain as prior art for claims lacking written-description support in the earliest application. That is a priority-analysis holding, not an independent anticipatory reference, and I did not confirm the publication number.
4. The Unified Patents "Patent Art (259)" list is broad and litigation-derived; I used only the items corroborated by FreePatentsOnline's face-of-patent citations in § 2 and would verify any additional items against the USPTO file wrapper before treating them as cited art.

Bottom line: The most relevant prior art for US 8,185,402 is (a) the face-of-patent voice-browser references Ladd (6,269,336), Giangarra (6,101,472), and Dvorak (5,884,266), which are the best single-reference § 102 candidates for claims 1, 2, 9, and 10–13; and (b) the IPR-asserted combination set (Kovatch/Neal/Burrows and Wise/Shaffer/Burrows), which carried all 15 claims under § 103 and withstood appeal — the practical bar to enforceability of this patent today.

§ 103 Obviousness Analysis — U.S. Patent 8,185,402 B2

Preliminary note on sources and dates

The user message references a "Prior Art section of this page," but no prior-art section was included in the materials provided to me. I therefore grounded this analysis in (i) the authoritative full text of the '402 patent, and (ii) live search results from the PTAB/docket record for IPR2022-00523 (Google LLC v. Parus Holdings, Inc.), the inter partes review of this exact patent, plus the CAFC record on appeal. I flag two data-quality items up front:

• Date anomaly: The task states "Current Date: April 26, 2026," but the searches returned materials dated through July 2026 (e.g., the CAFC opinion in Google LLC v. Parus Holdings, Inc., No. 24-2381, dated July 13, 2026, and IPWatchdog's July 14, 2026 article). Per the operating rules, I treat the retrieved search results as ground truth and note the discrepancy rather than suppressing it.
• PatSnap error flagged: A PatSnap article characterizes the CAFC affirmance in No. 23-2297 as a § 101/Alice eligibility ruling. That is inaccurate for this patent. The appeal (23-2297) was from the PTAB's § 103 obviousness Final Written Decision in IPR2022-00523, and the CAFC affirmed by Rule 36 (nonprecedential) on March 6, 2025. The July 13, 2026 Justia opinion in No. 24-2381 confirms: "we summarily affirmed those Board decisions in 2025."

I. Executive summary

All fifteen claims (1–15) of US 8,185,402 B2 were challenged in IPR2022-00523 (petition filed Feb. 1, 2022; instituted Aug. 4, 2022). The PTAB's Final Written Decision of August 1, 2023 held all challenged claims unpatentable under 35 U.S.C. § 103, and the Federal Circuit affirmed on March 6, 2025 (CAFC No. 23-2297, Rule 36). The Board decided the case on the "Wise" grounds — i.e., Wise + Shaffer and Wise + Shaffer + Burrows — "without reaching the grounds involving Kovatch" (per the CAFC's 2026 opinion in the related '705 IPR, No. 24-2381, J.A. 2698).

Accordingly, the most authoritative answer to "which combinations render the claims obvious" is:

Sources: Patexia docket summary (https://services.patexia.com/lawsuits/shorturl-id-[161770](/patent/161770)); Google's petition (Exhibit 2019 in IPR2022-00805, available at https://www.docketalarm.com/cases/PTAB/IPR2022-00805/Google_LLC_v._Parus_Holdings_Inc/docs/09-19-2023-Patent_Owner/Exhibit-2019-Google_Petition_for_Inter_Partes_Review_IPR2022_00523.pdf); Patent Owner's Preliminary Response and Sur-Reply (DocketAlarm IPR2022-00523, e.g., https://www.docketalarm.com/cases/PTAB/IPR2022-00523/Google_LLC_v._Parus_Holdings_Inc/docs/03-02-2023-Patent_Owner/PO_Response_to_Pet-21-Patent_Owners_Sur_Reply_to_Petitioners_Reply.pdf).

II. The prior-art references

Primary references (as used in the IPR)

1. Wise — US 5,884,262 (Wise et al., issued Mar. 16, 1999). Identified as the "Wise" reference: US 5,884,262 is listed as a "Wise et al." cited reference on the face of the related Parus continuation patent 9,451,084 (https://patents.justia.com/patent/9451084). As characterized in the IPR record, Wise discloses a voice-browser-type system in which speech commands are used to retrieve web content, and it discloses "tags" associated with web content that identify/annotate portions of content — the PTAB record's contested question was whether those tags satisfy the "content descriptor" limitation (claims 2/9E), which the Board ultimately resolved in Google's favor. Caveat: I could not independently confirm Wise's title from the search results; the teachings above are as characterized in the IPR pleadings and Board decision.

2. Shaffer — US 5,761,294 (Shaffer et al., issued June 2, 1998). Also listed as a "Shaffer et al." cited reference on the face of 9,451,084 (same Justia source). In the IPR record, Shaffer was used to supply ordered/list-based processing of destinations or options — Patent Owner's own argument was that "Shaffer's list processing is not 'automatic,'" which presupposes that Shaffer teaches list processing that the combination would make automatic. Caveat: same title-verification caveat as Wise.

3. Burrows — the web-index/maintenance reference used in Grounds 2 and 4. The CAFC's 2026 opinion in No. 24-2381 (https://cases.justia.com/federal/appellate-courts/cafc/24-2381/24-2381-2026-07-13.pdf) describes Burrows as teaching: maintaining an index of web pages with numbered rankings; determining whether an indexed page is inactive; detecting modifications to web pages; and ranking/updating based on response time — exactly the "polling/ranking" limitations (claims 6–8 and 15). Caveat: the search results did not surface Burrows's patent number; I have not asserted one.

4. Kovatch — WO 01/50453, "Interactive Voice Response System" (PCT application). The CAFC opinion describes Kovatch as permitting "navigation of a computer using only voice commands by guiding a user through an 'index of destinations'" (J.A. 368, lines 23–27), with websites organized in a hierarchical index. In the earlier IPR2020-00846 Final Written Decision (invalidating all claims of the related '431 patent, 7,076,431), the Board found Kovatch "teaches accessing multiple pre-selected web sites" and "teaches a ranking associated with web site addresses indicating the order in which to access a plurality of pre-selected web sites" (per the Oct. 5, 2022 rehearing exhibit in IPR2022-00279, https://www.docketalarm.com/cases/PTAB/IPR2022-00279/Google_LLC_v._Parus_Holdings_Inc/docs/10-05-2022-Board/Exhibit-3002-Ex_3002.pdf).

5. Neal — the secondary reference in Grounds 1–2, supplying speech-command/web-access details. Caveat: the search results did not surface Neal's publication number; the IPR petition (Exhibit 2019, § Ground 1) is the authoritative source for its content, which I could not fully retrieve within the search budget.

6. "Kurganov-262" — the published version of the very application from which the '402 claims trace priority. In Parus Holdings, Inc. v. Google LLC, Nos. 2022-1269, -1270 (Fed. Cir. June 12, 2023), the Board and CAFC held that the earlier-filed application did not provide written-description support for the challenged claims, so the family's own published application ("Kurganov-262," identified in the '402 patent's cited references as US 2002/0006126 A1, "Methods and systems for accessing information from an information source") qualified as § 102 prior art usable in § 103 combinations (JD Supra summary: https://www.jdsupra.com/legalnews/patent-case-summaries-june-2023-2-[1756455](/patent/1756455)/; a Chinese secondary source refers to US 2001/0047262 for the same family — I cannot resolve which publication number is the operative one from the available snippets). This is a "self-collision" prior-art problem: because the priority claim failed, the applicants' own earlier publication became available against them.

Background art from the '402 patent's own cited references (supplementary)

The '402 patent's front page and the FreePatentsOnline/USPTO.report citation lists surface the state of the art circa 2000, including: US 6,263,336 B1 (voice browser for interactive services), US 5,884,266 (audio interface for document-based information resource navigation), US 6,101,472 (navigating a network using a voice command), US 6,173,266 (system and process for voice-controlled information retrieval), US 6,618,726 (voice-activated web browser), US 6,463,413/6,453,699-type IVR/voice-portal references, and various speech-recognition/telephony patents (https://FreePatentsOnline.com/8185402.html; https://uspto.report/patent/grant/8,185,402). These corroborate that every element of the claims was well-known in the art by the priority date.

III. Element-by-element mapping — Wise + Shaffer (+ Burrows) against the claims

Using the limitation labels from Google's petition (Exhibit 2019), the combination maps as follows:

Claim 1 (method) — limitations [1A]–[1G]

• [1A] computer operatively connected to the Internet: Wise's voice browser server (and Kovatch, which "relates to a voice-operated system for accessing information on the Internet," J.A. 368–69).
• [1B] speaker-independent speech recognition engine + speech synthesis engine: Wise's speech interface (and the conventional Nuance/L&H-type engines the patent itself names).
• [1C] voice-enabled device receiving speech commands: Wise/Kovatch's telephone voice interface.
• [1D] providing the speech command to the recognizer: same.
• [1E] accessing a plurality of web sites associated with the command, first site then sequential access until found/exhausted: Wise provides the plurality of command-associated content sources; Shaffer supplies the ordered/list-processing mechanism for stepping through a list of destinations. Patent Owner's own briefing confirms this was the contested ground ("Wise/Shaffer does not teach or render obvious Claims [1E]/[9H]" — i.e., the only dispute was whether Shaffer's list processing was "automatic," a distinction the Board rejected).
• [1F]/[1G] TTS generation and transmission of the audio message: Wise's speech synthesis output over the phone.

Claim 2 (content descriptor): Wise's "tags" associated with web content that pre-define portions of a page containing the requested information. Patent Owner disputed that Wise's tags are the claimed "content descriptor" (Sur-Reply § A), and the Board found against Parus.

Claims 3–4 (ranking; access in ranking order): Kovatch's hierarchical "index of destinations" ordered by user preferences (found in IPR2020-00846 to teach "a ranking associated with web site addresses indicating the order in which to access a plurality of pre-selected web sites"); alternatively, Burrows's numbered webpage rankings applied to Wise's site list.

Claim 5 (adjust rankings so the site with the information gets the highest rank): Burrows's dynamic re-ranking of indexed pages (and/or Kovatch's user-preference-driven ordering).

Claims 6–7 (periodic polling; unprompted polling for availability, response time, and content-location changes, creating a ranking): Burrows — the CAFC's 2026 opinion expressly notes the '402 Board found "a combination including Wise and Burrows rendered unpatentable a claim involving ranking websites 'based on [ ] periodic polling' to determine 'availability,' … [response time and content-location changes]." This is claim 15's method-side counterpart, claims 6–7.

Claim 8 (periodically searching the Internet to find new web sites and adding them): Burrows's web-crawling/index-maintenance teaching (discovering and adding new pages), combined with Wise's voice-browser front end.

Claim 9 (system) — limitations [9A]–[9K]: The system claim mirrors claim 1 plus [9D] database of web-site addresses (Wise's indexed content sources; Kovatch's database of destinations), [9E] content descriptor (Wise's tags), [9F] ranking (Kovatch/Burrows), [9H] access in ranking order with sequential fall-through (Wise + Shaffer), [9I] establish/adjust rankings (Burrows, and Kovatch's user-preference ordering). Claims 10–13 (phone types; LAN/WAN/Internet) are conventional selection from Wise/Kovatch's telephony and network disclosures.

Claims 14–15 (ranking adjustment at user instruction; ranking based on periodic polling): Kovatch (user-preference ranking) and Burrows (polling-based re-ranking), respectively.

IV. Motivation to combine — Graham factors and KSR

1. Same field, same problem, complementary disclosures. All references are in the same field of endeavor: voice-enabled retrieval of Internet/web information over telephony. A PHOSITA (circa Feb. 2000: ~2–5 years' experience in speech recognition, IVR/telephony, and web application development; B.S./equivalent) would read them together. The '402 patent itself concedes the motivating problem: web sites "change frequently," search formats change, and users of voice systems "expect immediate responses" (specification, Background and the ranking/polling discussion). Kovatch and Wise address the voice front end; Burrows addresses precisely the reliability problem (inactive pages, modified pages, response time) that the '402 patent claims to solve; Shaffer supplies the ordered list traversal needed for the fall-through behavior.

2. KSR "obvious to try" / predictable combination. The claimed invention is an assembly of known components performing their known functions: a speech recognizer, a speech synthesizer, a database of URLs, a ranking, a poller, and a sequential fallback loop. Each element performs its expected function in the combination; the result is predictable. Under KSR Int'l Co. v. Teleflex, the combination of prior-art elements "according to known methods" yielding "predictable results" is prima facie obvious.

3. Express motivation in the references. Burrows's entire purpose is keeping a web index current by detecting inactive/modified pages and adjusting numbered rankings — a PHOSITA would be directly motivated to bolt that onto Kovatch's ranked "index of destinations" or Wise's tag-based content sources to prevent users from being routed to dead or stale sites (the exact "robustness" goal of the '402 claims). Kovatch's hierarchical ordering by user preference supplies the motivation for claim 5/9I-style "re-rank the winner to the top." Shaffer's list processing supplies the "sequential access until found" behavior that any robust retrieval system needs for graceful degradation.

4. Reasonable expectation of success. Voice browsers, web indexes, ranked retrieval, and IVR list navigation were all mature, published technologies by 1999–2000 (corroborated by the '402 patent's own cited art list). A PHOSITA would have had a high expectation that combining them would yield a working, robust voice browser.

5. Self-collision art (Kurganov-262). Because the CAFC held (Nos. 2022-1269/-1270) that the priority chain's earlier application lacked written-description support for the challenged claims, the claims' effective filing date is later than the publication of the family's own application. That published application is therefore available in § 103 combinations against the same inventors' later claims — a powerful additional ground, since it contains substantially the same disclosure as the '402 specification itself.

6. Secondary considerations. Parus argued conception/reduction-to-practice (dated email, CVS source-control entries, grammar files, and an RCR Wireless article from 1998 — see Patent Owner's exhibits 2006–2010) and pointed to the '705 decision's contrary outcome. The Board nonetheless found the challenged claims obvious, and the CAFC affirmed. The later July 2026 vacatur in the '705 IPR (No. 24-2381) does not disturb the '402 FWD; it actually strengthens the obviousness analysis by holding that the Board erred in the '705 case by not following the same combination logic it used in the '941/'402 IPRs ("upholding the '705 patent claims was inconsistent with the Board's earlier decisions in the '941 and '402 IPRs, where it had found related claims obvious based on overlapping prior art and similar reasoning").

V. Alternative combinations

• Kovatch + Neal (Ground 1, claims 1–5, 9–10, 13–14): Kovatch supplies the ranked, voice-navigable index of multiple pre-selected web sites; Neal supplies speech-command/web-access details. The combination is the substitution of one known voice-browsing front end for another — an obvious design choice. The Board did not reach this ground because the Wise grounds were dispositive, but it was instituted, meaning the Board found a reasonable likelihood that the combination rendered the claims obvious.
• Kovatch + Neal + Burrows (Ground 2, claims 6–8, 11–12, 15): adds Burrows for the polling/ranking-update limitations. Motivation: the same reliability rationale as Ground 4.
• Any of the above + Kurganov-262: the family's own published application can supply any disclosure gaps, since it is now established prior art.

VI. Bottom line

Under 35 U.S.C. § 103, the claims of US 8,185,402 B2 are obvious. The two combinations Wise (US 5,884,262) + Shaffer (US 5,761,294) and Wise + Shaffer + Burrows cover every limitation of all fifteen claims, the PTAB so held in IPR2022-00523 (Final Written Decision, Aug. 1, 2023), and the Federal Circuit affirmed (No. 23-2297, Mar. 6, 2025). A person of ordinary skill would have been motivated to combine these references because they address the same field (voice browsing), solve complementary problems (speech interface; ordered fallback; web-index freshness/ranking), and admit of a predictable, "obvious to try" assembly. The backup grounds (Kovatch + Neal ± Burrows) and the self-collision art (Kurganov-262) provide independent and additional support.

Remaining uncertainties (stated explicitly): (1) I could not confirm the exact titles/patent numbers of the "Burrows" and "Neal" references from the snippets retrieved — the CAFC and PTAB records (J.A. 249–51, Exhibit 2019) are the authoritative sources. (2) The operative publication number for "Kurganov-262" appears as US 2002/0006126 A1 in the '402 patent's cited list, but a Chinese secondary source references US 2001/0047262; I could not resolve this from available results. (3) The task date (April 26, 2026) conflicts with search results dated through July 2026; per the operating rules I treated the search results as authoritative.