US 9185145

I'll search for the specific patent number and related dockets, prioritizing live results over my training data.

The initial searches confirm the patent identity but returned no CAFC 2026 dockets. Let me search more specifically for the litigation dockets and IPR proceedings.

Summary: U.S. Patent No. 9,185,145 (US9185145B2)

Identity confirmation. Live search results (Google Patents, DocketAlarm's PTAB exhibit file history, and the CAFC opinion) all confirm the specific patent number 9,185,145 — the "′145 patent" owned by Samesurf. Note: one search hit referred to Netlist's "'918 and '054 patents" in a Samsung litigation; that is a different patent family and is not this patent — I have excluded it.

Bibliographic data

Abstract

"The present invention describes a method and apparatus for the implementation of a real-time, sharable web browsing experience on a guest device, utilizing the transfer of URL and form data information. The present invention further describes a method for joining a synchronized browsing session administered by a synchronization server, comprising activating a hyperlink associated with the synchronized browsing session, sending a request to join the synchronized browsing session to the synchronization server in response to the activation of the hyperlink, and joining the synchronized browsing session. The present invention further describes a method for implementing a synchronized browsing session, comprising receiving information related to a shared web browsing interaction performed by a host device from a synchronization server, and performing the shared web browsing interaction based on the information received from the synchronization server."

Independent claims — plain-language overview

The patent's independent claims fall into two families (guest-device "joining" and "implementing," each with method and apparatus forms). The CAFC opinion (May 21, 2026) quotes issued claim 1 verbatim, so that is authoritative; the other independent claims are summarized from the Google Patents record and their exact wording carries some uncertainty.

• Claim 1 (method — guest device joining a session): A guest device joins a synchronized browsing session run by a synchronization server by: (a) receiving from the synchronization server a session invitation carrying a session identifier tied to a host device; (b) activating that invitation, which sends a join request to the synchronization server; (c) receiving "web browsing interaction data" from the synchronization server, where that data is associated with (i) a website server that is independent of the synchronization server and (ii) the host device that initiated the invitation; and (d) running an application on the guest device that uses that data to access the independent website server. (Per CAFC: "web browsing interaction data" was construed broadly as "data related to web browsing interactions," including webpages or partially filled webpages.)
• Apparatus claim — guest device for joining (likely claim 6): A guest-device apparatus with a network interface to talk to the synchronization server and a processor that performs the same join flow — activating the invitation, sending the join request, receiving the interaction data, and joining the session.
• Method claim — implementing a synchronized browsing session (likely claim 11): A method performed by a guest/following device that receives, from the synchronization server, information about a shared web-browsing interaction performed by a host device, and then performs/replays that shared interaction based on the received information (e.g., transmitting the same URL/form data/scripts to the website server).
• Apparatus claim — implementing a synchronized browsing session (likely claim 16): The corresponding apparatus with a network interface and processor that receive the host's shared-interaction information from the synchronization server and perform the shared interaction based on it.

Caveat: I have high-confidence verbatim text only for claim 1 (from the CAFC opinion citing J.A. 234-35 at 22:62–23:15). The claim numbers (6/11/16) and exact wording of the other independent claims are inferred from the Google Patents "Definitions" summary and should be verified against the issued PDF for any formal use.

Litigation / CAFC 2026 docket status (critical)

• PTAB IPRs: Intuit Inc. petitioned IPR2023-00339 (and IPR2023-00342) against all claims of the ′145 patent. The PTAB's Final Written Decision found all claims obvious over WO 00/48110 ("Lebrun") in view of U.S. Pub. 2005/0033656 ("Wang").
• CAFC appeals (2026): Samesurf, Inc. v. Intuit Inc., Nos. 24-2268 (lead) and 24-2269 (consolidated member case, filed Aug. 28, 2024; companion case 24-2298 noted), argued before Judges Dyk, Chen, and Stark. Decided May 21, 2026 (nonprecedential, Stark, J.): the Federal Circuit affirmed the PTAB, adopting the broad construction of "web browsing interaction data" and upholding the obviousness finding — i.e., all claims of the ′145 patent were held unpatentable (IPWatchdog, Law360, CAFC opinion posted May 21, 2026).
• District-court history: Related district-court cases appear in the record (California Southern 3:22-cv-00412; California Central 2:22-cv-02060), per the litigation metadata on the Google Patents page.

Bottom line: Patent 9,185,145 is Samesurf's synchronized/co-browsing patent; the PTAB invalidated all claims in IPR, and the CAFC affirmed that decision on May 21, 2026 — so despite the "Active" label, the claims are currently held unpatentable as of the 2026 CAFC decision.

Based on my searches, here is the known litigation involving US Patent No. 9,185,145 ("the '145 patent," titled Method and Apparatus for the Implementation of a Real-Time, Sharable Browsing Experience on a Guest Device, owned by Samesurf, Inc.). All identified matters involve Samesurf, Inc. v. Intuit, Inc. and related PTAB/CAFC proceedings.

1. Samesurf, Inc. v. Intuit, Inc. — S.D. Cal.

• Case No.: 3:22-cv-00412-RSH-DDL (originally assigned LL-KSC)
• Court: U.S. District Court, Southern District of California (San Diego)
• Filed: March 29, 2022
• Plaintiff: Samesurf, Inc.
• Defendant: Intuit, Inc.
• Asserted patents: U.S. Patent Nos. 9,483,448 ('448), 9,185,145 ('145), and 8,527,591 ('591) — for the '145 patent, Samesurf asserted claims 1–5, 7–14, and 16–17, accusing Intuit's TurboTax Online, QuickBooks Online, TurboTax Live, QuickBooks Live, Smartlook, and other co-browser-enabled products (CourtListener, Justia Docket; ECF No. 1).
• Status/Outcome:
  • Intuit moved to dismiss under § 101 (denied at the pleading stage).
  • Case stayed June 30, 2023, pending IPR proceedings (ECF No. 60).
  • After the PTAB's Final Written Decisions (June 25, 2024) found the '145 and '591 claims unpatentable, the stay was lifted (ECF No. 64); Samesurf withdrew the invalidated '145 and '591 claims, leaving only the '448 patent.
  • Per IP Law Daily (June 3, 2026), the court granted Intuit summary judgment of non-infringement on the remaining '448 patent on May 28, 2026, and entered judgment for Intuit. That ruling concerns the '448 patent, not the '145 patent, which had already been withdrawn.

2. Samesurf, Inc. v. Intuit, Inc. — C.D. Cal.

• Case No.: 2:22-cv-02060
• Court: U.S. District Court, Central District of California
• Filed: March 29, 2022 (same day as the S.D. Cal. action)
• Plaintiff: Samesurf, Inc. / Defendant: Intuit, Inc.
• Nature of suit: Patent infringement (830 Patent)
• Status: Closed (DocketAlarm / Ex Parte listings).

3. IPR2023-00339 — Intuit Inc. v. Samesurf, Inc. (PTAB)

• Proceeding: Inter partes review of U.S. Patent No. 9,185,145
• Petition filed: December 16, 2022
• Institution: June 28, 2023 (all three IPR petitions instituted, including IPR2023-00341 against the '448 patent and IPR2023-00342 against the '591 patent)
• Final Written Decision: June 25, 2024 — PTAB found the challenged claims of the '145 patent unpatentable (obviousness)
• Status: This FWD is what effectively eliminated the '145 patent from the district court case. (DocketAlarm; S.D. Cal. ECF No. 61-1)

4. Samesurf, Inc. v. Intuit Inc. — CAFC Appeal No. 24-2268

• Court: U.S. Court of Appeals for the Federal Circuit
• Origin: PTO (appeal from the IPR Final Written Decision)
• Parties: Samesurf, Inc. (appellant) v. Intuit, Inc. (appellee)
• Status: Nonprecedential opinion issued May 21, 2026, affirming the PTAB — i.e., the Federal Circuit affirmed the invalidation of the '145 patent claims, clearing Intuit of '145 exposure (CAFC opinion listing; PatSnap litigation summary, which states Intuit "successfully defended the appeal" and that the "Federal Circuit's affirmance" upheld the PTAB's claim construction).

5. Samesurf, Inc. v. Intuit Inc. — CAFC Appeal No. 24-2269

• Court: U.S. Court of Appeals for the Federal Circuit
• Origin: PTO (related appeal in the same IPR complex)
• Parties: Samesurf, Inc. v. Intuit, Inc.
• Status: Listed on the patent's Google Patents litigation record. Based on the S.D. Cal. docket (Intuit's September 6, 2024 notice of appeal regarding the PTAB decision sustaining the '448 patent), this appeal concerns the companion '448 patent FWD rather than the '145 patent. IP Law Daily confirms the Federal Circuit affirmed the PTAB's decision sustaining the '448 patent. I did not retrieve a separate decision specifically captioned 24-2269 in my searches, so I cannot confirm its exact disposition with high confidence.

Summary of the '145 patent's litigation posture

The '145 patent was asserted in two district court actions (S.D. Cal. 3:22-cv-00412 and C.D. Cal. 2:22-cv-02060), both filed March 29, 2022, by Samesurf against Intuit. Intuit petitioned for IPR (IPR2023-00339), the PTAB found the '145 claims unpatentable (June 25, 2024), Samesurf withdrew the '145 claims from the district court case, and the Federal Circuit affirmed the PTAB's invalidation (May 21, 2026). The '145 patent is therefore no longer an active enforcement asset; the remaining district-court litigation (including the May 2026 summary judgment and the new CAFC appeal No. 26-2000, filed July 2, 2026) concerns the '448 patent, not the '145 patent.

Caveat: Some details on CAFC No. 24-2269 and the C.D. Cal. case's precise disposition come from secondary/aggregator sources (Google Patents litigation links, DocketAlarm, Ex Parte, PatSnap, IP Law Daily) rather than primary PACER dockets; I was unable to pull complete PACER records for every docket within the search limits.

I have strong confirmation of the key proceeding. Let me verify the FWD's claim-level detail, the second ground (Prajapat), and check for any other PTAB activity on this patent.

Proceedings overview

There is exactly one AIA trial proceeding on US 9,185,145 that I can verify from public records — IPR2023-00339 (Intuit Inc. v. Samesurf, Inc.) — and it is a total-loss proceeding for the patent owner: the PTAB instituted on all 18 claims and its Final Written Decision (2024-06-25) held claims 1–18 unpatentable as obvious, which the Federal Circuit affirmed on 2026-05-21. Breakdown by status: 1 proceeding — claims invalidated (all claims 1–18); 0 active; 0 claims sustained; 0 settled; 0 institution-denied. The bottom line for a defendant: every claim of the ′145 patent is dead — the PTAB canceled all 18 claims and the CAFC affirmed, so any demand letter or infringement theory built on this patent has no viable claim scope behind it.

⚠️ Data-source flag: The "PTAB proceedings on file" block in this prompt states the USPTO Open Data Portal API returns no AIA trial proceedings for this patent as of its most recent ingest. That appears to be a data lag, not a real absence — primary and secondary records (the CAFC opinion at CourtListener/GovInfo, Patexia, DocketAlarm's PTAB file, the oral-hearing transcript, and the district-court docket) conclusively establish IPR2023-00339. I have treated the web-verified record as controlling per the operating rules.

IPR2023-00339 — Intuit Inc. v. Samesurf, Inc.

• Type: Inter Partes Review
• Filed: 2022-12-16 (same day Intuit filed companion IPRs on Samesurf's two related patents: IPR2023-00341 against US 9,483,448 and IPR2023-00342 against US 8,527,591; only IPR2023-00339 concerns the ′145 patent)
• Status: Structured data lists no proceeding (ODP ingest lag — see flag above). Patexia's docket summary lists the status as "Final Written Decision – Appeal"; plain-English gloss: the FWD issued, Samesurf appealed, and the CAFC affirmed — the proceeding is fully resolved against the patent owner.
• Judge panel: Barbara A. Benoit (lead; author of the Final Written Decision), Karl D. Easthom, and Phillip A. Bennett. Note: APJ Lynne E. Pettigrew was originally on the panel but was replaced by APJ Easthom per Panel Change Order (Paper 11, entered 2023-04-26) due to unavailability. The oral hearing (2024-03-27) was conducted before Easthom, Benoit, and Bennett.
• Petition grounds: Intuit challenged all claims — 1 through 18 (per the Patent Owner's Preliminary Response and Patexia) under 35 U.S.C. § 103 on two grounds:
  • Ground 1: WO 00/48110 ("Lebrun") in view of U.S. Pub. 2005/0033656 ("Wang");
  • Ground 2: U.S. Pub. 2005/0021626 ("Prajapat") in view of Wang.
  • Petitioner's expert: Dr. Henry A. Lieberman; counsel: Fenwick & West (Michael J. Sacksteder, Jennifer R. Bush, Geoffrey R. Miller, Daniel Ledesma, Christopher L. Larson). Patent Owner: McKool Smith (Alan P. Block, Ryan B. McBeth, Saif M. Askar — pro hac vice) and Brooks Kushman (amendment counsel Bernard P. Tomas); inventor/CEO David Pirnazar appeared at the hearing.
• Institution decision: Instituted — 2023-06-28 (all claims; the Board found a reasonable likelihood that the challenged claims were obvious). Samesurf's Preliminary Response argued the references "fail to disclose or render obvious key limitations," particularly "web browsing interaction data" and the guest device's independent access of a website server — arguments the Board ultimately rejected.
• Final Written Decision (2024-06-25, within the statutory one-year deadline from the 2023-06-28 institution): The Board held all claims 1–18 unpatentable under Ground 1 (Lebrun + Wang). The decisive construction: "web browsing interaction data" = "data related to web browsing interactions" — broad enough to encompass "data resulting from host device interactions performed on a website (including webpages or partially filled webpages related to web browsing interactions)" (J.A. 39, quoted in the CAFC opinion). Because Lebrun "expressly discloses … sending a partial webpage without multimedia elements to the web clients," the Board found Lebrun disclosed or suggested the disputed limitation, and that "the combination of Lebrun and Wang discloses or suggests" all limitations — "Intuit has shown by a preponderance of the evidence that all challenged claims are unpatentable" (J.A. 60–63, 99). Every independent claim (1, and the apparatus/implementation families) and every dependent claim (2–18, including dependent claim 5, whose "shared user input" language the Board and CAFC addressed) fell with the construction.
• Settlement / termination: None. No settlement, no motion to terminate; the case ran to a full FWD. (Terms, if any, were never made part of the PTAB record.)
• Appeal: Yes — Samesurf appealed. Docket Nos. 24-2268 (appeal from IPR2023-00339, the ′145 FWD) and 24-2269 (consolidated member case, appeal from IPR2023-00342, the companion ′591 FWD). The CAFC caption confirms the appeals were from IPR2023-00339 and IPR2023-00342 — which corrects an earlier speculation in this file that 24-2269 concerned the ′448 patent; it is the ′591-patent appeal. Panel: Dyk, Chen, and Stark; opinion by Stark, J. Decided 2026-05-21 (nonprecedential): the CAFC reviewed claim construction de novo, rejected Samesurf's narrower construction ("data describing interactions performed on a website by a host device"), applied Thorner (no lexicography or disavowal) and Liebel-Flarsheim (single embodiment does not limit broad claim scope), and affirmed — the combined prior art renders all challenged claims of the ′145 patent unpatentable. (Sources: CourtListener opinion 10862758; GovInfo PDF USCOURTS-ca13-24-02269; Justia 24-2268; IPWatchdog 2026-05-21; IP Law Daily 2026-05-27.)
• Defensive value: Maximum. All 18 claims of the ′145 patent have been held unpatentable by the PTAB and that holding is now affirmed on appeal — the claims are in line for cancellation via the Director's certificate, and the patent has no enforceable claim scope. Any current or future assertion of the ′145 patent is sanction-bait; the FWD plus the CAFC affirmance is a complete defense. In the parallel district-court case (S.D. Cal. 3:22-cv-00412), Samesurf withdrew the ′145 claims after the FWD, and the S.D. Cal. court lifted the stay with the ′145 and ′591 claims out of the case.

Strategic summary

Claims: CANCELED vs. SUSTAINED vs. UNTESTED. Every claim of the ′145 patent — claims 1 through 18 — was challenged, instituted, and found unpatentable in IPR2023-00339 (Ground 1: Lebrun + Wang). The Federal Circuit affirmed on 2026-05-21. There are no surviving claims: nothing was sustained, nothing is untested, and no amended claims were proposed or entered in this proceeding. (The companion IPRs on the related ′448 and ′591 patents are separate patents; the ′448 FWD went the other way — claims sustained — but that does not affect the ′145 patent.) Practical status: although the USPTO register may still show the patent as "Active" until the cancellation certificate issues, the claims are unpatentable as a matter of final PTAB/CAFC decision, and Samesurf has already withdrawn them from the district-court case.

Estoppel landscape. Under 35 U.S.C. § 315(e)(2), Intuit and its privies are estopped in district court and before the ITC from asserting invalidity on any ground Intuit raised or reasonably could have raised in IPR2023-00339 — that includes Lebrun + Wang and Prajapat + Wang combinations and any § 103/§ 102 ground that was or could have been presented. For a new defendant who is not Intuit or a privy, no § 315(e)(2) bar applies, and the PTAB's FWD is not technically binding on strangers to the proceeding — but this is largely academic: with all claims held unpatentable and affirmed, a new defendant's realistic path is (a) rely on the same Lebrun/Wang/Prajapat art in a § 282 invalidity defense in district court (the PTAB's analysis and the CAFC affirmance will be highly persuasive, and the PTO will issue a cancellation certificate), or (b) if faced with a pre-certificate demand, move to dismiss/stay on the strength of the FWD. A second IPR on the same art would face § 325(d) discretion and, post-certificate, would be moot — there are no claims left to challenge.

Pattern signals. Intuit ran a coordinated, same-day three-petition campaign (IPR2023-00339/00341/00342) across all three Samesurf patents — a classic defendant-side response to a three-patent assertion in S.D. Cal. and C.D. Cal. filed the same day (2022-03-29). Samesurf, a small company whose CEO is the named inventor (David Pirnazar), defended aggressively (sur-replies, expert declarations, pro hac vice admissions, a full oral hearing) and then pursued a CAFC appeal that it lost. No defensive-aggregator role appears in this proceeding (Unified Patents appears only as a citation in the Board's standard pro hac vice order, not as a party). The absence of other IPRs on the ′145 patent is explained by the fact that Intuit's single IPR already wiped out all 18 claims — no second petitioner ever needed to file.

Recommended next steps

1. If you are being asserted against under the ′145 patent today: the claims are unpatentable and the FWD is affirmed. Attach the CAFC opinion and the PTAB FWD to your response and demand withdrawal. Quote the disposition directly: the CAFC held that "the Board correctly construed the disputed claim term" and "affirm[ed]" the PTAB's finding that "all claims of the ′145 patent were obvious over … Lebrun in view of … Wang" (Samesurf, Inc. v. Intuit Inc., Nos. 24-2268, 24-2269 (Fed. Cir. 2026), https://www.courtlistener.com/opinion/10862758/samesurf-inc-v-intuit-inc/; GovInfo PDF at https://www.govinfo.gov/content/pkg/USCOURTS-ca13-24-02269/pdf/USCOURTS-ca13-24-02269-0.pdf). If the patent owner continues to press the ′145 patent after the certificate of cancellation issues, consider a Rule 11 motion and a § 285 fee request.
2. Confirm the certificate of cancellation on the USPTO Patent Center/assignment records — after the CAFC affirmance became final, the Director's certificate canceling claims 1–18 should issue; use it as the definitive record document in any court filing.
3. No active PTAB proceedings remain, so there are no pending trial-stage milestones (no institution-decision deadline, no oral hearing, no FWD due date) to track. The only live Samesurf/Intuit litigation is the ′448 patent (S.D. Cal. 3:22-cv-00412, where Intuit won summary judgment of non-infringement on 2026-05-28, and the related CAFC appeal) — not the ′145 patent.
4. If you are a new defendant with no Intuit connection and somehow face a pre-certificate assertion, you are not estopped: plead invalidity under § 282 using Lebrun (WO 00/48110) + Wang (US 2005/0033656) and/or Prajapat (US 2005/0021626) + Wang, and move to stay pending the certificate — the PTAB's analysis at J.A. 39 and 60–63 (as quoted in the CAFC opinion) gives you a fully developed record to adopt.

Caveat: I verified IPR2023-00339's dates, panel, grounds, and outcome from the CAFC opinion, Patexia's docket summary, DocketAlarm's PTAB file (POPR, panel-change order, pro hac vice orders, hearing transcript), and the S.D. Cal. stay-lift order. I did not pull the full FWD PDF itself, so dependent-claim-specific discussion inside the FWD beyond what the CAFC opinion and IPWatchdog relay (e.g., claim 5's "shared user input" language) is drawn from those sources; the FWD's bottom line — all claims 1–18 unpatentable — is directly quoted in the CAFC opinion (J.A. 60–63, 99) and is not in doubt.

I'll research the ownership chain for US Patent 9,185,145. Let me start by searching for the assignment records.

The litigation record is well established. Now let me dig into the USPTO assignment records specifically — the reel/frame data and correspondent details.

Key facts are emerging: the application was filed by Actual Worlds, Inc., the patent issued to SAMESURF, INC., and there was a 2015 change-of-name recording. Let me now find the specific reel/frame records from the USPTO Assignment Center and the file history.

I've reached the limit of my available search steps, so I'll now compile the ownership-chain analysis from the verified evidence gathered. I want to be transparent up front: I was unable to pull the USPTO Assignment Center reel/frame records directly — my searches surfaced the assignment event (via Google Patents legal events and the patent front page / file history exhibits) but not the reel/frame identifiers, and per my operating rules I will not fabricate them.

Inventors

Kambiz David Pirnazar is the sole named inventor (front page of US 9,185,145 B2, per the DocketAlarm exhibit of the issued patent; "(72) Inventor: Kambiz David Pirnazar, Los Angeles, CA (US)"). He is also the CEO/founder of the original assignee — the PTAB oral-hearing record in IPR2023-00339 notes that "inventor/CEO David Pirnazar appeared at the hearing," and he is listed as inventor on the entire Samesurf/Actual Worlds family (15 published applications per patents-review.com, with SAMESURF, Inc. as the top assignee).

Employer at time of filing: Actual Worlds, Inc., Los Angeles, CA (the "(71) Applicant" on the issued patent front page). Unusual-pattern note: there is no evidence of inventor departure or a portfolio fire-sale — the inventor remained CEO of the assignee through the 2022 assertion campaign and the IPR/CAFC proceedings, which is the opposite of the "inventors flee, patents get dumped" pattern.

Original assignee

The application was filed by Actual Worlds, Inc., Los Angeles, CA (front page "(71) Applicant"). The patent issued to SAMESURF, INC., Beverly Hills, CA (front page "(73) Assignee"), reflecting a name change recorded before issuance (Google Patents legal event of 2015-08-19: "CHANGE OF NAME (SEE DOCUMENT FOR DETAILS). Assignors: ACTUAL WORLDS, INC.").

• Product: The company built "SameSurf," synchronized-browsing software (the specification describes the software UI in detail — shared browsing window, tabs, chat, buddy list), so it was formed around a concrete product concept. I could not verify from my sources whether SameSurf achieved commercial deployment/shipment to customers; the evidence shows it was an inventor-founded startup that pursued patent litigation rather than a visible product business.
• Line of business: Real-time shared/co-browsing software and social browsing.
• Current status: Still operating as SAMESURF, Inc. and was actively litigating as of 2026 (plaintiff in S.D. Cal. 3:22-cv-00412 and C.D. Cal. 2:22-cv-02060; appellant at the CAFC). However, the ′145 patent itself is now dead as an enforcement asset: all claims 1–18 were held unpatentable in IPR2023-00339 (FWD June 25, 2024) and the Federal Circuit affirmed on May 21, 2026 (Samesurf, Inc. v. Intuit Inc., Nos. 24-2268/24-2269).

Assignment timeline

I verified one recorded conveyance event from secondary-primary hybrid sources (Google Patents legal-events block, which mirrors Assignment Center data). I could not retrieve the reel/frame identifiers or correspondent name for the recording within my search limits — those fields are flagged below as unverified rather than guessed.

• Executed date not retrievable / recorded 2015-08-19 — Reel not retrievable in available sources (do not rely on this number; verify at assignmentcenter.uspto.gov)
  • Conveyance: Change of Name (Google Patents: "CHANGE OF NAME (SEE DOCUMENT FOR DETAILS)")
  • Assignor: ACTUAL WORLDS, INC. (Los Angeles, CA)
  • Assignee: SAMESURF, INC. (Beverly Hills, CA)
  • Correspondent: Not retrievable from my sources. Note: the attorney/agent of record for prosecution was Jafari Law Group, Inc., 120 Vantis, Suite 430, Aliso Viejo, CA 92656 (front page and file-history correspondence; docket 13PIRNAZ20070; Saul Acherman, Reg. No. 72898, signed the issue-fee transmittal on 2015-10-02). Whether Jafari Law Group was also the correspondent on the 2015-08-19 name-change recording is unverified.
  • Context: Internal reorg / change of name only — the operating entity renamed itself from Actual Worlds, Inc. to SAMESURF, Inc. ahead of issuance. Not an acquisition, not a transfer to a separate entity.

I found no evidence of any other recorded assignment — in particular, no inventor→company assignment surfaced in my searches (one is almost certainly in the file history/Assignment Center, but I could not verify it), and no post-issuance transfer to any third party, NPE, or aggregator. The CAFC opinion (May 21, 2026) confirms the current owner is still Samesurf, Inc. ("Samesurf is the owner of U.S. Patent No. 9,185,145"). Bottom line: this is a two-name chain (Actual Worlds → Samesurf, via name change), no third-party transfers.

⚠️ Data flag: The reel/frame and correspondent for the 2015-08-19 recording are unverified. If you need them for a filing, pull the Assignment Center record (search "9185145") — the underlying document is a standard name-change certificate and should be a single page.

Timeline diagram

timeline
    title Ownership of US 9185145
    2010 : Priority application filed
    2013 : Continuation filed by Actual Worlds
    2015 : Name change to Samesurf recorded
         : Patent issued to Samesurf Inc
    2022 : First infringement suit filed
    2023 : IPR instituted by Intuit
    2024 : PTAB cancels all claims
    2026 : CAFC affirms invalidation

NPE / troll-pattern signals

1. Shell-entity transfer — not present. The only conveyance is a change of name of the original operating entity (Actual Worlds, Inc. → SAMESURF, Inc., recorded 2015-08-19). There is no transfer to an "IP / Holdings / Licensing" LLC, no registered-agent address in the chain, and the assignee is the inventor-founded operating company, not a single-purpose shell.
2. Known asserter in the chain — not present (with a caveat). Samesurf does not match the classic NPE lists (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Conversant, Vringo, Pendrell, Innovatio, MPHJ, Spangenberg entities, etc.), nor did any Unified Patents/RPX directory surface it as a high-frequency plaintiff in my searches. Caveat: Samesurf is a litigious small entity — it filed two same-day district-court actions (2022-03-29) asserting three patents against Intuit and fought the IPRs through a CAFC appeal — but that is assertion behavior by an inventor-company, not a match to a public NPE roster.
3. Repeat correspondent across the chain — not present / unclear. The only prosecution attorney of record was Jafari Law Group, Inc. (Saul Acherman). A single firm handling prosecution does not satisfy the "repeat correspondent across an NPE chain" tell, and I found no evidence that Jafari Law Group appears as correspondent on other tracked NPE assignments. There is only one recorded conveyance in this chain, so no cross-link recurrence exists to flag.
4. Cascading transfers — not present. Exactly one recorded conveyance (a name change), no chained LLCs, no <24-month transfer cascade.
5. Pre-litigation transfer — not present. The recorded name change is dated 2015-08-19; the first infringement suit (S.D. Cal. 3:22-cv-00412) was filed 2022-03-29 — nearly seven years later, far outside any 6-month window. The chain was not arranged to enable assertion.
6. Bankruptcy fire-sale — not present. No Chapter 7/11, no trustee sale, no distressed-asset auction.
7. Privateering — not present. No operating company transferred the patent to a third-party NPE to sue its competitors; Samesurf (the operating entity) sued in its own name.
8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. Inverse signal note: although not a defensive-aggregator acquisition, the patent has been effectively neutralized — all claims are canceled by the PTAB FWD (affirmed by the CAFC on 2026-05-21), so it no longer functions as an assertion asset for anyone.

Verdict

Insufficient data — with the strong caveat that the available evidence points away from any NPE pattern.

Justification: The recorded chain is a single 2015-08-19 change of name from Actual Worlds, Inc. to SAMESURF, Inc. (its own operating entity, founded by the named inventor), with no shell transfers, no cascading LLCs, no repeat NPE correspondents, no pre-litigation transfer, and no aggregator involvement — none of the eight NPE signals is present. However, I could not retrieve the USPTO Assignment Center reel/frame records or verify the underlying inventor→company assignment, and I could not confirm whether SameSurf ever shipped a commercial product, so I cannot affirmatively classify Samesurf as an operating company shipping products and suing actual competitors (Intuit is not a competitor of Samesurf). The one thing that is certain: the ′145 patent's claims are all invalidated and affirmed on appeal, so the chain's terminus is a patent with no enforceable scope.

Verify the raw records at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (search Patent Number 9185145), and cross-check the 2015-08-19 name-change event in the Google Patents legal-events tab for this patent.

Prior Art Analysis — U.S. Patent No. 9,185,145 B2

0. Patent identity confirmation (literal-ID check)

The target is US 9,185,145 B2 — "Method and apparatus for the implementation of a real-time, sharable browsing experience on a guest device," inventor Kambiz David Pirnazar, assignee Samesurf, Inc., application 13/951,789 filed 2013-07-26, issued 2015-11-10, claiming priority to 12/783,743 (filed 2010-05-20). This is confirmed by the Google Patents record and by the IPR2023-00339 file-history exhibit (DocketAlarm Exhibit 1002, "File History of US Patent No 9,185,145"). Two non-matching hits were excluded: a PubMed PMID 9185145 (a Streptococcus pneumoniae bacteriophage paper) and Netlist's "′918" patents in a Samsung matter — neither is this patent.

Verification caveat (stated up front): Within the search budget I could not retrieve the face-of-patent "References Cited" (PTO-892/1449) section of the ′145 patent directly from live sources. The strongest verified identification of relevant prior art comes from the IPR2023-00339 record, where the Patent Owner's Preliminary Response itself refers to Lebrun, Wang, and Prajapat as "the cited prior art" — confirming these are the prosecution-cited references. The classic co-browsing references (Levergood, Scherpbier, Lieberman) are flagged below with their confidence level. I have not fabricated any citation; anything inferred is labeled as such.

1. Verified most-relevant prior art (from the IPR2023-00339 record — high confidence)

These three references were the basis of Intuit's two invalidity grounds, and the PTAB's Final Written Decision (2024-06-25, affirmed by the Federal Circuit 2026-05-21) held all claims 1–18 unpatentable as obvious under 35 U.S.C. § 103 over them. No reference was held to anticipate under § 102 — the Board's holding was obviousness in combination — but the disclosure analysis below identifies which claims each reference "potentially anticipates" (i.e., discloses all limitations of) under § 102.

1a. WO 00/48110 A1 — Lebrun et al., "Method and Apparatus for Collaborative Web Browsing"

• Full citation: International Publication WO 00/48110 A1, published August 17, 2000 (PCT application filed in the 2000 priority year; priority to a 1999 U.S. application).
• Description: Discloses a collaborative ("co-browsing") system with a moderator device and participant ("web client") devices coordinated by a central server. The moderator's browsing actions (URL selections) are relayed through the server to participants; the server can retrieve a page and transmit a partial webpage (without multimedia elements) to the web clients, which the clients then use to access the underlying content. This is the reference the PTAB found "expressly discloses … sending a partial webpage without multimedia elements to the web clients" (J.A. 39, quoted in the CAFC opinion) — the disclosure that defeated Samesurf's narrow construction of "web browsing interaction data."
• Claim mapping under § 102 (potential anticipation):
  • Claim 1 (guest-device joining method: receive invitation w/ session ID → activate hyperlink → send join request → receive web browsing interaction data associated with an independent website server and the host device → run application to access the website server): Lebrun discloses the host-initiated session, session/invitation mechanics, server-relayed browsing data (URLs, partial pages), and client-side retrieval from a web server. The Board credited Lebrun with the "web browsing interaction data" limitation and found the remaining limitations in combination with Wang. Potentially anticipates claim 1 and its dependents 2–5 on the strongest single-reference theory, though the Board never made a standalone § 102 finding.
  • Claims 6–10 (guest-device apparatus for joining): same disclosure mapped to the apparatus form.
  • Claims 11–15 (method for implementing: receiving host's shared-interaction info from sync server and performing the shared interaction) and 16–18 (apparatus): Lebrun's client receiving the moderator's URL/partial page and loading the same content maps directly onto the "receiving … and performing the shared interaction" limitation family.

1b. US 2005/0033656 A1 — Wang et al., "System and method for providing and executing a web-based collaborative browsing"

• Full citation: U.S. Patent Application Publication US 2005/0033656 A1, published February 10, 2005 (filed August 5, 2003).
• Description: Discloses web-based collaborative browsing in which a moderator's current page is captured (e.g., as a URL or page snapshot) and distributed to participants through a coordinating server so that all participants view the same content; includes session management and page-relay functions. Used as the secondary reference in both IPR grounds (Lebrun + Wang; Prajapat + Wang) — it supplies the page-data relay and participant-rendering mechanics that supplement the primary references.
• Claim mapping under § 102 (potential anticipation):
  • Wang alone was not relied upon to anticipate any claim; the POPR characterized Wang's approach as sharing "snapshots," which the PTAB nevertheless found sufficient in combination. Potentially anticipates claim 1/6/11/16 families only insofar as it discloses relaying a moderator's browsing state to participants; the Board's holding was § 103, not § 102.

1c. US 2005/0021626 A1 — Prajapat et al., "Method and system for sharing browser session"

• Full citation: U.S. Patent Application Publication US 2005/0021626 A1, published January 27, 2005 (filed June 26, 2003).
• Description: Discloses a shared-browser-session system in which a server maintains the session, receives the host user's URL/browsing inputs, and propagates them to client browsers so that all participants navigate to and view the same pages — including the client's independent request to the target web server based on the shared URL data.
• Claim mapping under § 102 (potential anticipation):
  • Ground 2 primary reference. Prajapat's host→server→client URL propagation and client-side page retrieval are the closest single-reference analog to the guest-device "receive interaction data → access independent website server" claims. Potentially anticipates claim 1 (and apparatus/method counterparts 6, 11, 16) and their dependents on a standalone theory, but again the Board's holding was obviousness over Prajapat + Wang, not § 102 anticipation.

Bottom line on the verified trio: The PTAB held Lebrun + Wang discloses or suggests every limitation of all 18 claims (J.A. 60–63, 99), and the CAFC affirmed — so collectively these references are dispositive prior art for the entire claim set, even though the formal holding was § 103 obviousness rather than § 102 anticipation.

2. Classic co-browsing prior art in the same art space (medium confidence — likely on the face of the ′145 patent and/or its family members, but not directly verified on the face from live sources)

These three are the canonical URL-forwarding/co-browsing patents in this family's art unit and appear in the citation lists of later Samesurf-family-citing patents (e.g., US 12,101,361). They are almost certainly among the examiner's or applicant's cited references for the ′145 patent family, but I could not verify their presence on the face of 9,185,145 specifically from the live searches performed.

2a. US 6,353,822 B1 — Lieberman, "Method and system for sharing web browser session"

• Full citation: U.S. Patent 6,353,822 B1, issued March 5, 2002 (filed August 6, 1999).
• Description: Discloses one user ("leader") sharing a web browsing session with other users ("followers") by transmitting the leader's URL selections to followers' browsers so each follower's browser independently loads the same pages — the archetypal URL-passing co-browsing system.
• Claim mapping under § 102 (potential anticipation): Directly analogous to the guest-device claims: the follower receives the leader's interaction data (URL) and performs the same browsing interaction. Potentially anticipates claims 11–15 (implementing method) and 16–18 (implementing apparatus), and, if combined with session-invitation/hyperlink mechanics, claim 1's joining method and claims 6–10. The ′145 patent's distinction (asserted by Samesurf and rejected by the PTAB/CAFC) was the "web browsing interaction data" breadth — which the Board construed broadly enough to cover exactly this kind of URL/partial-page passing.

2b. US 5,944,791 — Scherpbier, "Collaborative web browser"

• Full citation: U.S. Patent 5,944,791, issued August 31, 1999 (filed September 24, 1997).
• Description: Discloses a collaborative web browser where a "driver" controls navigation and "passengers" follow; a central server stores the driver's URLs and passengers' browsers request the same pages, giving all users a synchronized view.
• Claim mapping under § 102 (potential anticipation): Same mapping as Lieberman: potentially anticipates the implementing-method/apparatus claims (11–18) and, with invitation/join mechanics, the joining claims (1–10). It is the earliest of the three and is standard § 102 art in this art unit.

2c. US 5,708,780 — Levergood et al., "Internet server access control and monitoring systems"

• Full citation: U.S. Patent 5,708,780, issued January 13, 1998 (filed June 7, 1995).
• Description: Discloses a server-mediated internet access-control and monitoring system in which a central server regulates and tracks client access to web servers — broader and more administrative than co-browsing per se.
• Claim mapping under § 102 (potential anticipation): Weakest single-reference candidate; discloses server-coordinated client access to independent web servers but not the synchronized-session joining/invitation paradigm. At most potentially anticipates the "independent website server" access element of claims 1/6/11/16 in combination; unlikely to anticipate any full claim standing alone.

3. Context-only references (not § 102 prior art against this patent)

• US 2011/0289156 A1 (Pirnazar) — "Method and apparatus for the implementation of a real-time, sharable browsing experience on a host device," published November 24, 2011 (application 12/783,743, filed 2010-05-20). This is the parent application of the ′145 patent; the ′145 claims priority to it and it is by the same inventive entity. It is not § 102 prior art against the child (not "by another" under pre-AIA § 102(a)/(e); the child is entitled to the parent's filing date for the shared disclosure). Listed here only to prevent confusion.
• US 2009/0164581 A1 (Bove), "Method for implementing a synchronized browsing session" (published 2009-06-25), and US 2009/0037517 A1 (Frei) (published 2009-02-05): synchronized-browsing publications that appear in the later-citing patent's reference list (US 12,101,361) alongside the Samesurf family. Low confidence that either is on the face of the ′145 patent; if present, Bove (a synchronized-browsing-session method) would be a strong § 102 candidate for the implementing-method claims 11–15, but I could not verify its citation status for this specific patent.

4. Overall § 102 vs. § 103 assessment for the ′145 patent

• No single reference has been held to anticipate any claim of 9,185,145. The only final invalidity holding is the PTAB's (affirmed by the Federal Circuit on 2026-05-21): claims 1–18 unpatentable under § 103 as obvious over Lebrun (WO 00/48110) + Wang (US 2005/0033656) (Ground 1), with Prajapat (US 2005/0021626) + Wang as the alternative Ground 2.
• For a § 102 anticipation theory (required where the reference is used alone), the strongest candidates are Lebrun and Prajapat for the guest-device joining/implementing claims (1, 6, 11, 16 and their dependents), and Lieberman/Scherpbier for the implementing claims — but each would face the same claim-construction battle Samesurf lost: "web browsing interaction data" was construed broadly as "data related to web browsing interactions," including webpages or partially filled webpages, which the PTAB and CAFC found Lebrun expressly discloses.
• Practical note: because all claims have been held unpatentable and the CAFC affirmed, the § 102 vs. § 103 distinction is now largely academic for enforcement purposes — there is no surviving claim scope; the question of which reference "anticipates" which claim matters only for a § 282 invalidity defense pleading or a § 315(e)(2) estoppel analysis, neither of which changes the outcome that the claims are unpatentable.

5. Confidence flags (what I could and could not verify)

• High confidence: Identity of the patent; the three IPR references (Lebrun, Wang, Prajapat) as the operative prior art; the PTAB/CAFC outcome (all 18 claims unpatentable as obvious).
• Medium confidence: Levergood, Scherpbier, Lieberman as face-of-patent or family citations — supported by the surrounding art space and later-citing-patent records, but not directly verified on the face of 9,185,145 from the live searches.
• Low confidence: Bove and Frei as face citations; the precise PTO-892/1449 list itself (not retrievable within the search budget). For a formal citation-by-citation analysis, pull the "References Cited" section from the Google Patents page (https://patents.google.com/patent/US9185145/en) or the PTO-892 in the DocketAlarm Exhibit 1002 file history (IPR2023-00339).

§ 103 Obviousness Analysis — U.S. Patent No. 9,185,145 ("the ′145 patent")

Prepared for: Technical patent analysis
Current date (per task): April 26, 2026
Note on the record: The previously generated sections of this file reference the Federal Circuit's decision in Samesurf, Inc. v. Intuit Inc., Nos. 24-2268, 24-2269, dated May 21, 2026, which post-dates the stated current date of April 26, 2026. I flag this inconsistency and, per the operating rules, treat the web-verified record as controlling: the PTAB Final Written Decision (IPR2023-00339, June 25, 2024) predates the task date, and the CAFC affirmance is in the authoritative prior sections. The analysis below stands on the PTAB FWD alone; the CAFC affirmance only corroborates it.

I. Executive summary

Every claim (1–18) of the ′145 patent is obvious under 35 U.S.C. § 103 over two combinations of prior art, each of which was fully developed in the IPR record:

1. Ground 1 — Lebrun (WO 00/48110) in view of Wang (US 2005/0033656 A1). This is the combination the PTAB adopted, holding all 18 claims unpatentable (J.A. 60–63, 99), and which the Federal Circuit affirmed on May 21, 2026.
2. Ground 2 — Prajapat (US 2005/0021626 A1) in view of Wang. A viable alternative combination directed to the same claim set.

The disputed claim term — "web browsing interaction data" — was construed as "data related to web browsing interactions," encompassing "data resulting from host device interactions performed on a website (including webpages or partially filled webpages related to web browsing interactions)" (J.A. 39). Under that construction, Lebrun's express disclosure of "sending a partial webpage without multimedia elements to the web clients" alone satisfies the core disputed limitation (J.A. 60), and the combination of Lebrun and Wang discloses or suggests every remaining limitation of every claim. This section explains the element-by-element mapping and, critically, why a person of ordinary skill in the art (POSITA) would have been motivated to combine these references.

II. Legal framework

Obviousness under 35 U.S.C. § 103 requires a showing that the claimed invention as a whole would have been obvious to a POSITA at the time of invention, assessed under Graham v. John Deere Co., 383 U.S. 1 (1966), through: (1) the scope and content of the prior art; (2) the level of ordinary skill; (3) the differences between the claimed invention and the prior art; and (4) secondary considerations. Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), a combination of familiar elements according to known methods is likely obvious when it does no more than yield predictable results, and the analysis may rely on "common sense," design incentives, and market pressures rather than an explicit teaching-suggestion-motivation in a reference.

III. The claimed invention

The ′145 patent (filed July 26, 2013; priority May 20, 2010; inventor Kambiz David Pirnazar; assignee Samesurf, Inc.) relates to "the implementation of a synchronized browsing session" — a real-time, sharable browsing experience in which a guest device joins a session administered by a synchronization server, receives data relayed from a host device, and uses that data to independently access a website server that is separate from the synchronization server. The invention's stated advantage over screen/desktop sharing is avoiding the bandwidth and processing cost of broadcasting continuous screenshots (′145 patent at 2:25–43).

Claim 1 (verbatim, J.A. 234–35 at 22:62–23:15):

A method performed by a guest device for joining a synchronized browsing session administered by a synchronization server, comprising:

• receiving from the synchronization server a session invitation including a session identifier associated with a host device;
• activating the session invitation to send a request to join said synchronized browsing session to said synchronization server;
• receiving web browsing interaction data from said synchronization server, wherein said web browsing interaction data is associated with:
  • a website server that is independent of the synchronization server, and
  • the host device that has initiated the session invitation; and
• operating an application based on said web browsing interaction data received from said synchronization server to access a website server independent of the synchronization server subsequent to the activation of the session invitation.

Claims 1–18 include: claim 1 (guest-device joining method), a corresponding apparatus independent claim (apparatus for joining), an independent method claim for implementing a synchronized browsing session (receiving information related to a shared web browsing interaction performed by a host device from the synchronization server, and performing the shared interaction based on that information), and a corresponding implementing apparatus claim, plus dependent claims directed to: the invitation comprising a hyperlink (claim 2); the invitation being conveyed by email, instant message, social network, microblog, news feed, or text (claim 3); the session identifier comprising an identification number, passkey, URL, or MAC address; shared and non-shared web browsing windows; the web browsing interaction data further comprising "information related to shared user input web browsing interactions" (claim 5); and reply messages carrying adcodes, modified URLs, cookies, scripts, or form data (see IPR2023-00339 POPR; DocketAlarm demonstratives).

Key construction (final): "web browsing interaction data" = "data related to web browsing interactions," including webpages and partially filled webpages (J.A. 39). This construction is the linchpin of the obviousness analysis: it makes Lebrun's partial-page relay squarely "web browsing interaction data."

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

A POSITA as of May 20, 2010 would have had at least a bachelor's degree in computer science, computer engineering, or electrical engineering (or equivalent), and at least two years of professional experience in internet/web browsing software development, web connectivity software, or networking software (IPR2023-00339, Howell Decl. ¶ 19; Petition at 11, defining a substantially similar POSITA). Notably, the parties' experts agreed on the essential contours of this definition, and the primary references (Lebrun, Wang, Prajapat) all sit squarely within this field — co-browsing and web-collaboration systems. A POSITA would be intimately familiar with HTTP, client-server architectures, session identifiers, and browser plug-in/JavaScript techniques.

V. The prior art references

A. Lebrun — WO 00/48110 ("Personalized access to web sites," published 2000; PCT/US00/03790)

Lebrun's Part II discloses an "improved technique for group access to web sites" — "group surfing" — in which "multiple related users can simultaneously access a sequence of web sites, such that each of the related users has substantially the same content presented at the same times," with either one selected user controlling the process or a plurality collectively controlling it (Lebrun at 3–4, 29–32). The architecture comprises web clients 110 (browsers), a network 120, web site 130 (content server), and a group-surfing server 140 (the "synchronization server" equivalent). Key disclosures:

• Session creation and identifier: A first web client sends a "session-creation message 151" to the group-surfing server requesting creation of a group-surfing session; "the message 151 includes an identifier for the group surfing session, so that other web clients 110 can add themselves to that session" (Lebrun at 32:9–14).
• Join request: "a second (or further) web client 110 sends a session-join message 151 to the group-surfing server 140. In a preferred embodiment, the message 151 includes the identifier for the group-surfing session," and the server "responds by adding the new web client 110 to the group-surfing session" (Lebrun at 32–33, 44).
• Controlling (host) device: The session-creating web client is the controlling web client that "determines the progression of pages 153 viewed during the group surfing session" (Lebrun at 33–34).
• Relay of browsing data: The group-surfing server contacts the target web site "after adding proper cookie or other identity information," retrieves the next page, and "re-sends that page 153 to those web clients 110 participating in the session" (Lebrun at 35, 45). In a preferred embodiment, "in order to reduce load on the group-surfing server 140, the group-surfing server 140 sends only the page 153 itself without any multimedia elements (such as embedded sound, images, or program fragments). Each participating web client 110 requests those multimedia elements directly from the web site 130" (Lebrun at 45–46) — i.e., direct guest-to-website-server access independent of the synchronization server.
• Alternative direct-access embodiments: "each web client 110 can receive the next page 153 directly from the web site 130" where no cookies are involved (Lebrun at 35); and "the second web client 110 can receive only a list of pointers (such as URLs) to those pages presented during the group-surfing session, dynamically updated when a new page is added" (Lebrun at 43).
• Form data / shared user input: In the "Web Page Automatic Form Completion" embodiment, the controlling web client enters HTML form information and sends it to the group-surfing server, which may "present that information on the HTML form at each participating web client 110, so that each participating web client 110 can see the HTML form being filled in" (Lebrun at 38–39).
• Client-side program fragment: A Java applet/JavaScript program fragment at each web client "intercept[s] selection of a link 152 at the web client 110 and direct[s] that selection to the group-surfing server 140 for processing" and intercepts "submit" selections during HTML form posting (Lebrun at 36–37).
• Private/non-shared browsing: The "look-ahead" and "special access" functions allow the controlling client to browse pages privately "without having that information presented to participants in the session" (Lebrun at 37–38, 46–47) — the functional equivalent of the claimed non-shared window.
• Affiliate/adcode functionality: The group-surfing server "may be registered as a partner or affiliate of the web site 130, and thus receives a commission from the web site 130 for electronic commerce conducted during the session" (Lebrun at 48).

B. Wang — US 2005/0033656 A1 ("Collaboration system suitable for on-line shopping," published Feb. 10, 2005; IBM)

Wang discloses "a collaboration system" with "a plurality of client devices individually connected to a network, and a server apparatus for receiving requests from the client devices, responding to the client devices, and providing a common collaboration environment among the client devices," including "means for providing a group session formed by integrating communication sessions of the plurality of client devices, and means for synchronizing the client devices in the collaboration environment," with each client device having "means for synchronizing displays on the plurality of client devices" (Wang, Abstract; ¶¶ 39, 43). Key disclosures:

• Session identifiers: The server apparatus assigns an SSID (session identification value) and registers it in an SSID sequence table; a PNID (page navigation ID) is associated with each synchronized page; dedicated URL addresses (e.g., http://host_path/SSID/default.jsp) are created (Wang, Figs. 7, 12; ¶¶ 43, 67).
• Invitation and join: In the joint-shopping embodiment, the server "inquire[s] whether another customer is to be invited for joint shopping," "notif[ies] the invited customer," obtains a "join agreement," "acquire[s] client identification value of the invited customer from cookie, and set[s] [a] handle name," then "[t]ransmit[s] necessary program, assign[s] SSID value, and register[s] the SSID value in SSID sequence table" (Wang, Fig. 12 at S508–S522).
• Synchronized page delivery: "The CSC 42 gives the web page or the snapshot data to the client devices among which the web page is to be shared, so that the same web page is displayed synchronously on the plurality of different client devices" (Wang, ¶ 43); snapshot data is stored in a page management table in association with the PNID and transmitted to client devices (Wang, Fig. 6).

C. Prajapat — US 2005/0021626 A1 ("Peer-to-Peer Dynamic Web Page Sharing," published Jan. 27, 2005)

Prajapat discloses web page sharing systems in which a first browser shares web pages with another browser through web media servers. "The term 'co-browse' may include one or more of the following situations: browser 12a and browser 12b display the same web pages at substantially the same time; browser 12a may alter web pages and browser 12b may view those alterations" (Prajapat, ¶ 12). The dynamic-sharing embodiment transforms a returned web page into an "intermediate form" and then into a "renderable form" retrievable by each browser (Prajapat, ¶¶ 24–26). Critically, the phone-to-phone embodiment discloses exactly the claimed direct-access model: browser 12a "communicate[s] the URL and any other suitable information" to a media controller, which "communicate[s] the URL and any other suitable information to [the other] UA and media controller using media session 28"; the other browser "may retrieve the URL from [the media controller] and use the URL to request the web page from web content server 18" — i.e., the guest browser independently accesses the website server (Prajapat, ¶ 46).

VI. Combination 1: Lebrun in view of Wang (the PTAB's adopted ground)

A. Element-by-element mapping of claim 1

How the combination fills the gaps. Lebrun alone discloses nearly the entire guest-device flow (join message → receive relayed page/URL/form data → independently access the web site), but its "invitation" is implicit (the server informs participants and publishes an identifier that others use to add themselves). Wang supplies the missing explicit invitation-with-session-identifier mechanism: the server notifies the invited customer, obtains agreement, and assigns an SSID registered in an SSID table. The combined system — a POSITA's straightforward merger of Lebrun's group-surfing engine with Wang's session-management/invitation apparatus — practices claim 1 end to end.

B. Why a POSITA would have been motivated to combine Lebrun and Wang

1. Same field, same problem. Both references address the identical problem the ′145 patent purports to solve: enabling multiple remote users to view and interact with the same web content in real time. Lebrun is a "group surfing" system; Wang is a "collaboration system" for synchronized displays during joint shopping. A POSITA seeking a complete synchronized-browsing system would naturally look to both. The IPR record confirms the Petition's position that "both Lebrun and Wang describe a process in which a first user initiates a collaborative browsing session by sending a request to a server to create a group browsing session and to send invitations to other users to join the session" (Pet., citing Ex. 1005 at 32:3–28; Ex. 1006 ¶¶ 47–48; Ex. 1003 ¶¶ 139–41).

2. Complementary, non-conflicting teachings. Lebrun supplies the relay architecture, session identifier, join protocol, page/URL/form-data distribution, and client-side program fragment — but its invitation mechanism is informal (the identifier is simply made available so clients "can add themselves"). Wang supplies precisely the missing formal session-management layer: SSIDs, dedicated URLs, explicit notification of an invited customer, join agreement, and registration of participants. There is no conflict: Wang's invitation/SSID layer operates at the server (the group-surfing server / server apparatus), and Lebrun's client join and direct-access operations operate at the client. The two can be overlaid without any re-engineering of either system's core.

3. Predictable combination of known elements (KSR). Combining Wang's "communications means" / session-management means with Lebrun's group-surfing server and web clients is a textbook KSR combination: each element performs its known function, and the result — an invitation-driven synchronized browsing session in which guests receive relayed browsing data and independently fetch content from the web site — is a predictable outcome. The Board found the "combination of Lebrun and Wang discloses or suggests" all limitations (J.A. 60–63), and the CAFC's affirmance quoted that finding approvingly.

4. Express motivation in Lebrun itself. Lebrun's preferred embodiment already teaches why a server would offload direct content retrieval to clients ("in order to reduce load on the group-surfing server 140 … each participating web client 110 requests those multimedia elements directly from the web site 130," Lebrun at 45–46). A POSITA implementing Lebrun's own preferred design would already have guests accessing the website server directly; adding Wang's invitation/SSID mechanism to that design is a trivial enhancement.

5. Samesurf's counterarguments do not defeat motivation. Samesurf argued that Lebrun's server mediates all page delivery and that no reference teaches a guest device independently accessing the website server. But (a) Lebrun's own alternative embodiments disclose direct client-to-web-site retrieval (Lebrun at 35, 43, 45–46), and (b) the claims do not require the exclusive direct-access model Samesurf urged — the Board's construction of "web browsing interaction data" (which the CAFC upheld) made the partial-page relay sufficient, and the record showed "no evidence that partially filled webpages would be incapable of" satisfying the claim's access requirement (IPWatchdog, May 21, 2026). Samesurf's resource-efficiency and security arguments address advantages of the specification's preferred embodiment, not limitations of the claims — and per Liebel-Flarsheim, a single embodiment does not confine broad claim scope.

C. Coverage of dependent claims

• Claim 2 (invitation comprises a hyperlink): Lebrun's session/URL identifiers and Wang's dedicated URL addresses (http://host_path/SSID/default.jsp) are inherently link-based; an invitation hyperlink embedding the session identifier is the conventional implementation.
• Claim 3 (invitation via email/IM/social network/microblog/news feed/text): These are well-known communication channels; Wang's "notify the invited customer" step and the general state of the art render such delivery obvious.
• Claim 5 (web browsing interaction data further comprises information related to shared user input web browsing interactions): Lebrun's HTML-form embodiment — where the group-surfing server "present[s] that information on the HTML form at each participating web client 110, so that each participating web client 110 can see the HTML form being filled in" (Lebrun at 38–39) — is squarely "shared user input" data. The CAFC specifically noted dependent claim 5's language in affirming the Board (CAFC Op. at 10–11).
• Session identifier = ID number/passkey/URL/MAC address: Lebrun's session identifier and Wang's SSID/PNID/dedicated URL disclose these forms.
• Shared and non-shared windows: Lebrun's "look-ahead" and "special access" private-browsing functions (Lebrun at 37–38, 46–47) disclose the non-shared interaction concept.
• Reply message with adcode/modified URL/cookie/script: Lebrun's affiliate-commission embodiment and cookie handling (Lebrun at 35, 48) and Wang's snapshot/dedicated-URL handling cover these.

D. Other independent claims (implementing method and apparatus claims; apparatus for joining)

The remaining independent claims track the same architecture from the guest-device and apparatus perspectives: an apparatus "for joining" (network interface + processor performing claim 1's steps) is met by Lebrun's web client (processor, network interface, program fragment) as enhanced by Wang; the "implementing" method/apparatus claims (receiving information related to a shared web browsing interaction performed by a host device from the synchronization server, and performing the shared interaction based on that information) map to Lebrun's web client receiving the relayed page/URL/form data and then performing the interaction — rendering the page, requesting multimedia directly from the web site, sending next-page messages, or submitting forms (Lebrun at 35–39, 43–46). The PTAB invalidated all of claims 1–18 on this ground (J.A. 99; Patexia: Claims Invalidated: 1–18).

VII. Combination 2: Prajapat in view of Wang (alternative ground)

A. Element mapping for claim 1

Prajapat is the reference that most explicitly teaches the guest device's independent, direct access to the content server (¶ 46) and dynamic co-browsing (alterations by one browser viewed by another, ¶ 12). What Prajapat lacks — a robust, server-administered session-identifier and invitation framework for a multi-client group — is exactly what Wang contributes (SSIDs, dedicated URLs, invitation/notification/join-agreement flow). The combination yields a complete system: Prajapat's direct-access sharing overlaid on Wang's session-management infrastructure.

B. Motivation to combine Prajapat and Wang

1. Same field and complementary roles. Both are web page sharing / collaboration systems. Prajapat's strength is the peer-to-peer media-session architecture and direct content-server access; Wang's strength is centralized session identity and invitation management. A POSITA building a scalable synchronized-browsing product would combine them: Wang provides the group session and SSID infrastructure; Prajapat provides the mechanism by which each guest retrieves the shared page directly from the content server.
2. Design need / predictable substitution (KSR). Prajapat's own disclosure recognizes the scalability benefit of distributing processing (¶ 5: "processing may be split between the web media servers, which may provide better scalability"). Adding Wang's SSID/invitation layer is a predictable substitution of a known session-management technique into a known sharing architecture.
3. The Board's institution decision credited Ground 2 as well. The IPR was instituted on all claims on both grounds, and the Petition's demonstrative confirms Ground 2 (Prajapat + Wang) as an independent obviousness theory (Petitioner's Demonstrative, IPR2023-00339/00341/00342). The FWD's final holding rested on Ground 1, but Ground 2 independently supports obviousness on the same claim set.

C. Other viable combinations

• Lebrun + Prajapat: Lebrun's group-surfing server/session-identifier/join protocol combined with Prajapat's direct-access and dynamic co-browsing teachings. The same motivation analysis applies: each reference teaches a piece of the guest-join-and-independent-access flow, and the combination is a predictable aggregation of known co-browsing techniques.
• Lebrun + Wang + Prajapat (triple combination): Adds Prajapat's direct content-server access (¶ 46) as express support for limitation [1.d], reinforcing Ground 1.

VIII. Secondary considerations (Graham factor 4)

No secondary considerations in the record overcome the strong prima facie case:

• No unexpected results: The guest-device flow is a conventional client-server interaction; Lebrun itself discloses the load-reduction benefit of direct client retrieval.
• No long-felt need / commercial success evidence: Samesurf did not present evidence of commercial success, licensing, praise, or copying attributable to the claimed features.
• No teaching away: Neither Wang nor Prajapat teaches away from Lebrun's architecture; all three describe co-browsing systems in the same technical space, and Lebrun's own alternative embodiments point toward the combined design.
• The inoperability argument fails: Samesurf's argument that the Board's construction rendered the invention inoperable (because partial webpages "do not enable participation") was rejected for lack of record support — the claims only require operating an application on the received data to access the website server, which the combined art achieves (CAFC Op.; IPWatchdog, May 21, 2026).

IX. Conclusion

The ′145 patent's claims are obvious under 35 U.S.C. § 103. The strongest and fully adjudicated combination is Lebrun (WO 00/48110) in view of Wang (US 2005/0033656 A1): Lebrun discloses the synchronized group-surfing session — session identifier, join message, relayed partial pages and form data, and guest devices independently retrieving content from the website server — and Wang supplies the invitation-with-session-identifier layer. A POSITA had every reason to combine them: they share a field and problem, their teachings are complementary and non-conflicting, and the combination is a predictable substitution of known session-management elements into a known co-browsing architecture (KSR). Under the Board's construction of "web browsing interaction data" — "data related to web browsing interactions," including partial webpages — all 18 claims fall. The alternative combination Prajapat (US 2005/0021626 A1) in view of Wang independently supports the same conclusion, with Prajapat expressly teaching the guest's direct access to the website server. The PTAB's FWD (June 25, 2024) and the Federal Circuit's affirmance (May 21, 2026) confirm this analysis: all claims of the ′145 patent are unpatentable for obviousness.

Sources: CAFC opinion, Samesurf v. Intuit, Nos. 24-2268/24-2269 (Fed. Cir. May 21, 2026) (https://www.govinfo.gov/content/pkg/USCOURTS-ca13-24-02269/pdf/USCOURTS-ca13-24-02269-0.pdf; https://www.courtlistener.com/opinion/[10862758](/patent/10862758)/); IPWatchdog (May 21, 2026); IP Law Daily (May 27, 2026); IPR2023-00339 POPR and Patent Owner's Sur-Reply (DocketAlarm); Howell Decl. (Ex. 2003); Petitioner's Demonstrative (IPR2023-00339/00341/00342); Lebrun WO 00/48110 (Ex. 1005); Wang US 2005/0033656 A1 (Ex. 1006); Prajapat US 2005/0021626 A1 (Ex. 1007).