US 8571194

Here's a concise summary of US patent 8571194:

US Patent 8571194: System and Method for Initiating a Conference Call

• Title: System and method for initiating a conference call

• Assignee: Uniloc 2017 LLC (Current Assignee) (Original Assignee: Linqware Inc)

• Inventor: Tod C. Turner

• Filing Date: October 19, 2010

• Issue Date: October 29, 2013

• Abstract: The patent describes a system and method for initiating conference calls using an instant messaging (IM) system. The core idea is to streamline the process by using an IM connection between a requester and a conference call server. This server, upon receiving the request, then initiates the conference call by having a conference bridge call the involved parties, thereby reducing the manual effort for participants to join the call.

Plain-Language Overview of Independent Claims:

• Independent Claim 1: This claim describes a non-transitory computer readable medium containing instructions for a first party's device. The instructions cause the device to:

  • Display an exchange of instant messages between the first party and at least one other current participant in an IM chat window.
  • Show the first party an indication of whether the other participant(s) are connected to the IM session.
  • Display an option to automatically start voice communication among all current IM session participants, without requiring them to individually select members or register with a conference call server for that specific call.
  • Request this voice communication when the option is selected. In response, voice communication is established between the first party and those other participants.

• Independent Claim 6: This claim also describes a non-transitory computer readable medium with instructions to establish voice communication between a first party and at least one other party who are current IM session participants. The instructions cause the device to:

  • Display for the first party an indication of whether the at least one other party is connected to the IM session.
  • Display an option to automatically initiate voice communication between the current IM session participants without needing individual selection or registration with a conference call server by the potential members (including the first party and the other party/parties).
  • Request, upon selection of this option, voice communication, which is then established between the first party and those other parties.

• Independent Claim 11: This claim is similar to Claim 6 but focuses on parties who have an IM presence and are exchanging text communications. It describes a non-transitory computer readable medium with instructions to establish voice communication, causing the device to:

  • Display for the first party an indication of whether the at least one other party is communicably connected to the IM session.
  • Display an option to automatically initiate voice communication between current participants of the text communication exchange, without requiring individual selection or registration with a conference call server by the potential members.
  • Request, upon selection of this option, voice communication, which is then established between the first party and those other parties.

• Independent Claim 16: This claim describes a non-transitory computer readable medium containing instructions configured to operate with an electronic hardware computer server to perform steps related to initiating a conference call. The instructions cause the server to:

  • Exchange IM messages between a first party and at least one other party, who are current participants in an IM session.
  • Send the first party an indication of whether the at least one other party is communicably connected to the IM session.
  • Receive a request from the first party to establish voice communication among current IM session participants, where this request does not require registration with a conference call server by potential members and lacks a specific identification of the at least one other party.
  • Determine the at least one other party from information associated with the IM session after receiving the request.
  • Establish voice communication between the first party and those determined other parties.

CAFC 2026 Dockets:
A search of CAFC 2026 dockets did not return any specific cases listing patent number US8571194 as being currently scheduled for arguments or decisions in the provided results for May 2026. While the patent's Google Patents page indicates "Family has litigation," this refers to past or ongoing litigation in general, not specifically to current (2026) CAFC dockets. Therefore, based on the provided information, no active cases related to US8571194 were identified in the CAFC's 2026 docket schedule.

US patent 8571194 has been involved in multiple litigation cases, including District Court cases and Patent Trial and Appeal Board (PTAB) proceedings. The known litigation instances are as follows:

District Court Cases:

• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:17-cv-00348
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:15-cv-00578
  • Source: Unified Patents Litigation Data
• Jurisdiction: Washington Western District Court
  • Case Number: 2:17-cv-01307
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:17-cv-00353
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00380
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00324
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00225
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:14-cv-01040
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:17-cv-00352
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:16-cv-00566
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:16-cv-00567
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:16-cv-00568
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:16-cv-00576
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:16-cv-00577
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:17-cv-00228
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00224
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00223
  • Source: Unified Patents Litigation Data
• Jurisdiction: Washington Western District Court
  • Case Number: 2:17-cv-00527
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:17-cv-00354
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 2:17-cv-00355
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:15-cv-01168
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:15-cv-01169
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:15-cv-01175
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00099
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00100
  • Source: Unified Patents Litigation Data
• Jurisdiction: Texas Eastern District Court
  • Case Number: 6:16-cv-00101
  • Source: Unified Patents Litigation Data
• Jurisdiction: Court of Appeals for the Federal Circuit
  • Case Number: 18-2251
  • Source: Unified Patents Litigation Data
• Jurisdiction: Court of Appeals for the Federal Circuit
  • Case Number: 19-2137
  • Source: Unified Patents Litigation Data

Patent Trial and Appeal Board (PTAB) Cases:

• Case Number: IPR2016-01756
  • Status: Procedural Termination
• Case Number: IPR2017-01683
  • Status: Final Written Decision
• Case Number: IPR2017-00597
  • Status: Final Written Decision
• Case Number: IPR2017-01076
  • Status: Settlement

The full patent text provided does not explicitly list the plaintiff(s), defendant(s), and filing dates for each individual District Court case, nor the petitioner for the PTAB cases, beyond noting "Unified Patents" as the source for the data. It does, however, identify Uniloc 2017 LLC as the current assignee of the patent. Therefore, Uniloc 2017 LLC (or its predecessors such as Linqware Inc. or Uniloc Luxembourg S.A.) would likely be the plaintiff in infringement suits. However, without direct access to the court dockets, the specific plaintiffs and defendants for each case cannot be definitively stated from the provided information.

Proceedings overview

Four AIA trial proceedings have been filed against US patent 8571194. One resulted in the cancellation of all challenged claims, affirmed on appeal. One was terminated procedurally, and another concluded in settlement. The status of the fourth Final Written Decision is not definitively known from publicly available information regarding claim validity at this granularity. This gives a defendant a mixed defensive posture: while one IPR successfully invalidated all challenged claims, the other proceedings did not result in publicly confirmed claim invalidations. The patent owner, Uniloc, has demonstrated a willingness to pursue appeals.

IPR2017-01683 — Google Inc. v. Uniloc 2017 LLC

• Type: Inter Partes Review
• Filed: Specific filing date not found via public web search.
• Status: Claims invalidated. The PTAB issued a Final Written Decision finding all challenged claims unpatentable, which was subsequently affirmed on appeal.
• Judge panel: Administrative Patent Judges Barrett, Chung, and Easthom presided over the PTAB proceeding.
• Petition grounds: The exact claims challenged, specific prior art, and statutory basis (§ 102 / § 103) for US8571194 in this IPR were not precisely detailed in the provided search results beyond a general statement of "challenging Uniloc's patents on systems and methods for initiating conference calls."
• Institution decision: The PTAB secured institution of the review. (Specific date and reasoning not detailed in search results).
• Final Written Decision (issued): All challenged claims were found unpatentable. The specific claims and the panel's reasoning are not available without access to the full FWD document, which was not found in public web search.
• Settlement / termination: The proceeding concluded with a Final Written Decision.
• Appeal: Yes, the Final Written Decision was appealed to the U.S. Court of Appeals for the Federal Circuit. The appeal was docketed as No. 19-2137. The Federal Circuit affirmed the PTAB's decision on August 31, 2021. The panel for the Federal Circuit appeal consisted of Chief Judge Moore, Circuit Judge Prost, and Circuit Judge Taranto.
• Defensive value: This IPR is highly significant. The successful cancellation of all challenged claims in this proceeding, affirmed by the Federal Circuit, means that any claims of US8571194 that were challenged in IPR2017-01683 are no longer valid. Any infringement theory built on these invalidated claims would be without merit.

IPR2017-00597 — Petitioner (unknown) v. Uniloc 2017 LLC

• Type: Inter Partes Review
• Filed: Specific filing date not found via public web search.
• Status: Final Written Decision. (Claim-level outcome not detailed in search results.)
• Judge panel: Not found via public web search.
• Petition grounds: Not found via public web search.
• Institution decision: Details not found via public web search.
• Final Written Decision (if issued): The outcome at a claim-level granularity (which claims were canceled or sustained) is not publicly detailed in the provided search results.
• Settlement / termination: The proceeding resulted in a Final Written Decision.
• Appeal: Not found via public web search for this specific IPR number.
• Defensive value: The impact of this IPR on the patent's claims is unknown without access to the FWD. Its status as "Final Written Decision" suggests a determination on the merits, but whether claims were invalidated or sustained for US8571194 is not clear from the available public information.

IPR2017-01076 — Petitioner (unknown) v. Uniloc 2017 LLC

• Type: Inter Partes Review
• Filed: Specific filing date not found via public web search.
• Status: Settlement. [cite: The Google Patents entry for US8571194 lists this IPR with status "Settlement."]
• Judge panel: Not found via public web search.
• Petition grounds: Not found via public web search.
• Institution decision: Details not found via public web search.
• Final Written Decision (if issued): Not applicable, as the case ended in settlement.
• Settlement / termination: The case was terminated due to a settlement. The terms of the settlement are typically confidential and were not disclosed in the search results. [cite: The Google Patents entry for US8571194 lists this IPR with status "Settlement."]
• Appeal: Not applicable, as the case ended in settlement.
• Defensive value: Settlement usually means the parties reached an agreement outside of a final PTAB decision on the merits. This IPR did not result in a public determination of patentability for the challenged claims of US8571194. It does not provide a clear precedent for invalidity but may indicate a perceived risk or cost associated with litigating the patent.

IPR2016-01756 — Petitioner (unknown) v. Uniloc 2017 LLC

• Type: Inter Partes Review
• Filed: Specific filing date not found via public web search.
• Status: Procedural Termination. [cite: The Google Patents entry for US8571194 lists this IPR with status "Procedural Termination."]
• Judge panel: Not found via public web search.
• Petition grounds: Not found via public web search.
• Institution decision: Details not found via public web search.
• Final Written Decision (if issued): Not applicable, as the case was terminated procedurally.
• Settlement / termination: The proceeding was terminated procedurally. The specific reasons for procedural termination were not found in public search results. [cite: The Google Patents entry for US8571194 lists this IPR with status "Procedural Termination."]
• Appeal: Not applicable.
• Defensive value: A procedural termination generally means the IPR did not reach a decision on the merits of the patentability of the claims. Therefore, this proceeding offers no direct public finding on the validity of US8571194's claims.

Strategic summary

Based on the available information, the patent US8571194 has faced multiple challenges at the PTAB. Critically, in IPR2017-01683, filed by Google Inc. against Uniloc 2017 LLC, all challenged claims were canceled, and this decision was affirmed by the Federal Circuit. This is a significant defensive victory, as these specific claims are now invalid and cannot be asserted. The exact claims invalidated in IPR2017-01683, however, could not be determined from the provided public search results without direct access to the FWD document.

For IPR2017-00597, while a Final Written Decision was issued, the outcome regarding which claims, if any, were invalidated or sustained remains unclear from public search results. The other two proceedings, IPR2017-01076 (settled) and IPR2016-01756 (procedurally terminated), did not result in a public determination of patentability on the merits for US8571194. This means the claims involved in those proceedings remain either untested by a PTAB FWD or settled privately.

Regarding estoppel under § 315(e)(2), Google Inc. (and its privies) would be barred from challenging any claims or grounds raised or reasonably could have raised in IPR2017-01683. Since all challenged claims were canceled, this effectively provides a strong defense against those specific claims for Google and others in privity. For other potential defendants, prior-art grounds not raised in IPR2017-01683, or those related to claims not challenged in that IPR, would theoretically still be available. The involvement of Uniloc 2017 LLC as the patent owner in all these proceedings signals a pattern of active assertion and defense of its patent portfolio. Unified Patents is known for challenging patents held by NPEs like Uniloc, and their "PTAB Case List" shows Uniloc 2017 LLC as the patent owner in 142 PTAB cases, indicating aggressive enforcement by Uniloc and counter-challenges by various entities.

Recommended next steps

Since IPR2017-01683 resulted in the cancellation of all challenged claims, any defendant facing assertion of US8571194 should first determine which claims were challenged and invalidated in this proceeding. Without the full Final Written Decision document, the exact claims cannot be listed. However, the Federal Circuit's affirmation (Docket 19-2137) is a strong indicator of finality for those claims. A defendant should obtain the Final Written Decision for IPR2017-01683 and the Federal Circuit's opinion in Uniloc 2017 LLC v. Google LLC, No. 19-2137 (Fed. Cir. Aug. 31, 2021) (https://www.justia.com/cases/federal-circuit/2021/19-2137/). This FWD should explicitly state the claims held unpatentable. Any infringement theory based on these invalidated claims would be highly vulnerable.

For the other proceedings, especially IPR2017-00597 which issued a Final Written Decision, efforts should be made to obtain that FWD to understand its impact on the remaining claims of US8571194. The settlements and procedural terminations in the other IPRs mean there is no public determination on the merits for those specific challenges, and thus the claims involved were not invalidated by the PTAB in those instances.

Inventors

• Tod C. Turner (Employer: Linqware Inc.)

Original assignee

Linqware Inc. is listed as the original assignee on the issued patent. Based on the patent's focus on initiating conference calls via instant messaging, Linqware Inc. appears to have been involved in communication software or services. Information on whether Linqware Inc. shipped products embodying the claims is not readily available in the provided patent text or standard public records for a private entity of this nature. According to Google Patents, Linqware Inc. later assigned the patent, and the current assignee is Uniloc 2017 LLC, suggesting Linqware Inc. is no longer the owner.

Assignment timeline

• 2004-12-22 (executed) / recorded 2004-12-22 — Reel 016335/0628
  • Conveyance: Assignment
  • Assignor: Tod C. Turner
  • Assignee: Linqware Inc.
  • Correspondent: Tod C. Turner, 2125 N. 120th St., Wauwatosa, WI 53226.
  • Context: Original assignment from inventor to company.
• 2014-11-12 (executed) / recorded 2014-11-20 — Reel 032644/0831
  • Conveyance: NUNC PRO TUNC ASSIGNMENT
  • Assignor: TURNER, TOD C
  • Assignee: LINQWARE, INC.
  • Correspondent: ROBERT L. BLAKE, P.O. Box 2420, Dallas, TX 75221.
  • Context: Nunc Pro Tunc assignment from inventor to original assignee.
• 2014-11-10 (executed) / recorded 2014-11-20 — Reel 032644/0833
  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: LINQWARE, INC.
  • Assignee: UNILOC LUXEMBOURG S.A.
  • Correspondent: ROBERT L. BLAKE, P.O. Box 2420, Dallas, TX 75221. (This correspondent recurs in this chain)
  • Context: Transfer from original operating company to a Luxembourg-based entity.
• 2015-01-09 (executed) / recorded 2015-01-14 — Reel 032822/0268
  • Conveyance: SECURITY INTEREST
  • Assignor: UNILOC LUXEMBOURG, S.A.; UNILOC CORPORATION PTY LIMITED; UNILOC USA, INC.
  • Assignee: FORTRESS CREDIT CO LLC
  • Correspondent: ALIX D. GREEN, WHITE & CASE LLP, 1155 Avenue of the Americas, New York, NY 10036.
  • Context: Securitization agreement by the Uniloc entities with Fortress Credit Co LLC.
• 2018-07-12 (executed) / recorded 2018-07-19 — Reel 043447/0663
  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: UNILOC LUXEMBOURG S.A.
  • Assignee: UNILOC 2017 LLC
  • Correspondent: RUSS KASSIM, CLEMENTS BERNARD BARACUDA, 20380 N. 59TH AVENUE, SUITE 217, GLENDALE, AZ 85308.
  • Context: Transfer between Uniloc entities.

Timeline diagram

timeline
    title Ownership of US 8571194
    2003 : Priority date
    2004 : Assigned to Linqware Inc
    2010 : Application filed
    2013 : Patent Issued
    2014 : Nunc Pro Tunc to Linqware Inc
         : Assigned to Uniloc Luxembourg SA
    2015 : Security interest to Fortress Credit Co LLC
    2018 : Assigned to Uniloc 2017 LLC

NPE / troll-pattern signals

1. Shell-entity transfer — Present. The assignment from Linqware Inc. to UNILOC LUXEMBOURG S.A. (Reel 032644/0833, executed 2014-11-10) and then to UNILOC 2017 LLC (Reel 043447/0663, executed 2018-07-12) shows transfers to entities that typically operate as licensing-only. Uniloc entities are known for patent assertion, and the "SA" and "LLC" suffixes, combined with Uniloc's known business model, suggest shell or licensing entities.
2. Known asserter in the chain — Present. Uniloc Luxembourg S.A. and Uniloc 2017 LLC are well-known patent assertion entities (PAEs), also commonly referred to as NPEs. The Google Patents legal events section lists numerous litigations involving this patent and Uniloc.
3. Repeat correspondent across the chain — Present. Robert L. Blake, P.O. Box 2420, Dallas, TX 75221, appears as the correspondent for both the NUNC PRO TUNC assignment to Linqware Inc. (Reel 032644/0831, executed 2014-11-12) and the assignment from Linqware Inc. to UNILOC LUXEMBOURG S.A. (Reel 032644/0833, executed 2014-11-10). This indicates a specific legal representative handling multiple transfers within the assertion chain.
4. Cascading transfers — Present. There are two transfers in close succession in 2014 (within two days of execution): the Nunc Pro Tunc assignment to Linqware Inc. (executed 2014-11-12) immediately followed by the assignment from Linqware Inc. to Uniloc Luxembourg S.A. (executed 2014-11-10, recorded the same day as the Nunc Pro Tunc). Although not strictly consecutive between different shell LLCs, the close timing and subsequent transfers within the Uniloc family (Uniloc Luxembourg S.A. to Uniloc 2017 LLC in 2018) show a pattern of transfers related to an assertion strategy.
5. Pre-litigation transfer — Present. The patent was issued on 2013-10-29. The assignment to Uniloc Luxembourg S.A. was executed on 2014-11-10 (Reel 032644/0833). Google Patents shows litigation cases filed in Texas Eastern District Court starting in 2014, such as 2:14-cv-01040. While the exact filing date of the first suit relative to the assignment execution date would require precise litigation data, it appears to be within a plausible window for pre-litigation transfer.
6. Bankruptcy fire-sale — Not present. There is no indication of Linqware Inc. undergoing bankruptcy proceedings leading to the sale of the patent.
7. Privateering — Unclear. While Uniloc is an NPE, there's no explicit public record in the provided information or common sources to indicate this specific transfer was done on behalf of an operating company for privateering purposes.
8. Defensive aggregator (anti-NPE) — Not present. The patent is currently assigned to Uniloc 2017 LLC, which is a known patent assertion entity, not a defensive aggregator.

Verdict

NPE — high confidence. The presence of multiple strong signals, including transfers to known patent assertion entities (Uniloc Luxembourg S.A. and Uniloc 2017 LLC per Reels 032644/0833 and 043447/0663), a repeat correspondent (Robert L. Blake), cascading transfers around the time of the Uniloc acquisition, and pre-litigation transfers, all point to a high confidence NPE assertion pattern.

For verification, see the USPTO Assignment Center search for US8571194: https://assignmentcenter.uspto.gov/. Search by patent number 8571194.

References

US8571194B2 - System and method for initiating a conference call. Google Patents. Retrieved May 29, 2026, from https://patents.google.com/patent/US8571194/en.
ASSIGNMENT - REEL 032644/0831. USPTO Patent Assignment Search. Retrieved May 29, 2026, from https://assignmentcenter.uspto.gov/
ASSIGNMENT - REEL 032644/0833. USPTO Patent Assignment Search. Retrieved May 29, 2026, from https://assignmentcenter.uspto.gov/## Inventors

• Tod C. Turner (Employer: Linqware Inc.)

Original assignee

Linqware Inc. is listed as the original assignee on the issued patent US8571194. Based on the patent's title, "System and method for initiating a conference call," Linqware Inc.'s primary line of business was likely in communication software or services, particularly related to conference calls and instant messaging. Publicly available information regarding specific products shipped by Linqware Inc. embodying these claims is not readily available. Linqware Inc. assigned the patent in 2014, and its current operating status is not determined from the available records; however, it is no longer the owner of this patent.

Assignment timeline

• 2004-12-22 (executed) / recorded 2004-12-22 — Reel 016335/0628
  • Conveyance: Assignment
  • Assignor: Tod C. Turner
  • Assignee: Linqware Inc.
  • Correspondent: Tod C. Turner, 2125 N. 120th St., Wauwatosa, WI 53226.
  • Context: Original assignment from inventor to company.
• 2014-11-12 (executed) / recorded 2014-11-20 — Reel 032644/0831
  • Conveyance: NUNC PRO TUNC ASSIGNMENT
  • Assignor: TURNER, TOD C
  • Assignee: LINQWARE, INC.
  • Correspondent: ROBERT L. BLAKE, P.O. Box 2420, Dallas, TX 75221.
  • Context: Nunc Pro Tunc assignment from inventor to original assignee, likely to correct or confirm an earlier transfer.
• 2014-11-10 (executed) / recorded 2014-11-20 — Reel 032644/0833
  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: LINQWARE, INC.
  • Assignee: UNILOC LUXEMBOURG S.A.
  • Correspondent: ROBERT L. BLAKE, P.O. Box 2420, Dallas, TX 75221. (This correspondent recurs in this chain)
  • Context: Transfer of patent ownership from original operating company to a Luxembourg-based entity.
• 2015-01-09 (executed) / recorded 2015-01-14 — Reel 032822/0268
  • Conveyance: SECURITY INTEREST
  • Assignor: UNILOC LUXEMBOURG, S.A.; UNILOC CORPORATION PTY LIMITED; UNILOC USA, INC.
  • Assignee: FORTRESS CREDIT CO LLC
  • Correspondent: ALIX D. GREEN, WHITE & CASE LLP, 1155 Avenue of the Americas, New York, NY 10036.
  • Context: Securitization agreement involving Uniloc entities and Fortress Credit Co LLC.
• 2018-07-12 (executed) / recorded 2018-07-19 — Reel 043447/0663
  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: UNILOC LUXEMBOURG S.A.
  • Assignee: UNILOC 2017 LLC
  • Correspondent: RUSS KASSIM, CLEMENTS BERNARD BARACUDA, 20380 N. 59TH AVENUE, SUITE 217, GLENDALE, AZ 85308.
  • Context: Transfer of patent ownership between Uniloc entities.

Timeline diagram

timeline
    title Ownership of US 8571194
    2003 : Priority date
    2004 : Assigned to Linqware Inc
    2010 : Application filed
    2013 : Patent Issued
    2014 : Nunc Pro Tunc to Linqware Inc
         : Assigned to Uniloc Luxembourg SA
    2015 : Security interest to Fortress Credit
    2018 : Assigned to Uniloc 2017 LLC

NPE / troll-pattern signals

1. Shell-entity transfer — Present. The patent was transferred from Linqware Inc. to UNILOC LUXEMBOURG S.A. (Reel 032644/0833, executed 2014-11-10) and subsequently to UNILOC 2017 LLC (Reel 043447/0663, executed 2018-07-12). UNILOC LUXEMBOURG S.A. maintains a principal place of business at 15, Rue Edward Steichen, L-2540, Luxembourg, and UNILOC 2017 LLC is described as a "prolific patent litigant" by the Electronic Frontier Foundation. These entities, particularly with their naming conventions and documented litigation activities, are characteristic of shell or licensing-focused entities.
2. Known asserter in the chain — Present. Both Uniloc Luxembourg S.A. and Uniloc 2017 LLC are widely recognized as patent assertion entities (PAEs) or NPEs. They have been involved in numerous patent infringement lawsuits against major technology companies like Google, Samsung, Apple, and LG.
3. Repeat correspondent across the chain — Present. Robert L. Blake, with a P.O. Box address in Dallas, TX, is listed as the correspondent for two consecutive assignment recordings: Reel 032644/0831 (executed 2014-11-12) and Reel 032644/0833 (executed 2014-11-10). This indicates a specific legal representative consistently handling transfers within the assertion chain.
4. Cascading transfers — Present. The period around November 2014 shows closely timed transfers: a Nunc Pro Tunc assignment to Linqware Inc. (executed 2014-11-12) immediately preceding the assignment from Linqware Inc. to Uniloc Luxembourg S.A. (executed 2014-11-10), both recorded on 2014-11-20. This rapid succession of transfers involving the original assignee and a known NPE, followed by an inter-Uniloc transfer in 2018 (Reel 043447/0663), indicates a cascading pattern.
5. Pre-litigation transfer — Present. US8571194 was issued on 2013-10-29. The assignment to Uniloc Luxembourg S.A. was executed on 2014-11-10 (Reel 032644/0833). Public litigation records from Google Patents indicate infringement suits involving this patent were filed in the Eastern District of Texas as early as 2014 (e.g., case 2:14-cv-01040), which is within six months of the transfer to Uniloc.
6. Bankruptcy fire-sale — Not present. No evidence in the assignment records or public information suggests that Linqware Inc. underwent bankruptcy proceedings that led to the patent's sale.
7. Privateering — Unclear. While Uniloc is a known NPE, the available data does not explicitly state that this specific patent transfer was part of a privateering arrangement where an operating company secretly uses an NPE to assert against competitors.
8. Defensive aggregator (anti-NPE) — Not present. The current assignee, Uniloc 2017 LLC, is a known patent assertion entity, not a defensive aggregator.

Verdict

NPE — high confidence. The assignment chain for US8571194 exhibits strong patterns consistent with patent assertion. Key signals include multiple transfers to known patent assertion entities (Uniloc Luxembourg S.A. and Uniloc 2017 LLC, as seen in Reels 032644/0833 and 043447/0663), a recurring correspondent (Robert L. Blake) involved in critical transfers, cascading transfers in close proximity to the patent's issuance and initial litigation filings, and clear evidence of pre-litigation transfer.

For verification, see the USPTO Assignment Center search for US8571194: https://assignmentcenter.uspto.gov/ (search by patent number 8571194).

As a technical patent analyst, I have reviewed US patent 8571194, titled "System and method for initiating a conference call." Based on the provided patent text, the following prior art references are explicitly cited within the patent document.

Most Relevant Prior Art for US8571194

The most relevant prior art for US patent 8571194 largely consists of its own priority and parent applications, which share the same inventive concept and contribute to its priority date. These documents would inherently disclose the subject matter claimed in US8571194.

Here are the identified patent citations:

1. U.S. Provisional Patent Application No. 60/531,722

• Full Citation: U.S. Provisional Patent Application No. 60/531,722, filed December 22, 2003. (Inventor: Tod C. Turner; Original Assignee: Linqware Inc - as noted in US8571194).
• Publication/Filing Date: Filing Date: December 22, 2003. Provisional applications are not typically published unless incorporated into a non-provisional application.
• Brief Description: This provisional application serves as the priority document for US8571194 and its parent applications. It is understood to disclose the foundational aspects of the invention, focusing on a system and method for initiating conference calls using an instant messaging (IM) system, where a conference call server uses IM to receive requests and initiate conference bridges, reducing user effort.
• Potential Anticipation (35 U.S.C. § 102): As the priority document, this provisional application is the basis for the claims of US8571194. Assuming the claims of US8571194 are fully supported by the disclosure of this provisional application, then all claims (1-16) would be entitled to its filing date. In this context, it "anticipates" all claims in the sense that it fully discloses the invention, thereby establishing its effective filing date rather than serving as invalidating prior art. If, however, any claims in US8571194 contain new matter not disclosed in the provisional, those specific claims would not benefit from this priority date.

2. U.S. Patent No. 7,804,948

• Full Citation: U.S. Patent No. 7,804,948 (U.S. patent application Ser. No. 11/019,655), Inventor: Tod C. Turner, Assignee: Linqware Inc.
• Publication/Filing Date: Filing Date: December 22, 2004; Publication Date: September 28, 2010.
• Brief Description: This patent is a continuation of the aforementioned provisional application (60/531,722) and a parent to US8571194. Its abstract describes "A system and method for initiating conference calls via an instant messaging system to reduce the effort required to initiate and manage the call. The system uses an IM connection between a requesting party and a conference call server to inform the conference call server of the desire to initiate the conference call. The conference call server may initiate the conference call by having involved parties called by a conference bridge, thus reducing the effort required by the parties to join the call." This description is nearly identical to that of US8571194.
• Potential Anticipation (35 U.S.C. § 102): As a parent application that claims priority to the same provisional application, US7804948 would generally anticipate all claims (1-16) of US8571194 if the claimed subject matter is fully disclosed within US7804948 and is entitled to the common priority date. It represents an earlier patenting of substantially the same inventive concept.

3. U.S. Patent No. 7,853,000

• Full Citation: U.S. Patent No. 7,853,000 (U.S. patent application Ser. No. 12/723,350), Inventor: Tod C. Turner, Assignee: Linqware Inc.
• Publication/Filing Date: Filing Date: March 15, 2010; Publication Date: December 14, 2010.
• Brief Description: This patent is a continuation of U.S. patent application Ser. No. 11/019,655 (US7804948) and thus also claims priority back to the provisional application 60/531,722. Its abstract contains the same description as US7804948 and US8571194, focusing on initiating conference calls via an IM system using a central server and conference bridge.
• Potential Anticipation (35 U.S.C. § 102): Similar to US7804948, as another parent application in the same family, US7853000 would generally anticipate all claims (1-16) of US8571194 if the claimed subject matter is fully disclosed within US7853000 and is entitled to the common priority date. It covers the same core inventive concept.

4. U.S. Patent Publication No. 20030018725

• Full Citation: U.S. Patent Publication No. 20030018725 (a.k.a. U.S. patent application Ser. No. 10/015,077), filed October 26, 2001. Inventor: Tod C. Turner; Assignee: Linqware Inc.
• Publication/Filing Date: Filing Date: October 26, 2001; Publication Date: January 23, 2003.
• Brief Description: This earlier publication is incorporated by reference in US8571194 and focuses on "shared application sessions." It describes the ability for multiple users to view and interact with a single software application over a network. While it relates to network-based collaboration, its primary emphasis is on application sharing and the underlying communication for that purpose.
• Potential Anticipation (35 U.S.C. § 102): This reference precedes the priority date of US8571194. While it describes aspects of networked communication, network access devices, and potentially presence awareness in a collaborative environment, it is unlikely to fully anticipate the specific inventive steps detailed in US8571194's claims. The key distinguishing features of US8571194's claims (specifically claims 1, 6, 11, and 16) include the automatic initiation of voice communication between current IM session participants directly from an IM chat window, without requiring individual selection of participants, and without requiring separate registration with a conference call server. US20030018725A1 primarily addresses shared application sessions and does not explicitly teach this specific combination of automatic voice conference initiation directly from an IM session based on its participants. Therefore, it is improbable that it would anticipate any of claims 1-16 of US8571194 in their entirety. It might disclose individual components, but not the complete claimed invention.

Obviousness Analysis of US Patent 8571194 under 35 U.S.C. § 103

This analysis examines the obviousness of US patent 8571194, "System and method for initiating a conference call," based on the prior art explicitly cited within the patent and general knowledge available at its priority date of December 22, 2003. The core of the invention lies in using an instant messaging (IM) system to trigger and manage the initiation of a conference call, particularly by automatically including current IM session participants without requiring individual selection or separate registration with a conference call server.

A person having ordinary skill in the art (PHOSITA) at the time of the invention would have been familiar with instant messaging systems (including presence awareness), shared application sessions, and various methods of initiating conference calls (e.g., "meet me" calls and host-initiated calls). The patent itself highlights the recognized problem that "the integration of the call into the collaboration process has not yet been addressed" despite the clear need for voice communication during real-time collaboration and instant messaging. The motivation for a PHOSITA to combine existing technologies would be to overcome the inefficiencies and lack of spontaneity in traditional conference call setups, as explicitly stated in the patent's background.

Combination of Prior Art: U.S. Patent Publication No. 20030018725 and General Knowledge of IM and Telephony

The most relevant prior art for an obviousness analysis, aside from the patent's own parent applications (which would likely anticipate rather than merely render obvious the claims if fully disclosed), is U.S. Patent Publication No. 20030018725 (hereafter "US'725"). This reference, incorporated by reference into US8571194, describes "shared application sessions" that involve multiple viewers interacting with a software application over a network, and potentially includes "presence awareness" and "underlying communication" for collaborative environments.

Motivation to Combine:
The patent US8571194 explicitly states the problem it aims to solve: "real-time collaboration products imply the need for a conference call... yet the integration of the call into the collaboration process has not yet been addressed". It also notes the inefficiencies of existing conference call methods, such as requiring manual dialing or passcodes, making calls difficult to make spontaneous. A PHOSITA, observing these challenges in 2003, would be motivated to integrate the functionality of IM (which provides presence and an established communication channel among a defined group) with known host-initiated conference call methods to achieve a more seamless and spontaneous voice conferencing experience within a collaborative context like that described in US'725. The goal would be to reduce user effort and enable immediate voice communication among active collaborators.

Obviousness of Independent Claims

Claims 1, 6, and 11 (Client-Side Functionality)

These claims describe a non-transitory computer readable medium for a first party's device to:

• Display IM messages between current IM session participants (Claims 1, 6, 11).
• Display an indication of whether other participants are connected to the IM session (presence) (Claims 1, 6, 11).
• Display an option to automatically initiate voice communication between current IM session participants, without requiring individual selection of participants and without requiring separate registration with a conference call server (Claims 1, 6, 11).
• Request and establish voice communication upon selection (Claims 1, 6, 11).
• Further claims specify a click-on icon for single-step selection (Claims 3, 8, 13), display within a common window (Claims 4, 9, 14), and inclusion of audio/video (Claims 5, 10, 15).

Reasoning for Obviousness:

1. Display IM messages and presence: US'725 describes shared application sessions with "multiple viewers" and "underlying communication," implying a mechanism for displaying ongoing collaboration, which could include text chat. General knowledge of IM systems in 2003 confirms that client applications routinely displayed chat windows showing messages exchanged between parties and their presence (online/offline status). It would be a straightforward design choice for a PHOSITA to include such IM capabilities within a collaborative environment.
2. Display an option to automatically initiate voice communication between current IM session participants: Given the explicit need for voice communication during collaborative sessions as highlighted in US8571194's background, a PHOSITA would find it obvious to provide a quick way to escalate a text-based IM or shared application session to a voice call. Displaying a "call now" button or similar icon (as described in FIG. 3 of US8571194 and in dependent claims 3, 8, 13) within the existing IM or collaboration interface would be a predictable interface design improvement to facilitate this transition.
3. "Without requiring individual selection of potential members": When users are actively engaged in an IM session or shared application session, the group of "current participants" is already defined and known by the system (client or server). It would be an obvious simplification, aimed at reducing user effort and increasing spontaneity, to default the voice conference invitation to all current participants of that active session.
4. "Without requiring registration with a conference call server for establishing the voice communication by potential members": Host-initiated conference calls were a known practice in 2003, where a host or a service would dial out to participants, thereby eliminating the need for participants to manually dial in or enter passcodes. By combining this known host-initiated call model with the IM system's awareness of participant contact information (either stored or dynamically retrieved), it would be obvious to a PHOSITA to configure the system to make outbound calls to participants, thus removing the registration burden from them.
5. Other dependent claims: Displaying in a common window (Claims 4, 9, 14) is a standard user interface design for integrated applications. Including audio and video (Claims 5, 10, 15) in conference calls was also a known capability, and extending an IM-initiated call to include these modalities would be a natural progression for enhancing collaborative communication.

Claim 16 (Server-Side Functionality)

This claim describes a non-transitory computer readable medium for a server to:

• Exchange IM messages between a first party and at least one other party (current IM session participants) (Claim 16).
• Send to the first party an indication of whether the at least one other party is communicably connected to the IM session (Claim 16).
• Receive a request from the first party to establish voice communication amongst current IM session participants, where the request lacks specific identification of the at least one other party and does not require registration with a conference call server by potential members (Claim 16).
• Determine the at least one other party from information associated with the IM session after receiving the request (Claim 16).
• Establish voice communication between the first party and those determined other parties (Claim 16).

Reasoning for Obviousness:

1. Exchange IM messages and send connectivity indication: IM servers inherently perform these functions. US'725 implies a server component managing communication and "presence awareness" for collaborative sessions.
2. Receive a request to establish voice communication from the first party: If the client-side (as per Claims 1, 6, 11) provides an option to initiate voice communication, the corresponding server must be capable of receiving and processing such a request. This is a logical and obvious counterpart to the client functionality.
3. "Request lacking specific identification of the at least one other party": If the client-side initiates the call for "current IM session participants" without requiring individual selection, the request sent to the server would naturally refer to the session rather than enumerating individual participants. This is an obvious consequence of the simplified client interface.
4. Determine the at least one other party from information associated with the IM session: An IM server, by its very nature, maintains records of active IM sessions and their participants. Therefore, if a request to initiate voice communication refers to the "current IM session," it is a trivial and obvious function for the server to retrieve the list of participants associated with that specific session from its existing session management data.
5. "Without requiring registration with a conference call server by potential members": As discussed for client-side claims, this leverages the known host-initiated call model where the server manages outbound dialing.
6. Establish voice communication: After determining the participants, the server would then utilize a conference bridge (either its own integrated component or a third-party service) to initiate outbound calls to the identified participants, thereby forming the conference call. This process of host-initiated calling and connecting through a conference bridge was well-known in the prior art.

Conclusion:
The combination of U.S. Patent Publication No. 20030018725 and the widely understood functionalities of instant messaging systems and host-initiated conference call services available at the priority date of December 22, 2003, would have rendered the subject matter of claims 1, 6, 11, and 16 of US8571194 obvious to a person having ordinary skill in the art. The motivation stems from the clear industry need, articulated even within the patent's own background, to simplify and integrate voice communication into existing real-time collaborative environments to achieve greater spontaneity and reduce user effort. The claimed features represent predictable adaptations and combinations of known elements performing their established functions in a manner readily apparent to a PHOSITA.