US 8639634

I'll search for authoritative information about this patent, including any litigation or CAFC docket activity.

Let me check for litigation/docket activity and verify the claim set.

Let me verify the full independent claim set and confirm there is no litigation.

US Patent 8,639,634 — Analyst Summary

Bottom line: No litigation, PTAB, or Federal Circuit activity involving US 8,639,634 was found in my searches. Searches for "'634 patent" litigation return different patents (e.g., 7,629,634 and 7,812,409 — Force-MOS v. ASUSTeK; 7,543,634; 8,938,634 — Invincible IP), which are not this patent and are not related. I found no CAFC 2026 docket naming 8,639,634; I cannot affirmatively rule out a pending case that is not indexed in the sources I could reach.

Bibliographic data (per Google Patents / USPTO public record)

Abstract (as issued)

A computer system and computer-implemented method for management of employee leave and absence policies. The system receives data related to an employee leave claim at a single point of contact (e.g., a single telephone number, web address, or fax number usable for any type of leave, including workers' compensation, short-term disability, long-term disability, and other leave). The system prompts a user for claims relating to multiple types of leave, furnishes data to separate computer systems that administer the different leave types, and provides communications between those separate computer systems responsive to data received from one of them.

Plain-language overview of the independent claims

• Claim 1 — Computer system for employee leave management. A processor receives (over a network) a request to start a claim for one of several leave types; determines the leave type (at least a first vs. a second type); causes the user device to prompt for data specific to that type; routes the leave data to the matching backend — a workers' compensation administration system for WC leave or a short-term disability administration system for STD leave; and stores the claim data. Notably, it also must receive, from the WC system, data indicating a denial of a WC claim for an injury and, in response, signal the STD system to initiate an STD claim for that same injury.

• Claim 11 — Computer-implemented method. The method counterpart to Claim 1: receiving the leave request, determining the leave type, causing type‑specific prompts, and storing the claim data. (The snippet available to me was truncated before any routing/denial‑to‑STD limitations; I cannot confirm whether Claim 11 includes those steps.)

• Claim 17 — Non‑transitory computer‑readable medium. Instructions that, when executed, cause the processor to perform the intake / type determination / type‑specific prompting / storing steps. (Text truncated in the source; I cannot confirm whether the routing and WC‑denial‑triggered‑STD‑initiation limitations are included.)

• Claim 20 — Computer system for administration of employee leave. A comprehensive leave management system receives data indicating an employee leave claim, determines from at least two claim types whether it is a workers' compensation claim or a short-term disability claim, and, based on that determination, outputs a signal routing the data to the corresponding administration system.

• Claim 22 — Computer-implemented method. Receive claim data at a comprehensive leave management system; determine the claim type (WC vs. STD) based on rules stored in memory; route the data to the matching administration system; and, on receiving from the WC system data indicating denial of a WC claim for an injury, signal the STD system to initiate an STD claim for that injury.

• Claim 24 — Non‑transitory computer‑readable medium of a handheld wireless device with a display. Instructions that cause the handheld's processor to: prompt (via the display) for employee‑leave‑claim data; receive responses via the device UI; determine the leave type from the received data; further prompt for data particular to that leave type; receive those responses; determine eligibility for the leave based on the received data; if eligible, output a signal to a leave management server carrying employee identity, employer identity, leave data, and an eligibility indication; and display a message indicating eligibility. (I could not confirm the exact numbering/terminal claim here — the source listing was truncated after claim 24, so the total claim count and whether a claim 25 exists are uncertain.)

What the independent claims collectively protect

The core inventive concept asserted in the claims is claim-type triage and routing across administratively separate leave systems, coupled with a cross-system hand‑off: intake at one point → classify the leave → prompt for type‑specific data → route to the WC or STD administration system → and, on denial of a WC claim, automatically seed an STD claim for the same injury. Claims 1 and 22 uniquely capture that last denial‑to‑STD step; Claims 20 and 24 focus on the determination/routing and on the mobile eligibility determination respectively.

Uncertainty flags

• Claim text for Claims 11, 17, and 24 (and the total claim count) was truncated in the sources I could retrieve; the overviews above for those claims are partially inferred from the specification's Summary section and should be verified against the granted claim set.
• The Google Patents "Legal status: Active" and the 2031‑08‑17 expiration are the database's assumptions, not legal conclusions; maintenance‑fee status was not independently verified.
• No assignee change (e.g., to a litigation entity) was found; current assignee remains Hartford Fire Insurance Company on the record I consulted.
• No CAFC, district court, or PTAB proceeding involving US 8,639,634 was identified. Any "'634" case hits were unrelated patents and should not be conflated with this one.

I'll search multiple litigation-focused sources for US patent 8639634.

Initial searches returned nothing. Let me try the litigation-specific portals and other query formulations.

Let me search additional litigation-specific sources and try Hartford-centric queries.

Summary of findings

No litigation involving U.S. Patent No. 8,639,634 appears to be publicly recorded. I searched litigation-oriented sources (Unified Patents litigation portal, Docket Alarm, Justia dockets) and general web sources using the exact number 8639634 and the formatted 8,639,634, and found no district court case, ITC investigation, PTAB proceeding, or CAFC appeal in which the '634 patent is identified as an asserted or challenged patent.

What the searches did and did not return

Important caution on false positives: several results referenced different patents with "863" in the number — e.g., the Exmark '863 patent in Exmark v. Briggs & Stratton (turf-mower baffle patent) and Patent 11,448,863 in IPR2024-00839 (micro-optic security). Per the strict instruction to interpret identifiers literally, none of these is US 8,639,634, and I have excluded them as non-responsive.

Related but distinct Hartford litigation (does NOT name the '634 patent)

One Hartford-related docket surfaced, but it does not appear to involve the '634 patent:

• Case: Hartford Fire Insurance Company et al v. Intellectual Ventures I LLC et al
• Case number: 1:2026cv00392
• Jurisdiction: U.S. District Court for the District of Delaware
• Plaintiffs: Hartford Fire Insurance Company and The Hartford Insurance Group, Inc.
• Defendants: Intellectual Ventures I LLC, Intellectual Ventures II LLC, Callahan Cellular LLC, and others
• Cause of action: 35 U.S.C. § 271 Patent Infringement (declaratory judgment action)
• Filed: 2026 (docket listed 2026; Bloomberg Law coverage dated April 8, 2026)
• Status: Pending; a declaratory-judgment/preemptive action filed after IV demand letters to insurers over alleged use of open-source software
• Sources: https://dockets.justia.com/browse/state-delaware/court-dedce/noscat-?page=18 ; https://news.bloomberglaw.com/ip-law/insurers-preemptively-sue-patent-monetizer-after-demand-letters

This case is Hartford's own DJ action against IV concerning open-source-software allegations. It does not identify US 8,639,634 (the employee-leave administration patent) as an asserted patent, so it should not be reported as '634 litigation.

Context for the '634 patent

Per the patent record, US 8,639,634 B2 ("System and method for administration of employee leave") is assigned to Hartford Fire Insurance Company, naming inventors Karen J. Nelson, Marjorie E. Savage, and Fredrick J. Weber, with priority to provisional 61/368,304 (filed 2010-07-28) and a continuation family including US 2013/0110736 A1 and US 2014/0114874 A1. It is a business-methods patent (G06Q 10/1057) — the type of asset that historically is asserted by the owner against others, not typically a target of NPE suits. I found no record of Hartford ever asserting it.

Bottom line

• Known litigation for US 8,639,634: none found.
• I cannot rule out an obscure or recent filing that is not indexed in the sources reachable by these searches, and I cannot verify PACER directly here. If a definitive negative is required, the authoritative checks are: (1) PACER's patent docket search, (2) the CAFC docket, and (3) the USPTO Patent Center "Litigation" / assignment records for Reel/Frame history on 13/025,498. I recommend confirming via those primary sources rather than relying solely on the aggregated portals above.

I'll verify the structured data against public sources before reporting.

The first pass returned mostly noise from unrelated "‑634" patents (Acceleration Bay's 6,829,634, BlackBerry's 8,209,634, etc.). Let me search with more targeted terms.

Let me run one final confirmation search targeting the patent owner and CBM-type challenges specifically.

AIA Trial Proceedings — US Patent 8,639,634

Proceedings overview

Total AIA trial proceedings on file: 0 (zero). The USPTO Open Data Portal returns no IPR, PGR, or CBM proceedings for US 8,639,634 as of the most recent ingest, and my independent web searches surfaced no PTAB proceeding naming this patent (searches for the patent number and owner returned only unrelated "‑634" patents — e.g., Acceleration Bay's US 6,829,634 and BlackBerry/Snap's US 8,209,634 — which are different patents entirely and must not be conflated with this one). Because there are no proceedings, the breakdown is: active 0 / claims invalidated 0 / claims sustained 0 / settled 0 / institution denied 0.

Defensive posture: the patent stands entirely untested at the PTAB. The bottom line for a defendant is not "the patent is hardened" and not "the claims are dead" — it is "no one has fired at this patent yet, so all 24 claims are live and the validity record is a blank slate." That cuts both ways: the patent owner has no IPR survivability to point to, but you also have no roadmap of the Board's claim constructions or a prior-art attack to build on. An IPR is an available, un-estopped option if you are (or are about to be) served with a complaint.

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Proceedings

No PTAB proceedings exist to describe. There are no proceeding numbers, panels, institution decisions, final written decisions, settlements, or Federal Circuit appeals to report for US 8,639,634. I will not fabricate proceeding numbers to fill this section.

What I can confirm about the patent itself (from the specification and bibliographic record), which frames the defensive analysis:

• Patent: US 8,639,634 B2 — "System and method for administration of employee leave."
• Assignee / Patent Owner: Hartford Fire Insurance Company (Hartford, CT).
• Inventors: Karen J. Nelson; Marjorie E. Savage; Frederick J. Weber.
• Application: 13/025,498, filed 2011-02-11; provisional 61/368,304 filed 2010-07-28 (priority date).
• Granted: 2014-01-28. Adjusted expiration: 2031-08-17 (per Google Patents legal-status data — a long runway of remaining term).
• Claims: 24 total.
• Classification: G06Q 10/1057 (Human resources — benefits/employee welfare) — i.e., a software/business-method patent. That classification is precisely the profile that historically attracted CBM review, and it is also the profile that routinely attracts § 101 / § 103 IPRs when asserted.
• Related family: continuations/continuation-in-parts exist, including US 2013/0110736 A1 ("Computer system and method for processing of data relating to employee absence," Ser. No. 13/722,352) and US 2014/0114874 A1 (Ser. No. 14/145,403). If a campaign develops, expect the owner to assert across the family, not just this patent.

Caveats on the "zero" finding: the ODP structured block is the canonical source and states no proceedings; my web searches were consistent with that but are not a substitute for a docket-complete check. Patent-office data on recently filed, not-yet-instituted petitions can lag. Before relying on this for a litigation decision, confirm against PTAB E2E (https://ptacts.uspto.gov) and the patent's "Related Matters"/"Litigation" tabs on Google Patents (https://patents.google.com/patent/US8639634/en).

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Strategic summary

Claim status: 100% UNTESTED. No claim of US 8,639,634 has been canceled, confirmed, or construed by the PTAB. Claims 1–24 — including every independent claim — remain presumptively valid under § 282 and enforceable. There is no narrowing of the kind an IPR would have produced, so the patent owner is asserting the full original scope with the full original statutory presumption intact. The absence of any validity adjudication also means there is no estoppel, no adverse claim construction, and no prosecution-disclaimer/amendment record generated by an AIA trial.

Estoppel landscape: none attaches. Because no petitioner has been through an AIA trial on this patent, § 315(e)(2) estoppel is empty — neither against any party nor against any privy. Conversely, a defendant is fully free to file an IPR on any § 102/§ 103 ground. The controlling clock is § 315(b): the one-year bar runs from service of a complaint alleging infringement. If you have already been served, count the days; if you have not, the window is open and runs one year from service. Note the CBM escape route is closed — the CBM transitional program sunset on 2018-09-16, so the only AIA vehicle left for this patent is IPR (and PGR is unavailable because the patent issued before the PGR window; the patent's 2011 filing / 2010 priority makes it a pre-AIA patent for substantive purposes, but IPR availability is not affected by pre/post-AIA status).

Pattern signals: none. There is no repeat petitioner, no serial-IPR dynamic, no defensive-aggregator footprint (no Unified Patents–style filing), and no PTAB-then-Federal-Circuit appellate track record for this patent. That is itself informative: this patent is an unasserted-in-volume, untested business-method patent. A § 101 eligibility attack (Alice/Mayo) is not available in an IPR — IPRs are limited to §§ 102/103 "prior art only" grounds (and certain § 112 issues only where they were raised at institution) — so eligibility must be litigated in district court. That asymmetry matters: the strongest modern attack on a G06Q claims-recitation patent has to be run in the district court, not at the Board.

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Recommended next steps

• No PTAB activity exists. The absence is the signal itself: this patent has never been stress-tested. A well-asserted patent eventually attracts IPRs; the fact that this one has not yet had an AIA proceeding suggests either limited prior assertion activity or that any prior disputes were resolved (e.g., settlements or license) before petitions were filed — which I could not confirm from the record and do not assert as fact.
• If you have been served with a complaint citing this patent, calendar the § 315(b) one-year bar immediately, and treat IPR as a live option. Because the patent is classified G06Q 10/1057 (human-resources/benefits software), build the prior-art search around 2007–2010 employee-leave/absence-management, FMLA-tracking, and unified-claims-intake systems — the specification's own cited references (e.g., Synchrony Integrated Absence Management, Oct. 2006) are a starting map, since they are of-record art the examiner considered.
• Preserve the § 101 defense for district court. An IPR cannot reach Alice/§ 101. If your theory is that the claims are directed to an abstract idea (administering leave and routing claims data), that must be raised under § 101 in litigation, not at the PTAB — plan the parallel tracks accordingly.
• If the patent owner asserts claims, demand the FWD-style record that does not exist. There is no Final Written Decision to quote and no claim-level disposition to rely on; any assertion of this patent comes with zero PTAB validation history. That is a fair point to press on the patent owner's reasonableness (and, if relevant, a § 285 / Rule 11 counterweight), but do not overstate it — untested does not mean invalid.
• Verify before relying. Re-confirm the zero count against PTAB E2E (https://ptacts.uspto.gov) and the Google Patents "Similar/Litigation" views for US 8639634 (https://patents.google.com/patent/US8639634/en), since recently filed petitions can post-date the ODP ingest.

Bottom line: There is nothing to quote from a PTAB decision because there is no PTAB decision. The patent has never been challenged in an AIA trial, all 24 claims are live through 2031-08-17, and an IPR (grounds limited to §§ 102/103) remains an un-estopped option for a defendant inside the § 315(b) window — with any § 101 challenge reserved to district court.

I'll verify the assignment record before writing anything.

Verification note before the findings

I searched for the USPTO Assignment Center record for US 8,639,634 / App. 13/025,498 and for any post-issuance assignment of it. My retrievable sources returned no reel/frame-level assignment data for this patent — the searches were dominated by unrelated "-634" patents and by unrelated security-interest recordings for other companies (Security First Corp., Inventory, Inc., etc.). I will therefore not invent reel/frame numbers. Where the record is blank, I say so.

What is on the record, from the patent's own legal-events block (Google Patents, fetched 2026‑09‑24), is a single assignment event at filing:

2011‑02‑11 — Assigned to HARTFORD FIRE INSURANCE COMPANY; ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS). Assignors: NELSON, KAREN J.; SAVAGE, MARJORIE E.; WEBER, FREDRICK J.

No further assignment, security agreement, release, merger, or change-of-name recording appears in the legal-events history I could reach.

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Inventors

The trio assigned to Hartford on the same day the application was filed (2011‑02‑11), which is the standard pattern for employee inventors in a corporate patent program — the assignment was executed at filing, not later.

Pattern check — inventor departures: No data. I found no evidence in the reachable record of any inventor leaving Hartford, and no evidence of a post-issuance inventor-side acquisition. I cannot affirm or deny departures; nothing in the assignment record suggests a fire-sale precursor.

Contradiction flag: The previously generated PTAB section spelled the third inventor "Frederick J. Weber." The authoritative patent text (and the assignment-of-interest entry) spells him "Fredrick J. Weber" — no "e." The earlier section's spelling should be treated as an error to correct, not as a second inventor.

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Original assignee

Hartford Fire Insurance Company — the entity named on the issued patent (and identified as both original and current assignee in the record).

• Line of business: Large U.S. property & casualty and group benefits insurer; the parent, The Hartford Financial Services Group, Inc., is a public company. The patent sits squarely in Hartford's insurance-operations stack — the specification repeatedly frames the system as an insurance company computer system (e.g., "Hardware server 1640 … such as an insurance company computer system") administering leave on behalf of employer clients.
• Product embodying the claims: Hartford is a long-standing provider of group benefits that include absence/leave management and disability administration services, which is the commercial activity the specification describes. I could not verify in this session a specific branded product or a specific published claim chart tying the issued claims to a shipped offering; treat "ships a product embodying the claims" as plausible but unverified.
• Current status: Operating. No bankruptcy, dissolution, or acquisition of Hartford Fire Insurance Company was found. It remains a going-concern insurer and the recorded owner.

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Assignment timeline

Chronological list of every recorded assignment:

• 2011‑02‑11 (executed) / recorded 2011‑02‑11 — Reel not retrieved / not published in the sources available to me
  • Conveyance: Assignment of Assignors' Interest (assignment of invention/application)
  • Assignor: Karen J. Nelson; Marjorie E. Savage; Fredrick J. Weber (individually)
  • Assignee: Hartford Fire Insurance Company
  • Correspondent: Not retrieved. The legal-events entry is abbreviated ("SEE DOCUMENT FOR DETAILS") and does not name the recording correspondent. I have no attorney/firm of record to report, and I will not guess one. Because there is only one link in this chain, the "recurring correspondent" test is inapplicable regardless — there is no recurrence to detect.
  • Context: Initial corporate assignment. Inventors assigned their rights to their employer on the filing date. This is ordinary employee-invention practice, not an acquisition, reorg, securitization, or transfer-to-asserter.

Family note (not assignments): Google Patents lists priority links to Ser. Nos. 13/722,352 (pub. US 2013/0110736 A1) and 14/145,403 (pub. US 2014/0114874 A1). Those are continuation-family filings of the same applicant, not recorded ownership transfers. I did not retrieve separate assignment records for them; they are very likely on the same Hartford-employee-assignment footing, but I have not verified that.

No post-issuance activity. There is no recorded security interest, lien, release, merger, change of name, or outright transfer after the 2014‑01‑28 grant. If the Assignment Center holds additional entries, they were not reachable by my searches.

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Timeline diagram

timeline
    title Ownership of US 8639634
    2010 : Provisional filed by inventors
    2011 : Application filed 11 Feb
         : Inventors assign to Hartford Fire Insurance
    2014 : Patent issued 28 Jan
    2031 : Scheduled expiration 17 Aug

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NPE / troll-pattern signals

Cross-reference checks attempted: Google Patents legal events, litigation/PTAB portals (Unified Patents, Docket Alarm, Justia), and general web. SEC filing cross-reference: no 10‑K/8‑K disclosure of a patent sale of this asset was surfaced. The patent is not individually material to a company of Hartford's size, so its absence from SEC disclosure is expected and is not evidence of anything.

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Verdict

Insufficient data (only the original assignment) — which, on these facts, is the reassuring form of that verdict.

Justification: The complete ownership record I can verify consists of one entry — the 2011‑02‑11 assignment of inventors Nelson, Savage, and Weber to Hartford Fire Insurance Company, recorded contemporaneously with the 2011‑02‑11 filing of App. 13/025,498 — and no post-issuance assignment, security interest, merger, or release. A chain that ends where it began, at a solvent operating insurer, is the inverse of an NPE chain: there is no shell LLC, no known asserter, no cascade, no pre-suit transfer, and no defensive-aggregator purchase. The verdict is "insufficient data" strictly because the rubric reserves that label for a record showing only the original assignment — not because anything suspicious is missing.

Two honest caveats. (1) I could not retrieve reel/frame numbers, the recording correspondent, or a transaction-level printout from the Assignment Center during this session; those fields are blank above rather than filled by inference. (2) The record I could reach shows no additional assignments, but Assignment Center output can lag and I could not query PACER or PTAB E2E directly. Confirm at the primary source before relying on this for a transaction: https://assignmentcenter.uspto.gov/ (or https://assignment.uspto.gov/patent/index.html), searching patent number 8639634 or application 13/025,498, and check the "Assignments" tab on https://patents.google.com/patent/US8639634/en.

Practical read: if you are evaluating this patent for acquisition or as a target, the diligence question is not "who is the NPE behind it" — it is "will Hartford sell it, and on what terms." On the current record, Hartford is the owner of an unasserted, never-PTAB-tested business-method patent with ~5 years of term remaining to 2031‑08‑17.

I'll research the prior-art references cited on US 8,639,634. Let me start with searches for the patent's citation record and the reference documents themselves.

I found the Justia citation list. Let me pull the complete "Referenced Cited" set and get details on each reference.

I've stopped tool use per the step limit. Here is the prior-art analysis based on what I could retrieve. Important framing up front: because my retrieval was partly truncated and the reference texts for two of the five patent documents could not be fully verified, I have flagged confidence levels explicitly rather than filling gaps with invention.

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Prior Art Cited on US Patent 8,639,634

0. Patent identification (the searched document)

The reference list below is the patent's "References Cited" front-page set as mirrored on the Justia record (https://patents.justia.com/patent/8639634). A listing of record is not a finding of anticipation — it means the examiner cited or considered the document. Because the '634 patent issued with these references on its face, the examiner necessarily did not find any one of them to anticipate the issued independent claims; the § 102 mapping below is therefore a defensive/hypothetical analysis, and I mark where it is weak.

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1. U.S. Patent Documents

(a) US 7,974,857 B2 — Fischer et al. — verified

• Full citation: US 7,974,857 B2, "Unemployment insurance management," inventors Thomas M. Fischer et al., assignee Accenture Global Services Limited; App. No. 10/733,251, filed 2003-12-12; granted 2011-07-05.
• Description: A system for handling unemployment insurance (UI) built on a unified database containing both UI benefit data and UI tax data; a functional layer evaluates a claimant's benefit request against the claimant's benefit status and the employer's tax status; an access channel supports telephone contact center, web self-service, and OCR of scanned paper documents; a "unified desktop" with scripted pop-up screens for workers; an external interface to state/federal agencies; a reporting layer.
• § 102 potential: Low for the independent claims; moderate for dependent intake claims. The only arguable overlap is the multi-channel single intake concept (phone / web / OCR) and the unified record concept. It has no employee-leave-type determination, no type-specific prompting, no routing to a workers'-comp (WC) vs. short-term-disability (STD) administration system, and no WC-denial→STD-initiation hand-off. It is not anticipatory of independent claims 1, 11, 17, 20, 22, or 24. Best used as § 103 background for the "single point of contact / unified database" limitation.

(b) US 2005/0060174 A1 — Heyward et al. — title/abstract not fully verified

• Full citation: US 2005/0060174 A1 (published 2005-03-17), inventors Heyward et al.; absence-management subject matter (appears in the citing/“Cited By” trail of the Hartford family, which confirms the '634 family cites it).
• Description (moderate confidence): An absence-management system/method publication — i.e., intake and processing of employee absence events. This is topically the closest patent reference to the '634 intake concept.
• § 102 potential: The strongest of the five for § 102 against the intake/absence-data aspects, but I could not verify its disclosure in enough detail to map it to specific claims. A reference titled/characterized as "absence management systems and methods" could plausibly reach claims directed to receiving an absence/leave request and processing it, but it almost certainly does not disclose the two limitations the examiner allowed over — (i) routing the claim to a separate WC vs. STD administration computer system, and (ii) initiating an STD claim upon WC denial for the same injury. Verify the full text before relying on this.⚠

(c) US 2006/0224478 A1 — Harbison et al. — not verified

• Full citation: US 2006/0224478 A1 (published 2006-10-05), inventors Harbison et al.
• Description: I could not retrieve the title/abstract of this publication in the searches run. I will not invent one. It is a mid-2000s benefits/absence-management-family publication by its position in the list, but that is inference, not fact.
• § 102 potential: Cannot be assessed on the available record. Retrieve the document directly (USPTO Patent Public Search / Google Patents US20060224478) to determine its disclosure before asserting any § 102 mapping.⚠

(d) US 2008/0195512 A1 — Klebanoff et al. (Workbrain Inc.) — verified

• Full citation: US 2008/0195512 A1, "System and method for administering consecutive and concurrent leaves," inventors Klebanoff et al., applicant Workbrain Inc.; published 2008-08-14.

• Description: A "leave policy manager" that stores leave policies each specifying a leave sequence of one or more leaves, each with a balance; the processor determines an absence and its length, determines the applicable leave policy, determines the position in the leave sequence, and updates balances. Expressly contemplates concurrent and consecutive leaves, and enumerates leave types including FMLA, State FML, Military, Jury Duty, Short Term Disability, Long Term Disability, Vacation, Sick, Pregnancy Disability, Education, Bereavement, Personal Day, Sabbatical, plus statutory (federal/state/provincial) and corporate leaves. Claim 22 recites that a segment may correspond to one of FMLA, State FML, Military, Jury Duty, STD, LTD, Vacation, Sick, etc.

• § 102 potential: The most topically overlapping reference. It is strong § 102/§ 103 art against any claim reciting administration/tracking of multiple leave types (including FMLA running concurrently with STD/LTD) and against dependent claims reciting leave-type rules and balances. However, its architecture is a single leave-policy engine with balances — it does not disclose:

  • intake at a single point of contact that determines the leave type and causes type-specific prompts;
  • outbound routing of claim data to separate WC vs. STD administration computer systems; or
  • the WC-denial → STD-initiation hand-off.

  On the record available, it does not anticipate independent claims 1, 20, or 22 (which require routing/hand-off), but it is the leading candidate for a § 103 combination, and it may anticipate narrower dependent claims reciting concurrent-FMLA/STD leave tracking.

• Note: The WoW/Workbrain reference also appears in the "Cited By" trail of US 2005/0060174 (search result), consistent with its being family-adjacent literature.

(e) US 2010/0036671 A1 — Chu et al. — not verified

• Full citation: US 2010/0036671 A1 (published 2010-02-11), inventors Chu et al.
• Description: Not verified in the searches run; no title/abstract retrieved. No inference offered.
• § 102 potential — plus a date problem: Even setting disclosure aside, this is the weakest on dates. Published 2010-02-11, it is exactly one year before the 2011-02-11 non-provisional filing — arguably not "more than one year" before, so it likely does not qualify as a § 102(b) statutory bar measured from the non-provisional. It would need to serve as § 102(a)/(e) art, depending on its own underlying filing date relative to the '634 priority date (2010-07-28). Retrieve both the publication and its filing data before using it.⚠

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2. Other (Non-Patent) References

(f) "Synchrony Integrated Absence Management" — Travelers Insurance Company, Hartford, CT, Oct. 2006

• Citation: Synchrony Integrated Absence Management, Travelers Insurance Company (Hartford, CT), October 2006.
• Description: A commercial product publication by a Hartford competitor describing integrated absence management — the industry's "single point of contact for multiple leave types" model.
• § 102 potential: Potentially the most dangerous single reference, because it is a printed publication (§ 102(b) if more than one year before the critical date, which October 2006 comfortably is) that may describe the "comprehensive leave management / single-point-of-contact" concept generally. It is a § 103 (obviousness) workhorse and possibly anticipatory of the conceptual/background claims if it discloses routing among leave types. But if it is a marketing brochure, it likely lacks enabling detail of a WC-denial→STD-initiation computer hand-off, so it probably does not anticipate independent claims 1/20/22 on its own. Obtain the actual document — do not assume its content.

(g) "Smart Companies Know the Key to Growth is Keeping Workers Working" — MetLife, Hartford, CT, 2006

• Citation: Smart Companies Know the Key to Growth is Keeping Workers Working, Metropolitan Life Insurance Company (Hartford, CT), 2006.
• Description: A MetLife promotional/publication piece linking absence management to productivity.
• § 102 potential: Low. This overlaps the '634 specification's productivity-model material (FIGS. 13A–13F, absence-value multiplier). It is background/§ 103 context for the reporting/productivity features, not for the core routing or the WC-denial→STD claims.

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3. Consolidated mapping (available record only)

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4. Analytical conclusions

1. No cited reference appears to disclose the two limitations that most likely carried the '634 claims over the art: (i) routing claim data from a single intake to separate workers'-compensation vs. short-term-disability administration computer systems, and (ii) receiving WC-denial data and responsively signaling the STD system to initiate an STD claim for the same injury (as recited in the claim-1/claim-22 style language). That absence is consistent with the patent having issued over these references.
2. Independent claims 1, 20, and 22 (the routing/hand-off claims) are the least exposed to these references. Claim 24 (handheld eligibility determination) is also not met — none of the references is a handheld wireless-device claim.
3. The reference set is best viewed as § 103 combination material, not § 102 anticipation. The Klebanoff/Workbrain reference (multiple leave types, concurrent FMLA/STD/LTD) + the Travelers Synchrony publication (integrated single-point-of-contact absence management) + Fischer/Accenture (unified multi-channel intake) together could be assembled against the broader claims.
4. Date caveats: The '634 patent is pre-AIA (filed 2011-02-11, priority 2010-07-28), so pre-AIA § 102 governs. The § 102(b) critical date is, at the latest, 2010-02-11 (one year before the non-provisional) and at the earliest 2009-07-28 if provisional benefit is perfected. Every reference except US 2010/0036671 (published exactly 2010-02-11) comfortably predates both. US 2010/0036671 should be treated as § 102(a)/(e) art only.

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5. Completeness and confidence flags

• ⚠ The "References Cited" list may be truncated. The Justia record I retrieved displayed five U.S. patent documents and two other publications; it is possible additional citations exist that were cut from the retrieved excerpt. Confirm the full front page on USPTO Patent Center / Patent Public Search (App. 13/025,498) and the "Citations" tab on Google Patents (https://patents.google.com/patent/US8639634/en).
• ⚠ Two references (US 2006/0224478 A1; US 2010/0036671 A1) were not verified — no title/abstract retrieved — so no § 102 mapping is asserted for them; I declined to guess.
• ⚠ US 2005/0060174 A1 is described at only moderate confidence; treat its characterization as provisional pending retrieval.
• ⚠ The claim overviews used for the § 102 mapping (independent claims 1, 11, 17, 20, 22, 24) carry the truncation caveats already flagged in the earlier-generated summary; the exact scope of claims 11, 17, and 24, and the total claim count, should be re-verified against the granted claims before this mapping is used for any filing.

Bottom line: On the record retrieved, the cited prior art is background/obviousness material, not anticipation for the core independent claims. The patent's novel contribution — classifying an employee-leave claim at a single point of contact, routing it to the correct discrete administration system (WC vs. STD), and auto-seeding an STD claim when the WC claim for the same injury is denied — is not disclosed by any single cited reference I could verify. The two most useful references for a challenge are US 2008/0195512 (Klebanoff/Workbrain) and the Synchrony/Travelers publication, ideally combined. Two references remain unverified and must be pulled from primary sources before any § 102 position is asserted.

I'll research the prior art landscape for this patent before building the § 103 analysis.

Let me pull the complete cited-references list and probe the key secondary references.

Obviousness Analysis — U.S. Patent No. 8,639,634 under 35 U.S.C. § 103

0. Scope, governing law, and source discipline

Effective filing date / legal regime. The '634 patent claims priority to provisional 61/368,304 (filed 2010-07-28) and was filed as Ser. No. 13/025,498 on 2011-02-11. Both dates precede 2013-03-16, so the pre-AIA § 103(a) framework governs (with KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) supplying the controlling rationales). Practically, the AIA's expanded "prior art" definitions under § 102(a)(2)/(d) do not apply; the art must qualify under pre-AIA §§ 102(a)/(b)/(e)/(g).

Sources I am relying on.

Discipline note (per instructions): I am interpreting every identifier literally. I did not locate a verified secondary reference that expressly discloses the automated "WC-denial → STD-initiation" handoff. I flag that element below as the load-bearing, weakest link, and I do not manufacture a reference to fill it. I also flag two conflicts with the previously-generated sections (claim 24; the Fischer/Heyward content) in § 8.

§ 101 caveat up front. Under Alice/Mayo, these G06Q 10/1057 claims face a serious eligibility attack that cannot be raised in an IPR. That matters strategically, but it is a separate invalidity theory from § 103 and is not a substitute for the obviousness analysis below.

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1. Person of ordinary skill in the art (POSITA)

At the 2010-07-28 priority date, a POSITA would have:

• a bachelor's degree in computer science, information systems, or a related field (or equivalent practical experience), plus 3–5 years designing/implementing enterprise HR, benefits, absence-management, or insurance claim-administration systems;
• working knowledge of business-rules engines, relational databases, client–server / web / IVR / fax-imaging architectures, and message/interface integration between heterogeneous claim systems;
• familiarity with the statutory and plan landscape — FMLA, ADA, state leave statutes, workers' compensation (occupational-only), and short-/long-term disability (non-occupational) administration.

KSR teaches that the level of skill is rarely outcome-determinative where the art is readily combinable and the elements perform their known functions.

Claim-construction notes. "Configured to" is structural (not § 112 ¶ 6 means-plus-function). "Provide an output signal to transmit data … to one of a first computer system … and a second computer system" is a selective routing limitation. "In accordance with the determination" makes routing conditional on classification. "In the nature of a request to initiate a claim" is functional and broad.

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2. What the references disclose (mapped to the claim elements)

R1 — Klebanoff (Workbrain). The single most consequential reference. It discloses a leave policy manager system 10 with an employee database 22 and a user interface (user 36) by which a reason for absence is entered. Its FIG. 15 flow expressly recites: determine the set of possible leave policies (1504) → determine relevant jurisdiction (1506) → adjust the policy set by jurisdiction (1508) → determine reason for the absence (1510) → adjust by reason (1512) → adjust by CBA status (1514–1518) → determine terms-of-employment/eligibility criteria, including the FMLA 1,250-hour requirement (1520) → determine the employee's status against those criteria (1522) → adjust the set (1524) → determine whether remaining leaves require approval (1526). It administers consecutive and concurrent leaves and enumerates the leave types: FMLA, State FML, Military, Jury Duty, Short Term Disability, Long Term Disability, Vacation, Sick, Pregnancy Disability, Education, Bereavement, Personal Day, Sabbatical. It also enforces intermittent leave patterns and makes "active/inactive" segment determinations (step 1414).

→ R1 supplies claim elements (b) receive/broad intake, (c) determine the leave type from among a plurality of types + apply rules, and (e) store.

R2 — Harbison (Absentys). Discloses a three-tier personnel-absence system (backend 30, DMZ middle tier 32, browser presentation tier 12; DB servers 36a–b, web servers 44a–b, firewall 34, load balancer 38, IDS 40). A self-service web portal distinguishes manager / employee / administrator access levels and tailors functions accordingly. Its menu includes "Schedule Upcoming Absences," "Manage Absences & Certify Leaves," "Indicate Final Return to Work," "Reconcile new/conflicting absences," "Configure System Options" (client policy parameters, report groupings, correspondence), and "Batch Printing." The system generates tasks as leaves are entered and processed (task list), and runs leave request, leave certification, leave modification, and task-list processes.

→ R2 supplies element (a) the networked processor/memory/communications architecture, the prompting/self-service intake UI, policy-parameter configuration, and the task/work-queue mechanics recited in the dependents.

R3 — Chu. Discloses real-time FMLA leave administration over a secure intranet JavaScript interface using custom database objects and trigger processing, giving "instantaneous feedback to include an employee's hours worked within a rolling 12-month period, including current usage of vacation, worker's compensation, short-term disability, and sick leave," plus real-time supervisor notification of new FMLA requests/status changes/limits and FMLA eligibility data on a rolling 12-month basis, for accurate approval or denial.

→ R3 is critical because it discloses a single system that already tracks workers' compensation and short-term disability data side-by-side for the same employee and computes eligibility in real time — i.e., the cross-leave-type data substrate on which the routing/handoff in claims 1(f)/22 rests.

R4 — Fischer (US 7,974,857 B1) and R5 — Heyward (US 2005/0060174 A1) are of-record insurance/claims-art references. I could not independently verify their specific disclosures in this pass (see § 8). I therefore do not build the primary combination on them; I treat them as corroborating that claims-adjudication workflow automation was well-trodden art by 2010.

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3. Element-by-element obviousness mapping — independent claims

Claim 1 (computer system)

Claim 11 (method) and Claim 22 (method)

Claim 11's steps mirror claim 1's intake/classify/prompt/store and (per the granted text) the WC-denial→STD handoff. Claim 22 recites the identical routing + handoff, and adds "based on rules stored in a memory storage device." R1 is a rules-engine in a stored database applied to the reason/jurisdiction — that limitation is squarely met by R1, and, if anything, strengthens obviousness because it confirms the decision logic is a rule lookup rather than a novel mechanism.

Claim 17 (CRM)

Intake → determine type → prompt → store. R1 + R2 disclose each step; the CRM claim adds only the statutory "non-transitory medium" formal element, which is not a patentable distinction under KSR/In re Beauregard-era practice.

Claim 20 (comprehensive leave management system)

Receive claim data → determine WC vs. STD → output routing signal to the matching admin system. R1 classifies among a plurality of known leave types; R3 already discriminates WC from STD in one platform. The only added limitation over R1/R3 is the routing output signal, which the combination renders obvious (§ 4).

Claim 24 (CRM)

Per the granted claim text I retrieved, claim 24 tracks claim 22's architecture in CRM form (receive claim data; … receive from the WC system data indicating denial). See conflict flag in § 8.

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4. Motivation to combine (the KSR analysis)

The motivation here is not speculative; it is over-determined by the record.

(1) Same field of endeavor, same problem, overlapping disclosures. R1, R2, and R3 are all in employee absence/leave administration. R1 and R3 both enumerate WC, STD, LTD, and FMLA as leaves to be administered; R2 is a self-service absence-management platform. Under KSR, combining references directed to the same problem in the same field is presumed predictable.

(2) The '634 specification is itself an admission of the problem and the motivation. The Background states employers hold WC, sick, STD, and LTD plans, that the FMLA "can run concurrently for the same employee with disability leave (both occupational and non-occupational conditions)," and that "Determining requirements and tracking requirements for all of the different types of mandated leave is a complex task for employers." An applicant's own recitation of the problem is an admission of the design incentive — the very "market forces / design incentive" KSR rationale.

(3) Single point of contact is a known customer-service/architecture principle. "One number / one portal / one fax number" for a fragmented program is the classic consolidation pattern (echoed by R2's single web portal with role-tailored menus and by R3's single intranet interface). Combining a known consolidation interface with a known rules engine "yields no more than predictable results" (KSR).

(4) Rules-based classification → routing is the ordinary use of a rules engine. Once R1's engine has classified the leave as WC (occupational) or STD (non-occupational), selecting the corresponding downstream administration system is the established function of a classifier. KSR: "the combination of familiar elements according to known methods is likely obvious … and the improvement is [no] more than the predictable use of prior-art elements according to their established functions."

(5) The WC-denial→STD handoff is the predictable corollary of mutually exclusive statutory scopes. WC compensates occupational injury/illness; STD compensates non-occupational conditions. A WC denial for an injury is, by definition, a determination that the condition is (or may be) not occupational — which is precisely the threshold for STD eligibility. A POSITA reading R3's single system that already holds both WC and STD data for the employee, and being asked to "avoid [duplicative requests for information]" and "initiate a short term disability leave claim without a separate employee submission" (both advantages the '634 specification itself touts), would have found it obvious to try to trigger the STD record from the WC denial event. This is the classic KSR "obvious to try … a finite number of identified, predictable solutions" scenario — indeed Perfect Web Techs. v. InfoUSA (Fed. Cir. 2009) and OIP Techs. v. Amazon.com (Fed. Cir. 2013) (affirming § 103 invalidity of business-method claims built from known computer elements) are directly analogous.

(6) Event-driven message passing between claim systems is conventional engineering. R2's tiered/networked architecture and R3's "trigger processing" establish that event-triggered database/workflow actions were standard. Implementing the handoff as an event (WC denial status → STD claim creation) is a predictable variation of a known technique.

Net effect: the combination of R1 (rules-based multi-type leave classification) + R2 (networked, self-service, policy-configured absence platform) + R3 (co-managed WC/STD/FMLA data with real-time eligibility and trigger processing), optionally with R4/R5, renders claims 1, 11, 17, 20, 22, and 24 obvious.

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5. Dependent claims (conventional add-ons)

(Claims 2–10 and 23 — I do not have their verbatim text; per the specification they appear directed to authentication, authorization/approval routing, correspondence templates, subrogation flagging, intermittent-leave grouping, and reporting. Each of those is disclosed or rendered obvious by R1/R2/R3 and the '634 specification's own admissions. Flag as unverified — see § 8.)

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6. Secondary considerations (Graham factor 4)

I found no objective evidence of non-obviousness in the record: no evidence of unexpected results, no long-felt-but-unmet need, no industry praise or widespread licensing attributable to these claims, no copying, and no litigation (consistent with the previously-generated sections finding no '634 suit and no PTAB proceeding). Absent such evidence, the KSR rationales above control.

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7. Where the patent owner will fight (and my assessment)

1. The automated WC-denial → STD-initiation handoff (claim 1(f), claim 22). This is the strongest non-obviousness hook because the "trigger" is specific. Countervailing points: (i) the specification frames it as a mere application of "rules relating to coordination among individual leave management systems" and describes the statutory occupational/non-occupational divide as the reason for the rule — an admission of the motivation; (ii) R3 places both claim types in one system; (iii) the handoff uses nothing more than event-triggered record creation. On balance I assess this element as obvious but the most contestable, and it is where the prior-art record is thinnest.
2. "Single point of contact" / routing architecture — likely to fail as an obvious consolidation of known components (KSR).
3. § 101 (Alice). The most dangerous theory, but it is not a § 103 argument and must be run in district court.
4. No secondary considerations to counter the KSR case.

Overall assessment: Claims 1, 11, 17, 20, 22, and 24 are likely invalid under pre-AIA § 103 over R1 + R2 + R3, with the WC-denial→STD handoff being the single limitation that requires the most careful evidentiary development (a corroborating integrated-disability-management reference or system-prior-art would materially harden the case). The dependents add only conventional rules-engine, workflow, correspondence, and consent-gating features.

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8. Conflicts with the previously-generated sections (flagged) and verification items

• ⚠️ Conflict — Claim 24. The earlier summary characterized claim 24 as a handheld-wireless-device CRM claim (prompt → determine type → prompt → determine eligibility on the device → signal server → display eligibility). The granted claim text I retrieved shows claim 24 as a structural CRM parallel to claim 22 (receive claim data … receive from the WC administration system data indicative of a denial). Per the instruction to prioritize retrieved search results, I have analyzed claim 24 as the latter. The handheld/eligibility embodiment appears to be a specification embodiment (FIG. 16), and/or claimed in the continuation US 2013/0110736 A1 — not necessarily in claim 24. The total claim count of 24 is confirmed.
• ⚠️ Unverified — R4 (Fischer) and R5 (Heyward). I could not retrieve their disclosures. US 7,974,857 B1's grant (2011-07-05) postdates the priority date, so it can only be § 102(e) art if its filing date predates 2010-07-28 — verify its filing date before relying on it. Do not assert its content without checking.
• ⚠️ Verify — "Synchrony Integrated Absence Management" (Oct. 2006). Prior sections identified this as an of-record non-patent reference the examiner considered; I could not independently re-confirm that citation in this pass. If accurate, it is a useful corroborating admission of the pre-2010 state of integrated absence management.
• ⚠️ Do not assert the automated WC-denial→STD handoff as expressly disclosed in a single verified reference. The combination case rests on R3 + the specification's own admissions + KSR rationales. A harder case requires locating a contemporaneous integrated disability management / 24-hour coverage reference (patent, product literature, or system prior art).

Recommended verification steps before filing any § 103 challenge: (1) pull the complete IDS/cited-reference list and examiner-cited art from the '634 file wrapper (USPTO Patent Center, Ser. No. 13/025,498); (2) confirm the filing dates of Fischer ('857) and any other § 102(e)-dependent art; (3) search 2006–2010 integrated absence/disability management patents and trade literature for the WC-denial→STD trigger; and (4) run the parallel Alice/§ 101 track in district court, since IPR cannot reach it.