Invalidity dossier

US 9370934

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

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

Added 9/24/2026, 9:59:25 AM

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

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Patent summary

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

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I'll verify the bibliographic details and check for any litigation/docket activity around this specific patent number.

Now let me check the CAFC docket activity and the second ITC investigation number cited on the patent page.

Let me check for CAFC 2026 appellate activity and pull the actual claim text.

US 9,370,934 — "Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board"

Scope note / date caveat: Your message states the current date as April 26, 2026, while my system clock reads 2026‑09‑30. I searched and retrieved material dated after April 26, 2026 (including an August 2026 ITC notice). I flag that explicitly so you can reconcile the timeline. Also, I could not retrieve verbatim claim text from the USPTO PatentCenter/PatFT side, and I found no CAFC 2026 docket naming 9,370,934. Statements below drawn from the patent document itself are authoritative; statements about claim wording carry stated uncertainty.


1. Bibliographic data (from the granted patent document)

Field Value
Patent number US 9,370,934 B2
Title Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board
Application no. US 14/319,609
Pre-grant publication US 2014/0307031 A1 (published 2014‑10‑16)
Inventors Noboru Asauchi; Shuichi Nakano
Assignee (original & current) Seiko Epson Corporation
Priority date (stated as an assumption) 2010‑09‑03
Filing date 2014‑06‑30
Issue date 2016‑06‑21
Legal status Active; adjusted expiration 2031‑09‑10
Assignee location (per ITC record) Nagano, Japan
Classifications B41J 2/17526, 2/1753, 2/17543, 2/17546, 2/17553, 2/17513, 2/1752; G03G 15/0863

Source: https://patents.google.com/patent/US9370934/en (the authoritative document text supplied to me). Note the 2031‑09‑10 expiry implies a 20‑year term running from a ~2011‑09‑10 parent filing, consistent with the 2010‑09‑03 priority claim and with the family relationship to US 8,764,172 (which Chinese trade-press analysis describes as the parent/母案 of the ’934). This is a continuation-family patent, not a standalone original filing.


2. Abstract

I do not have a verbatim copy of the official abstract. The closest authoritative text in the document's own opening summary reads:

"This invention relates to a printing apparatus, a printing material cartridge used for the printing apparatus, an adaptor for a printing material container, and circuit boards for these components. … a circuit board electrically connectable to a plurality of apparatus-side terminals of a cartridge attachment unit of a printing apparatus … comprises: a memory device; a plurality of first terminals through which a power source voltage and signals for operating the memory device are supplied from the printing apparatus; and a plurality of second terminals to be used for detecting connection conditions between the plurality of apparatus-side terminals and the circuit board. … Four contact portions among the plurality of second contact portions are placed at both ends of the first and second rows, respectively."

Treat that as a faithful paraphrase of the abstract's substance, not as the certified abstract text. Do not quote it as verbatim.


3. What the patent actually covers (plain language)

This is an ink-cartridge chip / electrical-contact architecture patent for large-format inkjet printers (Epson's off-carriage cartridge holders). The problem it attacks: big cartridges tilt inside the holder (uneven spring loads, shifting center of gravity as ink drains), so the 9‑terminal circuit board can make intermittent or bad contact with the printer's spring pins — and users/printers may misjudge a badly-seated cartridge as properly seated.

The disclosed solution:

  • 9 terminals on the cartridge board, in two staggered rows (upper row R1 = 4 terminals, lower row R2 = 5 terminals).
  • 5 terminals serve the memory device: reset (220), clock (230), power/VDD (260), ground (270), data (280).
  • 4 terminals (210, 240, 250, 290) are dedicated attachment/contact-detection terminals, deliberately placed at the four corners surrounding the memory-terminal cluster, so that a good detection contact implies good memory-terminal contact.
  • Contact points define a trapezoidal second area (short base = upper row) because the detection terminals farthest from the ink supply outlet 110 are the ones most likely to be displaced by tilt.
  • First row detection terminals are NOT tied to a fixed voltage (avoiding the failure mode where a grounded detection pin makes a bad connection look good when the apparatus pin floats/bears ground). They are used as a series "daisy-chain" route through all N cartridges (N≥2) — both ends of the route go to the attachment-detection circuit — so the printer can tell whether all cartridges are seated.
  • Second row detection terminals are connected individually per cartridge and are shared with the remaining-ink piezo sensor — enabling both contact detection and ink-level sensing, and enabling per-cartridge attachment identification.
  • Later embodiments add overvoltage/short-circuit detection and leak detection (e.g., detecting a ~10 kΩ-or-less leak between a detection terminal and a sensor terminal by exploiting the RC/low-pass-filter behavior of the piezo sensor), with the inspection signal's high level set below the overvoltage threshold to avoid false overvoltage trips.

Independent claim categories disclosed: circuit board, printing material cartridge, adaptor for printing material container, and printing apparatus (plus second-generation variants of each using the "first area / second area four-corners" formulation).


4. Independent claims — plain-language overview

⚠️ Uncertainty: The document text I was given was truncated before the numbered claims. I therefore cannot give you verbatim claim language. I can, however, anchor the claim structure on the ITC record, which is precise about which claim numbers exist and were asserted:

  • Claims 1 and 7 are the claims adjudicated infringed and covered by the GEO — these are among the independent claims.
  • Claims 8 and 10 were also originally asserted, then terminated on 2026‑01‑20 — so the patent has at least 10 claims. The total count is unknown to me.

Best reconstruction (moderate confidence):

Claim 1 — Circuit board (independent). A circuit board electrically connectable to plural apparatus-side terminals of a printer's cartridge attachment unit, comprising: a memory device; plural first terminals carrying power and memory-operating signals; plural second terminals for detecting connection conditions between the board and the apparatus terminals. The first and second contact portions form first and second rows, and four of the second contact portions sit at the two ends of each row. Optional/dependent features:

  • first contact portions inside a "first area"; the four second contact portions outside it, at the four corners of a quadrangular (trapezoidal, upper base shorter) "second area" encompassing the first area;
  • neither first-row end contact portion connected to a fixed voltage; the second-row end contact portions connectable to an electric device (a resistance element, or the remaining-ink sensor);
  • the memory ground terminal's contact portion centered in the second row;
  • first row driven at ≤ VDD; second row at ≤ VHV (print-head drive voltage) but > VDD;
  • overvoltage detection on the first-row pair with the inspection signal's high level below the overvoltage threshold;
  • first/second attachment inspection pulse signals with different rise timings so a poor-contact pair can be isolated;
  • two first contact portions in row R1 and three in row R2.

Claim 7 — Independent (likely the printing material cartridge or the printing apparatus). Same nine-terminal, two-row, four-corner architecture claimed from the cartridge/apparatus side, including the N≥2 cartridge configuration in which the first-row detection terminals of all N cartridges are connected in series via the holder's device-side terminals to form a single wiring route whose ends terminate at the attachment detection circuit (→ "are all cartridges present?"), while the second-row detection terminals are wired individually per cartridge (→ "which specific cartridge is seated?"). The attachment detection circuit performs both judgments.

Claims 8–10 (dependent; 8 and 10 later withdrawn from the ITC complaint). Consistent with dependent claims narrowing to specific contact geometry, voltage relationships, signal timings, leak/overvoltage detection, or the sensor-sharing arrangement.

Other independent claims in the family variants (adaptor; cartridge; circuit board; apparatus — second formulation) recite: first contact portions arranged within a first area, second contact portions outside it, including four contact portions at the four corners of a quadrangular second area encompassing the first area, such that good contact of the second contact portions confirms good contact of all memory-device-connected first terminals.


5. Litigation status (verified)

ITC Investigation No. 337‑TA‑1452, Certain Ink Cartridges and Components Thereof II

  • Complaint filed 2025‑05‑13 by Epson Portland Inc. (Hillsboro, OR), Epson America, Inc. (Los Alamitos, CA), Seiko Epson Corporation (Japan). Institution notice: 90 FR 25644‑45 (June 17, 2025): https://regulations.justia.com/regulations/fedreg/2025/06/17/2025-11106.html
  • Asserted patents: 8,764,172; 9,370,934; 11,535,038; 12,240,248; 12,240,249. The old DN 3828 / "337‑TA‑3828" interim number appearing on the Google Patents page refers to this complaint docket — it is the pre-institution number, not a separate investigation.
  • 2026‑01‑20: Commission terminated the investigation as to claims 2, 3, 8, 10 of the ’172 patent; claims 8 and 10 of the ’934 patent; claims 12, 17, 19‑20, 24 of the ’038 patent; claims 13, 15, 20‑21 of the ’248 patent; claims 2, 8, 13‑15, 20‑22 of the ’249 patent (complainant withdrew).
  • 2026‑03‑24: ALJ Order No. 16 — summary determination of a Section 337 violation (many respondents in default), recommending a GEO, CDOs against Mountain Peak and Straightouttaink, and a 100% bond.
  • 2026‑05‑08: Commission review in part, limited to the economic prong of the domestic-industry requirement (91 FR 25921‑23).
  • 2026‑08‑13: Commission final determination — violation found; GEO issued covering claims 1 and 7 of each of the five patents, including the ’934 patent; CDOs against Mountain Peak, Inc. and Straightouttaink, LP; 100% bond; investigation terminated. Official notice: https://www.usitc.gov/system/files?file=secretary/fed_reg_notices/337/337_1452_notice08132026sgl.pdf and 91 FR (2026‑08‑18).

Companion case 337‑TA‑1451 (patents 8,540,347; 9,061,508; 11,535,037; 11,820,150; 12,246,539) runs in parallel and does not include the ’934.

CAFC 2026 dockets: I found no Federal Circuit appeal docketed in 2026 that names US 9,370,934. Given that the ITC case was resolved by summary determination against largely defaulting respondents, an appeal is unlikely, but I cannot positively confirm the absence of a docket — treat this as "no evidence found," not as a verified negative. Repeated CAFC enforcement litigation over Epson cartridge patents exists in earlier years (e.g., Ninestar v. ITC, No. 12‑552), but that concerned different patents.

Family litigation tracker cited on the patent page: https://patents.darts-ip.com/?family=45770408 (Epson v. aftermarket cartridge suppliers).


6. Bottom line

US 9,370,934 is a Seiko Epson continuation patent (priority 2010‑09‑03; filed 2014‑06‑30; issued 2016‑06‑21; expiry 2031‑09‑10) by Noboru Asauchi and Shuichi Nakano, covering the nine-terminal, two-row, four-corner contact-detection layout on large-format ink-cartridge circuit boards, including daisy-chained all-cartridge presence detection, per-cartridge sensor-terminal contact detection, and overvoltage/leak detection. Its asserted claims 1 and 7 were adjudged infringed by the ITC in Inv. No. 337‑TA‑1452, and a general exclusion order covering those claims issued 2026‑08‑13. I could not retrieve verbatim claim text or confirm any CAFC 2026 appeal; those two gaps are the main uncertainties in this report.

Generated 9/30/2026, 7:34:21 PM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 9370934. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

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

✓ Generated

I'll research litigation involving US patent 9370934. Let me start with targeted searches.

Let me dig deeper into the specific ITC investigations and district court cases.

Litigation Involving U.S. Patent No. 9,370,934 (US 9,370,934 B2)

Summary: The only adversarial proceedings I could positively confirm involving U.S. Patent No. 9,370,934 are at the U.S. International Trade Commission (ITC) — not in district court or the Federal Circuit. Google Patents' litigation tab for the patent lists two ITC case numbers (337-TA-1452 and 337-TA-3828), and both trace to the same 2025 Epson enforcement campaign.


Case 1 — Certain Ink Cartridges and Components Thereof II

Field Detail
Plaintiffs / Complainants Epson Portland Inc. (Hillsboro, OR); Epson America, Inc. (Los Alamitos, CA); Seiko Epson Corporation (Nagano, Japan) — collectively "Epson"
Defendants / Respondents 20 entities: Shenzhen Hongxinyuan E-Commerce Co., Ltd. d/b/a Jianjai; Shangrao Shixuan E-Commerce Co., Ltd. d/b/a Inkgo; Shen Zhen Sailing Technology Ltd. d/b/a Triple-Color; Qiong Wang d/b/a 7-Magic; Dongguan Ocbestjet Digital Technology Co., Ltd. d/b/a Ocbestjet; Ocbestjet Printer Consumables (HK) Co., Ltd.; Shenzhen Kaizhen Technology Co., Ltd. d/b/a PayForLess; ZhuHai MeiJiAn Trading Co., Ltd. d/b/a HaloFox; Zhuhai Shuofeng E-commerce Co., Ltd.; Tatrix International China Co., Ltd.; Luozhi Trading Co., Ltd.; Zhuhai Zhenyang Electronics Co., Ltd.; Zhuhai Hengyunda Electronics Co., Ltd.; Zhuhai Rongtaida Electronics Co., Ltd.; Zhuhai Shi Wei Tai Electronics Co., Ltd.; Zhuhai Yixing Electronics Co., Ltd.; Zhuhai Bowang Technology Co., Ltd.; Mei Jin Technology HK Co., Ltd.; Mountain Peak, Inc.; Straightouttaink, LP. (Office of Unfair Import Investigations also a party.)
Jurisdiction U.S. International Trade Commission (Section 337)
Case Number Inv. No. 337-TA-1452 (Federal Register 90 FR 25644–45)
Filing Date Complaint filed May 13, 2025 (supplements May 19, May 30, June 3, 2025); instituted June 17, 2025 (vote June 12, 2025)
Asserted claims of '934 Claims 1, 7, 8, and 10
Outcome / Status Concluded. Commission determination of August 13, 2026 found a Section 337 violation and issued a General Exclusion Order (GEO) prohibiting importation of products infringing claims 1 and 7 of each of U.S. 8,764,172; 9,370,934; 11,535,038; 12,240,248; 12,240,249, plus cease and desist orders against Mountain Peak, Inc. and Straightouttaink, LP. Investigation terminated. Eleven respondents were found in default (Nov. 2025); four respondents (Shenzhen Hongxinyuan, Shangrao Shixuan, Shen Zhen Sailing, Qiong Wang) were terminated in January 2026. An ALJ granted summary determination in March 2026.

Sources: USITC Federal Register notice (published Aug. 18, 2026), https://www.govinfo.gov/content/pkg/FR-2026-08-18 ; USITC institution notice 90 FR 25644 (June 17, 2025), https://www.federalregister.gov/documents/2025/06/17/2025-11106 ; USITC news release 25-074 (June 12, 2025), https://www.usitc.gov/press_room/news_release/2025/er0612_67166.htm ; Google Patents litigation tab, https://patents.google.com/patent/US9370934/en


Case 2 — "337-TA-3828" (the companion complaint tied to the '934 patent)

Google Patents also lists an ITC filing under the identifier 337-TA-3828. Based on contemporaneous reporting, on May 13, 2025 Epson filed two Section 337 complaints, which were assigned the temporary pre-institution numbers 337-TA-3827 and 337-TA-3828. The 3828 complaint asserted U.S. 8,764,172; 9,370,934; 11,535,038; 12,240,248; and 12,240,249 — i.e., the same patent set as 337-TA-1452. The two complaints were instituted as 337-TA-1451 and 337-TA-1452; the 3827 set (U.S. 8,540,347; 9,061,508; 11,535,037; 11,820,150; 12,246,539) maps to the companion case 337-TA-1451, which does not involve the '934 patent.

Caveat: I could not independently retrieve the primary ITC docket page confirming whether "337-TA-3828" persisted as an official investigation number or was purely a temporary/pre-institution number superseded by 337-TA-1452. Treat "337-TA-3828" as the same May 13, 2025 Epson filing event as 337-TA-1452 rather than as a separate, later proceeding. Source for the 3827/3828 pairing: https://mp.weixin.qq.com/s/Z-EVD3FpBRLEUhhpE5uVmw and https://dippc.dg.cn/zscqzx/c100334/[202509](/patent/202509)/357e5fcc7ec240588e24c9f7de8f0fef.shtml


What I could NOT confirm

  • No district court case asserting U.S. 9,370,934 was confirmed. Epson maintains a large parallel district-court enforcement program against aftermarket ink-cartridge sellers (e.g., Seiko Epson Corp. v. BCH Technologies LLC, 1:19-cv-01067 (M.D.N.C.); STS Refill Technology, 9:18-cv-81723 (S.D. Fla.); CIS Systems, 1:18-cv-06586 (N.D. Ill.); Advance Image Manufacturers, 3:17-cv-425 (D. Or.); and numerous others), but the complaints I reviewed from that program assert Epson's earlier cartridge/chip patents (the '233, '116, '749, '163, '513, '917, '902 families) — not the '934 patent. I did not find any district-court complaint or judgment naming U.S. 9,370,934.
  • No CAFC appeal of any '934-specific ruling was confirmed. Because the ITC determination issued August 13, 2026, any appeal to the Federal Circuit (under 35 U.S.C. § 1295(a)(2) / 19 U.S.C. § 1337) would only now be ripening; I found no record of one.
  • No PTAB proceeding (IPR/PGR/CBM) specific to U.S. 9,370,934 was confirmed. PTAB documents surfaced in my searches referenced unrelated patents.

Important verification notes

  • The patent number in the ITC materials is rendered as "9,370,934" / "the '934 patent." Read literally, 9,370,934 = 9370934, the patent at issue here (US 9,370,934 B2, titled Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board, applicant Seiko Epson Corp.). I have not altered any identifier.
  • The Google Patents record for US9370934B2 independently corroborates the ITC linkage by listing two USITC filings: 337-TA-1452 and 337-TA-3828.
  • ITC Section 337 investigations are adversarial adjudications but are not Article III "litigation"; no plaintiff/defendant damages award or jury verdict exists here. The remedy is exclusion/cease-and-desist, not money damages.

Bottom line: U.S. Patent No. 9,370,934 has been asserted in at least one confirmed ITC proceeding — Inv. No. 337-TA-1452 (complaint filed May 13, 2025; violation found and GEO/CDOs issued August 13, 2026) — with a second ITC identifier (337-TA-3828) tied to the same filing. No district-court or Federal Circuit case specifically asserting this patent is known to me.

Generated 9/30/2026, 7:34:11 PM

Proceedings on file (0)

All PTAB activity →

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

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

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

PTAB challenges

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

✓ Generated

I'll verify the structured PTAB data against web sources before writing anything.

Let me probe more specifically before concluding.

Now let me check whether any PTAB petitions were filed against the '934 in connection with the 2025 ITC campaign, and check Unified Patents' docket.

Proceedings overview

Total AIA trial proceedings on file for US 9,370,934: 0. The structured "PTAB proceedings on file" block — the canonical USPTO Open Data Portal list supplied with this assignment — reports no AIA trial proceedings (IPR, PGR, or CBM), so the breakdown by status is 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution denied. My independent web searches (PTAB document repositories, Google Patents litigation block, CourtListener / Justia docket mirrors) also surfaced no IPR, PGR, or CBM naming U.S. Patent No. 9,370,934. The bottom line for a defendant today: no claim of the '934 has ever been canceled or even adjudicated for validity in an AIA trial. That cuts both ways — there is no "claim 1 is dead" argument available to you, but the patent's validity is likewise completely untested, not "hardened." Its enforceable bite comes from ITC Section 337, not from the PTAB, and one ITC investigation already ended in a general exclusion order covering claims 1 and 7.

⚠️ Confidence caveat, stated explicitly: the ODP ingest can lag recent filings, and my search tooling ran out before I could exhaustively sweep every 2025–2026 IPR docket. The absence of record is reliable as of the ODP ingest date but should be re-verified in PTAB E2E before you rely on it in a brief. I found nothing, but I cannot prove a negative across every recently-filed petition number.


No proceedings to report (per-proceeding sections intentionally omitted)

There is no IPR, PGR, or CBM to format under the required per-proceeding headings. Rather than fabricate a docket, proceeding number, panel, or FWD, I state plainly that none exists on the record provided. Everything below is related adversarial activity that is not an AIA trial — it is Section 337 litigation at the ITC, which is a separate forum with different law (no PTAB claim-cancelation power; validity is a defense under § 337, 19 U.S.C. § 1337).


Related non-AIA adversarial activity (context a defendant must have)

ITC Inv. No. 337-TA-1452 — Epson (Epson America / Epson Portland / Seiko Epson) v. 20 named respondents

  • Type: Section 337 investigation (importation-based enforcement; not an AIA trial proceeding)
  • Complaint filed: 2025-05-13 (supplements 2025-05-19, 2025-05-30, 2025-06-03)
  • Instituted: 2025-06-12; notice of investigation published 2025-06-17, 90 Fed. Reg. 25644-45
  • Asserted patent family: U.S. Patent Nos. 8,764,172; 9,370,934; 11,535,038; 12,240,248; 12,240,249
  • Scope as instituted for the '934: claims 1, 7, 8, and 10 of the '934 (per the FR notice: "claims 1, 7, 8, and 10 of the '934 patent")
  • Procedural path: numerous respondents were found in default (the bulk of the Chinese respondents); four respondents — Shenzhen Hongxinyuan E-Commerce, Shangrao Shixuan E-Commerce, Shen Zhen Sailing Technology, and Qiong Wang — were terminated from the investigation in 2026-01; in 2026-03 the ALJ granted Epson's motion for summary determination of a Section 337 violation and recommended a GEO, CDOs, and a 100% bond
  • Commission determination: 2026-08-13 — violation found; general exclusion order (GEO) issued covering products infringing claims 1 and 7 of each of the five patents, including the '934; CDOs issued against Mountain Peak, Inc. and Straightouttaink, LP; investigation terminated. The Commission ordered a bond of 100% of entered value during the Presidential review period.
  • Domestic-industry wrinkle: the Commission conducted a partial review of ALJ Initial Determination No. 16 (2026-03-24) on whether Epson satisfied the economic prong of the domestic industry requirement, and affirmed with additional analysis — i.e., the DI economic-prong issue was the only live merits question at the Commission level.
  • Link: Commission notice, 2026-08-13; institution notice (Justia / Fed. Reg.); USITC press release, 2025-06-12
  • Defensive value: This is the actual weapon being pointed at cartridge importers. The GEO is in rem — it is not limited to the named respondents, so un-named importers are equally exposed on claims 1 and 7. Critically, the merits were resolved by default and summary determination, not by a contested validity trial. No invalidity ruling, no claim construction that binds anyone, and nothing that gives you a validity-based shield.

Identifier flag: "337-TA-3828" in the Google Patents litigation block

The patent record's litigation block lists "US case filed in International Trade Commission … 337-TA-3828" alongside 337-TA-1452. Read literally, as instructed, 337-TA-1452 is the real, corroborated investigation number. 337-TA-3828 does not correspond to any ITC investigation number I can corroborate, and I note (without effecting a correction) that the pre-institution complaint docket for the second of Epson's two May 2025 complaints was numbered 337-DN-3828, which is the matter that became instituted Investigation No. 337-TA-1452. Treat "337-TA-3828" as a mislabeled precursor docket, not a second live ITC case.

Parallel ITC matter (different patents, no '934)

Inv. No. 337-TA-1451 — the first of Epson's two 2025 complaints (pre-institution docket 337-DN-3827) asserted U.S. Patent Nos. 8,540,347; 9,061,508; 11,535,037; 11,820,150; 12,246,539 — the '934 is not among them. The Commission issued its final determination and a GEO in that investigation on 2026-09-29 per Federal Register publication. Take a general exclusion order and two cease-and-desist orders were part of the remedy.


Strategic summary

Claim status of the '934: all claims UNTESTED for validity; claims 1 and 7 are adjudicated infringed by default/summary determination in the ITC. No claim has been canceled, confirmed, or construed in any AIA trial. The only claim-level adjudication anywhere is the ITC's finding that articles infringed claims 1 and 7, which is now embedded in a general exclusion order effective 2026-08-13 and final 60 days later absent Presidential disapproval. Claims 8 and 10 of the '934 were named in the ITC notice of investigation but were not carried into the GEO's claim coverage — they are therefore entirely untested in any forum. Claims outside 1, 7, 8, and 10 (the '934 has dependent and independent claims addressing the adaptor, circuit board, and printing-apparatus aspects) are likewise untested. The patent is active with an adjusted expiration of 2031-09-10, so roughly five years of term remain.

Estoppel landscape: § 315(e)(2) estoppel is a non-issue, because no IPR was ever instituted. There is no petitioner-side estoppel barring anyone, and symmetrically no PTAB record for Epson to leverage defensively. That means a defendant today has the full universe of prior art available for a fresh IPR or PGR (subject only to § 315(b)'s one-year bar running from service of a complaint alleging infringement, § 325(d) discretionary considerations, and the Fintiv-style discretionary-denial overlay). Note the practical trap: the respondents who defaulted at the ITC never ran an invalidity case, so they created no record that helps you and may face issue-preclusion problems on the infringement findings. A defendant served with a complaint — including a new § 337 complaint — should calendar the § 315(b) one-year IPR window immediately; it will often expire long before any ITC target date.

Pattern signals: no repeat petitioner, no PTAB appeals, no defensive aggregator. Because there are zero AIA proceedings, there is no serial petitioner, no Patent Owner appeal to the Federal Circuit from any FWD, and no evidence of a defensive aggregator such as Unified Patents sponsoring an IPR challenge here (the Unified Patents link in the patent record is an ITC litigation-tracking entry, not a petition). The pattern that does emerge is a forum-selection strategy by the patent owner: Epson routes 934 enforcement through the ITC, where absent/defaulting respondents and in-rem exclusion orders do the work, and where validity gets little airtime. That is the signature of a patent owner that prefers the ITC's speed and remedy over a district-court or PTAB fight on validity.


Recommended next steps

  1. Do not tell anyone "the PTAB killed this patent." It did not. There is no FWD to link and no claim to quote as canceled. Any demand-letter response built on "claims 1-7 are invalidated" would be affirmatively wrong. The correct framing is: no AIA trial has ever been filed against the '934, and no claim of the '934 has ever been held invalid by any tribunal.
  2. Re-verify the null result before reliance. Confirm in USPTO PTAB E2E / the Patent Trial and Appeal Board proceedings search (https://ptacts.uspto.gov/) and in USPTO Patent Center for application 14/319,609, and check CourtListener (https://www.courtlistener.com/) for any Federal Circuit appeal from an ITC determination. ODP ingest lag is the one realistic way a pending IPR2025/IPR2026 petition could be missing. If you find one, the per-proceeding template above applies verbatim and I would want the institution date, panel, and statutory FWD deadline.
  3. If you are importing or planning to import compatible cartridges: the operative risk is not a PTAB decision, it is the GEO from 337-TA-1452 covering claims 1 and 7 of the '934, effective on issuance and final 60 days after 2026-08-13 unless disapproved, with a 100% entered-value bond during Presidential review. Customs enforcement is in rem and reaches non-respondents. Design-around analysis should start with claim 1 (and the dependent claim 7) as the ITC construed them for infringement purposes.
  4. If you were served with a complaint asserting the '934, the § 315(b) one-year IPR clock is your critical milestone; there is no existing estoppel or FWD record constraining your grounds. Because no IPR has ever been filed, the art you can raise is unconstrained by any prior § 325(d) prosecution record of note — but you should confirm what art was before the examiner, since the '934 issued from a 2014 continuation of a 2010-priority family and the specification states the inventors' own expectation that terminal-contact failures were a known problem in large-format printers, which is worth mining for a § 103 motivation-to-combine narrative.
  5. If you are a defendant in district court and the patent owner points to the ITC win: note that the ITC violation was established largely by default and by summary determination without a validity trial. That finding is persuasive-sounding but carries no preclusive effect on validity — invalidity was never decided, and no claim was ever construed in a contested proceeding that binds you.

Sources cited: USITC Commission determination, Inv. No. 337-TA-1452, 2026-08-13 · Notice of Institution, 90 Fed. Reg. 25644-45 (2025-06-17) · USITC News Release 25-074 (2025-06-12) · US9370934B2 on Google Patents · PTAB E2E · CourtListener

Generated 9/30/2026, 7:34:31 PM

Assignment history

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

✓ Generated

I'll research the assignment record for US 9370934 using the available sources.

Let me dig into the assignment records and litigation history.

Let me search for the specific assignment records and any NPE-related transfers.

Ownership Analysis — US 9,370,934 B2

Patent: US 9,370,934 B2 ("Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board")
Application: 14/319,609 (filed 2014-06-30; grant 2016-06-21)
Priority: 2010-09-03 (assumed)

Methodological caveat (read first): My direct query access in this session covered public web indexes (Google Patents, Justia, USITC/Federal Register, plainsite, and secondary reporting). I was not able to open a live USPTO Assignment Center record for this patent, and no assignment-event reel/frame appears in the Google Patents legal-events block for US 9,370,934 (which shows only filing, publication, grant, and the 2031-09-10 adjusted-expiration entry). Accordingly, I report no located post-issuance assignment records rather than inferring any. Reel/frame fields below are left unpopulated because I could not verify them — see the closing section for what a direct Assignment Center query should be used to confirm.

Inventors

Inventor Employer at filing (determinable)
Noboru Asauchi Seiko Epson Corporation (JP)
Shuichi Nakano Seiko Epson Corporation (JP)
  • Both inventors are Seiko Epson personnel. Third-party inventorship analytics (PatentLeaderboard) credit Shuichi Nakano with ~43–50 patents assigned to Seiko Epson, consistent with a career Epson engineer; Noboru Asauchi appears on the same Epson ink-cartridge circuit-board family (the '934 patent lists him as co-inventor).
  • Unusual-pattern check: No evidence that either inventor departed Seiko Epson within 12 months of filing, and no evidence of an inventor-side assignment to a third party. The inventor population is homogeneous (single-company, Japan-based), which is the opposite of the "orphaned inventors / fire-sale precursor" pattern. Not present.

Original assignee

Seiko Epson Corporation (4-1 Nishi-shinjuku 2-chome, Shinjuku-ku, Tokyo, JP) — the as-issued assignee of record on the face of the patent and the current assignee listed by Google Patents.

  • Primary line of business: Operating manufacturer of inkjet printers, large-format printers, projectors, semiconductor/display components, and (through Epson America, Inc. and Epson Portland, Inc.) the U.S. distribution arm for the ink cartridges at issue.
  • Does it ship a product embodying the claims? Yes. The '934 patent claims a printing apparatus, a printing-material cartridge, and a circuit board for a cartridge — i.e., Epson's own genuine ink cartridges and the large-format/off-carriage printers that accept them. Epson asserted the patent in an ITC §337 action on its own cartridge products, and the ITC found a domestic-industry requirement satisfied (see timeline).
  • Current status: Operating. Publicly traded (TSE: 6724), no bankruptcy, no dissolution, no acquisition of the patent portfolio by a third party.

Assignment timeline

No post-issuance assignment records were located for US 9,370,934. The chain of title visible on the public record terminates at the original assignee:

  • Not determinable (executed) / recorded not located — Reel not located/not located
    • Conveyance: Assignment (inventor → Seiko Epson Corporation) — presumed as part of Epson's standard practice, but the specific reel/frame for this application could not be confirmed in this session and is not fabricated here.
    • Assignor: Noboru Asauchi; Shuichi Nakano
    • Assignee: Seiko Epson Corporation
    • Correspondent: Not confirmed. (Epson's U.S. patent recordations are commonly filed through Oliff PLC, P.O. Box 320850, Alexandria, VA — e.g. correspondent "James A. Oliff" on the separately-verified Epson recordation at Reel 035691/Frame 0967 — but I have no verified reel/frame linking that correspondent to US 9,370,934, so this is context, not a finding.)
    • Context: Original assignment from inventors to their employer; no downstream transfer recorded.

There is likewise no recorded assignment to any NPE, LLC, holding company, or defensive aggregator. Since the Assignment Center shows no post-issuance records for this patent, the operative conclusion is that Seiko Epson Corporation still owns the patent — an ownership fact, not a transfer fact.

Timeline diagram

timeline
    title Ownership of US 9370934
    2010 : Priority filing JP for cartridge circuit board
    2014 : US app 14319609 filed by Seiko Epson
    2016 : Patent issued to Seiko Epson
    2025 : ITC complaint filed by Epson entities
    2026 : General exclusion order issued

NPE / troll-pattern signals

  1. Shell-entity transfer — Not present. No assignment from Seiko Epson to any "IP / Patents / Holdings / Ventures"-suffixed entity; no single-purpose LLC appears anywhere in the chain. Current assignee is an operating, publicly traded manufacturer.

  2. Known asserter in the chain — Not present. The current and only visible owner is Seiko Epson Corporation, which is not on any of the listed NPE directories (Acacia, Marathon, IV, IPNav, Wi-LAN/Conversant, Vringo, Pendrell, MPHJ, Round Rock, Spangenberg entities). Neither Unified Patents nor RPX lists Epson as a high-frequency NPE plaintiff; Unified Patents' docket entry for the related ITC complaint categorizes Epson as the complainant and the China/Hong Kong/U.S. resellers as defendants — the inverse of the NPE posture.

  3. Repeat correspondent across the chain — Not present (not assessable). Because there is only one owner and no recorded downstream links, there is no chain in which a correspondent could recur. (Note: Oliff PLC is a well-known Epson prosecution/recordation firm with many Epson filings; a single appearance there would not be an NPE signal in any event.)

  4. Cascading transfers — Not present. Zero consecutive assignments; nothing transferring through chained LLCs within 24 months.

  5. Pre-litigation transfer — Not present. The ITC complaint was filed 2025-05-13 and instituted 2025-06-17 (Inv. No. 337-TA-1452). There is no assignment recorded within 6 months before that date — the patent has been held by Epson continuously since grant, so the suit was brought by the original owner, not by a recently-acquired plaintiff. This is materially different from the "clean standing record" setup typical of NPE pre-suit transfers.

  6. Bankruptcy fire-sale — Not present. Seiko Epson has not filed Chapter 7/11; no portfolio sale of Epson patents in bankruptcy proceedings was located.

  7. Privateering — Not present. This is the reverse: the operating company (Epson) is asserting its own patents, in its own name, together with its own U.S. subsidiaries (Epson America, Epson Portland), against third-party aftermarket importers — not transferring to an NPE to assert on its behalf.

  8. Defensive aggregator (anti-NPE) — Not present. The chain does not terminate at RPX, AST, LOT, Unified, or OIN. The patent is an actively asserted operating-company asset.

Verdict

Operating-company assertion.

Justification: The only owner of record is Seiko Epson Corporation, which has held the patent from issuance (2016-06-21) with no recorded assignment to any third party, NPE, or aggregator; the asserted products are Epson's own cartridges and printers, so the patentee ships a commercial embodiment of the claims. The 2025 assertion runs through the original owner and its U.S. subsidiaries — Epson America, Epson Portland, and Seiko Epson as complainants in ITC Inv. No. 337-TA-1452 (complaint 2025-05-13; instituted 2025-06-17), which produced a general exclusion order on 2026-08-13 covering claims 1 and 7 of the '934 patent against aftermarket importers — not a shell-entity assertion.

Verification link (Assignment Center): https://assignmentcenter.uspto.gov/ — search by patent number 9370934. Any record would also surface at https://assignment.uspto.gov/patent/index.html. (Both index the same underlying reel/frame records.)

Residual items a direct Assignment Center pull should close out

  • Confirm whether the inventor→Seiko Epson assignment for application 14/319,609 (or its parent) was recorded, and capture its reel/frame, execution date, and correspondent of record. I could not verify these and have deliberately not invented them.
  • Confirm that no later conveyance (including any error-correction or change-of-name entry) exists for this patent number. If none exists, that silence is itself the dispositive finding that Epson remains the owner.
  • One Google Patents legal-events entry references a second ITC matter styled 337-TA-3828. The docket number is anomalous for a 2016 patent (the 3800-series dates to the 1990s), and I could not verify it; treat it as unverified and do not rely on it. The verified Epson ink-cartridge investigations are 337-TA-1452 (2025, the one naming the '934 patent) and, in earlier years, 337-TA-946 (2014) and 337-TA-565 (2006).

Sources: USITC notice of institution, 90 FR 25644-45 (2025-06-17); USITC final determination, 91 FR 53424-25 (2026-08-18) (Inv. No. 337-TA-1452, GEO covering claims 1 and 7 of US 9,370,934); Justia Federal Register compilations of the same; Google Patents legal-events block for US 9,370,934; Unified Patents litigation portal entry for the Epson complaint (Epson America, Epson Portland, Seiko Epson as complainants); PatentLeaderboard inventor page for Shuichi Nakano.

Generated 9/30/2026, 7:34:29 PM

Prior art

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

✓ Generated

I'll research the cited prior art for US 9,370,934. Let me run several targeted searches.

Good — I found a citation list. Let me get the full "Referenced Cited" table and cross-check on other databases.

Let me pull the complete citation tables from multiple sources.

Prior-Art Analysis — US 9,370,934 B2

Scope, sourcing, and three verification flags

1. Patent identity confirmed (no auto-correction needed). US 9,370,934 B2 (application US 14/319,609) is the patent at issue — Printing apparatus, printing material cartridge, adaptor for printing material container, and circuit board, inventors Noboru Asauchi and Shuichi Nakano, original assignee Seiko Epson Corporation, priority date 2010‑09‑03, filed 2014‑06‑30, issued 2016‑06‑21. The identifier "9370934" as given matches the grant number exactly; nothing needed normalizing.

2. Sources used. The authoritative patent document text supplied to me (Google Patents, fetched 2026‑09‑24) is truncated before the "Patent Citations" section — it ends mid‑sentence at the equivalent‑circuit discussion for FIG. 15B. I therefore had to obtain the citation list from USPTO‑derived full‑text mirrors: Justia Patents (https://patents.justia.com/patent/9370934) and EPO Global Patent Index. The citation list below is a secondary‑source reconstruction, not read off the face of the granted patent. Where the mirror returned a truncation, I say so.

3. Date discrepancy — flagged, not reconciled. Your instruction states the current date as April 26, 2026. My environment clock reads 2026‑09‑30, and the previously generated sections in this file cite events dated 2026‑08‑13 (the ITC final determination) and 2026‑08‑18 (Federal Register). Those cannot both be true if today is April 26, 2026. This is a live contradiction between the task header and the accumulated work product. I am not silently resolving it. It matters for the § 102 analysis below only in a minor way (it does not change the 2010‑09‑03 priority date or any reference's publication date), so the prior‑art analysis stands regardless.


1. The citation record (as retrieved)

1a. U.S. patent documents cited in US 9,370,934

⚠️ The mirror's list is partially truncated. The retrieved sequence runs 5138344 … [gap] … 8678541, so there are one or more U.S. patent numbers between 5,138,344 and 8,678,541 that I could not retrieve. I am not going to invent them. What I retrieved verbatim:

Cited U.S. document Date shown Inventor / Applicant (as listed)
US 5,138,344 Aug 11, 1992 Ujita
[…] gap not retrieved […]
US 8,678,541 Mar 25, 2014 Uchiyama
US 2002/0112878 A1 Aug 22, 2002 Ishizawa et al.
US 2003/0002080 A1 Jan 2, 2003 Asauchi
US 2006/0238558 A1 Oct 26, 2006 Hatasa et al.
US 2007/0002087 A1 Jan 4, 2007 Matsui et al.
US 2007/0092270 A1 Apr 26, 2007 Inukai
US 2007/0126770 A1 Jun 7, 2007 Asauchi
US 2007/0149044 A1 Jun 28, 2007 Asauchi
US 2008/0259135 A1 Oct 23, 2008 Asauchi et al.
US 2009/0085939 A1 Apr 2, 2009 Asauchi
US 2009/0237439 A1 Sep 24, 2009 Ishizawa et al.
US 2009/0262161 A1 Oct 22, 2009 Nishihara
US 2010/0259579 A1 Oct 14, 2010 Wu
US 2010/0289847 A1 Nov 18, 2010 Ishizawa et al.

1b. Foreign patent documents cited

Cited foreign document Date shown Jurisdiction
EP 0440261 A Aug 1991 EPO
JP 03-284953 Dec 1991 JP
JP 06-155758 Jun 1994 JP
JP 06-262771 Sep 1994 JP
WO 02/40275 May 2002 PCT
JP 2002-198627 Jul 2002 JP
JP 2002-273900 Sep 2002 JP
JP 2003-300333 Oct 2003 JP
JP 2005-007893 Jan 2005 JP
JP 2005-119228 May 2005 JP
JP 2005-326779 Nov 2005 JP
WO 2006/025575 2006 PCT
JP 2006-297826 Nov 2006 JP
EP 1800872 A Jun 2007 EPO
CN 1990255 Jul 2007 CN
JP 2007-121551 May 2007 JP
JP 2007-168078 May 2007 (date as listed by mirror; I have not independently confirmed the month) JP
JP 2007-196664 Aug 2007 JP
CN 100373163 C Mar 2008 CN
CN 101486272 Jul 2009 CN
JP 2009-241591 Oct 2009 JP
JP 2009-274438 Nov 2009 JP

The foreign list also appears truncated after "WO 2006/025575" in the retrieved text — the snippet cuts off mid‑entry. I cannot rule out additional foreign citations beyond those above.

1c. Forward citations (for completeness — these are not prior art)

US 9,370,934 is itself cited by later Epson/HP documents, confirming it is now treated as background art in this space. Example: EP 3 666 527 A4 ("Chip and ink cartridge") cites "US 9370934 B2 … ASAUCHI NOBORU" with the EPO category "[XAI]" — i.e., the EPO considers it particularly relevant, taken alone against that later application (http://data.epo.org/gpi/EP3666527A4-CHIP-AND-INK-CARTRIDGE.html). Other forward citers include US 11,198,298; US 11,034,157; US 11,429,554; US 11,331,925; US 10,940,693; US 11,738,562.


2. § 102 analysis — and the limits of what I can responsibly assert

Two hard constraints you should weigh before relying on any anticipation conclusion below:

(a) I still do not have verbatim claim text for the '934. This was flagged as an unresolved gap in the previously generated sections, and it remains unresolved here — the document text I was given is truncated before the claims, and I could not pull claim text from PatentCenter. A § 102 anticipation analysis is an element‑by‑element comparison of a reference against a claim. Without the claim language, I cannot state that any reference anticipates a specific claim in the strict § 102(b) sense. What follows is therefore a § 102 screening / priority‑ranking, with the anticipation question flagged as hypothesis to be tested, not finding.

(b) I have not verified the disclosure content of most listed references. For most of the JP/CN/EP/WO entries I retrieved only the number, date and (sometimes) inventor. I will not manufacture technical summaries for them. Where I state what a reference is probably about, it is based on family/assignee/number inference and is marked as such.

2a. Legal framework applied (keyed to the 2010‑09‑03 priority date)

Because the '934 claims priority to 2010‑09‑03 (and the patent itself records this as an assumption, not an adjudicated fact), the § 102 categories split as follows:

  • § 102(a)/(b) art — references published before 2010‑09‑03 (or more than one year before filing for § 102(b)). This is the only category that can properly anticipate the '934 claims on the current priority record. Nearly every retrieved reference falls here.
  • § 102(e) candidates only — the three retrieved documents dated after 2010‑09‑03: US 2010/0259579 (Wu, Oct 14, 2010), US 2010/0289847 (Ishizawa, Nov 18, 2010), and US 8,678,541 (Uchiyama, Mar 25, 2014). These could only be prior art under § 102(e) if their U.S. filing dates predate 2010‑09‑03, which I have not verified. On their face, they post‑date the priority date and are presumptively NOT prior art.

2b. Relevance ranking (best effort, explicitly provisional)

Tier 1 — Most relevant; these are the references a validity challenge would lead with.

These are all Seiko Epson references in the same cartridge/terminal/memory space, and several are the named inventor Asauchi's own earlier applications (self‑citations that the examiner nonetheless had to distinguish):

Reference Why it is Tier 1 Potential § 102 target Confidence
US 2009/0262161 A1 (Nishihara), Oct 22, 2009 Same assignee family and era; a Epson cartridge‑detection‑adjacent application published ~11 months before the '934 priority date. A § 102(a)/(b) reference on its face. Independent cartridge and apparatus claims (the "printing material cartridge … attachable to a cartridge attachment unit" claim and the apparatus claim), if it discloses multi‑terminal contact/attachment detection. Not verified. Low‑moderate — content not retrieved
US 2007/0092270 A1 (Inukai), Apr 26, 2007 Epson liquid‑container/attachment technology, comfortably pre‑priority → § 102(b) if published >1 yr before. Cartridge + apparatus claims; possibly the attachment‑detection concept. Low‑moderate — content not retrieved
US 2002/0112878 A1 (Ishizawa et al.), Aug 22, 2002 Earliest Ishizawa Epson entry in the list; >8 years pre‑priority, so § 102(b). The Ishizawa line recurs (also US 2009/0237439, US 2010/0289847), suggesting it is the family the examiner treated as closest art on the container/contact side. Cartridge claims (container + electrical contact with the apparatus). Moderate on dating; disclosure not verified
US 2009/0237439 A1 (Ishizawa et al.), Sep 24, 2009 Same family lineage, published ~11 months pre‑priority. Cartridge/apparatus claims. Low‑moderate — content not retrieved
US 2008/0259135 A1 (Asauchi et al.), Oct 23, 2008 The inventor's own earlier application. Because it shares an inventor, it is a § 102(a) reference but cannot be § 102(e) art against the '934 (common ownership/inventorship considerations); it is primarily an obviousness (§ 103) and double‑patenting concern rather than a pure § 102 anticipation. Most likely the broad "memory device + terminals on cartridge board" concepts. Moderate on provenance; disclosure not verified

Tier 2 — Same field, broad container/contact disclosures; anticipatory only in theory.

Reference Note Potential § 102 target Confidence
US 5,138,344 (Ujita), Aug 11, 1992 — "Ink jet apparatus and ink jet cartridge therefor" The oldest U.S. reference in the list. Confirmed via NCBI/PubMed patent record as an ink‑jet cartridge/apparatus patent with 10+ forward citations. It is a cartridge‑architecture reference, predating ink‑level sensing and chip terminals by a decade. At most the preamble‑level "printing material cartridge attachable to a cartridge attachment unit" concept. It cannot reach the two‑row/nine‑terminal/four‑corner detection architecture. High that it lacks the distinguishing limitations
US 2003/0002080 A1 (Asauchi), Jan 2, 2003 Inventor's own early application; § 102(b) by date. Likely cartridge/contact basics; § 102(e) unavailable due to common inventorship. Low — content not retrieved
US 2007/0126770 A1 (Asauchi), Jun 7, 2007 and US 2007/0149044 A1 (Asauchi), Jun 28, 2007 Same — self‑citations, § 102(b) by date. Cartridge/memory‑terminal concepts. Low — content not retrieved
US 2009/0085939 A1 (Asauchi), Apr 2, 2009 Same. Cartridge/memory‑terminal concepts. Low — content not retrieved
US 2006/0238558 A1 (Hatasa et al.), Oct 26, 2006 § 102(b) by date; likely ink‑supply/liquid‑container subject matter. At most container‑level claims. Low — content not retrieved
US 2007/0002087 A1 (Matsui et al.), Jan 4, 2007 § 102(b) by date. Unknown. Low — content not retrieved
EP 1 800 872 A, Jun 2007 EPO counterpart in the same era; likely an Epson liquid‑container/cartridge family member. Foreign counterpart; § 102(a)/(b) by date. Low — content not retrieved
WO 02/40275, May 2002 Pre‑priority PCT; number pattern is consistent with a Seiko Epson ink‑cartridge publication. Cartridge/apparatus claims at a high level. Low‑moderate — content not retrieved
WO 2006/025575, 2006 Pre‑priority PCT. Unknown. Low — content not retrieved

Tier 3 — Japanese, Chinese and older European documents. All of JP 03‑284953; JP 06‑155758; JP 06‑262771; JP 2002‑198627; JP 2002‑273900; JP 2003‑300333; JP 2005‑007893; JP 2005‑119228; JP 2005‑326779; JP 2006‑297826; JP 2007‑121551; JP 2007‑168078; JP 2007‑196664; JP 2009‑241591; JP 2009‑274438; CN 1990255; CN 100373163; CN 101486272; EP 0440261 A are pre‑priority on their faces and therefore facially available as § 102(a)/(b) art. Their numbers/dates place them in the printing/apparatus field, and the JP 2005–2009 entries cluster around the Epson cartridge/holder era. I did not retrieve their disclosures and will not characterize them. In a real invalidity analysis, JP 2007‑168078, JP 2009‑274438 and JP 2009‑241591 in particular warrant full‑text review first, because (i) their dates sit immediately before the 2010‑09‑03 priority date and (ii) Epson's own recent Japanese filings frequently appear in this citation list.

Tier 4 — Post‑priority; flag as likely non‑art.

  • US 2010/0259579 A1 (Wu), Oct 14, 2010 — ~6 weeks after the priority date.
  • US 2010/0289847 A1 (Ishizawa et al.), Nov 18, 2010 — ~2.5 months after.
  • US 8,678,541 (Uchiyama), Mar 25, 2014 — issued nearly four years after the priority date.

Neither of these can anticipate the '934 unless its underlying U.S. filing date predates 2010‑09‑03 (§ 102(e)) — and for US 8,678,541 that is implausible on its face. These are most likely listed as background art or as § 102(e)/§ 103 candidates during the 2014 prosecution, not as § 102(b) art.

2c. The limitation that decides anticipation

Whatever the claims literally say, the previously generated sections of this file (grounded in the patent's own specification) establish that the distinguishing architecture of the '934 is:

nine terminals in two staggered rows; five memory terminals (reset 220, clock 230, VDD 260, GND 270, data 280) with their contact portions clustered in a central "first area"; four attachment‑detection terminals (210, 240, 250, 290) with contact portions at the two ends of each row, i.e. at the four corners of a trapezoidal "second area" encompassing the first area; the first‑row detection pair not tied to any fixed voltage but series‑chained across N ≥ 2 cartridges; the second‑row detection pair shared with the piezo remaining‑ink sensor.

No reference on the retrieved list can be shown, from what I retrieved, to disclose that combination. For a § 102 anticipation finding against new claim 1 (circuit board) or claim 7, a reference would need to show all of: (i) a cartridge board memory plus detection terminals; (ii) the two‑row layout; and (iii) the four‑corner placement. The Tier 1 references are the only plausible places to look for (i) and (ii); (iii) is where I would expect the '934 to survive. That is consistent with the patent having issued over this record in 2016.


3. What I could not do (explicit gaps)

  1. Verbatim claim text — still not retrieved. Without it, no defensible § 102 anticipation conclusion is possible.
  2. The truncated U.S. citation entries between US 5,138,344 and US 8,678,541, and any foreign citations after WO 2006/025575.
  3. Reference disclosures and examiner's § 102/§ 103 rejections — I did not retrieve the file wrapper (Office actions, examiner's reasons for allowance), which would tell you which references the examiner actually applied and how. That is the single highest‑value next document to pull from PatentCenter.
  4. Section 102 vs. 103 — a large block of this list (the Asauchi self‑citations and the Epson JP/EP family members) is more naturally § 103 combination material than § 102 anticipation art, since none of them, so far as retrieved, discloses the whole combination.

4. Bottom line

  • The cited art for US 9,370,934 is a Seiko Epson‑dominated list: the inventor's own earlier U.S. applications (2003/0002080; 2007/0126770; 2007/0149044; 2008/0259135; 2009/0085939 — all Asauchi), other Epson cartridge/contact filings (Ishizawa 2002/0112878 and 2009/0237439; Inukai 2007/0092270; Hatasa 2006/0238558; Matsui 2007/0002087; Nishihara 2009/0262161), one Canon ink‑jet cartridge patent (US 5,138,344, Ujita, Aug 11, 1992), one pre‑priority PCT (WO 02/40275), and ~16 JP/CN/EP foreign documents whose disclosures I did not retrieve.
  • On the face of the record, only the pre‑2010‑09‑03 references are § 102(a)/(b) prior art. The Wu, Ishizawa‑2010 and Uchiyama documents post‑date the priority date and are presumptively not prior art.
  • I cannot name a single reference on this list that anticipates any specific claim of the '934, because (a) I do not have the claim language, and (b) I have not verified any reference's disclosure. My best assessment is that the four‑corner/two‑row/ungrounded‑first‑row combination—not the generic "cartridge with a memory chip"—is where anticipation would fail, and that the Tier 1 references are the ones to read in full.
  • Two contradictions in this file remain unresolved and I am not papering over them: the task header's date (April 26, 2026) conflicts with the system date (Sep 30, 2026) and with the August 2026 ITC events cited earlier; and the claim‑text gap flagged in the earlier sections persists here.

Generated 9/30/2026, 7:35:09 PM

Obviousness

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

✓ Generated

I'll build on the Prior Art section, but first I need to close the two gaps that section itself flagged: the missing verbatim claim text and the truncated citation list. Let me try to retrieve both.

I now have verbatim claims 1–11. Let me retrieve the remaining claims (the independent cartridge/adaptor/apparatus claims) and close the truncated citation list.

I have verbatim granted claims 1–11 and a critical new fact (the pre-grant publication's broader claim set). Let me get the remaining granted claims and the full citation table.

I ran out of tool budget before I could re-pull the full citation table, but I did retrieve the verbatim granted claims — which materially changes two things the Prior Art section had to guess at. Building on that section rather than repeating it.


Obviousness Analysis under 35 U.S.C. § 103 — US 9,370,934 B2

0. Corrections to the earlier sections (read before relying on them)

New verbatim claim text retrieved. The Claims section of the granted patent is available at https://patents.justia.com/patent/9370934. I retrieved claims 1–11 verbatim. Two previously-flagged uncertainties are now resolved, and one earlier reconstruction is wrong:

Prior-section statement Status now
"⚠️ I do not have verbatim claim text" (Summary §4; Prior Art §2) Resolved for claims 1–11. Full text below.
"Claim 7 — Independent (likely the printing material cartridge or the printing apparatus)" (Summary §4) ❌ CONTRADICTED. Claim 7 is dependent on claim 1: "The circuit board according to claim 1, wherein two contact portions placed at both ends of the second row are connectable to an electric device, and the electric device is a resistance element installed in the circuit board."
"Claim 1 — … comprising: a memory device; plural first terminals…" (Summary §4) Partially contradicted. Granted claim 1 does not positively recite a memory device. It recites terminals "through which a power source voltage and signals for operating a memory device are supplied." The memory device itself is added only by claim 11 ("further comprising the memory device").

Date contradiction, still unresolved. The task header says April 26, 2026; my clock reads 2026‑09‑30; the accumulated work product cites an ITC final determination dated 2026‑08‑13 and a Federal Register notice of 2026‑08‑18. These cannot all be true. It does not affect the § 103 analysis (nothing turns on post‑2026 dates), but it remains live.

Unresolved gap carried forward: I could not confirm whether the granted patent contains claims 12 and beyond (the pre‑grant publication US 2014/0307031 A1 contained at least 61 claims, including independent cartridge, adaptor and printing‑apparatus claims — e.g. claim 31 adaptor, claim 46 apparatus, claim 61 the N‑cartridge series/parallel detection claim). The ITC's asserted set for the '934 was {1, 7, 8, 10} — all within claims 1–11. That is consistent with but does not prove an 11‑claim patent. If claims 12+ exist, they are unanalyzed here.


1. The claim‑1 element set (verbatim, decomposed)

Claim 1, as granted:

"A circuit board electrically connectable to a plurality of apparatus‑side terminals of a cartridge attachment unit of a printing apparatus, comprising: a plurality of first terminals through which a power source voltage and signals for operating a memory device are supplied from the printing apparatus; and a plurality of second terminals to be used for detecting connection conditions between the plurality of apparatus‑side terminals and the circuit board, wherein the plurality of first terminals have a plurality of first contact portions that get in contact with corresponding apparatus‑side terminals, the plurality of second terminals have a plurality of second contact portions that get in contact with corresponding apparatus‑side terminals, the plurality of first and second contact portions are arranged so as to form a first row and a second row, and four contact portions among the plurality of second contact portions are placed at both ends of the first and second rows, respectively."

El. Limitation Character
1.1 Circuit board electrically connectable to apparatus‑side terminals of a cartridge attachment unit of a printing apparatus Preamble / intended use
1.2 Plural first terminals — power + memory‑operating signals Functional, generic
1.3 Plural second terminals — for detecting connection conditions between the apparatus terminals and the board Functional, generic
1.4 / 1.5 First and second terminals have contact portions Structural, generic
1.6 First and second contact portions arranged to form a first row and a second row Layout
1.7 Four of the second contact portions placed at both ends of the first and second rows, respectively The point of novelty

Dependent claims that matter:

  • Claim 7 (in the GEO): second‑row end contact portions connectable to an electric device that is a resistance element installed in the circuit board.
  • Claim 8 (asserted, then withdrawn): first terminals = ground, power (different voltage than ground), clock, reset, data; two first contact portions in the first row and three in the second row.
  • Claims 2–6, 9, 10: ungrounded first‑row pair; ground terminal centered in second row; ≤VDD on row 1 / ≤VHV on row 2; first and second inspection pulse signals; overvoltage on the first‑row pair with inspection‑signal high level below the overvoltage; inter‑row spacing asymmetry; attachment to a unit comprising a print head.

Structural observation for the § 103 case: claim 1 is broad and layout‑only. It does not recite the memory device, does not recite voltages, does not recite ungrounded terminals, and does not recite the trapezoid or the "first area / second area" formulation (those appear in the publication's second‑generation independent claims, not in granted claim 1). The entire inventive weight of granted claim 1 rests on element 1.7.


2. Governing law and the person of ordinary skill

Pre‑AIA vs. AIA. US 14/319,609 was filed 2014‑06‑30 — after the AIA's 2013‑03‑16 changeover — but is a continuation claiming 2010‑09‑03 priority. If every claim is supported by the 2010 priority document, pre‑AIA §§ 102/103 govern. This is not a formality: it changes (a) the prior‑art categories, and (b) whether pre‑AIA § 103(c) disqualifies commonly‑owned art (see §6 below). Verify the AIA/transition status from the file wrapper before relying on any ground below.

POSITA. Given the field (off‑carriage large‑format inkjet cartridge/holder electrical interfaces), a POSITA would be someone with a bachelor's degree in mechanical or electrical engineering and roughly 2–4 years of experience designing inkjet cartridge electrical interfaces, or equivalent. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), governs.

Effective date for art. Most cited references on the Prior Art section's list published before 2010‑09‑03, making them available at minimum under pre‑AIA § 102(a) and — for those published more than a year before the earliest US filing in the chain — under § 102(b). Either suffices for § 103.


3. The prior‑art universe, re‑sorted by what each reference can supply

The Prior Art section established the list but (correctly) refused to characterize disclosures it had not read. Re‑sorting the list functionally makes the combination logic visible. All buckets are hypotheses to be tested against the references' actual text.

Bucket What claim 1 needs Candidate references (from the earlier citation list) Caveat
A — cartridge/board with memory + multi‑terminal interface Elements 1.1–1.5 US 2002/0112878 (Ishizawa); US 2009/0237439 (Ishizawa); US 2003/0002080, US 2007/0126770, US 2007/0149044, US 2008/0259135, US 2009/0085939 (all Asauchi); US 2006/0238558 (Hatasa); US 2007/0002087 (Matsui); US 5,138,344 (Ujita); WO 02/40275; EP 1 800 872 Disclosures not retrieved.
B — attachment/presence detection via cartridge terminals Element 1.3 + the purpose of 1.7 US 2009/0262161 (Nishihara); US 2007/0092270 (Inukai); plus applicant‑admitted prior art (AAPA) Disclosures not retrieved; AAPA is authoritative.
C — remaining‑ink sensor terminals shared with detection Dependent scope (claims 2, 7 in spirit) AAPA; US 2010/0289847 (Ishizawa) and US 2010/0259579 (Wu) are post‑priority → § 102(e) only § 102(e) art is disqualified for § 103 if commonly owned (see §6).
D — two‑row / staggered contact geometry Element 1.6 US 5,138,344; US 2008/0259135; the JP/CN/EP group Disclosures not retrieved.

Two AAPA admissions in the specification are the single most valuable § 103 material in the file, because they are statements by the applicant, not third‑party art that must be authenticated:

  1. "A technology to detect attachment conditions of the printing material cartridges has been used." — and "attachment conditions have been commonly detected by the use of one or two of many terminals on the cartridge."
  2. "attachment conditions of cartridges are detected by sending signals different from those for detecting the amount of remaining ink to the remaining ink sensor installed in the ink cartridge." — plus the admitted pull‑up/pull‑down resistance detection schemes and the admitted failure mode of keeping a detection terminal at a fixed voltage (grounded detection terminal + apparatus terminal bearing ground ⇒ false "attached").

AAPA cannot be the only basis for a § 103 rejection, but it supplies the motivation, the known problem, and the known solutions for combining the Bucket A/B/C/D references.


4. Proposed grounds of rejection (screening‑level)

Ground 1 — Claim 1 over Ishizawa '878 (or Asauchi '135 / Hatasa '558) in view of Nishihara '161 or Inukai '270, further in view of AAPA

  • Bucket A reference supplies the cartridge circuit board with a memory device and a multi‑terminal interface (1.1–1.5).
  • Bucket B reference supplies detecting cartridge attachment/contact through one or more cartridge terminals (1.3, and the purpose of 1.7).
  • Motivation: both are in the identical field (inkjet cartridge/holder electrical interface), the problem is the same (verify the cartridge is properly seated and its memory‑device terminals are contacting), and the specification itself concedes that terminal‑based attachment detection was conventional. Under KSR, combining a known detection function onto a known terminal array is "the predictable use of prior art elements according to their established functions."
  • Weakness: does the combination reach element 1.7 — four second contact portions at the four ends of two rows? Bucket B art appears to disclose one or two detection terminals (per AAPA). This ground wins or loses on that element alone.

Ground 2 — Element 1.7 as an obvious design choice under KSR ("finite number of identified, predictable solutions")

This is the ground a challenger should lead with, because it does not depend on finding a reference that literally shows four detection contacts.

  • Once a POSITA decides to verify contact reliability of a cluster of memory‑device terminals (1.2) using peripheral detection terminals (1.3), the detection envelope is maximized by placing the detection contacts at the outermost extremes of the cluster. Four contacts at the four row‑ends is the natural, and essentially only, way to bound the cluster in two dimensions.
  • The specification supplies the motivation in the applicant's own words: the detection terminals farthest from the ink supply outlet are the ones displaced most when the cartridge tilts, and the cartridge is expected to tilt in large‑format printers. A POSITA seeking a detection envelope robust to tilt would predictably select the extremes.
  • The change from "one or two" detection terminals (admitted) to four is a quantitative, not qualitative, change with a predictable benefit (better coverage), and no new result is obtained.

Ground 3 — Claim 8 (five memory terminals; two in row 1, three in row 2)

  • A five‑signal non‑volatile memory interface — reset, clock, data, power, ground — is the archetypal serial EEPROM interface and is disclosed or rendered obvious by essentially any Bucket A reference.
  • Splitting five terminals 2/3 across two staggered rows is a routine layout choice driven by board real estate and by keeping the ground terminal central (the specification itself states the ground terminal is centered "to prevent the plurality of second contact portions from being connected to a ground terminal due to foreign matters" — i.e., a recognized, solvable design concern).
  • Claim 8 adds no structural feature that is not a predictable arrangement of known terminals.

Ground 4 — Claim 7 (the GEO claim) is the weakest claim in the patent

Claim 7 differs from claim 1 only in specifying that the electric device across the second‑row detection contacts is "a resistance element installed in the circuit board."

  • A resistor is the most generic possible "electric device," and the AAPA expressly admits attachment detection by connecting a cartridge‑side detection terminal to a first fixed voltage and the apparatus side to a second fixed voltage via a resistance (and the mirror‑image pull‑up/pull‑down arrangement).
  • Therefore, if claim 1 is invalid, claim 7 falls with essentially zero additional reasoning: "the substitution of one known element for another to obtain its predictable results" (KSR).
  • Practical significance: because the ITC's general exclusion order covers claims 1 and 7, the invalidity exposure of the GEO is bounded by claim 1 and a trivial dependent. This cuts for a defendant: there is no deep, separately‑defensible claim 7 to fall back on — if claim 1 falls.

Ground 5 — Claims 2 and 3 (ungrounded first‑row pair; ground centered in second row)

  • The specification concedes the reason for the ungrounded pair: "if the attachment detection terminal on the printing apparatus side bears a ground voltage from any cause, the system may erroneously identify a non‑attached cartridge as attached." A rejection can be framed as: a known defect in a known detection scheme + an obvious remedy (remove the fixed‑voltage connection) ⇒ § 103.
  • Similarly, centering the memory ground terminal in the second row (claim 3) is a predictable arrangement to reduce foreign‑matter shorting to surrounding detection contacts — the specification says as much, and the direction of foreign‑matter ingress ("from the top down … and from the outside inward") supplies the rationale.

Ground 6 — Claims 4–6, 9, 10

  • Selecting detection voltages from already‑available rails (VDD for the logic side; VHV — the print‑head drive voltage — for the high side) is a routine power‑supply design choice, and claim 4 recites no more than "no higher than" each rail.
  • Setting the inspection pulse's high level below the overvoltage threshold (claim 6) is likewise a routine constraint to avoid false overvoltage trips — again, the specification states the reason.
  • Claim 9 (outermost row‑1 spacing > outermost row‑2 spacing) is a mathematical consequence of the staggered two‑row layout, not a separate inventive act.
  • Claim 10 (board "to be attached to a cartridge attachment unit … that comprises a print head") is a statement of intended environment.

5. Motivation to combine — the affirmative case

A challenger's motivation narrative is unusually strong here, on four independent legs:

  1. Same field of endeavor and same problem. Every Bucket A/B reference cited is an inkjet printing‑material container/contact reference. No KSR "analogous art" fight is available to the patent owner.
  2. Common ownership and a common inventor. A large block of the cited art is Seiko Epson's, and five references name Asauchi as inventor — the same Asauchi who is the '934's first‑named inventor. An inventor's own prior work is the paradigm "reason to modify."
  3. A stated, known problem with a known failure mode. The specification frames the invention as a response to tilt‑induced poor contact in large‑format printers and to false positives from grounded detection terminals. Both are conceded to be pre‑existing problems.
  4. KSR "predictable solutions." Element 1.7 is a selection from a small, enumerated set of ways to place detection contacts around a terminal cluster; the benefit (maximized detection envelope) is linear and predictable.

6. Where the attack fails — the patent owner's defenses

A. The element‑1.7 gap is real and I have not closed it. On everything I retrieved, no reference on the cited list is shown to disclose four second contact portions placed at both ends of two rows. The examiner allowed the claims over this exact record in 2016. Until Nishihara '161, Ishizawa '878 and the JP references are read in full, Grounds 1–2 are arguments, not evidence.

B. Pre‑AIA § 103(c) disqualification is a genuine shield. If the '934 is governed by pre‑AIA § 103, subject matter that qualifies as prior art only under § 102(e), (f) or (g) and that was commonly owned (or subject to an obligation of assignment to the same person) at the time the invention was made is disqualified for § 103. That would knock out a substantial part of the Epson‑cited art — including, notably, the post‑priority‑date references (US 2010/0259579 (Wu); US 2010/0289847 (Ishizawa); US 8,678,541 (Uchiyama)), which the Prior Art section already flagged as presumptively non‑art. The references that survive § 103(c) are the ones published more than a year before the critical date — i.e., the printed publications (US 2002/0112878; US 2007/0092270; US 2008/0259135; US 2009/0085939; US 2009/0237439; US 2009/0262161; and the JP/CN/EP group). Any § 103 case must be built on those, not on the Asauchi self‑citations relied on as § 102(e) art.

C. AAPA limits. The specification's admissions are powerful for motivation, but an examiner cannot reject claim 1 on AAPA alone; a real reference must supply element 1.7.

D. Objective indicia. Epson can point to (i) commercial success and an ITC domestic‑industry finding on its own cartridges, and (ii) copying by the aftermarket respondents in Inv. No. 337‑TA‑1452. Copying is weak evidence, and both require a nexus to element 1.7 specifically. But they are not nothing, and they are more credible here than in most § 103 fights because the accused products are cartridges designed to mate with the claimed board.


7. Vulnerability ranking

Claim Vulnerability Reason
7 High Claim 1 + a resistor; the resistance‑based detection scheme is AAPA
8 High Standard 5‑signal memory interface; 2/3 row split is routine layout
3 Mod‑High Centered ground terminal; rationale conceded in the specification
2 Mod‑High Removing a fixed‑voltage tie to cure a conceded false‑positive
1 Moderate — the whole case turns here Element 1.7 is the only non‑routine limitation, and it is vulnerable to a KSR "predictable solution" attack rather than a § 102 blowout
9, 10 Mod‑High Geometric consequence / intended use
4–6 Moderate Routine voltage selection with a conceded rationale

Bottom line: US 9,370,934's § 103 exposure collapses onto element 1.7 of claim 1. Break that element and the GEO's coverage (claims 1 and 7) goes with it; fail on that element and every other claim in the asserted set is a routine dependent that will not save a defendant.


8. What must be verified before any of this is filed

  1. Read the references. In priority order: US 2009/0262161 (Nishihara) and US 2007/0092270 (Inukai) (Bucket B); US 2002/0112878 and US 2009/0237439 (Ishizawa, Bucket A/D); then JP 2007‑168078, JP 2009‑274438, JP 2009‑241591 — the Prior Art section flagged these three as the highest‑value unread references because their dates sit immediately before the priority date and Epson's own filings cluster there.
  2. Retrieve the file wrapper (PatentCenter, application 14/319,609): which references did the examiner actually apply, and on what rationale? That is the single highest‑value document and the fastest way to find the stated reason for allowance.
  3. Confirm the AIA/transition status and, if pre‑AIA, perform the § 103(c) common‑ownership screen on every reference before relying on it.
  4. Confirm the granted claim count and whether claims 12+ exist (unresolved above). If the granted patent retains cartridge/adaptor/apparatus independent claims from the publication, they need their own § 103 analysis — the publication's claim 61 (N‑cartridge series/parallel detection) in particular has no counterpart in claims 1–11.
  5. Re‑verify the ITC posture, given the unresolved date conflict in this file: the earlier sections report a GEO issued 2026‑08‑13 covering claims 1 and 7, with claims 8 and 10 terminated on 2026‑01‑20. Secondary Chinese‑language reporting independently corroborates the claims 1 and 7 finding (toutiao.com/w/1873489783526403). Any invalidity challenge must be timed against the resulting § 315(b) window.

Sources newly used in this section: Justia, US 9,370,934 claims · Justia, US 2014/0307031 A1 (pre‑grant publication claims 31, 42–61) · Google Patents, US9370934B2 · PatentLeaderboard, Shuichi Nakano · corroborating ITC‑outcome report: https://www.toutiao.com/w/1873489783526403/. Reference disclosures for the cited art remain unretrieved; the truncated U.S. citation gap between US 5,138,344 and US 8,678,541 (flagged in the Prior Art section) remains unfilled.

Generated 9/30/2026, 7:42:02 PM

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