Invalidity dossier
US 8874474
Added 9/24/2026, 10:58:55 AM
Active provider: DeepSeek · deepseek-v4-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for authoritative information on this patent, including any litigation activity.
Initial searches returned mostly unrelated results. Let me try more targeted queries.
Let me search litigation databases and PTAB directly.
US Patent 8,874,474 — Summary
Important caveat up front: My searches did not surface any authoritative USPTO record or any Court of Appeals for the Federal Circuit (CAFC) 2026 docket involving US 8,874,474. I found no evidence of litigation, IPR/PGR, or appeal for this specific number. Everything below is grounded in the full patent text supplied in the prompt (which appears to be the Google Patents rendering of US8874474B2); I flag uncertainties explicitly.
Bibliography (from the supplied authoritative text)
| Field | Value |
|---|---|
| Patent number | US 8,874,474 B2 (published application: US 2013/0298150 A1) |
| Title | "Communication server, communication method, memory medium and integrated circuit for mediating requests for content delivery according to expectation values of a probability of acceptance of the request, desired location, and history information" |
| Application no. | US 13/979,238 |
| Filing date | 2012-03-07 |
| Priority date | 2011-03-23 |
| Issue date | 2014-10-28 |
| Inventors | Ryohei Wakai; Takahisa Fujita; Yuzo Kawamura |
| Original assignee | Panasonic Intellectual Property Corp. of America |
| Reassignment chain | → PANASONIC CORPORATION (2013-09-11) → PANASONIC INTELLECTUAL PROPERTY CORPORATION OF AMERICA (2014-05-27) → SOVEREIGN PEAK VENTURES, LLC (2018-10-31) |
| Status | Expired – Fee Related; anticipated expiration 2032-03-07 |
Identifier note (per your strict rule): one third-party aggregator (idiyas.com) renders this as "US 8874474 B1." That is inconsistent with the primary source, which states B2. I have not auto-corrected anything; I simply flag the third-party page as unreliable on this point. Also note that the phrase "'887 Patent" appearing in unrelated litigation documents I retrieved is a different patent (a number ending in 887), not 8,874,474, and should not be conflated.
Abstract
A communication server (200) acquires a request specifying a desired location for content creation from a requester terminal (310) and notifies an accepter terminal (300) that accepts the content creation. A notification history managing unit (206) stores, as notification history, the distance from the notified accepter terminal to the desired recording location, plus acceptance information. Upon a new request, a request notification terminal selecting unit (203) selects an accepter terminal likely to accept, based on the notification history, and a request notifying unit (204) sends the notification to the selected terminal.
Plain-language overview of the independent claims
The supplied text truncates the formal claim set (the "Solution to Problem" section cuts off mid-sentence), so the following is reconstructed from the specification's own claim-style recitation ("a communication server as an embodiment of the present invention includes: …") plus the summary paragraphs (A)–(H). Treat this as high-confidence but not a verbatim claim set.
Independent claim 1 — Communication server. A server that: (a) acquires a content-creation request naming a desired location; (b) acquires the current locations of multiple accepter terminals; (c) sends a notification of the request to a selected subset of those terminals; (d) acquires acceptance information saying whether a notified terminal accepted; (e) maintains history information recording, for each past notification, the accepter's location at notification time, the request's desired location, and the acceptance outcome; and (f) upon a new request, selects which accepter terminals to notify based on that history. The core insight: rather than notifying only terminals near the desired location, the server learns each accepter's individual willingness-to-accept from past notifications and targets accordingly.
Dependent/narrower claimed features (recited as alternatives in the specification summary):
- Expectation value: the selecting unit computes a probability of acceptance per accepter terminal from current locations + new request's desired location + history, and selects according to that value.
- Distance tendency value: the acceptance rate observed in past notifications where the notification distance was approximately equal to the current distance; set directly as the expectation value.
- Time tendency value: history also stores notification time; expectation computed from distance tendency plus a time-based acceptance rate (same time attribute as now).
- Location tendency value: expectation computed from distance tendency plus acceptance rate when the past notification location was within a predetermined range of the terminal's current location.
- Correction by current distance: the distance tendency value is adjusted according to how far the terminal currently is, favoring terminals that can arrive sooner.
- Category tendency value: a location-category information managing unit maps locations to categories; expectation combines distance tendency with a category-based acceptance rate for the subject of the recording.
- Per-user expectation: history includes user identifiers, so expectation is computed per user (handles one user with multiple devices, or multiple users sharing a device).
- Distance stored instead of two points: history may store only the one-dimensional notification distance rather than both locations, reducing data.
Additional independent claims (inferred from the title): the title expressly covers a communication method, a memory medium (i.e., a recording medium storing the control program), and an integrated circuit (LSI) implementing the same functionality — consistent with the specification's closing paragraphs on program distribution and LSI/FPGA implementation. I could not verify their exact wording from the supplied text.
Litigation / CAFC search results
- No CAFC 2026 docket, no district court complaint, and no PTAB proceeding referencing US 8,874,474 was found in my searches.
- CAFC 2026 materials retrieved (Innovaport LLC v. Target Corp., 2024-1545, decided Feb. 6, 2026; VLSI v. Intel; Exafer v. Microsoft; AOI v. Eoptolink) are unrelated to this patent.
- Uncertainty statement: my search coverage of USPTO PatentCenter/P-TACTS and CAFC dockets is indirect (via web search), not a direct registry query. I cannot certify that no such proceeding exists — only that I found none. Treat "no litigation" as not located rather than confirmed absent.
Generated 9/30/2026, 1:31:00 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 8874474. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US patent 8874474 (US 8,874,474 B2).
Let me search more specifically, including the current assignee (Sovereign Peak Ventures) and litigation databases.
Litigation Search: US Patent No. 8,874,474
Bottom line: I was unable to identify any known litigation specifically asserting US Patent No. 8,874,474.
What I searched
- Google Patents / general web for "US 8874474 litigation," "8,874,474 infringement complaint," "'8874474' CAFC appeal"
- CourtListener / RECAP, Unified Patents portal, PTAB (PTACTS), and Docket Navigator-style aggregators
- Searches combining the patent's current assignee, Sovereign Peak Ventures, LLC, with the patent number
Neither the patent number nor its title surfaced in any complaint, docket, PTAB petition, or CAFC appeal. No plaintiff/defendant, case number, jurisdiction, filing date, or outcome could be confirmed for a case involving this specific patent.
Important caveat (active, but unconfirmed)
The patent's current assignee, Sovereign Peak Ventures, LLC, is an active patent litigant — and because my searches returned assignee-level hits but no patent-level hits, I cannot rule out that '474 is being asserted in a case I could not tie to the number. Assignee-level results included:
- Sovereign Peak Ventures, LLC v. Micro-Star International Co., Ltd., No. 2:2025-cv-00449 (W.D. Tex.), 35 U.S.C. § 271 — patent(s) asserted not identified in the results; cannot confirm '474 is among them.
- Sovereign Peak Ventures, LLC v. Arashi Vision Inc. d/b/a Insta360, No. 2:25-cv-01216 (E.D. Tex., Judge Gilstrap), filed Dec. 2025, 35 U.S.C. § 271 — patent(s) asserted not identified; cannot confirm '474 is among them.
To confirm whether '474 is asserted in either matter, the operative complaints (e.g., E.D. Tex. docket 72031938, the 131‑page complaint filed 12/12/2025) would need to be pulled and the asserted patent numbers checked directly.
Similar-number results deliberately excluded
Per your instruction not to return similar numbers, I did not treat the following as hits — each is a different patent:
- U.S. 8,835,474 (Astellas Pharma v. Ascent Pharmaceuticals) — a pharmaceutical patent, not '474
- U.S. 7,245,874 (Elbit Systems v. Hughes Network Systems)
- U.S. 7,064,874 (K.Mizra v. Brother Industries)
- U.S. 5,579,239, 7,756,087, 7,551,596, 6,226,449 (Apple v. Samsung)
Recommendation
If a definitive answer is required, run a targeted search in Docket Navigator or Unified Patents Portal filtered to the exact patent number 8,874,474 (rather than the assignee), and pull the pleadings in the two Sovereign Peak Ventures cases above to confirm which patents are asserted. Based on the sources available to me, no litigation asserting US 8,874,474 is confirmed. I do not have high-confidence knowledge of any such litigation from training data either, so I am stating this as "not found/not confirmed" rather than asserting that no case exists.
Generated 9/30/2026, 1:30:55 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.
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.
I'll start by verifying the structured data against public sources.
No PTAB hits yet. Let me run more targeted checks, including defensive aggregators and the Federal Circuit docket.
Let me do a couple of final confirmation searches on PTAB dockets and CourtListener.
PTAB Proceedings Report — U.S. Patent No. 8,874,474
Patent: US 8,874,474 B2 — "Communication server, communication method, memory medium and integrated circuit for mediating requests for content delivery according to expectation values of a probability of acceptance of the request, desired location, and history information"
Inventors: Ryohei Wakai, Takahisa Fujita, Yuzo Kawamura
Assignee of record: Sovereign Peak Ventures, LLC (via Panasonic Corporation → Panasonic IP Corp. of America)
Priority date: 2011-03-23 | Filed: 2012-03-07 | Granted: 2014-10-28
Legal status (as fetched 2026-09-24): Expired – Fee Related
Proceedings overview
There are zero AIA trial proceedings on file against US 8,874,474 at the PTAB. The USPTO Open Data Portal returns no IPR, PGR, or CBM proceedings for this patent, and my independent web sweeps of PTAB document repositories and public dockets surfaced no petition, institution decision, or Final Written Decision naming this patent or its application number (13/979,238). The breakdown is therefore: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials.
The bottom-line defensive posture is not "the patent has survived two IPRs and is hardened," and it is not "claims 1–5 have been canceled." It is a third posture that defendants frequently overlook: the patent has never been stress-tested at the PTAB at all, and it has lapsed for failure to pay maintenance fees. Every claim of 8,874,474 is UNTESTED — there is no IPR estoppel running against anyone, no claim construction adopted by the Board, and no validity ruling of any kind. Combined with the "Expired – Fee Related" status, the practical question for a defendant is not "how do I beat this at the PTAB," but "what is there left to assert?"
⚠️ Verification caveat. I was unable to find a single third-party source linking 8,874,474 to any AIA trial. My searches returned PTAB petition documents for unrelated patents (e.g., IPR petitions concerning 15/714,909, IPR2021-01557, IPR2022-00055), which I have not attributed to this patent. Per the operating rules, I have not invented any proceeding number to fill the gap. Absence of indexed proceedings is strong but not conclusive — a very recently filed petition may pre-date the ODP ingest.
Proceedings
None to report. No proceeding can be listed because no proceeding exists in the structured ODP data or in any public source I could reach.
For completeness on the required framings, there is nothing to populate for:
- Type / Filed / Status / Judge panel — N/A
- Petition grounds (claims, art, § 102 / § 103 / § 112) — N/A
- Institution decision — N/A
- Final Written Decision — N/A
- Settlement / termination — N/A
- Appeal to the Federal Circuit — N/A (no PTAB FWD exists to appeal, so there is no CAFC docket keyed to an IPR of this patent; that is different from district court appeals, which I could not tie to this patent either)
Strategic summary
Claim status: everything is UNTESTED. Because no petition was ever filed, no claim of 8,874,474 has been canceled, confirmed, or even construed by the Board. There are no "surviving claims" to list, because nothing was ever narrowed through IPR. This is materially different from the typical NPE-patent profile and it cuts both ways: the patent owner has no PTAB win to point to as a validity endorsement, and a defendant has no PTAB loss to be bound by.
Estoppel landscape: clean slate. Under 35 U.S.C. § 315(e)(2), estoppel only attaches to a petitioner that reaches a Final Written Decision, and only as to grounds it raised or reasonably could have raised. With no IPR, no § 315(e)(2) estoppel exists against any party. A defendant facing assertion today can raise any § 102 or § 103 ground in district court or file a fresh IPR — subject only to the ordinary § 315(b) one-year bar from service of a complaint, and to § 325(d)/General Plastic considerations if the owner has family-member proceedings elsewhere. There is no prior petitioner to piggyback on and no prior petitioner's art to inherit.
Pattern signals — and the more important signal. Sovereign Peak Ventures, LLC is a well-known patent monetization entity that has run assertion campaigns in the E.D. Tex. and elsewhere (public dockets show SPV matters against TCL, Micro-Star International, and Arashi Vision). I found no defensive aggregator participation — no Unified Patents petition, no IPR funded on behalf of an industry group — tied to 8,874,474. The notable non-signal is that this patent, despite being held by an active monetization entity for years, never attracted an IPR. That pattern usually means either (a) the patent was asserted only in fora and against parties where an IPR was uneconomic or stayed, or (b) the asserted claims were not commercially threatening enough to justify the filing fee. Either way, a defendant should not assume the absence of IPRs reflects a strong patent.
Recommended next steps
Confirm the maintenance-fee lapse first — this is the highest-leverage fact. The structured data says "Expired – Fee Related" with an anticipated expiration of 2032-03-07. Read literally, that means the patent lapsed early for non-payment, roughly nine years short of its nominal term. Pull the USPTO Patent Center maintenance-fee records to pin down the exact lapse date and whether any petition to accept late payment or reinstatement was ever filed. If the lapse is real and unremedied, infringement damages are capped at the period before lapse (subject to the six-year lookback of § 286), which usually collapses the exposure. Note the patent is not pending expiration in the ordinary sense — do not let opposing counsel describe it as "still enforceable until 2032."
Get a full assignment and entity-relationship trace. Confirm the chain Panasonic Corporation → Panasonic IP Corp. of America → Sovereign Peak Ventures, LLC as it stands today, including any further transfers. SPV's status as a monetization vehicle matters for § 315 real-party-in-interest analysis if a defendant later files an IPR, and for identifying privity if any co-plaintiff joins.
Screen for unasserted first-to-file art. Since no IPR ever constricted the prior-art space, run an independent pre-2011 search against the two Patent Literature references cited on the face of the patent — JP 2002-374514 and JP 2008-217831 — plus the GPS/location-based content-delivery literature. The claims are broad functional recitations (acquire request → acquire accepter locations → compute expectation value from distance-tendency history → notify likely accepters), which is exactly the profile that KSR obviousness challenges tend to reach.
If a complaint is actually served, watch the § 315(b) clock. There is no estoppel debt to worry about, so a fresh IPR remains fully available — but the one-year bar from service starts immediately, and an ill-timed Fintiv discretionary-denial posture may still apply in the Fifth Circuit district courts where SPV litigates.
Do not represent in any filing that this patent has been PTAB-tested, in either direction. The record shows no IPR activity. If opposing counsel asserts the patent has "survived PTAB review," that statement is unsupported by the ODP data and by every public source I could reach.
Sources
- USPTO Open Data Portal structured record for US 8,874,474 — no AIA proceedings returned (canonical list for this report).
- Google Patents, US8874474B2 (fetched 2026-09-24) — bibliographic data, assignment chain, "Expired – Fee Related" status, cited Patent Literature 1 and 2.
- Web sweeps (conducted 2026-09-30) of PTAB petition/decision repositories, Docket Alarm PTAB records, Patexia PTAB case summaries, and Federal Circuit docket material — no matter naming US 8,874,474 or application 13/979,238 located. All PTAB documents returned by these searches pertained to unrelated patents and were excluded.
Generated 9/30/2026, 1:31:05 PM
Ownership chain (3)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2013-09-11 · Assignment
Wakai, Ryohei; Fujita, Takahisa; Kawamura, YuzoPANASONIC CORPORATION
internal corporate assignment
? · recorded 2014-05-27 · Assignment
PANASONIC CORPORATIONPanasonic Intellectual Property Corporation of America
internal reorg
? · recorded 2018-10-31 · Assignment
Panasonic Intellectual Property Corporation of AmericaSovereign Peak Ventures, LLC
transfer-to-asserter
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.
I'll research the assignment record for US 8874474 before drafting.
Let me dig into the specific assignment records and correspondents.
Assignment & Ownership Analysis — US 8,874,474 B2
Verification note (read first): I ran targeted searches against the USPTO Assignment Center index, Google Patents legal events, PTAB filings, and court dockets. I was able to confirm the existence, dates, and parties of the recorded assignments, but the live USPTO Assignment Center interface did not return machine-readable reel/frame numbers or the attorney of record on the assignment cover sheets for this specific patent in my searches. I have not filled those gaps with invented values. Where I cite a reel/frame or a correspondent, I say explicitly whether it is for this patent or for a sibling patent in the same portfolio batch.
Inventors
| Inventor | Employer at filing (determinable) | Basis |
|---|---|---|
| Ryohei Wakai | Panasonic Corporation (Japan) | Named as assignor on the 2013-09-11 recorded assignment to PANASONIC CORPORATION |
| Takahisa Fujita | Panasonic Corporation (Japan) | Same 2013-09-11 assignment record |
| Yuzo Kawamura | Panasonic Corporation (Japan) | Same 2013-09-11 assignment record |
All three inventors appear as a block on a single inventor→corporate assignment, which is the standard Panasonic employment-agreement pattern (assignment executed after the 2012-03-07 filing, recorded 2013-09-11 as the case moved toward grant).
Unusual-pattern check: not present / not determinable. I found no evidence of the inventors departing Panasonic within 12 months of filing, and no evidence they were named on any subsequent assignment or litigation. A pre-grant, all-inventors-block assignment to the employer is the ordinary corporate pattern — there is no fire-sale precursor visible at the inventor level. I could not independently verify each inventor's employment status beyond the assignment document; treat that as inferred, not documented.
Original assignee
Entity named as original assignee (per Google Patents bibliographic record for US 8,874,474): Panasonic Intellectual Property Corporation of America (PIPCA).
Nature of the entity: PIPCA is not an operating company — it is Panasonic's U.S.-based IP holding and management subsidiary, the vehicle Panasonic used from roughly 2013–2014 onward to concentrate U.S. patent assets. The assignment record itself confirms the structure: inventors → Panasonic Corporation (the Japanese operating parent, 2013-09-11) → Panasonic Intellectual Property Corporation of America (2014-05-27). That is a two-hop internal reorganization into the IP-holding subsidiary, not a sale to a third party.
Primary line of business of the ultimate operating parent: Panasonic Corporation — consumer and industrial electronics (TVs, appliances, AV, semiconductors, automotive electronics, batteries).
Did Panasonic ship a product embodying the claims? The claims are directed to a communication server that mediates requests for content creation (matching a requester's desired recording location to accepter terminals via acceptance-probability history). This is a service-platform abstraction, not a device claim. Panasonic did operate live/remote-camera video services in the relevant era, but I did not verify that any Panasonic commercial service practiced these specific claims, and I am not asserting it. Mark as unclear.
Current status of the original assignee: Panasonic Corporation remains an operating, publicly traded company (it has since restructured into a holding-company structure and spun off/renamed several units). No bankruptcy proceeding involving Panasonic is implicated. Panasonic is, however, the well-documented source portfolio behind one of the largest patent monetization divestitures of the decade (discussed below).
Assignment timeline
Google Patents legal events for US 8,874,474 record three post-filing assignments. I list them in order. Reel/frame and cover-sheet correspondent are marked [not retrieved] rather than guessed.
2012-03-07 — Application filed (US 13/979,238; priority 2011-03-23; PCT-origin, expired 2032-03-07).
- Conveyance: n/a (filing event)
- Applicant / assignee of record at filing: Panasonic Intellectual Property Corporation of America
- Context: initial filing of a Panasonic corporate patent application.
2013-09-11 (executed n/a) / recorded 2013-09-11 — Reel [not retrieved] / Frame [not retrieved]
- Conveyance: Assignment (reassignment event per Google Patents)
- Assignor: Wakai, Ryohei; Fujita, Takahisa; Kawamura, Yuzo (inventors)
- Assignee: Panasonic Corporation
- Correspondent: [not retrieved]. Panasonic's U.S. prosecution correspondence around this period ran through Greenblum & Bernstein, P.L.C., 1950 Roland Clarke Place, Reston, VA 20191 (USPTO Customer No. 125331) — confirmed as PIPCA's attorney of record in later PTAB files for sibling Panasonic patents, not confirmed as the correspondent on this specific recording.
- Context: internal corporate assignment — inventors to employer; standard pre-grant perfection of title.
2014-05-27 (executed n/a) / recorded 2014-05-27 — Reel [not retrieved] / Frame [not retrieved]
- Conveyance: Assignment ("Assignment of Assignor's Interest")
- Assignor: Panasonic Corporation
- Assignee: Panasonic Intellectual Property Corporation of America
- Correspondent: [not retrieved]
- Context: internal reorganization — transfer of the parent's IP into its U.S. IP-holding subsidiary, consistent with Panasonic's 2013–2014 consolidation of U.S. patent assets.
2018-10-31 (executed n/a; SPV's authorized signatory dated the related power of attorney 2018-10-30) / recorded 2018-10-31 — Reel [not retrieved for '474] / Frame [not retrieved]
- Conveyance: Assignment (reassignment event per Google Patents)
- Assignor: Panasonic Intellectual Property Corporation of America
- Assignee: Sovereign Peak Ventures, LLC (successor-in-interest; now recorded as current assignee)
- Correspondent: [not retrieved on the '474 cover sheet]. For the same SPV acquisition batch, correspondence of record in USPTO filings is Ascenda Law Group, PC, 333 W San Carlos St., Suite 200, San Jose, CA 95110 (USPTO Customer No. 27571), with David Pridham, CEO, signing as the assignee's authorized signatory (see PTAB petitions 1547147 / 1547270, 37 CFR 3.73 statements). Sibling-patent lead, not a verified '474 correspondent.
- Sibling reel data point (flagged as unverified for '474): a 37 CFR 3.73 chain-of-title statement in PTAB petition 1547270 cites Reel 035343, Frame 0392 in the Panasonic → Sovereign Peak Ventures chain for US 10,102,861, a different patent acquired in the same batch. I could not confirm that '474 sits at reel 035343 at a different frame.
- Context: transfer-to-monetizer / portfolio sale — this is the decisive link; see NPE analysis.
Subsequent event (not an assignment): Google Patents lists the current legal status as "Expired – Fee Related", i.e. lapsed for non-payment of maintenance fees, with anticipated expiration 2032-03-07. This is consistent with a monetization entity harvesting a portfolio and abandoning low-value members once licensing revenue did not materialize. (Status is a Google Patents assumption, not a legal conclusion.)
Litigation (not an assignment, but relevant to the chain's purpose): I found no infringement suit asserting US 8,874,474 specifically. Sovereign Peak Ventures' documented campaigns asserted other former-Panasonic patents:
- Dec 2018 – Oct 2019: LED-lighting campaign (Anker, Feit Electric, LiFi Labs, SengLED).
- April 2020: three E.D. Tex. suits vs. LG Electronics (2:20-cv-00107/-108/-109) asserting 7,133,658; 9,042,457; 9,414,059; 8,374,152; 8,442,569; 8,467,723; 8,792,453; 9,620,282; 9,935,481; 9,991,735; 10,044,225; 10,291,069; 8,902,871; 9,357,441; 10,039,144; 9,431,017; 9,747,903; 10,102,861.
- Aug 2025: Verifone (N.D. Ga. 1:25-cv-04730) asserting 8,374,152; 8,442,569; 8,467,723; 8,792,453.
- Sep 2025: NXP Semiconductors (W.D. Tex. 1:25-cv-01573/01574) asserting 7,796,512; 8,045,531; 8,270,384; 8,552,684; 8,963,490; 9,620,282.
'474 is not among them — so it is a portfolio asset that was acquired for assertion but (on the record I can find) never individually asserted, and has now lapsed.
Timeline diagram
timeline
title Ownership of US 8874474
2011 : Priority date 23 March 2011
2012 : Application filed 7 March 2012
2013 : Inventors assign to Panasonic Corp
2014 : Panasonic Corp assigns to PIPCA
: Patent issued 28 October 2014
2018 : PIPCA assigns to Sovereign Peak Ventures
2018 : SPV first litigation campaign starts
2020 : SPV sues LG Electronics
2025 : SPV sues Verifone and NXP
NPE / troll-pattern signals
1. Shell-entity transfer — PRESENT (strong).
The patent moved out of Panasonic Intellectual Property Corporation of America — an operating company's IP-holding arm — into Sovereign Peak Ventures, LLC on the 2018-10-31 recorded assignment. Corroborating evidence beyond the name suffix "Ventures":
- SPV's own corporate disclosure statement in Sovereign Peak Ventures, LLC v. Verifone, Inc., N.D. Ga. 1:25-cv-04730 (filed Aug 2025) identifies Dominion Harbor Enterprises, LLC and Monument Patent Holdings, LLC as affiliates.
- SPV's recorded address of record in USPTO filings is 1400 Preston Road, Suite 400 (later Suite 475), Plano, TX 75093 — Dominion Harbor's business address, shared across its "peak ventures" family (Sovereign Peak / Monument Peak / Vista Peak).
- RPX Insight (2020-04-19) describes SPV, MPV and VPV as "three of the four 'peak ventures'" of "Texas monetization firm Dominion Harbor Enterprises, LLC."
- Dominion Harbor's own portfolio page markets SPV as the exclusive licensing vehicle for the former-Panasonic assets.
No products in commerce are attributed to SPV in any source located.
2. Known asserter in the chain — PRESENT (strong).
The current assignee Sovereign Peak Ventures, LLC is not on the specific legacy list in the brief (Acacia, Marathon, IV, Wi-LAN, etc.), but the brief's catch-all — "any entity surfaced by Unified Patents or RPX as a high-frequency plaintiff" — is squarely met. RPX Insight has covered SPV's campaigns since December 2018; RPX Empower and Unified Patents both maintain dockets on SPV as respondent/patent owner (e.g., IPR2023-01262 and IPR2023-01261, Hewlett Packard Enterprise v. Sovereign Peak Ventures, both terminated by pre-institution settlement in October 2023). Back-to-back 2025 filings against Verifone (N.D. Ga.) and NXP (W.D. Tex.) confirm the entity is still actively asserting. '474 itself has not been identified as asserted.
3. Repeat correspondent across the chain — PRESENT (moderate; portfolio-level).
- Ascenda Law Group, PC, 333 W San Carlos St., Suite 200, San Jose, CA 95110 (USPTO Customer No. 27571) appears as the SPV/Dominion Harbor correspondence and power-of-attorney address in multiple USPTO filings for patents in the same acquired Panasonic batch (PTAB petitions 1547147, 1547270), with David Pridham, CEO signing as the assignee's authorized representative. This is a recurring correspondent across the SPV portfolio, not a one-off.
- Greenblum & Bernstein, P.L.C., 1950 Roland Clarke Place, Reston, VA 20191 (Customer No. 125331) was PIPCA's attorney of record on sibling Panasonic patents before the SPV acquisition (same filings).
Caveat, stated precisely: I confirmed these two firms as correspondence of record on sibling patents in the same batch and on related PTAB filings. I did not retrieve the assignment cover-sheet correspondent for US 8,874,474 itself, so I cannot state that Ascenda (or Greenblum) filed this particular recording. A single appearance would not be a finding; recurrence is what is evidenced here, and recurrence is visible at the portfolio level.
4. Cascading transfers — NOT PRESENT (as defined).
The chain has three recorded links spread over roughly five years (2013 → 2014 → 2018). Two of those (2013, 2014) are internal Panasonic reorganizations, not third-party chained LLCs. There is no sequence of consecutive transfers through chained LLCs inside a 24-month window, and no evidence of shared principals or correspondent addresses across competing assignees. This signal does not fire.
5. Pre-litigation transfer — PRESENT for the portfolio; UNCLEAR for '474.
The PIPCA → SPV assignment is dated/recorded 2018-10-31. SPV's first infringement campaign (LED lighting — Anker, Feit Electric, LiFi Labs, SengLED) began in December 2018, i.e. within roughly two months of the acquisition. That is the classic "acquire-then-assert" setup. However, US 8,874,474 is not among the patents asserted in that or any later campaign I could locate, so I cannot tie this patent's transfer to a specific suit within the 6-month window. Score as present at the portfolio level, unclear at the patent level.
6. Bankruptcy fire-sale — NOT PRESENT.
No bankruptcy of Panasonic Corporation or PIPCA appears in any source. The Panasonic → SPV transfer was a voluntary portfolio divestiture, not a court-supervised sale. (This distinguishes the chain from the Kodak/Nortel/Polaroid paradigm.)
7. Privateering — UNCLEAR (unverified intermediate link).
RPX Insight (2020-04-19) states that Dominion Harbor "received each of these portfolios from Intellectual Ventures LLC (IV)." If the Panasonic assets transited IV on the way to SPV, that is textbook privateering (operating company → IV → assertion vehicle). But the recorded chain for US 8,874,474 shows a direct PIPCA → Sovereign Peak Ventures assignment on 2018-10-31, with no recorded IV link. I therefore mark this unclear: either (a) the IV leg exists for other Panasonic batches but not this one, (b) an IV intermediate transfer was never recorded for this patent, or (c) RPX's characterization is at the portfolio-deal level rather than the recordation level. I cannot resolve this from the sources retrieved.
8. Defensive aggregator (anti-NPE) — NOT PRESENT.
The chain terminates at Sovereign Peak Ventures, LLC — an assertion vehicle. There is no RPX / AST / LOT / Unified / OIN link anywhere in the chain, and the patent's own lapse for unpaid maintenance fees is not a defensive-neutralization event.
Verdict
NPE — high confidence.
Three strong signals fire on documented evidence: (i) shell-entity transfer — the 2018-10-31 recorded assignment moved the patent from Panasonic's U.S. IP-holding subsidiary (PIPCA) to Sovereign Peak Ventures, LLC, a licensing-only entity at 1400 Preston Road, Plano, TX, whose own Rule 7.1 corporate disclosure statement in SPV v. Verifone (N.D. Ga. 1:25-cv-04730) affiliates it with Dominion Harbor Enterprises, LLC; (ii) known asserter in the chain — SPV is a Dominion Harbor monetization vehicle with continuous assertion activity from December 2018 through 2025 across former-Panasonic patents (RPX Insight, 2020-04-19; SPV v. LG, E.D. Tex. 2:20-cv-00109); and (iii) acquire-then-assert timing — the SPV acquisition closed roughly two months before SPV's first suits in December 2018. The correspondence of record on the SPV portfolio runs repeatedly through Ascenda Law Group, PC (Customer No. 27571), with David Pridham signing as CEO for the assignee.
Two honest qualifications belong in the verdict: US 8,874,474 itself has not been identified as asserted in any litigation, and it is now "Expired – Fee Related" per Google Patents, i.e. lapsed for non-payment of maintenance fees. So this is a former Panasonic asset that passed into a well-documented Dominion Harbor assertion vehicle, was held in the portfolio, was never individually litigated on the record I can find, and was subsequently abandoned. The NPE characterization rests on the assignee's identity and conduct, not on this patent's own assertion history.
Primary-source caveats: reel/frame numbers and the assignment cover-sheet correspondent for US 8,874,474 were not retrieved and are not asserted above. Only the sibling-patent reel reference (035343/0392, US 10,102,861) and the sibling-patent POA correspondents are evidenced.
Verify at:
- USPTO Assignment Center: https://assignmentcenter.uspto.gov/
- Legacy Assignment Search (patent number lookup): https://assignment.uspto.gov/patent/index.html
- Google Patents legal events for this patent: https://patents.google.com/patent/US8874474/en
Generated 9/30/2026, 1:31:36 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research US patent 8874474 and its cited prior art. Let me run several searches.
Let me fetch the primary patent pages directly to get the citation lists.
Let me retrieve the citation sections directly from Justia and the patent PDF front page.
Scope, method, and important caveats
What I was able to establish (and how):
| Item | Value | Source |
|---|---|---|
| Patent | US 8,874,474 B2 | Google Patents / Justia |
| Application no. | US 13/979,238 | Google Patents |
| Priority date | 2011-03-23 | Google Patents |
| Filing date | 2012-03-07 | Google Patents |
| Grant date | 2014-10-28 | Google Patents |
| Inventors | Ryohei Wakai; Takahisa Fujita; Yuzo Kawamura | Google Patents |
| Original assignee | Panasonic Intellectual Property Corp. of America; later Sovereign Peak Ventures LLC | Google Patents |
Caveats you must weigh before treating anything below as a legal conclusion:
- I performed open-web searches (including Google Patents' rendering of the patent, Justia's page, and the grant PDF at
patentimages.storage.googleapis.com/8f/bd/4e/47aceaf27ccfd1/US8874474.pdf). I was not able to page through the USPTO Patent Center / Patent Public Search "References Cited" (IDS) list or the full "Cited By" list for US 8,874,474 within the search budget. So I cannot guarantee completeness of the citation list. - I did not retrieve the full text of either cited Japanese reference. My description of them is drawn from US 8,874,474's own Background Art section, which characterizes them. That is a summary by the applicant, not the references' actual disclosures, and should be verified against the primary documents.
- Per your instruction, I have not corrected any identifier. Note one third-party discrepancy: the site
idiyas.comrenders the number as "US 8874474 B1," whereas Google Patents, Justia, and the grant PDF all render "B2." I am recording the discrepancy, not silently fixing it. The authoritative documents (Google Patents page and the front page of the grant PDF) show B2. - Nothing here is a legal conclusion; it is a technical prior-art mapping for analysis only.
Independent-claim structure I am using (from the specification's claim summary and the Justia claim text):
- Claim 1 – independent server claim (request acquiring unit; terminal location acquiring unit; notifying unit; acceptance information acquiring unit; history managing unit storing, per notification, (i) notification-time location, (ii) desired location, (iii) acceptance information; selecting unit that, on a new request, selects the notified terminal according to the locations + desired location + history information, and calculates expectation values of acceptance).
- Claim 2 – distance tendency value as the expectation value.
- Claim 3 – time tendency value combined with distance tendency value.
- Claim 4 – location tendency value (depends on claim 2).
- Claim 5 – correction of distance tendency value by current distance.
- Claim 6 – category tendency value with a location-category database (depends on claim 2).
- Claim 7 – user identifiers, expectation value computed per user.
- Claim 8 – storing notification distance instead of the two locations.
- Claim 9 – independent method claim mirroring claim 1.
(An earlier pre-grant publication, US 2013/0298150 A1, carries a differently numbered claim set — e.g., claims 13–21 use a "location tendency value" formulation — so be careful not to conflate the application claims with the granted claims.)
Prior-art references cited in US 8,874,474
Reference 1 — Patent Literature 1
Full citation: Japanese Patent Application Publication No. 2002-374514 (JP 2002-374514 A).
Dates: Cited in the '474 specification under "CITATION LIST / [Patent Literature 1]." Publication year 2002 (JP publication numbers encode the publication year). I do not have a verified exact publication date or filing date for this document — treat those as unconfirmed rather than as stated facts.
Brief description (per the '474 Background Art): A delivery server acquires, from a requester terminal, a delivery request specifying a desired location for content creation; the server then provides a notification of the delivery request to an accepter terminal near the desired location, selected from among accepter terminals that would accept content creation; the accepter terminal creates the content at the specified location and transmits it to the delivery server. (See the "Background Art" section, PL1 paragraph, at https://patents.google.com/patent/US8874474/en.)
§ 102 anticipation analysis — as to the granted claims: The reference is not anticipatory of any claim (1–9) because it is missing the claimed history-based selection architecture, which is the point of novelty:
| Claim 1 limitation | Disclosed by PL1? |
|---|---|
| request acquiring unit (request with desired location for content creation) | Yes |
| terminal location acquiring unit (locations of accepter terminals) | Yes (implicitly – used to pick a "near" terminal) |
| notifying unit sends request notification to a selected accepter terminal | Yes |
| acceptance information acquiring unit (whether the notified terminal accepted) | Not shown in the '474's summary; unverified |
| history managing unit storing, per past notification, notification-time location + desired location + acceptance information | No |
| selecting unit that, on a new request, selects the notification target according to locations + desired location + history information, and computes expectation values of acceptance | No — PL1 selection is proximity-based only, using no acceptance history and no expectation value |
| Claims 2–8 (tendency-value features) | No — all depend on the claim-1 history/expectation architecture |
| Claim 9 (method mirroring claim 1) | No for the same reason |
Conclusion: PL1 is relevant as § 103 background art (it establishes the general "locate an accepter near the desired location and notify" framework that the '474 acknowledges), and the '474's own specification concedes this framework. But because it lacks the notification-history store and history-based expectation-value selection, it does not disclose every element of claim 1 (or 9), and cannot anticipate them or their dependents under § 102.
Reference 2 — Patent Literature 2
Full citation: Japanese Patent Application Publication No. 2008-217831 (JP 2008-217831 A).
Dates: Cited in the '474 specification under "CITATION LIST / [Patent Literature 2]"; the grant PDF's front-page reference data associates it with September 2008 ("… JP 2008-217831 9/2008"). Exact filing date unverified.
Brief description (per the '474 Background Art): On acquiring a delivery request including the desired content-creation location, the delivery server presents information about accepter terminals near the desired location to the requester terminal; the requester terminal then selects an accepter terminal from that presented information; the server notifies the selected accepter terminal; that terminal creates the content at the desired location and transmits it to the server. (See the "Background Art" section, PL2 paragraph, at https://patents.google.com/patent/US8874474/en.)
§ 102 anticipation analysis — as to the granted claims:
| Claim 1 limitation | Disclosed by PL2? |
|---|---|
| request acquiring unit | Yes |
| terminal location acquiring unit | Yes (used to find "nearby" accepters) |
| notifying unit | Yes |
| selection performed by the server using a stored acceptance history and an expectation value | No — in PL2 the human requester performs the selection from presented candidates; there is no server-side expectation-value computation and no acceptance-history store |
| history managing unit (notification-time location + desired location + acceptance information) | No |
| Claims 2–9 (tendency values, expectation value, method) | No — all flow from the claim-1 architecture |
Conclusion: Like PL1, PL2 is § 103 background art that discloses the general requester-selects-nearby-accepter mediation model. It is missing at least the "history managing unit" and the "selecting unit … calculates expectation values … using the history information" elements, so it does not anticipate any of claims 1–9 under § 102.
Other citation leads I encountered (flagged as unverified)
- JP 2003-256684 A — a Google Patents page for JP 2003256684A ("Method of mediating social welfare activity," NTT) shows US 8,874,474 B2 listed in its "Cited By" table (https://patents.google.com/patent/JP2003256684A/en). That relationship is consistent with US 8,874,474 citing JP 2003-256684 A, but "Cited By"/"Citations" tables can be auto-generated and I could not confirm the IDS entry. Treat JP 2003-256684 A as a possible-but-unconfirmed citation.
- US 2011/0258066 A1 — the page for this document likewise lists US 8,874,474 B2 in a "Cited By" table (https://patents.google.com/patent/US20110258066A1/en), suggesting a possible citation relationship. Unconfirmed.
- My searches also surfaced unrelated documents (e.g., a "predictive streaming" PCT, various IPR/PTAB papers about other patents) that are not citations of US 8,874,474; I am excluding them rather than padding the list.
I could not recover the complete examiner-cited U.S. patent documents in the "(56) References Cited" block of the grant PDF (the text I could see only exposed a fragment such as "G06Q JP 2008-217831 9/2008"). If you need a fully reliable § 102/§ 103 chart, the next step is to pull the front page of the grant PDF and the USPTO Patent Center "References Cited"/IDS documents directly, plus the full text (and certified translations) of JP 2002-374514 and JP 2008-217831.
Bottom line
- Patent: US 8,874,474 B2 (app. 13/979,238; priority 2011-03-23; filed 2012-03-07; granted 2014-10-28).
- Cited prior art identified from the patent's own Citation List: (1) JP 2002-374514 A, and (2) JP 2008-217831 A. Both describe proximity-based request mediation (server-notifies-nearby-accepter in PL1; server-presents-nearby-accepters-and-requester-selects in PL2).
- § 102 conclusion: Neither PL1 nor PL2 anticipates any of claims 1–9, because neither discloses the claimed notification-history store (notification-time location + desired location + acceptance information) or the history-based expectation-value selection recited in independent claim 1 (and mirrored in claim 9). They are properly characterized as background/§ 103 art.
- Confidence: High on the identity of the two cited JP references and on the claim limitations that defeat anticipation; low/unverified on exact publication and filing dates for those JP references, and incomplete as to the full examiner-cited U.S. reference list, which I could not retrieve within this session.
Generated 9/30/2026, 1:31:19 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll start by gathering the authoritative claim text and details on the cited prior art, since the excerpt above cuts off before the claims.
I need the exact claim language before analyzing. Let me try to retrieve the claims.
Obviousness Analysis — US 8,874,474 B2
Patent: US 8,874,474 B2 ("Communication server, communication method, memory medium and integrated circuit for mediating requests for content delivery according to expectation values of a probability of acceptance of the request, desired location, and history information")
Priority: 2011-03-23 · Filed: 2012-03-07 · Granted: 2014-10-28 · Status: Expired – Fee Related · Assignee of record: Sovereign Peak Ventures LLC (originally Panasonic IP Corp. of America)
Family: PCT/JP2012/001553 → WO2012127799A1; US20130298150A1
1. Verification limitations (read before relying on this analysis)
I am flagging these up front because they bound the reliability of everything below:
- Claim text. The authoritative full text supplied in the user message is truncated before the claims. I reconstructed the claim set from Google Patents and Justia snippets (https://patents.google.com/patent/US8874474#8 ; https://patents.justia.com/patent/[8874474](/patent/8874474)#5 ; https://patents.justia.com/patent/20130298150#5). The granted patent appears to carry claims 1–11 (claim 1 independent server; claims 2–8 dependent; claim 9 method; claim 10 non-transitory computer-readable recording medium; claim 11 integrated circuit). Word-level verification of claim 1 against the granted document was not possible with the tools available to me.
- Prior art text. Per your instruction I used the Prior Art section of the page. That section supplies only two references — JP 2002-374514 (Patent Literature 1) and JP 2008-217831 (Patent Literature 2) — and does not reproduce their text. My searches for the full text of those two Japanese publications returned unrelated documents. I therefore rely on the applicant's own characterization of PL1 and PL2 in the specification, which is an admission about the prior art and is citable against the patent. I have not independently verified PL1's or PL2's disclosure.
- Metadata discrepancy (not auto-corrected). Google Patents lists the document as US8874474B2; idiyas.com lists it as "US 8874474 B1" (https://idiyas.com/patent/badge/8874474). I use the number exactly as given (8874474) and note the kind-code conflict as an unresolved metadata discrepancy.
- File history. I could not inspect the US file wrapper for the examiner's cited art or the PCT/JP2012/001553 search report. A production-grade § 103 opinion must do so.
2. The claims to be analyzed (reconstructed)
Claim 1 (independent, server) — a communication server comprising:
- a request acquiring unit that acquires a request for content creation specifying a desired location;
- a terminal location acquiring unit that acquires locations of a plurality of accepter terminals;
- a notifying unit that notifies a selected accepter terminal of the request;
- an acceptance information acquiring unit that acquires acceptance information showing whether the notified terminal accepted;
- a history managing unit that manages history information containing, for each past notification: (i) the location of the accepter terminal at the time of provision of the notification, (ii) the desired location of the corresponding request, and (iii) the acceptance information; and
- a selecting unit that, upon a new request, calculates expectation values showing a probability of accepting the new request for each accepter terminal using the terminals' locations, the new request's desired location, and the history information, and selects the terminal to be notified according to the expectation value.
Dependents: cl. 2 distance tendency value; cl. 3 time tendency value; cl. 4 location tendency value; cl. 5 correction of distance tendency value by current distance; cl. 6 location-category tendency value; cl. 7 expectation value computed per user using stored user identifiers; cl. 8 history stores a notification distance instead of the two locations. Claims 9–11 are the method, recording-medium and integrated-circuit counterparts.
(Note: US20130298150A1's claims 13–21 describe a differently-worded independent claim centered on "location tendency values." If that set reflects the pre-grant claims, the granted set evidently shifted the core to the expectation-value/history combination. This is a prosecution-history point worth developing against the file wrapper.)
3. The prior art of record
| Ref | Identity | Disclosure per the applicant's own characterization |
|---|---|---|
| PL1 | JP 2002-374514 | Delivery server acquires a delivery request specifying a desired location for content creation from a requester terminal; notifies an accepter terminal near the desired location, selected from among accepter terminals that would accept the content creation; the accepter creates the content at the desired location and transmits it to the server. |
| PL2 | JP 2008-217831 | On acquiring a delivery request including the desired location, the server presents information about accepter terminals near the desired location to the requester terminal; the requester selects one; the server notifies the selected accepter. |
Both are comfortably pre-2011 (2002 and 2008) and therefore qualify as prior art under § 102(b)/pre-AIA § 102(b) as of the 2011-03-23 priority date.
The specification itself frames the problem the invention purports to solve: "Some of the users of the accepter terminals willingly accept the request, but others do not. Some users accept the request even though they are distant from the desired location, whereas some users deny the request even though they are close to the desired location." It further states that close-only selection is "difficult" and that notifying unwilling, nearby users is undesirable "because the notification of the request is unnecessary information for such users."
4. Governing standard
Under Graham v. John Deere and KSR Int'l v. Teleflex, a claim is obvious if the differences between the claim and the prior art are such that the subject matter as a whole would have been obvious to a person of ordinary skill at the time of the invention, considering (1) scope and content of the prior art, (2) level of ordinary skill, (3) differences, and (4) secondary considerations. KSR additionally authorizes (a) combining known elements to achieve predictable results, (b) the "obvious to try" rationale where there is a finite number of identified, predictable solutions, and (c) reliance on design incentives and market demands present in the field. MPEP § 2143 requires an articulated reason for the combination — not mere juxtaposition of references.
Level of ordinary skill. A POSITA here is a software/systems engineer with ~2–3 years' experience in networked client-server service platforms (location-based services, media delivery) plus working familiarity with database-backed user profiling and basic statistical scoring. This is not a hardware or algorithmic-research invention.
5. Primary combination: PL1 + PL2 (+ knowledge of predictive user profiling)
5.1 What PL1 alone discloses
PL1 discloses elements (a)–(d) of claim 1 essentially verbatim: acquiring the request with a desired location; knowing accepter-terminal locations (it must, to select those "near the desired location"); notifying a selected accepter; and knowing whether the request was accepted (PL1's selection is expressly drawn from terminals that "would accept," and the accepted terminal then creates and transmits the content).
5.2 The only real differences
The claimed subject matter adds exactly two things:
- (e) Recording, per notification, the triple {notification-time accepter location, desired location, acceptance outcome}; and
- (f) using that recorded history to compute a probability of acceptance and rank/select notifications by it.
Neither recording a notification log nor predicting a user's future response from past responses is novel technology. What claim 1 does is apply empirically-estimated acceptance propensity to PL1's location-based dispatch.
5.3 Motivation to combine — articulated reasons
The problem is admitted as known. The background of the patent itself identifies the deficiency of distance-only selection as the problem to be solved. Where the prior art discloses the problem and the inventor merely applies a known remedy, the claim is obvious (In re Kahn; KSR). A POSITA reading PL1's own premise — notifying terminals "that would accept" — is directly prompted to ask how does the server know who would accept? The answer supplied by the claim (count past acceptances under similar conditions) is the most natural and only data-driven answer.
PL2 supplies an explicit ranking/evaluation step. PL2 teaches surfacing accepter-terminal information so that the accepters can be evaluated before selection. Once the system is evaluating candidates rather than blindly notifying, the substitution of a quantitative evaluation (predicted acceptance probability) for PL2's manual/manual-ish evaluation is an improvement of the same function by a known technique — a quintessential obvious combination (KSR).
Predictable result, no new mechanics. Using historical response rates to predict future response rates (propensity scoring, response modeling) was, by 2011, standard practice in targeted advertising, recommender systems, CRM/campaign management, and worker/task dispatch (e.g., choosing the nearest and most likely-to-accept worker). Combining it with PL1's location filter yields nothing more than the sum of the two functions: the same notification pipeline, gated by an additional filter. The result — fewer futile notifications and a higher acceptance rate — is predictable, which is the touchstone under KSR.
Recognized design incentives. Notification spam reduces user goodwill and wastes bandwidth/battery on mobile terminals; the specification's own UI flow (a list of terminals shown to the requester, e.g. FIGS. 11A/11B) makes clear that the system's value depends on eligible accepters actually responding. These market pressures supply the design incentive KSR recognizes.
"Obvious to try." The claim selects from a finite, small set of readily identifiable predictors available in the same data (distance, time, location, category, user). Substituting or combining them is the definition of obvious-to-try.
Inherency/design choice for the stored fields. Because a server that performs PL1's location-based selection necessarily receives and computes both the accepter's current location and the desired location at notification time, persisting those two values alongside the acceptance outcome is a matter of routine data-logging design choice, not invention. Storing a derived "notification distance" (claim 8) rather than the two constituent coordinates is a pure data-representation/efficiency choice with no unexpected result.
6. Claim-by-claim disposition
| Claim | Rejection basis (art) | Reason |
|---|---|---|
| 1 | PL1 (a–d) + PL2 (evaluation concept) + secondary art/known practice (e, f) | Problem admitted; propensity-from-history is known; predictable improvement of PL1's dispatch function |
| 2 (distance tendency value = expectation value) | Claim 1 + known empirical-rate scoring | Simply computing P(accept | distance band) = a histogram/MLE on the stored data |
| 3 (add time attribute) | Claim 1 + known time-targeted campaign scheduling | Day-of-week/hour targeting is ubiquitous in advertising/campaign art; storing a timestamp is a design choice |
| 4 (location tendency value) | Claim 1 + known "near the usual location" gating (geofence) | GIS proximity queries (H04W4/02 geofencing arts) are conventional |
| 5 (correct distance tendency by current distance) | Claim 2 + known confidence/decay weighting | Applying a distance-dependent weight to a distance-based score is an obvious refinement; the patent's own FIG. 20 shows the inverse relationship |
| 6 (category tendency via location-category DB) | Claim 1 + known POI/category databases | Mapping coordinates → semantic category via a lookup table and conditioning on it is routine; the spec treats it as an added database |
| 7 (per-user expectation using stored user IDs) | Claim 1 + PL1 (user registration) + known cross-device profile aggregation | The system already stores user IDs; aggregating a user's history across his devices is an obvious data-modeling choice |
| 8 (store notification distance) | Claim 1 + design choice | Deriving/deriving-storing one scalar instead of two coordinates — predictable, no unexpected benefit |
| 9 (method) | Same art | Mere recitation of claim 1's functions as steps |
| 10 (recording medium) | Same art + program-on-medium practice | Obvious statutory-category counterpart |
| 11 (integrated circuit) | Same art + the spec's own statement that "each functional block of the delivery server is typically realized as an LSI" | Applicant's own admission that LSI implementation is conventional |
7. Secondary-reference search directions (UNVERIFIED — flagged as leads, not verified art)
I could not verify the disclosures of any of the following, so they must be treated as search leads requiring independent confirmation before use in any pleading or office action: (i) crowdsourcing/task-dispatch systems that score workers by past acceptance rates; (ii) ride/vehicle dispatch systems (circa 2009–2011) that score candidate drivers by historical acceptance and proximity; (iii) recommender/targeted-advertising response-prediction patents; (iv) geofencing/POI-category arts under H04W 4/021 and G06Q 30/0605 (the classes the USPTO itself assigned to these claims). Any such reference must predate 2011-03-23.
If PL1 is not available as a translated full text, the combination that comes closest to the pre-grant characterization would be PL1 + (secondary art teaching history-based acceptance/response probability) with PL2 used only to show it was known to evaluate accepter candidates before notifying.
8. Where the § 103 case is weak
- No single reference appears to disclose elements (e) and (f). Unless secondary art squarely teaches storing the notification-time location paired with the desired location and the outcome, the rejection is a combination rejection requiring the articulated motivation above. A bare "reference A + reference B" recitation without that reasoning is vulnerable under MPEP § 2143 and In re Kahn.
- Applicant may argue the specific triple in the history record is non-obvious — i.e., that others stored acceptance history or stored location history, but not the paired notification-location/desired-location/outcome tuple that enables a distance-conditioned acceptance rate. That is the strongest non-obviousness argument available on this record, and it is a narrow one: the specification's own abstract admits the history is essentially "the distance from an accepter terminal to be provided with the notification to the desired recording location and acceptance information."
- The claimed selection is functional ("according to the expectation value"), which invites an argument that any threshold/rank rule reads on it; conversely, an accused infringer may argue the claim requires a literal probability computation. Either way, this affects breadth, not patentability.
- Secondary considerations (commercial success, long-felt need, industry praise) are not evidenced here; the "long-felt need" narrative is, if anything, undermined by the patent's own statement that the problem was known. No nexus evidence is in the record I can see.
- Prosecution history estoppel / amendments between US20130298150A1 (claims 13–21, "location tendency values" independent claim) and the granted claims 1–11 may narrow what the applicant argued, and may also reveal the examiner's own cited art. This must be checked before finalizing any opinion.
9. Bottom line
On the record available, claims 1–11 of US 8,874,474 are more likely than not invalid under § 103 as obvious over JP 2002-374514 (PL1) in view of JP 2008-217831 (PL2) and the state of the art in history-based user-response prediction, with the strongest articulated rationale being (i) the applicant's own admission that distance-only selection was the known problem, (ii) the explicit incentive to notify only willing accepters, (iii) PL2's teaching of evaluating candidates before notification, and (iv) the predictability of gating PL1's notification pipeline with an empirically-derived acceptance probability. Dependent claims 2–8 are obvious refinements (additional predictors, weighting, cross-device user aggregation, and a data-representation choice), and claims 9–11 are obvious statutory-category counterparts.
Confidence: moderate on the framework and on the PL1-based disclosure mapping (built on the applicant's admissions); low on the precise wording of claim 1 and on the actual content of PL1/PL2, both of which I could not verify. Those two verification gaps should be closed — by pulling the granted claim set from the USPTO PatentCenter PDF and obtaining verified translations of JP 2002-374514 and JP 2008-217831 — before this analysis is used for any invalidity contention.
Sources cited: https://patents.google.com/patent/US8874474/en · https://patents.google.com/patent/US8874474#8 · https://patents.justia.com/patent/8874474#5 · https://patents.justia.com/patent/20130298150#5 · https://patentimages.storage.googleapis.com/00/3a/20/3cb285d629c401/US20130298150A1.pdf · https://idiyas.com/patent/badge/8874474
Generated 9/30/2026, 1:31:33 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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- US 8024752I'll search for this specific patent number and any related litigation. US 8,024,752 B2 — Summary Search note: I searched for this exact patent number and for any 2026 Federal Circuit activity tied to it. The patent-number searches…
- US 7013478I'll search for authoritative information on US 7013478. Let me get the claim text and check for any 2026 litigation. US 7,013,478 — Verification and Summary Important caveat up front: I was able to confirm the bibliographic record and…