An Integrated Circuit (IC) is a set of electronic circuits on one small flat piece (or "chip") of semiconductor material (normally silicon). The integration of large numbers of tiny MOS (Metal Oxide Semiconductor) transistors into a small chip resulted in circuits that are orders of magnitude smaller, faster, and less expensive than those constructed of discrete electronic components. The IC's mass production capability, reliability, and building-block approach to integrated circuit design has ensured the rapid adoption of standardized ICs in place of designs using discrete transistors. ICs are now used in virtually all electronic equipment and have revolutionized the world of electronics. Computers, mobile phones, and other digital home appliances are now inextricable parts of the structure of modern societies, made possible by the small size and low cost of ICs. Broadly, Integrated Circuit (IC) Design can be categorised into Analog and Digital design. Analog IC design has specializations in power IC design and RF IC design. Analog IC design is used in the design of op-amps, linear regulators, phase locked loops, oscillators and active filters and it is more concerned with the physics of the semiconductor devices such as gain, matching, power dissipation, and resistance. Fidelity of analog signal amplification and filtering is usually critical and as a result, analog ICs use larger area active devices than digital designs and are usually less dense in circuitry. Digital IC design is to produce components such as microprocessors, FPGAs (Field Programmable Arrays), memories (RAM, ROM, and flash) and digital ASICs. Digital IC design focuses on logical correctness, maximizing circuit density, and placing circuits so that clock and timing signals are routed efficiently. Application Specific IC An integrated circuit (IC) that is built for a specific use, rather than general use can be named Application Specific IC. For example, a chip designed solely to run a laptop is an ASIC. There are multiple benefits of using application specific ICs: They have higher reliability than general purpose ICs as they are customised to serve a particular function. They have a faster turn-around time (i.e. total time taken between the submission of a program for execution and the return of the complete output to the user.) They are more secure and can’t be exploited easily. They have lower non-recurring costs i.e. the unusual charge, expense or loss that rarely occurs again in the regular period of the function. They show better performance than general purpose ICs. They make more efficient use of board space. It is easier to incorporate unique features and fine-tune the product. IC Design Styles 1. Full Custom Design: A full custom design means designing integrated circuits by specifying the layout of each transistor and the interconnections between them. This design potentially maximizes the performance of the chip, and minimizes its area, but is extremely labor-intensive to implement, which means higher production costs. This design is limited to ICs that are to be fabricated in extremely high volumes. The time taken to design an IC is long and slow. A full-custom IC includes some logic cells that are customized and all mask layers that are customized. Therefore, full-custom ICs are the most expensive to manufacture and design. For example microprocessors. The major advantage of this design is that while making optimum use of the chip area, it can integrate analog components and pre-designed components, which leads to a higher degree of optimisation in performance. In a full custom design, the entire mask design is done from scratch without the use of any library. However, the development cost of such a design style is high which has propelled the reuse of designs, to reduce design cycle time and development cost. 2. Gate Array Design: A gate array is an approach to the design and manufacture of application-specific integrated circuits (ASICs) which makes use of a prefabricated silicon chip circuit with no particular function which has transistors, standard NAND or NOR logic gates, and other active devices placed at regular predefined positions and manufactured on a wafer, collectively known as the gate array circuit. Some parts of the chip (transistors) are pre-fabricated, and other parts (wires) are custom fabricated according to customer needs and the circuit is accomplished by adding layers of metal that interconnect to the chips. Gate array implementation can be understood as a two-step process, in which the first phase is based on generic masks, resulting in an array of uncommitted transistors on each chip. These uncommitted chips can be stacked for later customization. Since the patterning of metallic interconnects is done at the end of the chip fabrication, the turn-around time is usually short, ranging from a few days to a few weeks. The above figure shows a corner of a gate array chip which contains bonding pads on its left and bottom edges, diodes for I/O protection, nMOS transistors and pMOS transistors for chip output driver circuits in the neighboring areas of bonding pads, arrays of nMOS transistors and pMOS transistors, underpass wire segments, and power and ground buses along with contact windows. Further, there are two types of gate array, namely, Channeled Gate Array and Channel-less or Sea-of-Gates Gate Array. Channels are the dedicated areas on a GA chip for intercell routing between rows or columns of MOS transistors. The availability of these routing channels simplifies the interconnections and makes a pattern, even using one metal layer only. These patterns are used to realize basic logic gates that can be stored in a library, and can then be used to customize rows of uncommitted transistors according to the desired connectivity of an electronic circuit. In channeled gate arrays, the interconnections between the logic cells are performed within the predefined channels between the rows of the logic cells. Using multiple interconnect layers, routing can be achieved over the active cell areas; thus, the routing channels can be removed as in Sea-of-Gates (SOG) chips. Here, the entire chip surface is covered with uncommitted nMOS and pMOS transistors and the connections are made on an upper metal layer on top of the logic cells. In the gate array chip, neighboring transistors can be customized using a metal mask to form basic logic gates. For intercell routing, however, some uncommitted transistors must be sacrificed. This approach results in more flexibility for interconnections, and usually in a higher density. 3. Standard Cell: Standard Cell Design is an approach to designing application specific integrated circuits using mostly digital-logic features. The standard-cells based design is one of the most prevalent full custom design styles which require development of a full custom mask set and is an example of design abstraction, whereby a low-level very-large-scale integration (VLSI) layout is encapsulated into an abstract logic representation. Standard Cell is a group of transistors and inter-connects structures that provide a Boolean Logic function (e.g., AND, OR, XOR, XNOR, inverters) or even a storage function (flip-flop or latch). In this design style, all the commonly used logic cells are developed, characterized, and stored in a standard cell library. A typical library may contain a few hundred cells including inverters, NAND gates, NOR gates, flip-flops etc. There can be multiple implementations for the same components to provide high circuit speed or adequate driving capability for different fanouts, as chosen by the designer. Inside the input/output (I/O) frame, the chip area contains rows or columns of standard cells. Between cell rows are channels for dedicated inter-cell routing, but they can be reduced or even removed, provided that the cell rows offer sufficient routing space as in the case of Sea-of-Gates, with over-the-cell routing. The physical design and layout of logic cells ensure that when cells are placed into rows, their heights are matched and neighboring cells can be abutted side-by-side, which provides natural connections for power and ground lines in each row. After chip logic design is done using standard cells in the library, the most challenging task is to place individual cells into rows and interconnect them in a way that meets the desired requirements of design in circuit speed, chip area, and power consumption. For this purpose, many advanced CAD tools have also been developed and are used extensively. The circuit models which include interconnect components can be extracted from the chip layout and used for various timing operations in the circuit. In many VLSI chips, such as microprocessors and digital signal processing chips, standard-cell design is used to implement complex control logic modules. Although the standard-cell design is often called full custom design, in a strict sense, it is somewhat less than fully custom since the cells are pre-designed for general use and the same cells are utilized in many chip designs. The standard cell design chips are more flexible as they include digital as well as analog functions and have a more compact design. 4. Field Programmable Gate Array (FPGA): It can be “field” programmed to work as per the intended design. It means it can work as a microprocessor or graphics card, or even as both at once. FPGA chips contain thousands of logic gates, with programmable interconnects and are ready to be programmed by users for desired functionality. Hardware Description Languages such as VHDL and Verilog are used to create FPGA designs. A typical FPGA chip is made up of several Configurable Logic Blocks (CLB’s), I/O Buffers and are connected with Programmable Interconnects. The CLB’s are primarily made of Look-Up Tables (LUT’s), Multiplexers and Flip-Flops. Apart from CLB’s, and routing interconnects, many FPGAs also contain dedicated hard-silicon blocks for various functions such as Block RAM, DSP Blocks, External Memory Controllers, PLL’s etc. The programming of the interconnects is implemented by the programming of RAM cells whose output terminals are connected to the gates of MOS pass transistors. The general architecture of the FPGA chip is shown in the following figure. The flow of FPGA Fabrication 1. Design Entry: This can be done in two ways, through schematic or through Hardware Description Language (HDL). Various Tools convert these schematic to HDL or HDL to schematic. Generally, for a complex design, it is better to go with HDL, a quicker, language-based process that eliminates the need to design in lower level hardware, while schematics is a good choice for someone who wishes to design using hardware because it provides more accessibility to the entire system. Schematics are better for low level or smaller designs whereas HDL is better for complex designs. 2. Synthesis: As the design entered by us is in the form of code, it needs to be converted into an actual circuit that we intend to implement. This is done by the synthesis tools such as Vitis, Icarus Verilog, vivado etc. It converts the behavior code into gate level netlist where the entire circuit will be represented in form of gates, flip-flops and multipliers. The interconnections between them are also shown in a netlist. The process begins with a syntax check once you feed in your HDL based design. It is then optimized by the reduction of logic, elimination of redundant logic, and the reduction of the size of the design while simultaneously making it faster to implement. The last step is to map out the technology by connecting the design to the logic, estimating the associated time, and churning out the design netlists which are subsequently saved. 3. Implementation: This step determines the layout of your design and consists of three steps: translate, map, and place & route. The tools used in this step are provided by the FPGA vendors because they have the most accurate knowledge about translating a synthesized netlist to an FPGA. The first step for the tools is to gather all the constraints that are set by the user together with the netlist files. Then the tool maps out the implementation by comparing the resource requirement specified in the files to the resources available on the FPGA being used and then the circuit is divided into the logic blocks. As a result, your entire design is placed in specific logic blocks and is ‘mapped out’ into the FPGA. The next step is to connect and route all the signals according to the constraints set by the user between all the logic blocks and I/O blocks. 4. Program FPGA: The last step in the process is to finally load the mapped out and completely routed design into the FPGA chip. For this reason, we need to generate a Bit-Stream file and this bitstream file is to be dumped onto our FPGA board using a Flash programmer device. When we run our FPGA the board mimics our design functionality. This is the entire process for FPGA based design. Also in FPGA, there are simulation checks which are done at each level. Behavior simulation is done at the design entry level, Functional simulation is done post synthesis and timing simulation is done at the implementation level. This design provides fast prototyping and has a very short turn-around time (the time required from the start of the design process to obtaining a fully functional chip). The typical price of FPGA chips is usually higher than other realization alternatives (such as gate array or standard cells) of the same design, but for small-volume production of ASIC chips and fast prototyping, FPGA offers a very valuable option. Comparison References https://www.globalspec.com/learnmore/semiconductors/programmable_logic_devices/asic https://www.electronicshub.org/introduction-to-asic-technology/ http://lad.dsc.ufcg.edu.br/epfl/ch01.html#1.3 https://www.wikipedia.org/ https://www.tutorialspoint.com/ Keywords integrated circuit chip, fpga for dummies, xilinx programmer, ic in electronics, ic integrated circuit, plc programmable logic controller, analog integrated circuit design, analog ic design, plc logic, fpga chip, digital integrated circuits, labview fpga, types of integrated circuit, ic circuit, fpga development board, fpga design, vlsi technology, field programmable gate array, xilinx fpga, fpga board, fpga programming, ic chip, intel fpga, vlsi design, ic design, fpga, vlsi, integrated circuit Copperpod helps attorneys dig deep into technology products and find evidence of patent infringement through reverse engineering, product testing, and network packet capture. Our reverse engineering and network captures have been relied upon by leading trial attorneys for negotiating over a dozen settlements and royalty agreements on behalf of technology clients. Know more about how we leverage different RE techniques to uncover even the hardest to find evidence of patent infringement.

In this digital age, we appear to have more alternatives for entertainment and recreation. Be that as it may, our hectic way of life and conflicting food habits have made us vulnerable to several diseases and some serious conditions like cardiac arrests. Gone are the days when individuals with just cholesterol and heart issues suffer from cardiac arrests. There are a few instances of Sudden Cardiac Arrests (SCAs) and millions of us appear to succumb to this without any health warnings. In such conditions, it is considered important to get the heart 'defibrillated' at the earliest opportunity – as the odds of endurance for the individual (experiencing SCA) decreases by 7 to 10% for every minute lost. As we are living in this pandemic of COVID-19, more precautions are required for the cardiac patient as pre-existing cardiovascular disease and hypertension in addition to age and diabetes has emerged as fairly strong associations of a poor outcome in patients with this disease. Cardiovascular complications are frequent among COVID-19 patients and might contribute to adverse clinical events and mortality. Some people also have an emergency oxygen kit at home for coronavirus to deal with respiratory problems. The same is for cardiac patients where they are required to have a defibrillator at home which increases their chances of survival to maximum with fewer chances of infection. What Is A Defibrillator? A defibrillator is a device that restores a normal heartbeat by sending an electric pulse or shock to the heart. If the heartbeats unevenly or too fast or too slow, defibrillators are used to correct the heartbeat, but if the heart stops then these defibrillators can restore the electric pulse which works by using a moderately high voltage (200–1000 volts) by correcting the rhythm of the heartbeat. This disruption in the heart rhythm is called arrhythmia. Often there are no symptoms, but some people feel an irregular heartbeat which can be caused by damage from disease, injury, or genetics which might make them feel a little dizzy, fainted, and breathless. Every defibrillator has its own working style and is used for different purposes. There are total 3 types of defibrillators : Automated External Defibrillator (AED) Implantable Cardioverter Defibrillator (ICD) Wearable Cardioverter Defibrillator (WCD) How Do Defibrillators Work? 1. How Do AEDs Work? AEDs are available in public places, which are used to save the life of people with sudden cardiac arrest in public places. AED can be used even by a bystander, which is used for emergencies while waiting for the ambulance to arrive. In such conditions, energy based AEDs are used, but there are other two types of AED: Impedance-Based Defibrillators: It allows selection of the current applied based upon the transthoracic impedance (TTI). TTI is assessed from a test pulse and subsequently, the capacitor gets charged to the appropriate voltage. Current-Based Defibrillators: It delivers a fixed dose of current, which results in defibrillation thresholds that are independent of TTI. The optimal current for ventricular defibrillation has to be 30 to 40 amperes independently of both TTI and body weight, thus achieving defibrillation with considerably less energy than the conventional energy-based method. AED Architecture AEDs need a processor with an associated operating system that is powerful enough to process and interpret several parameters at once, getting accurate results with a user-friendly interface. Key Considerations For The Design: Reliability and safety Accuracy Extremely fast boot times Outstanding power management Communication flexibility (wired and wireless) Security Rich and easy-to-use HMI These design considerations make us contemplate which processor and software to use in the defibrillator. The single important objective is to seek out the supplier with a strong board support package (BSP). In the past, medical device design first chose the processor and then the hardware design was made around that. Now, many companies are combining hardware and software designers, whereas a team considers a design platform composed of both hardware and software. Today, organizations and leaders understand the relationship between hardware and software that will run on it. It is wise to start by selecting a hardware and software reference platform that comes complete with a board support package (BSP) inclusive of an application-appropriate operating system and the necessary drivers to complete the work. In this way, design organizations can focus their energy on intellectual property rather than becoming an operating system or software company themselves. 2. How Do Implantable Cardioverter Defibrillators (ICDs) Work? It is a device that is placed under the chest or abdomen which is connected to the heart using electrodes. The ICD is programmed in such a way that if it detects an irregular heartbeat, it instantly sends low/high electric shock to the person as per the need. The ICD also records the heart's electrical activity and heart rhythms, which is then used to program the ICD for irregular heartbeats. 3. How Do Wearable Cardioverter Defibrillators (WCDs) Work? It is a device that is placed outside the body. The device has a belt that is connected with wires which is linked with the vest to monitor the heartbeat and if the rhythm is not correct it beeps to indicate an electric shock. If the person does not need a shock then he/she can turn off the alert, but if the alert is not responded to, then the device gives an electric shock to correct the rhythm. Patent Analysis 1. Top 10 Countries This chart describes the smart defibrillator patent strength in key regions across the globe. The chart covers the top 10 countries with the US leading the race with 2,676 patents in the defibrillator domain followed by WIPO with 1,375 patents. India (144), and Austria (88) accounted for the lowest number of patents in the industry across the globe. 2. Top 10 Players The above chart depicts the total number of defibrillator patents assigned to the top market players. With 606 patents, Medtronic, Inc. is the top player. Pacesetter, Inc., Cardiac Pacemakers Incorporation and Zoll Medical Corporation are not so closely behind with 528, 465 and 95 patents respectively. Physio Control has the lowest number of patents among all with 35 patents. Seminal Patent Assignee: Zoll Medical Corp Grant Date: 2015-03-27 The patent US10610679B2 states that the devices and methods described below provide for identification of ECG electrodes being handled by a rescuer, followed by prompts indicating which electrode the rescuer has in hand and prompts indicating the proper placement of that electrode. To detect the electrode being manipulated by the rescuer, motion sensors (accelerometers or other sensors) are mounted on the electrodes. (The system already knows which electrode is which, because each electrode is connected to a conductor cable which in turn is connected to a connector with unique inputs for each electrode). The system of the defibrillator to which the electrodes are connected is programmed (in addition to its programming for displaying and analyzing an ECG signal obtained through the electrodes, and generating and delivering a defibrillating shock to the electrodes or separate paddles), to analyze the sensor input to determine a characteristic of the motion of the electrodes, determine which electrode is being handled, and prompt the rescuer to put the electrode on the patient in its proper position. The prompts may be verbal prompts or images displayed on a display screen of the defibrillator. Challenges And Future Developments Cardiac patients have to face many challenges in real life, with different challenges for every defibrillator device. As AED devices are very effective in treating ventricular arrhythmias, it still needs a bystander capable of applying and operating it. On the other hand, the ICD device patients have to face device malfunction, fearing death during the shock, pain due to the shock, loss of control, cost of the device, and lifestyle limitations. Later, it was advocated that AED should be included in the compulsory safety equipment category such as smoke alarms or fire extinguishers, which increases the survival rate of the cardiac patient. In the future, the defibrillator will be widely available to people in most areas and this may find a way to home, cars etc. In fact, various mobile phone apps will be created to let people know the nearest AED device and also get delivered with a drone. AED communication with bystanders will also improve with better video instructions and eventually live video feedback to help lay rescuers during the trickiest parts of administering AED-assisted CPR. AED will also offer better data sharing for communication outside the room and a more portable and lighter system. References https://www.nhlbi.nih.gov/health-topics/defibrillators https://www.intechopen.com/books/cardiac-defibrillation/principles-of-external-defibrillators https://www.fda.gov/consumers/consumer-updates/how-aeds-public-places-can-restart-hearts#:~:text=The%20user%20 attaches%20two%20 sticky,and%20electric%20 shock%20is%20needed. https://patents.google.com/patent/US10610679B2/en?oq=US10610679B2 https://www.medicaldesignandoutsourcing.com/theres-more-to-the-aed-than-meets-the-chest/ Keywords: defibrillators, smart defibrillators, smart cardiac devices, patents, how does a defibrillator work, working of a defibrillator, patents for the defibrillator, top patent holders for the defibrillator, smart medical devices

As technological developments spread from one part of the world to another, the internet inevitably follows suit. In a world where 66% of the population is carrying a mobile phone, a mobile presence is a must for any individual who seeks success on the internet. In this context, a million-dollar question arises -- how to target mobile and desktop users similarly without building and maintaining a mobile app (for iOS, Android, etc.) and a responsive website at the same time? In recent years, the Progressive Web Applications (PWAs) trend has been the best thing to happen to the web community. In contrast to native applications, progressive web applications are a hybrid of standard web pages (or sites) and a mobile application. This new application model endeavors to consolidate highlights offered by most current browsers with the advantages of improved mobile experience. Mobile traffic is at its all-time high and is continuing to expand – which is the reason companies like Google are focusing more on improving the mobile user experience. To further enhance the quality of mobile user experience, Google presented Progressive Web Apps (PWAs) at the Chrome Dev Summit in 2015. It was a stage towards upgrading traditional sites and mobile applications. Why Build A PWA? For some organizations, particularly for the applications intended for internal use, the expense of creating, testing, and keeping up applications for a few stages is irrational. It was predicted that one year from now, up to 20% of organizations will forsake their native mobile applications. All things considered, they accept that PWA is ultimately a more suitable option. Progressive Web Apps permit the developers to enhance user experiences that rival native applications provide without having development teams and distributing binaries and updates. PWA innovations are supported by the enormous hitters: Google and Microsoft. All Android gadgets are PWA viable and Microsoft is building a few of its cutting edge applications like Outlook and Teams as PWA. Apple is additionally carrying out support, which will dispatch in Safari 11.1 and iOS 11.3. Even though Progressive Web Apps expand on new advancements, they are as of now broadly used in the business. PWA working examples include: Forbes Pinterest The Washington Post Treebo Starbucks Tinder Uber Jumia Make My Trip Trivago Flipkart Twitter Snapdeal OLX CNN Target Ali Express Walmart Medium Airbnb Wired Telegram Instagram Shine The Guardian Three Pillars of PWA 1. Reliability: A Progressive Web App feels quick and reliable regardless of the network. Speed is critical for clients’ user experience. Truth be told, as page load times go from 1 second to 10 seconds, the likelihood of a user closing the page increases by 123%. Performance doesn't stop after the onload event as the customers don’t think about whether their interaction was enrolled or not. Scrolling and animation should feel smooth as performance influences the whole experience, from how clients see the application to how it really performs. At last, dependable applications should be usable regardless of network connections. Clients expect applications to fasten upon slow or flaky network connections or when offline. They expect the latest content they've interacted with to be accessible and usable regardless of whether getting a request to the server is hard. At the point when a request is beyond the realm of imagination, they expect to be told that there's an inconvenience rather than quietly failing or crashing. Clients love applications that react to cooperation in a split second, and an experience they can rely upon. 2. Capability: The web is very proficient by its own doing today. The user can construct a hyper-local video chat application utilizing WebRTC, geolocation, and push up notifications. He can make that application easy to install and have virtual discussions with WebGL and WebVR. With the introduction of Web Assembly, designers can take advantage of different ecosystems, similar to C, C++, and Rust, and bring many years of work and abilities to the web as well. Squoosh app, for example, uses this for its high-level image compression. As of now, just platform-specific applications could truly make a case for these capabilities. While a few capabilities are still out of the web's reach, new and forthcoming Application Performing Interfaces (APIs) are hoping to change -- how the web can manage highlights like file framework access, media controls, application badging, and full clipboard support. These capacities are built with the web's protected, client-driven consent model, guaranteeing that going to a website is never a scary recommendation for users. Between the present day Application Performing Interfaces (APIs), Web Assembly, and new and impending APIs, web applications are more proficient than any other time, and those capabilities are only growing. 3. Installability: Installed Progressive Web Apps run in an independent window and not in a browser tab. They're launchable from the client's home screen, dock, taskbar, or shelf. It's feasible to look for them on a gadget and jump between them with the application switcher, causing them to feel like a piece of the gadget they're installed in. New capabilities open up after the installment of a web application. Keyboard shortcuts, generally saved when running in the program, become accessible. Technical Components of PWA The Web App Manifest - The Web App manifest, a JSON document — is the main segment giving the progressive its native application interface appearance. With the manifest, a developer handles the way the application appears to the client and how it launches. The document permits the developer to track down a unified spot for the web application's metadata. The manifest for the most part contains the starting URL, an application's full and short name, connections to links, and links' sizes, type, and area. The developer can likewise characterize a splash screen and a theme color for the address bar. To apply these settings, the developer just needs to add a solitary connection to the manifest in all site page headers. Service Worker: A service worker is another technical component backing up one of the principal highlights of progressive web applications — the offline work mode, background sync, and push up notifications mainly for native applications. The service worker is a JavaScript record running independently of the website page/application and reacts to the user's interactions with the application, including network demands produced using the pages it serves. Since the service worker deals with a particular event, its lifetime is short. Add Home Screen: The user can add the web application to their home screen without downloading and install it from the application store. From here, they can open the application directly from their home screen without the need to open it in a tab, for example, Chrome or Opera. Likewise, the application can be used in a full-screen mode which provides a far superior user experience. Background Sync: The application can be refreshed in a background framework when not in use. It is helpful and valuable, particularly in places where one’s web connection is moderate or poor. Later, waiting time for the necessary information becomes fundamentally more limited and then the user only needs an already downloaded application. Offline Caching: Even when the user is offline, a site permits him to enjoy a few functionalities. They can utilize it without an internet connection and that is actually why PWAs bring client experience to a more significant level than conventional sites. Push Notifications: Push notifications to increase client engagement, making the communication between the content supplier and client more significant. Comparison (Native App, Web App, Progressive Web App (PWA)) Conclusion At their heart, Progressive Web Apps are simply web applications. Utilizing progressive upgrades, new abilities are empowered in modern browsers and by incorporating service workers and a web application, the user’s web application becomes solid and easy to install. The numbers never lie! Organizations that have launched Progressive Web Apps have seen great outcomes -- Twitter saw a 65% increment in pages per meeting, 75% more tweets, and a 20% abatement in bounce rate, all while diminishing the size of their application by more than 97%. In the wake of changing to a PWA, Nikkei saw 2.3 times more natural traffic, 58% more memberships, and 49% all the more everyday users. Hulu supplanted their platform-specific desktop experience with a Progressive Web App and saw a 27% expansion in consequent visits. The incredible thing about PWA is that even though all the browsers don't uphold the fundamental technology, users will be able to carry them out without stress and get an incredible improved experience. Truth be told, organizations like Alibaba, have shown that by focussing their efforts just on a PWA application as opposed to having separate native applications, expands changes and normal purchases. References https://web.dev/what-are-pwas/ https://vaadin.com/pwa https://www.onely.com/blog/what-are-progressive-web-apps/ https://www.biznessapps.com/blog/progressive-web-apps/ https://brainhub.eu/library/is-pwa-the-future/#:~:text=Progressive%20Web%20Apps%20seem%20to,the%20 functionality%20of%20native%20apps. https://www.appschopper.com/blog/best-tools-technologies-leverage-progressive-web-app-pwa-development/ https://developer.mozilla.org/en-US/docs/Web/Progressive_web_apps https://www.mobiloud.com/blog/progressive-web-app-examples https://web.dev/progressive-web-apps/ https://developers.google.com/web/ilt/pwa/introduction-to-progressive-web-app-architectures https://www.altexsoft.com/blog/engineering/progressive-web-apps/ https://medium.com/@deepusnath/4-points-to-keep-in-mind-before-introducing-progressive-web-apps-pwa-to-your-team-8dc66bcf6011 Rahul is a seasoned IP Professional with 10 years of experience working closely with senior litigators on patent infringement and trade secret misappropriation. Rahul has a Bachelor's degree in Electrical Engineering from Indian Institute of Technology (IIT) Delhi and is a certified Project Management Professional (PMP). He has advised clients on more than 100 technology cases cumulatively resulting in over $1 billion in settlements and verdicts, including cases where he has testified at deposition or through expert reports. Copperpod provides portfolio analysis and prior art search services that help clients to make strategic decisions such as In-licensing/Out-Licensing of patents, new R&D investments, or pruning out less critical patents. Our team provides strength parameters for each patent in a portfolio based on their technical quality, enforceability, offensive/defensive strengths & business value. Please contact us at info@copperpodip.com to know more about our services. Keywords: pwa, progressive web application, web application, lite apps, web based applications, browser based applications, api, software applications

Microsoft announced its brand-new Microsoft Mesh platform at the Ignite conference 2021. Mixed Reality, Holoportation, Holographics— terms only used when we have sci-fi discussions referring to a futuristic utopia, are now equaling reality. Microsoft Mesh is the company’s new “Mixed Reality” platform, possibly the cutting-edge medium that is attempting to make these concepts real. Mesh came out as the fruit, for the years of Microsoft’s research and development in areas starting from hand and eye-tracking and HoloLens development to create persistent holograms and AI models. Mesh is a platform designed to help build multi-user, cross-platform Mixed Reality applications based on AI-powered tools. Microsoft Mesh will allow geographically distributed teams to join collaboratively in a meeting, share holographic experiences on different kinds of devices, conduct virtual design sessions, assist others, learn together and host virtual social meetups. For example, people around the world will attend conferences from their living rooms and home offices as if they were in person. They will be presented as holographic avatars present in a shared holographic world watching events unfold in the meeting. During the Ignite conference, Microsoft announced two apps built on the Microsoft Mesh platform–HoloLens and AltspaceVR. Over time, the company expects that people will be able to choose from an expanding set of Microsoft Mesh-enabled applications built by external developers and partners and benefit from the planned, full integration of Mesh with Microsoft products such as Microsoft Teams and Dynamics 365. "This has been the dream for Mixed Reality, the idea from the very beginning. You can actually feel like you're in the same place with someone sharing content or you can teleport from different Mixed Reality devices and be present with people even when you're not physically together," Microsoft Technical Fellow Alex Kipman said. Kipman came on the Ignite virtual stage as a fully realized holoportation of himself to narrate his Mixed Reality experience of the show’s opening in real-time as the rays of light simulated his physical body. Why Mesh? Mixed reality can be claimed as the fourth wave in computing after Mainframes, PCs, and smartphones. It is becoming mainstream across consumers and commercials, liberating them from screen-bound experiences into instinctual interactions in their own space that became a holographic space, among their things and with their people. The people missing the in-person social interactions, meet-ups like concerts, and fitness training are moving to the virtual world. Nearly 50% of the Fortune 500 companies currently use Mixed Reality solutions such as HoloLens. Given that big number, it is surprising that the options in Mixed Reality applications and experiences are very few. Some underlying problems, like Lack of time and resources for people representation, hologram stability in a shared MR space across time and device types, building high-fidelity 3D models into Mixed Reality, and synchronization of people’s actions and gestures are some underlying hard problems in developing such platforms. Core Components - Microsoft Mesh Platform With Mesh, Microsoft hopes to help developers design immersive MR apps without having to worry about complex technical issues. Not to be confused with an application or device, Mesh is a platform that offers developers a comprehensive developer platform, tooling based on Microsoft Azure with a suite having various AI-powered tools for avatars, synchronization across multiple users, session management, spatial rendering, and holoportation to build solutions in Mixed Reality with a combination of all. It also benefits from Azure’s privacy and enterprise-grade security advancements. “More and more we are building value in our intelligent cloud, which is Azure,” Kipman said. “In these collaborative experiences, the content is not inside my device or inside my application. The holographic content is in the cloud, and I just need the special lenses that allow me to see it.” Developer Platform: Developers need not worry about the core infrastructure around live-state management capabilities, audio/video transmission, and billing. Mesh benefits from the identity services such as Azure Active Directory and Microsoft Accounts to bring duly authenticated and authorized users and enable secure and trusted sessions. With Microsoft Graph API, users are able to bring connections, content, and preferences from the commercial and consumer space. Mesh also has AI capabilities for enabling massive multi-user online (MMO) scenarios for Mixed Reality. Multi-Device Support: Mesh allows ‘meet users where they are. For example, Mesh supports many devices to give a 3-dimensional volumetric experience. Mesh is compatible with fully immersive head-mounted displays (HMDs) such as HP Reverb G2, Microsoft HoloLens, and Oculus Quest 2. An accessible 3D presence is provided by Mesh with representative avatars created with inside-out sensors of the devices that can be seen, touched, and interacted with. The avatar rig and customization studio of Mesh allow creating out-of-the-box avatars. The platform can also function with existing avatar rigs due to its AI-powered motion models that accurately capture motions. Along with avatars, Mesh enables holoportation, a 360° 3D representation creation, and transmission, using outside-in sensors. These sensors can be custom camera setups. Mesh allows both local stand-alone and cloud-connected remote holographic rendering for each scene and model regardless of the device’s (mobile, PC, tablet) computing and thermal capacity. Additionally, native rendering of 3D file format is possible on Mesh-enabled apps. Mesh fulfills the need to understand each participant’s physical world and space to build Mesh-enabled apps that persist holographic content in the real world. It places holograms in a way that can persist across time, space, and devices through Spatial maps. The mesh helps you create a map of your world by delivering ‘world-locked holograms’ tied to specific points of interest. Mesh also generates holographic content aligned precisely to the layout and geometry of objects to allow a developer to build apps with visual information, service records, and other data. The multi-user sync feature in Mesh allows the creation of a hologram’s common perspective in a collaborative session. According to Microsoft, all the motions, pose updates, expressions, or holographic transformation happens within 100 milliseconds of latency, irrespective of whether the participant is in the same physical location or halfway around the world. This enables Mesh to create a sense of being in the same physical space in a multi-user situation. Mesh-Enabled Apps: Among many other Mixed Reality experiences built by Microsoft, Mesh also delivers some app experiences on top of the development platform that brings the platform alive. Mesh lights up collaborative experience for immersive headsets with apps built by Microsoft like the HoloLens 2 Mesh app and AltspaceVR with new enterprise capabilities. The Mesh platform is comprehensive. It is designed with tools and capabilities to help developers get started quickly to deliver engaging multi user Mixed Reality experiences. Seminal Patent U.S. Patent No. 9,508,197 - Generating An Avatar From Real-Time Image Data Assignee: Microsoft Technology Licensing LLC Grant Date: 2016-11-29 The patent describes the technology for automatically generating a facial avatar resembling a user in a defined art style. One or more processors are used to generate a user 3D head model for the user based on 3D image data captured from a communicatively coupled 3D image capture device. A set of user transferable head features from the user 3D head model are automatically represented by one or more processors in the facial avatar by rules governing transferable user 3D head features. In some embodiments, a base or reference head model of the avatar is remapped to include the set of user head features. In other embodiments, the model of an avatar head shape is selected based on the user 3D head model, and the transferable features of the user 3D head are represented in the avatar head shape model. The above figure illustrates an example of shape units of a 3D head model. A shape unit is a collection of 3D points which represent a head feature or an aspect of a head feature. Facebook’s AR and VR efforts togetherly named “Facebook Reality Labs,” announced recently a new consumer wearable that’s going to be their latest advancement in augmented reality devices. Mark Zuckerberg revealed at the fittingly virtual event that Facebook is going to launch “the next step on the road to augmented reality glasses” next year, a pair of smart glasses that falls short of AR capability. Zuckerberg also announced that Facebook will be bringing in luxury eyewear giant Luxottica, and the new consumer device will have Ray-Ban branding. Apple analyst Ming-Chi Kuo revealed in the latest research note that Apple will release a “helmet-type” mixed reality headset next year. “We foresee that the helmet product will provide AR and VR experiences, while glasses and contact lens types of products are more likely to focus on AR applications,” Kuo writes in the note. He added that the headset will likely be priced in the $1,000 range in the US. Qualcomm with its Qualcomm® Snapdragon™ XR2 Platform, the world’s first 5G-supported XR platform, unveils some innovative features and boasts multiple firsts for XR that can be scaled across AR, VR, and Mixed Reality. BAE Systems, a defense, security, and aerospace company, has been using HoloLens in its processes to make electric propulsion devices. The company has realized a 50% reduction in assembly time through the use of the device. Conclusion Microsoft Mesh is a platform built to help developers build their own multi-user Mixed Reality apps. It does a good job to address the challenges faced by developers to build a Mixed Reality experience and provides an interesting avatar system. Mesh has a massive potential to be integrated into a variety of applications and industries that may eventually become an industry-changing technology. Shubham is a research analyst at Copperpod IP. He has a Bachelor's degree in Electronics and Communication Engineering. His interest areas are the Internet of things (IoT), Networking, Semiconductors, Embedded System and Software. References https://www.businesstoday.in/current/corporate/microsoft-launches-mixed-reality-platform-mesh/story/432896.html https://www.forbes.com/sites/saibala/2021/03/07/microsoft-mesh-a-new-holoportation--mixed-reality-platform-that-may-disrupt-healthcare/?sh=3298c69f3d98 https://levelup.gitconnected.com/talk-about-the-brand-new-microsoft-mesh-platform-from-a-developers-perspective-3ded4d951303 https://www.microsoft.com/en-us/mesh?activetab=pivot%3aprimaryr7 https://techcommunity.microsoft.com/t5/mixed-reality-blog/microsoft-mesh-a-technical-overview/ba-p/2176004 https://news.microsoft.com/innovation-stories/microsoft-mesh/ https://www.macrumors.com/roundup/apple-glasses/ https://patents.google.com/patent/US9508197B2/en?q=microsoft+mesh&assignee=microsoft https://patentimages.storage.googleapis.com/e7/d9/9d/bbe4f4a8a04245/US09508197-20161129-D00005.png

Security becomes a priority, especially when the transaction of money or transaction of “Data” is concerned. Data is becoming one of the richest assets for companies, which needs security and should be kept in trusted hands. Data privacy and data security have been the primary and challenging stage in this digital world. Many data security standards (such as TLS security for websites) and software (such as Antivirus software) are being used to protect digital data. This article presents the upcoming and most promising data security technology – Blockchain. The blockchain is a database of information, which instead of getting stored in a single place, gets stored across a variety of data servers that participate in the network. How Transaction Occurs in a Blockchain A blockchain transaction includes the transfer of cryptocurrency from one account holder (nodes) to another and securely creates a record/log for the transaction made. In a centralized system, every transaction is validated and recorded in financial institutions such as banks. In a Blockchain, however, there is no such central bank - the transfer of cryptocurrency from one account holder (nodes) to another securely creates a record/log for the transaction made – which may be authenticated and validated by users participating in the network (called miners). Miners are special types of nodes in a network that have dedicated themselves to the task of validating batches of these transactions called blocks, signing and broadcasting them to the rest of the network to be added on an existing chain of Blocks. For example, the Figure given below shows the transaction log of the Ethereum exchange between two parties. Public Key Cryptography in Blockchain Public key cryptography is performed differently in Blockchain in which Bitcoin users send and receive cryptocurrencies using their public address. For instance, the public key is derived using some algorithmic transformation on the private key. Further, some hash function is used to convert the public key to that public address, which is a unique hash value and is used for sending/receiving cryptocurrencies. A blockchain transaction is signed by the account holder’s private key and is sent to the public address of the receiver account. The encryption provides a secured and anonymous transaction as the user doesn’t need to reveal his identity. Public key Cryptography provides both integrity and authenticity to the Blockchain transaction. Integrity: The sender digitally signs the Blockchain transaction with the help of a session ID, Transaction ID, and Timestamp so that the receiver will not be able to copy the transaction in the future. The private key is also used for the creation of a wallet. Authenticity: For using the public key, the account holder generates a public address (hash value) by some algorithm, such as SHA256 which is authentic and cannot be hashed backward to get the public key – thus retaining the authenticity of the transaction. Patent Analysis This chart describes the blockchain patent strength in key regions across the globe. The chart covers the top 10 countries with China leading the race with 29238 patents in the blockchain domain followed by the US with 8698 patents. Besides these, Japan, Taiwan and India are almost on the same level with 1678, 1165 and 1073 patents respectively. Singapore (887), and Canada (869) accounted for the lowest number of patents in the industry across the globe. The above chart shows the total number of blockchain patents assigned to top market players. With 1910 patents, Tencent Technology Shenzhen is the top player in the blockchain industry. Pingan Technology, Advanced New Technologies and IBM are not so closely behind with 830, 754 and 701 patents respectively. Alipay InfoTech, Beijing Baidu Netcom Science and Technology, Shenzhen Qianhai Webank are almost equal assignees of blockchain patents. Hangzhou Fuzamei Technology has the least patents amongst all with 384 patents. The above data shows the technology trends in respect to the number of patents in the blockchain industry since 2016. The initial years showed a very low performance of technology investment in the patent count. In the middle of 2017, there was an upward trend showing an increase in the number of blockchain patents. During the start of 2018, the technology investment trends peaked with respect to acquiring 11410 patents in 2018 and 13640 patents in 2019. In recent years, there has been a slight decline in the blockchain technology trend with 13062 patents in 2020. Download the full report Rinku advises clients on infringement investigations related to patented encryption techniques, source code review, and software inventions. Rinku has a Bachelor's degree in Computer Science and Engineering. His primary interests lie in cutting-edge cryptography, data security, web scraping, and artificial intelligence technologies. He is also well versed with both frontend and backend technologies such as HTML, CSS, PHP, Jquery, Javascript, Python, AJAX and MySQL databases. Keywords - Blockchain, cryptography, computer security, data security, distributed ledger, cryptocurrency, bitcoin, Ethereum, digital currency, patents in blockchain, blockchain leading countries, blockchain leading players Copperpod provides Technology Due Diligence and Source Code Review services to help attorneys dig deep into computer technology products. Our experts are well versed with Java, Objective-C, C/C++, PHP and most other popular programming languages, as well as expertise on security and cryptography standards such as DES, AES, RSA, OpenPGP, MD5, SHA-1, SHA-2, DSA and WEP to provide clients with unparalleled insights and thorough analysis during IP monetization and litigation.

“A smart contract is a self-executing contract with the terms of the agreement between buyer and seller being directly written into lines of code. The code and the agreements contained therein exist across a distributed, decentralized blockchain network. The code controls the execution, and transactions are trackable and irreversible.” - Investopedia While blockchain goes about as a sort of information base, affirming that exchanges have occurred, smart contracts execute code involving pre-decided conditions. The code contains a bunch of rules under which the gatherings of those smart contracts consent to communicate with one another. If and when the predefined rules are met, the understanding is naturally implemented. These contracts give instruments to productively oversee tokenized resources and access rights between at least two gatherings. The hidden qualities and access rights they oversee are put away on a blockchain, which is a straightforward, shared record, where they are shielded from erasure, altering, and amendment. In this way, they give a public and obvious approach to implant administration rules and business rationale in a couple of lines of code, which can be examined and implemented by the greater part agreement of a P2P organization. Smart agreements — an idea created by cryptographer Nick Szabo, empower blockchain's utilization case past computerized resources via naturally permitting the execution of the provisions of an agreement without requiring a mediator. The smart contract platforms— specifically, Ethereum had likewise seen increased interest during the 2017-2018 assembly. How Does Smart Contract Work? Smart contracts work by following simple “if/when…then…” statements that are written into the code on the blockchain. A network of computers executes the actions when predetermined conditions have been met and verified. These actions could include releasing funds to the appropriate parties, registering a vehicle, sending notifications, or issuing a ticket. The blockchain is then updated when the transaction is completed. That means the transaction cannot be changed, and only parties who have been granted permission can see the results. Further, within a smart contract, there can be as many stipulations as needed to satisfy the participants that the task will be completed satisfactorily. To establish the terms, participants must determine how transactions and their data are represented on the blockchain, agree on the “if/when...then…” rules that govern those transactions, explore all possible exceptions, and define a framework for resolving disputes. Then, the smart contract can be programmed by a developer accordingly. One of the best things about the blockchain is that, because it is a decentralized system that exists between all permitted parties, there’s no need to pay intermediaries and it saves time and conflict. If implemented correctly, smart contracts provide transaction security superior to traditional contract law, thereby reducing coordination costs of auditing and enforcement of such agreements. They track the performance of the agreement in real-time and hence save costs, as compliance and controlling happens on the fly. Further, smart contracts reduce the transaction costs by reducing the costs of reaching an agreement, formalization, and enforcement. Owing to these advantages, smart contracts are now being used for registering ownership and property rights, like land registries and intellectual property, or managing smart access control for the sharing economy. Industry Examples Elections - Blockchain voting systems could make voting securely and helpfully reachable through advanced methods. Blockchain voting systems may broaden availability, empower bigger electing interests, and accelerate the difficult strategy for counting and announcing votes in certain regions. Real Estate - Smart contracts in this industry measure accustomed record property possession of any structure. They optimize dealing speed and potency by reducing the requirement for lawyers or brokers. Sellers can take charge of the process. Insurance - Smart contracts strengthen claim processing through frequent checks in errors and facilitate administering policies from individuals or organizations. Shorter processing times will result in lower costs for consumers – together with premium rates. Medical - More healthcare institutions are gearing up towards reliable automation and up-to-date security measures. Hospitals are primary targets of cybercriminals since they hold a wealth of sensitive information. Even massive names within the sector like UCLA Health have been victims of data breaches, amounting to 4.5 million patient records compromised. With this, many healthcare institutions across the US have begun prioritizing healthcare managers and administrators with specific skill sets to counter these. Considering that new technologies and innovative practices increase at a speedy rate. Trade Finance - Smart contracts cut back costly errors. The ability of these contracts to modify workflows and sharpen calculations helps in reducing work hours as well. Mortgage - Like exchange clearing, contract loaning depends on for the most part obsolete systems. Advance endorsement includes bank representatives and outsiders auditing a torrential slide of monetary records and afterward physically sharing them using email. Each report should be endorsed to be followed, making this cycle amazingly arduous and defenseless against human-related slip-ups. With smart contracts, the whole interaction can be digitized and generally mechanized. All elaborate gatherings will approach the digitized forms of reports, and installments will be naturally finished after gathering electronic marks. Limitations of Smart Contracts Smart contracts are an extremely young technology. Despite having a lot of promise, it is still prone to problems. For example, the code that makes up the agreement must be perfect and must not contain any bugs. A savvy agreement must be just about as brilliant as individuals coding it, considering all accessible data at the hour of coding. This can prompt mix-ups and, in some cases, to such bugs being abused by tricksters. Blockchains have their issues, yet they are appraised, evidently, quicker, less expensive, and safer than customary frameworks, which is the reason banks and governments are going to them. Also, there are worries about unofficial law, tax collection and requirements around these agreements. Inflexibility - The interest in smart agreements among ventures can be generally ascribed to the robotization capacities that this innovation infers. Ideally, smart agreements are a completely self-working component that doesn't need any human intercession after being conveyed on a blockchain. Notwithstanding, most business connections are perplexing. Representing every single imaginable possibility and subtleties in an agreement is inconceivable both in composed and computerized arrangements. Traditionally, parties are compelled to look for legal help to help them settle authoritative issues that are regularly forced by unanticipated conditions. While this issue can't be totally alleviated paying little mind to the kind of agreement, smart agreements can consequently reference an outer arbitrager when unforeseen components become an integral factor. Other than that, we can anticipate that AI should incredibly improve the agreement drafting and requirement by covering a greater extent of potential possibilities. Honestly, AI actually will not have the option to change contract arrangements inconsistency with standards of reasonableness, in any event in the near future. Presently, most smart agreements applied in business connections should be open-finished and depend on the mediator to be successful. Link To The Real World - Numerous authoritative arrangements require a type of connection to this present reality, which thwarts the guarantee of smart agreements to be completely self-governing. At times, it's feasible for a blockchain to adequately deal with off-chain information if it's freely accessible and can be generally trusted. For instance, stock costs or climate conditions can be effortlessly checked from numerous confided sources. Notwithstanding, there are various situations when data is freely free yet requires one's actual presence to be checked. For instance, the online business area could profit from smart agreement execution, yet product conveyance confirmation is presently impractical without human intercession. It very well may be contended that this test can be overwhelmed with the expansion of IoT, however, the absence of normalization and generally speaking youthfulness of this innovation makes it attainable just in the distant future. In addition, numerous contractual obligations that fall into the off-chain class can't be equitably estimated and computationally checked. For instance, while in principle you can confirm item conveyance, the approval of the item's highlights can't be caught by double rationale. What is the Need of the Hour? While smart agreements possibly authorize legal agreements if certain conditions are met, there is a need to determine numerous techno-lawful inquiries which will require time and interdisciplinary talk among legal advisors and programming engineers. We can likewise have to execute more modern authoritative conditions, including decentralized debate settlement devices. We will most likely see a combination of lawful agreements and brilliant agreements arise over the course of the following not many years as the innovation turns out to be more fully grown and inescapable, and as lawful principles are embraced. Notwithstanding, we right now actually need best practices, and will most likely need some ideal opportunity to go through an aggregate learning stage. In any case, the greater part of these issues exists absolutely on account of how youthful smart agreements are as an innovation. With such a guarantee, the innovation will unquestionably be consummated over the long run. Without a doubt, smart contracts are going to turn into a necessary piece for our public. Future of Smart Contracts Like any new innovation, blockchain has advanced from a plan to a market trendy expression, and now to a genuine arrangement with applications in genuine business conditions. The advancement from a plan to a fruitful application requires significant investment; however blockchain was revealed as an idea in 1991, associations are seconds ago starting to consolidate it into architected applications in their creative innovations. As an ever increasing number of associations develop blockchain conditions, one freedom for advancement appears to be clear: smart contracts. It is unquestionably the route forward for moderately straightforward contracts that can be coded and executed consequently once pre-conditions have been met for example in private conveyancing where fruition monies can be delivered when agreements are agreed upon. Smart contracts will save organizations around the world a lot of time and cash and will profoundly change the way that they associate with each other in the production network, and with their buyers. There will be restricted human collaboration which will let loose people and key chiefs from managing routine organization and formality, empowering them to continue ahead with normal everyday employment as the smart contract automatically takes up the slack. Furthermore, smart contracts eradicate the need for trust within business relationships. Parties will not control the contract, so any commercial fears will cease to play a part. Events will be monitored and triggered automatically by blockchain. Because a smart contract creates a digital relationship between the parties to the contract, it also means that any updates are recorded in real time, avoiding the danger of multiple iterations being in circulation at any one time. References https://corpgov.law.harvard.edu/2018/05/26/an-introduction-to-smart-contracts-and-their-potential-and-inherent-limitations/ https://blockgeeks.com/guides/smart-contracts/ https://ethereum.org/en/developers/docs/smart-contracts/ https://www.computerworld.com/article/3412140/whats-a-smart-contract-and-how-does-it-work.html https://blockchainhub.net/smart-contracts/ https://www.ibm.com/topics/smart-contracts https://cointelegraph.com/ethereum-for-beginners/what-are-smart-contracts-guide-for-beginners https://www.itransition.com/blog/smart-contract-applications https://www.edureka.co/blog/smart-contracts/ https://in.pinterest.com/pin/296393219222347663/ https://medium.com/@diamantemedia/blockchain-and-smart-contracts-flow-diagram-d1f1c5d8472b https://medium.com/@teexofficial/what-are-oracles-smart-contracts-the-oracle-problem-911f16821b53 Gulshanpreet assists clients on protecting and enforcing their patent portfolios in multiple jurisdictions. Gulshan has a Bachelor's degree in Electronics and Communication Engineering. His undergraduate studies focused on analog and digital devices, microprocessors, antenna systems and digital and wireless communication. Keywords - Smart Contracts, Blockchain, cryptography, computer security, data security, distributed ledger, cryptocurrency, bitcoin, Ethereum, digital currency, patents in blockchain, blockchain leading countries, blockchain leading players Copperpod provides Technology Due Diligence and Source Code Review services to help attorneys dig deep into computer technology products. Our experts are well versed with Java, Objective-C, C/C++, PHP and most other popular programming languages, as well as expertise on security and cryptography standards such as DES, AES, RSA, OpenPGP, MD5, SHA-1, SHA-2, DSA and WEP to provide clients with unparalleled insights and thorough analysis during IP monetization and litigation.

Trade Secrets are IP rights that apply on confidential information. Any information that has a commercial value because it is a secret, known to limited people, and is subject to reasonable steps taken by the rightful holder of the information to keep it a secret, including the use of confidentiality agreements for business partners and employees, is termed as a trade secret. For example, the secret formula for Coca-Cola, which is locked in a vault, is an example of a trade secret that is a formula or recipe. Since it has not been patented, it has never been revealed. In general, any confidential information which provides an enterprise a competitive edge and is unknown to others may be protected as a trade secret. Trade Secrets include both technical information, such as information related to the manufacturing process, pharmaceutical test data, designs, and commercial information, such as a list of suppliers, distributors, and clients, and marketing strategies. Other examples of information that may be protected by trade secrets may include financial information, formulas, and source codes. Although India has no specific trade secrets law, Indian courts have upheld trade secrets protection under various other laws, including contract law, copyright law, the principles of equity and – at times – the common law action of breach of confidence (which in effect amounts to a breach of contractual obligation). The Indian Contract Act, 1872 and the Information Technology Act, 2000 (for digital contracts) are the statutes under which trade secrets may be protected. The benefits available to the owners of trade secrets are: an injunction preventing a licensee, employee, vendor, or another party from disclosing a trade secret. the return of all confidential and proprietary information. compensation for any losses suffered due to the disclosure of trade secrets. Trade Secret Laws in India In lieu of a statute, Trade Secrets are capable of being considered within the framework of the contract, competition, and intellectual property laws simultaneously. 1. Contract law In India, a person can be bound not to disclose any information that is revealed to him or her in confidence with the use of a contract. 2. Copyright law In some cases, client information stored in the form of databases has been categorised as copyrightable material. Every business collects data while operating, which is arranged systematically and can be accessed electronically – for example, to analyse the increase in customer base through various channels or effectiveness of the applied marketing strategies or to maintain an inventory of goods. The wide applications of databases make them an important tool for businesses, allowing them to realise their current efforts, run smoothly and plan their future development. Databases are protectable under copyright law. Section 2(o) of the Copyright Act 1957 defines compilations, including computer databases, as “literary works” The present legal system suggests that every effort, industry or expense of skill is covered under copyrightable work, but only those works are protectable which are somewhat different or involve some intellectual effort or involve a minimum degree of creativity. 3. Principles of Equity Specifically, Indian courts have relied on the principles laid out in the Saltman Engineering case, which, as summarized by Patrick Hearn, author of The Business of Industrial Licensing, states that maintenance of secrecy, according to the circumstances in any given case, either rests on the principles of equity, that is to say the application by the court of the need for conscientiousness in the course of conduct, or by the common law action for breach of confidence, which is in effect a breach of contract. 4. Indian Contract Act, 1872 The Indian Contract Act, 1872 ("Act") governs the law of contracts in India and is predominantly based on English common law. The Act defines the term "contract" as an agreement enforceable by law. In other words, it is a legally enforceable and binding agreement, which is voluntarily entered into between two or more competent parties, for consideration and with mutual obligations. In today's dynamic business environment, the majority of the commercial transactions are successfully and effectively undertaken through contracts. 5. Information Technology Act, 2000 Section 72 of the Information Technology Act provides for criminal remedies, whereby a person may be punished with imprisonment for a term along with a fine in case he is found to have secured access to any electronic record, book, register, information document, or other material without the consent of the person concerned and such first person discloses such information further. In 2009, the Information Technology Act, under Section 43A provided for "Compensation for failure to protect sensitive personal data." Sensitive personal data is further defined in the rules promulgated under this act and includes passwords, financial data, biometric data, etc. Trade Secret Theft Cases in India In “Navigator Logistics Ltd v Kashif Qureshi & Ors (2018)”, the plaintiff, an employer, filed an application for a permanent injunction against eight of its ex-employees and four of its competitors to restrain them from violating and disclosing copyrighted confidential information and trade secrets contained in electronic devices given by the plaintiff to the former employees during the course of their employment. After examining documents, the high court observed that the confidential information was created from client information, which primarily included names, addresses, contact numbers of the clients, customer database, account information, airway drawings, airway bills templates, etc. The court held that such information was purely a mechanical exercise and easily available in the public domain, and thus could not qualify as being a confidential list. The case was dismissed with the court holding that the plaintiff had no cause of action. In “Ritika Pvt Ltd v Biba Apparels Pvt Ltd (2016)”, where a suit was filed for infringement of the plaintiff’s clothing designs, the court took the view that if an injunction order were sought with respect to trade secrets, the specific trade secrets would have to be mentioned, as well as how the plaintiff had ownership of them; only then would the court consider granting an injunction order. A general order in respect of an unspecified trade secret could not be passed against the defendant. Further, no relief under the Copyright Act could be granted, since Section 15(2) of the act provides that once a drawing, sketch or design has been used for creation of more than 50 garments, no copyright can subsist in it. In “Diljeet Titus, Advocate v Alfred A Adebare (2006)” it was held that the courts must step in to restrain a breach of confidence independent of any right under law. The court held that in the context of a law firm, copyright existed in a list which had been specially designed by an advocate and contained details of the firm’s clients, along with the nature of work and contact person for each one. Notably, this obligation need not be expressed, but need only be implied. How Do I Protect My Trade Secrets? Copperpod follows and proposes to clients a 4-pronged DM2 model of trade secret management: DEFINE commercially valuable trade secrets owned by the company, the date of origination, creators as well as employees and vendors that have been given access to individual trade secrets. This may be implemented as an intellectual asset management database maintained by the in-house counsel. MARK documents that contain trade secret information providing ample notice to a recipient of the confidential nature of the document. DISSEMINATE to all current and new employees and vendors the nature and importance of trade secrets that will be disclosed to them, and insert trade secret provisions in contracts. MONITOR continuously the activities and association of current and former employees and vendors with competitors. Conclusion In theory, at least, the treatment of databases as trade secrets can be a stronger form of protection, since it helps to protect the inherent data rather than the mere form of expression protected by copyright law. Copyright and trade secrets law protect different elements of compiled business data, with copyright protecting the expression in these compilations and trade secrets law protecting the underlying data. Currently, no specific or separate legislation regulates the protection of trade secrets and confidential information in India. However, Indian courts rely on equitable and common laws along with the principle of equity to protect trade secrets, with the jurisprudence as a whole revolving around an employee’s obligations and duties towards the employer regarding confidential information gained during employment. Further, in the absence of a specific trade secrets law, the courts have ruled in favor of the proprietor of information as literary work as defined under copyright law. The National IP Rights Policy has raised hopes for the enactment of a trade secrets law as well, since this is one of the objectives of the policy. Although no timeframe has been provided for the achievement of this objective, one can be certain that there will be a trade secrets law soon. References https://www.lexology.com/library/detail.aspx?g=c83e8a6c-a02e-44ba-8723-94087d2e5e20 https://www.loc.gov/law/help/tradesecrets/india.php https://www.mondaq.com/india/trade-secrets/204598/trade-secrets-in-indian-courts https://www.khuranaandkhurana.com/2020/06/09/protecting-trade-secrets-in-india-in-the-absence-of-a-regime/ https://practiceguides.chambers.com/practice-guides/trade-secrets-2020/india https://indiankanoon.org/doc/1836871/ To learn more about the Trade Secrets, read our article on “Demystifying Trade Secrets” Keywords: Trade Secrets, Trade Secret Law, Trade Secret Theft, Trade Secret Protection, Trade Secret Law, Trade Secrets Act, Trade Secret Examples, Intellectual Property Copperpod helps companies protect their competitive advantage through trade secrets, and trade secrets through technology. Contact us to find out if you have trade secrets that might be at risk.

Virtual Reality (VR): It is being used to decode the internal working of the human brain. By tasking people and rodents with solving puzzles inside virtual spaces, neuroscientists hope to learn how the brain navigates the environment and remembers spatial information. Immersive Virtual Reality offers a digital reproduction of real-life environments, whereas Augmented Reality (AR) provides additional information or greater interactivity with the surrounding environment and in both cases, there is a great potential in changing the neuroscience research landscape. Immersive technologies have shown their potential in the evaluation and treatment of various psychological disorders such as anxiety, Post-Traumatic Stress Disorder (PTSD), depression and eating disorders. Virtual Reality has finally come of age for serious applications in behavioral neurosciences. This technology allows for the creation of fully interactive, three-dimensional computerized models of social situations that can be fully controlled by the experimenter. Furthermore, the introduction of interactive virtual characters—either driven by a human or by a computer—allows the researcher to test, in a systematic and independent manner, the effects of various social cues. Recently, however, improvements in computer speed, quality of head-mounted displays and wide-area tracking systems have made VR attractive for both research and real-world applications in neuroscience, cognitive science and psychology. Virtual Reality as Simulation Technology An increasingly popular hypothesis—predictive coding—suggests that the brain actively maintains an internal model (simulation) of the body and the surrounding space, which provides predictions about the expected sensory input and tries to minimize the number of prediction errors. This approach is used not only for actions but also for concepts and emotions. So, the simulation of a concept involves its reenactment in modality-specific brain areas. Moreover, the brain uses emotional concepts to categorize sensations. Virtual Reality: It uses computer technology to create a simulated world that individuals can manipulate and explore as if they were in it. Specifically, VR hardware tracks the motion of the user, while VR software adjusts the images on the user's display to reflect the changes produced by the motion in the virtual world. This prediction is then used to provide the expected sensory input using VR hardware. The VR system maintains a model (simulation) of the body and the surrounding space. Virtual Reality as Embodied Technology If presence in the body is the outcome of different embodied simulations, and VR is a simulation technology, this suggests the possibility of altering the experience of the body by designing targeted virtual environments. In this view, VR can be defined as an “embodied technology” for its possibility of modifying the embodiment experience of its users. Up to now, VR has been used to simulate external reality, that is, to make people feel “real” what is actually not really there. But what is the real clinical potential of VR as an embodied technology? According to neuroscience, the body matrix serves to maintain the integrity of the body at both the homeostatic and psychological levels by supervising the cognitive and physiological resources necessary to protect the body and space around it. Specifically, the body matrix plays a critical role in high-end cognitive processes such as motivation, emotion, social cognition, and self-awareness, while exerting a top-down modulation over basic physiological mechanisms such as thermoregulatory control and the immune system. An altered functioning of the body matrix and/or its related processes might be the cause of different neurological and psychiatric conditions. If this is true, VR can be the core of a new trans-disciplinary research field—embodied medicine—the main goal of which is the use of advanced technology for altering the body matrix, with the goal of improving people's health and well-being. Virtual Reality as Cognitive Technology VR is an embodied technology for its ability to modify the experience of the body. However, the body is not simply an object like any other; it has a special status. It is perceived in a multisensory way, from the outside (exteroception, the body perceived through the senses) as well as from within (inner body, including interoception, the sense of the physiological condition of the body; proprioception, the sense of the position of the body/body segments; and vestibular input, the sense of motion of the body) and from memory. This is true for the simulative code used by the brain for creating concepts. The body integrates visceral/autonomic (interoceptive), motor (proprioceptive), and sensory information. If concepts are embodied simulations, and VR is an embodied technology, it should be possible to facilitate cognitive modeling and can be changed by designing targeted virtual environments which could modify concepts both from outside and from inside. Concept of “Sonoception,” a novel noninvasive technological paradigm based on wearable acoustic and vibrotactile transducers, has a possible approach to structure, augment, and/or replace the contents of the inner body. The first outcome of an integrated VR platform was able to simulate both the external and the inner world with the possibility of structuring, augmenting, and/or replacing all the different experiential aspects of bodily self-consciousness, with clinical applications in the treatment of psychiatric disorders, such as depression or schizophrenia, and neurological disorders, such as chronic pain and neglect. The chart above shows the total count of patents assigned in the last 20 years in the Virtual Reality for the neuroscience field. There was an upward trend in the patents assigned with 462 patents in total from 2001 to 2020. A steep incline was seen from 2015 up to the middle of 2017 with the maximum number of patents i.e. 64 patents. The latest data recorded for the year 2020 showed 39 patents in the Virtual Reality for neuroscience technology trend. Future of Virtual Reality in Neuroscience Virtual and augmented reality devices are measurement tools that generate large amounts of behavioural and neurological data, both in test modes by industry and through consumer use. To advance science, industry and academia should work together to identify ways to improve researchers’ access to this data while safeguarding user privacy and research ethics. There needs to be more research into how VR use may affect the development of a child’s brain, both to understand how its use in educational programs could be beneficial, and how excessive use could be harmful, particularly in developing the child’s sense of reality. More broadly, it is as yet uncertain how the design of VR experiences could shape users’ social behaviour. Better tools for reading and capturing thoughts, which open the door to more intuitive and less effortful control by users, also raise questions about privacy and data ownership that will need to be tackled by interdisciplinary dialogue among neuroscientists, technology developers, ethicists, social scientists, legal scholars and more. It might be instructive to look at how other fields, such as Artificial Intelligence (AI) or genomics, are tackling the ethical implications arising from their research and applications (e.g., through the creation of stakeholder/user communities controlling their own data). Conclusion In conclusion, even if VR is already a reality in behavioral health, the possibility of using it to simulate both the external and internal world may open new clinical options in the near future able to target the experience of the body and its related processes directly. Psychosomatics is an interdisciplinary field that explores the relationships between psychosocial, behavioral factors, and bodily processes. The long-term goal of the vision presented is the use of simulative technologies—both simulating the external world and the internal one—to reverse engineer the psychosomatic processes that connect mind and body but all the benefits of using these tools are not yet known and exploited. The brain sciences are therefore opening up new horizons for cognitive sciences and new practical possibilities, also susceptible to important ethical implications which must also be discussed. References https://www.nature.com/articles/nrn3122 https://www.frontiersin.org/research-topics/9528/virtual-and-augmented-reality-methods-in-neuroscience-and-neuropathology https://link.springer.com/article/10.1007/BF01408706 https://cifar.ca/cifarnews/2019/08/07/the-future-of-neuroscience-and-vr/ https://conductscience.com/maze/virtual-reality-neuroscience-history-applications-future/ https://www.liebertpub.com/doi/full/10.1089/cyber.2017.29099.gri https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5406699/ Keywords: Virtual Reality, Artificial Intelligence, AI, VR, Neuroscience, Life Sciences, Medical Devices, Patents

In the 1990s, office desktops were a tangled mess of serial, parallel, and proprietary cables. Universal Serial Bus (USB) changed all of that, simplifying computer connectivity through a small, inexpensive interface. It is a plug-and-play interface that allows a computer to communicate with peripheral devices. USB-connected devices cover a wide range of electronics like keyboards, mice, game controllers, printers, scanners, digital cameras, and removable media drives, just to name a few. The USB interface can also be used to provide power to low-power peripherals such as smartphones. With billions of USB devices now in daily use, USB is the most widely used wired interface for laptops, tablets, phones, and other devices. How Does USB Work? When a peripheral device is attached via USB, the host computer will detect what kind of device it is and automatically load a driver that allows the device to function. Data is transferred between the two devices in small amounts known as ‘packets’. A set number of bytes (a unit of digital information) is transmitted with each packet. Other information is also sent, including- the source of the data, the destination of the data, the length of the data, and details of any errors that have been detected. Four types of data transfer can occur : Interrupt Transfer - Peripheral devices such as keyboards and mice use this type of data message to send smaller amounts of data. Such transfers are often used for less frequent but important requests. The devices generate the requests, though they must wait for the host to inquire about the specific data the remote device needs. Such requests are guaranteed to be reattempted if the first transfer fails. These transfers will also let you know about any changes to the status of the device. Bulk Transfer - Used by printers and digital scanners for large amounts of data, this type of transfer is low-priority and not time-critical. The transfer will slow down if the host computer has several USB devices connected. Isochronous Transfer - Audio, video, and other real-time data use isochronous transfer. Errors can occur during the transfer, though the transfer will not be interrupted to resend the packets. However, such transfers usually involve situations where the accuracy of the data is not critical, such as audio elements that may not be picked up by the listener. Missing these elements is preferable to retrying data, which could result in glitching audio. Control Transfer - This type of data transfer is used to configure and control a USB device. The host sends a request to the device and the data transfer follows. Control transfers are also used to check status. Only one control request is handled at any one time. USB Protocol USB data is transferred in so-called transactions. Normally, they consist of three packets: The token packet is the header defining the transaction type and direction, the device address, and the endpoint. Data is transferred in a data packet. The final status of the transaction is acknowledged in the handshake packet. IN Transaction – IN Transaction is initiated with IN Token from host followed by data packet by the device. If the device is unable to send data, it uses STALL/NAK handshake. The host can return only one type of handshake ACK. If the host received a corrupted data packet it discards data and issues no response. No handshake packet for isochronous transfer. OUT Transaction – OUT Transaction is initiated with OUT Token from host followed by data packet by the host. The device may return any one of three handshake types. If the device received a corrupted data packet it discards data and issues no response. No handshake packet for isochronous transfer. Setup Transaction – Setup Transaction is similar to OUT, but the data payload is exactly 8 bytes (DATA0 only). Upon receiving the setup token, the device must accept the data. It is not permitted for a device to respond to a SETUP token with a NAK or a STALL. Split Transaction – It is used to initiate a full-/low-speed transaction via the hub and some full-/low-speed device endpoints. The split transaction has two parts: Start Split transaction (SSPLIT) and Complete Split transaction (CSPLIT). USB Standards Released in 1996, the USB standard is maintained by the USB Implementers Forum (USB-IF). There have been four generations of USB specifications: USB 1.x, USB 2.0, USB 3.x, and USB4. There is also the less known Wireless USB standard which was not widely adopted. A group of seven companies began the development of USB in 1994: DEC, Nortel, NEC, Intel, Microsoft, IBM, and Compaq. 1. USB 1.x - It was released in January 1996, USB 1.0 specified data rates of 1.5 Mbit/s and 12 Mbit/s. Few USB devices made it to the market until USB 1.1 was released in August 1998. USB 1.1 was the earliest revision that was widely adopted and led to what Microsoft designated the "Legacy-free PC". It provided a Master / Slave interface and a tiered star topology which was capable of supporting up to 127 devices and a maximum of six tiers or hubs. The master or "Host" device was normally a PC with the slaves or "Devices" linked via the cable. The cable length for USB 1.1 was limited to 5 meters, and the power consumption specification allowed each device to take up to 500mA, although that was limited to 100mA during start-up. 2. USB 2.0 - The USB 2.0 standard is a development of USB 1.1 which was released in April 2000. The main difference, when compared to USB 1.1, was the data transfer speed increase up to a "High Speed" rate of 480 Mbps. However, it should be noted that even though devices are labeled USB 2.0, they may not be able to meet the full transfer speed. The data encoding method for this version of USB is Unicode. In addition to the improvements in data capability USB 2 also saw an increase in the power provision to 1.8A. This enabled USB to provide charge for smartphones that were increasingly charging faster and also for more power-hungry peripherals such as external drives, etc. When compared to USB 1, this provided a much-needed improvement in current capability. 3. USB 3.x - The USB 3.0 specification was released on 12 November 2008. USB 3.0 adds a SuperSpeed transfer mode, with associated backward compatible plugs, receptacles, and cables. SuperSpeed plugs and receptacles are identified with a distinct logo and blue inserts in standard format receptacles. USB 3.0 also introduced the UASP protocol, which provides generally faster transfer speeds than the BOT (Bulk-Only-Transfer) protocol. USB 3.1, released in July 2013 has two variants. The first one preserves USB 3.0's SuperSpeed transfer mode and is labeled USB 3.1 Gen 1, and the second version introduces a new SuperSpeed+ transfer mode under the label of USB 3.1 Gen 2. SuperSpeed+ doubles the maximum data signaling rate to 10 Gbit/s while reducing line encoding overhead to just 3% by changing the encoding scheme to 128b/132b. USB 3.2, released in September 2017, preserves existing USB 3.1 SuperSpeed and SuperSpeed+ data modes but introduces two new SuperSpeed+ transfer modes over the USB-C connector with data rates of 10 and 20 Gbit/s (1.25 and 2.5 GB/s). The increase in bandwidth is a result of multi-lane operation over existing wires that were intended for the flip-flop capabilities of the USB-C connector. 4. Wireless USB - The concept for wireless USB is that, as the name suggests, it provides a wireless connection over which data can be transferred. This USB standard has not been as widely adopted even though the standard was released in September 2010. Sometimes the abbreviation WUSB is used, although the USB-IF does not encourage the use of this abbreviation. Wireless USB uses frequencies in the band 3.1 - 10.6 GHz and provides a data bandwidth of 53 - 480 Mbps over a distance of up to 3 to ten meters. 5. USB 4 - The USB4 specification was released on 29 August 2019 by USB Implementers Forum. USB4 is based on the Thunderbolt 3 protocol specification. It supports 40 Gbit/s throughputs, is compatible with Thunderbolt 3, and backward compatible with USB 3.2 and USB 2.0. The architecture defines a method to share a single high-speed link with multiple end device types dynamically that best serves the transfer of data by type and application. USB Standards and Patent Pool Intel Corporation was granted a patent (US5694555A) on USB technology in 1997, but the protocol system was created in conjunction with six other companies. This technology has become a standard in the industry. However, from both a legal and a business perspective, patents, and industry standards can be problematic. Companies need to fully disclose all relevant patent information before trying to implement proposed industry standards. It might also be expensive to protect and maintain these types of patents and their proprietary nature might hinder wide-spread use. One solution to these problems is to create a "patent pool" - something used by companies associated with the USB standard. All holders of essential patents relating to USB technology - either the first or subsequent USB versions - have combined their patents into one pool called the USB Implementers Forum. This organization allows other participating companies to license USB patents under RAND (Reasonable and Non-Discriminatory) terms without having to pay royalties. Implementers, who use the USB standard, are free to create products that support the standard without fear of lawsuits from the patent holders. Top Players The graph shows the top 10 players who have been assigned the most number of patent families related to USB technology. These patent families come under the CPC classification of G06F13/409 (Mechanical coupling) or H01R27/00 (Coupling parts adapted for co-operation with two or more dissimilar counterparts). There are a total of 1,681 patent families in this category out of which 1015 are still alive. The top 2 assignees, Hon Hai Precision Industry and Apple own 39 and 27 patent families respectively related to USB technology. HP, Intel, and Samsung are ranked 4th, 5th, and 6th positions with an equal number of patent families, i.e. 21, to their name. Conclusion With the ever-increasing requirements for faster and larger levels of data transfer as well as increased levels of convenience and capability, the concept for USB has evolved. The levels of functionality that are available today are enormous when compared to the first standard release in the late 1990s. Since then several new versions of the USB standard have been introduced, each providing a greater level of performance. However, as new standards bring more speed, power, and versatility to market, they also bring a complex assortment of features and capabilities to consider when deciding which cable or peripheral is right for your application. References https://en.wikipedia.org/wiki/USB https://www.cmd-ltd.com/advice-centre/usb-chargers-and-power-modules/usb-and-power-module-product-help/identifying-usb-connector/#identifyingusb4 https://www.tripplite.com/products/usb-connectivity-types-standards https://www.computerhope.com/jargon/u/usb.htm https://www.electronics-notes.com/articles/connectivity/usb-universal-serial-bus/standards.php https://www.cmd-ltd.com/advice-centre/usb-chargers-and-power-modules/usb-and-power-module-product-help/usb-data-transfer-guide/#:~:text=USB%20is%20an%20industry%20standard,then%20via%20a%20USB%20port. https://www.epo.org/news-events/events/european-inventor/finalists/2013/bhatt/feature.html#:~:text=Intel%20Corporation%20was%20granted%20a,a%20standard%20in%20the%20industry Copperpod helps attorneys dig deep into technology products and find evidence of patent infringement through reverse engineering, product testing, and network packet capture. Our reverse engineering and network captures have been relied upon by leading trial attorneys for negotiating over a dozen settlements and royalty agreements on behalf of technology clients. Know more about how we leverage different RE techniques to uncover even the hardest to find evidence of patent infringement.

Snoring, a form of tensed breathing, interferes with quality and quantity of sleep, both for the person who snores and for the person who sleeps with the snorer. Disordered sleep caused by snoring can create significant physical, mental, and economic problems. Humans have been trying to withhold snoring for literally thousands of years, and we have focused on developing straps, pillows, and prods that make it difficult for snorers to sleep on their backs; nose plugs or nasal strips to widen our nasal airways, or in the case of plugs provide EPAP (Expiratory Positive Airway Pressure); and chin straps or mouth inserts to change the position of our jaws, or even move our tongues forward. It’s important to get to the reason behind the snoring to make sure it’s not a medical condition, such as Sleep Apnea. People whose snoring is caused by severe sleep apnea have a 40% greater chance of dying early than their peers and there are severe conditions that are generally found in people with this disease - Stroke (intensity of snoring was related to the risk of carotid atherosclerosis, narrowing of the arteries in the neck due to fatty deposits called plaque — and as a result, stroke) Heart Disease Arrhythmias (people with sleep apnea are more likely to have episodes of atrial fibrillation, the most common type of arrhythmia, than people without it or people whose apnea is treated with CPAP. Apnea may affect the conductive system of the heart) GERD (People who have sleep apnea also may have GERD (Gastroesophageal Reflux Disease) because of the disordered way in which their throat closes while air moves in and out during sleep, causing pressure changes that can suck the contents of their stomach back up into the esophagus) Nocturia (men over the age of 55 who wake up often to urinate may have both benign prostate enlargement and obstructive sleep apnea), Fetal Complications Excess weight gain Smart Snore Detecting Devices A novel wearable gadget SnoreLab records snoring sounds while sleeping and is developed to apply a vibration notification on the upper arm until the snorer sleeps on the side. Unlike an alarm sound, as the vibration is only applied to the snorer, the gadget doesn’t disturb any other person who is sleeping near the snorer. The gadget is low power, rechargeable, and it is wirelessly connected to the listener module using Bluetooth low energy. A smartphone app—connected with the listener module using home Wi-Fi—is developed to start/stop a snoring session, and to log the snoring events with timestamps. As discussed above, about 75% of people who snore, they suffer from disrupted breathing during sleep for short periods—known as Obstructive Sleep Apnea (OSA). Severe sleep apnea carries a significant risk of early death, but even mild to moderate sleep disorders can be related to heart disease, diabetes, reduced sexual function, obesity, gastroesophageal reflux disease, arrhythmia (irregular heart rhythm), headache, nocturia (wake at night several times to urinate) and stroke. The proposed gadget will notify the snorer by vibration and compel them to sleep on their side. Moreover, the logged snoring data can be used to diagnose and monitor OSA and other diseases by the physicians. Poor quality and disordered sleep reduce memory, thinking skills, and the ability to manage conflict. Lack of sleep can make a person irritable, short-tempered, and depressed. The proposed gadget will reduce snoring, increase sleep quality, and facilitate better mental health. In the United States, insufficient sleep and sleep disorders account for $411 billion in economic losses and represent 2.28% of the country’s gross domestic product (GDP) annually. This device can improve sleep quality and reduce economic loss. Smart Nora uses hardware that is placed on a nearby table, listens for snoring. Once detected, another piece of hardware placed under the pillow starts to move in order to stimulate the throat muscles for breathing. This system will slightly move the person’s head when it catches him snoring. Smart Nora includes a wireless, mic-equipped device that can sit bedside or be mounted on your wall to detect snoring. Once it does that, Smart Nora communicates with an under-bed base station that pumps air through a tube to an insert that lives inside the pillow. That motion gently adjusts the head position to reduce snoring. Another built-in electronic is a Smart Pillow. Some smart pillows are meant to deter snoring, others act as sleep tracks, and a few smart pillows, like the ZEEQ, aim to dump every possible smart pillow feature into a single package. Created by the active lifestyle bedding brand REM-Fit, ZEEQ is an innovative smart pillow that not only tracks sleep, but automatically intervenes in the night to help sleep more soundly. It comes with a washable, branded pillowcase and is attached to a small, white remote. Inside, it’s jam-packed with technology that includes eight miniature Bluetooth speakers, adjustable memory foam pieces, a decibel-tuned microphone that monitors snoring, two adjustable vibration motors, and a three-axis gyroscope that tracks motion while the user is asleep. Even while the person is sleeping, the pillow continues to work. If a person begins to snore, the pillow’s two motors gently vibrate, encouraging him to roll over into a position where he will stop snoring. ZEEQ determines the optimal time in the sleep cycle to wake up, at the point where the user can use the app to review his real-time snoring, rest and sleep scoring data. Itamar Medical WatchPAT ONE made a few waves, promising to listen for snoring and with internal motors. The product comprises a chest sensor which consists of a snore sensor and a chest movement sensor. The snore sensor is an acoustic decibel detector and uses a sensitive microphone that responds to snoring and other sounds in the audio range and converts them to a signal that provides an indication of the presence of these sounds. The chest sensor uses a 3-axis accelerometer that provides a signal reflecting the movement of the chest, which can be translated both to the patient's sleeping posture (supine, prone, right, left and sit) and to the chest movement signal resulted by the subject’s breathing during the night. Fitbit provides Snore Detect, an app for Fitbit Versa 2, which uses the microphone on Versa 2 to identify snores along with the intensity and duration of the snores. Fitbit versa 2 currently is beta-testing a feature that will tell a smartwatch wearer if it notices snoring. Snore Detect uses the device’s microphone to note sounds and reports on the duration and intensity of snoring. Eventually, Fitbit hopes to be able to track changes in oxygen levels in the bloodstream to help identify potential breathing problems especially that of obstructive sleep apnea. Hupnos is a lightweight microfiber sleep mask that comes with a silicone nose piece plus breathing valves. It's basically an EPAP (Expiratory Positive Airway Pressure) device but enhanced by various sensors. Hupnos works by detecting the sleeping position and snoring. If a person is indeed sawing logs while lying flat, the mask will send vibrational cues to change their sleeping position, in the hopes of immediately stopping the snoring. Hupnos will then close the expiratory valve by way of a motorized lever covering the hole to increase the exhalation pressure, thus clearing the airway to reduce snoring. The smart part about Hupnos is that this is all controlled by the iOS or Android app via Bluetooth 4.0 LE, and likewise, the mask sends back sleep quality data as well as triggering audio recording for snoring. Based on the sleep data, Hupnos can better determine when to send out vibrations or whether to increase the pressure. The app also lets a person punch in factors like smoking, coffee or alcohol, so that one can observe how these may affect their sleep. On a full charge, Hupnos can monitor at least 20 hours of sleep, which should be good for about three nights for most people; just plug it into a micro-USB cable when charging is needed. Top 10 Players The chart is a depiction of top 10 players in the market which were assigned patents in the smart snore detection device industry. ResMed is the top player to attain 24 patents in the smart snore detection device industry. Closely behind are RIC Investments with 11 patents and Xiamen Tuwan Intelligent Technology with 9 patents. Panasonic and Sanyo Electric are at equivalence with 6 patents each. Seminal Patents 1. US20170361044A1 - Methods and apparatus for treatment of respiratory disorders Assignee: ResMed Limited The patent discloses a method and apparatus for treating a respiratory disorder. The apparatus comprises a pressure generator configured to generate a supply of air at positive pressure to an airway of the patient, a sensor to generate data representing a property of the supply of air, and a controller configured to control the pressure generator to generate the supply of air at a positive treatment pressure that oscillates in synchrony with the patient's spontaneous respiratory efforts. Further, the controller is configured to compute a measure indicative of ventilation of the patient from the sensor data, compute the pressure support so as to bring the measure indicative of ventilation towards target ventilation that is dependent on the measure indicative of ventilation, and control the pressure generator to deliver backup breaths at a backup rate in the absence of significant spontaneous respiratory efforts from the patient, wherein the backup rate increases from a spontaneous backup rate to a sustained timed backup rate. 2. US7246619B2 - Snore detecting method and apparatus Assignee: RIC Investments LLC The patent teaches a method and apparatus for detecting disordered breathing in a patient. The apparatus is used for detecting patient snoring and/or for dynamically determining a snore detection threshold. The apparatus comprises a pressure support system that uses the unique snore detection and/or snore detection dynamic adjustment technique to control the pressure provided at the patient. The snore detector further detects a first and second vibration from a plurality of vibrations defining a single snore event that occurs during the respiratory cycle of such a patient responsive to the filtered digital signal exceeding the threshold value. Conclusion Habitual snoring is a prevalent condition that is not only a marker of obstructive sleep apnea (OSA) but can also lead to vascular risk. However, it is not easy to check snoring status at home. These smart devices may not seem like much, but to a subset of snorers and those in their lives, it might mean the world. More importantly, even if these early pieces of smart anti-snoring tech are limited in their utility, they offer a path forward for future iterations—towards responsiveness, learning, and adaptable therapies. This flexibility will work far better to address the diverse types of snoring and their causes, and work better for the varied sorts of sleepers out there than the old, fixed anti-snoring tech that has for centuries defined our attempts to sleep peacefully—and quietly. References https://www.researchgate.net/publication/335627226_A_Deep_Learning_Model_for_Snoring_Detection_and_Vibration_Notification_Using_a_Smart_Wearable_Gadget https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5620742/ https://www.forbes.com/sites/forbes-personal-shopper/2018/06/27/this-smart-pillow-will-stop-your-partners-terrible-snoring/?sh=79086074d54a https://www.everydayhealth.com/news/eleven-health-risks-snoring/ https://www.reviewgeek.com/17481/what-on-earth-is-a-smart-pillow/ https://www.itamar-medical.com/professionals/disposable-hsawatchpat-one/ https://www.engadget.com/2019-01-07-hupnos-smart-sleep-mask-anti-snoring.html https://hupnos.store/pages/hupnos-sleep-mask https://www.researchgate.net/figure/The-proposed-snoring-detection-and-vibration-notification-system-The-user-configures-the_fig1_335627226 Keywords Sleep apnea, snore detection, snore sensors, Smart wearable devices, Smart pillow, Health risks, e-gadgets, Fitbit, Sleep disorders, microfibres, anti-snoring technology, OSA

3D printing is a process that creates a three-dimensional object by building successive layers of raw material which are produced from a digital 3D file, such as a computer-aided design (CAD) drawing or a Magnetic Resonance Image (MRI). 3D printed medical devices can help doctors better visualize complex health cases. Because of its versatility, 3D printing also has medical applications for FDA-regulated drugs and biologics. Some technical steps are required to finalize a printed model which include selecting the anatomical target area, the development of the 3D geometry through the processing of the medical images coming from a CT/MRI scan, the optimization of the file for the physical printing, and the appropriate selection of the 3D printer and materials. The future is near when it comes to 3D printing. In current times, manufacturers use 3D printing to create devices matched to a patient’s anatomy as well as devices with very complex internal structures. This has sparked huge interest in the 3D printing of medical devices and other products, including food, household items, and automotive parts. Medical Applications Patient-Specific Devices and Implants: Patient-specific devices (like hearing aids) and implants (like artificial joints, cranial plates and even heart valves) are rapidly converting to 3D printing for its easy customization and fast production. There are design advantages too like the 3D printed silicone heart valves provide an exact fit that rigid, traditionally manufactured heart valves simply can’t. For implants like titanium artificial joints or cranial plates, 3D printing can create complex, porous surfaces that make patients’ bodies less likely to reject the implants. Dentistry and Orthodontics: We rely on our teeth to stand up to heavy use day after day—as a result, dentures, crowns, implants and retainers need to be durable, precise and comfortable. On top of that, they need to be made of biocompatible materials like cobalt chrome and porcelain. 3D printing allows dental and orthodontic professionals to accomplish all of this faster and at less cost than traditional methods. A combination of 3D scans and x-rays can be used to produce high-quality dental devices without any setup time. Even for devices like braces or expanders that do not require 3D printed components, 3D printed models made from sterilizable plastics can be used to measure form and fit. Prosthetics: The prosthesis-fitting process typically consists of multiple castings and follow-up appointments to fine tune the fit. With 3D printing, patients don’t even need to sit for a physical cast, instead, technicians can use a 3D scanner to quickly create a precise 3D model of the patient’s residual limb. This 3D scan then serves as the basis for an accurate and affordable 3D printed socket that typically only requires a single fitting visit. Medical Device Development: 3D helps medical device developers produce and test functional prototypes in a fraction of the time, leading to more iterations, better products and less expensive care. Additive manufacturing shines in product development because of its fast turnaround, easy alterations and low cost for very small volumes of parts, it can easily save businesses hundreds of thousands of dollars and months of time in product development. Custom Anatomical Models: Students and professionals regularly use models for education, training, surgery preparation and to provide visual aids for patients. With 3D printing, medical professionals and educators can create affordable custom anatomical models for a range of purposes. For example, surgeons can practice for difficult surgeries using patient-specific models that precisely reproduce the conditions that they will encounter during surgeries. Bioprinting: It works like other 3D printing technologies by using a range of methods, material is deposited or solidified in successive layers to build 3D objects. With bioprinting, printers use stem cells or cells cultivated from tissue samples. These cells are held together with a binding gel or collagen scaffold. Bioprinted body parts and organs would allow patients’ natural tissue to grow over the 3D printed parts and eventually replace the cells with their own. Benefits From printing patient-specific surgical models, surgical instruments to customized prosthetics, 3D printed implants’ applications are vast and ever-growing. One of the most popular applications is ‘patient specific implant’, which has multiple benefits for both- doctors and patients. Aesthetics: 3D printed implants provide very good aesthetics, thus giving back patient’s their lost shape as well as confidence in a very less span of time. Faster patient’s recovery: If the implants are of perfect fit they will start performing their functions early and help in the speedy recovery of patients. Post-op recovery may get delayed if the surgery performed is not efficient due to multiple implants adjustment, larger resection of bones to adjust conventional implants, longer operative times, or any infection occurred during the surgery. Less surgery time: In traditional procedures of implant surgeries, surgeons perform a pre-op assessment on a patient and then visually inspect the placement of the implant. The surgeon makes repeated adjustments until a best fit is found. More adjustments mean longer operative times, higher risk of infections, and are likely to delay post-op recovery. 3D printed implants help to resolve these problems and give a high-success rate in surgery. Perfect fit: 3D printed implants offer a perfect fit for the patients as they are designed precisely as per the patient’s anatomy. Any complex shape can be easily made with the help of ultra-modern 3D designing software and 3D printing machine, that too in much lesser time and without taking multiple sessions with a patient. Less damage to the patient: By using 3D metal printed customized implants will help surgeons to plan surgeries well. Such innovative implants fit well with the defective anatomy where surgeons don’t need to resect large bony tissues and soft tissue to fit the implant perfectly. Product development - Creation of new kinds of geometries like trabecular lattices to encourage bone in-growth on a given implant, 3D printing allows all. The technology not just offers the capability to create and test these geometries, but to prototype them using the intended manufacturing process. When the right design is found, the implant can go straight into production. Custom implants more get-at-able - Custom implants can be developed and made much more quickly. Patients can have access to implants made to fit their bodies leading to easier surgeries and better health outcomes. Biocompatible materials - There is a process for the 3D printing of stents made from nitinol, a shape memory alloy that will resume its intended geometry after deformation; the material is already used for arterial stents, but the ability to apply it with 3D printing could enable more sizes and configurations to made easily. Bioceramics used as support structures and artificial bone grafts can be 3D printed into precise geometries to fit a patient’s anatomy rather than having to be packed manually by the surgeon. Simplifying procedures - Working with an implant made for the patient at hand means that the surgeon has less manual work to do in the operating room. Procedures can be accomplished faster and less invasively and thus patients recovering more quickly and with better health outcomes. 3D printed implants could even reduce the number of surgeries necessary for a given condition. For example, glaucoma stents 3D printed from a dissolvable polymer could eliminate the follow-up surgery necessary to remove the titanium devices commonly used today. Future The 3D printing medical devices market is projected to grow from USD 0.84 billion in 2017 to USD 1.88 billion by 2022, at a CAGR of 17.5% during the forecast period. Market growth is largely driven by factors such as technological advancements, increasing public-private funding for 3D printing activities, easy development of customized medical products, and growing applications in the healthcare industry. In 2017, the software & services segment accounted for the largest share of the 3D printing medical devices market. Whereas, the 3D printing equipment segment is poised to witness the highest growth rate during the forecast period. Every year, 3D printing offers more and more applications in the healthcare field helping to save and improve lives. In fact, 3D printing has been used in a wide range of healthcare settings including, but not limited to cardiothoracic surgery, cardiology, gastroenterology, neurosurgery, oral and maxillofacial surgery, ophthalmology, otolaryngology, orthopaedic surgery, plastic surgery, podiatry, pulmonology, radiation oncology, transplant surgery, urology, and vascular surgery. This clearly shows that 3D printing is one of the most turbulent technologies that have the potential and capability to significantly change the clinical field making care affordable, accessible, and personalized. As printers evolve, printing biomaterials get safety regulated and the public understands how 3D printing works. References https://www.fda.gov/consumers/consumer-updates/3rs-3d-printing-fdas-role https://www.fda.gov/medical-devices/products-and-medical-procedures/3d-printing-medical-devices https://www.energy.gov/articles/how-3d-printers-work https://3dincredible.com/benefits-of-3d-printed-implants-for-doctors-and-patients/ https://www.rapidmade.com/3d-printing-in-the-medical-industry https://www.mmsonline.com/articles/4-ways-3d-printing-is-changing-medical-implants Tanisha is a Technical Content Writer at Copperpod IP. She has a Master's degree and a Bachelor’s degree in Economics specialising in Policy Making and Industrial Economics. Tanisha has worked before as a Content Strategist at an Event Management Company and a Non-Profit Organisation. She takes a keen interest in Sensor Networks, IoT, Wearables, Life sciences and Virtual Reality.

When one person has, by his declaration or by his act, intentionally caused or permitted another person to believe a thing to be true and to act upon such belief neither he nor his representative shall be allowed, in any suit or proceeding between himself and such person or his representative, to deny the truth of that thing. The doctrine of estoppel has gained a new dimension in recent years with the recognition of an equitable doctrine of promissory estoppel both by English and Indian courts. According to it, if a promise is made in the expectation that it should be acted upon in the future, and it was in fact acted upon, the party making the promise will not be allowed to back out of it. Estoppel in Patent Law states that a person can’t simply say one thing and take a position in the US Patent and Trademark Office (USPTO) and then when they go litigate their patent in court, come up with a completely different theory of what a term means or how a particular invention operates. In Cohen v. Cowles Media Co. 501 US 663 (1991), the Supreme Court recognized promissory estoppel as a "state law doctrine creating legal obligations never explicitly assumed by the parties that are enforceable." An agreement made by promissory estoppel will typically have the same binding effects on parties that a valid contract would. If a party breaches an obligation created by promissory estoppel, a court can choose to assign either reliance damages or expectation damages. Types of Estoppels Prosecution History Estoppel - Traditionally, the doctrine of prosecution history estoppel has been utilised as an equitable tool for determining the scope of patent claims. The doctrine bars the patentee from construing its claims in a way that would resurrect subject matter previously surrendered during prosecution of the patent application, and thus prevents a patentee from enforcing its claims against otherwise legally equivalent structures if those structures were excluded by claim limitations added to avoid prior art. The traditional view that depending upon the nature and purpose of an amendment, the doctrine may have a limiting effect within a spectrum ranging from great to small to zero was recently changed by the Federal Circuit. Accordingly, all amendments made for the purpose of patentability are now deemed to have the effect of depriving the inventor of a claim interpretation that includes equivalent structures. During the patent prosecution or invalidity procedures, applicants or patentees usually make amendments on claims or make statements that limits and narrows the scopes of claims in order to accommodate the patent law. Adding new technical features into the independent claim ——picking technical features from the specification and adding them into the independent claim or using a subordinate claim as a new independent claim is a common manner of amendments in practice, and therefore leads to the change of the scope of the independent claim. It was once believed that if such a change produced an essential effect on the patent right, for example overcoming the lack of novelty or inventive step, then all of the other technical features other than the new added one should be excluded from the scope of the independent claim (i.e., the prosecution history estoppel should be applied). Estoppel by a Matter of Record or Quasi-Record - Once a court has given a judgement, the parties, their representatives, their executors, etc. all are bound by that decision. This doctrine stops the parties to a case, from raising another suit in the same matter or to dispute the facts of the case after the decision has been made by the court. Situations where estoppel by record or quasi record arises are as follows: Where the dispute between the parties on the facts have been decided upon by the tribunal which was entitled to take decision in the particular case, and when the same dispute arises again in the matter subsequent to the first one, between the same parties; Where the issue raised between the parties which has been resolved by the judiciary, incidently comes again into question in the subsequent proceedings between the same party. Where an issue raised on the facts, affecting the status of the person or thing, has been willingly determined in a manner that in the final decision it be included as a substantive part of the judgment in rem of the tribunal that has been setup to decide the particular case. This should take place when the same issue comes directly in question in subsequent civil proceedings between any party whatever. Estoppel by Deed - It is the concept where two parties enter into an agreement by way of a deed as to certain facts. This implies that neither he nor his representatives or any person claiming under him can deny the facts mentioned and agreed in the deed. Estoppel by Pais or Estoppel by Conduct - “Estoppel by Pais means ‘Estoppel in the Country’ or ‘Estoppel before the public’. Estoppel by conduct means when a person through agreement, misrepresentation or negligence makes the other person believe in certain things upon which the other person had taken some action causing a change in their current situation, then the first person cannot deny the veracity of the statements given by him in the latter stages. Estoppel by Negligence - This principle allows one party to claim a right over the property of another party who might not be having the possession of it. This reflects that the person being estopped owes a duty to the other person whom he had led into wrong belief. Estoppel on a Point of Law - The Doctrine of estoppel does not apply to statutes but only to the facts. Estoppel, if applied to the law, would go against public policy and general welfare of the society. The principle of estoppel can never be invoked for the purpose of defeating the provisions of law. Estoppel by Acquiescence - When one party, through a legitimate notice, informs the other party about the facts of a claim, and the other party fails to acknowledge it, that is, neither he/she challenges it nor does refute it within a reasonable period of time. The other party now would be estopped from challenging it or making any counterclaim in the future. The other party is said to have accepted the claim though reluctantly, that is, he/she has acquiesced it. Conflict Estoppel - When one person through his speech or conduct makes the other person believe in a particular thing and induces him to act upon it, he would be estopped from taking any conflicting or contrary or erratic position, which could cause loss to the other party. Collateral Estoppel - The doctrine of collateral estoppel safeguards a criminal from being prosecuted for the same issue as raised in the earlier trial in more than one criminal trial. Equitable estoppel - When a person tries to take a legal action that would conflict with his previously given statements, claims or acts, this legal principle would prohibit him from doing so. So, the plaintiff would be stopped from bringing a suit against the defendant who acted pursuant to the commands of the plaintiff. In cases involving contracts between U.S. companies, courts frequently allow a nonsignatory to a contract to enforce an arbitration provision in the contract against a signatory when the signatory to the contract relies on the terms of that agreement in asserting its claims against the nonsignatory. On June 1, 2020, the U.S. Supreme Court ruled unanimously that this principle — known as “equitable estoppel” — may also be applied to international contracts governed by the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, also known as the New York Convention, because nothing in that Convention conflicts with the enforcement of arbitration agreements by nonsignatories under domestic law equitable estoppel doctrines. About the Law Trademark Law In cases involving contracts between U.S. companies, courts frequently allow a nonsignatory to a contract to enforce an arbitration provision in the contract against a signatory when the signatory to the contract relies on the terms of that agreement in asserting its claims against the nonsignatory. On June 1, 2020, the U.S. Supreme Court ruled unanimously that this principle — known as “equitable estoppel” — may also be applied to international contracts governed by the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, also known as the New York Convention, because nothing in that Convention conflicts with the enforcement of arbitration agreements by nonsignatories under domestic law equitable estoppel doctrines. To establish the affirmative defense of estoppel, which may bar all relief on a claim, a respondent must demonstrate: (1) that the trademark owner has engaged in some misconduct that leads the alleged infringer to reasonably believe that the trademark owner will not assert a claim; (2) that the respondent relied on the trademark owner's misconduct; and (3) that the respondent has been materially prejudiced26 based on its reliance. Aukerman, 960 F.2d at 1040. The trademark owner's misconduct “may include specific statements, action, inaction or silence where there was an obligation to speak.” Id. If a respondent points to a complainant's silence or inaction as the basis for its estoppel defense, such “inaction must be combined with other facts respecting the relationship or contacts between the parties to give rise to the necessary inference that the claim against the defendant is abandoned.” Id., at 1042; accord Hemstreet v. Computer Energy Sys. Corp., 972 F.2d 1290, 1295 (Fed. Cir. 1992). However, “even where the three elements of equitable estoppel are established, the court must also ‘take into consideration any other evidence and facts respecting the equities of the parties in exercising its discretion and deciding whether to allow the defense of equitable estoppel to bar the suit.” The doctrine of apparent authority, also referred to as “agency by estoppel,” includes elements of reliance and prejudice associated with the equitable defense of estoppel. Crinkley v. Holiday Inns. Inc., 844 F.2d 156, 166 (4th Cir. 1988). “Agency by estoppel specifically applies to situations where no actual agency relationship exists.” Id.; see Minskoff v. American Express Travel Related Services Co., 98 F.3d 703, 708 (2d Cir. 1996) (discussing proof required to estopp principal from denying apparent authority). Thus, the apparent authority of Deere's dealers arises from manifestations of Deere, as distinguished from the dealers, to third parties and what the third parties reasonably believe from those manifestations. Estoppel Case Law Douglas E. Barnhart, INC. v. CMC Fabricators, INC. (November 2012) In this appeal from an order denying a motion for an award of an attorney fees, it must decide whether a defendant who defeats a claim for breach of contract but loses a related claim for promissory estoppel is entitled to recover attorney fees when the alleged contract provides the prevailing party in any dispute between the parties shall recover such fees. It is held that such a defendant is entitled to recover the attorney fees reasonably incurred in defeating the breach of contract claim. Therefore, there was a reversal of the trial court’s order and remand for further proceedings. Newton Tractor Sales v. Kubota Tractor (April 2009) Plaintiff-Appellant Newton Tractor Sales, Inc. (Newton), brought suit against defendants, Kubota Tractor Corporation and Michael Jacobson, a local Kubota representative on counts of promissory estoppel, common law fraud and negligent misrepresentation. The circuit court of Fayette County granted summary judgement in favour of Kubota on all 3 counts. The appellate court affirmed. 382 III. App. 3d 1176. Newton then filed a petition for leave to appeal, which allowed pursuant to Supreme Court Rule 315 (210 III. 2d R. 315(a)). On appeal it was asked to determine whether promissory estoppel is a recognised cause of action in Illinois, and if so, whether Newton has sufficiently established a genuine issue of material fact so as to survive Kubota’s motion for summary judgement. Tuscano v. Greene Music (December 2004) Joseph Tuscano sued Greene Music for promissory estoppel originating from Greene’s unfulfilled promise of employment, which forced tuscano to resign from an at-will employment position with his former employer. The court awarded Tuscano damages including lost wages based on what Tuscano would have earned from his former employer to the time of his retirement. Greene appeals from the judgement, contending such future wages are impermissible reliance damages and are speculative as a matter of law. Such damages are recoverable on a promissory estoppel theory as long as they are not speculative or remote and are supported by substantial evidence, but they are not available to Tuscano under the evidence in this case. Accordingly, the award of damages to Tuscano for lost future earnings from September 1, 2001, to his retirement and remand the matter to the trial court for retrial limited to the amount of those damages only was vacated. The judgement was affirmed in all other aspects. Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co., Ltd. (May 2002) Plaintiff (Festo) owns two patents for a magnetic rodless cylinder, a piston-driven device that uses magnets to move objects in a conveying system. In response to rejection, the prosecution history reveals that both patent applications were amended to reference prior art and new limitations. There were two new limitations: (1) the inventions are to contain a pair of sealing rings, each having a lip on one side, and (2) the outer shell of the device, the sleeve, is to be made of a magnetizable material. Defendant (Shoketsu) then brought a similar device to the market that had a single sealing ring with a two-way lip and a sleeve made of magnetizable alloy. Plaintiff sued for infringement claiming that although there was no literal infringement, Defendant’s device infringed under the doctrine of equivalents because the devices were very similar. Defendant argued that Plaintiff was stopped from presenting this argument because of the prosecution history regarding the patents. The district court held that Plaintiff’s amendments were not made to avoid prior art and did not result in estoppel. The court of appeals reversed and held that by narrowing a claim to secure a patent, the patentee surrenders all equivalents to the amended claim element. Prior decisions held that prosecution history estoppels made a flexible bar, foreclosing some, but not all, claims of equivalence, depending on the reason for the amendment and the changes in the text. Plaintiff appealed. Walser v. Toyota Motor Sales, U.S.A., INC (December 1994) The plaintiffs, Paul Martin Walser and Philip Martin McLaughlin, appeal from a jury verdict in this diversity case awarding them $232,131 in damages on their promissory estoppel claim against Toyota Motor Sales. The plaintiffs argue that the district court erred by instructing the jury that the plaintiffs damages on their promissory estoppel claim were limited to out-of pocket expenses. The plaintiffs also argue that the district court erred in declining to award specific performance as an alternative remedy on their promissory estoppel claim, in denying their motion for judgement as a matter of law in their contract claim, in instructing the jury on their contract claim, in requiring to accept payment from Toyota for $.89 less than the amount of damages and interest awarded, in granting summary judgement on their claim under Minnesota Motor Vehicle Sale and Distribution Regulations, and in precluding them from taxing costs prior to a final determination of this case on appeal. This was affirmed. Conclusion To sum up, estoppel plays an important role in limiting the legal rights enjoyed by the inventors. The relevant estoppel might be used to set up a cause of action, give a defense to a cause of action or have some other unequivocal impact on evidence causing a claim to succeed or fail. 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References https://blog.ipleaders.in/doctrine-of-estoppel-in-the-indian-evidence-act/#:~:text=Reference-,Introduction,in%20a%20Court%20of%20Law. https://www.lexology.com/library/detail.aspx?g=7cf884c1-1e4b-4763-bf8a-012fe2da5b76 https://www.casemine.com/search/us/promissory%2Bestoppel%2Bcases https://www.casemine.com/judgement/us/5914b6b8add7b0493477aa9c https://www.scconline.com/blog/post/tag/promissory-estoppel/ https://www.ip-watch.org/2017/04/04/current-future-scope-ipr-estoppel/ https://www.bananaip.com/ip-news-center/patents-prosecution-history-estoppel/ https://www.casebriefs.com/blog/law/patent-law/patent-law-keyed-to-adelman/infringement/festo-corp-v-shoketsu-kinzoku-kogyo-kabushiki-co-ltd/ Keywords: Estoppel, patentability, patent infringement search, patent licensing, patent novelty, patent claim terms, infringement claim charts, patent litigation.