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Linked List Patented in 2006

Posted by Hemos on Mon Mar 19, 2007 07:11 AM
from the good-thing-that's-protected-now-as-well dept.
An anonymous reader writes "Congratulations are in order to Ming-Jen Wang of LSI Logic Corporation who, in patent #10260471 managed to invent the linked list. From the abstract, "A computerized list is provided with auxiliary pointers for traversing the list in different sequences. One or more auxiliary pointers enable a fast, sequential traversal of the list with a minimum of computational time. Such lists may be used in any application where lists may be reordered for various purposes." Good-bye doubly linked list. We should also give praise to the extensive patent review performed by Cochran Freund & Young LLP."
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  • Prior Art? (Score:5, Funny)

    by tedgyz (515156) * on Monday March 19 2007, @07:13AM (#18400031) Homepage
    I would show the prior art, but I can't read the reel-to-reel tapes.
    • by Tsagadai (922574) on Monday March 19 2007, @07:23AM (#18400105) Journal
      Screw that I'm filing a patent on lodging patents. I'll make millions as gullible companies try to protect their "original" ideas. This guy will be required to pay me a fee for filing that patent.
      • by lanc (762334) on Monday March 19 2007, @07:39AM (#18400205)

        We should also give praise to the extensive patent review performed by Cochran Freund & Young LLP.
        Zefram, Zefram... have you been drinking again?

      • Re:Prior Art? (Score:5, Insightful)

        by Fordiman (689627) <{fordiman} {at} {gmail.com}> on Monday March 19 2007, @07:57AM (#18400381) Homepage Journal
        Well, if your read the patent, it's for triply-linked lists, the purpose for which I can only fathom. Possibly, it's easier to sequence them for block encryption or somesuch. Though, I also imagine that the patent will get killed for its obviousness; adding a tertiary pointer when you need to access a list via another sequence is pretty damned obvious.
        • Re:Prior Art? (Score:4, Informative)

          by ReverendHoss (677044) on Monday March 19 2007, @08:22AM (#18400579)

          I'm not going to take the time to read the patent itself, but just an FYI on your comment, multi-list cells can be considered triply-linked lists. Useful for replacing sparsely populated two-dimensional arrays. Or skip lists, which are rather nifty, though I've never had a real-world application for them beyond job-interview brainteasers.

          Hrm, I wonder if there's anything else patentable in my old Data Structures and Algorithms class notes...

        • Re:Prior Art? (Score:5, Insightful)

          by kripkenstein (913150) on Monday March 19 2007, @08:45AM (#18400787) Homepage
          Well, if your read the patent, it's for triply-linked lists

          True. So it is just slightly less ridiculous than the headline makes it out to be. For crying out loud, I implemented various sorting methods on my linked lists by adding multiple pointers to them two decades ago as a teenager, and I don't believe for a second that I was doing anything remarkable at all. Once you have heard of linked lists then doubly-linked lists, triply-linked lists or whatever-linked lists are pretty much obvious.

          Anyhow, what is really missing in all of this discussion is a response from the patent submitter or the persons in charge of accepting the patent; we never get this on Slashdot nor the stories referred to. Since the patent appears to be so unbelievable, I am very curious as to what their official response would be. Perhaps some IT journalist can get one?
      • by Bitsy Boffin (110334) on Monday March 19 2007, @07:44AM (#18400257) Homepage
        Punch cards? Luxury! In my day we had to carry around bundles of hookup wire...
          • make cast? (Score:5, Funny)

            by norminator (784674) on Monday March 19 2007, @09:11AM (#18401017)

            In my day we had to make cast the bronze ourselves

            make cast? I've done make, make install, make clean, make menuconfig, make xconfig, make modules make modules install, but I've never done make cast...

            But obviously I've never compiled anything with a linked list in it anyhow, since this dude just barely invented them.
      • by Anonymous Brave Guy (457657) on Monday March 19 2007, @07:47AM (#18400281)

        I think you misunderstood. To make the links, you take about 5-6 inches of reel-to-reel tape, wrap it around to form a loop, and then seal it with a bit of sticky tape. Then you take the next piece of reel-to-reel, and loop it through the first before sealing it, thus forming the link. The prior art the GPP mentioned is found in every school for five-year-olds in the country, around 15 December every year, and has been since long before your new-fangled punch cards were invented! :-)

  • wow. (Score:4, Funny)

    by thhamm (764787) on Monday March 19 2007, @07:14AM (#18400041)
    what a genius. he deserves millions over millions for that. and chicks for free.
  • by erroneus (253617) on Monday March 19 2007, @07:15AM (#18400059) Homepage
    People are immediatly shouting "prior art!" I don't care about prior art as much as I care about the fact that it's another software patent and unworthy of being patented.
    • by dreamchaser (49529) on Monday March 19 2007, @07:29AM (#18400133) Homepage Journal
      You're absolutely right. Patenting an algorithm like this would be like me patenting, "A method of transportation involving the repeated placement of one foot in front of the other, thereby conveying motion upon the transportee."
    • by Angostura (703910) on Monday March 19 2007, @07:31AM (#18400147)
      Ah, but you should care. This is good news since it is another excellent piece of ammunition in the battle to show that the system is broken.
      • by bokmann (323771) on Monday March 19 2007, @10:40AM (#18401949) Homepage
        I think the poster's original point is that it is not enough that there is prior art - these things shouldn't get to the point where prior art defense is necessary. We know the system is broken because a patent like this should never have been granted, while someone who is part of the system could say, "you see? the system worked! People Identified prior art and shot down the patent".

        Prior art is a defense if they try to enforce the patent on you. They never should have been given the ability to enforce the patent in the first place.

        Just to be clear, for people who might read this and have no idea what all this linked-list business is about, this ia a data structure that is taught in every 200-level com sci "algorithms and data structures" class, and is so ubituitous that it would certainly be on any exam based on that material. Put in terms in another domain, this would be like patenting "the use of horse hair for the application of water, oil, or acrylic-based substances in an effort to produce a visually aesthetic experience" - that is, a paint brush. Linked lists are in the basic toolset that software engineers use every day. If you are reading this post electronically, then there are probably hundreds of them swirling around inside your computers memory at this very second.

      • by ThePiMan2003 (676665) on Monday March 19 2007, @07:51AM (#18400315)
        Patenting y=mx+b as a method of drawing a line is wrong. Patenting a device that uses this to draw a line, that is different. Algorithms that describe basic ways of doing things are not novel. The biggest difference though is that with a device, if someone discovers some neat effect they can patent a certain way of doing it, but others can come an innovate on that device, inventing something that has the same effect but does it differently and is therefore not covered under the original patent. In software they are patenting the effect, here we have a mutli-way linked linked list, something that CS students have to do in freshman level classes. But now, we can't use it in any way without having to worry about defending ourselves. As someone who writes software for a living I would rather give up on ever getting a patent than having to worry for the rest of my life about implementing something someone else came up with and patented.

        The there is the issue that computer science moves along at such a clip that one company having a monopoly on an idea for the standard patent term could seriously stifle innovation in the field, which is directly against what the entire point of patents are.
      • "I have yet to hear a convincing argument why Babbage's engine, which uses physical mechanical gears to implement an algorithm, is inherently more patentable than the same algorithm in software. How about if I use an FPGA instead? Is it patentable then?"

        Easy: Babbage had to design the gears, switches, etc, and the arrangement thereof to get the effect of calculation. That's patentable. The algorithm he intended to use it to accomplish is not; it's just an artifact of math, and subject to the natural laws clause.

        If you used an FPGA, you could patent the arrangement of gate-feilds, possibly, but the algorithm you're trying to achieve would (should) still not be patentable.
      • by SwiftOne (11497) on Monday March 19 2007, @08:21AM (#18400559)
        I have yet to hear a convincing argument why Babbage's engine, which uses physical mechanical gears to implement an algorithm, is inherently more patentable than the same algorithm in software.

        First, when discussing patents (or copyright), everyone must agree that this is an artificial concept developed to try and achieve a purpose. The purpose in the U.S. is (arguably) to promote innovation. There's no natural or inherent quality of such concepts beyond an inconsistent and ill-defined sense of possessiveness.

        Second, with that in mind, if we look at your question, there are a few ways to approach it. "more patentable" could mean a few different things. I'll argue the discussion about "should be more patentable" i.e. I'll be arguing achieving the purpose, not the current letter of the law legality, of which I'm not fully clear (patents aren't copyright, and that's where the bulk of my limited legal knowledge is).

        When a device is patented, there are a few areas of benefit:

        1) The industry benefits, because the patent is (theoretically) detailed and recorded, meaning that the knowledge will not be lost, and that knowledge will eventually become public domain.

        2) The inventor benefits, because his/her device is recorded, and for a time, no one can use that device or claim credit for it without getting permission.

        3) Licensees benefit, because they can develop new inventions that improve upon or use or otherwise rely upon the patented device.

        4) Competitors benefit, because there is new idea introduced, and though they can't copy that implementation, they can try their own ways of achieving that idea. (knock-offs) In some cases, these prove to have some benefit over the original (a better method, cheaper production, etc)

        I would argue that #4 is why algorithms, business processes, and the like shouldn't be patented. Patenting Babbage's engine doesn't prevent the next guy from trying his luck at building a better mousetrap, so long as he doesn't actually copy Babbage. Patenting the algorithm (effectively the concept) does. Less competition means less benefit, and if I build a better mousetrap that doesn't rely on anything from your mousetrap, I'm not violating your work.

        That's a "should" argument from my personal views. It could well be that patents expressly try to protect ideas and concepts, though I suspect otherwise.

        • by ericlondaits (32714) on Monday March 19 2007, @09:29AM (#18401201) Homepage

          4) Competitors benefit, because there is new idea introduced, and though they can't copy that implementation, they can try their own ways of achieving that idea. (knock-offs) In some cases, these prove to have some benefit over the original (a better method, cheaper production, etc)

          I would argue that #4 is why algorithms, business processes, and the like shouldn't be patented. Patenting Babbage's engine doesn't prevent the next guy from trying his luck at building a better mousetrap, so long as he doesn't actually copy Babbage. Patenting the algorithm (effectively the concept) does. Less competition means less benefit, and if I build a better mousetrap that doesn't rely on anything from your mousetrap, I'm not violating your work.


          You have a good point. I would add a second situation that for me is the worst with algorithms:

          A patent shouldn't be granted if there's a good chance that someone will come across the same exact solution with no knowledge from the patent. By "good chance" I mean probability... in Information Theory terms this would mean that an algorithm should yield some amount of information before being patentable.

          IMHO the n-linked lists don't meet the "amount of information" quota because it's very likely someone comes across this solution on his own when faced with certain types of problems. The same way that many people with no knowledge on sorting come across their own versions of bubble sort... or the same way you can "build" (i.e. emerge) quicksort out of some sorting theory.
          • Yeaaaaaaaa (Score:4, Insightful)

            by unity100 (970058) on Monday March 19 2007, @08:23AM (#18400583) Homepage Journal
            its nice that drug companies each invested $100m and more drug research, got their patents, and they are now selling the drugs for reasonable prices to public and drugs are accessible anywhere in the world. not only that, but they are also making discounts and providing easy access, and even giving out drugs in most poor and needy countries so that things like aids or other dangerous diseases do not spread out.

            oh wait - none of these are valid in this universe - all these are happening in alternate universes.
          • by gnasher719 (869701) on Monday March 19 2007, @08:24AM (#18400589)
            '' Sure hippie. Just as soon as you explain to me how, without patents, a drug company would invest $100M in R&D for a drug that will take comptetitors $1M to copy, driving the price down to the point that they never recover their initial investment. ''

            In German law, this would be very simple: You would sue your competitor for "unfair competition". That was for example the way to handle software pirates in the years before it was established that you could have copyright on software. Worked quite well. It is still used to protect phonebooks on CD, or maps, which are not the kind of material that can be protected by copyright: Copying phonebooks and selling the copies is "unfair competition" unless you hired a bunch of people who typed the material in themselves, using a scanner and OCR software to read them or just copying someone else's CDs is "unfair competition" and therefore illegal.
          • by montyzooooma (853414) on Monday March 19 2007, @08:44AM (#18400769)
            Aside from old age, heart disease and cancer are the big killers in the developed world and they both see major improvement by simply eating healthy and exercising more. Now when someone comes up with a drug that cures cancer as effectively as healthy living prevents it happening in the first place then you can try convincing me about the benefits of drug research.

            Now the more likely scenario is that the drug companies are mainly working on chemical solutions to psychological conditions like depression which were often previously treated with counselling. Those 100 million dollar drugs aren't curing anything, they're alleviating symptoms marginally better than the previous patent-protected drug did.

            • by Fnkmaster (89084) on Monday March 19 2007, @08:45AM (#18400797)
              Finding compounds that are potentially active against some disease, especially compounds with relatively new mechanisms of action, is considered "basic research" - academia does a good job in this area, because it makes for good papers, PhD dissertations and academic plaudits.

              Taking those compounds and ensuring they are safe to administer in humans (rather than just animal models), and that they are as efficacious or more efficacious than other existing treatments is a costly, time-consuming process that requires managing a huge staff, coordinating clinics and hospitals, managing information systems, etc. This is not something universities or most research labs are set up to do properly.

              If you eliminated patents, you clearly wouldn't stop the scientists, but you'd put a huge damper on industry and financiers wanting to back the latter part of this process. This would result in far fewer drugs getting through the FDA approval process.

              It may be the case that there is a more societally efficient way to do this than the current system, but I'm not sure what it is. One problem with the current system is that one effect of it is that the US effectively subsidizes other countries drug availability, because drug companies expect to earn a large portion of their profits here, and have to deal with centrally negotiated pricing and other issues in foreign markets. But I don't see how you'd think that eliminating patents entirely would help the situation.
              • The key difference is that Merk, Phizer, et al would all be able to sell the drug. There would be competition rather than monopoly rents in drug pricing. The money may need to come from taxes, but the people will get that back on the back end by paying less for drugs.

                Sure, the R&D bill needs to be paid. Right now, a ton of it is going into researching new lifestyle medicines that can be marketed via tv adds to affluent aging baby-boomers. That's where the big money is, not curing diseases. Academics are less inclined to pour $100M into researching a new arthritis medication simply because their old (though highly effective) one has gone out of patent.

  • by sco08y (615665) on Monday March 19 2007, @07:16AM (#18400061)
    I read the claims... somebody submit a patent for insertion and deletion operations.
    • I could make millions off of the Pr0n industry for a patent for insertion!

      1 : something that is inserted : as a : the part of a muscle that inserts b : the mode or place of attachment of an organ or part c : embroidery or needlework inserted as ornament between two pieces of fabric d : a section of genetic material that is inserted into an existing gene sequence
      2 a : the act or process of inserting b : the mutational process producing a genetic insertion
  • by Anonymous Coward on Monday March 19 2007, @07:17AM (#18400069)
    The US patent office has proved its incompetence in this area time and time again.
    If you must have software patents, why not a specialist software patent office to deal with them?
  • by Paul Crowley (837) on Monday March 19 2007, @07:17AM (#18400071) Homepage Journal
    If you RTFP, what's actually being patented is the idea of using multiple pointers so that the same item can be in more than one linked list at a time. This idea is also a long way from being novel, but it's slightly different from patenting the linked list. Arguably a doubly-linked list is prior art...
    • The same patent was mentioned in this Slashdot article [slashdot.org]. What is new since then?
    • If you RTFP, what's actually being patented is the idea of using multiple pointers so that the same item can be in more than one linked list at a time. This idea is also a long way from being novel, but it's slightly different from patenting the linked list. Arguably a doubly-linked list is prior art...

      Back in lat 70s when I was a junior programmer, I did some hacking in SNOBOL to produce a list of thinkgs that had to be sorted two different ways. I had nodes that were in two separate list at the same time. Had I known I would have patented it (unfortunately I lost the card deck with the source).

      • by nickovs (115935) on Monday March 19 2007, @08:08AM (#18400473)
        ... if your solution doesn't infringe leaf nodes in the tree of claims, it doesn't infringe.

        That's simply not true. Patent claims are frequently built upon prior claims in the same patent; if a later claim is built on an earlier claim (e.g. in this case where claim 2 cites claim 1) then you need to infringe both parts in order to fall fowl of the later claim. That said, infringing a stand-alone claim (like claim 1 here) is sufficient in itself.

        As far as I can tell claim 1 really does hit a standard doubly-linked list; you have the plurality of data items, a primary order of traversal and an auxiliary order (e.g. reverse traversal). There is obvious prior art for this and the claim should be invalid. Claim 2 is therefor also invalid, irrespective of it's novelty, since it cites an invalid claim. Claims 3 and 4 also have obvious prior art.

        Personally I think that patents like this are great, since they add substantial support to the argument that the USPTO are, despite their avowed best efforts, incapable of assessing the novelty of software patents, and that they should stop trying.
  • by mgblst (80109) on Monday March 19 2007, @07:19AM (#18400083) Homepage
    These, were the examiners. I wonder what it takes to be an examiner, surely you must have a little knowledge in that particular area?

    Do they get a bonus at the end of the week, for the number of patents they have past.
    • by larryboymi (1026734) on Monday March 19 2007, @08:20AM (#18400543)
      I was an examiner for awhile. Got out after 9 months because I saw the path. A lot of $, but a lot of OCD people, and stress due to quotas.

      I had a B.S. in C.S. and I was simply working on GUI patent apps. They wouldn't hire someone with a degree in an outside area (like Business or something) to do C.S. work, although there were a lot of EE's doing C.S. work (although I see that in the commercial realm a lot too, not always to great success, but sometimes).

      Wouldn't recommend it for anyone other than an anti-social who wants to make bank and doesn't mind a boring, high-stress job.
      • I had a friend who was an EE and worked for the USPTO for a while. They were very aggressive in recruiting her, but after six months she was desperate to get out.

        As a few nearby posts have said, they are apparently desperate for bodies. They seem to be in a chicken-and-egg situation - while they are understaffed, the reputation for stress and being underpaid makes it hard for them to hire/retain examiners. Inability to hire/retain examiners results in the existing examiners being overstressed.

        Sadly, for a LONG time, the USPTO was one of the government's biggest moneymakers but was also one of the most underfunded, as all of their income went to what was basically a "generic" fund allocation pool. I've heard efforts are being made to rectify this (i.e. let the USPTO use the majority of what they bring in rather than sending it elsewhere), which should help make things a bit saner.
  • Oh yeah (Score:5, Funny)

    by eeyore (78059) on Monday March 19 2007, @07:28AM (#18400131) Homepage

    I read about this technique about 23 years ago. What is going on here? This looks like material for a slashdot poll, viz:-


    Why do you think that the latest LSI is bogus?
    • (o) It isn't. Free enterprise musn't be regulated by stupid rules, such as "prior art"
    • (o) I read about this in Knuth
    • (o) I slept through a college lecture about this.
    • (o) You woke me up, you insensitive clod!
    • (o) It is an attempt to boost LSI's share price
    • (o) It is a pathetic attempt to dis' LSI!
    • (o) Cowboy Neal has prior art

    What about it, guys?

    --
    E.
  • by TheVelvetFlamebait (986083) on Monday March 19 2007, @07:29AM (#18400135) Journal
    I've got so much code modifying to do.
  • Two things... (Score:5, Informative)

    by thebdj (768618) on Monday March 19 2007, @07:39AM (#18400213) Journal
    The patent # is actually 7028023. The summary quoted number is the application number. Also, this is OLD, issued almost a full year ago. I actually think we had an argument about this long before now. I am starting to wonder if some of these anonymous submissions for these are actually coming from examiners with a clue. (Trust me there are some.) And look, I found it. [slashdot.org]
  • by Anonymous Coward on Monday March 19 2007, @07:48AM (#18400291)
    You are all suffering from hindsight bias, you all think you've used linked and double links and n-linked lists before but in reality you were using vectors and this is a genuine innovation. ;)

    Here in the EU, JURI is trying to criminalize all IP infringements again:
    http://press.ffii.org/Press_releases/Criminal_Sanc tions_Rapporteur_fails_to_protect_European_industr y [ffii.org]

    The vote is expected 20th March (tomorrow) with the aim of making minor copyright, trademark and patent infringement into a criminal offense. There is no fair use in Europe either.
    This has little to do with the real world, EU has no jurisdiction in European criminal law, but if it can make a trade issue into a criminal law issue it can expand EU control in that direction. So JURI has cooked up this trick whereby IP rights are claimed as a trade issue and pumped it up to claim infringement needs criminal prosecutions.

  • Texture mapping [google.com].

    How about slocate [google.com]?

    Or rsync [google.com]?

    Oh and data muxing [google.com].

    Fantastic!
  • Conspiracy (Score:4, Interesting)

    by -Neko- (67564) on Monday March 19 2007, @08:09AM (#18400475) Homepage
    I think this is a global conspiracy to undermine the patent system by submitting totally invalid patents. Once it's found they're unenforcable they'll kill off the patent system that is broken. Yay for that. Congratulations to that law firm and whatever!?

    Actually I'm curious, when was your first experience of a linked list implemented in a highly exposed manner? As far as I recall it was in AmigaOS (but then I am only just young enough to remember that as my first OS and the first OS I cared coding for). A lot of systems do use linked lists, it's a very old (1960's? :) concept. But AmigaOS gave you a linked list for nearly everything, stored all it's windows and objects and tasks in them, and expected you to traverse it with exec.library and utility.library.

    Along with tags (tagitems, taglists) and ReadArgs they're things I miss in modern operating systems which seem too 'hidden' and trying to feel too unixy. It's all pipes and sockets and syscalls, blagghhh.. I'm glad QNX puts message passing right in your face, and DragonFly is bringing it all back to me again. I can't wait until someone patents one of those again!
  • by Greyfox (87712) on Monday March 19 2007, @09:17AM (#18401061) Homepage Journal
    Should be forced to eat a printout of every example of prior art ever published, including the 70s era data structures book I still have on my bookshelf which details the structure in assembly language and the Java, C++ and Linux kernel code bases. Then for dessert he should be forced to eat a printout of the patent. I'd say the applicant should too but he was probably just being sarcastic.

    My regime would require this for patents that are blatantly obvious or have as much published prior art as linked lists do. You can be there'd be a lot fewer frivolous patents issued if the examiner and the applicant were forced to eat the printouts if the patent turned out to be retarded.

    • Re:oh dear (Score:5, Funny)

      by simm1701 (835424) on Monday March 19 2007, @07:19AM (#18400081)
      thats not a reference, thats a pointer!!

      *smack*

      Go back to Algorithms and Data Structures, Do not pass go, Do no increment the Counter by 200 ;)
      • Re:oh dear (Score:5, Funny)

        by Fordiman (689627) <{fordiman} {at} {gmail.com}> on Monday March 19 2007, @08:00AM (#18400391) Homepage Journal
        You've still got it wrong. It's an abstracted class.

        You cannot dereference the pointer; that's impossible. You must first realize that there is no pointer, and that you're only dereferencing yourself.
        • Re:oh dear (Score:4, Funny)

          by Alioth (221270) <no@spam> on Monday March 19 2007, @10:00AM (#18401515) Journal
          Reminds me of...

          C: You shoot yourself in the foot.

          C++: You accidently create a dozen instances of yourself and shoot them all in the foot. Providing emergency medical assistance is impossible since you can't tell which are bitwise copies and which are just pointing at others and saying "That's me, over there."
    • by blckbllr (242654) on Monday March 19 2007, @11:07AM (#18402303)
      One last follow-up that I realized I forgot to discuss:

      In submitting your pre-September 26, 2002 "prior art," you should also make sure that the "prior art" is at least "prior art" under 35 U.S.C. Section 102(b) [uspto.gov]. For the unfamiliar, this is "102(b)" prior art. "Prior art" that falls under the rubric of 35 U.S.C. Section 102(b) generally cannot be challenged by the Applicant of the application for patent. For example, with "102(a)" prior art, the Applicant for patent can "swear behind" the prior art to show that the the Applicant's "date of invention" is before the "prior art's" earliest effective date.

      As an example, I note that the filing date of application is September 26, 2002. In this example, if you were to submit "102(a)" prior art with an earliest effective date of September 27, 2001, the Applicant of the patent may be able to demonstrate that he/she was working on the invention as of September 20, 2001, hence, overcoming the application of this art (there are some legal concerns regarding what constitutes "working on," but I'll save that discussion for a later time). Now, suppose you submit "prior art" with an earliest effective date of September 25, 2001. This is "102(b) prior art" because it's earliest effective date is at least one year prior to the earliest effective filing date of the application (there are some issues when the application claims priority to an earlier filed application, but this is not the case). In this scenario, where the "prior art" applied is "102(b) prior art," the Applicant cannot swear behind the applied "prior art," even if the Applicant was working on the invention before the earliest effective date of the "102(b) prior art."

      That being said, you should also consider whether your "102(b) prior art" discloses each and every limitation of all of the claims, not simply the independent claims (in this case claims 1, 3 and 4.) (For a discussion of "what is a limitation," see the various sub-sections of Section 608.01 [uspto.gov] of the MPEP. However, I will note that you can combine references under 35 U.S.C. 103 [uspto.gov], but again, that's a discussion for another topic.

      So, to recap:

      1) Make sure that your reference is before the earliest, effective filing date of the application for patent (i.e. that it is "prior art");
      2) Make sure that your "prior art" is "102(b) prior art"; and,
      3) Make sure that each and every limitation of each and every claim is disclosed in the application.

      These views represent my own and are in no way associated with any government organization or private entity.