Invalidity dossier
US 9420212
Added 9/25/2026, 6:48:59 PM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for this specific patent number across USPTO and CAFC 2026 docket sources.
Let me search for additional specifics on the claims and any 2026 appellate activity.
Let me get the actual claim language and check for 2026 appellate dockets.
US Patent 9,420,212 (US9420212B2) — Analyst Summary
Search scope note: I searched for the literal identifier "9420212" / "US 9,420,212". Several results were noise from different patents sharing the "212" suffix (e.g., US 7,454,212 "OFDMA with Adaptive Subcarrier-Cluster Configuration," US 8,638,728, US 7,385,949). I have excluded those and report only material tied to US 9,420,212.
Bibliographic data
| Field | Value |
|---|---|
| Patent number | US 9,420,212 B2 |
| Title | Display apparatus and video processing apparatus |
| Inventors | Toshiyuki Kurita (Yokohama, JP); Hitoaki Owashi (Yokohama, JP) |
| Assignee (as printed) | Hitachi Maxell, Ltd., Osaka (JP) |
| Original assignee | Hitachi Maxell Ltd (application filed by) |
| Current assignee (per Google Patents) | Maxell, Ltd. |
| Application no. | 12/260,410 |
| Filing date | October 29, 2008 |
| Issue/publication date | August 16, 2016 |
| Priority | JP 2007-306750, filed November 28, 2007 |
| Pre-grant publication | US 2009/0135307 A1 (May 28, 2009) |
| Claims / drawings | 6 claims, 9 drawing sheets |
| Attorney/agent | Baker Botts L.L.P. |
| Patent term adjustment | 1,245 days (printed on the face) |
| Adjusted expiration (per Google Patents legal status) | 2032-03-27 |
Sources: Google Patents page for US9420212B2; the patent's own PDF hosted at docketalarm (Apple IPR exhibit) confirming front-page data; and FreePatentsOnline family record for the continuation (US 11,451,861) confirming the priority chain.
Assignment chain (per Google Patents reels): Hitachi, Ltd. (2008) → Hitachi Consumer Electronics Co., Ltd. (2013) → Hitachi Maxell, Ltd. (2014) → Maxell, Ltd. (Jan 2018) → Maxell Holdings, Ltd. via merger (2021) → Maxell, Ltd. via change of name (Dec 2021).
Abstract (verbatim)
"While presenting on a display apparatus videos of high picture quality obtained from portable video processing apparatuses such as a camera and a cellular, it is possible to communicate with the Internet and/or a home network. A display apparatus includes a first radio communication unit capable of receiving video information by radio from an external video processing apparatus, a second radio communication unit capable of connecting by radio to a network, and a control unit for controlling assignment of connection by radio transmission for each of the first and second radio communication units. The control unit assigns connection of the first radio communication unit with higher priority and controls the assignment of the transmission rate such that the transmission rate between the first radio communication unit and the external video processing apparatus is more than that between the second radio communication unit and the network."
Plain-language overview of the independent claims
⚠️ Uncertainty flag: I was not able to retrieve the verbatim text of claims 1–6 from an authoritative source within this search. The overview below is reconstructed from (a) the abstract, (b) the "Summary of the Invention" in the specification, and (c) claim-construction language quoted in a W.D. Tex. filing referencing the '212 patent. Treat exact claim wording as unverified.
The patent presents two aspects, corresponding to two independent claims:
1. Independent claim directed to a display apparatus. A display apparatus contains two separate radios:
- a first radio communication unit that receives video information wirelessly from an external video processing apparatus (e.g., a camera or phone), and
- a second radio communication unit that connects wirelessly to a network (Internet / home network),
- plus a control unit that controls the assignment of the radio transmission for each unit. The control unit gives higher priority to the first radio communication unit and sets the transmission rate to the external video processing apparatus higher than the rate to the network.
The claim-construction excerpt from the Texas filing indicates the independent claim(s) also recite a user-indication limitation — roughly: "wherein the control unit … the external video processing apparatus[/display apparatus] … when a user issues an indication to receive[/transmit] video information by using the first radio communication unit from the video processing apparatus[/to the external display apparatus] … communication unit." In other words, the priority/rate reassignment is at least in one embodiment triggered by a user command to receive/transmit video over the first radio.
2. Independent claim directed to a video processing apparatus (the mirror image). A video processing apparatus contains:
- a first radio communication unit that transmits video information wirelessly to an external display apparatus, and
- a second radio communication unit that connects wirelessly to a network,
- plus a control unit that assigns radio transmission between them, giving the first unit higher priority and a higher transmission rate than the second unit's network link.
Dependent claims (claims 2–6, unverified wording): Based on the specification, they would narrow the above with features such as: variable control of the modulation/demodulation scheme, frequency band, and/or number of carriers (see the "scheme 1 = 17 Mbps vs. scheme 2 = 5 Mbps" example in FIG. 9); band-splitting/allocation across multiple fixed modems (FIGs. 4, 8, 11); and/or MIMO-based rate control.
Core inventive concept (plain language): When a small portable device (camera/phone) streams high-quality video to a display over a wireless link while that same device/display is also wirelessly connected to the Internet/home network, the limited radio spectrum is shared by giving video traffic priority — so the video link gets the wider band/higher rate (17 Mbps) and the network link gets the narrower band/lower rate (5 Mbps). Because network data (updates, non-video info) is exchanged far less frequently than video, the user loses little network performance while the video picture quality does not degrade.
Litigation and PTAB activity
From the Google Patents page and cross-checked dockets:
- W.D. Tex. — Maxell, Ltd. v. Lenovo Group Ltd., Lenovo (United States) Inc., and Motorola Mobility LLC, Civil Action No. 6:21-cv-01169 (identified as the "Critical" Texas Western District case on the patent page). A redacted petition document lists the '212 Patent ("the '212 Patent") among eight Maxell-asserted patents and shows claim-construction terms for it.
- N.D. Ill. — case 1:22-cv-00256 (listed as a district court filing tied to this patent's family).
- W.D. Tex. — Maxell, Ltd. v. Apple Inc., 6:20cv646, filed July 16, 2020 (Judge Alan D. Albright), in which the '212 patent appears.
- PTAB (related continuations, not the '212 itself): IPR2021-00400 (Apple) and IPR2024-00906 (Samsung) concern US 10,129,590, which is a continuation of 12/260,410 (the '212 patent). A reexamination 90/014,651 of the '590 patent also traces back to 12/260,410 → US 9,420,212. Both confirm the '212 patent's role as the family root.
Continuation family descending from the '212 patent (per Google Patents priority links and FPO): 15/208,886 → US 10,129,590; 15/891,085 → US 10,244,284; 16/269,662 → US 11,451,860; 16/269,724 → US 11,451,861; 16/713,182 → US 10,958,971; 16/738,059 → US 11,509,953; 17/568,166 → US 11,445,241; 17/967,092 → US 12,143,665; 18/905,664 → US 12,418,692.
CAFC 2026 docket — explicit finding
I did not locate any Court of Appeals for the Federal Circuit (CAFC) docket in 2026 naming US 9,420,212. My searches for CAFC/2026 appellate activity returned only: (a) unrelated district-court and PTAB records in the same Maxell family, and (b) a NYIPLA February-2026 PTAB committee list of § 314(a) discretionary denials that contains no entry for the '212 patent.
Uncertainty note: I cannot authoritatively assert that no 2026 Federal Circuit appeal exists — absence of results in my searches is not proof of absence. If you need a definitive check, query the CAFC CM/ECF docket by the patent number and by the Maxell case captions directly, and query USPTO Patent Center / PTAB API for the application number 12/260,410 and the family members above.
Summary of confidence levels
- High confidence: bibliographic data (number, title, inventors, application no. 12/260,410, filing 2008-10-29, issue 2016-08-16, priority JP 2007-306750, assignee Hitachi Maxell/Maxell, 6 claims/9 sheets, abstract wording, 1,245-day PTA).
- Medium confidence: the plain-language content of the two independent claims (display apparatus / video processing apparatus with prioritized first-radio link over network link), reconstructed from the abstract + summary + a claim-construction excerpt.
- Low / unverified: exact verbatim wording of claims 1–6 (especially the specific user-indication limitation), and whether any 2026 CAFC appeal exists.
Generated 9/28/2026, 5:22:26 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 9420212. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US 9,420,212. Let me run several searches.
Let me dig deeper on the specific cases.
Let me check the status of the W.D. Tex. case and whether the '212 patent was asserted elsewhere (e.g., against Apple or in the ITC).
Litigation Involving U.S. Patent No. 9,420,212
Cross-check with the patent's own record: The Google Patents litigation section for US 9,420,212B2 flags exactly two U.S. district court cases (a Texas Western District Court case, 6:21-cv-01169, marked "Critical," and an Illinois Northern District Court case, 1:22-cv-00256), plus a first worldwide family suit reported through Darts-IP (family 40669376). My research below is consistent with that record — I found no additional U.S. cases asserting the '212 patent.
Case 1 — Maxell, Ltd. v. Lenovo Group Ltd., Lenovo (United States) Inc., and Motorola Mobility LLC
| Item | Detail |
|---|---|
| Plaintiff | Maxell, Ltd. (successor to Hitachi Maxell, Ltd.; patent owner of record) |
| Defendants | Lenovo Group Ltd.; Lenovo (United States) Inc.; Motorola Mobility LLC |
| Jurisdiction / Court | U.S. District Court for the Western District of Texas, Waco Division |
| Case No. | 6:21-cv-01169-ADA |
| Filing date | November 12, 2021 |
| Judge | Hon. Alan D. Albright |
| Cause | 35 U.S.C. § 271 patent infringement; jury demanded |
| Outcome / status | Closed. Docket Alarm shows the case terminated June 29, 2023, with case flags "CLOSED, PATENT, STAYED." Third-party docket compilations (ExParte) show a closure date of June 15, 2023. |
'212 patent asserted: Yes. The complaint asserted eight patents: 8,098,695; 7,577,417; 7,072,673; 7,551,209; 6,928,292; 9,420,212; 7,952,645; and 8,059,177. (Note: one secondary summary of the complaint also lists 7,199,821 — treat that list with care; the court filings and Defendants' invalidity contentions consistently list the eight patents above, including the '212.)
Procedural history relevant to the '212 patent:
- The court granted Maxell leave for alternative service on Lenovo Group Ltd. (via email to U.S. counsel or service on Lenovo (United States) Inc.), Order filed Feb. 15, 2022 (Doc. 43).
- Defendants served Final Invalidity Contentions (Sept. 19, 2022) challenging the '212 patent on prior art and § 101 grounds, and raised indefiniteness.
- The parties briefed claim construction, including a disputed term of the '212 patent: "wherein the control unit ... the external video processing apparatus[/display apparatus] ... when a user issues an indication to receive[/transmit] video information by using the first radio communication unit ..." (Maxell's Responsive Claim Construction Brief; Lenovo's Opening Claim Construction Brief).
- Motorola Mobility separately filed a declaratory-judgment action (Case 2 below) asserting that the accused Motorola products (Moto E, Edge, G, One, Razr, Z series) do not infringe claim 1 of the '212 patent, arguing that Maxell "self-contradictorily" identified Bluetooth and cellular radios as either the "first" or "second" radio communication unit.
Caveat on outcome: I could not verify from the sources retrieved the reason for closure (e.g., dismissal with prejudice, settlement, or consolidation into a later Maxell–Lenovo action). Given that a companion case, Maxell, Ltd. v. Lenovo Group Ltd., No. 6:22-cv-00334 (W.D. Tex.), was stayed pending ITC Inv. No. 337-TA-1312, and that the parallel ITC investigation 337-TA-1324 was terminated in August 2023 based on settlement, a global settlement is plausible — but I cannot state that as confirmed for the '212 patent. This should be verified against PACER/the W.D. Tex. docket before being relied on.
Case 2 — Motorola Mobility LLC v. Maxell, Ltd.
| Item | Detail |
|---|---|
| Plaintiff | Motorola Mobility LLC |
| Defendant | Maxell, Ltd. |
| Jurisdiction / Court | U.S. District Court for the Northern District of Illinois, Eastern Division |
| Case No. | 1:22-cv-00256 |
| Filing date | January 14, 2022 |
| Judge | Hon. Charles R. Norgle, Sr. (Magistrate: Hon. Beth W. Jantz) |
| Cause | 28 U.S.C. § 2201 — Declaratory Judgment of non-infringement; jury demanded by both sides |
| Outcome / status | Closed (June 15, 2023). |
'212 patent at issue: Yes. The declaratory-judgment complaint attached the '212 patent as Exhibit 10 and sought a declaration of non-infringement of the '212 patent (Count addressing the '212 patent, ¶¶ 70–76), alongside the other patents Maxell had asserted against Motorola (the '292, '673, '209, '417, '645, '177, and '695 patents). The complaint expressly noted that Maxell's earlier W.D. Tex. suit (Case 1) had been filed in an allegedly improper venue. A First Amended Complaint was filed March 4, 2022.
Related proceedings (NOT on the '212 patent — flagged to avoid confusion)
- PTAB IPR2022-01287, Motorola Mobility LLC v. Maxell, Ltd. — a Motorola Mobility IPR petition filed in 2022 arising out of the same W.D. Tex. dispute. Maxell filed the Defendants' Final Invalidity Contentions as an exhibit in this IPR. I did not confirm which patent(s) this IPR targets, so I cannot state it covers the '212 patent. Verify at the PTAB.
- ITC Inv. No. 337-TA-1324, Certain Mobile Electronic Devices (Maxell v. Lenovo/Motorola) — asserted U.S. Patent Nos. 7,199,821; 7,324,487; 8,170,394; 8,982,086; 10,129,590; and 10,244,284. The '212 patent was not asserted in this investigation. The '394 patent was terminated May 2023 (withdrawal), the '590 and '284 patents terminated March 2023 (withdrawal), and the entire investigation terminated August 18, 2023 based on settlement.
- Child/continuation patents of the '212 have been separately litigated and challenged: U.S. 10,129,590 (IPR2021-00400, Apple; IPR2024-00906, Samsung; ex parte reexamination 90/014,651) and U.S. 10,244,284 (IPR2025-00520). These proceedings concern the continuation patents, not the '212 patent itself.
- Earlier Maxell campaigns (e.g., Maxell v. Apple, No. 5:19-cv-00036 (E.D. Tex.); Maxell v. ZTE, No. 5:16-cv-00179 (E.D. Tex.); Maxell v. Huawei) asserted other Maxell patents; I found no indication that the '212 patent was asserted in them.
Bottom line
Two known litigations involve U.S. 9,420,212, both filed within two months of each other in the winter of 2021–22, both asserting/attacking the patent in the context of Maxell's smartphone campaign against Lenovo/Motorola Mobility:
- Maxell, Ltd. v. Lenovo Group Ltd., et al., No. 6:21-cv-01169-ADA (W.D. Tex.), filed Nov. 12, 2021 — Maxell's infringement suit; closed/terminated June 2023, after substantial progress (claim construction briefing, final invalidity contentions).
- Motorola Mobility LLC v. Maxell, Ltd., No. 1:22-cv-00256 (N.D. Ill.), filed Jan. 14, 2022 — Motorola's mirror-image declaratory judgment of non-infringement; closed June 15, 2023.
Both closures occurred in mid-2023, contemporaneously with the settlement-based termination of ITC Inv. No. 337-TA-1324 (August 2023), suggesting resolution as part of a broader global settlement — but I have not confirmed the disposition terms in the '212 litigation itself, and the specific dismissal mechanism should be verified on PACER.
Generated 9/28/2026, 5:22:42 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll start by checking the structured data and then hunting for any IPR/PGR filings that post-date the ODP ingest.
Let me drill into specific candidate proceedings and the Maxell/Apple and Maxell/Samsung campaigns.
Let me pin down which IPRs actually target the '212 patent and check the litigation thread.
Proceedings overview
Total AIA trial proceedings on US 9,420,212 on file: 0. The structured "PTAB proceedings on file" block reflects the USPTO Open Data Portal ingest, which returned no IPR, PGR, or CBM naming this patent — 0 active, 0 claims-invalidated, 0 claims-sustained, 0 settled, 0 institution-denied. My independent web search turned up no petition, institution decision, or Final Written Decision directed at the '212 patent either; what it did surface is an active, aggressive Maxell-family PTAB/litigation campaign against sibling and continuation patents (see "Adjacent activity," below), which is precisely why the absence here should be read as "untested, not cleared." Verification note: I could not confirm the subject patent of Motorola Mobility's 2022 Maxell IPRs (a lead worth chasing — see below), so I state expressly that I am not asserting an IPR was filed on the '212 patent. Bottom line for a defendant: there is no IPR disposition you can lean on, and equally no § 315(e)(2) estoppel shadowing the '212 art — every prior-art ground remains live for you, but you also have no free "claim 1 is dead" argument.
Proceedings
None. No AIA trial proceeding has been identified against US 9,420,212. There is no FWD to quote, no claim-level disposition, no panel, no appeal. Anything purporting to be a '212 FWD should be treated as unverified.
Adjacent activity (NOT proceedings against the '212 patent — do not cite as such)
These matter for strategy and for identifying who has already burned money attacking this family, but none of them is a determination on the '212 patent's claims. I am flagging each with its verification status.
IPR2022-01287 — Motorola Mobility LLC v. Maxell, Ltd. (subject patent unconfirmed)
- Type: Inter Partes Review
- Filed: 2022 (exact filing date not confirmed in my sources)
- Status: Unknown to me; not confirmed to involve the '212 patent
- Why it matters / lead to chase: The PTAB record for this proceeding includes, as Patent Owner Exhibit 2001 filed 2022-11-04, the "Defendants' Final Invalidity Contentions" from
Maxell, Ltd. v. Lenovo Group Ltd., Lenovo (United States) Inc., and Motorola Mobility LLC, W.D. Tex. Civil Case No. 6:21-cv-01169-ADA, which expressly include a section "INVALIDITY OF THE '212 PATENT." That proves the '212 patent was a patent-in-suit in W.D. Tex. 6:21-cv-01169 (filed 2021-11-12, Judge Alan D. Albright), and that Motorola was mounting §§ 101/102/103 invalidity attacks on it. It does not prove IPR2022-01287 itself challenges the '212 patent. Source: docketalarm PTAB docket/exhibit and W.D. Tex. 6:21-cv-01169 case summary - Defensive value: If IPR2022-01287 is a '212 IPR and reached FWD, Motorola and its privies are estopped under § 315(e)(2) as to grounds raised or reasonably raisable, and the FWD/any appeal would be the single most important document for your case. Verify first.
IPR2020-00407 — Apple Inc. v. Maxell, Ltd. (U.S. Patent 6,748,317, not '212)
- Type: Inter Partes Review
- Filed: 2020-01-13
- Status: Institution Denied (2020-08-11)
- Judge panel: John Hudalla, Lynne Pettigrew, Minn Chung, Frederick Laney, Jason Melvin (per docketalarm listing)
- Institution decision: Denied under the then-applicable NHK-Fintiv framework (parallel E.D. Tex. litigation,
Maxell, Ltd. v. Apple Inc., 5:19-cv-00036-RWS); the Board held "the efficiency and integrity of the system are best served by denying institution." Citation: Apple Inc. v. Maxell, Ltd., No. IPR2020-00407, 2020 WL 4680039 (PTAB Aug. 11, 2020). Companion denials the same day: IPR2020-00408, IPR2020-00409. - Appeal: Apple appealed to the Federal Circuit (Nos. 20-2132, -2211, -2212, -2213; 2021-1033). The panel (Judges Dyk, Wallach, Taranto) dismissed for lack of jurisdiction over non-institution decisions, 2020-10-30; Apple sought panel rehearing/rehearing en banc, opposed by the USPTO as intervenor (2021-02-03). Sources: Fed. Cir. blog copy of Intervenor's Response, RPX Insight docket
- Defensive value: Establishes Maxell's willingness to litigate institution denials all the way up, and that Apple's 2020 Maxell IPR wave was largely shut out by Fintiv — but this precedent is now largely obsolete: the Office's 2025 discretionary-denial regime (Acting Director memorandum 2025-03-26; Director Squires memorandum 2025-10-17) reallocated institution decisions to the Director. A defendant today should not assume Fintiv will block a petition the way it blocked Apple's.
IPR2024-00828 — [Samsung Electronics Co., Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) v. Maxell, Ltd. (subject patent unconfirmed; not '212 on the record I saw)
- Type: Inter Partes Review
- Filed: 2024-04-26; Instituted: 2024-11-04
- Status: Final Written Decision issued 2025-10-30 — outcome reported as "Unpatentable"; appealed
- Judge panel (per third-party docket): Jason W. Melvin, Kevin C. Trock, Neil T. Powell, Terrence W. McMillin
- Procedural color: A Sotera stipulation was filed 2024-09-12; Patent Owner requested Director Review of the institution decision (2024-11-21), which was denied (2025-01-03).
- Defensive value: Direct evidence that Samsung is successfully invalidating Maxell patents at the Board in this campaign, and that the Director Review route was unavailing for Maxell here. If this FWD covers a patent in the '212 family (e.g., a continuation), pull the FWD text for its claim-construction and art teachings.
IPR2025-01309 / -01312 / -01314 / -01315 — Samsung v. Maxell, Ltd. (second wave, 2025)
- Type: Inter Partes Review
- Filed: -01315 filed 2025-08-29; companion petitions filed in the same window
- Status: IPR2025-01315 instituted 2026-02-10 ("Trial Instituted"; panel assignment pending as of the source's last update). The others' statuses were not confirmed in my sources.
- Scope: Maxell's briefs in this wave identify ten asserted patents spanning ten families: 7,577,417; 7,952,645; 8,180,198; 8,471,950; 10,783,228; 10,812,646; 11,026,088; 11,277,650; 11,812,091; and 12,160,681. The '212 patent is not on that list. Maxell has been arguing discretionary denial hard (heavy reliance on the GenghisComm, Tesla, Tuozhu, Wilus, Audio Pod, and Murata line of decisions). Sources: Maxell discretionary-denial brief, '091 patent, Maxell discretionary-denial brief, '417 patent, IPR2025-01315 docket
- Defensive value: Shows the current front line is elsewhere in the portfolio. Note the trial-stage clock: for -01315, institution 2026-02-10 means a statutory FWD due ~2027-02 (1-year § 316(a)(11) deadline, extendable up to 6 months for good cause).
IPR2025-00942 — Coretronic Corp. v. Maxell, Ltd. (subject patent unconfirmed)
- Type: Inter Partes Review
- Filed: 2025-05-14
- Status: Terminated 2025-09-26 — Discretionary Denial (third-party docket listing panel members as Robert W. Schroeder III and Robert W. Schroeder II; that entry looked anomalous and I could not corroborate it, so treat the panel attribution as unverified)
- Defensive value: Another data point that a projector/display maker sought PTAB review of a Maxell display-related patent and was turned away on discretionary grounds. Source: Coretronic v. Maxell docket
Ex parte reexaminations (Central Reexamination Unit — not AIA trials, but central to this family)
Apple requested twelve ex parte reexaminations against ten Maxell patents, all granted; Appendix A to those requests lists the patents, request dates, grant dates, and Patent Owner Statement deadlines. Critically for this family, one of them is Reexamination No. 90/014,651 of U.S. Patent No. 10,129,590 — a direct continuation of the '212 patent (the '590 issued from application 15/208,886, which is itself a continuation of application 12/260,410, now the '212 patent). Source: EX1006, file history of Reexam 90/014,651 ('590 patent)
- Also relevant: the '590 patent was held non-infringed on summary judgment in E.D. Tex. (
Maxell, Ltd. v. Samsung Elecs. Co., No. 5:23-cv-92-RWS), a ruling Maxell has argued does not collaterally estop adjudication of the '241 patent (a different family member). Source: ITC notice, Inv. No. 337-TA-1432
Litigation context for the '212 patent itself
- W.D. Tex. No. 6:21-cv-01169-ADA —
Maxell, Ltd. v. Lenovo Group Ltd., Lenovo (United States) Inc., and Motorola Mobility LLC(filed 2021-11-12), asserting eight patents including the '212 patent among '695, '417, '673, '821, '292, '645, and '177. This is the only confirmed district-court assertion of the '212 patent I located. It is also the litigation Google Patents links to the patent, alongside N.D. Ill. No. 1:22-cv-00256. Source: Google Patents US9420212B2 litigation links - Current Maxell v. Samsung campaigns are elsewhere in the portfolio (E.D. Tex. 5:23-cv-92 and a 2025 E.D. Tex. complaint; ITC Inv. No. 337-TA-1432, instituted 2025-01-23 on U.S. Pat. Nos. 8,130,280; 11,490,004; 11,750,915; 11,509,953; 12,108,103; 11,445,241); and the E.D. Tex. appeal is at the Federal Circuit as No. 26-1111 (filed 2025-10-29; Maxell's corrected opening brief filed 2026-03-24; Samsung's response brief extended to 2026-06-26; consolidated as companion with Nos. 2026-1320 and 2026-1330). Sources: CAFC docket 26-1111, E.D. Tex. complaint (2025-04-21)
Strategic summary
Claim status: entirely untested at the PTAB. No claim of US 9,420,212 has been canceled, confirmed, or even reviewed in an AIA trial. So there is no surviving-claims list to work from — claims 1–N stand as issued and as construed by whatever district court has tackled them. The only claim-level record I found on the '212 patent is a § 112 indefiniteness fight: Lenovo contended the claims are indefinite for reciting "capability" limitations tied to a user indication (e.g., "wherein the control unit … when a user issues an indication to receive[/transmit] video information by using the first radio communication unit …"), and Maxell successfully defended against that as a claim-construction dispute in the W.D. Tex. case — Maxell's brief walks through Microsoft v. Litig. (874 F.3d 1316), Nintendo, Halliburton, and IPXL Holdings, and notes that '590 claims were amended during reexamination to add exactly this capability limitation and were still held definite. Source: Maxell's claim construction brief, W.D. Tex. 6:21-cv-01169. Defendants should assume the capability language is a live, but hard, § 112 attack — and that the PTAB has never ruled on it for this patent.
Estoppel landscape: wide open, with one caveat. Because no IPR/PGR on the '212 patent reached a Final Written Decision, no § 315(e)(2) estoppel attaches to the '212 patent at all. A defendant today may raise any § 102/§ 103 ground, before the Board or in court, without estoppel risk. Two real constraints nonetheless apply: (i) § 315(b)'s one-year clock — for a party served with a complaint asserting the '212 patent more than a year ago (e.g., Lenovo/Motorola in 6:21-cv-01169, served late 2021/early 2022), the IPR door on this patent is now closed unless they fall within a joinder or RPI exception; (ii) § 315(e)(2) estoppel from the sibling proceedings applies only to the claims/grounds those proceedings actually adjudicated — it does not reach the '212 patent's claims but can reach a parent/sibling like the '590 and thereby constrain arguments about the shared specification. The caveat: if Motorola's IPR2022-01287 (or a yet-unverified petition) does turn out to be a '212 proceeding that reached FWD, that is your estoppel and your best invalidity roadmap in one document. Confirm before relying on the "clean slate" conclusion.
Pattern signals. (1) Maxell is a serial, sophisticated enforcer — Japanese-origin (ex-Hitachi) rights holder with Mayer Brown as lead counsel, running parallel ITC § 337, UPC Germany, Tokyo District Court, and E.D./W.D. Tex. campaigns, and it litigates PTAB institution denials aggressively (Apple's 2020 appeals; Maxell's 2025 discretionary-denial briefing against Samsung). (2) The petitioners arrayed against this portfolio are the biggest names in consumer electronics — Apple (2020 IPR wave: largely Fintiv-denied, plus 12 granted ex parte reexams), Samsung (2024 and 2025 waves, at least one FWD of "unpatentable" and multiple institutes in 2026), Motorola/Lenovo (2022 IPRs tied to the very case that asserted the '212 patent), and Coretronic/Optoma (2025, denied on discretion). (3) I found no defensive aggregator — specifically no Unified Patents involvement in the '212 patent chain; the Unified Patents data on the Google Patents page is the litigation tracker link to W.D. Tex. 6:21-cv-01169, not a Unified-filed IPR. (4) The pattern of persistent challengers plus an aging, HD-video-interface patent whose family has been reexamined repeatedly means a future '212 petition is more likely than not — the patent's 2032 adjusted expiration (per the Google Patents legal-status field) leaves plenty of runway.
Recommended next steps
- Verify the '212 record directly and authoritatively before advising a client. Start with PTAB E2E / the USPTO Open Data Portal trial API (
patent/publications-style endpoints and the PTAB trial endpoint) filtered on patent number 9420212, and the Patent Center assignment/reexam tabs for any ex parte reexamination of the '212 patent itself (distinct from Reexam 90/014,651, which is on the '590 continuation). If nothing appears, the honest answer is a clean "no PTAB activity" — which is what the ODP ingest indicates. - Resolve IPR2022-01287's subject patent. Pull the petition (Paper 1/2) and Exhibit 1001 from the PTAB record. If it is the '212 patent and an FWD issued, link and quote the disposition as the centerpiece of your defense; if it settled or was denied, say so and check whether a separate Motorola/Lenovo petition exists covering the same art.
- Build the invalidity story from the unreviewed corpus, not from PTAB estoppel. Because there is no FWD, the useful artifacts are: (a) Motorola/Lenovo's Final Invalidity Contentions addressing the '212 patent (W.D. Tex. 6:21-cv-01169) — a prior-art roadmap, not a validity ruling; (b) the Apple-requested ex parte reexams in this family (Appendix A to the reexam requests lists patents, request/grant dates, and Patent Owner Statement deadlines) and the '590 reexam file history, which is the best source of claim-scope concessions and amendment-based estoppel affecting the shared specification; and (c) the IPR2024-00828 FWD ("Unpatentable," 2025-10-30) for the Board's treatment of the common disclosure.
- Watch the clock on Maxell's pending campaigns. For Samsung's 2025 wave, IPR2025-01315 was instituted 2026-02-10, so its FWD is due on or about 2027-02-10 absent a § 316(a)(11) extension; the E.D. Tex. docket control order contemplates pretrial conference 2027-08-10, and Maxell itself argued the FWD (expected "March 2027") would land near the close of expert discovery and fact discovery. If Maxell adds '212 to any complaint = a new one-year § 315(b) window opens for that defendant.
- Treat the absence of PTAB activity as a signal, not a shield. Well-asserted, 14-year-old, HD-interface patents with a decade of licensing litigation eventually attract IPRs; the fact that seven-plus defendants have attacked everything around the '212 patent but not the '212 patent itself may mean the art against it is weaker, or that challengers selected the continuation ('590) as the cheaper target. Either way, do not tell a client the patent has been "hardened" — it has simply never been stress-tested at the Board.
Generated 9/28/2026, 5:23:11 PM
Ownership chain (6)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2008-10-29 · reel 021756/0400 · Assignment
? · recorded 2013-06-12 · reel 030622/0001 · Assignment
Hitachi, Ltd.Hitachi Consumer Electronics Co., Ltd.
internal reorg
2014-09-04 · Assignment
Hitachi Consumer Electronics Co., Ltd.Hitachi Maxell, Ltd.
internal reorg
2017-10-01 · recorded 2018-01-25 · reel 045142/0208 · Assignment
Hitachi Maxell, Ltd.Maxell, Ltd.
Correspondent: Nadeen Nsouli · Mayer Brown
internal reorg
2021-11-29 · Merger
internal reorg
2021-12-03 · Change of Name
change of name only
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll research the assignment record for US 9,420,212, focusing on reel/frame data, correspondents, and litigation/asserter patterns.
Strong results. Let me pin down the specific reel/frame records for the '212 patent's own application (12/260,410) and the Maxell reorganization links.
I have enough to reconstruct the chain. A note on evidence quality up front: the reel/frame numbers and correspondents are only partially recoverable from public sources. I recovered two reel/frame entries verbatim from a certified chain-of-title statement filed in the family (the '590 continuation) and one from a recorded assignment abstract. For the remaining links I report dates and parties from Google Patents legal events / court pleadings but must flag the reel/frame as not independently confirmed.
Inventors
| Inventor | Residence (per patent) | Employer at filing | Basis |
|---|---|---|---|
| Toshiyuki Kurita | Yokohama, JP | Hitachi, Ltd. | Sole/co-assignor to Hitachi, Ltd. on Reel 021756/0400 |
| Hitoaki Owashi | Yokohama, JP | Hitachi, Ltd. | Co-assignor on Reel 021756/0400 |
Both are named on the 2008 application (12/260,410) and re-appear as inventors on the continuations (e.g., 15/208,886 → US 10,129,590, filed 2016-07-13). Their continuance onto the 2016 continuation indicates they remained within the Hitachi orbit at least through 2016.
Unusual-pattern check: No evidence that either inventor departed the assignee within 12 months of filing, and no inventor-initiated reversion. The assignment to Hitachi, Ltd. was executed contemporaneously with the 2008-10-29 filing — the normal employment-assignment pattern. No "all inventors departed" red flag.
Original assignee
Two different entities matter here, and they are frequently conflated:
- First assignee of record (2008): Hitachi, Ltd. (Tokyo). Confirmed by Reel 021756/0400 and by Maxell's own litigation statement (E.D. Tex. 5:18-cv-00034: "in 2009 Hitachi, Ltd. assigned intellectual property … to Hitachi Consumer Electronics Co., Ltd.").
- Assignee named on the issued patent (2016): Hitachi Maxell, Ltd., Osaka (JP) — i.e., the patent face and Google Patents "Original Assignee" reflect the issue-time owner, not the filing-time owner.
Line of business / products: Hitachi, Ltd. is a diversified global conglomerate (rail, energy, IT, automotive systems) that at the relevant time also sold Hitachi-brand consumer electronics (TVs, camcorders, displays). Hitachi Maxell, Ltd. (later just Maxell, Ltd.) is a public Japanese manufacturer of batteries, storage media, optical components, projectors, and consumer accessories — TSE Prime listing 6810.
Current status: Operating. Maxell, Ltd. remains an active public company (fiscal 2024 revenue ~¥125 bn; segments: energy, functional materials, optics/systems, life solutions). It has exited the consumer-electronics categories (smartphones, TVs, tablets) that its patent portfolio is asserted against. The Hitachi-side consumer-electronics IP was carved out through a series of internal reorganizations (2013 → 2014 → 2017), not a bankruptcy or fire-sale.
Assignment timeline
Chain-of-title for the family, as recorded. Where reel/frame is known I give it; where not, I say so rather than guess.
2008-10-29 (executed, contemporaneous with filing) / recorded 2008 — Reel 021756 / 0400
- Conveyance: Assignment of application for patent
- Assignor: Toshiyuki Kurita; Hitoaki Owashi
- Assignee: Hitachi, Ltd.
- Correspondent: not recovered (the certified 3.73(c) statement cites the reel/frame but not the correspondent). No recurrence flag possible for this link.
- Context: inventor-to-employer assignment (standard, on filing).
Executed ~2009 / recorded 2013-06-12 — Reel 030622 / 0001
- Conveyance: Assignment (internal corporate transfer)
- Assignor: Hitachi, Ltd.
- Assignee: Hitachi Consumer Electronics Co., Ltd.
- Correspondent: not recovered.
- Context: internal reorganization — carve-out of Hitachi's consumer-electronics IP. (Note a date discrepancy: Maxell's ZTE complaint characterizes this transfer as occurring "in 2009," while the recording date is 2013-06-12.)
2014-09-04 (executed/recorded per Google Patents legal events) — Reel NNNNNN/NNNN — not recovered
- Conveyance: Assignment
- Assignor: Hitachi Consumer Electronics Co., Ltd.
- Assignee: Hitachi Maxell, Ltd.
- Correspondent: likely Antonelli, Terry, Stout & Kraus, LLP, 1300 N. 17th St., Ste. 1800, Arlington, VA 22209 — this firm appears as correspondent on a sibling HCE→Hitachi Maxell family assignment (Plainsite record id 7265172 for US 9,204,142 / app 14/300,300), but I cannot confirm it was the correspondent on the '212's own record. Treat as probable, not established.
- Context: internal reorganization to "align its intellectual property with the licensing, business development, and R&D efforts of Maxell" (Maxell's own description, E.D. Tex. 5:18-cv-00034).
Executed 2017-10-01 / recorded 2018-01-25 — Reel 045142 / 0208 (141 pages; bulk portfolio assignment)
- Conveyance: Assignment of assignors' interest (see document for details)
- Assignor: Hitachi Maxell, Ltd.
- Assignee: Maxell, Ltd. (1 Koizumi, Oyamazaki, Otokuni-gun, Kyoto 618-8525, JP)
- Correspondent: NADEEN NSOULI, 71 South Wacker Drive, Chicago, IL 60606 — this is the Chicago headquarters address of Mayer Brown LLP. ⚑ Repeat-player flag: Mayer Brown is also lead litigation counsel for Maxell (e.g., the Maxell v. VIZIO complaint) — the same firm appears on both the assignment side and the assertion side of this portfolio.
- Context: carve-out / de-merger — the EP family record corroborates: Hitachi Maxell, Ltd. was replaced by Maxell, Ltd. "by virtue of a de-merger dated 01.10.2017." This transfer aligns with Maxell's 2017 exit from the Hitachi Group.
- Confirmation caveat: Reel 045142/0208 is documented verbatim for the sibling continuation (app 15/208,886 → US 10,129,590), whose abstract of title reads exactly this way. Given the 141-page bulk nature and the shared family, it almost certainly covers app 12/260,410 as well — but I have not seen the '212-specific abstract.
2021-11-29 (executed) / recorded 2021 — Reel NNNNNN/NNNN — not recovered
- Conveyance: Merger
- Assignor: Maxell, Ltd.
- Assignee: Maxell Holdings, Ltd.
- Correspondent: not recovered.
- Context: internal holding-company merger (EP record: merger dated 01.10.2021). Name/structural change only — no change in beneficial ownership.
2021-12-03 (executed) / recorded 2021 — Reel NNNNNN/NNNN — not recovered
- Conveyance: Change of name
- Assignor: Maxell Holdings, Ltd.
- Assignee: Maxell, Ltd.
- Correspondent: not recovered.
- Context: change of name only — the surviving entity renamed back to "Maxell, Ltd." (EP record: name change dated 01.10.2021). No title transfer of substance.
Bottom line on the record: This is a six-link, entirely intra-family chain spanning 13 years. No transfer ever leaves the Hitachi/Maxell corporate family, and no third-party shell LLC, NPE, or aggregator appears. Two reel/frame entries are confirmed (021756/0400; 030622/0001), one is confirmed for the family via the '590 (045142/0208), and three links lack an independently recovered reel/frame.
Timeline diagram
timeline
title Ownership of US 9420212
2007 : Priority JP application filed
2008 : Filed by Hitachi Ltd
: Inventors assign to Hitachi Ltd
2013 : To Hitachi Consumer Electronics
2014 : To Hitachi Maxell Ltd
2016 : Patent issues
2017 : Carve-out to Maxell Ltd
2018 : Maxell assignment recorded
2021 : Merger into Maxell Holdings
: Renamed back to Maxell Ltd
NPE / troll-pattern signals
Shell-entity transfer — NOT PRESENT. Every assignee in the chain is a named operating corporation in the Hitachi/Maxell family: Hitachi, Ltd. → Hitachi Consumer Electronics Co., Ltd. → Hitachi Maxell, Ltd. → Maxell, Ltd. → Maxell Holdings, Ltd. → Maxell, Ltd. No "IP / Licensing / Ventures / Holdings" LLC, no registered-agent-service address, no single-member Delaware/Texas LLC. Maxell Holdings, Ltd. is a genuine parent in a merger, not a shell. (Reels 021756/0400, 030622/0001, 045142/0208.)
Known asserter in the chain — NOT PRESENT (against the named lists). The current assignee, Maxell, Ltd., does not match Acacia, Marathon, IV, Wi-LAN, Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, or any Spangenberg entity. It is a publicly traded manufacturer (TSE 6810). Caveat: Maxell is a high-frequency patent plaintiff per Unified Patents' litigation tracker (multiple 2019–2025 campaigns against Apple, Samsung, Lenovo/Motorola, ZTE, VIZIO; ITC Inv. 337-TA-1432), so it is an aggressive monetizer even though it is not an NPE-list entity.
Repeat correspondent across the chain — PRESENT (weak-to-moderate). The modern portion of the chain shows correspondent continuity: Nadeen Nsouli, 71 South Wacker Drive, Chicago (Mayer Brown LLP) recorded the 2017/2018 Hitachi Maxell → Maxell assignment (Reel 045142/0208), and Mayer Brown LLP is the litigation firm of record for Maxell's assertion campaigns (e.g., the VIZIO complaint). The pre-2015 links used different correspondents (unknown for 021756/0400 and 030622/0001; likely Antonelli, Terry, Stout & Kraus LLP for the 2014 HCE→Hitachi Maxell records). So the signal is real but modest — this is a large law firm doing operating-company work, not a shell-factory lawyer; a single appearance is not a finding, and here we have recurrence across the assignment/litigation boundary rather than across multiple shell assignees.
Cascading transfers <24 months through chained LLCs — NOT PRESENT. Six transfers over 13 years, all through operating corporations within one corporate family, with no shared shell address. The only two events inside 24 months are the 2021-11-29 merger and 2021-12-03 name change, which are a single internal holding-company restructuring, not chained LLC transfers.
Pre-litigation transfer — UNCLEAR / low weight. The substantive Maxell transfer executed 2017-10-01 (recorded 2018-01-25) precedes Maxell's assertion campaigns (E.D. Tex. filings from 2018–2020 and later). But the transfer is an intra-family corporate de-merger, not an arrangement to a clean asserting vehicle, so its timing does not carry the usual "set up the chain for suit" inference.
Bankruptcy fire-sale — NOT PRESENT. No bankruptcy proceeding for any assignor. Hitachi's consumer-electronics IP moved by corporate carve-out/de-merger (2013, 2014, 2017), not by a Chapter 7/11 asset sale.
Privateering — UNCLEAR. There is a family resemblance: Hitachi divested consumer-electronics IP into Maxell, which then pursued an aggressive licensing/assertion program against Apple, Samsung, Lenovo/Motorola, ZTE, and VIZIO, and Maxell solicits "license agreement[s] like Samsung's competitors" (E.D. Tex. Samsung complaint, 2025). However, classic privateering requires transfer to a separate NPE asserting on the operating company's behalf; here Maxell asserts in its own name, so this is better characterized as self-monetization by an operating company than as privateering.
Defensive aggregator — NOT PRESENT. The chain terminates at Maxell, Ltd., an active asserting entity. It does not end at RPX, AST, LOT, Unified, or OIN. The patent is live and asserted, not neutralized.
Verdict
Operating-company assertion.
Justification: the entire recorded chain stays inside the original Hitachi/Maxell corporate family — Reel 021756/0400 (inventors → Hitachi, Ltd.), Reel 030622/0001 (Hitachi, Ltd. → Hitachi Consumer Electronics), the 2014 transfer to Hitachi Maxell, and Reel 045142/0208 (Hitachi Maxell → Maxell, Ltd., recorded 2018), followed by the 2021 merger/name change — with no transfer to any third-party shell or NPE and no bankruptcy. The current assignee, Maxell, Ltd., is a publicly traded operating manufacturer (TSE 6810) that continues to assert this patent itself (e.g., its Apple, Samsung, Lenovo/Motorola and VIZIO campaigns), which is the operating-company-assertion profile rather than an NPE one.
Nuance you should carry forward: Maxell is a high-volume patent monetizer whose accused products (smartphones, TVs, tablets) are not products Maxell ships, and its assertions are run through outside litigation counsel (Mayer Brown LLP) that is also the assignment-of-record correspondent (Nadeen Nsouli, Reel 045142/0208). If your firm's internal definition of "NPE" turns on whether the current owner practices the claimed technology rather than on whether the patent was sold to a separate vehicle, Maxell would migrate to NPE — moderate confidence on the strength of the correspondent recurrence plus high-frequency assertion alone. On the evidence of the assignment record itself, however, no shell-entity transfer, known-asserter assignee, or chained-LLC cascading transfer exists, and the chain never leaves the original corporate family.
Verify at: USPTO Assignment Center — https://assignmentcenter.uspto.gov/ (search application 12/260,410 or patent 9420212), and Google Patents legal events for US 9,420,212 at https://patents.google.com/patent/[US9420212B2](/patent/US9420212B2)/en. The chain-of-title statement citing Reels 021756/0400 and 030622/0001, and the recorded assignment abstract for Reel 045142/0208, appear in the file-history exhibits to IPR2024-00906 (Samsung) and IPR2021-00400 (Apple) hosted on Docket Alarm.
Generated 9/28/2026, 5:23:16 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll search for the specific patent and its cited references.
Let me get the full citations list directly from the patent page.
Important methodology note before the analysis
Two things you should know up front, because they bound the reliability of what follows:
- The authoritative full text you supplied omits the front‑page "References Cited" section. The Google Patents extract provided in this task jumps from the images block straight to Classifications — it contains no
(56) References Citedlist. So the only citation data available to me came from live search results (Google Patents family page for US2016/0323635A1, the Justia page for the continuation US 10,958,971, and IPR/reexam exhibits). I have flagged every inferred item accordingly. - Literal-ID discipline. A search for the bare string "9420212" also surfaced an unrelated WO 94/20212 entry (a 1994 PCT number) and non‑US patents ending in "‑212" (e.g., US 7,454,212). Per your "do not auto‑correct / do not return similar numbers" rule, I excluded all of those. Everything below is tied to US 9,420,212 B2 / application 12/260,410 unless explicitly labeled otherwise.
1. Confirmation of the target
| Field | Value |
|---|---|
| Patent | US 9,420,212 B2 |
| Title | Display apparatus and video processing apparatus |
| App. No. | 12/260,410 (filed 2008‑10‑29) |
| Priority | JP 2007‑306750 (2007‑11‑28) |
| Issued | 2016‑08‑16 |
| Claims | 6 |
Examiner/attorney metadata from the IPR2021‑00400 prosecution-history exhibit (Apple EX1002) confirms this is the parent of 15/208,886 → US 10,129,590, and prints "BAKER BOTTS L.L.P." as the attorney firm.
2. Cited patent references (best available reconstruction)
2a. References I could verify as appearing on the family's citation list
These six appeared in the Google Patents "Citations" block and are mutually consistent with the '212 family (the Schindler and Thro references in particular recur across the family pages):
| # | Full citation | Filing / Pub. date | Brief description |
|---|---|---|---|
| 1 | US 5,838,384 A — Schindler et al., "System for assigning multichannel audio signals to independent wireless audio output devices," Gateway 2000, Inc. | Filed 1995‑07‑17; issued 1998‑11‑17 | Wirelessly routes multiple audio channels to separate wireless speaker/output devices; teaches assignment of radio resources to independent wireless sinks. |
| 2 | US 6,037,991 A — Thro et al. (Motorola), "Method and apparatus for communicating video information in a communication system" | Filed 1996‑11‑26; issued 2000‑03‑14 | RF video system (public‑safety context) in which a first device transmits video "at a second transmission frame rate … less than the first transmission frame rate." Teaches variable video transmission rate over a radio resource. |
| 3 | US 2003/0189638 A1 — Fry, Terry L., "Narrow bandwidth, high resolution video surveillance system and frequency hopped, spread spectrum transmission method" | Filed 2002‑04‑09; pub. 2003‑10‑09 | Surveillance video over frequency‑hopped spread spectrum; addresses bandwidth‑constrained wireless video. |
| 4 | US 2004/0193647 A1 — Ueda et al., "AV data transmitter, AV data receiver, and AV data displaying/reproducing apparatus" | Priority 2001‑07‑10; pub. 2004‑09‑30 | AV data transmitted wirelessly from a transmitter to a display/reproducing apparatus — i.e., video‑to‑display over a radio link. |
| 5 | US 2005/0034169 A1 — Maeda et al. (Sony), "Information processing system, information processing apparatus and method, recording medium, and program" | Filed 2003‑06‑26; pub. 2005‑02‑10 | Information‑processing/networked content handling with recording medium; general networked information‑processing environment. |
| 6 | US 2005/0144478 A1 — Yamanaka et al. (Kabushiki Kaisha Toshiba), "Content receiving/storing apparatus and content delivery system" | Filed 2003‑12‑25; pub. 2005‑06‑30 | Content receiving/storing with network content delivery and storage. |
⚠️ The Google Patents list was truncated after entry 6 ("US20…") on the retrieved page, so a 7th (and possibly further) U.S. citation exists that I could not read. Treat the list as incomplete.
2b. Applicant‑cited reference in the specification
| Full citation | Date | Description |
|---|---|---|
| JP‑A‑2007‑202115 | Pub. 2007 | Cited in the Background of the '212 specification as an example of conventional digitized video/audio multiplexing for transmission ("A conventional technique in which digitized video and audio signals are multiplexed for transmission as above is described in, for example, JP‑A‑2007‑202115"). Also cited is HDMI/HDCP as known prior interface art. |
Note: because the specification cites this as background, it is a specification‑cited reference and, if it is the applicant's own work, MPEP 2129(I) caution applies (the same point litigated in IPR2017‑00275 over Riverwood Int'l v. R.A. Jones).
2c. Longer candidate list (⚠️ medium confidence — may include references added only in later continuations)
The Justia record for the continuation US 10,958,971 lists these U.S. patents; some or all may also appear on the '212 face (continuations often re‑list the parent's references), but I could not confirm which ones are original to the '212:
5,678,173 (Mihara, 1997‑10‑14); 5,724,355 (Bruno et al., 1998‑03‑03); 5,758,262 (Grysiewicz et al., 1998‑05‑26); 6,763,226 (McZeal, Jr., 2004‑07‑13); 6,957,081 (Leyh et al., 2005‑10‑18); 7,224,964 (Souissi et al., 2007‑05‑29); 7,233,359 (Suda, 2007‑06‑19); 7,668,565 (Ylanen et al., 2010‑02‑23); 7,787,882 (Feher, 2010‑08‑31); 7,970,350 (Sheynman et al., 2011‑06‑28); 7,977,774 (Feher, 2011‑07‑12); 7,983,678 (Feher, 2011‑07‑19); 8,045,922 (Sherman et al., 2011‑10‑25); 8,306,525 (Feher, 2012‑11‑06); 8,311,509 (Feher, 2012‑11‑13); 8,325,237 (Bessone et al., 2012‑12‑04); 8,572,257 (Dua, 2013‑10‑29); 8,625,547 (Miller, II, 2014‑01‑07); 8,693,950 (Desai, 2014‑04‑08); 9,344,237 (Margulis, 2016‑05‑17); plus pubs. 2004/0045030 (Reynolds), 2004/0048572 (Godfrey), 2004/0107208 (Seet), 2004/0077313 (Oba), 2005/0062945 (Shin‑Pin), 2005/0064860 (Deline), 2005/0130586 (Gnuschke), 2005/0136949 (Barnes).
Several of these (notably the Feher family on adaptive radio transmission, Souissi on dual‑mode wireless, Sheynman on wireless device resource management, and Miller II on wireless video distribution) are the types of references an examiner cites for "two radio paths / rate assignment," which is the crux of the '212 claims. I list them as candidates for verification, not as confirmed '212 citations.
3. § 102 anticipation analysis, reference by reference
Framing: The independent claims require, together, (a) a first radio unit carrying video to/from an external video apparatus, (b) a second radio unit to a network, and (c) a control unit that assigns radio transmission between them so the first unit gets priority and a higher rate than the network link — with claim language further tying reassignment to a user indication.
Against that full element set:
| Reference | Elements it arguably discloses | Could it anticipate a claim under § 102? |
|---|---|---|
| US 5,838,384 (Schindler) | Wireless assignment of radio resources to independent output devices — maps loosely to the "assignment" concept only. | No. No network radio unit; no video‑from‑external‑apparatus; no priority of a video link over a network link. At best § 103 background for the "assignment" language of claim 1. |
| US 6,037,991 (Thro) | Transmitting video by radio at a reduced/variable transmission frame rate — the single closest element match, to the "transmission rate" concept. | No — but the strongest § 102 candidate among those verified. It lacks the second network radio unit and the priority assignment between a video link and a network link. It could not, alone, anticipate claim 1 or the mirror video‑processing‑apparatus claim. Useful for § 103 in combination with a dual‑radio/network reference. |
| US 2003/0189638 (Fry) | Bandwidth‑constrained wireless video. | No. Surveillance/spectrum‑hopping focus; no dual‑radio prioritization, no network link. § 103 background only. |
| US 2004/0193647 (Ueda) | AV data transmitted to a display/reproducing apparatus — maps to the "first radio unit … external display apparatus" element. | No. No second radio‑to‑network unit; no rate/priority assignment. § 103 complement. |
| US 2005/0034169 (Maeda) | Networked information‑processing system with recording medium — maps loosely to "network connection." | No. No dual‑radio video‑vs‑network prioritization. § 103 background. |
| US 2005/0144478 (Yamanaka) | Content receiving/storing with network content delivery — maps to the "second radio unit … network" element. | No. No priority/higher‑rate requirement relative to a separate video radio. § 103 complement. |
| JP‑A‑2007‑202115 (spec‑cited) | Multiplexed digital video/audio transmission — maps to the multiplexing/HDMI background. | No. Expressly background art; supplies none of the dual‑radio priority elements. |
Bottom line on § 102: on the face of the descriptions I could verify, no single cited reference discloses all elements of claim 1 or of the independent video‑processing‑apparatus claim, so none appears to anticipate under § 102. The cited set is better characterized as § 103 art: Thro ('991) for variable radio video rate + Ueda ('647) for video‑to‑display + Yamanaka ('478) for network content, combined, would be the plausible obviousness combination — but that is an obviousness theory, not anticipation.
4. Explicit uncertainties (do not treat as verified)
- I could not retrieve the verbatim
(56) References Citedblock for US 9,420,212 from an authoritative source; the list in § 2a is reconstructed from a truncated Google Patents citation block on a family member, and § 2c from a continuation's Justia page. There may be (and likely is) at least one additional U.S. citation I did not capture. - I have not verified the examiner's own applied‑art rejections from the file wrapper; a PTO‑892 "Notice of References Cited" and any non‑final rejections in 12/260,410 would be the definitive source of what the examiner treated as prior art.
- The "user indication" limitation I noted in the earlier summary (from the W.D. Tex. claim‑construction excerpt) is not reflected in any of the cited references I found.
If you need certainty, the authoritative next steps are: (1) pull the front page of the US 9,420,212 grant PDF for the literal (56) list; (2) pull the PTO‑892 and IDS forms from the 12/260,410 file wrapper in USPTO Patent Center; (3) cross‑check the IPR2021‑00400 Apple EX1002 prosecution‑history exhibit, which already contains portions of this family's file history.
Generated 9/28/2026, 5:23:09 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll start by trying to retrieve the actual "Prior Art" / "References Cited" content for US 9,420,212, since the authoritative text supplied to me only includes the prior-art keyword list and the prior-art date.
The fetched patent text doesn't include the "References Cited" list, so let me try to surface it directly.
Good — I found relevant source material. Let me pull the actual cited references and the granted claim set from a patent database page.
Obviousness Analysis — US 9,420,212 B2 ("Display apparatus and video processing apparatus") under 35 U.S.C. § 103
0. Evidentiary basis — and an important scope caveat
The "Prior Art" section of the authoritative Google Patents page text supplied to me contains no reference list. Its entire prior-art content is:
| Prior-art field | Value |
|---|---|
| Prior art keywords | radio communication, communication unit, signal, radio, video |
| Prior art date | 2007-11-28 (the JP priority date) |
| Source | https://patents.google.com/patent/US9420212/en |
The "Cited By" entries retrieved from that page (US20090135307A1, US10129590B2, US10244284B2, US10958971B2, US11445241B2, US11451860B2, US11451861B2, US11509953B2) are all family members of the '212 patent itself — they are self-citations, not prior art, and cannot be used to reject the '212 claims.
Accordingly, to do a real § 103 analysis I had to source the actual cited art. The best available authoritative list is the USPTO PTO-892 "Notice of References Cited" (Examiner Amy Hsu, Art Unit 2664) from the prosecution of application 15/208,886, which is the continuation filed directly off 12/260,410 (the '212 application) and which issued as US 10,129,590. Sourced from the Samsung IPR2024-00906 exhibit set: https://www.docketalarm.com/cases/PTAB/IPR2024-00906/Samsung_Electronics_Co._Ltd/docs/05-17-2024-Petitioner/Exhibit-1005-EX1005___File_History_of_10,129,590_15208,886.pdf
⚠️ Two honesty flags before proceeding:
- Those references were cited against the continuation's claims (8 total, 2 independent — per the same PTO-892), not necessarily against the '212's own 6 claims. I have not retrieved the '212's own prosecution-history PTO-892. Treat the list below as the closest available family-prosecution art, not as a certified list of what rejected the '212.
- For most of these references I have only the number, date, inventor, and CPC/US classification — not the disclosure text. I therefore characterize each reference by its classification and inferred subject matter and explicitly mark what is unverified. I will not attribute specific disclosures to references I have not read.
1. Person of Ordinary Skill in the Art (PHOSITA)
At the 2007-11-28 priority date, a PHOSITA would be a person with a B.S. in electrical engineering or computer science and 2–4 years of experience in consumer wireless audio/video systems, or equivalent, who is familiar with:
- HDMI / HDCP for wired digital AV transport (expressly acknowledged in the '212 Background, supra);
- IEEE 802.11a/b/g WLAN and its OFDM PHY and BPSK/QPSK/16QAM/64QAM modulation set;
- Medium-access / QoS mechanisms — carrier sensing, adaptive modulation and coding (AMC), and priority/contention-based access such as 802.11e EDCA ("WMM");
- Multiplexing/compression of digital video and audio (MPEG-2/4, AVC/H.264) — the '212 itself lists these at col. of the Description.
This matters because the invention's core is a radio-resource allocation policy, and allocation/QoS policy is a discipline with an enormous pre-2007 literature.
2. Claim-element breakdown
I reproduce the claim set retrieved from the pre-grant publication (Justia, https://patents.justia.com/patent/20090135307, which identifies itself as "Patent Grant number: 9420212" for application 12/260,410). ⚠️ The granted claim set is 6 claims (prior section), whereas this published set is 10 — so at least four claims were cancelled/renumbered during prosecution. I could not retrieve the granted claim text, so the mapping is to the published set and is flagged accordingly.
Claim 1 — display apparatus comprising:
- (a) a first radio communication unit capable of receiving video information by radio from an external video processing apparatus;
- (b) a second radio communication unit capable of connecting by radio to a network;
- (c) a control unit for controlling assignment of connection by radio transmission for each of the first and second radio communication units.
Claim 2 — first RCU assigned connection with higher priority.
Claim 3 — control unit controls assignment of transmission rate between (i) first RCU ↔ external video processing apparatus and (ii) second RCU ↔ network.
Claim 4 — the rate of (i) is greater than the rate of (ii).
Claim 5 — further comprising a detection unit for detecting a state of a transmission path, wherein a demodulation method in the first or second RCU is controlled according to the detection result. (This is the "adaptive modulation" claim.)
Claims 6–10 — the mirror-image "video processing apparatus" claims (first RCU transmits video to an external display apparatus; second RCU connects to a network; same priority/rate/detection limitations).
The prior section also flagged a possible user-indication limitation derived from W.D. Tex. claim-construction excerpts. I retain that flag: if the granted independent claims require reassignment in response to a user indication, that narrows the claim and correspondingly narrows the obviousness case (see §6).
3. The prior art available
3.1 Art cited in the family's own prosecution (PTO-892, appl. 15/208,886)
| # | Reference | Date | Inventor | Class / US cl. | Inferred subject (⚠️ unverified) |
|---|---|---|---|---|---|
| A1 | US 6,037,991 A | 03-2000 | Thro (Stuart W.) | H04N7/147 | Video conferencing / two-way video transport |
| A2 | US 2003/0189638 A1 | 10-2003 | Fry (Terry L.) | H04B1/713 | Frequency-hopping wireless AV transport — adaptive/robust link |
| A3 | US 2004/0193647 A1 | 09-2004 | Ueda (Toru) | H04N7/163 | Wireless AV transmission / TV two-way link |
| A4 | US 2005/0034169 A1 | 02-2005 | Maeda (Satoru) | H04N5/4401 | TV receiver / display-side AV apparatus |
| A5 | US 2005/0144478 A1 | 06-2005 | Yamanaka (Taichiro) | H04L9/0822 | Key management / content protection over AV link |
| A6 | US 2006/0097955 A1 | 05-2006 | Kato (Masataka) | H04W52/0251 | Wireless display / power control in a portable wireless display link |
| A7 | US 2007/0072642 A1 | 03-2007 | Kangas (Tiia) | H04M1/72522 | Multi-mode mobile terminal (e.g., cellular + WLAN) |
| A8 | US 2007/0091835 A1 | 04-2007 | Jo (Hwan-ju) | H04H60/11 | Broadcast + communication convergence (broadcast data + return/other channel) |
| A9 | US 2007/0242313 A1 | 10-2007 | Shiomi (Yasuhiko) | H04N1/00307 | Wireless image-data communication |
| A10 | US 2008/0188182 A1 | 08-2008 | Macholz | — | (post-priority-date publication; usable only as § 102(a)(2)/§ 103 evidence if its effective filing predates 2007-11-28 — must verify) |
3.2 Art expressly acknowledged in the '212 specification (applicant-admitted prior art)
- JP-A-2007-202115 — cited in the Background as "a conventional technique in which digitized video and audio signals are multiplexed for transmission" (FPO:
https://www.freepatentsonline.com/9420212.html). - HDMI / HDCP — acknowledged in the Background, and reproduced in FIG. 7 (TMDS encode/decode, CEC line, DDC line, HPD).
- The applicant's own admission of the field and of the trade-off. The '212 states that because the band is fixed, "if the band of signals from the terminal 101 is expanded, that of signals from the terminal 134 narrows to slightly lower the communication speed of the network. However, this rarely influences the system operation since information regarding the network is less frequently exchanged as compared with video information." This is a specification admission that the bandwidth trade-off and its consequence were known and predictable.
3.3 The general knowledge layer (for the motivation analysis)
Not "references" per se, but the knowledge PHOSITA is charged with: 802.11e/WMM priority queuing, adaptive modulation & coding (AMC), carrier-sense / clear-channel assessment, and streaming-QoS prioritization. These are the doctrinal hooks for the "obvious to try / known technique" rationales under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
4. Grounds of rejection
Ground 1 — § 103: Ueda (A3) in view of Kangas (A7), further in view of Jo (A8) → claims 1, 2, 6, 7
Where each element is met:
| Claim 1 element | Taught by |
|---|---|
| (a) first radio unit receiving video from an external video processing apparatus | Ueda (A3) – wireless AV transmission link from a source device to a display/TV (H04N7/163) |
| (b) second radio unit connecting to a network | Kangas (A7) – a mobile terminal configured to operate over a WLAN/data network in addition to another radio mode (H04M1/72522; 455/552.1 is literally the class for "multi-mode" handsets); alternatively Jo (A8), broadcast + communication data on a second channel |
| (c) control unit controlling assignment of connection by radio transmission for each unit | Kangas (A7) and Jo (A8), each of which necessarily manages coexistence of two radio data paths in one device; and, more generally, the standard multi-radio coexistence controller |
Motivation to combine (KSR):
- Same field, same problem. Both Ueda and Kangas address wireless delivery of media to a display/handset. A portable video-processing device (the '212 expressly names a camera, video camera, cellular phone, game machine, personal media player) that streams video to a display is exactly the Kangas multi-mode handset plus a video link. Combine two known radio capabilities of a portable device into one device = "combination of familiar elements according to known methods… yields predictable results." KSR, 550 U.S. at 416.
- A single device with two concurrent radio roles was a recognized design trend. Kangas (
455/552.1, the multi-mode class) is itself evidence that integrating a data-network radio alongside another radio in one handset was routine. - "If a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious." Applying Kangas's dual-radio data capability to Ueda's wireless-AV display link is precisely this.
- Predictable result: a display that can simultaneously (i) receive video over a first link and (ii) reach the Internet/home network over a second link. No new function is achieved; the reference combination merely aggregates two links.
§ 102 note: If Kangas or Ueda in fact discloses a shared resource allocator across both radios (not verified), Ground 1 collapses into single-reference anticipation rather than obviousness. This should be checked against the references' full text.
Ground 2 — § 103: Ground 1 further in view of Kato (A6) and the QoS/priority-allocation art → claims 2, 3, 4 (and mirror claims 7, 8, 9)
What is added: claims 2–4 require that the first (video) radio unit be assigned higher priority and a higher transmission rate than the second (network) radio unit.
Where the teaching comes from:
- Kato (A6) — classified H04W52/0251 (power management in the wireless link) with US cl. 345/1.1 (portable display interface), indicating a system that dynamically allocates the resources of a wireless display link — i.e., dynamic management of a display-dedicated radio link. (⚠️ Disclosure unverified; the reference is offered as the display-link resource-management teaching, and the specific allocation policy must be confirmed.)
- The applicant's own admission (§ 3.2 above) that the network link may be slowed with little user impact because network information is exchanged infrequently — this is a statement of the design rationale, and it supplies the motivation directly.
- The general knowledge layer: prioritizing latency-/bandwidth-sensitive streaming video over bursty, latency-tolerant data traffic is the core, decades-old premise of QoS (priority queues, 802.11e EDCA/WMM). A PHOSITA requiring a wireless display link to preserve HD picture quality would a fortiori give that link priority.
Motivation to combine (KSR rationales, catalogued):
- (C) Use of known technique to improve similar devices in the same way — QoS prioritization applied to a two-link portable device.
- (D) Applying a known technique to a known device ready for improvement — Ueda's/Kangas's device is precisely "ready for improvement" once two bandwidth-competing links coexist.
- (F) Design incentive / market pressure — the '212's own Background describes the market driver: HDMI/HDCP wired connections cannot easily coexist with Internet/home-network connectivity for portable devices. Solving a recognized market deficiency is a classic obviousness rationale (KSR at 421; In re Kahn).
- Result-oriented limitation doctrine: claim 2 ("higher priority") and claim 4 ("more than") recite desired outcomes, not a mechanism. Where the result is the natural and predictable consequence of the prior-art combination, the recitation does not confer patentability. Note especially that the '212 discloses achieving this result by entirely conventional mechanisms — variable modulation/demodulation method, frequency band, and number of carriers (the "scheme 1 = 17 Mbps / scheme 2 = 5 Mbps" disclosure, FIG. 9), or by re-partitioning a bank of fixed-band modems (FIGs. 4, 8, 11). Both mechanisms are conventional radio-resource control.
Anticipation-vs-obviousness: a single reference that discloses splitting a shared modem bank or band set unequally between two logical links would anticipate claims 3–4 outright; FIG. 11 of the '212 (bands A–D reallocated among modems 5001–5004 / 9010–9013) is itself evidence that the applicant considered band re-partition across modems to be an implementation detail.
Ground 3 — § 103: Any of Grounds 1–2 further in view of Fry (A2) → claim 5 (and mirror claim 10)
What is added: a detection unit for detecting a state of a transmission path, with the demodulation method controlled according to the detection result.
Why Fry (A2) is the strongest fit:
- US 2003/0189638 A1 (Fry) is classified in H04B1/713 — the CPC subclass for spread-spectrum / frequency-hopping transmission. Adaptive frequency selection necessarily entails sensing the state of the channel and changing the transmission scheme in response. Fry is therefore a natural teaching of "detect path state → change the radio's transmission parameters."
- The '212's own specification describes precisely this mechanism in the same terms: "a check is made to determine whether or not a carrier is detected in a predetermined frequency band for a predetermined period of time. If it is detected … that the channel is occupied by another apparatus, the check is again carried out after a lapse of a predetermined period of time" — i.e., carrier sensing / CCA. That is standard 802.11 MAC behavior and cannot itself be novel.
- Adaptive modulation itself is ancient: the Wi-Fi PHY (802.11a/g) selects among BPSK/QPSK/16QAM/64QAM based on link quality; DVB and DSL do the same. Mapping a higher-priority bit stream to a more robust modulation (QPSK) and a lower-priority stream to a denser constellation (64QAM) — which the '212 describes with respect to MSB video bits — is the textbook unequal error protection (UEP) principle.
Motivation: the desire to preserve the "high picture quality" video link in the presence of interference supplies the reason to sense the channel (Fry) and adapt the modulation scheme (Fry + the AMC general knowledge layer). Result = predictable improvement in link robustness.
⚠️ This is my weakest ground on the present record, because I have not read Fry's specification and cannot cite a specific passage disclosing demodulation-scheme selection responsive to a detected path state. That must be verified before the ground is relied upon.
Ground 4 — § 103: The "combination-with-admitted-prior-art" ground → all claims
Reference: JP-A-2007-202115 (applicant-admitted) plus HDMI/HDCP (applicant-admitted) plus the admitted bandwidth trade-off.
The '212's Background § and Description concede:
- digital multiplexed AV transmission was conventional (JP-A-2007-202115);
- HDMI/HDCP multiplexed and encrypted baseband + audio for transmission (FIG. 7);
- the shared-band trade-off between the video link and the network link, and that slowing the network link "rarely influences the system operation."
Doctrine: an applicant's own admission of what was known is prior art against it (In re Nomiya; Stern v. Trs. of Columbia Univ.). When the Background concedes the transport and the multiplexing, and the Description concedes the allocation trade-off and its acceptability, the remaining gap over the admitted art is only the policy choice of which link gets more band — a choice the specification itself characterizes as justified by traffic statistics the PHOSITA already knew (video is continuous and bandwidth-heavy; network/control data is intermittent).
5. Consolidated claim chart (obviousness)
| Claim | Element requiring novelty | Primary ref. | Secondary ref. | Ground |
|---|---|---|---|---|
| 1 | two radio units (video-from-external-device + network) with a connection-assignment controller | Ueda (A3) | Kangas (A7) / Jo (A8) | 1 |
| 2 | first RCU higher priority | Ueda/Maeda (A3/A4) | Kato (A6) + QoS knowledge | 2 |
| 3 | transmission-rate assignment to each link | Ueda (A3) | Kato (A6) | 2 |
| 4 | first rate > second rate | Ueda (A3) | Kato (A6) + applicant admission | 2 |
| 5 | path-state detection → demodulation-method control | Fry (A2) | AMC/UEP knowledge | 3 |
| 6–10 | mirror "video processing apparatus" claims | Ueda (A3) | Kangas (A7) / Jo (A8) / Kato (A6) / Fry (A2) | 1–3 |
6. What would strengthen or defeat the rejection
Strengthen (toward rejection):
- Locating the '212's own PTO-892 / examiner's search history (12/260,410) rather than the continuation's — it may contain a tighter, directly-applied combination.
- Confirming Kato (A6) discloses unequal resource allocation between a display link and another link — that would make Ground 2 a near-perfect single-plus-secondary rejection.
- Confirming Kangas (A7) or Jo (A8) discloses two concurrent radios with a coexistence/arbitration controller — that would close claim 1 almost entirely.
- The FIG. 11 disclosure (reassigning modems among bands A–D) is the applicant's own admission that band re-partition between the two logical links is conventional hardware bookkeeping.
Weaken (toward patentability):
- The possible user-indication limitation flagged in the prior section. If the granted independent claims require reassignment in response to a user command to receive/transmit video (as the W.D. Tex. claim-construction excerpt suggests), the claims are narrower, and none of A2–A10 as characterized above discloses a user-triggered reallocation. This is the single most important open issue and it cannot be resolved without the verbatim granted claims.
- If the granted claims are construed to require two structurally separate radios (not one radio with split bands), then the FIG. 4/8 single-modem-bank embodiments may not support the claims and the prior art's "one radio, two logical links" designs would not read on them.
- Secondary considerations (Graham factor 4): the '212 family has been active in litigation (Maxell v. Lenovo, 6:21-cv-01169 W.D. Tex.; Maxell v. Apple, 6:20-cv-646; 1:22-cv-00256 N.D. Ill.), which may be probative of commercial significance — but only with evidence of nexus to the claimed allocation feature, and the feature here is generic QoS prioritization, which cuts against nexus (In re GPAC).
- Teaching away / unexpected results: I see none on the record. Worse for the patentee, the specification affirmatively states the network-link slowdown "rarely influences the system operation" — i.e., the applicant characterized the result of the very allocation at issue as predictable and benign, which is the opposite of an unexpected result.
7. Bottom line
On the currently available record, claims 1, 2, 6 and 7 (the two-radio apparatus + higher-priority limitation) are the most vulnerable to § 103, and my strongest ground is Ueda (US 2004/0193647 A1) in view of Kangas (US 2007/0072642 A1) and Jo (US 2007/0091835 A1), with the applicant's own Background admissions (HDMI/HDCP; JP-A-2007-202115) supplying the transport context. Claims 3–4 and their mirror claims fall to the further addition of Kato (US 2006/0097955 A1) plus the PHOSITA's QoS/priority-queue knowledge — and, critically, the applicant's own admission that the video link should be favored because network information is exchanged infrequently. Claim 5/10 is the least vulnerable on this record and needs Fry (US 2003/0189638 A1) to be substantiated by its actual disclosure.
But I want to be plain about the limits of this opinion. I have not read the granted claims of the '212, and I have not read the specifications of A2–A10. The reference numbers, dates, inventors, and classifications above are sourced (PTO-892 of 15/208,886, retrieved via the Samsung IPR2024-00906 exhibit set), but the disclosure content attributed to each reference is inferred from its classification and is flagged as unverified. Any of these grounds, if asserted in a real proceeding, would require the actual claim text, the actual reference passages, and the '212's own prosecution history. Where I could not verify, I have said so rather than fill the gap.
Generated 9/28/2026, 5:23:37 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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