US 9614943

I'll search for authoritative information on this specific patent number and any 2026 CAFC activity.

Let me search additional sources for litigation and PTAB post-grant activity.

US 9,614,943 B1 — summary

Identification (interpreted literally, not auto-corrected)

Source: https://patents.google.com/patent/US9614943/en

Priority chain (as recited verbatim in the specification's Cross Reference section)
Continuation of 12/912,607 (filed Oct. 26, 2010, now US 8,824,434) → continuation of 10/940,428 (filed Sep. 13, 2004, now US 7,848,300) → continuation of 09/617,608 (filed Jul. 17, 2000, now US 7,286,502) → continuation-in-part of 09/281,739 (filed Jun. 4, 1999, now US 6,169,789).

⚠️ Uncertainty: Google Patents separately displays a "Prior art date" and "Anticipated expiration" of 1996‑12‑16, which does not match the date chain recited in the specification (earliest date there is 1999‑06‑04). I cannot reconcile the 1996 date from the record available and flag it as an anomaly rather than asserting a 1996 priority.

Abstract (verbatim)
"A method and apparatus in which multiple Internet Protocol (IP) based wireless data transmissions are simultaneously provided between a wireless device and a server, including providing multiple antennas, multiple T/R units, multiple processors and multiple I/O ports on the wireless device. The method includes receiving multiple IP data packets on the I/O ports at substantially the same time, and sending multiple data packets from the wireless device to the server, whereby the transmission rate between the wireless device and the server is increased."

Plain-language overview of the independent claims

• Claim 1 (independent — device claim). As described by the Federal Circuit, claim 1 claims "[a] wireless communication device" having a plurality of antennas capable of wireless communication and parallel processing of multiple data streams (col. 11, line 63, through col. 12, line 9).
• Method-type independent claim described in the abstract. The abstract frames a method of simultaneously providing multiple IP-based wireless transmissions between a wireless device (multiple antennas, multiple T/R units, multiple processors, multiple I/O ports) and a server — receiving multiple IP data packets on the I/O ports at substantially the same time and sending multiple packets to the server to increase throughput. I could not verify from the retrieved record which claim number carries this method language (candidate independent claims include 12, 15, or 20), so I am not assigning it a number.
• Claim 12 / 15 / 20 — independent-claim text not verified. The Board's Final Written Decision grouped claims 15–20 with claim 2 as "not relevant" to the principal appeal issue, so the record I retrieved does not reproduce their text. Flagged as uncertain.

Dependent claims on the record (verified from the Federal Circuit opinion)

• Claim 2 (depends on claim 1): two-part structure — one clause directed to the nature of the transmission (simultaneous vs. sequential transmit/receive using the antennas over a single transmission connection), and a second clause in which the processor multiplexes the received signals into the single transmission connection.
• Claim 3 (depends on claim 1, verbatim): "The device of claim 1, further in communication with a network switch box configured with a plurality of ports and configured to connect to a plurality of networks to forward packets between different networks and join a virtual network" (col. 12, lines 16–20).
• Claim 4 (depends on claim 3): adds nothing significant for the appeal.
• Claims 10–11 do not appear among the claims challenged in IPR2022‑01004 (challenged: 1–9 and 12–20), so I have no authoritative description of them.

Core inventive concept (from the specification)
Parallelism replaces the prior-art single-antenna/single-T-R/single-processor architecture: multiple antennas, multiple transmit/receive units, multiple processors (or one processor with built-in parallelism) and multiple I/O ports (USB, coaxial, POTS, twisted pair, Ethernet, optical) coexist in a cellular telephone/mobile device (CT/MD) or network switch box. A "Server C" partitions data and assigns each subtask to a separate channel, so parallel wireless, fibre-optic or wired paths overcome RF-to-digital and optical-to-electrical conversion bottlenecks; multiple nodes may be grouped into VPNs under Server C control.

Litigation, PTAB and Federal Circuit posture (as of the retrieved record)

• District court: W.D. Tex. 6:21‑cv‑00603 (Apple); W.D. Tex. 6:21‑cv‑00701 (Samsung); N.D. Cal. 3:23‑cv‑04168 (Apple, transferred). The Samsung case ended in dismissal with prejudice (July 15, 2024), with a joint motion to vacate the claim construction order. — https://www.patsnap.com/resources/blog/litigation/smart-mobile-technologies-v-samsung-mobile-patent-dispute-ends-in-dismissal-patsnap-eureka/
• PTAB: Apple and Samsung filed IPR2022‑01004 (May 19, 2022) against claims 1–9 and 12–20. Final Written Decision December 4, 2023 confirmed patentability of claims 2–4 and 15–20, while holding claims 1, 5–9 and 12–14 unpatentable as obvious. Director Review was denied January 30, 2024. — https://gravesshaw.com/and-another-[ipr](/resources/cost-of-inter-partes-review)-win-for-gs-client-smart-mobile/ ; https://www.docketalarm.com/cases/PTAB/IPR2022-01004/Samsung_Electronics_Co._Ltd._v._Smart_Mobile_Technologies_LLC/
• CAFC: Google Patents lists Nos. 24‑1623 and 24‑1654 for this patent family. A Federal Circuit opinion in Apple Inc. v. Smart Mobile Technologies LLC, No. 24‑1623 (Fed. Cir. Feb. 27, 2026) addresses precisely the '943 grounds — the Byrne (EP 0 660 626 A2) + WO 98/27748 VPN theory against claims 3–4, and the Raleigh‑Byrne grounds — and affirms the Board's rejection of those challenges (petition interpretation not an abuse of discretion; motivation-to-combine finding supported by substantial evidence). — https://law.justia.com/cases/federal/appellate-courts/cafc/24-1623/24-1623-2026-02-27.html ; https://www.courtlistener.com/opinion/[10801276](/patent/10801276)/apple-inc-v-smart-mobile-technologies-llc/

Two cautions you should be aware of

1. Date anomaly in the search record. Today's stated date is April 26, 2026, but the retrieved results include material dated after that: a CourtListener oral-argument audio record created 2026‑06‑02 (Apple v. Smart Mobile, Nos. 24‑1607 and 25‑1090) and a VitalLaw article dated Aug. 28, 2026. I am reporting these as retrieved rather than reconciling them.
2. Related-but-different patents. The Nos. 24‑1607 / 25‑1090 appeals concern U.S. 8,842,653, 9,019,946 and 9,319,075 (the "multiplexed signals" construction and the vacated bottleneck findings), not the '943 patent. Do not attribute that decision to 9,614,943.

Bottom line: US 9,614,943 is a Rao-family Smart Mobile Technologies continuation directed to a multi-antenna, multi-T/R, multi-processor, multi-port wireless device (CT/MD or network switch box) that splits data into subtasks across parallel channels to a server; claim 1 is the device claim, claim 3 adds the multi-port network switch box joining a virtual network, and claims 2–4, 15–20 survived IPR2022‑01004 and an appeal to the Federal Circuit (No. 24‑1623), while claims 1, 5–9 and 12–14 were held unpatentable in the unchallenged portion of that decision. Verbatim text of the independent claims other than claim 1 was not available in the retrieved record and is flagged as unverified.

I'll research litigation involving US patent 9614943.

Litigation involving U.S. Patent No. 9,614,943 ("'943 patent")

Scope note: I searched for the exact number 9,614,943 and filtered out look‑alikes (e.g., PCT publication WO 9614943 A1 — an unrelated SRAM-cell application — and the other Smart Mobile patents such as 9,191,083, 9,756,168, 9,049,119). Everything below is tied to 9,614,943 B1, titled "System to interface internet protocol (IP) based wireless devices with subtasks and channels," filed 2012‑09‑17, granted 2017‑04‑04, current assignee Smart Mobile Technologies LLC.

1. District Court Cases

A. Smart Mobile Technologies LLC v. [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.)

B. Smart Mobile Technologies LLC v. Apple Inc. (transferred/continued action)

C. Smart Mobile Technologies LLC v. [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) and Samsung Electronics America, Inc.

2. PTAB Post-Grant Proceedings

Caveats: Google Patents' litigation entry for IPR2022‑01004 does not name the petitioner in the data I retrieved, and I could not independently confirm the FWD outcome (e.g., which claims were held unpatentable) or whether it was later appealed. Related, contemporaneous IPRs in this campaign (IPR2022‑00980/00981 by Apple; IPR2022‑01003 and IPR2022‑01005 by Samsung) suggest the '943 IPR was part of the same coordinated Apple/Samsung challenge, but I did not verify the petitioning party for ‑01004 itself. Treat the petitioner/outcome as unconfirmed.

The district courts both addressed IPR-related stays: W.D. Tex. denied Apple/Samsung's opposed motion to stay (Feb. 17, 2023 motion; denied 2023), whereas N.D. Cal. granted Apple's unopposed stay (Sept. 19, 2023).

3. Federal Circuit Appeals

Caveat: My searches did not surface the docket contents (appellant, appellee, appealed-from decision, or disposition) for either appeal. They are recorded as pending/appealed matters in the Unified Patents CAFC dataset. Based on timing (2024) they most plausibly arise from the PTAB final written decisions and/or the N.D. Cal. and W.D. Tex. proceedings, but I am not stating that as a verified fact.

Also of record: the patent family has a "First worldwide family litigation filed" entry (Darts‑IP, family 34221038), indicating litigation outside the U.S. involving this family; I could not identify the foreign case(s).

4. Summary Table

Key Sources

• Google Patents, US9614943B1: https://patents.google.com/patent/[US9614943](/patent/US9614943)/en (litigation panel: CAFC 24‑1654 and 24‑1623; N.D. Cal. 3:23‑cv‑04168; W.D. Tex. 6:21‑cv‑00603 and 6:21‑cv‑00701; PTAB IPR2022‑01004)
• Unified Patents litigation portal: https://portal.unifiedpatents.com/litigation/caselist and the case links above
• Docket Alarm, Smart Mobile v. Apple, 6:21‑cv‑00603: https://www.docketalarm.com/cases/Texas_Western_District_Court/6--21-cv-00603/
• CourtListener, Smart Mobile v. Apple, N.D. Cal. 3:23‑cv‑04168, Dkt. 146: https://www.courtlistener.com/docket/67698985/146/smart-mobile-technologies-llc-v-apple-inc/
• W.D. Tex. Preliminary Infringement Contentions (Exhibit K = 9,614,943): https://www.docketalarm.com/cases/PTAB/IPR2022-01003/.../Exhibit-1041-35-Plaintiffs_Preliminary_Disclosure...pdf
• PatSnap case summary, Smart Mobile v. Samsung, 6:21‑cv‑00701 (dismissal with prejudice): https://www.patsnap.com/resources/blog/litigation/smart-mobile-technologies-v-samsung-mobile-patent-dispute-ends-in-dismissal-patsnap-eureka/

Bottom line: U.S. Patent 9,614,943 was asserted in two 2021 W.D. Tex. campaigns by Smart Mobile Technologies LLC — one against Apple (6:21‑cv‑00603, later N.D. Cal. 3:23‑cv‑04168, stayed) and one against Samsung (6:21‑cv‑00701, dismissed with prejudice July 15, 2024) — and was the subject of IPR2022‑01004 at the PTAB, with two related Federal Circuit appeals (24‑1623, 24‑1654) on the family. I could not verify the '943 IPR petitioner/outcome or the content of the two appeals; those items are flagged as unconfirmed rather than asserted.

I'll reconcile the structured "no PTAB activity" block against the previously-generated section (which identified IPR2022-01004), then research the proceeding's details.

Key contradiction confirmed: the structured block says "no PTAB activity," but the record shows IPR2022-01004. Let me pin down the remaining details — other proceedings on this patent, institution, grounds, and the appeals.

Let me verify whether any other AIA proceeding targeted the '943 patent, and check the patent's expiration/term situation (Google Patents shows an "anticipated expiration" of 2016-12-16, which would predate the 2021 litigation).

Data-integrity flags before the substance

Three conflicts need to be stated up front, per the operating rules:

1. The structured "PTAB proceedings on file" block is wrong (or stale). It reports "no AIA trial proceedings." The record shows IPR2022‑01004, filed 2022‑05‑19 against the '943 patent, with a Final Written Decision on 2023‑12‑04 and a Federal Circuit affirmance on 2026‑02‑27. The ODP trials ingest evidently failed to link this proceeding to the '943 patent (likely an index-by-application‑number vs. patent‑number issue: the '943 application is 13/621,294). Do not rely on the ODP block.
2. "Unified Patents" appears on the Google Patents page only as the data vendor ("Unified Patents Litigation Data" / "Unified Patents PTAB Data" are licensed datasets). There is no defensive aggregator in this chain — the '943 IPR petitioners were Apple and Samsung themselves.
3. Date contradiction with the earlier section. The previously generated summary states "today's stated date is April 26, 2026" and flags post-April‑2026 material as anomalous. This task states today is 2026‑09‑14. Under 2026‑09‑14 there is no anomaly: the 2026‑06‑02 and 2026‑08‑27 items are simply in the past. I flag it so the two sections aren't read as inconsistent.

Proceedings overview

One (1) AIA trial proceeding has ever been filed against US 9,614,943: IPR2022‑01004. Breakdown: 0 active / 0 settled / 0 institution‑denied; 1 proceeding that both invalidated claims and sustained claims — the Board held claims 1, 5–9 and 12–14 unpatentable (including independent claims 1, 5, 8 and 12) while holding claims 2–4 and 15–20 not shown unpatentable, and the Federal Circuit affirmed on 2026‑02‑27. The patent is therefore split, not hardened and not dead: the broadest independent device claim (claim 1) is canceled, so any infringement theory built on claim 1 or claims 5–9/12–14 is unwinnable; but claims 2–4 and 15–20 survived the Board and an Apple appeal, so a demand letter citing those claims is still live. Two further facts materially change the defensive calculus: (a) claims 10–11 were never challenged and are untested, and (b) the patent's anticipated expiration is recorded as 2016‑12‑16, i.e. before the 2021 suits were filed (see § strategic summary, item 3).

IPR2022‑01004 — [Samsung Electronics Co., Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.), Samsung Electronics America, Inc., and Apple Inc. v. Smart Mobile Technologies LLC

(Claims-invalidated proceeding — placed first per the ordering rule; it is also the only proceeding.)

• Type: Inter Partes Review (Tech Center 2400, Art Unit 2476)

• Filed: 2022‑05‑19

• Status: "Final Written Decision – Appealed" (DocketAlarm verbatim); terminated 2023‑12‑04; now final and affirmed. The "appealed" status is historical — the appeal was decided on 2026‑02‑27.

• Judge panel: Initially APJs Hyun J. Jung (writing), Nathan A. Engels, and Monica S. Ullagaddi. Per a Panel Change Order entered 2023‑02‑03 (Paper 18, signed by Acting Deputy Chief APJ Michael W. Kim), APJ Paul J. Korniczky replaced APJ Ullagaddi "due to unavailability." The FWD panel was therefore Jung, Engels and Korniczky — the same three judges who presided at the oral hearing held 2023‑09‑15. (DocketAlarm's header also lists Aaron Moore, Garth Baer and Ullagaddi; those appear to be panel members from earlier papers/expanded-panel listings, not the deciding panel.)

• Petition grounds: Nine grounds of obviousness (§ 103) involving six references, against claims 1–9 and 12–20 collectively. Three principal references on the face of the appeal:

  • "Byrne" — EP 0 660 626 A2, "Multi-mode Radio Telephone" (cordless + cellular, with existing encryption/security);
  • "WO748" — WO 98/27748, "Wireless Communications Station and System" (in-building base + "remote units" with multiple antennas);
  • "Raleigh" — U.S. Pat. No. 6,144,711, "Spatio-temporal Processing for Communication" (multi-antenna reconstruction of an attenuated signal).
  • Allocation: claims 3–4 → Byrne + WO748; claims 1–9 and 12–20 → five Raleigh‑Byrne combinations; claims 1, 5–9, 12–14 → three further Byrne-based grounds without WO748 or Raleigh. No § 102 anticipation and no § 112 grounds appear in the FWD or the CAFC recitation.

• Institution decision: Instituted on all challenges, December 2022 (reported as 2022‑12‑05). The Board found a reasonable likelihood as to at least one challenged claim and, citing SAS Institute Inc. v. Iancu, instituted on all presented challenges — claims 1–9 and 12–20 in full. Real parties in interest: Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Apple Inc.; related matters identified included W.D. Tex. 6:21‑cv‑00701 and the sibling IPRs IPR2022‑00766 and IPR2022‑01005. Decision Granting Institution: DocketAlarm PDF

• Final Written Decision (2023‑12‑04) — claim-level disposition, verbatim from the judgment line:

  "we determine that Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and Apple Inc. (collectively, 'Petitioner') have shown by a preponderance of the evidence that claims 1, 5‑9, and 12‑14, but not claims 2‑4 and 15‑20, of U.S. Patent No. 9,614,943 B1 … are unpatentable."

  The FWD also states: "Of the challenged claims, claims 1, 5, 8, and 12 are independent." So four independent claims were canceled and the dependent claims 6–7, 9, 13–14 fell with them.

  • Canceled (unpatentable): 1 (independent), 5 (independent), 6, 7, 8 (independent), 9, 12 (independent), 13, 14.
  • Sustained (not shown unpatentable): 2, 3, 4, 15, 16, 17, 18, 19, 20.
  • Untested: 10, 11 (never challenged).
  • Reasoning, sustained claims: For claims 3–4 (Byrne + WO748), the Board gave two independent reasons — (i) no motivation to add a VPN: "the full record [did] not make clear how the asserted benefits of a VPN would apply to the cordless and cellular communications of Byrne's [telephone]," and "[f]inding no indication in the record that a phone like Byrne's [] could initiate or connect to a virtual network"; and (ii) no reasonable expectation of success in modifying WO748 to join a virtual network. For claims 2–4 and 15–20 on the Raleigh‑Byrne grounds, the Board found no reasonable expectation of success given "implementation challenges."
  • FWD: DocketAlarm PDF · USPTO PTAB Decisions search

• Settlement / termination: None. The proceeding ran to an FWD; no adverse judgment, no § 317 settlement.

• Director Review: Petitioners requested Director Review of the FWD (Paper 41; Ex. 3100). Denied 2024‑01‑30 by Director Katherine K. Vidal (Paper 42): "the request for Director Review is denied; and … the Patent Trial and Appeal Board's Final Written Decision in this case is the final decision of the agency." Order (DocketAlarm)

• Appeal: Two appeals were docketed; one was dismissed.

  • Apple Inc. v. Smart Mobile Technologies LLC, No. 2024‑1623 (Fed. Cir.) — Apple appealed only the sustained claims (2–4 and 15–20). Decided 2026‑02‑27, affirmed. Nonprecedential; panel Taranto (author), Dyk, Cunningham, with Judge Dyk concurring-in-part and dissenting-in-part. Holding: the Board did not abuse its discretion in reading Apple's petition as asserting that Byrne's phone itself would communicate over WO748's VPN ("Apple has not made a showing that the Board unreasonably understood the motivation assertion of Apple's petition"; the Board's reading was the "most natural understanding"), and the no-motivation and no-reasonable-expectation-of-success findings were supported by substantial evidence; likewise the Board acted within its discretion in assessing "the only theory of how Raleigh and Byrne could be combined that was clearly presented in Apple's petition." Because motivation failed, the court did not reach the separate expectation-of-success finding on Byrne‑WO748.
  • No. 2024‑1654 (Samsung's appeal) — dismissed 2024‑08‑13 on Samsung's unopposed motion to deconsolidate and dismiss, each side bearing its own costs; the caption was revised to leave only No. 24‑1623. So Samsung abandoned its appeal entirely.
  • Critically, the CAFC notes the invalidation of claims 1, 5–9 and 12–14 was "an aspect of its decision not challenged here" — Smart Mobile never appealed, so those claims are canceled and gone, not merely "held unpatentable pending appeal."
  • Sources: CAFC opinion page · CourtListener 10801276 · Justia · GovInfo PDF · Samsung dismissal: 24‑1654 order excerpt

• Defensive value: Split decision, and the split is the whole story. Claim 1 — the broadest independent device claim — is canceled, so an infringement theory pleaded solely on claim 1 (or on canceled claims 5–9 and 12–14) is dead on arrival. But do not treat the patent as unenforceable generally: claims 2–4 and 15–20 survived both the Board and an Apple appeal, and because they depend from claim 1 they may be asserted with claim 1's limitations read in. Note the narrowness of the reason they survived — the Board's holding was no motivation to combine / no reasonable expectation of success on the specific Byrne‑WO748 and Raleigh‑Byrne theories Apple pleaded, a defect of petition drafting, not a finding of novel technical content. A future challenger with different art (or an airtight motivation narrative) is not bound by that outcome.

Strategic summary

1) Claim status of US 9,614,943. Canceled/finally unpatentable: 1, 5, 6, 7, 8, 9, 12, 13, 14 — including all four independent claims that were challenged (1, 5, 8, 12). Sustained (Board not-unpatentable + CAFC affirmed): 2, 3, 4, 15, 16, 17, 18, 19, 20. Untested: 10 and 11 (never challenged). One structural oddity worth understanding, because it drives damages exposure: claims 2–4 depend from claim 1, yet survived while claim 1 was canceled. The Board's § 318(b) certificate will cancel claim 1 but not claims 2–4; those claims nonetheless carry claim 1's "plurality of antennas … parallel processing of multiple data streams" limitations. Practically: the surviving cause of action is claims 2–4 (video/voice multi-path device plus the claim‑3 "network switch box … join a virtual network" limitation) and claims 15–20. Assertion of claims 1, 5–9 or 12–14 is untenable after 2026‑02‑27.

2) Estoppel landscape. Under § 315(e)(2), Apple Inc., Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and their real parties in interest/privies are estopped from asserting in civil actions that claims 1–9 and 12–20 are invalid on any ground they raised or reasonably could have raised in IPR2022‑01004 — which sweeps in the entire art universe available to them as of the 2022 petition (Byrne, WO748, Raleigh and the other three references). That estoppel helps you only if you are in privity with Apple or Samsung; a newly asserted defendant is not estopped, and all of those references plus any new art remain available. The FWD is, however, a public roadmap: it tells you exactly which motivation and expectation‑of‑success theories failed, so re‑running Byrne+WO748 or Raleigh+Byrne in a fresh IPR is close to malpractice unless you are adding materially new art or new evidence. Note also that the § 315(e)(2) estoppel is petitioner-side; it does not prevent Smart Mobile from asserting the surviving claims against anyone.

3) The expiration point — likely the single most valuable defensive lever, and it needs verification. Google Patents records this patent's "Anticipated expiration" as 2016‑12‑16 with current legal status "Expired – Fee Related," and the Board's own institution decision states the '943 patent's earliest application "was filed on December 16, 1996" (this is the same 1996 date this analysis flagged as anomalous against the specification's recited cross‑reference chain, whose earliest listed filing is 1999‑06‑04). If the 20‑year term runs from 1996‑12‑16, the patent expired before Smart Mobile ever sued (W.D. Tex. suits filed June/July 2021). That would compress any recovery to infringement occurring within the § 286 six‑year lookback and before expiration — roughly June 2015 to December 2016. I am flagging this as a calculation, not a conclusion: the face of the patent must be checked for PTA/PTE and for any terminal disclaimer, and the FWD's "1996" reference is a statement about the earliest application in the chain, not necessarily the benefit date actually perfected. Pull the front page of the '943 patent and the patent term adjustment data before you build a defense on it.

4) Pattern signals. Smart Mobile did not litigate the IPR appeals aggressively on the '943 patent — it defended and won the surviving claims; it filed no cross‑appeal on the canceled claims even though it was the losing party on claims 1, 5–9 and 12–14, which is a telling decision to stop spending. Apple, by contrast, is a serial and persistent challenger across the family (IPR2022‑00766, ‑00980, ‑00981, ‑01002, ‑01005, ‑01223, ‑01248, ‑01249 and more), and those sibling-patent cases have produced mixed results (e.g., affirmed losses for Apple on the '653/'946/'075 "multiplexed signals" construction on 2026‑08‑27, but a partial vacatur/remand of the Board's unpatentability findings on claims 17–21 and 23–26 of the '653/'946 patents for failure to engage Smart Mobile's "bottlenecking" evidence, and a 2026‑01‑13 reversal against Smart Mobile on issue preclusion in IPR2022‑00981 re the '936 patent). Do not attribute any of those outcomes to the '943 patent — a caution the earlier section already raised and I confirm. There is no Unified Patents (or other aggregator) IPR on this patent; the Google Patents page's "Unified Patents" strings are dataset attributions.

Recommended next steps

1. Treat claims 1, 5–9 and 12–14 as canceled. If a demand letter or complaint against you cites any of those, the response is the FWD disposition itself: "we determine that … claims 1, 5‑9, and 12‑14 … of U.S. Patent No. 9,614,943 B1 … are unpatentable" (FWD, 2023‑12‑04), plus the CAFC affirmance confirming that aspect was "not challenged here" (No. 24‑1623, 2026‑02‑27).
2. Check the term before you check the art. Verify the '943 patent's expiration date (front-page priority data, any PTA under 35 U.S.C. § 154(b), any terminal disclaimer) against the recorded 2016‑12‑16 anticipated expiration. If the patent is expired, then even on the surviving claims your exposure is limited to pre-expiration acts within the § 286 window, and an obviousness fight may be unnecessary. This is the cheapest and potentially dispositive step.
3. If you must fight on the surviving claims (2–4, 15–20), do not re-run Apple's theories. The FWD sustained them for lack of a motivation to combine and lack of a reasonable expectation of success on the Byrne‑WO748 and Raleigh‑Byrne combinations — a petition‑drafting failure the CAFC expressly held was reviewed only for abuse of discretion. Build a fresh ground with new primary art, or with a clearly pleaded, record‑supported motivation narrative that engages Byrne's built-in encryption and the "implementation challenges" the Board credited. Pin claim 3's "join a virtual network" limitation carefully: the CAFC noted neither party sought a construction of it and declined to decide it, so that limitation is genuinely unsettled and is your best § 112/indefiniteness or construction battleground.
4. Notes on the record's limits (do not over‑claim). The retrieved record does not establish (i) the dependency of claims 15–20, (ii) the full text of independent claims 5, 8 or 12 or of claims 10–11, or (iii) the exact docketed filing date of Apple's notice of appeal beyond the 2024‑08‑13 order referencing it. Claims 10–11 were never challenged and remain an untested liability for any defendant. For anything you file, pull the primary documents from USPTO PTAB E2E at https://e2e.uspto.gov/ and confirm the certificate of cancellation under § 318(b) before asserting that any claim is canceled.

I'll research the assignment chain and NPE posture for US 9,614,943 across the primary and cross-reference sources.

Let me dig deeper into the assignment reel/frame specifics, the brokered sale, and NPE directory entries.

Assignment & Ownership Analysis — US 9,614,943 B1

Sourcing note (important). I attempted to retrieve the recorded-assignment detail (reel/frame, conveyance code, correspondent of record) from the USPTO Assignment Center (https://assignmentcenter.uspto.gov/, legacy index https://assignment.uspto.gov/patent/index.html) and from indexed mirrors. The sources I could reach in this session did not return reel/frame numbers or correspondent fields for this patent. I therefore reconstruct the chain below from the Google Patents legal-events record (which mirrors the recorded assignments at date/party level) plus corroborating litigation and PTAB records. Every reel/frame slot is marked [not retrieved] rather than filled with an invented number. If a downstream reader needs the correspondents, that is the one field still to pull directly.

Inventors

Unusual patterns noted:

• No pre-filing assignment is recorded. Google Patents lists the original assignee as "Individual," so at filing the three inventors personally held the '943 application. This is consistent with a family-controlled portfolio, not an employer-owned invention.
• The inventors did not "depart" an operating assignee — the ordinary fire-sale precursor is absent. Instead the inventors are the acquiring side: Sunil and Sanjay Rao are described in the transfer opinion as Smart Mobile's sole members, and the court found "Sunil K. Rao and Sanjay K. Rao are members of Smart Mobile … they likely possess relevant knowledge regarding Smart Mobile's ownership of the asserted patents and monetization efforts." So the NPE is inventor-controlled rather than a stranger-acquired shell.
• A deceased inventor's rights were conveyed through an estate representative (Rekha K. Rao) eleven years after filing — a probate-driven title cleanup that had to be completed before the assertion campaign.
• ⚠️ Carry-over contradiction (resolved in favor of 1996). The prior section flagged Google Patents' 1996-12-16 priority date as inconsistent with the specification's Cross Reference text. The PTAB institution decision in IPR2022-01004 resolves it: it recites that the '943 patent "is a continuation application of several previously filed continuation and continuation-in-part applications, the earliest of which was filed on December 16, 1996" (Ex. 1001, code (63)). I therefore treat 1996-12-16 as the operative earliest filing and the specification's "1999" recital as incomplete, not the reverse.

Original assignee

On the face of the issued patent: application 13/621,294 was filed by "Individual" (the three Rao inventors), and the patent issued 2017-04-04. By issuance, title had already moved to IP Holdings, Inc. and then Smart Mobile, Inc. (see timeline).

IP Holdings, Inc. (a California corporation) — the first corporate holder:

• Primary line of business: IP holding / portfolio management for the Rao family patent family. There is no evidence in the retrieved record of IP Holdings, Inc. shipping a product embodying the claims of the '943 patent. The claims (multi-antenna / multi-T-R / parallel-processing / multi-port wireless device) describe device architecture; no commercial device is documented as practicing them.
• Current status: the entity executed a final conveyance of its '943 rights on 2020-09-26. No bankruptcy, dissolution, or acquisition filing for IP Holdings, Inc. appears in the retrieved record. Status: not determinable from this record — say so rather than infer.
• Related Rao-family patents list "IP Holdings Inc" as original assignee on Unified Patents' portal (e.g., US 9,191,083 B1, US 9,084,291 B1), confirming IP Holdings was the family's standard title-holding vehicle.

Did the original assignee commercialize? No retrieved evidence of shipping products. The W.D. Tex. opinion records only that "Smart Mobile has an electronics project laboratory with various components, tools, equipment, and prototypes in Texas" and that "Sunil Rao has been working on developing a mobile device in Belton, Texas with an independent contractor from Austin." Lab/prototype activity is not a product in commerce.

Assignment timeline

All entries are recorded assignment events as reflected in Google Patents legal events. Execution dates are taken as the recorded event dates; Google Patents does not expose a separate execution-vs-recording date pair here. Reel/frame and correspondent: [not retrieved] for every entry — see the sourcing note.

• 2015-07-22 (recorded 2015-07-22) — Reel [not retrieved]

  • Conveyance: Assignment
  • Assignor: RAO, RAMAN K; RAO, SANJAY K; RAO, SUNIL K (all three inventors, individually)
  • Assignee: IP HOLDINGS, INC.
  • Correspondent: [not retrieved]
  • Context: Founders consolidate personally-held invention rights into the family holding company — title cleanup while the application was still pending (issued 2017-04-04).

• 2015-07-28 (recorded 2015-07-28) — Reel [not retrieved]

  • Conveyance: Assignment ("ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignor: IP HOLDINGS, INC.
  • Assignee: SMART MOBILE, INC.
  • Correspondent: [not retrieved]
  • Context: Internal reorg — six days after the inventors' assignment, the holdings entity moves the portfolio down to an operating-named affiliate. Two transfers inside one week is a cascade cluster.

• 2020-09-24 (recorded 2020-09-24) — Reel [not retrieved]

  • Conveyance: Assignment
  • Assignor: RAO, SUNIL K., MR.
  • Assignee: SMART MOBILE INC
  • Correspondent: [not retrieved]
  • Context: Post-issuance title cleanup — inventor's residual/after-acquired rights conveyed to the operating affiliate.

• 2020-09-24 (recorded 2020-09-24) — Reel [not retrieved]

  • Conveyance: Assignment
  • Assignor: RAO, SANJAY K., MR.
  • Assignee: SMART MOBILE INC
  • Correspondent: [not retrieved]
  • Context: Same-day parallel cleanup for the second surviving inventor.

• 2020-09-24 (recorded 2020-09-24) — Reel [not retrieved]

  • Conveyance: Assignment
  • Assignor: RAO, REKHA K., MRS. (legal representative of deceased inventor Raman K. Rao)
  • Assignee: SMART MOBILE INC
  • Correspondent: [not retrieved]
  • Context: Estate/probate title cleanup — required to perfect the chain before assertion.

• 2020-09-26 (recorded 2020-09-26) — Reel [not retrieved]

  • Conveyance: Assignment ("ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignor: IP HOLDINGS, A CALIFORNIA CORPORATION
  • Assignee: SMART MOBILE INC
  • Correspondent: [not retrieved]
  • Context: Residual rights from the original holding company swept up — two days after the inventor conveyances.

• 2020-11-12 (recorded 2020-11-12) — Reel [not retrieved]

  • Conveyance: Assignment
  • Assignor: SMART MOBILE, INC.
  • Assignee: SMART MOBILE TECHNOLOGIES LLC ← current assignee of record
  • Correspondent: [not retrieved]
  • Context: Transfer-to-asserter. The patents land in the LLC that is the plaintiff in every subsequent suit. This is the last recorded assignment; no assignment out of Smart Mobile Technologies LLC exists on the record.

On the correspondent field: I could not retrieve any correspondent for this chain. Because the "repeat correspondent" signal turns entirely on recurrence, I am recording it as unclear, pending direct Assignment Center lookups — not as absent.

Timeline diagram

timeline
    title Ownership of US 9614943
    1996 : Earliest priority filing per PTAB
    1999 : Priority application filed
    2012 : Application filed by the three inventors
    2015 : Inventors assign to IP Holdings Inc
         : IP Holdings assigns to Smart Mobile Inc
    2017 : Patent issues April 4
    2020 : Inventors and estate assign to Smart Mobile Inc
         : IP Holdings assigns to Smart Mobile Inc
         : Smart Mobile Inc assigns to Smart Mobile Technologies LLC
    2021 : Apple and Samsung suits filed
    2022 : Apple and Samsung file IPR2022-01004
    2023 : PTAB final written decision issued
    2024 : Director Review denied
    2026 : CAFC affirms Board on claims 3 and 4

NPE / troll-pattern signals

Verdict

NPE — high confidence

Justification. Three independent signals are strong and dated. (1) Purpose-built assertion entity: the 2020-11-12 recording moves the '943 patent from Smart Mobile, Inc. into Smart Mobile Technologies LLC, an entity with no products in commerce whose only documented activity is licensing and litigation — a transfer-to-asserter chain ending at the plaintiff named in W.D. Tex. 6:21-cv-00603 (Apple) and 6:21-cv-00701 (Samsung). (2) Cascading transfers: seven recordings convert three individual inventors into a litigation LLC, including two assignments in six days in July 2015 and four recordings in the seven weeks from 2020-09-24 to 2020-11-12. (3) Pre-litigation restructuring: the asserting entity received title roughly seven months before the first complaints, and the inventor/estate conveyances on 2020-09-24 existed solely to perfect a clean standing record — including probate cleanup for the deceased inventor Raman K. Rao via Rekha K. Rao. PatSnap independently characterizes Smart Mobile Technologies as "a patent assertion entity (PAE)."

Two qualifications against over-reading. First, this is not a third-party shell acquisition: the inventors Sunil K. and Sanjay K. Rao are the sole members of the asserting LLC, so the pattern is inventor self-monetization rather than a fire-sale to an anonymous Delaware entity. Second, signal 3 (repeat correspondent) is unresolved — I could not retrieve any correspondent of record, and that field could either strengthen the verdict (a single recording attorney across all seven entries) or complicate it. The verdict does not depend on it, but it should be pulled before this analysis is relied on in a filing.

Verify at: USPTO Assignment Center — search "9614943" and the legacy index assignment.uspto.gov. Pull the reel/frame and correspondent for each of the seven dates above; that closes the one open signal.

Secondary sources used: https://patents.google.com/patent/US9614943/en · https://www.docketalarm.com/cases/PTAB/IPR2022-01004/Samsung_Electronics_Co._Ltd._v._Smart_Mobile_Technologies_LLC/ · https://gravesshaw.com/and-another-ipr-win-for-gs-client-smart-mobile/ · https://www.patsnap.com/resources/blog/litigation/smart-mobile-technologies-v-samsung-mobile-patent-dispute-ends-in-dismissal-patsnap-eureka/ · https://www.courtlistener.com/opinion/[10215444](/patent/10215444)/smart-mobile-technologies-llc-v-apple-inc/ · https://portal.unifiedpatents.com/patents/patent/[9191083](/patent/9191083) · https://uspto.report/patent/grant/[8,977,323](/patent/8977323)

I'll research the prior-art citations of record for US 9,614,943, starting with the USPTO record.

Let me dig into the citation tables directly.

Let me find the actual "References Cited" list on the face of the '943 patent.

Scope, method, and one important limitation

What I searched. I queried for the literal string 9614943 / 9,614,943 and isolated results to US 9,614,943 B1 ("System to interface internet protocol (IP) based wireless devices with subtasks and channels," App. 13/621,294). I filtered out look-alikes that surfaced repeatedly: WO 96/14943 A1 (an unrelated SRAM application), US 5,614,943, and the sibling Rao/Smart Mobile patents (9,191,083, 9,049,119, 9,756,168, 10,530,907, 10,397,381). The authoritative full text I was given (the Google Patents rendering of the USPTO record) is my primary source for claim scope; PTAB and Federal Circuit documents are my primary source for which art was actually applied.

Limitation you must weigh. The authoritative full text in the record I was given does not contain a "References Cited" section, and my searches surfaced the citation tables only in fragments (via "Cited By" tables on other patents' pages). I therefore cannot give you a complete, verified face-of-the-patent citation list, and I will not fabricate one. What I can give you with high confidence is the prior art that was actually applied against the '943 claims in the post-grant proceeding — which is the materially more useful universe for a §102 analysis anyway, since reachable art is what matters, not what an examiner happened to cite.

I am flagging this rather than papering over it.

1. Threshold issue: the critical date controls everything in a §102 analysis

Any anticipation answer here is only as good as the effective filing date, and the record is internally inconsistent on this point (this also resolves an anomaly flagged in the previously generated summary):

This matters enormously:

• If the critical date is 1996-12-16, then Raleigh (US 6,144,711) and WO 98/27748 are not prior art at all, and the only §102(b) reference left standing is Byrne (EP 0 660 626 A2, published 1995).
• If the critical date is June 1999, Byrne qualifies under §102(b); WO 98/27748 published 1998-06-25 — roughly three weeks after the 1998-06-04 one-year bar date — so it likely fails §102(b) and would have to be §102(a)/(e) art; Raleigh works only via §102(e) as of its earlier U.S. filing.
• The Board's finding that claims 1, 5–9 and 12–14 were unpatentable is only coherent if the art was reachable, which is consistent with a post-1998 effective date (i.e., the specification's 1999 date, not Google's 1996 field).

Caveat: I could not retrieve the Board's or the court's explicit priority determination. The above is inference from the record, clearly labeled as such.

2. The prior art actually applied against the '943 claims (verified)

Nine grounds, six references, from Petitioners' Request for Oral Argument (July 26, 2023), IPR2022-01004, Paper 32:
https://www.docketalarm.com/cases/PTAB/IPR2022-01004/Samsung_Electronics_Co._Ltd._v._Smart_Mobile_Technologies_LLC/docs/07-26-2023-Petitioner/Other__other-32-Petitioners_Request_for_Oral_Argument_.pdf

Outcome (Board FWD, Dec. 4, 2023): claims 1, 5–9, 12–14 unpatentable; claims 2–4, 15–20 upheld; Director Review denied Jan. 30, 2024; affirmed on appeal, [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.) v. Smart Mobile Technologies LLC, No. 24-1623 (Fed. Cir. Feb. 27, 2026) (Taranto, J.; Dyk, J., concurring in part and dissenting on Byrne-WO748).
https://www.govinfo.gov/content/pkg/USCOURTS-ca13-24-01623/pdf/USCOURTS-ca13-24-01623-0.pdf · https://ipwatchdog.com/2026/03/02/split-federal-circuit-upholds-smart-mobile-patent-claims-against-challenge-apple/

3. Direct answer to the §102 question — and a correction to the framing

No reference in this record was asserted as a §102 anticipation ground. Every one of the nine grounds was a §103 obviousness ground. I want to say that plainly rather than map §102 labels onto §103 findings.

That said, the task's question has a real answer if reframed correctly:

Bottom line on §102: the strongest — and only — single-reference anticipation candidate is Byrne (EP 0 660 626 A2) against claims 1 and 5–9, and even there the record shows it was pleaded and decided as §103, with the Board ultimately holding those claims unpatentable on that basis. If you want a genuine §102 theory, Byrne is where to look — but you would need to establish that Byrne discloses the IP-based-processing limitation, which the Petition itself implicitly conceded it does not.

4. Face-of-patent citations (fragmentary — flagged as unverified)

Google Patents' citation graph indicates the '943 patent cites the following (they appear in the "Cited By" tables of those patents' pages, several of which are Rao-family continuations cited in an IDS rather than as substantive art):

I am explicitly not asserting that this list is the complete or correct "References Cited" set. The snippets I retrieved did not display the table headers, so I cannot rule out that some of these are "Families Citing this family" entries rather than applicant IDS citations. If you need the complete face-of-patent citation list, it must come from the front page of the '943 patent itself or USPTO Patent Center — I was unable to retrieve that page in this session and am not substituting inference for it.

5. Reconciliation with the previously generated sections

• Resolved: the Litigation summary flagged the IPR2022-01004 petitioner and outcome as unconfirmed. His now confirmed from primary documents: captioned [[[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.) v. Smart Mobile Technologies LLC, with the Panel Change Order caption reading "SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., and APPLE INC., Petitioner," and Graves & Shaw confirming the petition was "filed by Apple and Samsung." The FWD outcome (1, 5–9, 12–14 unpatentable; 2–4, 15–20 upheld) likewise now stands confirmed by three independent sources.
• Consistent: the Patent summary's account of the Byrne+WO748 and Raleigh-Byrne grounds, and of the Fed. Cir. affirmance on a "petition interpretation"/motivation rationale, is corroborated. The Patent summary's caution about the 1996-12-16 anomaly is well founded — I have carried that flag into §1 above and shown why it is dispositive for the §102 question rather than a clerical curiosity.
• No contradiction found between the earlier sections and the newly retrieved primary documents.

6. What I could not verify (stated explicitly)

1. The complete "References Cited" list on the face of US 9,614,943 B1.
2. The full titles, inventors, and exact filing dates of US 5,784,032 (Johnston), US 5,594,737 (Pillekamp), US 5,590,133 (Billstrom), and US 6,144,711 (Raleigh) — I gave issuance years as best-estimate with confidence labels and did not invent titles.
3. The full title of WO 98/27748 beyond "Wireless Communications Station and …, " as truncated in the Federal Circuit opinion.
4. The Board's and district court's explicit effective-filing-date determination for the '943 patent.
5. Verbatim text of claims 5–14 and 15–20, which is still unavailable in the retrieved record — this limits how precisely I can map individual references to individual claim limitations beyond what the ground chart shows.

I'll gather the prior-art references and IPR record for the '943 patent before running the §103 analysis.

Obviousness Analysis — U.S. Patent No. 9,614,943 B1 under 35 U.S.C. § 103

Analyst note on inputs. The prior-art section available on this page is the prior-art record developed in IPR2022‑01004 ([[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.), Samsung Electronics America, Inc., and [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.) v. Smart Mobile Technologies LLC) — i.e., exhibits EX‑1005 through EX‑1012, led by Byrne (EP 0 660 626 A2), WO 98/27748 ("WO748"), Raleigh (U.S. 6,144,711), Johnston (U.S. 5,784,032), Pillekamp (U.S. 5,594,737), Billström (U.S. 5,590,133), Wolniansky (V‑BLAST, 1998) and Cimini (U.S. 6,005,876). I am building on, not repeating, the earlier Patent summary and Litigation summary. I did not retrieve the full Final Written Decision text or the verbatim text of claims 12, 15, 18–20, so those are flagged as inferred from the ground-to-claim mapping in the parties' papers.

1. Framework and level of ordinary skill

Legal standard. A claim is obvious under § 103 if the differences between the claimed subject matter and the prior art are such that the subject matter as a whole would have been obvious to a person of ordinary skill in the art (POSITA) at the time of the invention. Graham v. John Deere Co., 383 U.S. 1 (1966); KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). The four Graham factors are (1) scope and content of the prior art, (2) differences between the prior art and the claims, (3) the level of ordinary skill, and (4) secondary considerations. A combination of references is obvious where a POSITA would have had a motivation to combine with a reasonable expectation of success; the rationales catalogued in MPEP § 2143 (known-elements/predictable-result, simple substitution, known technique improving a similar device, design incentive/market force, obvious to try) are the standard toolkit.

Level of ordinary skill. The Board record (declarations of Dr. Michael Allen Jensen, EX‑1003 and EX‑1048) framed the analysis around a POSITA familiar with wireless transceivers, cellular/cordless multi-mode handsets, and RF/baseband signal processing as of the critical date, and the Board heard competing expert testimony (Dr. Cooklev for Patent Owner). I did not retrieve a verbatim adopted POSITA definition, so I state the customary one and flag it: a person with at least a bachelor's degree in electrical engineering (or equivalent) and roughly two to five years of experience designing wireless communication devices, or equivalent practical experience. Unverified as to the Board's exact formulation.

2. The claims and the limitations that actually drive the analysis

Claim 1 (independent — device claim), as reproduced in Patent Owner's demonstratives and the RPX claim record:

"1. A wireless communication device comprising: a plurality of antennas; and a communication component coupled to the plurality of antennas, the communication component including a processor, a transmitter, and a receiver, wherein the communication component is configured to communicate via a first frequency band using a wireless communication protocol; and wherein one or more subtasks are assigned to one or more channels, and the one or more channels are sampled and clocked individually; and wherein the processor comprises multiple ones of the one or more channels and is further configured to process a first data stream and a second data stream in parallel."
— https://insight.rpxcorp.com/patent/[US9614943B1](/patent/US9614943B1) (claim 1); reproduced in Patent Owner's Demonstrative Exhibits, IPR2022‑01004 (Ex. 2019)

The four limitations that matter for § 103 are therefore: (a) plurality of antennas; (b) a processor/transmitter/receiver communication component operating in a first frequency band under a wireless protocol; (c) "subtasks assigned to channels" with the channels "sampled and clocked individually"; and (d) the processor comprising multiple channels and processing first and second data streams in parallel.

Claim 2 (depends from claim 1) adds the nature-of-transmission clause (simultaneous vs. sequential transmit/receive over a single transmission connection) plus the limitation that the processor multiplexes the received signals into the single transmission connection.

Claim 3 (depends from claim 1), verbatim: "The device of claim 1, further in communication with a network switch box configured with a plurality of ports and configured to connect to a plurality of networks to forward packets between different networks and join a virtual network" (col. 12, lines 16–20).

Claim 8 (independent, per the demonstratives) recites two antenna sets operating under different communication protocols, combined with the "subtasks/channels" and "first and second data stream in parallel" limitations.

Claims 12, 15, 18–20 — text not verified in the retrieved record. From the grounds mapping they are independent claims (12 and 15 at least), with claims 13–14 depending from 12 and claims 16–17 depending from 15 (or from 12/15), and 18–20 constituting further independents or dependents. I treat them as "the multipath/optical-fibre plus parallel-channel claims" only as a hedge.

IMPORTANT — why this matters: the earlier Patent summary already flagged the 1996‑12‑16 vs. 1999‑06‑04 priority-date anomaly. That is not a bookkeeping footnote; it is outcome-determinative for § 103 (see § 7 below).

3. The prior art

Note from the CAFC opinion: Byrne "employs known encryption or other security measures" and operates with both modes "in progress at the same time" — which is the linchpin of the Byrne-alone theory against claim 1.
https://www.govinfo.gov/content/pkg/USCOURTS-ca13-24-01623/pdf/USCOURTS-ca13-24-01623-0.pdf

4. Ground-by-ground obviousness mapping

The petition asserted nine grounds across six references. The mapping below is taken from Petitioner's Request for Oral Argument and reproduced in the CAFC opinion.

Sources: Petitioner's Request for Oral Argument, IPR2022‑01004 (July 26, 2023), https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2022-01004/ ; Graves & Shaw FWD summary, https://gravesshaw.com/and-another-ipr-win-for-gs-client-smart-mobile/ ; CAFC opinion, https://law.justia.com/cases/federal/appellate-courts/cafc/24-1623/24-1623-2026-02-27.html

4.1 Ground 1A — Byrne alone renders claims 1, 5–9 obvious

This is the strongest and cleanest § 103 case in the record, and it succeeded.

Motivation. KSR rationale (C)/(D): the two-mode handset was a known device ready for improvement (the entire purpose of Byrne's invention is dual-mode operation), and running its two existing receive chains through a single multitasking processor was a predictable use of a known technique in the processor art — as the Petitioner's expert put it, "processors as of 1999 were multitask capable" (EX‑1048, citing Dr. Cooklev's admission at EX‑1049, 20:13‑21:4). The motivation is also self-evident from Byrne's own stated objective: to have both systems in progress simultaneously. You cannot satisfy that objective with a serialized single-chain processor.

Reasonable expectation of success. High. Parallel/multi-tasking processors and time-multiplexed DSP pipelines were conventional; nothing in the '943 specification identifies a structural barrier that a POSITA would not have expected to overcome.

Doctrinal significance. The Board, contrary to Patent Owner's argument, credited the arrows in Byrne's FIG. 2 as data (not merely "instructions") flowing from the transceivers to microprocessor 210 — this is the credibility finding that carried the Byrne ground for claim 1.
https://www.docketalarm.com/cases/PTAB/IPR2022-01004/Samsung_Electronics_Co._Ltd._v._Smart_Mobile_Technologies_LLC/07-07-2023-Petitioner/Exhibit-1048-Second_Declaration_of_Dr_Michael_Allen_Jensen/

4.2 Ground 1B / 2B — Byrne + WO748 (claims 3–4): the obviousness case that lost

Claim 3's contribution over claim 1 is the multi-port network switch box that (i) forwards packets between different networks and (ii) "join[s] a virtual network."

• The switch-box half is squarely met by WO748. WO748 discloses a "base unit 10" wired for multiple signals with plural "remote unit[s] 20," each having multiple antennas for multiple wireless networks (cellular, cordless, WLAN, paging, satellite). That is a multi-port network element forwarding traffic among heterogeneous networks — a fact neither the Board nor the CAFC disturbed. Implementing WO748's infrastructure with Byrne's cellular/cordless telephone is a combination of two complementary knowns: WO748 supplies the in-building multi-network fabric, Byrne supplies the dual-mode handset that would use it.
• The "virtual network" half is where the petition failed. Neither reference expressly discloses a VPN. Apple's expert asserted that "network devices/interfaces (like Byrne's telephone and WO748's remote and base units) are part of a virtual network," and that VPNs "enable securing the network [and] improve network scalability" (J.A. 1152‑53, 162‑68). The Board held Apple to its petition framing and found the showing insufficient; the Federal Circuit affirmed, holding the Board's petition interpretation was not an abuse of discretion and that the motivation-to-combine finding was supported by substantial evidence.

Analyst's assessment — this is a procedural loss, not a technical one. The CAFC framed its affirmance in terms of the Board's construction of the petition (what theory Apple had actually pleaded), not in terms of an absence of motivation in the art. A future challenger that pleads the VPN limitation expressly — e.g., with a § 103 ground anchored on the admitted state of the art on secure remote-access tunnelling and on a specific reason to add tunnelling between Byrne's telephone and WO748's remote units (roaming across untrusted in-building infrastructure) — would present a materially different, and stronger, case. I therefore rate claims 3–4 as not-cleared art, but vulnerable: their survival rests on the challenger's pleading defect plus the Board's evidentiary weighing under substantial evidence, which is a deferential standard.

4.3 Grounds 1C / 1D / 2C / 2D — Byrne and Raleigh families (claims 12, 13–14)

Claims 12 and 13–14 were held unpatentable over the Byrne+Johnston+Pillekamp(+Billström) and Raleigh+Byrne+Pillekamp(+Billström) combinations. These claims evidently add a multiplexed parallel-channel/multiple-I/O-path dimension (Pillekamp supplies the multiplexed RF channel handling; Johnston supplies the multichannel signal-processing background; Billström supplies the I/O or channel-bonding dimension). The rationale is the familiar one:

• Predictable-result rationale (MPEP 2143(A)). Combining a known multiplexing front-end (Pillekamp) with a known parallel-processing core (Byrne/Raleigh) to increase aggregate throughput is the combination of familiar elements according to known methods, yielding nothing more than predictable results.
• Design-incentive / market-force rationale (MPEP 2143(F)). The '943 specification itself states the motivation: 14.4 kbps is "probably the best reliable speed for a wireless network commercially available," and RF-to-digital conversion speed is "the primary bottleneck." That is an express articulation of the market pull toward channel aggregation. The specification's admission of the problem is usable against the applicant as evidence of what a POSITA would have wanted to do.

4.4 Grounds 2A–2E — the Raleigh-centric family: where the Board drew the line

Claims 2, 15, 18–20 and 16–17 survived, and the CAFC affirmed. From the briefs:

• Claim 2 (multiplexing into "the single transmission connection"). Patent Owner successfully argued that Raleigh's "pre-processor" does not meet the claimed processor requirements (Patent Owner's Sur-Reply, § III.A.2), and separately that the Petitioner had not established a reasonable expectation of success in the Raleigh‑Byrne combination. On appeal, Apple argued in the alternative that the Board had "ignored Apple's evidence and required (erroneously) identification of express teachings in Raleigh or Byrne that would show expectation of success." The CAFC affirmed, treating the Board's weighing as supported.
• Claims 15, 18–20 and 16–17 survived over Raleigh+Byrne+Pillekamp(+WO748) — a combination involving four references. Four-reference combinations are — quite apart from substantive patentability — harder to carry: each link in the chain needs its own articulated motivation, and the cumulative "why would a POSITA bolt all of these together?" question becomes a credibility problem (this is the practical bite of KSR's warning against hindsight reconstruction, applied in reverse).

The technical read: the multipath/optical-conversion family of claims (15–20, and claim 16–17's combination with WO748) is where the '943 patent's specification is most concrete — see FIG. 8/FIG. 11 (RF/IF module 804 → AD/DA 806 → processor 810 → optical converter 812 → fibre 814) and FIG. 12 (USB 1202, telephone 1204, cable 1206, fibre 1208, wireless 1210 all carrying synchronized task/subtask data). A challenger who frames the motivation around the '943 specification's own identification of the optical-to-electrical conversion bottleneck would face a "teaching away / problem not recognized" counter-argument that the record shows the Board found persuasive.

5. Why a POSITA would have been motivated to combine — consolidated articulation

Distilled from the record, the motivation story that worked (and the parts that did not):

1. Byrne is a self-contained motivation (strongest). Byrne's express objective is simultaneous dual-mode operation; the only engineering step needed to read claim 1 onto it is a multitasking processor, which was conventional. KSR rationales (C)+(D). This carried claims 1, 5–9.
2. WO748 + Byrne is a complementary-systems combination (strong on the device, weak as pleaded on the VPN). WO748 exists to remove duplicative in-building wiring for multiple wireless services; Byrne's dual-mode handset is precisely the class of device that benefits from a shared multi-protocol, multi-antenna in-building fabric. MPEP 2143(A) predictable result; MPEP 2143(F) market force (in-building coverage). The Board's rejection went to the VPN limitation and the petition's framing, not to this complementary logic.
3. Pillekamp/Johnston/Billström supply known channel-aggregation and I/O-multiplexing elements. Straightforward known-technique-improving-similar-device rationale; the '943 specification's own "bottleneck" admissions supply the "reason the improvement was wanted" (MPEP 2143(F)).
4. Raleigh supplies the parallel multi-stream/multi-antenna signal-reconstruction teaching; V‑BLAST (Wolniansky, 1998) and Cimini corroborate that POSITA-level knowledge that parallel spatial streams/antenna diversity raise throughput existed by the critical date. Where the Board rejected the Raleigh combinations, it did so on (i) the "pre-processor ≠ claimed processor" mapping and (ii) failure to establish a reasonable expectation of success — i.e., a factual/evidentiary weighing under the substantial-evidence standard, not a holding that the references are categorically non-combinable.
5. Teaching-away check. Nothing in Byrne or WO748 disparages multi-antenna or parallel-path operation. WO748 positively teaches plural antennas per remote unit. There is no teaching away to blunt the combinations that succeeded.

Secondary considerations. I found no evidence in the retrieved record of objective indicia (commercial success with nexus, licensing, industry praise, copying) that was credited by the Board. No nexus argument appears in the FWD summary or the CAFC opinion. Treat secondary considerations as not developed / not dispositive on this record — but note that a patent owner in a fresh proceeding could attempt to develop a nexus to the multi-antenna handset market.

6. Where the § 103 case is weak (and why that matters)

What is settled: on this record, claims 1, 5–9 and 12–14 are obvious as a matter of the Board's findings, and the Federal Circuit did not disturb that (those claims were not within the scope of the CAFC appeal on the merits; Apple's case was about the grounds it lost).

7. The critical-date problem (flagged in the earlier section — now with consequences)

The earlier Patent summary flagged the 1996‑12‑16 date (Google Patents "Prior art date" and "Anticipated expiration") as irreconcilable with the specification's recited chain (earliest: 09/281,739, filed 1999‑06‑04). The RPX claim record independently lists "Est. Priority Date: 12/16/1996" (https://insight.rpxcorp.com/patent/US9614943B1), and the twenty-year "anticipated expiration" of 2016‑12‑16 is itself consistent with a 1996‑12‑16 filing date somewhere in the chain (most plausibly a provisional application). I am stating this as the most probable reconciliation, not as verified fact.

Why it is decisive for § 103:

• If the effective critical date is 1996‑12‑16, then on their faces WO748 (published 1998), Raleigh (U.S. 6,144,711, issued 2000), Johnston (issued 1998‑07‑21), Pillekamp (issued 1997‑01‑14), Billström (issued 1996‑12‑31 — fifteen days after), Wolniansky (Oct. 1998) and Cimini (1999) all post-date it and would fall out as § 102(b) art unless separately qualified under § 102(a) or § 102(e) (which depends on their own filing dates and the applicant's actual date of invention). Only Byrne (published 1995‑06‑28) survives cleanly.
• The Board's outcomes are consistent with exactly that structure: the only ground that carried the full independent claim with a single reference was Byrne alone (Ground 1A). Everything built on other references either failed (WO748, Raleigh) or involved claims that are narrower (12–14).
• The earlier W.D. Tex. infringement contentions identified the '943 patent with a "priority date June 1999" (Litigation summary, Ex. K). If the litigation theory used 1999 while the term runs from 1996, that is an internal inconsistency in the patent owner's own positions that a challenger should probe — it affects both the § 102 window and the § 103 reference set.
• Conversely, if the operative date is 1999‑06‑04 (as the specification's Cross Reference section recites), then WO748, Raleigh, Pillekamp, Johnston, Billström, Wolniansky and Cimini are all available, and the multi-reference grounds become materially stronger — particularly the Raleigh-based grounds the Board rejected, because Raleigh would unquestionably be § 102(b) art.

This is, in my view, the single highest-value line of inquiry for any further § 103 challenge to the '943 patent.

8. Bottom line

• Byrne (EP 0 660 626 A2) alone renders claims 1 and 5–9 obvious: a dual-mode (cellular + cordless) radio telephone operating both systems "in progress at the same time" with a microprocessor handling received data streams discloses every limitation of claim 1, and running two concurrent receive chains through a conventional multitasking processor is a predictable use of a known technique. The Board so held; the CAFC did not disturb it. High confidence.
• Byrne + Johnston + Pillekamp (+ Billström) and Raleigh + Byrne + Pillekamp (+ Billström) render claims 12 and 13–14 obvious on the predictable-result and known-element-combination rationales, with the '943 specification's own "bottleneck" admissions supplying the design incentive. High confidence (Board-held).
• Byrne + WO748 establishes the multi-port, multi-network, multi-antenna network switch box of claim 3, but the "join a virtual network" limitation defeated the ground as pleaded. The affirmance rests on petition interpretation and substantial-evidence review of motivation — a procedural rather than technical defeat. Claims 3–4 remain vulnerable to a better-pleaded VPN ground.
• Claims 2, 15, 16–17, 18–20 survived, primarily on (i) claim-construction mapping failures (Raleigh's pre-processor), (ii) insufficient reasonable-expectation-of-success showings, and (iii) the dilution that comes with four-reference combinations. These are the claims with the strongest residual validity.
• The 1996‑12‑16 vs. 1999‑06‑04 priority question is the pivot for any future § 103 attack: a 1996 date reduces the prior-art set essentially to Byrne (favoring validity); a 1999 date restores WO748, Raleigh, Pillekamp, Johnston, Billström, Wolniansky and Cimini (favoring obviousness).

Disclaimer. This is a technical and litigation-informed analysis of the record retrieved on this page, not a legal opinion or a freedom-to-operate/validity clearance. Claim text for claims 12, 15 and 18–20, the full Final Written Decision, the adopted POSITA definition, the claim-construction record, and the exact effective filing date were not available to me and are flagged accordingly.