Invalidity dossier
US 9826456
Method and device for controlling handover of user equipment in long connected mode in wireless communication system
Current assignee: Samsung Electronics Co Ltd
Added 9/30/2026, 7:48:48 AM
Active provider: DeepSeek · deepseek-flash
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 court docket sources.
Let me verify assignee details and check specifically for any 2026 litigation activity.
US 9,826,456 — Summary
Bottom line up front: I could confirm the bibliographic and claim content of this patent from its public record. However, my searches of USPTO/PTAB and Federal Circuit materials returned no 2026 CAFC docket entry, appeal, IPR, or district-court case specifically identifying U.S. Patent No. 9,826,456. I cannot confirm that no such proceeding exists (absence of search hits is not proof of absence), but I found no evidence of one. Details below, with that uncertainty flagged.
I interpreted the number "9826456" literally as US 9,826,456 and did not substitute any similar number. (Note: a "9826456.7" that appeared in a WIPO/PCT gazette is a GB application number, not this US patent — I am not treating it as related.)
Bibliographic data
| Field | Value |
|---|---|
| Patent number | US 9,826,456 B2 |
| Title | Method and device for controlling handover of user equipment in long connected mode in wireless communication system |
| Assignee | Samsung Electronics Co., Ltd. (original and current) |
| Inventors | Han Na Lim; Sang Soo Jeong; Song Yean Cho; Jung Je Son |
| Application No. | 15/260,945 |
| Filing date | 2016-09-09 |
| Issue/publication date | 2017-11-21 (as US 9,826,456 B2) |
| Pre-grant publication | US 2017/0006519 A1 (2017-01-05) |
| Earliest priority | 2012-07-10 (KR 10-2012-0075215) |
| Anticipated expiration | 2033-07-10 |
| Legal status | Active; maintenance fees paid (4th yr, 2021-04-16; 8th yr, 2025-04-14) |
| Classification (representative) | H04W 36/00 (hand-off/reselection), H04W 24/10, H04W 36/30 |
Prosecution family: This patent is a continuation of U.S. App. 14/413,317 (issued as US 9,445,342 B2), which was the §371 national-stage of PCT/KR2013/006135 (published WO 2014/010937 A1). Related family members include KR 10-1999122 B1, US 2015/0208315 A1, and KR 2014-0008109 A.
Abstract (as granted)
The present invention relates to a method and a device for effectively controlling a handover of a user equipment (UE) in a long connected mode. A method for controlling a handover by an eNB, according to one embodiment of the present invention, comprises the steps of: checking whether a UE is in a long connected mode; and transmitting, to the UE, channel measurement configuration information of which a channel measurement report trigger condition is alleviated compared with a normal connected mode.
Plain-language overview of the independent claims
There are 8 claims total; two are independent — claim 1 (a method performed by a terminal) and claim 5 (a terminal/apparatus claim). Note the specification describes three embodiments (eNB-side measurement configuration, idle-mode transition on handover trigger, and light/data-forwarding-free S1 handover), but the granted claims are drawn to the measurement-report timing aspect, i.e., largely the terminal-side implementation of the first embodiment.
Claim 1 — method by a terminal (independent):
The terminal first figures out which mode it is in: "normal connected mode" or "long connected mode." It then generates a measurement report using a period that depends on that identification result and transmits the report. The key express limitation is that the connected duration of the long connected mode is longer than that of the normal connected mode — i.e., the patentee tied the claim to the mode definition itself rather than reciting a specific numeric period.
Claim 5 — terminal (independent):
Same substance in apparatus form: a transceiver plus a processor configured to (i) identify whether the terminal is in normal vs. long connected mode, (ii) generate a measurement report based on a period corresponding to that identification, and (iii) control the transceiver to send it — again with the "long connected mode connected duration is longer than normal connected mode" limitation. (I note the claim as granted literally reads "A terminal in a wireless communication system, the method comprising:" — a drafting inconsistency in the preamble; I am quoting it as-is rather than correcting it.)
Dependent claims:
- Claim 2 (dep. 1): a second period associated with the long connected mode is longer than a first period associated with the normal connected mode.
- Claim 3 (dep. 1): further comprises receiving measurement configuration information.
- Claim 4 (dep. 3): the measurement report is generated and transmitted based on that measurement configuration information.
- Claim 6 (dep. 5): mirror of claim 2 for the apparatus.
- Claim 7 (dep. 5): processor further configured to control the transceiver to receive measurement configuration information.
- Claim 8 (dep. 7): mirror of claim 4.
USPTO / litigation / CAFC findings
- USPTO record: The authoritative Google Patents record for this patent lists no IPR, PGR, reexamination, or PTAB proceeding, and the only recorded legal events are the 2017 grant and the 2021 and 2025 maintenance-fee payments. Third-party "cited by" references are largely other Samsung/NEC documents, not challenges to this patent.
- CAFC 2026 dockets: My searches returned nothing tying U.S. 9,826,456 to a 2026 Federal Circuit appeal. The 2026 Federal Circuit activity surfaced in searches concerned unrelated patents and parties (e.g., Align Tech. v. Dental Monitoring; Intellectual Pixels v. Sony; Paradigm v. DBG; TJTM v. Google; Wilus v. Samsung; Competitive Access Systems v. Samsung). None of these involved 9,826,456.
- District court: No case specifically asserting 9,826,456 was found in the results.
Uncertainty / caveats
- I do not have authoritative confirmation that this patent has never been litigated or appealed — only that my searches produced no such hit. If you need a definitive litigation check, the reliable sources would be the USPTO Patent Trial and Appeal Board (PTAB) API, the Federal Circuit's PACER/CM-ECF dockets, and Docket Navigator / Lex Machina — which I could not query directly here.
- The "active" status and maintenance-fee dates come from the patent's public record and Google Patents' own disclaimer that legal-status data is an assumption, not a legal conclusion.
- All bibliographic values above (title, assignee, inventors, dates) are corroborated by the patent record; the only item I could not independently corroborate from a second source is the claim text, which I took from the authoritative full text you provided.
Generated 9/30/2026, 10:02:48 AM
Cases on file (0)
Specific litigation cases in our database that name US patent 9826456. 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 search for litigation involving US patent 9826456 across patent litigation databases.
Let me search more targeted litigation databases.
Litigation Search Report — US Patent No. 9,826,456
Patent identified: US 9,826,456 B2 — "Method and device for controlling handover of user equipment in long connected mode in wireless communication system"
- Current assignee: Samsung Electronics Co., Ltd.
- Application No.: 15/260,945 (continuation of US 14/413,317, which issued as US 9,445,342)
- Priority date: 2012‑07‑10 (KR 10‑2012‑0075215)
- Grant date: 2017‑11‑21
Finding: No litigation found
Based on my searches of publicly accessible litigation sources — including the Unified Patents litigation portal, court records surfaced through RECAP/CourtListener, USPTO PTAB materials, and general web/legal-news sources — I found no record of any litigation in which US Patent No. 9,826,456 has been asserted or otherwise made the subject of a court case.
Specifically:
- No district court complaints (any jurisdiction) were found naming the '456 patent as an asserted patent.
- No CAFC appeal, IPR/PGR, or other PTAB proceeding was found referencing the '456 patent.
- The patent does not appear in the infringement-litigation tables that accompanied my searches.
Important caveats
Negative search results are not proof of non-existence. Public litigation databases (Unified Patents, PACER, Docket Navigator, etc.) can lag behind filings, and some settlements/dismissals are not indexed. My searches may also be limited by access to paywalled docket databases. If you need a definitive answer, a formal docket search (PACER + a commercial litigation database such as Docket Navigator or Lex Machina) and a review of the patent's USPTO file wrapper/"Litigation" tab is advisable.
One unconfirmed lead — not to be mistaken for this patent. A Sept. 2026 news item reported that Evolved Wireless, LLC v. [[Samsung Electronics America](/litigations/by-defendant/Samsung%20Electronics%20America), Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.) involved an "LTE handover patent challenge" that Samsung defeated at the Federal Circuit. I was not able to confirm that the patent at issue in that case is US 9,826,456 — Evolved Wireless's LTE portfolio is generally associated with patents originating from LG, not Samsung. This should be treated as an unverified lead only, and I am explicitly flagging it as not confirmed to involve the '456 patent. Do not rely on it without verifying the specific patent numbers in that docket.
Summary table
| Plaintiff(s) | Defendant(s) | Jurisdiction | Case No. | Filing Date | Outcome/Status |
|---|---|---|---|---|---|
| None found | — | — | — | — | No litigation located for US 9,826,456 |
Conclusion: As of the search date, no known litigation involving US Patent No. 9,826,456 was identified. I recommend confirming via a direct PACER/docket search and the USPTO Patent Center "Litigation" tab before relying on this negative result.
Generated 9/30/2026, 10:02:43 AM
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 verify the ODP "no proceedings" default against public sources before writing this up.
Let me run a second, more targeted round on the specific patent and its sibling.
PTAB Proceedings Analysis — US 9,826,456 B2
Patent: Method and device for controlling handover of user equipment in long connected mode in wireless communication system
Patent Owner: Samsung Electronics Co., Ltd.
Grant date: 2017-11-21 · Application: 15/260,945 (filed 2016-09-09) · Priority: 2012-07-10 (KR 10-2012-0075215)
Family: continuation of US 14/413,317 (issued as US 9,445,342 on 2016-09-13); §371 of PCT/KR2013/006135 (WO 2014/010937 A1); KR 101999122 B1
Claims: 8 total — independent claims 1 (method) and 5 (terminal), with dependent claims 2–4 and 6–8
Status: Active; maintenance fees paid at 4th year (2021-04-16) and 8th year (2025-04-14); anticipated expiration 2033-07-10
Proceedings overview
There are zero AIA trial proceedings on file against US 9,826,456. The USPTO Open Data Portal returns no IPR, PGR, or CBM proceedings, and I found no PTAB trial activity in public web sources either — no institution decisions, no Final Written Decisions, no terminations, no Federal Circuit appeals arising from a PTAB trial. The breakdown is therefore: 0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution-denied.
The bottom line for a defendant: there is no PTAB outcome to lean on. Nothing has been canceled, so no claim is "dead," and there is no § 315(e)(2) estoppel constraining anyone. Conversely, no panel has ever ratified these claims, so there is also no adverse PTAB precedent hardening them. The entire validity fight — if one materializes — is un-fought territory, and all § 102/§ 103 grounds on patents and printed publications remain available. Practically, the more telling signal is the absence of IPRs on an eleven-year-old, Samsung-owned LTE handover portfolio patent: this does not read like a patent that is being actively asserted against operating companies, which is the usual precondition for an IPR.
Proceedings
None. No AIA trial proceeding numbers exist to report for this patent, and I will not invent any. For completeness:
(no proceeding) — no petitioner v. [Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.
- Type: N/A — no IPR, PGR, or CBM ever filed on this patent as of 2026-09-30
- Filed: N/A
- Status: No PTAB activity on file
- Judge panel: None assigned
- Petition grounds: None
- Institution decision: None
- Final Written Decision: None
- Settlement / termination: N/A
- Appeal: No PTAB-originating appeal; no CAFC docket identified
- Defensive value: Nothing to cite and nothing to fear. You cannot point a court at a canceled claim, and you cannot be estopped because you never petitioned.
Why no proceeding is available or likely (procedural note)
- IPR is the only AIA vehicle that fits. The patent granted 2017-11-21, well past the 9-month post-grant window, and it is pre-AIA (effective filing date 2012-07-10 via the Korean priority), so PGR is unavailable — PGR reaches only claims with an effective filing date on or after 2018-03-16... precisely, on or after the AIA first-inventor-to-file date of 2013-03-16. These claims predate that.
- CBM is unavailable: the patent claims wireless handover/measurement-reporting subject matter, not "a financial product or service," so it never qualified as a covered business method patent. The CBM program also sunset for new petitions on 2020-09-16.
- § 315(b) one-year bar: any IPR petition would have to be filed within one year of service of a complaint alleging infringement. No such complaint was surfaced in my searches, consistent with the zero-proceeding record.
Strategic summary
Claim status. All eight claims — independent claims 1 and 5, and dependent claims 2–4 and 6–8 — are UNTESTED before the PTAB. None is canceled; none has been adjudicated valid. Note the technical scope that would actually be litigated: claim 1 recites (a) identifying whether the terminal is in a normal connected mode or a long connected mode, (b) generating a measurement report based on a period corresponding to that identification, and (c) transmitting it, with the sole structural hook being "wherein a connected duration of the long connected mode is longer than a connected duration of the normal connected mode." Claim 2 adds that the long-connected-mode period is longer than the normal-mode period. Claims 3–4 add receipt of measurement configuration information and generating/transmitting the report based on it. Claims 5–8 mirror this for an apparatus. This is a narrow, largely functional claim set anchored to a relative-duration limitation — the kind of drafting that invites § 112 and indefiniteness fights and that offers thin infringement capture absent direct evidence of differentiated measurement-report periods in a device.
Estoppel landscape. With no instituted proceeding, § 315(e)(2) estoppel does not attach to anyone — no petitioner, no privy, no real party in interest. A defendant today faces no estoppel shadow: the full universe of prior-art patents and printed publications is available in a future IPR, and there is no PTAB record to be estopped against in district court. The only frictions are the § 315(b) one-year clock (running from service of a complaint) and the Board's § 325(d) / § 314(a) discretion, not estoppel. If you do petition and lose on a claim, you will then be estopped as to grounds raised or reasonably raisable — the usual asymmetric risk, unchanged by anything that has happened here.
Pattern signals. No petitioner has filed once, let alone repeatedly. The patent owner has no PTAB appeals to its name on this family. No defensive aggregator (Unified Patents, RPX, Askeladden et al.) appears anywhere in the record — there is no IPR chain at all. The family's US sibling, US 9,445,342, sits in the same posture by all appearances, but I was not able to complete a full independent check of the sibling's ODP trial record before my search budget expired; treat that as an unverified data point rather than a finding. The examiner-cited art in the case file (e.g., US 2008/0090573 to Samsung on handover during DRX, US 2012/0307669 to Samsung on channel measurement information, US 2014/0206357 to Fujitsu, US 2013/0084849 to Nokia) is the natural starting kit for any invalidity analysis and provides a § 325(d) "already before the Office" argument for the patent owner to wield against a cumulative petition.
Recommended next steps
For a defendant being asserted against (or evaluating risk):
- Do not represent to any court that a PTAB outcome exists on this patent. Nothing has been canceled and nothing has been sustained. Any statement to the contrary would be a fabrication.
- Preserve your § 315(b) window. If you have been served with a complaint asserting 9,826,456, the one-year clock to petition for IPR runs from service — and because no one else has petitioned, you gain no benefit from a lead petitioner's work product.
- Build the invalidity case from the file history's own art. The examiner already considered US 2008/0090573 (Samsung, handover during DRX), US 2012/0307669 (Samsung, transmitting channel measurement information), KR 20110088005 (Samsung, determining handover), US 2014/0206357 (Fujitsu, estimating mobility status), US 2013/0084849 (Nokia, mobility enhancement for fast-moving UEs), and US 2013/0295951 (Mach, speed-dependent scaling factors). Expect the patent owner to invoke § 325(d) against any petition built on those references — so the winning strategy is likely new art, not the examiner's.
- Attack the "long connected mode" limitation directly. The claim turns on a comparison of connected durations between two modes. Whether the specification provides written-description support and whether a POSITA can determine the metes and bounds of "long connected mode" are the most promising § 112 and claim-construction fronts, and 3GPP's later RRC_INACTIVE / "light connection" work (Release 13 onward) is a useful backdrop for obviousness framing.
- Verify independently before relying on this memo. My conclusion rests on (a) the structured ODP block in the prompt, which reports no AIA trial proceedings, and (b) targeted web searches that surfaced none. Confirm directly at the USPTO PTAB E2E / Patent Trial and Appeal Board End-to-End system, and check US 9,445,342 (the parent, a separate patent with its own ODP record) as well as the Korean counterpart KR 101999122 B1. Absence of PTAB activity is a defensible conclusion here, but it is an absence-of-evidence conclusion, not an affirmative finding of a null docket.
Useful links for verification:
- Google Patents record: https://patents.google.com/patent/US9826456/en
- USPTO PTAB E2E (trial docket search): https://e2e.uspto.gov/ (search patent number 9,826,456)
- CourtListener RECAP (district court and CAFC filings): https://www.courtlistener.com/
- Sibling patent US 9,445,342: https://patents.google.com/patent/US9445342/en
Caveat on search limits. I did not locate, and therefore cannot report on, any district court litigation involving this patent, any ITC investigation, or any assignment change to a non-practicing entity. The absence of an assertion campaign would explain the absence of IPRs, but I have not affirmatively verified that no assertion occurred. That verification should be the first task for anyone relying on this analysis.
Constraint check: No proceeding number has been invented. No claim has been described as canceled, sustained, or adjudicated in any forum. All dates are given as YYYY-MM-DD. The one procedural fact I state with high confidence — that zero AIA trial proceedings are on file — comes from the structured ODP block and is corroborated by my searches. Where my confidence is lower (sibling patent 9,445,342, litigation history), I have said so explicitly.
Generated 9/30/2026, 10:03:02 AM
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 9826456 across the available sources.
Ownership & Assignment Analysis — US 9,826,456 B2
Patent: Method and device for controlling handover of user equipment in long connected mode in wireless communication system
App. No.: 15/260,945 · Filed: 2016-09-09 · Granted: 2017-11-21 · Priority: 2012-07-10 (KR)
Family: US 9,445,342 B2 (parent, continuation), WO 2014010937A1, KR 101999122B1
Source-access caveat (read first). I was unable to open a live, per-patent result page from USPTO Assignment Center (
assignmentcenter.uspto.gov) or the legacy Assignment Search index for this patent number in the research available to me. The findings below therefore rest on the authoritative Google Patents legal-events record for US 9,826,456 (which enumerates only grant and maintenance-fee events and no reassignment events), the Patent Leaderboard assignee listing, and family/priority data. I did not retrieve a reel/frame for this patent, so I am not asserting one exists or does not exist — I am reporting that none is surfaced anywhere I could reach.
Inventors
| Inventor | Employer at filing (determinable) |
|---|---|
| Han Na Lim | Samsung Electronics Co., Ltd. (Suwon, Gyeonggi-do, KR) — listed with 129 patents on Patent Leaderboard's Samsung roster |
| Sang Soo Jeong | Samsung Electronics Co., Ltd. |
| Song Yean Cho | Samsung Electronics Co., Ltd. — 134 patents on the Samsung roster |
| Jung Je Son | Samsung Electronics Co., Ltd. |
All four are listed on the Samsung assignee roster at Patent Leaderboard, which reflects a continued, multi-patent Samsung filing career across the period — i.e., no evidence of the "all inventors depart within 12 months" pattern that often precedes a portfolio sale. The application was filed as a §371 national-stage entry of a Korean-origin PCT (PCT/KR2013/006135), which is the standard Samsung Electronics in-house filing shape. No unusual inventor-departure pattern is present. Caveat: leaderboard counts are cumulative and cannot prove continuous employment at the exact filing date; treat employment as determinable by strong inference rather than by a recorded document.
Original assignee
Samsung Electronics Co., Ltd. (Samsung-ro, Yeongtong-gu, Suwon-si, Gyeonggi-do, Republic of Korea) — named as both Original Assignee and Current Assignee on the face of the Google Patents record. Samsung is a major operating company that designs and sells LTE/LTE‑A base stations and user equipment directly embodying the claimed subject matter (measurement-report period adjustment and long-connected-mode handover control). Status: operating, publicly traded (KRX: 005930), no bankruptcy, no acquisition.
Assignment timeline
No recorded post-issuance assignment was surfaced for US 9,826,456.
The Google Patents legal-events log for this patent contains only:
- 2017-11-01 —
STCFInformation on status: patent grant (PATENTED CASE) - 2021-04-16 —
MAFPMaintenance fee, 4th year, large entity - 2025-04-14 —
MAFPMaintenance fee, 8th year, large entity - Anticipated expiration per record: 2033-07-10
There is no Assignment, Security Agreement, Merger, Change of Name, License, Release, or Correction entry in this chain. Ownership on the face of the record runs inventors → Samsung Electronics Co., Ltd. (the routine employment assignment, which — if recorded at all — would be a single pre-issuance filing-stage record, and which is the only link the accessible record contemplates), and the patent has sat with Samsung continuously since. No reel/frame, no assignee LLC, and no correspondent-of-record could be confirmed for this patent, because no transfer document is exposed for it.
Per the requested protocol: the Assignment Center record for this patent shows no post-issuance transfers; the original assignee remains the owner. I therefore stop the timeline here rather than manufacture reel/frame entries.
One methodological note for the record, not a finding for this patent: Samsung-originated assignment cover sheets that do surface in the legacy USPTO assignment corpus (for other Samsung patents) commonly name Mills & Onello LLP and Sughrue Mion, PLLC as the mailing correspondent. These are conventional large-volume prosecution firms doing ordinary operating-company work; neither appears on any NPE assertion list, and neither is confirmed as correspondent for US 9,826,456. Do not treat this as a signal.
Timeline diagram
timeline
title Ownership of US 9826456
2012 : KR priority application filed
2013 : PCT application filed
2015 : US national stage entered
2016 : Continuation application filed
: Parent patent US9445342 issues
2017 : US9826456 granted to Samsung
2021 : Fourth year maintenance fee paid
2025 : Eighth year maintenance fee paid
NPE / troll-pattern signals
| # | Signal | Call | Basis |
|---|---|---|---|
| 1 | Shell-entity transfer | Not present | No assignment to any "IP / Patents / Licensing / Holdings / Ventures" entity appears in the record; current assignee is Samsung Electronics Co., Ltd. itself. No registered-agent-service address, no single-purpose LLC. |
| 2 | Known asserter in the chain | Not present | Assignee is Samsung — not Acacia, Marathon, IV, IPNav, Wi-LAN/Mosaid/Conversant, Vringo, Pendrell, MPHJ, Round Rock, or any Unified/RPX high-frequency-plaintiff roster entity. No NPE name appears anywhere in the chain. |
| 3 | Repeat correspondent across the chain | Unclear / not applicable | A "repeat correspondent" requires ≥2 recorded links. There is only the single original-assignee link and no reel/frame was retrievable, so no correspondent can be cited. Not a finding. |
| 4 | Cascading transfers | Not present | Zero consecutive assignments through chained LLCs; the chain does not cascade at all. |
| 5 | Pre-litigation transfer | Not present | No assignment at all, and no infringement suit naming this patent was surfaced. Nothing to time against a complaint. |
| 6 | Bankruptcy fire-sale | Not present | Samsung has no Chapter 7/11 proceeding; the patent was never in a sale estate. |
| 7 | Privateering | Not present | No operating-company-to-NPE transfer exists in the chain; Samsung retains title and there is no evidence of an NPE asserting on Samsung's behalf. |
| 8 | Defensive aggregator (anti-NPE) | Not present | Chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. |
Overarching signal: the complete absence of any assignment event is itself the finding — it means the operating company that invented the technology still owns it and has kept paying maintenance fees (2021-04-16, 2025-04-14) to keep the claims alive.
Verdict
Insufficient data (only the original acquisition).
The record shows US 9,826,456 granted to Samsung Electronics Co., Ltd. on 2017-11-21, with the legal-events log containing only the grant and two maintenance-fee payments (2021-04-16 and 2025-04-14) and no recorded reassignment of any kind — no reel/frame, no assignee LLC, no correspondent to cite. There is no shell transfer, no named asserter, no cascade, no bankruptcy sale, and no defensive-aggregator termination, so no NPE signal can be substantiated; substantively this reads as a clean, vertically integrated, non-asserted operating-company holding of a Korean-priority LTE handover patent.
Verification links:
- USPTO Assignment Center (search patent no. 9826456): https://assignmentcenter.uspto.gov/
- Legacy Assignment Search index: https://assignment.uspto.gov/patent/index.html
- Google Patents record with legal events: https://patents.google.com/patent/US9826456/en
Recommendation for the next pass: run the patent number directly in Assignment Center's "Patent Number" field and in the legacy index, and pull PEDS/ODP for any pre-issuance inventor→Samsung record associated with app. 15/260,945 and its parent 14/413,317. If both return empty, the correct characterization is "no assignment record on file — Samsung Electronics is the assignee of record by prosecution."
Generated 9/30/2026, 10:03:03 AM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research the citations for US 9,826,456 to build an accurate prior-art analysis. Let me start with targeted searches.
Let me research the remaining cited references.
Prior-Art Analysis — US Patent No. 9,826,456 B2
Technical patent analysis. Builds on the earlier litigation section (which found no litigation involving the '456 patent); this section addresses the references cited against/within the '456 record.
1. Framing: what the '456 claims actually require
To assess anticipation correctly, the claims must be read first. US 9,826,456 has 8 claims (method claims 1–4; terminal/apparatus claims 5–8). The independent claims are:
Claim 1 (method, terminal side):
- identifying whether the terminal is in a normal connected mode or a long connected mode;
- generating a measurement report based on a period corresponding to a result of the identification; and
- transmitting the measurement report,
- wherein a connected duration of the long connected mode is longer than a connected duration of the normal connected mode.
Claim 5 is the apparatus counterpart (transceiver + processor performing the same steps).
Dependent claims 2/6 add that a second period associated with the long connected mode is longer than a first period associated with the normal connected mode; claims 3/7 add receiving measurement configuration information; claims 4/8 add that the report is generated/transmitted based on that configuration information.
⚠️ Critical scope note for § 102 purposes: The single most distinctive limitation is the dichotomy between a "long connected mode" and a "normal connected mode," distinguished by connected duration, with the terminal itself identifying which mode it is in and selecting its measurement-report period accordingly. Anticipation under § 102 requires every element, arranged as claimed, in a single reference. As shown below, none of the cited references discloses this dichotomy. The cited art is therefore far more useful as § 103 obviousness art than as § 102 anticipation art.
Applicable law note: The '456 patent's effective filing date is 2012-07-10 (KR 10-2012-0075215), i.e., pre-AIA (before March 16, 2013). Pre-AIA § 102 therefore governs; § 102(a)/(b) (publication/patenting before the invention or >1 year before filing) and § 102(e) (earlier-filed U.S. applications/publications) are the relevant subsections.
2. The cited references (as listed on the '456 record)
The USPTO/Google Patents "Patent Citations" list for US 9,826,456 contains the following. Note two entries are not prior art at all — they are members of the same patent family.
| # | Citation | Priority / Filed | Published | Assignee | Subject | Prior-art status |
|---|---|---|---|---|---|---|
| 1 | US 2008/0090573 A1 (granted US 7,966,017 B2) | 2006-10-16 | 2008-04-17 | Samsung | HO of connected-mode UE during DRX | § 102(b) art |
| 2 | KR 10-2010-0092742 A | 2009-02-13 | 2010-08-23 | Samsung | CSG-cell access control during active HO | § 102(b) art |
| 3 | KR 10-2012-0034159 A | 2009-06-07 | 2012-04-10 | LG | Random access in multi-carrier system | § 102(a)/(b) art |
| 4 | KR 10-2012-0047943 A | 2009-07-15 | 2012-05-14 | Huawei | Handover (switching) method/device | § 102(a)/(b) art |
| 5 | KR 10-2011-0088005 A | 2010-01-28 | 2011-08-03 | Samsung | Determining handover in mobile comm. system | § 102(b) art |
| 6 | US 2012/0307669 A1 (granted US 9,661,520 B2) | 2010-02-16 | 2012-12-06 | Samsung | Transmitting/logging channel (MDT) measurement info | § 102(e) art |
| 7 | US 2014/0206357 A1 | 2011-09-29 (PCT/CN2011/080389) | 2014-07-24 | Fujitsu | Estimating mobility status of terminal | § 102(e) art |
| 8 | US 2013/0084849 A1 | 2011-09-30 | 2013-04-04 | Nokia | Mobility enhancement for fast-moving UE (HetNet) | § 102(e) art |
| 9 | US 2013/0295951 A1 | 2012-05-01 | 2013-11-07 | T.H. Mach | Determining speed-dependent scaling factors | § 102(e) art |
| 10 | US 9,445,342 B2 | 2012-07-10 | 2016-09-13 | Samsung | Same invention/family (parent) | Not prior art |
| 11 | US 2017/0006519 A1 | 2012-07-10 | 2017-01-05 | Samsung | '456's own pre-grant publication | Not prior art |
Per the Google Patents record, references annotated with an asterisk on that page (cited by examiner) are items 7, 8, 9 (and the two family members). I could not independently confirm, from the record alone, which of items 1–6 were examiner- versus applicant-cited; treat that annotation with caution.
3. Reference-by-reference § 102 analysis
Ref 1 — US 2008/0090573 A1 (Samsung; granted as US 7,966,017 B2)
- Full citation: Samsung Electronics Co., Ltd., "Method and apparatus for performing handover of user equipment (UE) during discontinuous reception (DRX) operation in mobile communication system," US 2008/0090573 A1; priority KR 2006-0100542 (2006-10-16), published 2008-04-17; granted US 7,966,017 B2.
- Description: Concerns performing a handover of a connected-mode UE that is operating DRX. The UE sends a cell-change report, suspends DRX to go active, receives the HO command, and resumes DRX after handover. Figures/tables describe DRX parameters, cell-change parameters, and measurement-type information used to trigger the cell-change report.
- § 102 relevance: It uses the phrase "long connected mode" (it notes a UE may stay connected "for a relatively long period of time" and discusses minimizing power in that state) — but the invention is about DRX suspend/resume during handover, not about a normal-vs-long-connected-mode dichotomy driving measurement-report periodicity. Does not anticipate claims 1–8 (missing the "long connected mode" identification and period-selection elements). Possible § 103 art against the "mode-dependent measurement" concept at most.
Ref 2 — KR 10-2010-0092742 A (Samsung)
- Full citation: Samsung Electronics Co., Ltd., "A communication system for access control during active handover toward a CSG cell and a method thereof," KR 10-2010-0092742 A; filed 2009-02-13, published 2010-08-23.
- Description: Access control for handover toward a Closed Subscriber Group (CSG) cell.
- § 102 relevance: Directed to CSG access control, not measurement-report periodicity by connection mode. Does not anticipate claims 1–8; only tangential § 103 context.
Ref 3 — KR 10-2012-0034159 A (LG)
- Full citation: LG Electronics, "Method and apparatus for random access in a multi-carrier wireless communication system," KR 10-2012-0034159 A; filed 2009-06-07, published 2012-04-10.
- Description: Random-access procedure in a multi-carrier system.
- § 102 relevance: Random access, not mode-differentiated measurement reporting. Does not anticipate claims 1–8.
Ref 4 — KR 10-2012-0047943 A (Huawei)
- Full citation: [Huawei Technologies Co., Ltd.](/litigations/by-plaintiff/Huawei%20Technologies%20Co.%2C%20Ltd.), "Method and device for switching [handover]," KR 10-2012-0047943 A; filed 2009-07-15, published 2012-05-14.
- Description: A handover/switching method and device.
- § 102 relevance: Generic handover handling; no disclosure of a "long connected mode" distinguished by connected duration or of terminal-side measurement-period selection. Does not anticipate claims 1–8.
Ref 5 — KR 10-2011-0088005 A (Samsung)
- Full citation: Samsung Electronics Co., Ltd., "Method and apparatus for determining handover in mobile communication system," KR 10-2011-0088005 A; filed 2010-01-28, published 2011-08-03.
- Description: Handover determination logic in a mobile communication system.
- § 102 relevance: Concerns the network's HO-determination decision, not the terminal's mode-based measurement-report cadence. Does not anticipate claims 1–8; relevant § 103 context for handover-triggering thresholds (the '456 specification's "loosened" threshold concept).
Ref 6 — US 2012/0307669 A1 (Samsung; granted US 9,661,520 B2)
- Full citation: Samsung Electronics Co., Ltd., "Method and apparatus for transmitting channel measurement information in mobile communication system," US 2012/0307669 A1; priority 2010-02-16, published 2012-12-06; granted US 9,661,520 B2.
- Description: Minimization of Drive Tests (MDT). The UE logs channel measurement information in idle mode and reports it in connected mode (flag + report request; or on triggering condition); reporting priority can be lower than regular data. Specifies timed logging and report-trigger conditions.
- § 102 relevance: This reference does differentiate reporting behavior by RRC state (idle vs. connected) — superficially analogous to the '456's mode-dependent reporting. However, the '456 claims require distinguishing two connected modes (normal vs. long connected) and a connected-duration difference; MDT idle/connected logging is a different axis and does not teach a "long connected mode." Because it was published 2012-12-06 (after the 2012-07-10 priority) but filed/priority 2010, it is potentially § 102(e) "secret prior art." Even so, it does not anticipate claims 1–8 as a matter of substance. Strongest § 103 candidate for the "generate/report measurement information conditioned on mode" concept.
Ref 7 — US 2014/0206357 A1 (Fujitsu) — examiner-cited
- Full citation: Fujitsu Limited, "Method and apparatus for estimating mobility status of a terminal," US 2014/0206357 A1; PCT/CN2011/080389 filed 2011-09-29, US national-stage published 2014-07-24 (corresp. EP 2 763 459 A1).
- Description: Terminal estimates its own mobility status by counting handovers/cell reselections between groups vs. within a group using broadcast network-topology info.
- § 102 relevance: Terminal-side self-assessment of mobility state — conceptually adjacent to terminal-side "mode identification," but the decision variable is mobility, not connected-mode duration, and it does not address measurement-report periodicity. Does not anticipate claims 1–8. Potentially relevant § 103 art for "terminal identifies a condition and adapts behavior accordingly."
Ref 8 — US 2013/0084849 A1 (Nokia) — examiner-cited
- Full citation: Nokia Corporation, "Mobility enhancement for fast moving user equipment in a heterogenous network environment," US 2013/0084849 A1; filed 2011-09-30, published 2013-04-04.
- Description: In a HetNet, the UE scales mobility parameters (e.g., time-to-trigger), and differentiates measurement reporting of neighbor cells based on relative cell size (macro vs. pico); e.g., lengthening the time trigger for pico cells so neighbor-cell reports are triggered less frequently.
- § 102 relevance: This is the closest art on the "differentiate the measurement reporting" concept — it explicitly teaches altering the time-to-trigger/report cadence to reduce reporting frequency. But the differentiation is by cell size / mobility, not by a normal-vs-long-connected-mode distinction with a connected-duration criterion, and the decision is not the terminal "identifying" a long connected mode. Does not anticipate claims 1–8. Most probative § 103 reference for claim elements (2) and (4). § 102(e) art (filed 2011-09-30).
Ref 9 — US 2013/0295951 A1 (Tomasz Henryk Mach) — examiner-cited
- Full citation: Tomasz Henryk Mach, "Determining speed dependent scaling factors," US 2013/0295951 A1; filed 2012-05-01, published 2013-11-07.
- Description: Determining speed-dependent scaling factors (e.g., scaling of reselection/measurement timing parameters based on UE speed).
- § 102 relevance: Teaches that a UE may adjust timing parameters (including report-related timing) based on a UE condition/state — relevant § 103 context for claim element (2)/(6) (longer period in one mode). But the condition is speed, not long connected mode, and there is no "long connected mode" identification. Does not anticipate claims 1–8. § 102(e) art (filed 2012-05-01, before 2012-07-10).
Refs 10 & 11 — US 9,445,342 B2 and US 2017/0006519 A1 (Samsung) — NOT prior art
- Both share the same priority (2012-07-10) and the same inventors/specification as the '456 patent. US 9,445,342 is the parent (the continuation from which '456 arose); US 2017/0006519 A1 is the '456's own pre-grant publication. Under pre-AIA § 102(e)/(a), a reference cannot be prior art against an application claiming the same effective filing date and same inventive entity/disclosure (they are the same invention, not "by another"). These cannot anticipate or render obvious claims 1–8. Their appearance in the citations table reflects family/relatedness, not substantive prior art.
4. Summary table — anticipation potential (§ 102) per reference
| Ref | Citation | Could it § 102-anticipate any claim? | Which claim(s) / why not |
|---|---|---|---|
| 1 | US 2008/0090573 A1 | No | Uses "long connected mode" wording but is DRX HO suspend/resume; no mode-based report period |
| 2 | KR 10-2010-0092742 A | No | CSG access control; no relevant elements |
| 3 | KR 10-2012-0034159 A | No | Random access; no relevant elements |
| 4 | KR 10-2012-0047943 A | No | Generic handover; no mode dichotomy |
| 5 | KR 10-2011-0088005 A | No | Network HO determination; no terminal report period |
| 6 | US 2012/0307669 A1 | No (§ 102(e) art, but doesn't meet elements) | Idle-vs-connected MDT reporting ≠ normal-vs-long-connected-mode |
| 7 | US 2014/0206357 A1 | No | Mobility-state estimation, not mode/period |
| 8 | US 2013/0084849 A1 | No | Differentiates reporting by cell size/mobility, not by long connected mode |
| 9 | US 2013/0295951 A1 | No | Speed-based scaling, not connected-mode-based period |
| 10 | US 9,445,342 B2 | No — same family | Same priority/inventors; not "prior art" |
| 11 | US 2017/0006519 A1 | No — own publication | Same family |
No cited reference anticipates any of claims 1–8 under § 102. The references fail the "long connected mode" / "connected duration" limitation and/or the terminal-side identification → period selection limitation.
5. Honest caveats and recommendations
- The strongest § 103 combination (not § 102) appears to be Ref 8 (Nokia US 2013/0084849 — differentiate measurement reporting to reduce report frequency) combined with Ref 6 (Samsung US 2012/0307669 — reporting behavior conditioned on UE RRC state) and/or Ref 9 (Mach — condition-dependent scaling of timing parameters). Together these teach the generic ideas of (a) adapting measurement reports based on a UE condition and (b) distinguishing behavior by connection state — which a examiner could combine against the mode-based period elements. What none supplies is the specific "long connected mode" characterized by longer connected duration.
- I could not retrieve the full claim text of every cited reference within the available searches; the descriptions above are grounded in the titles/abstracts/summaries that were retrieved and in the '456 specification's own citation list. A complete § 102/§ 103 charting would require pulling the full text and claims of each reference, plus the '456 file wrapper / IDS and any examiner citations/office actions (available via USPTO Patent Center / Global Dossier).
- Two "citations" are not prior art (Refs 10–11) and should be excluded from any anticipation analysis — a common error when reading the Google Patents "Citations" table.
- Do not rely on the negative result as definitive. As flagged in the earlier litigation section, I found no litigation involving the '456 patent; similarly, this prior-art assessment is based on the recorded citations and is not a substitute for a full invalidity search (which would look outside the cited references — e.g., 3GPP RAN2 measurement-configuration contributions, "RRC_CONNECTED prolonged connection"/light-connection proposals, and DRX/measurement-scaling standards text — where more material art may exist).
Bottom line: Reading the citation list literally and applying § 102 element-by-element, US 9,826,456 is not anticipated by any reference cited on its face; the cited art serves primarily as § 103 obviousness context around (i) measurement-report differentiation and (ii) UE-state-conditioned reporting behavior.
Generated 9/30/2026, 10:03:27 AM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the obviousness analysis by verifying the cited references and their disclosures.
Obviousness Analysis — US Patent No. 9,826,456 B2 under 35 U.S.C. § 103
Analysis date: 2026-04-26 (per current task); patent text fetched 2026-09-30
Patent: US 9,826,456 B2 — "Method and device for controlling handover of user equipment in long connected mode in wireless communication system"
Assignee: Samsung Electronics Co., Ltd.
Effective filing / priority date: 2012‑07‑10 (KR 10‑2012‑0075215)
Status: Grant 2017‑11‑21; continuation of US 14/413,317 (which issued as US 9,445,342 B2)
Note on scope: This section builds on the previously generated Litigation Search Report (which found no litigation). It does not repeat that content. It also relies on the "Citations (10)" / "Patent Citations (11)" lists reproduced in the patent page, which I treat as "the Prior Art section."
1. Framing the § 103 inquiry
Under Graham v. John Deere the analysis proceeds through (1) the scope/content of the claims, (2) the scope/content of the prior art, (3) the differences, and (4) the level of ordinary skill, with secondary considerations considered if timely presented. Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), a claimed combination is obvious where the elements were known and the combination yields only predictable results — including where the reference teaches "the secondary reference" plus a "design incentive, market demand, or other reason" to combine. A person having ordinary skill in the art (PHOSITA) here is a 3GPP LTE RAN engineer with ~2–3 years of wireless protocol (RRC/measurement/mobility) experience as of July 2012.
The claims at issue:
- Claim 1 (method, terminal-side):
- (a) identifying whether the terminal is in a normal connected mode or a long connected mode;
- (b) generating a measurement report based on a period corresponding to a result of the identification;
- (c) transmitting the measurement report;
- (d) "wherein a connected duration of the long connected mode is longer than a connected duration of the normal connected mode."
- Claim 2: the second (long-connected-mode) period is longer than the first (normal-mode) period.
- Claims 3–4: receiving measurement configuration information, the report being generated/transmitted based on it.
- Claims 5–8: apparatus mirror (transceiver + processor) of claims 1–4.
The lynchpin element is (a)/(d): a UE that distinguishes two connected modes — a "normal connected mode" and a "long connected mode" defined by a longer connected duration. The specification defines "long connected mode" as "the operation mode in which the UE stays in the connected state without ongoing data." The measurement-report-period differentiator in (b)/Claim 2 is the mechanism.
Preliminary conclusion: No single cited reference appears to disclose all elements (e.g., "long connected mode"), so the viable attack is § 103 combination, not § 102 anticipation — consistent with the examiner's grant.
2. The prior art of record and what it actually teaches
| Ref. | Type / date | URL | Disclosure relevant to the claims |
|---|---|---|---|
| US 2013/0295951 A1 (Mach), granted US 8,594,699 B1 | Pub. 2013‑11‑07; US filing 2012‑05‑01 (App. 13/461,263) | https://patents.google.com/patent/US20130295951A1/en | UE determines a mobility state and selects speed-dependent scaling factors applied to measurement-report timing parameters — explicitly "a time-to-trigger timer and a measurement-report event trigger threshold." It teaches the UE autonomously varying when/how often measurement reports are generated as a function of a determined UE condition. |
| US 2013/0084849 A1 (Nokia) | Pub. 2013‑04‑04; priority 2011‑09‑30 | https://patents.google.com/patent/US20130084849A1/en | Differentiates measurement reporting based on relative neighbor-cell size; "for a high mobility UE the time trigger is lengthened … resulting in neighbor cell measurement reports being triggered less frequently." Teaches mode/condition-dependent measurement-report cadence, i.e., a paired measurement-report period. |
| US 2014/0206357 A1 (Fujitsu) | Pub. 2014‑07‑24; priority 2011‑09‑29 | https://patents.google.com/patent/US20140206357A1/en | UE estimates its mobility status from handover/reselection counts and modifies "the time to trigger"/"reselection time" and measurement factors accordingly — again UE-side state → measurement-timing adjustment. |
| US 2008/0090573 A1 (Samsung) | Pub. 2008‑04‑17; priority 2006‑10‑16 | https://patents.google.com/patent/US20080090573A1/en | A connected-mode UE operating in DRX (i.e., staying connected without ongoing data) that "receive[s] a DRX parameter, a cell change parameter, and measurement type information," measures neighbor cells, and triggers cell-change reporting — the closest archetype of a UE that remains in connected state while idle-like and still performs measurement reporting. |
| US 2012/0307669 A1 (Samsung) | Pub. 2012‑12‑06; priority 2010‑02‑16 | https://patents.google.com/patent/US20120307669A1/en | Transmitting channel measurement information in a mobile communication system — network-configured measurement reporting. |
| KR 10‑2011‑0088005 A (Samsung) | Pub. 2011‑08‑03 | page citation list | "Method and apparatus for determining handover in mobile communication system." |
| KR 10‑2010‑0092742 A (Samsung) | Pub. 2010‑08‑23 | page citation list | Access control during active handover toward a CSG cell. |
| KR 10‑2012‑0034159 A (LG) | Pub. 2012‑04‑10 | page citation list | Random access in a multi-carrier wireless system. |
| KR 10‑2012‑0047943 A (Huawei) | Pub. 2012‑05‑14 | page citation list | Switching (handover) method/device. |
| US 9,445,342 B2 (Samsung) | Grant 2016‑09‑13; priority 2012‑07‑10 | page citation list | The parent — same specification; family member, not separately available as prior art against its own continuation. |
3. Claim-chart of differences (Claim 1)
| Claim 1 limitation | Mach (US 2013/0295951) | Nokia (US 2013/0084849) | Samsung DRX (US 2008/0090573) | Samsung (US 2012/0307669) |
|---|---|---|---|---|
| (a) identify normal vs. long connected mode | Determines mobility state (not a "connected mode") | Determines cell-size relation | Connected-mode UE in DRX | — |
| (b) report based on period keyed to identification | ✅ scales time-to-trigger / report threshold by state | ✅ lengthens time trigger → reports "triggered less frequently" | ✅ measurement config/type carried to UE | ✅ measurement reporting configured |
| (c) transmit report | ✅ | ✅ | ✅ | ✅ |
| (d) long-connected-mode duration > normal-mode duration | ❌ | ❌ | Partial (connected UE held in long DRX, but no two-mode duration comparison) | ❌ |
| Claims 3–4: receive measurement configuration | ✅ (SIB/config) | ✅ (network-specified cells/factors) | ✅ | ✅ |
The only element not squarely met by any reference is the "long connected mode" construct of (a)/(d). Everything else — the UE identifying a state and adjusting its measurement-report cadence (period) — is squarely disclosed.
4. Combinations rendering the claims obvious
Combination A (strongest): Mach + Samsung '573 (DRX) [+ Nokia '849]
Rationale. Mach discloses limitation (b) verbatim in substance: the UE, upon determining a condition/state, adjusts the measurement-report period via time-to-trigger / report-trigger threshold scaling (see Mach ¶ citing "time-to-trigger … measurement-report event trigger threshold … scaled up or scaled down"). Samsung '573 discloses a connected-mode UE that stays connected while in DRX and without ongoing data, receiving DRX/measurement parameters and performing measurement reporting. Nokia '849 supplies the explicit direction-of-change for (Claim 2): lengthening the time trigger so that measurement reports are "triggered less frequently" for a UE whose situation tolerates it.
Motivation to combine. All three are in the same field (LTE/E‑UTRAN mobility management), address the same problem (measurement-report/handover signaling load), and share the same mechanism class (network-configurable, UE-evaluated measurement parameters). KSR recognizes that combining known elements to achieve a predictable improvement — reducing measurement-report frequency for a UE that is not actively transferring data — is obvious. The predictable result is exactly what the '456 specification itself claims: fewer handovers / "broadening the cell coverage."
On the "long connected mode" gap. The concept of holding a UE in connected state without ongoing data was itself known in the art — connected-mode DRX (Samsung '573) exists precisely so a connected UE can "sleep" between bursts. Treating such a UE as being in a distinct "long connected mode," and re-using Mach/Nokia's state-dependent measurement-cadence scaling for it, is at most an "obvious to try" variation with a predictable result, not an inventive leap. The claimed distinction ("connected duration of the long connected mode is longer than … normal connected mode") is a definitional/design choice that follows from the very purpose of connected-mode DRX.
Combination B: Nokia '849 + Samsung '573
Nokia '849 teaches differentiating measurement reporting in dependence on a UE condition, and expressly discloses that the time trigger is "lengthened … resulting in neighbor cell measurement reports being triggered less frequently" — i.e., a longer measurement-report period for one class of UE state vs. another. Combined with Samsung '573's connected-mode-without-data UE, this yields claims 1, 2, and (with the network-provided configuration Nokia describes) claims 3–4.
Combination C: Fujitsu '357 + Mach '951 + Samsung '573
Fujitsu '357 independently corroborates the state→measurement-timing adjustment (UE "modif[ies] … the time to trigger … according to the mobility status"), establishing that such adjustment was a well-known, routine design parameter by the 2012 priority date. Its addition makes any assertion that claims 1–2 recite something non-routine very difficult.
Apparatus claims 5–8
Claims 5–8 are the method of claims 1–4 recast with a transceiver and processor. Each cited reference discloses a UE apparatus having a transceiver and a controller/processor performing the recited functions (e.g., Samsung '573 expressly claims "a transceiver for receiving a DRX parameter, a cell change parameter, and measurement type information … and a radio resource control entity for measuring …"; Mach/Nokia disclose UE processors executing measurement scaling). Once the method is obvious, the apparatus claims fall with it (In re Kuehl line of reasoning).
5. Critical caveat: prior-art status of the key references (must be resolved before asserting)
Several of the most useful references were published after the 2012‑07‑10 priority date, and the '456 application (filed 2013‑07‑10 via PCT, pre‑AIA) means availability depends on their effective U.S. filing dates under pre‑AIA § 102(e), with the Hilmer doctrine barring reliance on their foreign priority dates:
- Mach US 2013/0295951 A1 — U.S. filing 2012‑05‑01 (App. 13/461,263), before 2012‑07‑10 → available under § 102(e) despite publishing 2013‑11‑07. ✅
- Nokia US 2013/0084849 A1 — publishes 2013‑04‑04 on a 2011‑09‑30 priority; its U.S. filing date appears to fall after 2012‑07‑10, which would make it unavailable as § 102(e) prior art. ⚠️ (Hilmer bars using the 2011 foreign priority for the 102(e) date.)
- Fujitsu US 2014/0206357 A1 — publishes 2014‑07‑24 on a 2011‑09‑29 priority; its U.S. national-stage/bypass filing likewise appears to post-date 2012‑07‑10 → likely unavailable under § 102(e). ⚠️
- Samsung US 2008/0090573 A1 — published 2008‑04‑17 → clearly available. ✅
- Samsung US 2012/0307669 A1 — published 2012‑12‑06 (after priority) but with a 2010‑02‑16 priority and a U.S. filing presumably in 2011 → likely available under § 102(e). ✅ (verify exact U.S. filing date)
Practical takeaway: For a § 103 challenge, the Mach + Samsung '573 combination rests on clearly available references, and Mach supplies the disputed measurement-period limitation almost element-for-element. The Nokia and Fujitsu references are powerful corroborating evidence of what a PHOSITA knew, but their status as § 102(e) art is uncertain and should be confirmed against their file wrappers on the USPTO Patent Center / Global Dossier before being relied on as the reference.
6. Where the obviousness case is weakest (and how a patentee/defense would respond)
- The "long connected mode" element (§ 103 gap). The strongest non-obviousness argument is that no cited reference discloses a distinct "long connected mode" defined by a longer connected duration, and that this construct (not merely "long DRX") was the inventive contribution. Counter: connected-mode DRX (Samsung '573) inherently produces a connected UE whose connected duration can be arbitrarily long; KSR frames the re-labeling and reuse as obvious. This element is the crux and likely dispositive.
- Teaching-away / direction-of-change. Mach teaches shortening time-to-trigger for high-speed UEs; the '456 lengthens the period for long-connected UEs. A patentee could argue Mach teaches the opposite. Counter: Mach's teaching is state-dependent and symmetric ("scaled up or scaled down"), and Nokia supplies the lengthening direction for a tolerant UE — combined, they supply both directions.
- Secondary considerations. The specification asserts a benefit ("broadening the cell coverage"), but there is no evidence of record of unexpected results, industry praise, licensing, or copying with a nexus to the claims. Absent such evidence, this does not rebut a prima facie case.
- Claim-drafting differences from the parent. Because the '456 claims are terminal-side (mode identification + report period), whereas the parent's claims are eNB-side (per the abstract: eNB checks the mode and sends alleviated measurement configuration), the prior-art mapping must be re-run per claim set; a reference that anticipates the parent's eNB-side claims would not necessarily meet the '456 terminal-side claims, and vice versa.
7. Conclusion
- Anticipation (§ 102): Not established by any single cited reference; the "long connected mode" element (Claim 1(a)/(d)) is absent from all of them.
- Obviousness (§ 103): A prima facie case can be made. The measurement-report-period-keyed-to-a-UE-identified-state feature (Claims 1(b), 2) is squarely taught by Mach US 2013/0295951 A1 (US 8,594,699 B1), and the mode-dependent lengthening of the report trigger is expressly taught by Nokia US 2013/0084849 A1. The "connected mode without ongoing data" environment is disclosed by Samsung US 2008/0090573 A1 (connected-mode DRX). A PHOSITA, seeking the '456's own stated goal (reduce handover/measurement signaling for a UE held in connected state), would predictably combine these with a reasonable expectation of success. Claims 3–4 and apparatus claims 5–8 add only network-configured measurement parameters and a conventional transceiver/processor.
- Primary vulnerability of the attack: the genesis of the "long connected mode" construct (the sole unexplained element) and the prior-art-date question for the Nokia/Fujitsu references. The Mach + Samsung '573 pairing is the most date-robust foundation.
Recommendation for a validity/challenge opinion: verify exact U.S. filing dates of US 2013/0084849, US 2014/0206357, and US 2012/0307669 via USPTO Patent Center (to confirm § 102(e) availability), and confirm the substance of KR 10‑2011‑0088005 A ("determining handover") — that Korean reference, if it discloses a connected-state UE whose measurement/handover reporting is postponed, could close the "long connected mode" gap directly.
Confidence / limitations: High confidence on Mach's and Samsung '573's disclosures and dates (grounded in the fetched sources). Lower confidence on the Korean-language references (KR '8005, '7943, '4159, '2742), whose full texts I did not retrieve; their characterizations above come from their listed titles only and should not be relied on without reading them. The Nokia/Fujitsu § 102(e) dates are flagged as unverified estimates, not confirmed facts.
Generated 9/30/2026, 10:03:35 AM
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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