Invalidity dossier

US 8715203

Composite electrode

Current assignee: Novocure GmbH

Added 9/28/2026, 2:14:11 PM

IndustryMedical (M)
At a glanceNo PTAB challenges1 lawsuit on fileasserted by Novocure GmbHMedical (M)

Active provider: DeepSeek · deepseek-v4-flash

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Patent summary

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

✓ Generated

I'll search for authoritative information on this patent number and any 2026 CAFC activity.

US Patent 8,715,203 — Quick Reference Summary

Note on scope: I searched for 8715203 / 8,715,203 as a literal string (no fuzzy matching, no auto-correction of the digits). All results below pertain to that exact number. I found no CAFC docket activity in 2026 for this patent — see the litigation section below for what I did and did not find.


Bibliographic Data

Field Value
Patent number US 8,715,203 B2
Title Composite electrode
Application no. 11/856,277
Filing date September 17, 2007
Priority date September 17, 2007 (no earlier priority claimed — no provisional/foreign priority)
Issue/grant date May 6, 2014
Inventor Yoram Palti
Original assignee Novocure Ltd USA (assignment to Standen Ltd. recorded 2008-05-12; name changed to Novocure Limited; later assigned to Novocure GmbH, 2019-08-20)
Current assignee (per Google Patents) Novocure GmbH; BPCR LP (Google notes its assignee list "may be inaccurate" and is not a legal conclusion)
Pre-grant publication US 2009/0076366 A1 (2009-03-19)
Child/continuation US 13/790,258 → US 8,764,675 B2 ("Composite electrode," published as US 2013/0190847 A1), a continuation of 11/856,277
Claims 27 total; independent claims 1 and 13
Status Active; "adjusted expiration" listed as 2031-01-18 (i.e., term extended beyond the nominal 20-year date of 2027-09-17); 4th, 8th and 12th year maintenance fees paid (12th year paid 2025-10-20)
Field of classification A61N 1/04, A61N 1/0476, A61N 1/0492, A61N 1/32, A61B 5/441, A61N 1/40
Examiner / agent of record Jon Eric C. Morales (primary examiner); Potomac Law Group PLLC
Only two references cited on the face US 4,809,707 (KVM Engineering, 1989) and US 2003/0029569 A1 (Sumitomo Electric, 2003)

Abstract (verbatim)

"An electrode for applying electric fields to a patient includes a plurality of ceramic elements (e.g., ceramic discs) that are designed to be positioned against the patient's skin. Electrical connections are made to the ceramic elements (e.g., using a flex circuit). Temperature sensors (e.g., thermistors) are preferably provided at at least some of the ceramic elements to sense the temperature at the skin beneath the ceramic elements, so that appropriate action can be taken if an overtemperature condition is detected."


Plain-Language Overview of the Independent Claims

Claim 1 (independent) — the base "composite electrode" concept. An electrode built from several ceramic elements rather than one. Each ceramic element has two faces: a lower surface that sits on the patient's body and an upper surface. A single first lead serves the assembly, and one or more electrical conductors create a direct electrical connection between the upper surface of each ceramic element and that lead. A support structure holds the ceramic elements together during use, while all their lower surfaces rest on the patient's body. So the core idea is: many ceramic elements, directly wired on their patient-facing-away side to a shared lead, held together by a common support.

Claim 13 (independent) — a more heavily specified version. This requires:

  • at least four ceramic elements (each with the same lower/upper surface arrangement);
  • a first lead and conductors making a direct connection from each element's upper surface to that lead;
  • a support structure tying the elements together during use with their lower surfaces on the body;
  • at least two temperature sensors, each sensing the temperature beneath one of the ceramic elements;
  • a layer of electrically conductive hydrogel on the lower surface of each ceramic element; and
  • a covering above the elements and support structure whose adhesive lower surface holds the assembly against the patient's body.

In short, claim 13 = the multi-element ceramic electrode of claim 1, plus per-element temperature sensing, plus the hydrogel/cover/adhesive "wearable patch" stack-up.

Representative dependent claims worth noting:

  • Claim 3: the conductor(s) and the support structure are both implemented by a single flex circuit.
  • Claim 5: at least 4 ceramic discs, each ~1.5–2.5 cm diameter and capacitance of at least 2.0 nF, with conductor and support both via flex circuit.
  • Claim 11: exactly nine discs, 1.5–2.5 cm, at least 20 nF each, flex circuit, and at least four thermistors.
  • Claim 12: the direct connection is a flex circuit soldered to a conductive backing on the upper surface of each element.

⚠️ Literal-reading flag (not a correction): the numeric capacitance thresholds are not uniform across the document. Claim 5 recites "at least 2.0 nF" per disc, claim 11 (and claim 18) recite "at least 20 nF," and the specification's description states "a capacitance of art [sic] least 10 nF per disc." I am reporting these exactly as they appear rather than reconciling them.


Litigation / Docket Check (as requested)

What I found:

  • The patent front page carries a "Family has litigation" flag linking to U.S. District Court, Middle District of Florida, Case No. 8:22-cv-02535.
  • That case is Novocure GmbH v. Fieldcure Co. Ltd., filed November 7, 2022, assigned to Judge Virginia M. Hernandez Covington (Magistrate Judge Julie S. Sneed). Novocure asserted three patents, including the '203 patent (attached to the complaint as Exhibit C, described in the complaint as issuing "May 6, 2014 … entitled 'Composite Electrode' … to Novocure Limited as assignee with named inventor Dr. Yoram Palti"). The other asserted patents were US 7,136,699 and US 7,715,921.
  • The docket shows the case was voluntarily dismissed without prejudice on December 2, 2022 (Doc. 15 notice; Doc. 16 endorsed order directing the Clerk to close the case). PACER was last retrieved on that docket December 2, 2022.

What I did NOT find — and this is a genuine gap, not a confirmation of absence:

  • I found no Federal Circuit docket (2026 or otherwise) naming US 8,715,203 or the Novocure/Fieldcure dispute. My searches for CAFC 2026 activity returned a general Federal Circuit weekly summary (week ending Feb. 13, 2026) covering unrelated patents (e.g., a Netflix v. DivX appeal, 2024-1541) and an unrelated 2020-1089 docket notice — nothing tied to '203.
  • Because the Florida case was dismissed without prejudice, any refiling would have been under a new case number, and any appeal from a refiled case would not necessarily surface in the searches I ran. I cannot confirm from authoritative sources whether the '203 patent is currently subject to any 2026 CAFC appeal. This should be verified directly against PACER/CM-ECF and the CAFC's docket, which I could not query directly.

Uncertainty and Sourcing Caveats

  • All bibliographic, claim, and specification data above is taken from the patent document itself (Google Patents full text of US 8,715,203, fetched 2026-09-28), which is authoritative and takes precedence over search snippets.
  • The current-assignee field is Google's own automated listing ("may be inaccurate," "not a legal conclusion"). The recorded assignment chain in the legal events is: Standen Ltd. (2008) → name change to Novocure Limited (2011/2013) → Novocure GmbH (2019) → with several security interests granted to and released by Deutsche Bank, BioPharma Secured Investments III, BioPharma Credit PLC, BPCR Limited Partnership, and JPMorgan Chase, plus a subsisting patent security agreement to BioPharma Credit PLC recorded 2024-05-04 (Reel/Frame 067315/0399). That security interest is a lien, not an ownership transfer.
  • The 2031-01-18 expiration is an "adjusted expiration" figure from the patent record (reflecting a patent term adjustment and/or terminal disclaimer), not a statutory 20-year calculation. The nominal 20-year date would be 2027-09-17.
  • Date discrepancy noted: the task prompt states the current date as April 26, 2026, while the retrieval metadata on the source document is timestamped September 28, 2026. I flagged this rather than silently normalizing it, since it affects how "current" the docket check should be considered.
  • I have not independently verified the complaint's characterizations (e.g., the claim that the Fieldcure device "meets each and every limitation" of claim 1 of the '921 patent) — those are plaintiff allegations, and the case was dismissed before any adjudication.

Generated 9/28/2026, 2:21:05 PM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 8715203. The free-form analysis below may also discuss cases beyond this list.

  • 8:22-cv-02535-VMC-JSSU.S. District Court for the Middle District of Florida (Tampa Division)terminated Dec 2, 2022dismissed

    Defendants: Fieldcure Co. Ltd.

    Other patents asserted: 7715921, 7136699

Litigation summary

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

✓ Generated

I'll research litigation involving US Patent 8,715,203. Let me start with targeted searches.

I found an active case. Let me dig into the specific case number and parties.

Let me verify the outcome and check for related or refiled actions (ITC, etc.).

Litigation Involving U.S. Patent No. 8,715,203

One litigation matter is documented. US 8,715,203 ("Composite electrode," inventor Yoram Palti, assigned to Novocure GmbH) was asserted as one of three patents in a single district court action, which was then voluntarily dismissed. Beyond that case, I found no other litigation specifically asserting the '203 patent.

Case details

Field Detail
Plaintiff Novocure GmbH
Defendant Fieldcure Co. Ltd. (Korea)
Court / Jurisdiction U.S. District Court, Middle District of Florida (Tampa Division)
Case No. 8:22-cv-02535 (a.k.a. 8:22-cv-2535-VMC-JSS)
Filed November 7, 2022
Cause of action 35 U.S.C. § 271 patent infringement (jury demand)
Presiding Judge Hon. Virginia M. Hernandez Covington (Magistrate: Julie S. Sneed)
Patents asserted US 7,136,699 ('699); US 7,716,921 ('921); US 8,715,203 ('203)
Outcome / Status Voluntarily dismissed without prejudice on December 2, 2022, and the case was closed.

How the '203 patent appears in the case

  • The complaint (Exhibit C) expressly identifies the '203 patent: "On May 6, 2014, the '203 Patent, entitled 'Composite Electrode,' issued to Novocure Limited as assignee with named inventor Dr. Yoram Palti. The '203 Patent is fully maintained, valid, and enforceable."
  • Novocure's prayer for relief sought a judgment that the Fieldcure device infringes "at least one claim of the '699 Patent, the '921 Patent, and/or the '203 Patent."
  • The '203 was one of three patents in the suit — it was not a standalone '203 action.

Termination

Per the docket, on December 2, 2022, Novocure filed a NOTICE of voluntary dismissal (Doc. #15), and the court entered an endorsed order: "Pursuant to the notice of voluntary dismissal without prejudice (Doc. #15), this case is dismissed without prejudice. The Clerk is directed to close the case." No merits rulings, claim-construction orders, or judgments on the '203 patent were issued. The case lasted less than a month.

Cross-check against the patent record

The Google Patents page for US 8,715,203 itself flags "Family has litigation," listing the same matter: U.S. case filed in Florida Middle District Court, case 8:22-cv-02535 (sourced from Unified Patents). Its Darts‑IP "first worldwide family litigation" link references the patent family (ID 40455310) rather than a distinct additional suit.

Caveats / things I could not confirm

  • I could not verify a refiling. Because the Florida case was dismissed without prejudice, a subsequent or parallel action (in the U.S. or elsewhere) is legally possible; my searches did not surface a confirmed follow-on suit naming the '203 patent. I cannot state with confidence that none exists.
  • Related patents in the same family — US 8,764,675 ("Composite electrode," continuation of the '203, same family) — may appear in other proceedings; those would be separate matters and I did not confirm any.
  • The "family has litigation" flag on the patent page refers to the family generally; the only concrete U.S. case tied to that flag is 8:22-cv-02535 above.

Bottom line: The only litigation I can confirm involving US 8,715,203 is Novocure GmbH v. Fieldcure Co. Ltd., No. 8:22-cv-02535 (M.D. Fla., filed Nov. 7, 2022), in which the '203 was one of three asserted patents and which was voluntarily dismissed without prejudice on Dec. 2, 2022. That matter is currently closed, so the '203 patent is not, to my knowledge, presently in active litigation.

Sources:

Generated 9/28/2026, 2:20:58 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: Novocure GmbH

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

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

✓ Generated

I'll verify the structured "no proceedings" default against live sources before writing anything up.

Let me check the litigation reference in the structured data and any Novocure-related PTAB filings more broadly.

Let me check whether Fieldcure (the defendant in the 2022 case) filed any PTAB challenge, and check Unified Patents' records.

Proceedings overview

Zero (0) AIA trial proceedings are on file against US 8,715,203. The canonical PTAB proceedings list supplied in the structured data returns no IPR, PGR, or CBM for this patent, and my independent searches for a PTAB docket naming the '203 patent or naming Novocure as patent owner in an AIA trial returned nothing. Breakdown by status is therefore: 0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denied. The defensive posture this gives a defendant is the hard version of "no IPR cover": the patent stands un-narrowed, with all 27 claims intact as issued, and there is no Patent Office record to mine for claim constructions, admitted prior art, or a cancellation you can lean on. If you are asserting the patent, that is good news; if you are defending against it, you are starting from a blank PTAB slate, not from a hardened patent.

No proceeding to report

I could not populate the per-proceeding fields ({PROCEEDING_NUMBER}, Petitioner, Judge panel, grounds, institution, FWD, settlement, appeal) because there is no proceeding to source them from. I will not fabricate a trial number, a panel, or a claim-level disposition. Explicitly:

  • Petitioner / Patent Owner: N/A.
  • Type: N/A.
  • Filed: N/A.
  • Judge panel: N/A — no panel has ever been constituted for this patent.
  • Petition grounds: N/A — there is no petition of record to characterize under § 102, § 103, or § 112.
  • Institution decision: N/A — nothing instituted, partially instituted, or denied.
  • Final Written Decision: N/A — no FWD exists, and therefore no claim of the '203 patent has been canceled, and none has been adjudicated patentable by the PTAB.
  • Settlement / termination: N/A.
  • Appeal: N/A — no FWD, so no CAFC appeal of a PTAB decision.

One related-artifact caution for the file: the structured data carries a Darts-IP "first worldwide family litigation filed" link (https://patents.darts-ip.com/?family=40455310...) and a Unified Patents litigation link pointing to Florida M.D. case 8:22-cv-02535. Neither is a PTAB proceeding. The Florida case is a district court action, and the Darts-IP record is a global litigation-family flag. Do not let either be mischaracterized in a brief as AIA trial history.

The litigation that is actually in the chain (context, not PTAB)

  • Case: Novocure GmbH v. Fieldcure Co. Ltd., No. 8:22-cv-02535 (M.D. Fla.), filed 2022-11-07, assigned to Judge Virginia M. Hernandez Covington (referral to Mag. J. Julie S. Sneed).
  • Asserted patents: US 7,136,699 ('699), US 7,714,921 ('921), and US 8,715,203 ('203) — Count V pleaded infringement of the '203 patent, and the complaint attached an element-by-element chart as Exhibit F for at least claim 1.
  • The '203 claim 1 theory pleaded: the complaint quoted claim 1 verbatim and alleged the Fieldcure device "meets each and every limitation of at least claim 1 of the '203 Patent literally and/or under the doctrine of equivalents."
  • Outcome: Novocure filed a notice of voluntary dismissal without prejudice on 2022-12-02, and the court entered an endorsed order dismissing the case without prejudice and directing the clerk to close it the same day (2022-12-02). The action lasted roughly 25 days on the docket.
  • Significance: a voluntary dismissal without prejudice is not an adjudication of validity, infringement, or claim scope. Nothing about the '203 patent was narrowed by it. Fieldcure never filed for IPR as far as I can determine — the case was abandoned by the plaintiff before any PTAB window ripened.
  • Sources: Docketbird docket, 8:22-cv-02535; RPX litigation profile; complaint text at RPX Insight.

Strategic summary

Claim status: everything is UNTESTED. No claim of US 8,715,203 has been canceled, confirmed, or even construed in an AIA trial. The full claim set remains as granted: independent claim 1 (composite electrode: plurality of ceramic elements, first lead, direct electrical connection between each element's upper surface and the lead, support structure holding elements against the body during use) and independent claim 13 (the same core plus at least four ceramic elements, at least two temperature sensors, a conductive hydrogel layer on each lower surface, and an adhesively-backed covering). Dependents 2–12 and 14–27 walk through the temperature-sensor details (thermistors, sensors in center holes), flex-circuit implementation, ≥4 discs of 1.5–2.5 cm at ≥20 nF, nine-element arrays, foam filler layers with cutouts, peel-away backing, and the soldered silvered-backing connection. Because the patent has never been through the PTAB, there are no survived-through-IPR claims to point to and no canceled claims to avoid — contrast a patent like this against one that has been trimmed, where the "hardened survivor" claims carry a presumption of tested validity.

Estoppel landscape: essentially wide open, but with a timing trap. There is no § 315(e) estoppel attaching to the '203 patent, because no petitioner has ever reached a final written decision on it. A defendant today can raise any § 102/§ 103 ground it can find, including art that might otherwise have been foreclosed. Two practical constraints: (i) if you are a defendant in a pending district court case, the § 315(b) one-year bar runs from service of the complaint, so the IPR clock is a hard deadline keyed to that service date; and (ii) the '699 and '921 patents were co-asserted against Fieldcure alongside the '203 — a realistic petition strategy attacks the electrode-family patents as a group, because the '203's ceramic-disc-plus-flex-circuit subject matter overlaps with the '921 electrode disclosure and with Novocure's own prior publications (e.g., US 2005/0209642, incorporated by reference into the '203 specification, and the '699/'210 patents cited in the '203 Background).

Pattern signals. No repeat-petitioner pattern exists, because there is no petitioner at all. There is no defensive aggregator in the chain — Unified Patents appears only as the source of the litigation-data link in the structured record, not as a party that filed anything. Novocure has been aggressive on the offensive side of the PTAB (the structured data shows Novocure filing IPRs against Cardiac Pacemakers' electric-field-shaping patents in 2022) and on the defensive side in EPO oppositions/appeals — notably T 2329/13 (Novocure, 2019-03-20), where the Board of Appeal remitted for grant of claims 1–16. But none of that activity touches the '203 patent's US validity. The patent owner's unrelated EPO wins are not a proxy for US PTAB posture.

The absence is itself weak evidence of something. Well-commercialized, heavily asserted medical-device patents usually attract at least one IPR petition. The '203 patent has been asserted at least once (M.D. Fla. 2022) and bears a Darts-IP "first worldwide family litigation" flag, yet no one has petitioned. Read that as either (a) the art space around a silvered ceramic disc on a flex circuit is genuinely thin, or (b) no defendant has yet had both the incentive and the 12-month window to file. Post-Optune commercial success will strengthen Novocure's § 103 secondary-considerations story in any future trial, which is another reason a challenger wants the PTAB forum rather than a jury.

Recommended next steps

  • If you are a defendant and you were told the '203 has been invalidated: it has not. No FWD exists. There is no disposition to quote and no link to a PTAB decision to cite, because there is no PTAB decision on this patent. Any assertion that claims 1–13 (or any claim) of the '203 patent are "canceled" or "held invalid" by the PTAB is factually wrong and should be challenged immediately.
  • If you are a defendant being asserted against right now: confirm the service date of the complaint to fix your § 315(b) deadline (one year from service, absent a stipulation-based exception), then run a fresh prior-art search against claim 1's three moving parts — (1) a plurality of ceramic elements each with a patient-contacting lower surface and an upper surface, (2) a direct electrical connection between the upper surface of each element and a single first lead, and (3) a support structure mechanically connecting the elements during use. The "direct electrical connection … between the upper surface" and the "support structure … during use" limitations are the most likely § 103 battlegrounds given the pre-2007 biomedical-electrode art (the patent itself cites only US 4,809,707 and US 2003/0029569 as prior art, both cited by the examiner).
  • Watch for a re-filed action. Novocure dismissed without prejudice on 2022-12-02, which leaves it free to sue again on the same patents. A re-filing would restart § 315(b) as to a new defendant, and could precede a new Novocure assertion of the '203.
  • Milestone tracking if a proceeding is later filed: nothing to track today. If a petition appears, the PTAB's statutory clock is institution within ~6 months of the patent owner's preliminary response (35 U.S.C. § 314(b)), a 12-month trial deadline from institution (§ 316(a)(11)), extendable up to 6 months for good cause, with a Final Written Decision addressing every challenged claim. Monitor PTAB E2E and USPTO PTAB Decisions for filings naming US 8,715,203.
  • Verification caveat. I searched for IPRs/PGRs naming this patent and Novocure as patent owner and found none, consistent with the ODP-derived block. The ODP ingest can lag; because the structured data is stated to be the canonical list and my searches corroborate it, treat "no PTAB activity" as current as of 2026-09-28, but re-check PTAB E2E before relying on the absence in a filing.

Generated 9/28/2026, 2:21:06 PM

Ownership chain (18)

Asserters network →

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

  1. 2008-05-11 · recorded 2008-05-12 · reel 020934/0313 · Assignment

    Palti, YoramStanden Limited

  2. 2011-02-21 · recorded 2013-02-15 · reel 029820/0302 · Change of Name

    Standen LimitedNovocure Limited

    change of name only

  3. 2013-01-28 · recorded 2013-02-20 · reel 029845/0135 · Security Agreement

    Novocure LimitedDeutsche Bank Trust Company Americas

    securitization

  4. 2013-12-20 · reel 031866/0567 · Release

    Deutsche Bank Trust Company AmericasNovocure Limited

    securitization

  5. 2015-01-30 · recorded 2015-02-02 · reel 034866/0402 · Security Interest

    Novocure LimitedBioPharma Secured Investments III Holdings Cayman LP

    securitization

  6. 2018-02-07 · reel 044858/0416 · Release

    BioPharma Secured Investments III Holdings Cayman LPNovocure Limited

    securitization

  7. 2018-02-07 · reel 045278/0825 · Security Interest

    Novocure LimitedBioPharma Credit PLC

    securitization

  8. 2018-02-07 · reel 045284/0851 · Security Interest

    Novocure LimitedBioPharma Credit PLC

    securitization

  9. 2019-04-24 · recorded 2019-05-06 · reel 050395/0398 · Security Interest

    Novocure LimitedBioPharma Credit PLC

    securitization

  10. 2019-04-24 · recorded 2019-08-20 · reel 050110/0098 · Assignment

    Novocure LimitedNovocure Limited

    internal reorg

  11. 2019-04-24 · recorded 2020-04-13 · reel 052383/0705 · Release

    BioPharma Credit PLCNovocure Limited

    securitization

  12. 2019-04-24 · recorded 2020-04-14 · reel 052391/0549 · Release

    BioPharma Credit PLCNovocure Limited

    securitization

  13. 2020-05-21 · reel 052741/0173 · Confirmation

    BioPharma Credit PLCBPCR Limited Partnership

    securitization

  14. 2020-08-18 · recorded 2020-08-19 · reel 053538/0623 · Release

    BPCR Limited PartnershipNovocure Limited

    securitization

  15. 2020-08-18 · recorded 2020-08-25 · reel 053597/0335 · Release

    BioPharma Credit PLCNovocure Limited

    securitization

  16. 2020-11-06 · reel 054344/0510 · Security Interest

    Novocure LimitedJPMORGAN CHASE BANK, N.A., AS ADMINISTRATIVE AGENT

    securitization

  17. 2024-04-23 · recorded 2024-04-24 · reel 067211/0839 · Release

    JPMORGAN CHASE BANK, N.A., AS ADMINISTRATIVE AGENTNovocure Limited

    securitization

  18. 2024-05-01 · recorded 2024-05-04 · reel 067315/0399 · Security Agreement

    Novocure LimitedBioPharma Credit PLC

    securitization

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll ground the litigation and ownership context with searches before writing.

One more check on the correspondent-of-record question, which the user weighted heavily.

Ownership & Assignment Analysis — US 8,715,203 B2 ("Composite electrode")

Data-source caveat (read first). The analysis below is built from the Google Patents legal-events record for US 8,715,203 (https://patents.google.com/patent/US8715203B2/en#legalEvents), cross-checked against the Novocure v. Fieldcure complaint text and the RPX/docket records for the Florida case. Google Patents republishes USPTO reel/frame numbers but does not republish the assignment correspondent field. I could not reach USPTO Assignment Center interactively from this session, so the "correspondent" slot for each recording below is marked as unavailable rather than guessed. Everything else (reel/frame, dates, conveyance, assignor, assignee) is as recorded.

Also note: Google Patents lists two "Current Assignees" — Novocure GmbH and Bpcr LP. BPCR LP appears only because USPTO shows secured parties alongside owners; it holds a security interest, not title. Do not read BPCR as an owner. See signals section.

Inventors

Inventor Employer at filing Notes
Yoram Palti (sole named inventor) Standen Ltd. (Jersey) — the entity that became Novocure; Palti is the company's founder Assigned to Standen Ltd. by reel 020934/0313, executed 2008-05-11

Pattern notes:

  • Single-inventor patent. There is no multi-inventor team whose members could "depart within 12 months of filing," so the classic fire-sale precursor you flagged is structurally inapplicable here.
  • Dr. Palti was a retired Technion professor who built the initial laboratory in his own basement and then founded the company; per the Fieldcure complaint (¶26), "the retired Dr. Palti built a laboratory in his basement" and "formed the company that would become Novocure." So inventor and original assignee are effectively the same origin point — the opposite of an inventor-detachment signal.
  • The invention was filed 2007-09-17 and issued almost seven years later, on 2014-05-06 — a long prosecution that produced substantial patent term adjustment (see the note on the 2031-01-18 adjusted expiration below).

Original assignee

Standen Ltd. (Jersey, Channel Islands) was the assignee of record on the application as filed. Via a name change effective 2011-02-21 (recorded 2013-02-15, reel 029820/0302), Standen Limited became Novocure Limited. US 8,715,203 therefore issued on 2014-05-06 to Novocure Limited, which is what the Fieldcure complaint states at ¶25: "On May 6, 2014, the '203 Patent, entitled 'Composite Electrode,' issued to Novocure Limited as assignee."

  • Product embodying the claims: Yes, directly and commercially. The claimed composite electrode (array of silvered ceramic discs on a flex circuit, thermistor per disc, hydrogel interface, foam filler layer, adhesive overlay) is the architecture of the Optune / NovoTTF-100A transducer arrays used for Tumor Treating Fields. Novocure's own later filings describe the Optune array as "a set of non-conductive ceramic disk electrodes … coupled to the patient's skin … through a layer of conductive medical gel" (see https://www.freepatentsonline.com/y2021/0346693.html). This is the patent behind the array that ships with the commercial device.
  • Primary line of business: commercial-stage oncology; TTFields delivery hardware plus therapy. Novocure Limited is Nasdaq-listed (NVCR), and the operating patent-holding entity since 2019 is Novocure GmbH (Baar, Switzerland), a wholly owned group company.
  • Current status: Operating. Not bankrupt, not dissolved. Corroborating non-assignment legal events on this very patent: 4th-year maintenance fee paid 2017-11-06 as a small entity; entity status flipped to undiscounted / large entity on 2019-05-16 (consistent with revenue growth past the small-entity threshold); 8th-year fee paid 2021-11-08; 12th-year fee paid 2025-10-20 as a large entity. A patent owner paying 12th-year maintenance fees is not a distressed seller.
  • Adverse corporate event, for completeness: a securities class action was filed against Novocure in June 2023 concerning LUNAR trial disclosures (Novocure 10-K, Item 3 Legal Proceedings). That is a securities suit, not a bankruptcy, and it has no bearing on title to the '203 patent.

Assignment timeline

Every recorded post-issuance (and pre-issuance) assignment on this patent is internal corporate structural or secured-lending. There is not one third-party patent transfer in the entire chain.

1. 2008-05-11 (executed) / recorded 2008-05-12 — Reel 020934/0313

  • Conveyance: Assignment of assignors' interest
  • Assignor: Palti, Yoram (individual inventor)
  • Assignee: Standen Ltd. (Jersey, Channel Islands)
  • Correspondent: not retrievable from the sources I could access (see caveat). This is the only inventor-origin recording, so there is no in-chain recurrence to flag.
  • Context: ordinary inventor-to-company assignment at the founding company.

2. effective 2011-02-21 / recorded 2013-02-15 — Reel 029820/0302

  • Conveyance: Change of Name ("CHANGE OF NAME; ASSIGNOR: STANDEN LIMITED")
  • Assignor: Standen Limited
  • Assignee: Novocure Limited (Jersey)
  • Correspondent: not retrievable.
  • Context: pure change of name only — no change in beneficial ownership, no consideration, no new party.

3. effective 2013-01-28 / recorded 2013-02-20 — Reel 029845/0135

  • Conveyance: Security Agreement
  • Assignor: Novocure Limited
  • Assignee: Deutsche Bank Trust Company Americas (New York)
  • Correspondent: not retrievable.
  • Context: securitization — patent pledged as collateral under a credit facility, not a sale.

4. effective 2013-12-20 / recorded 2013-12-20 — Reel 031866/0567

  • Conveyance: Release of Security Interest
  • Assignor: Deutsche Bank Trust Company Americas
  • Assignee: Novocure Limited
  • Correspondent: not retrievable.
  • Context: release of the 2013 collateral pledge; ownership never left Novocure.

5. effective 2015-01-30 / recorded 2015-02-02 — Reel 034866/0402

6. effective 2018-02-07 / recorded 2018-02-07 — three recordations, Reels 044858/0416, 045278/0825 and 045284/0851

  • Conveyance: (a) Release by Secured Party — BioPharma Secured Investments III Holdings Cayman LP → Novocure Limited; (b) Security Interest — Novocure Limited → BioPharma Credit PLC (United Kingdom); (c) Security Interest — Novocure Limited → BioPharma Credit PLC (second reel/frame for the same facility)
  • Correspondent: not retrievable on any of the three.
  • Context: securitization/refinancing — the 2015 Cayman lender is released and BioPharma Credit PLC steps in as secured party on the same day.

7. effective 2019-04-24 / recorded 2019-05-06 — Reel 050395/0398

  • Conveyance: Security Interest
  • Assignor: Novocure GmbH (Switzerland)
  • Assignee: BioPharma Credit PLC (United Kingdom)
  • Correspondent: not retrievable.
  • Context: securitization — collateral re-granted after the group's corporate reorganization (see entry 8).

8. effective 2019-04-24 / recorded 2019-08-20 — Reel 050110/0098

  • Conveyance: Assignment of Assignors' Interest
  • Assignor: Novocure Limited (Jersey)
  • Assignee: Novocure GmbH (Switzerland)
  • Correspondent: not retrievable.
  • Context: internal reorg — the group's Jersey holding entity moved the patent, together with the rest of the portfolio, down to the Swiss operating/ IP-holding subsidiary. This is the last title transfer of record and is where ownership still sits.

9. effective 2019-04-24 / recorded 2020-04-13 — Reel 052383/0705

  • Conveyance: Release by Secured Party
  • Assignor: BioPharma Credit PLC
  • Assignee: Novocure Limited (Jersey)
  • Correspondent: not retrievable.
  • Context: release of the BioPharma Credit collateral interest.

10. effective 2019-04-24 / recorded 2020-04-14 — Reel 052391/0549

  • Conveyance: Release of Security Interest (expressly for the security agreement filed at Reel/Frame 045278/0825)
  • Assignor: BioPharma Credit PLC
  • Assignee: Novocure Limited (Jersey)
  • Correspondent: not retrievable.
  • Context: second release clearing the 2018 facility from the record.

11. effective 2020-05-21 / recorded 2020-05-21 — Reel 052741/0173

  • Conveyance: Omnibus Confirmation of Assignment Agreement
  • Assignor: BioPharma Credit PLC (United Kingdom)
  • Assignee: BPCR Limited Partnership (United Kingdom)
  • Correspondent: not retrievable.
  • Context: securitization housekeeping — the secured party (not the patent owner) confirms transfer of the lender-side collateral position into an affiliated fund. This is the recordation that causes Google Patents to list "Bpcr LP" as a "Current Assignee." BPCR LP has never held title to the patent.

12. effective 2020-08-18 / recorded 2020-08-19 — Reel 053538/0623

  • Conveyance: Release of Security Interest (expressly for the agreement filed at Reel/Frame 050395/0398)
  • Assignor: BPCR Limited Partnership
  • Assignee: Novocure GmbH (Switzerland)
  • Correspondent: not retrievable.
  • Context: release of the 2019 collateral filing on the Swiss owner's copy of the chain.

13. effective 2020-08-18 / recorded 2020-08-25 — Reel 053597/0335

  • Conveyance: Release of Security Interest (expressly for Reel/Frame 045278/0825)
  • Assignor: BioPharma Credit PLC
  • Assignee: Novocure Limited (Jersey)
  • Correspondent: not retrievable.
  • Context: duplicate/parallel release on the Jersey chain; record cleanup only.

14. effective 2020-11-06 / recorded 2020-11-06 — Reel 054344/0510

  • Conveyance: Security Interest
  • Assignor: Novocure GmbH (Switzerland)
  • Assignee: JPMorgan Chase Bank, N.A., as Administrative Agent (Illinois)
  • Correspondent: not retrievable.
  • Context: securitization — a new bank credit facility secured by the Novocure patent portfolio, replacing BioPharma Credit as collateral agent.

15. effective 2024-04-23 / recorded 2024-04-24 — Reel 067211/0839

  • Conveyance: Release by Secured Party and Release of Security Interest (two releases recorded at the same reel/frame)
  • Assignor: JPMorgan Chase Bank, N.A., as Administrative Agent
  • Assignee: Novocure GmbH (Switzerland)
  • Correspondent: not retrievable.
  • Context: release of the 2020 bank lien.

16. effective 2024-05-01 / recorded 2024-05-04 — Reel 067315/0399

  • Conveyance: Patent Security Agreement
  • Assignor: Novocure GmbH (Switzerland)
  • Assignee: BioPharma Credit PLC (United Kingdom)
  • Correspondent: not retrievable.
  • Context: securitization — BioPharma Credit PLC returns as secured party under a new financing. Title remains with Novocure GmbH.

Not assignments (excluded, but recorded legal events worth noting): patent grant 2014-04-16 (STCF); maintenance-fee payments 2017-11-06 (4th yr, small entity), 2021-11-08 (8th yr, large entity), 2025-10-20 (12th yr, large entity); entity-status change to undiscounted/large entity 2019-05-16. Current legal status: Active, with an adjusted expiration of 2031-01-18 — roughly four years of term adjustment beyond the nominal 20-year date of 2027-09-17, which materially extends the assertion window on this patent.

Timeline diagram

timeline
    title Ownership of US 8715203
    2007 : Filed by Standen Ltd Jersey
         : Sole inventor Yoram Palti
    2008 : Palti assigns to Standen Ltd
    2011 : Standen renamed Novocure Limited
    2013 : Deutsche Bank security agreement
         : Deutsche Bank release recorded
    2014 : Patent issues to Novocure Limited
    2015 : BioPharma Cayman takes security
    2018 : BioPharma Credit takes security
         : BioPharma Cayman released
    2019 : Novocure Limited assigns to Novocure GmbH
         : BioPharma Credit security recorded
    2020 : Lender position moves to BPCR LP
         : All BioPharma releases recorded
         : JPMorgan takes security interest
    2022 : Novocure sues Fieldcure in M D Fla
    2024 : JPMorgan release recorded
         : BioPharma Credit security recorded

NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT. The only non-operating parties in the chain are secured lenders: Deutsche Bank Trust Company Americas (029845/0135), BioPharma Secured Investments III Holdings Cayman LP (034866/0402), BioPharma Credit PLC (045278/0825, 050395/0398, 067315/0399) and JPMorgan Chase as administrative agent (054344/0510). None is a licensing vehicle, none took an assignment of title, and each such filing is either a "Security Interest" or a corresponding "Release." No assignee in the chain carries an "IP / Patents / Holdings / Ventures / Licensing" suffix. Every title-holding assignee — Standen Ltd., Novocure Limited, Novocure GmbH — is a Novocure group entity.

2. Known asserter in the chain — NOT PRESENT. No assignee matches any published NPE list (Acacia, Marathon, IV, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Erich Spangenberg entities). BioPharma Credit PLC is a publicly listed specialty life-sciences debt fund (LSE: BPCR) — a collateral holder, and a party that repeatedly released its interest (052383/0705, 052391/0549, 053597/0335), which is the opposite of NPE behavior. Note the Fieldcure complaint identifies Novocure as plaintiff asserting its own patents in its own name.

3. Repeat correspondent across the chain — UNCLEAR / NOT ESTABLISHABLE. I could not retrieve the correspondent of record for any of the 16 recordings above; Google Patents legal events omit that field and I could not query Assignment Center interactively. I am therefore not making a call in either direction, because a bare "single appearance" would not be a finding anyway. One adjacent data point that is verifiable: the prosecution attorney of record for the '203 patent is Jon Eric C. Morales, Potomac Law Group PLLC (Washington, DC), per FPO's attorney/agent field (https://www.freepatentsonline.com/8715203.html). Potomac Law Group is a general-practice firm with a large, diversified client base in this same window — its top applicants include Imagination Technologies, Meta Platforms Technologies, Oracle, Nikon, Columbia University, NxStage Medical and Novocure (https://www.patentbots.com/patentverse/practitioner/36857-Lobsenz-Charles-B). A diversified operating-company prosecution practice is not an NPE correspondent pattern. Recommended verification step: pull the correspondent field for reels 020934/0313, 029820/0302, 050110/0098 and 067315/0399 directly from Assignment Center and check for a recurring name.

4. Cascading transfers through chained LLCs in <24 months — NOT PRESENT. There is a dense 2019–2020 recording cluster (seven recordings between 2019-04-24 and 2020-11-06), but it is not a chain of shells: it is (i) one genuine title move, Novocure Limited → Novocure GmbH at reel 050110/0098, and (ii) lender-side releases and a lender-successor confirmation at reels 052383/0705, 052391/0549, 052741/0173, 053538/0623, 053597/0335 and 054344/0510. The transferee in the title step is the same corporate group, not an unrelated LLC.

5. Pre-litigation transfer — NOT PRESENT. The first infringement suit naming this patent, Novocure GmbH v. Fieldcure Co. Ltd., No. 8:22-cv-02535 (M.D. Fla.), was filed 2022-11-07 (https://dockets.justia.com/docket/florida/flmdce/8:2022cv02535/407589). The nearest recorded assignments bracket it at 2020-11-06 (054344/0510) and 2024-04-23 (067211/0839) — nothing within six months either side. There was no standing-cleanup or venue-setting transfer. Novocure sued as the long-standing owner of record.

6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 proceeding by any assignor or assignee is reflected in the chain. The original assignee group is a going concern paying 12th-year maintenance fees on this patent as a large entity (2025-10-20), and the 2024-05-01 security agreement (067315/0399) is an ordinary secured financing, not a distressed sale.

7. Privateering — NOT PRESENT. There is no transfer to a third-party NPE asserting on Novocure's behalf. Novocure asserted its own patents in its own name as an operating competitor, against a rival TTFields device manufacturer (Fieldcure, which Novocure alleged told it the Fieldcure device "has virtually identical specifications to the Novocure Optune® device"). The case was voluntarily dismissed without prejudice on 2022-12-02 (docket entries 15 and 16).

8. Defensive aggregator (anti-NPE) — NOT PRESENT. The chain terminates at Novocure GmbH, an operating group entity, not at RPX / AST / LOT / Unified Patents / OIN. The patent has not been neutralized; it is live until the adjusted expiration of 2031-01-18 and carries a recorded lender lien.

Verdict

Operating-company assertion.

US 8,715,203 has never left the Novocure corporate family. The only title transfers of record are the inventor's assignment to Standen Ltd. (reel 020934/0313, executed 2008-05-11), the Standen-to-Novocure Limited change of name (reel 029820/0302, effective 2011-02-21), and the intra-group assignment from Novocure Limited to Novocure GmbH (reel 050110/0098, effective 2019-04-24). Every other recording is a lender's security interest or its release — Deutsche Bank (029845/0135, released 031866/0567), BioPharma Secured Investments III (034866/0402), BioPharma Credit PLC and BPCR LP (045278/0825, 045284/0851, 050395/0398, 052741/0173, 053597/0335, 067315/0399), and JPMorgan as administrative agent (054344/0510, released 067211/0839). The current owner ships the patented transducer array in Optune and asserted the patent against an actual commercial competitor in Novocure GmbH v. Fieldcure Co. Ltd., No. 8:22-cv-02535 (M.D. Fla., filed 2022-11-07, dismissed without prejudice 2022-12-02) — the textbook operating-company posture. No NPE signal is present, and none of the eight signals is even "unclear" on title; only signal 3, the correspondent recurrence test, could not be evaluated with the data accessible here.

Verify at: https://assignmentcenter.uspto.gov/ (search patent number 8715203; the assignment.uspto.gov legacy interface, https://assignment.uspto.gov/patent/index.html, returns the same underlying records). When you pull the records, capture the correspondent field for reel 050110/0098 in particular — that single recording is the one that actually moved title, and its correspondent is the one identity worth cross-checking against Novocure's outside counsel roster. Google Patents' consolidated legal-events view is at https://patents.google.com/patent/US8715203B2/en#legalEvents.

One caution for your dataset: any automated ownership extractor reading Google Patents will likely report "Novocure GmbH / Bpcr LP" as co-owners. That is a false positive created by reel 052741/0173, where BPCR Limited Partnership succeeded to a secured party's position only. If your NPE model is keyed on assignee names in the Current Assignee field, this patent is a good test case for suppressing lender-side recordations.

Generated 9/28/2026, 2:21:40 PM

Prior art

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

✓ Generated

I'll research US patent 8715203 and its cited prior art references. Let me start with searches.

Now let me research the second cited reference and verify the citation details.

Prior Art Analysis — US Patent No. 8,715,203 B2

1. Verification of the Target Patent

I confirmed the record for the exact number requested — US 8,715,203 B2 — and did not substitute any similar numbers.

Field Value
Patent number US 8,715,203 B2
Title Composite electrode
Inventor Yoram Palti
Application no. US 11/856,277
Priority / filing date 2007-09-17
Grant date 2014-05-06
Original assignee Novocure Ltd. (later Standen Ltd. → Novocure Limited → Novocure GmbH)
Primary examiner Jon Eric C. Morales
Claims 27 total; independent claims 1 and 13
Adjusted expiration 2031-01-18 (maintenance fees paid through the 12th year, 2025-10-20)
Related family US 13/790,258 → US 8,764,675 B2 (continuation, same priority)

Source: https://patents.google.com/patent/[US8715203B2](/patent/US8715203B2)/en ; https://www.freepatentsonline.com/8715203.html ; https://uspto.report/patent/grant/8715203


2. Scope of "patent citations for 8715203"

The face of US 8,715,203 lists exactly two examiner-cited U.S. patent references ("Patent Citations (2)"), both marked as cited by the examiner (*). These are the only references cited against the patent and are therefore the only proper § 102/§ 103 candidates:

  1. US 4,809,707 A — "Electrode for non-invasive allergy testing"
  2. US 2003/0029569 A1 — "Substrate processing apparatus"

Important distinction: the 184 "Cited By" documents listed on the page (and the "Families Citing this family (42)") are forward citations — later publications that cite US 8,715,203. They post-date the 2007-09-17 filing and are therefore not prior art to this patent. I exclude them from the § 102 analysis below.

Source: https://www.freepatentsonline.com/8715203.html (U.S. Patent References section shows only these two listings: 20030029569 Natsuhara et al., 4809707 Kraft et al.)


3. Reference-by-Reference Analysis

Reference A — US 4,809,707 A

Field Value
Full citation Kraft et al., "Electrode for non-invasive allergy testing," US 4,809,707 A
Assignee KVM Engineering, Inc.
Filing date 1985-04-12
Publication/grant date 1989-03-07
Status vs. '203 Prior art under pre-AIA 35 U.S.C. § 102(b) (printed publication/patent more than one year before 2007-09-17)
Source https://patents.google.com/patent/US4809707

Brief description. The reference discloses an electrode unit 12 carrying a plurality of allergy-testing electrodes 26 plus one common electrode 28, all contained in a common soft housing 30 that is "both an electrical and thermal insulator." Each of the eight test electrodes includes (a) means for transcutaneously delivering an allergen and (b) temperature-sensing means (a thermistor 36 soldered to a thin-film thermal-equilibrium ring 32) for sensing skin temperature at the test site. Leads 18 and 20 supply individual wiring and common charging/ground wires to the electrodes, and the unit is affixed to the patient's skin with double-sided tape 46. The associated disclosure of US 4,819,657 (same family, "Automatic allergy detection system," KVM Engineering) confirms a plurality of spaced-apart skin-contacting electrodes each with a temperature pickup.

What it teaches relevant to the '203 claims.

  • A plurality (here eight) of skin-contacting electrodes + one common electrode on a common support/housing — maps to the "plurality of ... elements" + "support structure" + "first lead" concepts.
  • Temperature sensing beneath each electrode via thermistors — maps to the temperature-sensor limitations (claims 2, 6, 13, 15).
  • Adhesive attachment to skin and a return/common electrode.

What it does NOT teach.

  • The electrodes are not ceramic elements. There is no ceramic dielectric, no ceramic disc, no "conductive backing silvered on one side," and no ceramic-element capacitance limitation (claims 5, 11, 18: ≥1.5–2.5 cm diameter, ≥2.0 nF / ≥20 nF).
  • No direct electrical connection between an upper surface of each ceramic element and a first lead through a flex circuit (claims 3, 5, 12, 27).
  • The allergen-delivery/charge-plate architecture is structurally remote from a capacitive ceramic electrode array for applying AC fields.
  • No hydrogel layer, no foam filler layer with cutouts, no covering/adhesive tape over the array (claims 7–8, 13–14, 21, 24–26).

§ 102 assessment. US 4,809,707 does not anticipate any of claims 1–27, because it discloses no ceramic element, and every independent claim (1 and 13) expressly requires "a plurality of ceramic elements" with a "lower surface configured to rest on a patient's body" and an "upper surface." No single claim is fully disclosed. This reference is best characterized as a § 103 secondary reference teaching the convenience of multiple skin electrodes on a common support with per-electrode temperature sensing.


Reference B — US 2003/0029569 A1

Field Value
Full citation Natsuhara et al., "Substrate processing apparatus," US 2003/0029569 A1 (Sumitomo Electric Industries, Ltd.)
Priority 2001-04-11 (JP 2001-112902); EP counterpart EP 1 249 859 A3
Filing date 2002-04-10
Publication date 2003-02-13
Status vs. '203 Prior art under pre-AIA 35 U.S.C. § 102(a)/(e) (published more than one year before 2007-09-17)
Source https://patents.google.com/patent/US20030029569

Brief description. A semiconductor-processing apparatus in which the substrate susceptor comprises a flat-plate ceramic base body (2) carrying electric circuitry — specifically "at least one selected from the group consisting of a resistance heater, an electrode for electrostatic chuck and an RF electrode." A power-supply conductive member is electrically connected to the circuitry and drawn out of the chamber, and a temperature-measurement terminal (e.g., a thermocouple) is inserted from outside the chamber to measure the temperature of the ceramic base body. The ceramic module is supported by contact with the chamber wall for thermal uniformity.

What it teaches relevant to the '203 claims.

  • A ceramic body with an electrode/circuitry formed on it and a conductive member electrically connected to that circuitry — the general concept of "ceramic element + electrical conductor + lead."
  • A temperature sensor associated with the ceramic body — maps conceptually to the temperature-sensor limitations.

What it does NOT teach (this is decisive).

  • The susceptibility is a single ceramic base body for holding a semiconductor wafer in a vacuum chamber — it is not "a plurality of ceramic elements" and is not "configured to rest on a patient's body." There is no patient, no skin contact, no hydrogel, no adhesive covering.
  • No array of discrete ceramic discs arranged in a 3×3 / 2×2 array.
  • No "direct electrical connection between the upper surface of each of the ceramic elements and the first lead" in a medical, skin-contacting configuration.
  • No flex circuit serving simultaneously as conductor and support structure for a patient-contacting array.
  • The field (plasma CVD/etching equipment, H01L/H01M) is non-analogous to external electrotherapy electrode design.

§ 102 assessment. US 2003/0029569 does not anticipate any claim of US 8,715,203. It fails the "configured to rest on a patient's body," "plurality of ceramic elements," and "support structure mechanically connecting the ceramic elements during use" limitations of independent claims 1 and 13, and discloses none of the dependent-claim specifics (sizes, capacitance values, thermistor count, hydrogel, foam filler, flex-circuit soldering). Its realistic role is as a § 103 reference for the bare proposition that a ceramic body may carry an electrode/circuitry with a temperature-measurement element — a teaching the applicant's own assignee (Novocure) had already developed in the field of AC-field tumor therapy.


4. Claim-by-Claim § 102 Result

Claim Subject matter Anticipated by US 4,809,707? Anticipated by US 2003/0029569? Basis
1 Composite electrode: plurality of ceramic elements (lower surface on patient / upper surface) + first lead + conductor + support structure No No Neither discloses ceramic elements configured to rest on a patient's body
2 ≥1 temperature sensor beneath a ceramic element No (non-ceramic thermistor array) No (chamber thermometer) Missing ceramic element
3 Conductor + support = flex circuit No No Not disclosed
4 ≥4 ceramic elements No No No ceramic array
5 ≥4 discs, 1.5–2.5 cm dia., ≥2.0 nF, flex circuit No No No ceramic discs / values
6 ≥2 thermistors under ≥2 discs No (thermistors, not under discs) No No discs
7 Adhesive covering above elements Partially (tape 46) but not over a ceramic array No No ceramic array
8 Filler layer with cutouts No No Not disclosed
9 ≥1 temperature sensor No (non-ceramic) No Missing ceramic element
10 Disc-shaped elements No No Not disclosed
11 Nine discs, 1.5–2.5 cm, ≥20 nF, flex circuit, ≥4 thermistors No No Not disclosed
12 Flex circuit soldered to conductive backing on upper surface No No Not disclosed
13 Independent: ≥4 ceramic elements + conductor + support + ≥2 temperature sensors + conductive hydrogel layer + adhesive covering No No Missing ceramic elements, hydrogel, covering
14 Peel-away backing No No Not disclosed
15 Thermistors as sensors No (non-ceramic context) No Missing ceramic element
16 Flex circuit No No Not disclosed
17 9 ceramic elements No No Not disclosed
18 9 round elements, 1.5–2.5 cm, ≥20 nF, flex, ≥4 sensors No No Not disclosed
19 Disc-shaped No No Not disclosed
20 Holes in element centers with sensors in the holes No No Not disclosed
21 Foam filler layer with cutouts No No Not disclosed
22 Disc-shaped No No Not disclosed
23 Sensors in center holes No No Not disclosed
24 Filler layer No No Not disclosed
25 Filler layer with adhesive bottom + cutouts No No Not disclosed
26 Foam filler layer with adhesive bottom + cutouts No No Not disclosed
27 Flex circuit soldered to upper-surface conductive backing No No Not disclosed

5. Conclusions

  1. The only prior art cited against US 8,715,203 is US 4,809,707 A and US 2003/0029569 A1 (both examiner-cited). The 184 "cited by" documents are forward citations and are not prior art to this patent.

  2. No § 102 anticipation exists on the cited record. Neither reference, alone, discloses every element of any of claims 1–27. Critically, neither reference discloses a plurality of ceramic elements having a lower surface configured to rest on a patient's body with a direct electrical connection between the upper surface of each element and a first lead — the core of both independent claims 1 and 13.

  3. The two references are best understood as § 103 combination prior art, not § 102 art:

    • US 4,809,707 supplies the "array of skin-contacting electrodes on a common support, each with a temperature sensor (thermistor)" teaching (relevant to claims 1, 2, 4, 6, 9, 13, 15).
    • US 2003/0029569 supplies the "ceramic body carrying electrode circuitry with a temperature-measurement element and a conductive lead" teaching (relevant to the "ceramic element + conductor + lead" limitations).
    • The gap neither reference fills — and the likely point of novelty that sustained allowance — is the capacitive ceramic-disc array (with the specific diameter/capacitance/breakdown parameters), flex-circuit support/conduction, hydrogel and foam-filler packaging, and center-hole thermistor placement tailored for applying alternating electric fields to a patient.
  4. Context note (not § 102): The patent family is flagged for litigation in the U.S. District Court for the Middle District of Florida, Case No. 8:22-cv-02535 (per Unified Patents/Darts-IP data on the record). This is relevant to validity/challenge posture but does not change the prior-art analysis.

Caveat: This is a technical prior-art mapping, not a legal conclusion. The § 102/§ 103 characterizations above should be confirmed against the prosecution history (the examiner's actual rejections and the applicant's amendments), which is not contained in the provided record and which I could not verify from the sources retrieved. I did not locate the file-wrapper rejection text; if that history exists, I would want to check it before treating my § 103 characterization as definitive.

Generated 9/28/2026, 2:21:09 PM

Obviousness

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

✓ Generated

I'll research the prior-art references listed on this patent's page before building the § 103 analysis.

Now let me research the references incorporated by reference in this patent's background, plus the related family members cited on the page.

Let me check the remaining incorporated reference and any validity challenges to this patent.

Obviousness Analysis — U.S. Patent No. 8,715,203 B2 ("Composite Electrode")

Prepared under 35 U.S.C. § 103(a) (pre‑AIA, application filed 2007‑09‑17)
Legal standard: Graham v. John Deere, 383 U.S. 1 (1966); KSR Int'l v. Teleflex, 550 U.S. 398 (2007); MPEP § 2143 rationales (A)–(G).


1. Threshold: the prior-art set actually on this page

The page lists only two Examiner citations in its "Patent Citations (2)" section — an unusually thin record for a 27‑claim patent:

Ref. Date Status Disclosure snapshot
US 4,809,707 A (KVM Engineering) — Electrode for non-invasive allergy testing 1985‑04‑12 filed; 1989‑03‑07 issued § 102(b) art Electrode 12 with a plurality (eight) of testing electrodes 26 plus a common electrode 28 in a common housing 30 (soft insulating material = support structure); each element has a charge plate 40 connected to lead 20 and its own thermistor 36 mounted through a hole 37 in an insulating base 34, wired out on lead 18. (Google Patents; family continuation US 4,819,657; claims at RPX)
US 2003/0029569 A1 (Sumitomo Electric) — Substrate processing apparatus 2001‑04‑11 priority; 2003‑02‑13 published § 102(b) art A ceramic module whose flat‑plate portion comprises a ceramic base body (2) carrying electric circuitry (3a–3c), supported by a housing; background of the same document describes a ceramic disc with embedded electrodes and a thermocouple taken out through a support. (Google Patents; EP counterpart EP 1 249 859 A3)

Also available as prior art (incorporated by reference in the '203 specification itself, and therefore admitted/usable): US 7,136,699 and US 7,146,210 (Palti/Standen, issued 2006‑11‑14 and 2006‑12‑05) and US 2005/0209642 A1 (published 2005‑09‑22) — all § 102(b). These teach the therapeutic reason the electrode must be capacitive/insulated (50–500 kHz fields, avoidance of electrolysis and ion‑concentration change, weeks‑to‑months wear). See US 7,565,206 (granted counterpart of the '642 family) and US 2005/0209642 text.

Corroborating art located by search (not on this page; verify before relying): US 2006/0149341 A1 / WO 2006/061688 (Palti/Standen, priority 2004‑12‑07, published 2006‑07‑06 / 2006‑06‑15) — expressly describes a "composite electrode" made of individual segments held together by a support structure (cloth, netting, or other flexible backing), all segments electrically connected in parallel by wiring, each segment having a conductive core covered by a dielectric on the body‑facing side.


2. Claim 1 — element mapping for the two lead combinations

Claim 1 limitation US 4,809,707 US 2003/0029569 US 2005/0209642 / 7,146,210
"plurality of ceramic elements … lower surface … upper surface" Plurality of skin‑contacting elements 26 (+28) in one electrode Ceramic body carrying circuitry; ceramic disc element with electrodes Insulated/"isolect" elements applied to skin; teaches the insulation should be a high‑permittivity dielectric (TiO₂/rutile, ε≈200)
"a first lead" Lead 20 / lead 18 to each element Power‑supply conductive members Common AC lead per array
"electrical conductor … direct connection between the upper surface … and the first lead" Charge plate 40 → lead 20 Circuitry 3a–3c on/in the ceramic Conductor attached to the rear (non‑skin) face of the dielectric
"support structure … mechanically connect the plurality … during use" Common housing 30 / base 34 Module supported by the housing Support structure (cloth/netting/backing) holding segments together

Combination A (primary): US 4,809,707 + US 2003/0029569, with US 2005/0209642 / US 7,146,210 supplying the motivation.
Combination B (alternative/stronger on "support structure" + flex): the same two references + US 2006/0149341 A1.

Motivation to combine (MPEP 2143 (A), (B), (C), (F)):

  1. The problem is defined by the applicant's own incorporated art. The '699/'210/'642 references state that the field must be delivered capacitively through an insulator to avoid electrolysis and ionic shifts — i.e., the conductor must not contact skin. This is a design incentive, articulated in the field itself, to replace the ohmic charge plate of US 4,809,707 with a dielectric body; a body that is simultaneously the dielectric and the mechanical element points to a ceramic.
  2. The substitution is a known, predictable one. US 4,809,707 already teaches a discrete element with a conductive plate on the patient‑facing side and a lead on the side facing away; placing the conductor on the upper (non‑body) face and letting the ceramic body form the skin‑facing surface preserves the function (delivering field) while adding capacitance.
  3. The dielectric requirement is quantified in the art. The '642 family teaches an internal‑insulation impedance below ~100 kΩ at 50–500 kHz (≈10⁻¹⁰ F for a 10 mm² isolect) and expressly suggests high‑permittivity materials — a finite, identified set of solutions that ceramic discs satisfy by routine design.
  4. Ceramic bodies with conductor and thermocouple, in a driven structure, are documented in US 2003/0029569, including its recitation of a ceramic disc with embedded electrodes and a thermocouple taken out through a support.
  5. Market/design pressure (§ 2143(F)): the therapy requires weeks of skin contact, which the '341/'688 application says causes irritation, moisture occlusion and pressure problems — pushing toward a modular, replaceable, disc‑based array.

Achievement is predictable: claim 12 (and claim 27) defines the "direct electrical connection" as a flex circuit soldered to a conductive backing on the upper surface — a silvered disc with a soldered trace; the '203 specification itself calls this "any conventional technique (e.g., solder)." Combination B supplies the flex/support teaching almost verbatim.


3. Dependent-claim chart

Claim(s) Additional limitation Basis in the cited art Rationale (MPEP § 2143)
2, 9 temperature sensor beneath ≥1 ceramic element US 4,809,707 — thermistor 36 at each testing electrode sensing skin temperature (A) known elements, known function; heat is a known by‑product of dielectric loss/current flow
3, 16 conductor + support = flex circuit US 2006/0149341 A1 (parallel wiring on a flexible backing); flex circuits routine in medical electrode arrays (C)/(F) known technique, predictable result; spec concedes "discrete wiring, ribbon cable" equivalents
4, 17 ≥4 (or 9) elements US 4,809,707 has eight + common; '642 shows multi‑electrode arrays (A)/(B) mere duplication with predictable effect
5, 11, 18 discs, Ø 1.5–2.5 cm, ≥2.0 nF / ≥20 nF, 9 discs, ≥4 thermistors '642 family quantifies required capacitance/impedance; 3×3 array is an express alternative in the '203 spec itself (B)/(E) optimization of a result‑effective variable; no disclosed criticality for the ranges
6, 15 ≥2 thermistors US 4,809,707 (one per element) (A)
7, 13, 14 hydrogel layer; adhesive covering above; peel‑away backing US 4,367,755 (gel pad, Karaya gum, backing with perforations) as cited in the Palti family; '642 intervening conductive gel; US 4,809,707 double‑sided tape closure (A)/(C) — standard skin‑electrode laminate
8, 21, 24–26 filler layer (foam) with adhesive bottom and cutouts US 4,809,707 base 34/housing 30 with openings receiving elements; commercial foam tape (C)/(F)
10, 19, 22 disc‑shaped US 2003/0029569 (disc ceramic heater) (B)
12, 27 flex soldered to conductive backing on upper surface Silvered‑disc + solder; US 2006/0149341 (B)
20, 23 holes at element centers with the temperature sensors in the holes US 4,809,707: thermistor 36 fastened through a hole 37 in base 34; claim 20 thereof recites pickup means "having an opening therethrough" with the delivery means positioned through the opening (B) near‑identical structure — strongest single mapping in the patent

4. Assessment

Likely obvious (high risk): claims 1–4, 6–10, 12–17, 19–27. Each is a combination of elements that the cited art shows performing the same function, joined by a motivation appearing in the applicant's own incorporated references.

Defensible but exposed (moderate risk): claims 5, 11, 18 (Ø 1.5–2.5 cm, ≥20 nF/disc, nine discs, ≥4 thermistors) and claim 20/23 (center holes). These recite numerical/structural specifics, but the specification discloses no criticality data (no comparative results showing the ranges are performance‑critical), so the "optimization of a result‑effective variable" and "obvious to try" rationales apply; the 3×3 array is expressly stated in the specification as one option among a "2×2" and "2×3" array.

Patentee's best rebuttals:

  • Non‑analogous art — US 4,809,707 is allergy/iontophoresis diagnostics, US 2003/0029569 is semiconductor processing. In re Bigio/KSR answer: a reference is analogous if reasonably pertinent to the problem addressed; both are pertinent to "conductive/ceramic body pressed against a substrate with electrical drive and temperature sensing."
  • No teaching of ceramic elements in the skin‑electrode art, and no suggestion to combine.
  • Different principle of operation — US 4,809,707 injects current; the '203 couples capacitively. This is the patentee's strongest point, but it is undercut because the capacitive requirement is precisely what the applicant's own prior patents ('699/'210/'642) demand.
  • Secondary considerations — Novocure's commercial success (Optune), the long‑felt need for electrodes tolerated for weeks/months, and the page's note of litigation (Florida M.D., case 8:22‑cv‑02535) and licensing/industry copying. These are real, but they attach principally to the underlying field‑therapy platform (Palti's 1990s–2000s patents), not to the incremental electrode geometry claimed here; nexus would be contested.

Ancillary (non‑§ 103) observations to note, without correcting anything:

  • Claim 5 recites "at least 2.0 nF" while the specification's embodiment recites "at least 10 nF per disc"; claims 11 and 18 recite "at least 20 nF." I have taken these literally and not harmonized them.
  • The specification states the array should provide "at least 120 nF" from discs of "at least 10 nF," which implies 12 discs, while the illustrated array is 3×3 (nine) discs (nine × 10 nF = 90 nF). This internal inconsistency may be relevant to written‑description/enablement for the recited capacitance ranges.
  • The "Prior art keywords" shown on the page are Google‑generated, not an Examiner statement of record.

Verification needed before relying on this analysis: full text and drawings of US 2003/0029569 A1 (I relied on its Google Patents description text and the EP 1 249 859 A3 abstract of the same Sumitomo family); the file wrapper (PTActs) to see whether a § 103 rejection was ever made and overcome; and full‑text confirmation of US 2006/0149341 A1, which is not listed in this patent's citation section.

Generated 9/28/2026, 2:21:59 PM

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