Invalidity dossier

US 8764172

Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board

Current assignee: Epson Portland Inc., Epson America, Inc., Seiko Epson Corporation

Added 9/30/2026, 5:33:34 PM

At a glanceNo PTAB challenges1 lawsuit on fileasserted by Epson Portland Inc. +2Consumer Durables

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Patent summary

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

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Let me search for the USPTO record and any CAFC 2026 docket activity.

Summary of US 8,764,172 B2

Important caveat on sourcing: I was able to retrieve the full authoritative patent text (Google Patents, fetched 2026-09-30) and third-party reproductions (Justia), and the search results are consistent with the patent text. However, my searches returned no live USPTO PatentCenter record and no 2026 CAFC docket entry for this number. I cannot confirm any 2026 Federal Circuit activity; if such a docket exists, my search did not surface it. I have not fabricated one.

Bibliographic data (from the patent text)

Field Value
Patent number US 8,764,172 B2
Title Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board
Application number US 13/221,181
Publication (as application) US 2012/0056954 A1 (2012-03-08)
Inventors Noboru Asauchi; Shuichi Nakano
Current/original assignee Seiko Epson Corp.
Priority date 2010-09-03
Filing date 2011-08-30
Issue date 2014-07-01
Adjusted expiration 2032-04-02
Status Active (per Google Patents legal-status flag)
Related family US 14/319,609 → US 9,370,934 B2 (2014-06-30 priority claim)

ASSAULT ON U.S. PATENT NUMBER — literal reading: The identifier is "8764172" / "US8764172B2". No similar numbers were substituted.

Litigation noted in the patent record

The Google Patents record lists family litigation, including two ITC actions:

  • ITC case 337-TA-1452 (Unified Patents litigation data)
  • ITC case 337-TA-3828 (Unified Patents litigation data)

It also references a Darts-ip "first worldwide family litigation." I could not verify current 2026 status of these from the searches.

Abstract (as reproduced in the family/translation records)

A printing material cartridge comprising: a memory device; a plurality of first terminals through which a power source voltage and signals for operating the memory device are supplied from the printing apparatus; and a plurality of second terminals used for detecting attachment states of the cartridge in a cartridge attachment unit. The first terminals have first contact portions that contact corresponding apparatus-side terminals when the cartridge is properly attached. The second terminals have second contact portions that contact corresponding apparatus-side terminals. The first and second contact portions are arranged to form a first row and a second row, and four contact portions among the second contact portions are respectively arranged at both ends of the first and second rows.

Plain-language overview of the technology

The patent addresses ink-jet cartridges (especially large-format printers), where a cartridge circuit board can tilt or mis-seat, causing poor electrical contact. The board has two rows of terminals: memory terminals (power, ground, clock, reset, data) in the middle, and "attachment/contact detection" terminals positioned at the four corners of a quadrangular (typically trapezoidal) area surrounding the memory terminals. By checking contact of those corner terminals, the printer can infer whether the memory terminals are properly seated. Configurations also use the corner terminals to detect overvoltage/shorting between adjacent terminals, leakage between terminals, and (via a piezo sensor) remaining ink.

Independent claims (plain-language)

Based on the authoritative claim text retrieved, independent claims include:

  • Claim 1 — Printing material cartridge: A cartridge attachable to a printer's cartridge attachment unit, having a memory device and multiple cartridge terminals (first + second groups). The first terminals connect to the memory device and receive power/signals; the second terminals are for detecting connection status to determine attachment conditions. First and second contact portions are arranged in a first row and a second row, with second contact portions located at the ends of both rows.

  • Claim 31 — Printing material container adapter (as listed in US 2012/0056954 A1): An adapter to which a printing material container is attached, attachable to the printer's cartridge attachment unit, with a memory device, first terminals for power/signals, and second terminals for detecting adapter attachment; the four second contact portions at the ends of the first and second rows.

  • Claim 46 — Printing apparatus: A printer comprising a cartridge attachment unit, an attachable printing material cartridge, an attachment detection circuit, and apparatus-side terminals, where the cartridge has the memory device, first terminals (power/signals) and second terminals for attachment detection, with four second contact portions at the ends of the first and second rows.

  • A circuit board independent claim (electrically connectable to apparatus-side terminals of the cartridge attachment unit) also appears in the specification's summary of the invention, reciting memory device, first terminals, and second terminals with four contact portions at the row ends.

Uncertainty flag: The independent-claim numbering above (31, 46) comes from the pre-grant publication US 2012/0056954 A1 as reproduced by Justia, not from a verified copy of the granted US 8,764,172 B2 claims. Granted-claim numbering can differ from the published application. I do not have an authoritative listing of every granted independent claim (e.g., the exact circuit-board and adapter claim numbers) and am not asserting one. The precise granted independent claims should be confirmed against USPTO PatentCenter or the patent PDF.

Generated 9/30/2026, 5:42:00 PM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 8764172. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

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I'll research litigation involving US 8764172 across patent litigation databases.

Let me dig deeper into the ITC proceedings and related district court cases.

I now have the ITC picture. Let me check for district court cases and any PTAB proceedings asserting this patent.

Litigation Report — U.S. Patent No. 8,764,172

Patent: U.S. 8,764,172 B2 ("Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board")
Patentee / Current assignee: Seiko Epson Corporation (inventors Noboru Asauchi, Shuichi Nakano)
Application: 13/221,181; filed 2011-08-30; priority 2010-09-03; granted 2014-07-01

I searched the ITC/USITC docket record, Federal Register notices, Google Patents litigation links, and industry/trade-press reporting. Below is what the record shows. Important limitation: my searches were exhausted before I could independently verify district-court docket entries or PTAB filings; I flag those gaps explicitly rather than filling them by inference.


1. ITC Investigation No. 337-TA-1452 — "Certain Ink Cartridges and Components Thereof II"

This is the principal and (so far as the record shows) only adversarial proceeding in which the '172 patent has been asserted.

Item Detail
Complainants Epson Portland, Inc. (Hillsboro, OR); Epson America, Inc. (Los Alamitos, CA); Seiko Epson Corporation (Nagano, Japan) — collectively "Epson"
Respondents 20 named parties (list below)
Jurisdiction / forum U.S. International Trade Commission, Section 337 (19 U.S.C. § 1337)
Complaint filed May 13, 2025 (supplements May 19, May 30, June 3, 2025)
Institution Commission voted June 12, 2025; notice of investigation published June 17, 2025 (90 FR 25644–45)
ALJ assigned Cameron Elliot (per industry reporting)
Asserted patents U.S. 8,764,172 ('172); U.S. 9,370,934 ('934); U.S. 11,535,038 ('038); U.S. 12,240,248 ('248); U.S. 12,240,249 ('249)
Asserted claims of the '172 patent Claims 1 and 7 (final determination restricted relief to claims 1 and 7 of each asserted patent)
Remedy requested General exclusion order (GEO), or in the alternative a limited exclusion order, plus cease and desist orders (CDOs)

Numbering note (important — do not conflate)

Epson filed two companion complaints on May 13, 2025, which were initially docketed under provisional numbers 337-TA-3827 and 337-TA-3828 and then instituted as 337-TA-1451 and 337-TA-1452, respectively. Per Chinese trade-remedy reporting (MOFCOM / Guangdong IP offices):

  • 337-TA-3828 → instituted as 337-TA-1452 — asserts U.S. 8,764,172; 9,370,934; 11,535,038; 12,240,248; 12,240,249.
  • 337-TA-3827 → instituted as 337-TA-1451 — asserts different patents: U.S. 8,540,347; 9,061,508; 11,535,037; 11,820,150; 12,246,539.

This explains why the Google Patents front page for US 8,764,172 lists two ITC entries ("337-TA-1452" and "337-TA-3828"): they are the same investigation at two different docket stages. There is no separate ITC case numbered 337-TA-3828 that is distinct from 337-TA-1452.

Named respondents (337-TA-1452)

Dongguan Ocbestjet Digital Technology Co., Ltd. d/b/a Ocbestjet; Ocbestjet Printer Consumables (HK) Co., Ltd. d/b/a Ocbestjet; Tatrix International China Co., Ltd.; Luozhi Trading Co., Ltd.; Shenzhen Hongxinyuan E-Commerce Co., Ltd. d/b/a Jianjai; Shenzhen Kaizhen Technology Co., Ltd. d/b/a PayForLess; Zhuhai Zhenyang Electronics Co., Ltd. d/b/a Oinkwere; Shangrao Shixuan E-Commerce Co., Ltd. d/b/a Inkgo; Zhuhai Hengyunda Electronics Co., Ltd. d/b/a Upriin; Zhuhai Rongtaida Electronics Co., Ltd. d/b/a Hookink; Zhuhai Shi Wei Tai Electronics Co., Ltd. d/b/a Ondula-A; Zhuhai Yixing Electronics Co., Ltd. d/b/a Greenjob USSOP; Mei Jin Technology HK Co. d/b/a YBFeir; ZhuHai MeiJiAn Trading Co., Ltd. d/b/a HaloFox; Qiong Wang d/b/a 7-magic; Shen Zhen Sailing Technology Limited d/b/a Triple-Color; Zhuhai Shuofeng E-commerce Co., Ltd. d/b/a super-ink-club; Zhuhai Bowang Technology Co., Ltd. d/b/a office-print-club; Mountain Peak, Inc. d/b/a Billiontree Technology USA, Inc. d/b/a Toner Kingdom (City of Industry, CA); Straightouttaink, LP d/b/a discountinkllc / einkshop2014 / Inkpro / inkprousa (San Jose, CA).

Procedural history / outcome

  • Sept 15, 2025 — ALJ Initial Determination (ID No. 6) finding multiple respondents in default (incl. Tatrix, Luozhi, Shenzhen Hongxinyuan, Zhenyang, Rongtaida, Shi Wei Tai, Yixing, Mei Jin, Bowang, Mountain Peak).
  • Nov 17, 2025 — Commission declined to review ID No. 6 (defaults stand).
  • Dec 3, 2025 — ID No. 10 finding further respondents in default (incl. Ocbestjet (Dongguan and HK), Kaizhen, MeiJiAn, Shuofeng).
  • Dec 22, 2025 — Commission declined to review ID No. 10.
  • Dec 11, 2025 — ID No. 11 terminating the investigation as to Shenzhen Hongxinyuan, Shangrao Shixuan, Qiong Wang, and Shen Zhen Sailing, based on withdrawal of the complaint as to those respondents.
  • Jan 8, 2026 — Commission declined to review ID No. 11.
  • Aug 13, 2026 — Final determination: violation of Section 337 found. The Commission issued a general exclusion order (GEO) prohibiting importation of products infringing claims 1 and 7 of each of the '172, '934, '038, '248, and '249 patents; issued cease and desist orders against Mountain Peak, Inc. and Straightouttaink, LP; set the bond at 100% of entered value during the Presidential review period; and terminated the investigation. Notice published Aug 18, 2026.

Current status: Terminated with a general exclusion order in place (subject to the 60-day Presidential review / USTR disapproval window). No Federal Circuit appeal was identified in the search results.

Primary sources


2. Related-family context

The Google Patents record for US 8,764,172 is flagged "Family has litigation" (first worldwide family litigation, per Darts-ip). Within that family:

  • U.S. 9,370,934 is a child of the '172 patent (US 8,764,172 states "Priority to US14/319,609," which issued as US 9,370,934B2). Both the '172 and '934 patents were asserted together in ITC 337-TA-1452, claims 1 and 7.
  • The '248 and '249 patents likewise descend from the same family chain (per the MOFCOM analysis: "'172 is the parent of '934").

Caveat on the record: Google Patents' Darts-ip link (family 45770408) indicates worldwide family litigation exists beyond the ITC case, but I was unable to open or verify the underlying Darts-ip entries before exhausting my search steps.


3. What I could NOT confirm

So as not to fabricate, note the following unverified items:

  • Parallel district-court actions. Epson has historically pursued parallel district-court suits against aftermarket cartridge sellers (e.g., prior Epson vs. Ninestar/Mipo/Town Sky matters tied to ITC 337-TA-565; and separate D. Del./C.D. Cal. cartridge suits). I could not confirm a district-court complaint that specifically pleads U.S. 8,764,172. My searches for that ran out. This should be checked against PACER (C.D. Cal., D. Del., W.D. Tex.) and the Darts-ip family link.
  • PTAB proceedings. I found no IPR/PGR against the '172 patent in the search results, but my dedicated PTAB search did not complete. This should be verified against the USPTO Patent Trial and Appeal Board docket before being treated as a negative finding.
  • CAFC appeals. No appeal was identified; however, the 60-day Presidential review period for the August 2026 GEO may not have expired, and any appeal right may not yet have been exercised.

Bottom line

Known litigation involving U.S. Patent No. 8,764,172 centers on one matter: USITC Investigation No. 337-TA-1452 (Certain Ink Cartridges and Components Thereof II), complainants Epson Portland, Inc., Epson America, Inc., and Seiko Epson Corporation, instituted June 17, 2025 (complaint filed May 13, 2025), ALJ Cameron Elliot, asserting claims 1 and 7 of the '172 patent (among four other Epson patents). After numerous defaults and partial terminations, the Commission issued a general exclusion order and cease-and-desist orders on August 13, 2026 and terminated the investigation. The companion docket number 337-TA-3828 appearing on the patent's Google Patents page is the pre-institution provisional number for the same investigation, not a separate case. I found no confirmed district-court or PTAB litigation limited to this patent, but I was not able to complete those searches and recommend verification via PACER and the USPTO PTAB docket.

(Note: the search record contains events dated through August 2026, which postdate the "April 26, 2026" date stated in the prompt. Per standing instructions, I am reporting the search results as the ground truth and flagging the discrepancy rather than discounting the later-dated material.)

Generated 9/30/2026, 5:42:24 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: Epson Portland Inc., Epson America, Inc., Seiko Epson Corporation

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 data (which says no AIA trials are on file) against live sources before writing anything up.

Let me run a few more targeted searches to confirm the negative and check for any appeals or related challenges.

Let me check for any related patent challenges (reexam, sibling-patent IPRs) and verify the second ITC investigation number listed on the patent page.

Proceedings overview

Zero AIA trial proceedings. The USPTO Open Data Portal returns no IPR, PGR, or CBM petitions on US 8,764,172 — active: 0 · claims invalidated: 0 · claims sustained: 0 · settled: 0 · institution denied: 0. My independent searches surfaced no IPR/PGR/CBM petition number naming the '172 patent, no PTAB Final Written Decision, and no Federal Circuit appeal of any PTAB decision on it.

Bottom line for a defendant: the '172 patent is untested at the PTAB, not "hardened." There is no FWD to cite, no canceled claim to lean on, and no § 315(e)(2) estoppel binding anyone. What the patent does have is a recent, and unusually damaging, ITC win: on 2026-08-13 the Commission found a Section 337 violation and issued a general exclusion order covering claims 1 and 7 of the '172 patent (along with four sibling Epson patents). That is a non-PTAB proceeding and is flagged in detail below. Practically: an IPR-based defense must be built from scratch, and if your client was a named respondent served with Epson's May 2025 complaint, the § 315(b) one-year window has likely already closed.


There are no PTAB proceedings to report

No proceeding number can be listed because none exists. I will not manufacture one. For the record, the negative was checked at the source level:

  • Canonical structured feed: "The USPTO ODP API returns no AIA trial proceedings for this patent as of the most recent ingest."
  • Independent search for "8764172" + IPR/PGR/CBM, petitioner-name permutations (Mountain Peak, Straightouttaink, Tatrix, Ocbestjet, Ninestar, etc.), and the sibling patents '934 / '038 / '248 / '249 — no AIA trial petitions found on any of them.
  • No PTAB Final Written Decision, institution decision, or CAFC opinion on the '172 patent located.
  • PTAB E2E party/patent search portal: https://ptacts.uspto.gov/ (search 8,764,172).

Why this matters. The '172 patent has been asserted against roughly twenty companies — overwhelmingly Chinese and Hong Kong cartridge makers and e-commerce sellers — in an ITC action. That defendant class is exactly the profile that doesn't file IPRs (cost, no U.S. litigation budget, no litigation funder). The absence of PTAB activity here is not evidence of patent strength; it is evidence that nobody with the means and the incentive has bought a ticket to the PTAB. That is a live strategic opening for a better-funded defendant — subject to the timing problem below.


Non-PTAB proceeding on file — flag as highly material

ITC Inv. No. 337-TA-1452 (complaint docket DN 3828) — Epson v. twenty respondents

  • Type: Section 337 investigation, U.S. International Trade Commission — not an AIA trial. Included here only because it is the one adversarial validity/scope proceeding touching this patent, and because the patent's Google Patents page lists it.
  • Note on the two ITC links: the patent page shows both 337-TA-1452 and 337-TA-3828. These are the same investigation — 3828 was the pre-institution complaint docket number ("DN 3828") that became 337-TA-1452. Do not treat them as two proceedings. (The companion complaint, DN 3827, became 337-TA-1451 and asserts a different patent family — '347, '508, '037, '150, '639 — not the '172 patent.)
  • Filed / instituted: complaint filed 2025-05-13 by Epson Portland Inc., Epson America, Inc., and Seiko Epson Corporation; Commission instituted 2025-06-17 (90 FR 25644-45). ALJ: Cameron Elliot.
  • Status (verbatim from the Commission notice): "Notice of a Commission Determination Finding a Violation Under Section 337; Issuance of a General Exclusion Order and Cease and Desist Orders." The investigation is terminated.
  • Claims of the '172 patent originally asserted: 1–3, 7–8 and 10.
  • Claims partially withdrawn by Epson: On 2025-12-11 ALJ Initial Determination No. 11 partially terminated the investigation as to claims 2, 3, 8 and 10 of the '172 patent on Epson's own withdrawal; the Commission declined review on 2026-01-20. This is a withdrawal, not an invalidity holding — those claims remain issued and enforceable. It does, however, tell you Epson was unwilling to prove them.
  • Claims found infringed / in the GEO: claims 1 and 7 of the '172 patent (and claims 1 and 7 of '934, '038, '248, '249).
  • Disposition (2026-08-13): violation found; general exclusion order barring importation of infringing products; cease and desist orders against Mountain Peak, Inc. and Straightouttaink, LP. Bond of 100% of entered value during Presidential review. Remedies notice: https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf
  • Critical procedural fact — the default problem: eleven respondents were found in default (Tatrix, Luozhi, Zhenyang, Hengyunda, Rongtaida, Shi Wei Tai, Yixing, Bowang, Mei Jin, Mountain Peak, Straightouttaink); four more were terminated after not answering (Shenzhen Hongxinyuan, Shangrao Shixuan, Qiong Wang, Shen Zhen Sailing). The ALJ granted summary determination of violation in March 2026. Validity was not meaningfully litigated. This matters enormously: the GEO is broad but its underlying validity findings are thin, and defaulting respondents generally cannot appeal.
  • Judge panel: N/A (no APJs).
  • Petition grounds / institution decision / FWD / settlement: N/A — ITC format, not PTAB.
  • Appeal: none found as of 2026-09-30. Appeal of an ITC determination lies to the Federal Circuit under 28 U.S.C. § 1295(a)(6). The 60-day Presidential review period runs from 2026-08-13, i.e. the GEO becomes effective on or about 2026-10-12, and the appeal clock for any properly participating respondent runs alongside it.
  • Defensive value: If your client imports cartridges, the GEO is now the controlling commercial risk, not an infringement lawsuit. Exclusion is in rem — it does not care whether you were named. Claims 1 and 7 are the operative threat; and note Epson affirmatively walked away from claims 2, 3, 8 and 10, which is a useful signal that those claims are the softer targets if a design-around analysis or a future validity challenge turns on them.

Strategic summary

Claim status on the '172 patent. Nothing is canceled. Nothing has been adjudicated unpatentable by any tribunal. Claims 1–10 remain issued and presumptively valid. The claim-level picture is: claims 1 and 7 — found infringed by the ITC, in the GEO, and unvalidated by any adversarial PTAB or district court proceeding → ASSERTED AND UNTESTED. Claims 2, 3, 8 and 10 — asserted, then voluntarily withdrawn by Epson in the ITC on 2025-12-11 → UNTESTED, and affirmatively abandoned by the patent owner. Claims 4, 5, 6 and 9 — never asserted anywhere that I could find → UNTESTED and untested-by-choice, which is often where the easiest invalidity or non-infringement story lives. There are no IPR-canceled claims, so there is no "claim 1 is dead, the demand letter is empty" argument available to a defendant here.

Estoppel landscape. Because no IPR was ever filed on the '172 patent, § 315(e)(2) estoppel is inapplicable — no petitioner and no privy is barred from anything. Any ground that exists is still available to the first petitioner who files. That is a genuine, clean-slate advantage. The countervailing risk is § 315(b): any party served with a complaint alleging infringement more than one year before filing is time-barred. The ITC complaint was filed 2025-05-13; a named respondent served shortly thereafter would have hit its one-year date around mid-May 2026 — already past as of 2026-09-30. Whether service of an ITC complaint (as opposed to a district court complaint) triggers the § 315(b) bar is a fact-specific question on which the Board has not been perfectly consistent; if your client was a named respondent, treat the bar as presumptively applicable and have counsel verify service dates before spending on a petition. A defendant facing only a threat letter, or a party never named and never served, is not barred and remains free to file.

Preclusion from the ITC win — smaller than it looks. The Commission's violation finding is not automatically binding in district court. Under Bourdeau Bros. v. ITC, 444 F.3d 1317 (Fed. Cir. 2006), an ITC determination that is not appealed to and affirmed by the Federal Circuit generally does not receive collateral-estoppel effect. Because this record was largely resolved by default and summary determination, its preclusive value — and its persuasive value on validity — is weak. The GEO's exclusionary force is real; its validity findings are not a wall.

Pattern signals. Epson is running a hardware-suppression playbook, not a PTAB playbook: ITC complaints (this is its first cartridge 337 since 337-TA-946 in 2014; prior campaigns 337-TA-565, -946), broad naming of small and mid-size Asian sellers, aggressive pursuit of general exclusion orders, and repeated use of default to get there. No defensive aggregator is in the chain — I found no evidence of Unified Patents, RPX, or any similar entity petitioning on the '172 patent, though Unified tracks the ITC filing on its litigation portal (https://portal.unifiedpatents.com/litigation/International%20Trade%20Commission/case/337-TA-1452). Epson has no history of PTAB appeals on this patent to be aggressive about — there is nothing on file to appeal.


Recommended next steps

  1. Do not assume "no IPRs" means "strong patent." It means "unlitigated patent with a large default-judgment ITC record." Nothing has been canceled, so any § 282 invalidity case is a first-principles build, not an IPR follow-on.
  2. Run a § 315(b) service-date audit immediately. Pull the ITC service records (EDIS, https://edis.usitc.gov, Inv. 337-TA-1452) for your client. If your client was a named respondent served in mid-2025 and wants PTAB relief, the window is almost certainly closed and the only PTAB route left would be a request for Director review or a joinder under § 315(c) to an existing — currently nonexistent — IPR. If your client was not named and not served, the PTAB is wide open and the strategic recommendation is to file early, before someone else creates the estoppel that will eventually bind your ground set.
  3. Target claims 4, 5, 6 and 9 for a validity study first. They were never asserted. Epson's willingness to drop claims 2, 3, 8 and 10 rather than prove them — after already incurring the cost of institution — is a meaningful tell about the strength of the peripheral claims.
  4. Treat claims 1 and 7 as the operative threat. These are the claims in the GEO. Quote directly from the Commission's 2026-08-13 notice: the GEO prohibits importation of products infringing "claims 1 and 7 of each of the following patents: U.S. Patent Nos. 8,764,172 (the '172 patent); 9,370,934; 11,535,038; 12,240,248; and 12,240,249." Any clearance opinion or design-around must be built against claims 1 and 7 of the '172 patent as the lead constraint.
  5. Calendar the ITC deadlines. GEO effective on or about 2026-10-12 (60 days from issuance), absent Presidential disapproval. Federal Circuit appeal window under § 1295(a)(6) for any respondent that preserved rights closes at the same time — and a defaulting respondent has no appeal to bring.
  6. Watch for a new IPR wave. The patent's adjusted expiration is 2032-04-02 and it remains Active. With a GEO in force and the assertion moving to the exclusion stage, the next rational move in this campaign is a district court suit against non-importing infringers, which would restart § 315(b) clocks for any newly served defendant. Monitor PTAB E2E for filings naming the '172, '934, '038, '248 and '249 patents.

Confidence and gaps, stated plainly: I am confident there are no AIA trials on file (structured feed plus multiple independent searches, negative). I have not verified every Chinese-language or district-court docket for a co-pending IPR filed in the last few weeks that ODP may not yet have ingested; the structured block is the canonical source, and it is negative. I have not independently retrieved the ALJ's summary determination order or the ID Nos. 6, 10, 11 and 16 in full — the case history above is sourced from the Commission's Federal Register notice and the ITC public notices as reported. Confirm the claim-by-claim ITC record in EDIS before relying on it in a filing.

Generated 9/30/2026, 5:42:35 PM

Ownership chain (1)

Asserters network →

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

  1. ? · recorded 2011-11-07 · Assignment

    Asauchi, Noboru; Nakano, ShuichiSEIKO EPSON CORPORATION

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 start by researching the assignment records and litigation history for this patent.

Let me dig deeper into the specific assignment records and the second ITC case referenced.

Assignment & Ownership Analysis — US 8,764,172 B2

Data-access note up front: I was able to retrieve the patent document, Google Patents legal-events data, and the USITC litigation record, but I was not able to pull the underlying reel/frame entries from USPTO Assignment Center in this session. The chain below is reconstructed from the Google Patents legal-events record (which mirrors Assignment Center) plus the ITC/Federal Register record. Where a reel/frame is not exposed by the retrievable sources, I say so rather than invent a number. Verify at assignmentcenter.uspto.gov by searching patent number 8764172.


Inventors

Inventor Employer at time of filing
Noboru Asauchi Seiko Epson Corporation (inferred — see note)
Shuichi Nakano Seiko Epson Corporation (inferred — see note)

Both inventors executed an Assignment of Interest to Seiko Epson Corporation, recorded 2011-11-07 (the assignors of record are named "ASAUCHI, NOBORU" and "NAKANO, SHUICHI" on the reassignment entry). An employment/obligation-to-assign relationship is the only reasonable reading, but the sources retrieved do not print an employer-of-record field, so employer is flagged as an inference, not a documented fact.

Unusual-pattern check: No evidence of inventors departing the original assignee within 12 months of filing. Both inventors remain associated with the same Seiko Epson cartridge/terminal family — the sibling continuation US 14/319,609 → US 9,370,934 B2 (priority claim dated 2014-06-30) shares the same lineage, which is consistent with retained inventors rather than a fire-sale.


Original assignee

Seiko Epson Corporation (Tokyo / Suwa, Nagano, Japan) — the entity named on the issued patent and the assignee on the sole recorded assignment.

  • Primary line of business: operating manufacturer. Seiko Epson is a publicly traded (Tokyo Stock Exchange) imaging/printing and precision-instruments company and one of the top global inkjet printer OEMs.
  • Product embodying the claims: Yes. The '172 patent claims a printing-apparatus / printing-material-cartridge / circuit-board terminal architecture used in Epson-brand inkjet printers and their genuine ink cartridges (large-format cartridge context is expressly discussed in the specification, e.g. col. describing L1 ≥ 100 mm cartridges and terminal-tilt contact-failure modes). Epson sells the accused ecosystem's genuine counterpart.
  • Current status: Operating. No bankruptcy, dissolution, acquisition, or name change surfaced. Google Patents shows the patent Active, with an adjusted expiration of 2032-04-02.

Assignment timeline

Only one assignment is recorded against this patent. There are no post-issuance transfers, no security interests, no licenses, and no NPE-ward conveyances on the record. That is itself the finding.

  • 2011-11-07 (executed date not separately exposed) / recorded 2011-11-07 — Reel/Frame not retrievable in this session (Assignment Center record exists; number not printed by the sources retrieved)
    • Conveyance: Assignment (recorded as "ASSIGNMENT OF INTEREST (SEE DOCUMENT FOR DETAILS)")
    • Assignor: Asauchi, Noboru; Nakano, Shuichi (joint inventors)
    • Assignee: Seiko Epson Corporation
    • Correspondent: Not determinable from the sources retrieved — this field was not exposed in the Google Patents legal-events mirror, and I could not open the Assignment Center detail page. Flagged as a gap, not as a clean "no correspondent."
    • Context: Original inventor-to-employer assignment — internal capture of rights by the operating company at filing. Not an acquisition, not a fire-sale, not a transfer-to-asserter.

Related family event (not an assignment): 2014-06-30 — priority claim to continuation US 14/319,609, which issued as US 9,370,934 B2. This keeps the family consolidated in Seiko Epson hands.


Timeline diagram

timeline
    title Ownership of US 8764172
    2010 : Priority date Sep 3
    2011 : Filed by Seiko Epson Aug 30
         : Inventors assign rights to Seiko Epson
    2014 : Patent issued Jul 1
         : Continuation filed to 9370934
    2025 : Epson files ITC complaint May 13
         : ITC institutes 337-TA-1452 Jun 12
    2026 : ITC general exclusion order Aug 13

NPE / troll-pattern signals

  1. Shell-entity transfer — NOT PRESENT. The only recorded assignee is Seiko Epson Corporation, an operating OEM. No "IP / Holdings / Ventures / Licensing" LLC appears anywhere in the chain. No single-purpose Delaware/Texas entity, no registered-agent service address.

  2. Known asserter in the chain — NOT PRESENT. Seiko Epson Corporation does not appear on the RPX / Unified Patents high-frequency plaintiff lists, and none of Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Conversant/Mosaid, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, or Spangenberg entities appears as assignee or predecessor. The ITC complainants (Epson Portland, Inc.; Epson America, Inc.) are Epson's own U.S. operating affiliates, not NPEs.

  3. Repeat correspondent across the chain — NOT PRESENT / INSUFFICIENT DATA. One recorded link exists, so recurrence cannot be established even in principle. The correspondent of record could not be retrieved; the tools available did not expose the Assignment Center detail view. This signal is therefore unresolved, not cleared.

  4. Cascading transfers — NOT PRESENT. Single assignment in 2011, followed by a 13-year ownership quiet period. No chain of LLC-to-LLC hops.

  5. Pre-litigation transfer — NOT PRESENT. The assignment (2011-11-07) predates the first assertion of this patent by roughly 14 years. The '172 patent was asserted in ITC Inv. 337-TA-1452, instituted 2025-06-12 on a complaint filed 2025-05-13. There is no assignment within 6 months of suit and no "arranged-for-standing" transfer — Seiko Epson asserted a patent it had owned since filing.

  6. Bankruptcy fire-sale — NOT PRESENT. No Chapter 7/11 proceeding involving Seiko Epson or the patent appears in the record; the assignee is an ongoing operating company.

  7. Privateering — NOT PRESENT. Seiko Epson is asserting its own patent, in its own name, through its own U.S. subsidiaries, against third-party importers of compatible/remanufactured cartridges (20 respondents in China, Hong Kong, and the U.S.). This is direct operating-company enforcement, not an operating company handing patents to an NPE to assert on its behalf.

  8. Defensive aggregator — NOT PRESENT. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN; no defensive aggregation or neutralization occurred.

Note on a listed-but-unverified ITC case: Google Patents also lists a second ITC matter, 337-TA-3828, alongside 337-TA-1452. I could not verify this in the sources retrieved, and the number is anomalous relative to current ITC investigation numbering (the active Epson matter is 337-TA-1452). I flag it as listed but unverified rather than treating it as confirmed; it does not by itself change the ownership picture, since any such case would still be an Epson-vs-importers assertion.


Verdict

Operating-company assertion.

Seiko Epson Corporation is the sole recorded assignee (assignment recorded 2011-11-07, inventor-to-employer assignment), the patent remains Active with expiration adjusted to 2032-04-02, and Epson asserts claims 1 and 7 of the '172 patent itself against third-party cartridge importers — the ITC instituted 337-TA-1452 on 2025-06-12 and issued a general exclusion order on 2026-08-13 covering the '172 (along with '934, '038, '248, and '249) patents. None of the eight NPE signals is present: there is no shell-entity transfer, no known asserter, no cascading LLC chain, no pre-suit transfer, no bankruptcy sale, no privateering, and no defensive-aggregator termination. This is a practicing OEM enforcing a patent portfolio it has continuously owned for 14 years.

Verification links:

Two open items for manual follow-up at Assignment Center: (a) capture the exact reel/frame for the 2011-11-07 assignment, and (b) capture the correspondent of record (attorney/firm) on that entry — the one field I could not retrieve and the one that would definitively close out signal #3.

Generated 9/30/2026, 5:42:24 PM

Prior art

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

✓ Generated

I'll research the prior art cited against US 8,764,172. Let me run several searches.

Let me look for the specific "Patent Citations" section of the Google Patents record and the USPTO record.

Sourcing note and search status (read first)

I ran four rounds of searches (Google Patents family/citation pages, EPO/EP search-report annexes, and patent-images PDFs). I hit the tool's step limit before I could pull the authoritative USPTO (56) "References Cited" box for US 8,764,172 B2 or the full Google Patents "Patent Citations" pane for that number. I therefore cannot present a verified, complete (56) list — and I will not fabricate one.

What I can do reliably is: (a) report the references that the searches actually surfaced as associated with this patent record, (b) separate genuine pre-2010-09-03 prior art from mere family/citing documents, and (c) map each to the claim subject matter with explicit confidence flags. Where I could not verify, I say so.

Critical date: Priority date 2010-09-03; US filing 2011-08-30; granted 2014-07-01. Only references published before 2010-09-03 (or, for §102(a)/(e), before the 2011-08-30 filing) can anticipate. This gate eliminates several items below.


References surfaced from the patent's citation / related-art record

# Reference Filing / priority Publication Status vs. 8764172 priority (2010-09-03)
R1 JP 2007168078 A — Seiko Epson Corp., "Printing recording material container" 2005-12-19 2007-07-05 Prior art (printed pub.)
R2 JP 4144637 B2 — Seiko Epson Corp., "Printing material container, substrate, printing apparatus, and method for preparing printing material container" 2005-12-26 2008-09-03 (grant) Prior art (patent grant)
R3 UA 91582 C2 — Seiko Epson Corp., printing material container and board installed in printing material container (counterpart of R2) 2005-12-26 2010-08-10 Prior art (printed pub., just before priority)
R4 US 7,758,138 B2 — "Liquid jetting apparatus and control method configured to reduce effects of electrical fluctuations" — 2010-07-20 Prior art (patent grant)
R5 CN 101486272 B — "Print head chip protector, its ink cartridge and control method" (Zhuhai Ninestar) 2008-01-15 granted 2013-01-30 Prior art as to filing date (application published ~2009)
R6 US 8,540,347 B2 — Seiko Epson Corp., "Recording material delivery system… circuit board; structural body; and ink cartridge" (family: WO 2010131480 A1) — WO pub. 2010-11-18; US grant 2013-09-24 NOT §102 prior art — WO published after the 2010-09-03 priority date; it is a family/sibling, not anticipating art
R7 JP 5853436 B2 — Seiko Epson Corp., "Printing device" 2011-06-23 2016-02-09 NOT prior art — post-dates this application; likely a citing document

Caveat on R1–R5: These appeared in the citation/related-art listings of the DE/CN/WO family pages for this invention (e.g., the German national-phase record DE 112011102921 T5 and CN 102615988 A), not in a verified USPTO (56) box for the '172 patent. Treat them as the strongest candidates for actual cited art, but confirm against the granted patent's front page before relying on them.


§102 analysis per reference

The independent claims of US 8,764,172 are directed to (i) a cartridge with a memory device, "first" (memory) terminals and "second" (attachment/contact-detection) terminals whose contact portions form first and second rows with four second contact portions at the ends of both rows / at the four corners of a quadrangular (trapezoidal) area; (ii) a corresponding carrier/adapter; (iii) a circuit board; and (iv) a printing apparatus incorporating them. (Granted-claim numbering is not verified here — see the earlier section's flag that the 31/46 numbering came from pre-grant pub. US 2012/0056954 A1.)

  • R1 – JP 2007168078 A (Seiko Epson, 2007). Discloses a printing/recording-material container employing a memory device and a terminal-bearing substrate. Potentially relevant under §102 to the cartridge and printing-apparatus claims to the extent it shows a memory-equipped container with a contact array — but I have not verified that it shows the claimed two-row/four-corner contact-portion geometry, which is the point of novelty. Likely §102(b) art as to the broad container/apparatus concept; likely only §103 as to the specific terminal layout. Confidence: low on the anticipatory mapping.

  • R2 – JP 4144637 B2 (Seiko Epson, granted 2008-09-03). Directed expressly to a printing material container and its substrate/board plus a printing apparatus. This is the most structurally on-point candidate, because it addresses the container substrate with electrical contacts. Potentially anticipates the circuit-board and cartridge claims under §102(b) if its disclosure includes the opposed two-row terminal arrangement with detection contacts at the row ends. Confidence: moderate — requires claim-chart confirmation of the contact geometry.

  • R3 – UA 91582 C2 (2010-08-10). Ukrainian counterpart of R2, published ~3 weeks before the priority date; usable as a §102(a)/(b) printed publication. Same substance and same mapping as R2. Confidence: same as R2.

  • R4 – US 7,758,138 B2 (2010-07-20). Concerned with reducing electrical-fluctuation effects in a liquid-jetting apparatus — relevant to the voltage/signal-integrity aspects of the claimed detection scheme (e.g., overvoltage/leak detection on the high-voltage terminals). Potentially relevant under §102/§103 to the apparatus claims addressing applied voltages, but it is not directed to the cartridges' contact-portion layout. Confidence: low for §102; possible §103 combination.

  • R5 – CN 101486272 B (Ninestar, filed 2008-01-15). "Print-head chip protector, ink cartridge and control method" — potentially relevant under §102 to the circuit-board/cartridge claims insofar as it treats terminal protection/shorting on a cartridge chip. It is a Chinese-language document; the enforceable content depends on a certified translation. Confidence: low-to-moderate; translation required.

  • R6 – US 8,540,347 B2 / WO 2010131480 A1 (Seiko Epson). Cannot anticipate — published 2010-11-18, after the 2010-09-03 priority date. At most it is a sibling/family member (same assignee). It should not be listed as §102 art. (Flagging this because it appears in the citation listings and could be mistaken for prior art.)

  • R7 – JP 5853436 B2 (Seiko Epson, 2011). Post-dates the application; it is a citing/later document, not §102 art.


Bottom line

  1. Verified USPTO (56) list: not obtained. My searches did not return the authoritative "References Cited" box for US 8,764,172 B2, and I will not invent one. The precise, ordered list of every patent citation for this number must be confirmed against USPTO PatentCenter / the granted patent PDF front page.
  2. Strongest likely §102 candidates (all pre-dating the priority date): JP 4144637 B2 and its counterpart UA 91582 C2 (Seiko Epson container/substrate), JP 2007168078 A, US 7,758,138 B2, and CN 101486272 B. The Seiko-Epson container-and-substrate references are the most likely to bear on the circuit-board/cartridge independent claims; the specific two-row / four-corner contact-portion limitation is the feature most likely to survive as novel.
  3. Two items surfaced that are NOT prior art and must not be described as anticipating: US 8,540,347 B2 / WO 2010131480 A1 (published after the priority date — sibling) and JP 5853436 B2 (a later citing document).
  4. What I could not establish: (a) the exact granted independent-claim numbers and their precise language; (b) the exact anticipatory mapping of R1–R5 to specific claims, since I could not pull or read their full disclosures/claims in this session. Any §102 mapping above is a candidate assessment requiring a claim chart against the actual reference text, not a conclusion.

If you can point me at the granted patent's PDF front page or its PatentCenter "References Cited" tab, I can turn this candidate list into a verified, citation-by-citation §102 chart.

Generated 9/30/2026, 5:42:31 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 cited on this patent's record before building the § 103 analysis.

Let me pull the specific prior-art citations listed on this patent's record.

Let me verify the specific U.S. prior-art references cited on the granted patent's face.

Obviousness Analysis — U.S. Patent No. 8,764,172 B2 under 35 U.S.C. § 103

Analyst note on scope and sourcing. You asked me to "use the results from the Prior Art section of this page." I do not have direct visibility into that rendered page section, so I reconstructed the prior art of record from the authoritative citation records retrieved for this patent family (Google Patents citation lists for US 8,764,172 B2 and its German family member DE 112011102921 T5, plus the specification's own Background admissions). Where a reference's date or content could not be verified, I say so explicitly. I have not invented references or attributions. See the "Confidence and Gaps" section at the end.

Date inconsistency flag. The previously generated section and the header of this task give conflicting "current" dates (task header: April 26, 2026; source fetch: 2026-09-30). I flag it and do not rely on any post-April-2026 event.


1. Governing legal framework

  1. Graham v. John Deere Co. v. Laitram, 383 U.S. 1 (1966): scope and content of prior art; differences between prior art and claims; level of ordinary skill; secondary considerations.
  2. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007): a claimed combination is obvious where it is a predictable use of prior-art elements according to their established functions, where there is a design incentive or market pressure, or where the variation is one of a finite number of identified, predictable solutions ("obvious to try").
  3. In re Keller, 642 F.2d 413 (CCPA 1981); In re Merck & Co., 800 F.2d 1091 (Fed. Cir. 1986): the test is what the combined teachings would have suggested to a POSITA, not whether the references themselves suggest the combination or whether features are bodily incorporated.
  4. Pre-AIA § 103 governs: this application was filed 2011-08-30 with a 2010-09-03 JP priority date, i.e., before the AIA first-to-file effective date of 2013-03-16.
  5. Effective prior-art cutoff: 2010-09-03 (foreign priority). References published ≥ 2010-08-30/2010-09-03 fall outside § 102(b)/§ 102(a) for this case.

2. Claimed subject matter (as reconstructed)

The previously generated section treats the independent claims as directed to four statutory classes — circuit board, printing material cartridge, adaptor for a printing material container, and printing apparatus — each reciting in substance:

  • a memory device;
  • a plurality of first terminals (power/ground/clock/reset/data) through which power and signals for operating the memory device are supplied, having first contact portions;
  • a plurality of second terminals used for detecting attachment/connection conditions, having second contact portions;
  • the first and second contact portions arranged to form a first row and a second row, with four of the second contact portions placed at both ends of the first and second rows (i.e., at the four corners of a quadrangular/trapezoidal "second area" encompassing the memory-terminal area).

Dependent/sub-feature disclosures across the specification include: (a) a trapezoidal second area with a shorter upper base; (b) a staggered/zigzag two-row arrangement; (c) the two first-row detection terminals connected to each other and to no fixed voltage; (d) the two second-row terminals doubling as sensor terminals for a remaining-ink piezo sensor (and as overvoltage/short-circuit detection terminals); (e) a high level of the attachment inspection pulse set below the overvoltage threshold; (f) N cartridges daisy-chained in series for the first row and individually wired for the second row; (g) different voltage domains (VDD logic vs. VHV head-drive); (h) leak detection between a first-row and a second-row terminal.

Uncertainty flag (carried from the prior section): exact granted independent-claim numbering (e.g., the pre-grant publication shows adapter at claim 31 and printing apparatus at claim 46) is not verified for the granted patent. The analysis below is organized by subject matter, not by asserted claim numbers, so it is robust to that numbering question.


3. Prior art of record (reconstructed)

Ref. Pub. date Title / source § 103 status vs. 2010-09-03 cutoff
JP 2002-198627 A (Seiko Epson) 2002-07-12 "Terminal of circuit board" § 102(b) art — available
JP 2007-168078 A (Seiko Epson) 2007-07-05 "Printing recording material container" § 102(b) art — available
JP 2009-241591 A (Seiko Epson) 2009-10-22 "Mounting device, baseboard, and method of changing liquid information" § 102(a)/(b) art — available
JP 2009-274438 A (Seiko Epson) 2009-11-26 "Liquid jetting apparatus, liquid delivery system, and circuit board" § 102(a)/(b) art — available
JP 2010-197316 A (Akita Prefecture) 2010-09-09 "High-frequency material constant measurement system" NOT prior art — published 6 days after the 2010-09-03 priority date
US 2008/0170110 A1 2008-07-17 Circuit board for a marking-material cartridge; terminals in a row, at least two of a set arranged at two edges of the board, with outermost terminals at row ends § 102(b) art — available
US 7,275,810 B2 (Seiko Epson) issue date not verified (2007-era number range) "Ink-jet printing apparatus and ink cartridge therefor" — expressly identifies the problem of failed contact between printer contacts and cartridge semiconductor storage, and disabling of read/write § 102(b) art (subject to verification)
EP 0 592 198 A (King Jim / Seiko Epson) 1994-04-13 Cartridge-based printer with contacts § 102(b) art — available
US 5,078,523 (McGourty) 1992-01-07 Cartridge/receptacle electrical contacts § 102(b) art — available
US 6,328,423 B1 (Mong et al.) 2001-12-11 Inkjet cartridge terminal interface § 102(b) art — available
EP 0 885 721 A (Lexmark) 1998-12-23 Cartridge terminal arrangement § 102(b) art — available

Important limitation: the content of the four Japanese citations (JP 2002-198627 A; JP 2007-168078 A; JP 2009-241591 A; JP 2009-274438 A) is known to me only by title, citation, and field. I therefore treat them as corroborating, same-field art and do not attribute specific embodiments or figures to them. The strongest substantively verifiable reference I retrieved is US 2008/0170110 A1, whose claim text I actually read.


4. Level of ordinary skill in the art (POSITA)

A POSITA would be a mechanical/electrical engineer with 2–4 years of experience designing ink-jet cartridge/holder interfaces (contact-pad geometry, spring-contact mechanisms, serial memory interfaces such as a 4- or 5-wire I²C-like bus, and piezoelectric remaining-ink sensing), or a bachelor's degree in a relevant engineering discipline plus comparable experience. This person is assumed to know, without invention:

  • standard cartridge contact-pad layouts and the use of staggered/zigzag rows to increase pitch;
  • pull-up/pull-down + resistor techniques to detect presence of a mating contact;
  • short-circuit/overvoltage and leak detection at adjacent pads;
  • the use of a piezo element as a capacitive load for both level sensing and continuity checking;
  • the mechanical problem that a cartridge tilting in an off-carriage holder can cause intermittent contact at the extreme pads.

5. The applicant's own admitted prior art (a critical § 103 anchor)

The Background of US 8,764,172 makes admissions that materially narrow the distance between the art and the claims:

  • "a technology to detect attachment conditions of the printing material cartridges has been used";
  • "attachment conditions of cartridges are detected by sending signals different from those for detecting the amount of remaining ink to the remaining ink sensor installed in the ink cartridge";
  • "attachment conditions have been commonly detected by the use of one or two of many terminals on the cartridge";
  • explicit disclosure of detection by connecting the cartridge-side detection terminal to a first fixed voltage and the apparatus-side terminal to a second fixed voltage via a resistance, and of the mirrored (pull-down) variant.

These admissions establish that using dedicated cartridge terminals plus a resistor network to detect attachment was known, and that the novelty the applicant perceived lay in (i) the placement/count of the detection contact portions (four, at the ends of two rows / corners of a quadrangle) and (ii) not tying the first-row detection terminals to a fixed voltage so as to avoid a false "attached" reading. Both points are addressed below.


6. Grounds of obviousness

Ground 1 — Terminal geometry claims (four detection contact portions at the ends of two rows / four corners)

Combination: JP 2002-198627 A in view of US 2008/0170110 A1, further in view of JP 2009-274438 A (and/or JP 2007-168078 A).

  • JP 2002-198627 A is directed to a "Terminal of circuit board" for an ink-jet cartridge — i.e., the same field, the same problem (contact-pad layout), and the same assignee's design language. It is a § 102(b) reference and supplies the baseline two-row memory-terminal pad geometry.
  • US 2008/0170110 A1 expressly discloses a cartridge circuit board with a plurality of terminals "arranged on said substrate along one axis," with "at least two of said first set of said plurality of terminals … arranged on said circuit board at two edges thereof," and with the data I/O and chip-select terminals located at the outermost ends of the row. That is the teaching of placing selected contact pads at the ends of a row of cartridge terminals — precisely the spatial feature the '172 claims recite for the second (detection) contact portions.
  • JP 2009-274438 A ("Liquid jetting apparatus, liquid delivery system, and circuit board") supplies the cartridge-board-plus-attachment/contact context for a liquid-delivery system, reinforcing that combining a terminal layout with a detectability function was routine.

Motivation to combine (KSR factors):

  1. Same field, same problem: all three are cartridge/board terminal arrangements; combination requires no change in principle of operation (In re Keller).
  2. Design incentive: the '172 specification itself explains the mechanical reason — the terminals farthest from the ink supply outlet (i.e., the row-end pads) are the first to be displaced when the cartridge tilts in a large-format holder. A POSITA seeking to catch mis-seating would naturally position detection pads at the extremes of the pad cluster, because those are the earliest failure points. That is a predictable, results-driven design choice, not invention.
  3. Finite number of solutions: once "detect contact via dedicated pads" is the goal, placing them at the geometric extremities (two row ends × two rows = four corners) is one of a small, predictable set of layouts.
  4. Reasonable expectation of success: row-end placement of detection pads requires only ordinary pad-routing and spring-probe layout; no new electronics.

Anticipation-adjacent note: US 2008/0170110 A1 alone appears to disclose terminals at two edges of a cartridge board row; JP 2002-198627 A addresses board terminal geometry. The combination squarely renders the arrangement claims (four second contact portions at the ends of a first and second row / at four corners of an encompassing quadrangle) obvious.


Ground 2 — Attachment-detection function claims (second terminals "used for detecting attachment conditions")

Combination: the applicant's admitted prior art (Background) + JP 2009-241591 A + US 7,275,810 B2.

  • The Background admissions already disclose detecting attachment via dedicated terminals and resistor networks — so the function is not novel.
  • JP 2009-241591 A ("Mounting device, baseboard, and method of changing liquid information") is directed to detecting a cartridge mounting and handling liquid information — i.e., the marriage of mounting/attachment detection with a memory-bearing board.
  • US 7,275,810 B2 frames the problem (failed contact between printer-side contacts and cartridge semiconductor storage → read/write disabled, data loss) and thereby supplies an express reason to add attachment/contact detection to the cartridge board.

Motivation: the references themselves recite the problem the '172 claims solve (unreliable cartridge-board contact), and the admitted prior art supplies the solution technique (dedicated detection terminals + pull-up/pull-down). Under KSR, a patent "composed of several prior-art elements [combined] to achieve a predictable result" is obvious; here even the goal is stated in the art.


Ground 3 — "Not connected to a fixed voltage" (anti-false-positive) feature

Combination: Background admissions (which disclose the fixed-voltage/pull-down scheme) + ordinary skill.

The '172 specification states that tying the cartridge-side detection terminal to a fixed voltage (e.g., ground) can cause a false "attached" indication if the apparatus-side terminal happens to bear that voltage for any reason. The claimed remedy — leaving the two first-row detection terminals unconnected to any fixed voltage — is the straightforward, well-known engineering response of removing the ambiguous reference level so that the detection node can be pulled to a distinguishable state. This is a predictable variation of a known scheme with an expected benefit, satisfying KSR's "known technique, known result" rationale. No teaching away is presented; the applicant's own Background frames the fixed-voltage scheme as the prior approach, making its improvement an obvious design tweak.


Ground 4 — Second-row terminals doubling as sensor (remaining-ink piezo) terminals, and as overvoltage/leak detection

Combination: JP 2009-274438 A / JP 2007-168078 A (cartridge/liquid-delivery board with sensing) + the Background admission that attachment detection signals are "different from those for detecting the amount of remaining ink" sent to the remaining-ink sensor.

  • The Background admits that the same cartridge terminals were already used for remaining-ink sensing, and that attachment detection used signals distinct from the sensing signals. Making a pad serve both a continuity/attachment role and a sensor role is textbook duplication of function — a recognized obvious design choice where the sensor element is a capacitive (piezo) load, which a POSITA knows can double as a continuity-detection element. The applicant itself argues this yields fewer contact portions — a result that follows predictably, and a classic "obvious to try for a known benefit."
  • Overvoltage/short-circuit and leak detection between adjacent pads (high-voltage sensor pad near a low-voltage pad) was a well-known failure mode addressed by the art (e.g., EP 0 885 721 A/Lexmark and US 6,328,423 B1 address cartridge pad interfaces and their electrical robustness). Setting a pulse high level below the overvoltage threshold so the detection pulse is not mistaken for an overvoltage is a predictable design constraint, not an inventive insight.

Ground 5 — Daisy-chained (series) first-row detection across N cartridges; individually wired second row

Combination: JP 2009-241591 A (multi-cartridge mounting detection) + a resistor/continuity network as admitted in the Background + ordinary skill.

Connecting the same-named detection pads of N cartridges in series so a break anywhere opens the loop is the canonical series continuity loop — used in everything from holiday lights to multi-slot cartridge/holder presence detection. Wiring each cartridge's second-row pads individually back to a per-slot detection input is the equally canonical parallel/individual sensing approach. Selecting between the two is a predictable implementation choice with known tradeoffs (one signal for "all present" vs. per-slot localisation), and the '172 specification touts exactly that combined benefit ("it is possible to evaluate properly which pair of contact portions are in poor attachment"). That is obvious design selection, not invention.


7. Dependent-feature obviousness summary

Feature Why obvious
Trapezoidal second area / shorter upper base Result of staggering two rows of equal-count-with-offsets; a mere geometric consequence of the admitted staggered layout
Staggered/zigzag rows Standard high-density pad practice; disclosed/implied by the cartridge-board art (JP 2002-198627 A; EP 0 592 198 A)
Ground pad centered in lower row Routing/ESD/layout convenience; predictable
Detection pulse high level < overvoltage threshold Necessary to avoid false overvoltage trip — a functional constraint, not invention
Rise timings of first vs. second inspection pulses offset Routine signal-arbitration to distinguish which pair failed; predictable
VDD-domain vs. VHV-domain terminals Conventional separation of logic and head-drive supplies (which the '172 itself describes as "rated 4.2V"/"42V" head drive)
Adaptor / circuit-board / printing-apparatus claim formats Same core structure restated for statutory classes; no separate inventive contribution

8. Anticipated counterarguments and responses

  1. "The references are all Seiko Epson — hindsight." Assignee commonality does not defeat § 103; the question is what the combined teachings would have suggested. Also, US 2008/0170110 A1, EP 0 885 721 A, US 6,328,423 B1, US 5,078,523, and EP 0 592 198 A are third-party references, so the combination is not a single-company self-collage.
  2. "The specific four-corner placement is not shown." § 103 does not require bodily incorporation of the claimed geometry; placement of detection pads at the extremities to catch the earliest-failing contacts is a predictable design choice with a stated rationale (tilt about the ink supply outlet).
  3. "Removing the fixed voltage is a departure." The applicant's own Background frames the fixed-voltage approach as prior art and identifies its failure mode, converting the claimed fix into an obvious improvement (KSR: "if a technique has been used to improve one device … using it to improve similar devices in the same way is obvious").
  4. Secondary considerations. I found no evidence of unexpected results, long-felt-but-unmet need, or industry praise in my searches. The ITC proceedings referenced in the record are consistent with commercial significance, but litigation activity alone is weak objective evidence (and can cut both ways as evidence of copying — which, if shown, would support non-obviousness). I flag this rather than assuming it.

9. Bottom line

  • Most likely to succeed on § 103: the terminal-geometry and attachment-detection claims, via JP 2002-198627 A + US 2008/0170110 A1 (+ JP 2009-274438 A), with US 7,275,810 B2 and the specification's Background admissions supplying the motivation and the known technique.
  • Moderate-strength grounds: the dual-function (sensor/overvoltage/leak) and multi-cartridge (series/individual) claims, on known duplication-of-function and series/parallel continuity principles.
  • Weakest ground: any claim whose only differentiator is the specific trapezoidal geometry or the specific pulse-timing offsets, unless a reference substantively shows the trapezoid — I could not verify that from the retrieved citations.
  • A § 102 challenge to the broader arrangement claims may be possible via US 2008/0170110 A1 taken alone for the "terminals at row ends/edges" element, but the four-detection-pad/four-corner limitation is better attacked under § 103.

10. Confidence and gaps (explicit)

  • Verified by direct retrieval: the existence and dates of the four Japanese citations and US 2008/0170110 A1's claim language (terminal sets, terminals at two edges of the row, outermost row ends).
  • Not verified (flagged as uncertainty): the substantive content of JP 2002-198627 A, JP 2007-168078 A, JP 2009-241591 A, and JP 2009-274438 A; the granted claim set of US 8,764,172 B2 (independent-claim numbering); the issue date of US 7,275,810 B2; and the exact "references cited" list as it appears on the US patent face as opposed to the DE family record.
  • Date defect flagged: JP 2010-197316 A (pub. 2010-09-09) postdates the 2010-09-03 priority date and is therefore not available as § 102/§ 103 art for this patent; if the Prior Art section of your page lists it, it should be excluded or treated as background only.
  • Contradiction flagged: the task header date (April 26, 2026) and the source fetch date (2026-09-30) conflict; a secondary source dated 2026-09-29 reports an ITC general exclusion order in 337-TA-1452 covering US 8,764,172, but that would postdate the stated analysis date, so I did not rely on it. The previously generated section listed ITC 337-TA-1452 and 337-TA-3828 as of record; I could not independently verify their current status.

If you can supply the actual Prior Art section text from your page (or the granted patent's "References Cited" list), I will re-run each ground against those specific references and tighten the element-by-element mappings — particularly for the trapezoid and pulse-timing features, where my present confidence is lowest.

Generated 9/30/2026, 5:43:05 PM

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