US 9164718

I'll verify against live sources before summarizing.

Let me pin down the '718 abstract and granted claims text specifically.

Patent Profile — US 9,164,718 B2

Verification posture first (read before relying on anything below)

• The authoritative text I hold for this task is the Google Patents rendering of US9164718B2 (https://patents.google.com/patent/US9164718B2/en). That fetch captured the bibliographic header, classification tree, definitions, and specification — it truncated mid-specification and did not include an "(57) Abstract" block or the granted claim text.
• My live searches for the granted abstract and granted claim language returned the sibling continuation US 10,108,394 B2 (which is a continuation of application 13/103,958 — i.e., of this patent) and the pre-grant publication US 2011/0211226 A1. I therefore could not read '718's own front-page abstract or granted claims directly. Everything below is labeled accordingly. I am not auto-correcting or substituting any identifier.

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Bibliographic summary

Name/address inconsistencies I am flagging rather than "fixing"

• Inventor Christina Ying Liu appears in the Google Patents header. The sibling US 10,108,394 prints the second inventor as "Christine Ying Liu, Fremont, CA" — a one-letter variant. I report both as found. Google Patents also lists Liu's residence as San Francisco, CA in the definitions section, while Justia lists Fremont, CA. These are mirror-vs-mirror discrepancies, not something I should resolve by correction.
• William Ho Chang's residence is listed as Vancouver, WA (Google Patents, Justia) but as Portland, OR in the sibling US 10,108,394. Again, reported as found.

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Abstract

Caveat: this is the abstract of the continuation US 10,108,394 B2, not a text I verified on '718's own front page. US 10,108,394 states on its face that it is a "Continuation of application No. 13/103,958, filed on May 9, 2011, now Pat. No. 9,164,718" — so its abstract is the best available proxy, but it is a proxy. Treat any wording difference as unresolved.

"An output device for providing output service to a mobile information apparatus without requiring a device specific output driver installed at the mobile information apparatus. The wireless output device may include an operating system, a wireless communication unit for radio frequency communication, a display screen, and a user interface over the display screen, the output device may include features for installing one or more application software at the output device for expanding the capabilities of the output device, registering the output device with a control point over a network and providing an identification of the output device for enabling one or more mobile information apparatuses to transmit output data to the output device. Subsequent to registering the output device and providing the identification information of the output device, the output device receives output data associated with the identification information from the mobile information apparatus for rendering."

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Plain-language overview of the independent claims

Important framing caveat. The previously generated section of this analysis characterized the independent claims as 1, 8, and 13 — but sourced that from the pre-grant publication 2011/0211226, with the express caveat that granted-claim amendments were not verified. I could not retrieve the granted claim set in this task. So the overview below is provisional, and I want to flag one live tension rather than paper over it:

• The previously generated section described claim 1 as a wireless output device claim reciting a restricted RF channel established after authentication, and claim 13 as an external output controller claim (distinct from the output device, with its own OS, self-updatable features, etc.).
• The sibling abstract actually retrieved here emphasizes operating system + control-point registration + identification provision + installable application software + subsequent receipt of output data. That cluster maps most naturally onto an output-device claim of the kind described as claim 1, and it does not describe an "external output controller distinct from the output device." Whether the granted '718 claim 13 is the external-controller claim or something else is unresolved on my record.

Provisional plain-language reading (uncertain — verify against the granted claims)

Independent claim 1 — the output device itself (apparatus).
A wireless output device (printer/display/audio-type) that can serve a nearby mobile device without that mobile device having a device-specific output driver installed. The device has its own controller, processor, memory/storage, a wireless (radio-frequency) communication unit, a display screen, and a user interface on that screen. It can have application software installed on it to expand its own capabilities. It registers itself with a control point over a network and supplies identification information so mobile devices can find and send output data to it. After registration/identification, it receives output data keyed to that identification and renders it. (Per the earlier section, the claim may additionally recite a restricted RF channel opened after authentication.)

Independent claim 8 — the method (output at the device).
The method counterpart: the output device performs output management (storing, queuing, and/or spooling the job), delivers processed output data to its marking/display engine, and provides a status indicator on the device's own display screen — again with the result that the sending information apparatus needs no device-specific driver.

Independent claim 13 — [UNRESOLVED] apparatus for an output controller.
Per the previously generated section, this is an external output controller that is distinct from both the output device and the mobile apparatus, with a processor, at least part of an operating system, a display screen, and a user interface, and configured to (a) install software components to update its own features, (b) register the associated output device with a control point, (c) provide security/authentication information, (d) provide device-dependent attributes including device identification, (e) conform received output data to a format the output device accepts, and (f) deliver the processed data to the output device. I could not independently confirm that this is claim 13 of the granted '718, or indeed that '718 has an external-output-controller independent claim at all.

Dependent claims. The earlier section lists dependents 3, 9, 10, 11, 12, 14 (and 9–12 depending from claim 8), covering: simultaneous multi-apparatus use (cl. 3), authentication/security (cl. 9–10), registration with a control point (cl. 11), the device being a printing device (cl. 12), and a further configuration of the external controller (cl. 14). Same verification caveat.

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Litigation / appellate docket check — specific to 9,164,718

A. CAFC 2026 dockets: no result for this patent.
I searched specifically for "9,164,718" and for the patent string in combination with Federal Circuit / CAFC / 2026 terms. The only Federal Circuit-related 2026 hit returned was Finnegan's "Federal Circuit PTAB Appeal Statistics for June and July 2026" (a statistical article — http://www.finnegan.com/print/content/438970/...) and the U.S. Courts Table 3.1 appellate-caseload report. Neither names US 9,164,718, and neither is a docket entry for this patent. I found no Federal Circuit appeal — 2026 or otherwise — captioned to or naming 9,164,718.

B. This is consistent with the rest of the record. As developed in the previously generated Litigation and PTAB sections of this analysis: no district-court assertion of '718 was found, and zero AIA trial proceedings (no IPR/PGR/CBM) name '718 as the challenged patent. The Google Patents "Family has litigation" flag is family-level, not patent-level. A patent that (i) has never been challenged at the PTAB, (ii) has never been asserted in an identified suit, and (iii) went expired-fee-related on 2021-11-01, has no obvious path to a 2026 Federal Circuit appeal. The negative finding is consistent across the record.

C. Where '718 does appear — as prior art, not as a party. Two search artifacts surfaced, and they are worth recording because they show '718 being used against other filings:

• A PTAB petition exhibit (ptacts.uspto.gov/ptacts/public-informations/petitions/1549382/...) contains the examiner search string "9110622".pn. OR "9164718".pn., logged 2015/11/16 — i.e., '718 was searched as art against a different application. Note carefully: "9110622".pn. is US 9,110,622, a different patent number — this is exactly the kind of near-miss the instruction warns about, and I am not conflating the two.
• US 12,009,940 (Telefonaktiebolaget LM Ericsson) lists "9164718 | October 20, 2015 | Chang et al." in its "Referenced Cited" table — confirming the patent number, the issue date, and the Chang et al. inventorship independently.

D. Do not rely on the negative as a clearance. Absence from the sources I searched is not proof the patent was never mentioned in a 2026 filing. A definitive check requires a patent-number query in PACER / Lex Machina / Darts-ip and the CAFC's own docket (appeal search by patent number), which I could not run here.

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Consolidated uncertainty statement

To close the two real gaps, pull (1) the '718 grant PDF front page for the verified abstract and "(56)" citation block, and (2) the granted claim set from Patent Public Search or Patent Center for application 13/103,958 — and, for the docket question, query the Federal Circuit's docket by patent number directly rather than by case name.

I'll research litigation involving US patent 9164718 specifically. Let me run several searches across litigation-focused sources.

Let me dig deeper into Flexiworld's enforcement campaigns and any case specifically listing the '718 patent.

Litigation Search: U.S. Patent No. 9,164,718

Bottom line

I found no litigation that asserts U.S. Patent No. 9,164,718 as a patent-in-suit. I searched litigation-oriented sources (Unified Patents litigation portal, Google Patents' litigation/family flags, PACER-derived dockets on Justia, UniCourt, Docket Alarm, PatSnap litigation summaries, RPX Insight, and PTAB filings that list related district-court cases). Nothing returned a case in which "9,164,718" appears as an asserted patent. Searches that surfaced the string "9164718" returned only PTAB prior-art search logs, not litigation.

Because my tool budget was exhausted mid-research, this is a negative finding based on the searches actually run, not a certified national clearance. See caveats below.

What the record shows about the '718 patent itself

Per the Google Patents record for US9164718B2:

• Application: US 13/103,958, filed 2011-05-09
• Granted: 2015-10-20; priority date 2000-11-01
• Inventors: William Ho Chang; Christina Ying Liu
• Original assignee / current assignee: Samsung Electronics Co., Ltd. (reassignment to Samsung recorded 2013-03-13, from Flexiworld Technologies, Inc.)
• Status: Expired – Fee Related; anticipated expiration 2021-11-01
• Marker: "Family has litigation" with a Darts-ip family link (family=22925285)

Material point on ownership — the '958 application was among the rights assigned to Samsung

The '718 patent issued from application 13/103,958, i.e., the "'958 Application" referenced in the Samsung/Flexiworld agreement litigated in Flexiworld Techs. v. Roku, Inc. (W.D. Wash.). In that decision, the court held that the Samsung Agreement assigned "four items (the '541 Patent, the '958 Application, a continuation application, and a second continuation application)" and rejected Roku's argument that the agreement swept in additional Flexiworld patents (the '064 and '066 patents).

Taking that finding literally: the application that matured into the '718 patent was one of the four assigned items, which is consistent with the Google Patents assignment record naming Samsung as assignee. This is inference, not a holding about the '718 patent, but it explains why an NPE enforcement campaign by Flexiworld would not ordinarily include '718 — Flexiworld would face a standing problem, and Samsung (a frequent defendant, not plaintiff, in this portfolio space) has no obvious enforcement history here.

Litigation in the Flexiworld output/wireless-printing family (NOT the '718 patent)

These are expressly related-but-distinct matters; none of the sources I reviewed identified '718 as asserted:

I could not verify the specific patent lists in TCL, Amazon, or the 2025 E.D. Tex. case (2:25-cv-00960), so I cannot affirmatively exclude '718 from any of them.

Caveats you should carry forward

1. No affirmative evidence either way. Absence from the sources searched is not proof that the patent has never been asserted — only that no such assertion surfaced.
2. The "Family has litigation" flag is family-level, not patent-level. The Darts-ip link (https://patents.darts-ip.com/?family=22925285) signals that some member of the family has been in litigation; it does not identify '718 as the asserted member.
3. Do not conflate similar numbers. I excluded unrelated hits, e.g., AstraZeneca Pharms. LP v. Becerra, 2021 WL 9164718 (a Westlaw citation number, not the patent), and various unrelated 9,164,7xx-type strings.
4. A definitive answer requires a verified PACER/Lex Machina or Darts-ip patent-level litigation query on "9,164,718," plus a check of Samsung's own assertion history. I was unable to complete that verification within the available search steps.

Conclusion: On the information gathered, no known litigation specifically asserting U.S. Patent No. 9,164,718. The patent appears to be Samsung-owned (assignment from Flexiworld recorded 2013), now expired for fee reasons (anticipated 2021-11-01), which further reduces the likelihood of any pending assertion.

I'll verify against public sources before reporting. Let me run parallel searches.

Found adjacent Flexiworld-family litigation but nothing yet on '718 itself. Let me drill down.

Let me check PTAB dockets and litigation directly for '718.

Proceedings overview

Total AIA trial proceedings on file for US 9,164,718: 0 — no IPRs, no PGRs, no CBMs. Breakdown by status: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denials. Per the structured USPTO Open Data Portal block, the ODP API returns no AIA trial proceedings for this patent, and independent web searching surfaced none either. The bottom line for a defendant: the patent has never been tested at the PTAB. That cuts both ways — there are no canceled claims you can point to, but there is also no petitioner, no § 315(e)(2) estoppel, and no hardened claim set. The full claim set is live, unadjudicated, and generally available to be asserted against you.

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No proceedings to report

I will not manufacture proceeding numbers to fill this section. There is nothing to list under ### {PROCEEDING_NUMBER} because no such proceeding exists. What follows is what I could verify, including the adjacent record that matters strategically.

Verification performed

• USPTO ODP (canonical, per the structured block): no AIA trial proceedings indexed for US 9,164,718.
• Web searches run: US9164718 IPR Samsung Flexiworld; "9,164,718" PTAB petition; "IPR" "9,164,718" Flexiworld Samsung; Flexiworld Technologies patent 9164718 lawsuit defendants; docketalarm PTAB "9,164,718". None returned an IPR/PGR/CBM docket number naming '718 as the challenged patent.
• Caveat I cannot close: the ODP "AIA trial proceedings" field does not cover ex parte reexamination or inter partes reexamination (pre-AIA). I found no reexam certificate or reexam request for '718 in searching, but I cannot rule one out from the sources available to me. If you need certainty on that narrow point, pull the '718 file wrapper directly from USPTO Patent Center and check the "Reexamination" and "Post-Grant" tabs.

The patent itself (verified context)

Source: patents.google.com/patent/US9164718B2/en.

A defendant-relevant ownership wrinkle. The '718 patent is a Flexiworld-family Chang/Liu patent, but the Google Patents assignee field shows Samsung. The '718 patent appears in a patent list attached to the Flexiworld Technologies, Inc. v. Roku, Inc., No. 6:20-cv-00819-ADA (W.D. Tex.) complaint, i.e., it was at least at one point part of the asserted Flexiworld portfolio. Whether Flexiworld or Samsung owns the enforceable right is genuinely contested ground in that family: in Flexiworld Techs. v. Roku Inc. the court construed the 2013 Samsung assignment agreement and held that it assigned only four identified items (the '541 patent, the '958 application, a continuation application, and a second continuation application) and that the '064 and '066 patents were not assigned to Samsung. Because '718 arose from application 13/103,958 and shows Samsung as record assignee, a standing/ownership challenge on '718 is worth running early if you are served — but do not assume the answer; the Roku holding addressed different patents and turned on Washington contract law and extrinsic evidence (letter of intent, Samsung's post-agreement silence).

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Strategic summary

Claim status: everything is UNTESTED. No claim of '718 has been canceled, confirmed, or even construed by the PTAB. There is no surviving-claims list to give you, because there has never been a narrowing event. Contrast that with the sibling patents in this family, which have been through the meat grinder and where the PTAB record is genuinely useful to a defendant:

Sources: IPR2022-01267 joint motion to terminate; Lexmark petition on the '233 patent, PTAB petition 1553926; Flexiworld/Roku W.D. Tex. status report (PTAB petition 1549802).

Estoppel landscape: clean. § 315(e)(2) estoppel is petitioner-specific and patent-specific. Because no one has petitioned on '718, no prior-art ground against '718 is estopped — not against you, and not against anyone else. There is no "prior petitioner already burned this reference" problem. Roku's and Lexmark's settlements do not estop you on '718, and their prior IPRs on sibling patents (which do generate estoppel as to those patents) are irrelevant to '718. Conversely, the absence of any prior petitioner means you get the full run of § 102/§ 103 art, including art that a prior petitioner might have used. The obvious starting points are the references already deployed against the family — Keeney (US 6,748,471) and Vatland (US 6,091,507) — plus the standard pre-2001 wireless/LAN printing and page-description-language art. Note that '718 claims priority to 2000-11-01, so the critical date is early and the art pool is deep.

Pattern signals. Flexiworld is an active, serial assertor — it has sued Roku (multiple W.D. Tex. cases starting 6:20-cv-00819 and 6:21-cv-00680), Amazon, Lexmark (E.D. Ky. 5:22-cv-00110 and related), Hisense, LG (E.D. Tex. 2:25-cv-00960), Kyocera (N.D. Tex. 3:26-cv-02381), and TCL (E.D. Tex. 2:26-cv-00229, filed 2026-03-20), among others. That means it is accustomed to PTAB defense and to settling mid-IPR rather than litigating to an FWD. No defensive aggregator is apparent in this chain — I found no Unified Patents, RPX, or similar petitioner on '718 or its siblings; the challengers are all operating-company defendants (Roku, Lexmark). And no Federal Circuit appeal involving '718 exists that I could locate, for the simple reason that there is no PTAB decision to appeal.

One forward-looking warning. The 2025 PTAB environment is materially less petitioner-friendly than when the Flexiworld siblings were challenged. Per Unified Patents' 2025 in Review, the PTAB issued a record-high 607 procedural denials in 2025, and Director Squires now issues institution decisions personally; proposed October 2025 rules would (i) require IPR petitioners to abandon all § 102/§ 103 defenses in other forums, (ii) mandate denial if any claim was previously upheld by the USPTO, ITC, or a court, and (iii) mandate denial where a parallel proceeding is set to resolve validity first. None of (i)–(iii) bites on a first challenge to a never-upheld patent like '718, so a petition filed today is not obviously impaired — but budget for a discretionary-denial fight.

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Recommended next steps

1. Confirm the negative before you rely on it. Re-run the Darts-IP family link in the Google Patents record and pull the '718 file wrapper from Patent Center to check for any ex parte/inter partes reexamination or reissue that would not show up in the ODP AIA-trial field. Everything in this report assumes that field is complete.

2. If you are served on '718, move immediately on two fronts. (a) Standing/ownership: demand the assignment chain establishing who owns the right to enforce '718 after the 2013 Samsung agreement. The Roku decision is your template — it shows a court is willing to read that agreement narrowly, and Samsung's ten years of silence during Flexiworld's prosecution was treated as probative. (b) § 315(b) clock: the one-year IPR bar runs from service of the complaint. If you intend to petition, calendar it the day you are served.

3. If you petition, the statutory milestones are: institution decision within 6 months of the petition's filing date (§ 314(b)); final written decision within 12 months of institution, extendable to 18 months for good cause (§ 316(a)(11)). Given (2)(a) above, consider filing the IPR with a motion to dismiss or a standing challenge in the district court rather than choosing one forum — the two theories are complementary, not duplicative.

4. Art strategy. Build the petition around the family's proven references — Keeney (US 6,748,471) and Vatland (US 6,091,507), both deployed against '233, plus the PGR2021-00112 § 112 written-description/Rivera theory if '718 has a conflation-type claim. Confirm the '718 claim set chapter-and-verse against the '233 mapping, since the two patents share a common specification.

5. Do not over-read the absence of IPRs. This is a 2015-issued, roughly-21-year-old priority patent that is now Expired – Fee Related. That fact, more than any PTAB statistic, explains the empty docket: nobody bothers to IPR a patent whose term has already run unless there are meaningful back damages on the table. If you received a demand letter, ask early what pre-expiration damages period is actually implicated — that number, not the claim-safety question, may drive the whole defense.

Confidence note: the count of zero AIA proceedings is grounded in the structured ODP block and corroborated by searches. The adjacent-family litigation and IPR facts above are sourced to the linked documents. The ownership analysis is not a legal conclusion about '718 — the Roku holding addressed other patents, and I have not seen a court construe '718's ownership.

I'll reconstruct the assignment record for US 9164718, starting with the primary sources.

Key leads surfacing. Let me dig into the assignment records and the Flexiworld litigation history.

Assignment & Ownership Reconstruction — US 9,164,718 B2

Patent: US 9,164,718 B2, "Output device and method for output without an output driver"
Application: 13/103,958 (filed 2011-05-09; published as US 2011/0211226 A1 on 2011-09-01; granted 2015-10-20)
Priority date: 2000-11-01 · Status: Expired – Fee Related (anticipated expiration 2021-11-01)

Retrieval note (read first). I could not directly query the USPTO Assignment Center / Patent Assignment Search (assignmentcenter.uspto.gov), because the search application is not reachable by the tools available to me. The assignment events below are taken from (a) the Google Patents legal-events record for this specific patent (the authoritative text supplied for this task), and (b) court and PTAB filings that reproduce the recorded assignment instruments and reel/frame numbers. The Google Patents legal events for US 9,164,718 do not display reel/frame numbers, and I did not obtain the reel/frame for the two assignments on this patent's chain. I am therefore leaving reel/frame marked "not confirmed" rather than guessing. The corroborating documents the reader should pull from Assignment Center to fill that field are named in each entry.

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Inventors

Unusual-pattern check — the classic "all inventors bolted within 12 months" tell is ABSENT. Both inventors were principals of the assignee company (Chang was the founder/president; Liu a shareholder), and both continued filing continuation applications in this family for roughly a decade after the 2013 Samsung transfer. The relevant anomaly here is the inverse of the usual one: the inventors never left the original assignee, but the application left the company.

Priority structure: The '958 application is a continuation in the Flexiworld family claiming earliest priority 2000-11-01. The same 2013 transaction that moved this application also moved US 7,941,541 (the "Assigned Patent") and two continuation applications, and the Samsung agreement's scope was later litigated — see below.

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Original assignee

Two different answers are defensible depending on which field you read, and the distinction matters:

1. Owner at filing / true original assignee: Flexiworld Technologies, Inc. (Vancouver, WA — Washington corporation). Recorded assignment from Chang and Liu to Flexiworld, recorded 2011-05-10, the day after the application was filed.

   • Primary line of business: R&D of short-range wireless (Bluetooth/Wi-Fi, 802.11) pervasive-output software and embedded solutions for mobile devices — self-described in its complaints as a developer of "wireless applications and embedded solutions," not a hardware manufacturer.
   • Did it ship a product embodying the claims? No documented one. In the Lexmark litigation Flexiworld pleaded that it "has not made, offered for sale, sold, or imported a product that practices any of the Patents-in-Suit or that would otherwise require marking." That is a § 287(a) admission of non-practice.
   • Current status: Operating, as a licensing/assertion business — not dissolved, not in bankruptcy, no acquisition located. Its principal place of business is pleaded as "2716 SE 169th Ave Q147, Vancouver, WA," a residential-style unit address (relevant only as context — see signal 1). It was still an active plaintiff as of 2025 (Flexiworld Techs. v. Roku-adjacent filings; e.g. E.D. Tex. 2:25-cv-00960). Stanford's NPE Litigation Database lists Flexiworld as a Non-Practicing Entity (Flexiworld Techs. v. Hisense, 2:22-cv-00225).
   • Caution: Flexiworld did not keep this patent. It divested the '958 application in 2013.

2. Entity named on the issued patent (71/73 assignee of record): Samsung Electronics Co., Ltd. Google Patents shows both "Original Assignee" and "Current Assignee" as Samsung Electronics Co Ltd, because the application was assigned to Samsung before it issued. Samsung is a public operating company (KOSPI: 005930) that ships printers, mobile devices, TVs and displays in the relevant field; it is not an NPE.

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Assignment timeline

Two recorded transfers, both Assignment-type. No security agreements, mergers, name changes, or releases appear anywhere on this patent's chain, and no assignment post-dates 2013.

• Executed ~2011-05-09 / recorded 2011-05-10 — Reel not confirmed (fetch from Assignment Center; the instrument is the Chang/Liu → Flexiworld assignment of the '958 application)

  • Conveyance: Assignment
  • Assignor: William Ho Chang; Christina Ying Liu (individually, as inventors)
  • Assignee: Flexiworld Technologies, Inc.
  • Correspondent: not retrieved. Flag: I could not confirm the recording correspondent on any Flexiworld inventor assignment. The recurring litigation/PTAB firm for Flexiworld — Nelson Bumgardner Albritton / Nelson Bumgardner Conroy P.C., Fort Worth, TX (attorneys Brent N. Bumgardner, Reg. No. 48,476; C. Austin Ginnings, Reg. No. 62,706) — is not evidence of the assignment-recordation correspondent, and I am not treating it as such.
  • Context: Founder/inventor-to-company assignment at the moment of filing — normal startup capture of employee/founder inventions, not an arm's-length acquisition.

• Executed not stated in the record consulted / recorded 2013-03-13 — Reel not confirmed (this is the "Samsung Agreement" assignment, produced in discovery in W.D. Tex. 6:20-cv-00819-ADA at ECF No. 56-3 and discussed in the court's 2022-06-06 order)

  • Conveyance: Assignment
  • Assignor: Flexiworld Technologies, Inc.
  • Assignee: Samsung Electronics Co., Ltd.
  • Correspondent: not retrieved.
  • Context: Outbound portfolio sale / asset divestiture to a large operating company. Per the agreement, § 1.1.1 "Assigned Patent Rights" comprised exactly four items: US 7,941,541, US Patent Application 13/103,958 (this patent), one continuation application, and one second continuation application. Flexiworld's letter of intent had identified only the '541 patent and the pending '958 application.

Post-2013: no further recorded assignments. Samsung prosecuted the family forward (e.g. US 10,108,394 B2, granted 2018-10-23, and US 2016/0011836 A1 both list Samsung Electronics Co., Ltd.), then allowed this patent to lapse for non-payment of maintenance fees (status: Expired – Fee Related; anticipated expiration 2021-11-01).

Scope dispute worth noting (standing): In Flexiworld Techs., Inc. v. Roku, Inc., No. 6:20-cv-00819-ADA (W.D. Tex.), Doc. 198 (June 6, 2022), the court construed the 2013 Samsung agreement and held it assigned only the four enumerated items and did not reach the '064/'066 patents, which stayed with Flexiworld. For this patent the outcome is the opposite of the disputed ones: the '958 application was one of the four items expressly assigned, so Samsung's title is the one the record supports. Related PTAB matters (IPR2021-00714, IPR2022-01269, PGR2021-00112) involve other Flexiworld patents, not the '718.

Portfolio context for the correspondent question

I could not establish a repeat assignment-recordation correspondent for the chain. For completeness, the reel/frames that flexiworld cites for its other Chang/Liu assignments (different patents — listed only to show the pattern, and to give Assignment Center search targets) are: 012325/0362 ('233), 028733/0064 ('402), 029112/0430 ('000 and '181), 029983/0989 ('576), 039816/0200 ('596), 042385/0202 ('178, '071, '072), 043035/0229 ('073), 043675/0451 ('847), 044174/0659 ('846). All are inventor→Flexiworld recordings; none is this patent.

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Timeline diagram

timeline
    title Ownership of US 9164718
    2000 : Earliest priority date
    2011 : Filed by Flexiworld Technologies
         : Inventors assign rights to Flexiworld
    2013 : Assigned to Samsung Electronics
    2015 : Patent issues to Samsung
    2021 : Patent lapses for fee non payment

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NPE / troll-pattern signals

1. Shell-entity transfer — NOT PRESENT (for this patent).
There is no "IP Holdings / Licensing / Ventures" LLC anywhere in the chain. The single transfer of this patent ran from an inventor-founded R&D/assertion company to Samsung Electronics, a large public operating company — the reverse of the classic operating-company→shell pattern. Observation, not a finding: Flexiworld's pleaded principal place of business (2716 SE 169th Ave Q147, Vancouver, WA) is a residential-style unit and Flexiworld does not practise the patents, but I have found no recorded assignment to a Delaware/Texas single-member shell for this patent, so the tell is not met.

2. Known asserter in the chain — PRESENT, but limited to the prior assignee.
Flexiworld Technologies, Inc. is not one of the classic enumerated names (Acacia, Marathon, IV, IPNav, Wi-LAN/Mosaid-Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Spangenberg), but it is publicly classified as a non-practicing entity by Stanford's NPE Litigation Database (Flexiworld v. Hisense, 2:22-cv-00225) and is a high-volume plaintiff that has sued Roku, Amazon, Canon, Epson, Lexmark and Hisense in 2020–2025, which is why it appears in the RPX and Unified Patents litigation portals. Critically, this signal attaches only to the pre-2013 owner. Flexiworld divested the '958 application in 2013 and did not assert US 9,164,718; the current owner, Samsung, is an operating company.

3. Repeat correspondent across the chain — UNCLEAR.
Only one link exists that could recur (inventor→Flexiworld, then Flexiworld→Samsung), and I could not retrieve the correspondent of record for either. I am not inferring recurrence from Flexiworld's litigation/PTAB counsel (Nelson Bumgardner) — a single firm doing assertion work is not an assignment-correspondent finding, and the prompt's own caution applies. This is the single most valuable field to pull manually from Assignment Center.

4. Cascading transfers — NOT PRESENT.
Two transfers total, 2011 and 2013, with ~22 months between them and no further movement. No chained LLCs, no shared registered-agent addresses.

5. Pre-litigation transfer — NOT PRESENT.
The 2013-03-13 transfer precedes the earliest Flexiworld assertion wave (2020) by ~7 years, and I found no infringement suit anywhere asserting US 9,164,718. There is no assignment sitting within 6 months of a suit naming this patent.

6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 proceeding involving Flexiworld or Samsung is reflected anywhere in the chain or in the litigation record. The 2013 transfer was a bargained patent sale documented by a letter of intent, not a bankruptcy disposition.

7. Privateering — NOT PRESENT.
Privateering is an operating company funding an NPE proxy to sue its competitors. Here the polarity is opposite: an NPE-classified company (Flexiworld) sold two assets to the operating company (Samsung). Samsung is the buyer/owner, not the sponsor of an assertion proxy on this patent. (The residual Flexiworld family that Samsung did not buy was later asserted by Flexiworld against Samsung's peers — Roku, Canon, Epson, Lexmark — but that is Flexiworld's own campaign over patents it retained, not a Samsung-funded one, and it does not involve the '718.)

8. Defensive aggregator (anti-NPE) — NOT PRESENT.
The chain does not terminate at RPX, AST, LOT, Unified Patents or OIN. It terminates at Samsung Electronics, an operating company — although note the effectual inversion: Samsung let the patent lapse in 2021, which neutralizes it as an assertion asset but is not a defensive-aggregator outcome.

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Verdict

Operating-company assertion (with an explicit qualification — see below).

The entire recorded chain for US 9,164,718 is inventor→Flexiworld (recorded 2011-05-10) then Flexiworld→Samsung Electronics (recorded 2013-03-13), and it terminates there: the current assignee of record is Samsung Electronics Co., Ltd., a large operating company, and the patent lapsed for fee non-payment in 2021. The high-volume-plaintiff tell in this file belongs to the former owner, and Flexiworld expressly surrendered this application to Samsung in 2013 — which is confirmed by the W.D. Tex. court's June 6, 2022 construction of the Samsung agreement (6:20-cv-00819-ADA, Doc. 198), holding that the pending '958 application was one of the four items assigned.

Qualification, stated plainly: the strict verdict definition requires that the current assignee be suing actual competitors on this patent. I found no infringement action asserting US 9,164,718 by Samsung or anyone else, and Samsung abandoned the patent in 2021. So the accurate description is operating-company ownership without documented assertion — the patent spent its life as Samsung portfolio/defensive material rather than a litigated asset. The "NPE" verdicts do not fit this patent; they fit the sibling patents Flexiworld retained and asserted, which are different US patent numbers.

Verify at: https://assignmentcenter.uspto.gov/ (search patent number 9164718 or application 13/103,958) — the two recordings you should expect to find are the 2011 Chang/Liu→Flexiworld assignment and the 2013 Flexiworld→Samsung assignment; their reel/frame numbers and correspondents are the two fields I could not confirm and that should be filled in manually. Secondary corroboration: https://patents.google.com/patent/US9164718/en (legal events) and https://law.justia.com/cases/federal/district-courts/texas/txwdce/6:2020cv00819/[1107258/198](https://assignmentcenter.uspto.gov/search/patent/reelFrameDetail?reelFrame=1107258-0198)/ (assignment-scope holding).

I'll research the prior-art citations for US 9,164,718 specifically.

Let me pull the specific "References Cited" lists for this patent.

Prior-art review — US 9,164,718 B2 ("Output device and method for output without an output driver")

0. Verification status first (read this before using anything below)

• The authoritative full text supplied for this analysis is the Google Patents rendering at https://patents.google.com/patent/US9164718B2/en. Its "(56) References Cited" block was not present in the retrieved HTML — the fetch captured the classification tree, definitions, and specification, but the front-page citation tables did not come through. I therefore could not read the patent's own citation list from the authoritative source.
• "Search the USPTO database" could not be performed against the USPTO's own system (Patent Public Search / PatentCenter file wrapper) within my available steps. Everything below is reconstructed from third-party mirrors: https://uspto.report/patent/grant/9,164,718, https://patents.justia.com/patent/9164718, and Google Patents family pages. None of these is the source of record for a §102 analysis.
• Consequently, what follows is a citation inventory, not a verified record of examiner-applied art. I did not obtain the PTO-892 notices or the examiner's §102/§103 rejections in application 13/103,958. Absence of a reference below is not evidence it was not cited, and presence is not evidence it was applied.
• Per the operating rule, I have not auto-corrected any number. Where a mirror renders an identifier in truncated form, I say so rather than "fixing" it.

Near-miss identifiers deliberately excluded (similar strings, unrelated subject matter): US 9,174,718 B1 ("Internal toroid balloon," Google LLC); EP 0 916 744 A2 (Sermatech, thermal-spray coatings); AstraZeneca Pharms. LP v. Becerra, 2021 WL 9164718 (a Westlaw cite, not a patent); and a set of unrelated international search reports that merely co-occurred in search results (EP 3 892 310; WO 2014/164895; WO 2017/013493; WO 2018/200874; EP 1 829 984; EP 1 982 969; PCT/ES2022/070220; WO 2021/208344).

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1. The claim frame the §102 analysis has to target

Taking the claim architecture from the previously generated section (independent claims 1, 8, 13; dependent claims 3, 9–12, 14), the §102-relevant elemental clusters are:

Critical date point that governs everything: App. 13/103,958 was filed 2011-05-09 with earliest priority 2000-11-01. References dated after November 1, 2000 are only §102 art if (i) the claims are denied the 2000 priority, or (ii) they qualify under the post-2011 §102 framework. The citation list below contains a very large number of 2001–2005 documents — which strongly suggests a large applicant IDS/background submission rather than a set of examiner-applied §102 references. Treat every post-2000-11-01 entry below as presumptively background, not anticipatory.

Also flagged: several cited items are the inventors' own later family publications (Chang et al.), which share the 2000-11-01 priority and are therefore not prior art to '718 at all. See §4.

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2. Inventory of cited U.S. patent documents (literal, as retrieved)

The retrieved list is a long contiguous ascending run (it begins before 5,987,454 and continues past 6,489,934), consistent with a bulk IDS. I captured the following; month/year and inventor name are as the mirror displays them — exact grant days were not in the source and are not supplied here.

5,987,454–6,499,xxx run (partial capture):

I could not capture the beginning of the list (pre-5,987,454) or the end (post-6,489,934+, which from the Justia page clearly runs into the 7,xxx,xxx range), so the inventory above is partial in both directions.

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3. Cited U.S. pre-grant publications and foreign documents

U.S. pre-grant publications (as retrieved from the Justia citation panel):

Foreign patent documents (rendered literally as they appear in the mirror — note the visible leading-digit truncation, which I am NOT correcting):

CN 1217503 (May 1999) · CN 100334577 (Aug 2007) · CN 1541370 (May 2010) · CN 101833430 (Sep 2010) · CN 101834892 (Sep 2010) · CN 101825996 (May 2012) · EP 738949 (Jun 2002) · EP 952513 (Jan 2004) · EP 691619 (Jul 2007) · GB 2332764 (Nov 2002) · JP 11316658 (Nov 1999) · WO 0195096 (Dec 2001)

⚠️ The EP 738949, EP 952513, EP 691619, JP 11316658, CN 1217503 entries are displayed with their leading digits clipped by the mirror's table formatting. Do not treat those strings as complete publication numbers — I am reporting them exactly as retrieved, per the no-auto-correction rule.

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4. References that are NOT prior art to '718 (must be excluded from any §102 argument)

The overwhelming majority of the pre-grant publications listed in §3 are Chang et al. publications from the same family, sharing the 2000-11-01 priority date — including 2011/0211226, which is the '718 application's own publication. Under §102 these are not "by another," and they share the priority date, so they cannot anticipate or render obvious claims 1/8/13. Any downstream analysis that cites them as prior art is wrong on its face. Similarly, US 10,108,394, US 10,161,?, and the other continuation/divisional siblings surfaced in Google Patents' family tables are family members, not art.

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5. §102 mapping — the subset with arguable relevance

Below I give the references whose subject matter can be meaningfully assessed. Confidence labels are explicit. "Verified" = the identity/date came from the retrieved record. "Recollection" = the subject-matter characterization comes from my training knowledge and was not confirmed in the retrieved sources; treat it as a lead to check, not a finding.

Net assessment. On the record I could actually retrieve, no cited reference is verifiably a §102 anticipation of independent claim 1, 8, or 13. The closest §102-type candidates are (a) a small group of pre-Nov-2000 network-printing and wireless-network patents that can reach the background elements (clusters A/D) but not the distinctive combination of restricted RF channel + authentication at the output device + device-side display/UI + control-point registration + driverless operation (clusters B/C/E/G), and (b) post-2000 documents that are date-disqualified unless the 2000-11-01 priority is defeated — and the 2000 priority is supported by the provisional chain described in the earlier section (60/245,101 via App. 10/016,223, now US 7,941,541).

One concrete lead worth chasing. A PTAB-exhibit examiner search log surfaced during this search contains the query string "9110622".pn. OR "9164718".pn., logged 2015-11-16. That indicates the '718 patent number was being searched as prior art against a different, later application — i.e., '718 is cited as art elsewhere, and the examiner's application of it may be recoverable from that other file wrapper. That is a search-log artifact, not a citation of '718's own prior art, and I could not resolve which application it belongs to.

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6. What is missing, and exactly how to close it

To answer the question to a §102 standard, these specific documents are required and were not available to me:

1. The '718 front page (56) block — obtainable from the grant PDF at https://patentimages.storage.googleapis.com/…US9164718.pdf or from Patent Public Search (ppubs.uspto.gov). This is the only authoritative citation list.
2. The 13/103,958 file wrapper — every PTO-892 "Notice of References Cited" and each Non-Final/Final Office Action, to separate cited from applied art and to see which claims drew §102 rejections. The Notice of Allowance and any Examiner's Interview/Reasons for Allowance will state what the examiner found the art did not teach — typically the most probative document for the "driverless / restricted RF / control point" combination.
3. The parent IDS from App. 10/016,223 (US 7,941,541) — much of the ~hundreds-of-references list in §2 was almost certainly carried forward from the parent, so the parent's examiner-applied art is the better starting point.
4. Family-level IPR records — the Flexiworld/Roku, Lexmark and related IPRs identified in the litigation section asserted sibling patents ('233, '402, '073, '846), not '718; their instituted grounds nonetheless map the same 2000-11-01 priority window and will indicate which pre-2000 references the family's challengers consider strongest. Those petitions are the most efficient proxy for "most relevant prior art" against this specification.

7. Confidence summary

• High: that the citation list is very large and includes a long 1999–2005 U.S.-patent IDS run; that many listed pre-grant publications are the inventors' own same-priority family members and are not prior art; the near-miss identifiers excluded.
• Moderate: the date-qualification framework (2000-11-01 vs. 2011-05-09) and the conclusion that most post-Nov-2000 citations are background rather than applied art.
• Low / unverified: the subject matter of essentially every individual U.S. patent cited (§5 "Unverified" rows), the completeness of the inventory, and the truncation of the foreign-document numbers. I did not verify the issued claims of 9,164,718 itself — the earlier section sourced them from pre-grant publication 2011/0211226, so all claim-number mapping above is provisional and should be re-checked against the granted claims before being relied on.

I'll verify the subject matter of the key references flagged "Unverified" or "Recollection" in the prior-art section before building §103 combinations on them.

Obviousness Analysis — U.S. Patent No. 9,164,718 B2 under 35 U.S.C. § 103

Scaffolding. This builds on the elemental clusters A–G defined in the Prior Art section of this page (A = wireless output device with controller/processor/memory/wireless unit; B = restricted RF channel established over the device's own wireless unit, data received after authentication; C = device-side display screen + UI + status indicator; D = device-side store/queue/spool and multi-apparatus use; E = control-point registration + device identification; F = external/on-board output controller with its own OS, screen, UI, component-install, and data-conformance functions; G = mobile apparatus transmits output data without a device-specific driver installed at the apparatus). I do not repeat the citation inventory here.

Two gating caveats carried forward, not re-litigated:

1. The claim set analyzed is the pre-grant publication US 2011/0211226 A1 rendering (claims 1, 3, 8–14). Per the earlier section, granted-claim amendments were not independently verified. Every mapping below must be re-run against the granted claims before it is relied on in a paper.
2. Per the operating rule, no identifier below has been auto-corrected. Where a mirror/clipped rendering is quoted, it is quoted as retrieved.

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1. The threshold question that dominates the whole § 103 analysis: which priority date?

The '958 application was filed 2011-05-09 claiming earliest priority 2000-11-01 (provisional 60/245,101 via App. 10/016,223, now US 7,941,541). The claims must be presumed entitled to the 2000 date only if the 2000/2001 disclosure supports each recited element. Two consequences:

(a) If the 2000-11-01 priority holds. The field of § 102 art narrows to pre-Nov-2000 documents. On the record retrieved, no cited reference is a verified anticipation of claims 1, 8 or 13, and the § 103 case must be built from a small set of pre-2000 wireless-network, network-printing and rights-management references (Kubler, Stefik, Yacoub, Gase, Van Ryzin/Staples). That is a workable but contested obviousness case — see § 4.

(b) If the 2000-11-01 priority fails for any claim. Under AIA § 102(a)(1)/(a)(2) the effective date becomes the 2011-05-09 filing, and the enormous block of 2001–2011 documents on the face of the patent (the 2008–2013 pre-grant publications, including US 2009/0094457 (Lapstun) and US 2008/0201236 (Field)) becomes available as prior art rather than mere background. This is by far the highest-leverage § 103 theory, for two compounding reasons:

• Prosecution-history estoppel asymmetry works in the challenger's favour. The applicant's own IDS stuffed the record with 2001–2011 art. If priority is denied, that material is fair game with no § 325(d) "previously presented art" problem in the district court, and only a discretionary § 325(d) issue at the PTAB.
• The claim vocabulary itself indicates a later effective date. Claim 11's "control point" and claim 1's "restricted radio-frequency wireless communication channel … after authentication" are not terms that appear in the 2000-era disclosure as generalized claim language in the manner recited; "Control Point" is a term of art specific to the Kubler/Intermec hierarchical-network family discussed below. If the "control point"/"restricted channel" limitations were added by amendment in the 2011 application (13/103,958) or in the intervening continuations, that is a priority defect on the face of the file wrapper. This is the single most valuable thing to pull from Patent Center first (see the Prior Art section, § 6, item 2: every PTO-892 and Office Action, plus any Examiner's Amendment that introduced claim language).

I therefore present the grounds in two tiers: (Tier 1) assume 2000-11-01 holds; (Tier 2) assume it breaks.

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

For this claim set, the POSITA would be a person with a bachelor's degree in electrical engineering or computer science and 2–4 years of experience in network-connected peripheral devices and/or wireless data communication, or equivalent. Critically, this is a systems-integration POSITA, not a specialist in any one field: the 2000-era art already routinely married (i) short-range RF network stacks (Bluetooth/IEEE 802.11/IrDA — all recited in the '718 specification itself, e.g., "IrDA, home RF, Bluetooth, IEEE 802.11, HiperLan2"), (ii) print-server spooling and job management, and (iii) download-and-install of device-side software over a network. The POSITA is therefore presumed to be aware of all three bodies of art simultaneously. That presumption is the load-bearing plank of every combination below.

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3. Graham factors — the differences that actually must be bridged

Net: the '718 claims are a combination of individually known elements with no unexpected result. Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), where elements are "known" and "the improvement is [no] more than the predictable use of prior art elements according to their established functions," the combination is obvious absent a teaching away. I identify no teaching away on this record.

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4. Tier 1 grounds (2000-11-01 priority preserved)

4.1 Ground 1 (primary): Kubler in view of Stefik, further in view of Yacoub

Kubler (US 6,389,010) — Hierarchical Data Collection Network Supporting Packetized Voice Communications Among Wireless Terminals and Telephones — Intermec IP Corp; listed on the '718 face; Unified Patents records grant 2002-05-13, application filed 1998-03-09, earliest priority 1995-10-04. It is § 102(e) art against a 2000-11-01 priority.

Kubler is the closest thing on the record to a one-reference answer on clusters B, E and C, and — tellingly — it supplies the exact vocabulary the '718 claims use. Kubler's specification discloses:

• A spontaneous short-range RF network between a mobile computing device and an output peripheral. "Instead of communicating through the premise LAN, the roaming computing device 20 needing to print: 1) identifies the presence of an available printer, the peripheral device 23; 2) establishes an RF link (binds) with the peripheral device 23; 3) directly begins transferring the bulk data for printing; and 4) lastly, when the roaming terminal finishes the transfer, the spontaneous LAN with the peripheral device 23 terminates." (Kubler family spec, [0112], retrieved via https://www.patentsencyclopedia.com/app/20100118864.) That is cluster A + B (RF link established over the device's own wireless unit) and cluster G in substance — the roaming terminal drives a printer directly with no intervening driver stack.
• A "Control Point" registration architecture. "Once a device has attained synchronization, it must register with the control point to be connected with the NET… The control point will register the device, and provide a short Network Address as an outbound message." ([0293].) That is cluster E nearly verbatim, including the "control point" name used in '718 claim 11.
• An authentication list controlling admission. "Local 16 bit addresses will not be assigned to devices whose global addresses are not on an authentication list maintained in each access point and routinely updated over the infrastructure." ([0292].) Plus encrypted SYNC: "The SYNC field information is optionally encrypted using a block encryption algorithm, with a key provided by the network user." ([0151].) That is cluster B's authentication/restriction element.
• Printers as peripheral-LAN constituents with device-side power management and status. Kubler expressly contemplates the printer as a peripheral-LAN device ([0115]–[0116], [0322]–[0339]), and its peripheral-LAN protocol is "the Access Interval … subset … SYNC transmissions … pending messages … activated … receivers" — i.e., device-side status signalling.

Stefik (US 6,233,971, as listed on the face of the '718 — the ContentGuard usage-rights/repository family; earliest priority Nov. 23, 1994 via App. 08/344,760; see also related US 7,225,160, US 7,765,403, and EP 1 293 871 A3). Identifier flag: the USPTO-mirror listings and the family cross-references render this as both 6,233,971 and 6,236,971 in different documents; I am using the number as listed in the Prior Art section and not correcting it. The subject matter and the 1994–1997 priority are confirmed by the ContentGuard family documents retrieved.

Stefik supplies precisely cluster G's mechanism — download of device-dependent software to the requesting/rendering repository, with a compatibility check and installation, followed by exercise of a print right:

• "In a typical case, the requester repository is a rendering repository and the software would be a new kind or new version of a player. Also in a typical case, the software would be copied to file system of the requester repository before it is installed." (US 7,225,160, 42:27-31; quoted in the '815 IPR petition, Ex. 1007 — https://ptacts.uspto.gov/ptacts/public-informations/petitions/1533784/download-documents.)
• "The requester retrieves the instructions in the compatibility-checking script and follows them. If the software is not compatible with the repository, the installation transaction ends with an error. (This step checks platform compatibility.) … The installation of the software is allowed to proceed." (Id.)
• The Install right is expressly "applied to a new type of player within the rendering repository" (20:48-53), and the purpose of access may be "to print the digital work or obtain a copy of the digital work" (7:19-26).
• Rendering devices include "a printer" (EP 1 293 871 A3, [0017]: "a rendering device (e.g. a printer…)").

Yacoub (US 6,452,692, "Networked printer server", Sept. 17, 2002, as listed) supplies cluster D and the server-side selection/dispatch aspect of E: the server, "not the user," selects the printer, the "job is spooled to the selected printer," and "the server will notify the user of the [status] … through the virtual printer on the client workstation" (https://uspto.report/patent/grant/6452692). Confidence: the title, date and this passage are verified in the retrieved record; the exact § 102(e) filing date is not, so its date-qualification should be confirmed.

Element-by-element map

Result: every element of claims 1, 3, 8–14 has a corresponding disclosure, and the only element not literally shown in Kubler alone (the "conformance/install of a device-dependent component delivered from the output side") is exactly what Stefik teaches.

Motivation to combine (KSR / In re Keller/In re Merck)

1. Same field, same problem, same solution. Both Kubler and Stefik address the same architectural pain point the '718 specification identifies: a mobile/roaming device that cannot be expected to carry the peripheral-specific software needed to use an arbitrary output device. Kubler solves it by binding directly to the peripheral and pushing bulk print data; Stefik solves it by delivering the necessary software to the requesting repository and then exercising a print right. Combining them is not a leap; it is the two halves of one architecture.
2. Articulated, predictable advantage (KSR factor (D)). Kubler's own text explains why a direct device-to-peripheral link is preferred to routing through the premises LAN — "bulk data transfer destined for a peripheral device … might be communicated through the premises LAN, a more direct interconnection proves less intrusive, saves power, and offers a lower cost solution" ([0112]). Appending Stefik's download-and-install step to that link yields the predictable benefit of eliminating per-model client-side driver pre-installation, which is the '718's stated object ("a user need not pre-install a device-dependent printer driver"). No new function is created; the elements perform their established functions.
3. Design incentive and market force (KSR factors (A)–(C)). The '718 specification itself documents the market pressure: "a user may not want to be bothered with looking for a driver or downloading it and installing it just to print out one page of email at the airport." That is a statement of the problem in the patent itself, which is competent evidence of the objective design incentive confronting the POSITA in 2000.
4. Reasonable expectation of success. Both references are in the same technological family (RF data networks + peripheral devices). Kubler already implements an install/registration/authentication handshake (register with control point → receive network address); adding a component download to that handshake is a mechanical extension of an existing, working protocol.
5. Teaching away: none identified. Stefik's "compatibility-checking script" that ends the transaction on failure is a defensive mechanism, not a teaching that device-dependent software should be pre-installed on the client. It teaches toward remote delivery.

4.2 Ground 2: Kubler + Stefik + Gase (claims 3 and 8 only)

Substitute Gase (US 6,185,996) for Yacoub to supply cluster D in explicit "spooling in a networked printing environment" terms. Gase and Yacoub are functionally interchangeable for the store/queue/spool and job-management limitations; use both in the alternative to foreclose a "reference doesn't teach spooling specifically" argument. Confidence caveat: Gase's subject matter was not verified in this session — the prior-art section lists it as "Recollection (low)" and my search returned only unrelated documents. Treat the Gase leg as a lead to confirm from its own face, not as a verified citation.

4.3 Ground 3: Yacoub + Van Ryzin/Staples + Stefik (claim 13-centric, external-controller framing)

For claim 13's "output controller that is an external and distinct device from the output device," a POSITA starting from the networked print-server art (Yacoub: networked printer server; Staples/US 5,889,845 and US 5,764,639, "System and method for providing a remote user with a virtual presence to an office" — verified as a 1995–1996 filing, expressly delivering "access to all the facilities and features of the corporate office PBX and LAN," including remote printer access, to a remote computing device) plus Stefik for the "install/update the controller's own software components" and "conform received output data" limitations, renders claim 13 obvious. The external box is a form-factor choice with a predictable benefit (retrofit of legacy non-networked printers), which is precisely the KSR "obvious to try" and "predictable use" rationale. Confidence: Staples/5,889,845 verified from its own PDF; the "Van Ryzin 6,275,961" number as listed in the Prior Art section was not verified in this session and should be confirmed.

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5. Tier 2 ground (if 2000-11-01 fails): the IDS art becomes the case

If the '958 claims cannot claim 2000-11-01 (see § 1), the effective date is 2011-05-09 and the following become § 102(a)(1)/(a)(2) art — each of which the applicant itself placed on the record:

• US 2009/0094457 A1 (Lapstun et al., Apr. 9, 2009) and US 2008/0201236 A1 (Field et al., Aug. 21, 2008) — the two non-family publications identified in the Prior Art section as the most § 102-relevant. Ground: either, alone or with Kubler, anticipates or renders obvious claims 1/8/13, since a post-2008 mobile-device-driven printer publication necessarily post-dates the Bluetooth/Wi-Fi printing art the '718 specification itself recites as background. Confidence: unverified subject matter — this is a lead requiring the publications' own faces.

Motivation to combine is trivial in Tier 2: when both references are in the same field, on the same record, and both address the same pervasive/driverless printing problem, the "combination" is little more than applying a known technique to a known device ready for improvement (KSR).

Do not overlook the family-art trap in Tier 2. Many of the 2008–2013 pre-grant publications cited on the '718 face are the inventors' own same-family publications (Chang et al.), including 2011/0211226 — the '718 application's own publication. Those are not "by another" and, if priority is preserved, are not prior art at all (Prior Art § 4). If priority breaks, the analysis for those specific documents turns on the AIA § 102(b)(2)(A) inventor-disclosure exception and is materially more complicated. Ground your Tier 2 case on Lapstun, Field and the third-party references, not on the Chang family publications.

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6. Where the § 103 case is weak, and how to shore it up

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7. Grounds at a glance (ranked)

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8. Recommended sequence

1. File wrapper first. Pull the 13/103,958 wrapper: (a) the exact granted claim language, (b) every PTO-892 and Office Action, (c) any Examiner's Amendment introducing "control point"/"restricted"/"authentication," and (d) the 10/016,223 (US 7,941,541) parent IDS and its examiner-applied art. Decide the priority question before drafting anything. Everything above is contingent on it.
2. Kubler as-filed verification. Confirm which Kubler family member's as-filed specification contains [0112], [0292]–[0293], [0151]. This determines whether Ground 1 is a § 102(e) ground or a § 103 ground and what date it carries.
3. Confirm Stefik's U.S. number on the '718 face and pull its PDF for the Install-transaction and compatibility-check passages (columns 20 and 42).
4. Date-qualify Yacoub and Gase; substitute pre-2000 print-server art if either fails.
5. If 2000-11-01 breaks, immediately re-scope to Tier 2 with Lapstun and Field and re-price the damages exposure (the patent is Expired – Fee Related, anticipated 2021-11-01, per the Litigation and PTAB sections — so the asserted past-damages window is what drives the economics, not the claim-safety question).

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9. Confidence disclosure

• High: the § 103 framework and its application to clusters A, C, D and F; that Kubler, as retrieved, discloses (i) a mobile device that "identifies the presence of an available printer," (ii) "establishes an RF link (binds) with the peripheral device," (iii) "directly begins transferring the bulk data for printing," (iv) registration "with the control point," and (v) an "authentication list" — all quoted verbatim from the retrieved family text; that Stefik discloses delivery of device-dependent software to the requesting/rendering repository with a compatibility check and installation, followed by exercise of a print right.
• Moderate: the Tier 1 motivation-to-combine as a whole; Yacoub's date qualification; that no teaching away exists.
• Low / unverified (do not rely on without confirmation): the subject matter of Gase (6,185,996), Sherer (6,449,052), Lapstun (2009/0094457), Field (2008/0201236), Suzuki (2009/0180142) and the clipped foreign numbers; the exact mapping of 6,233,971 vs 6,236,971; whether the Kubler peripheral-LAN print passages appear in the '010 as filed; whether US 6,275,961 (Van Ryzin) is the number corresponding to the virtual-presence art (the verified documents were Staples et al., US 5,889,845 / US 5,764,639); and the granted claim text of 9,164,718.
• Explicitly not asserted: that any ground above is a § 102 anticipation of any claim. On the record retrieved, no single reference anticipates claims 1, 8 or 13; every theory above is a § 103 combination, and the combinations are only as good as the verification steps in § 8.

Near-miss identifiers excluded (unchanged from the Prior Art section): US 9,174,718 B1 ("Internal toroid balloon," Google LLC); EP 0 916 744 A2; and AstraZeneca Pharms. LP v. Becerra, 2021 WL 9164718 (a Westlaw citation, not a patent).