Cedar Lane Tech Inc v. Bell Mark Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Bell-Mark Corp (New Jersey)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:24-cv-10453, D.N.J., 11/12/2024
• Venue Allegations: Venue is alleged to be proper in the District of New Jersey because Defendant has an established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe seven patents related to methods and systems for communication between a remote printer and a server, as well as high-speed digital printing systems.
• Technical Context: The technology at issue concerns protocols that enable network-connected printers to communicate directly with servers to download and manage print jobs without the need for a connected host computer.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,346,105 - "Method and system for communicating between a remote printer and a server," Issued July 9, 2019

The Invention Explained

• Problem Addressed: The patent’s background describes the conventional process of printing digital images from the internet as "cumbersome," "tedious, time-consuming, and error-prone," particularly for users without immediate access to a host computer or for transactions completed away from a desk, such as purchasing tickets over the telephone (’105 Patent, col. 1:56-col. 2:67). It also notes that data communications over telephone and wireless connections can be unreliable, leading to interrupted transmissions (’105 Patent, col. 3:41-45).
• The Patented Solution: The invention provides a server-side method for managing a remote printer. It involves receiving printer characteristics, verifying the printer is registered in a database, and then sending the printer information about pending print jobs, such as the number of data items to be printed and downloaded (’105 Patent, Abstract; col. 5:6-12; Claim 1). This protocol allows a printer to communicate directly with a server, bypassing the need for a traditional host computer and enabling more robust data exchange.
• Technical Importance: This approach obviates the need for a dedicated printer driver on a local computer and allows a network-enabled printer to operate independently, enhancing mobility and simplifying the printing process for remote or mobile users (’105 Patent, col. 4:46-53).

Key Claims at a Glance

• The complaint does not identify the specific claims asserted, referring only to "one or more claims" (Compl. ¶17). Independent claim 1 is a representative method claim.
• Essential Elements of Claim 1:
  • Receiving, by a computing device from a remote printer, data identifying one or more characteristics of the remote printer.
  • Verifying, by the computing device, that the remote printer has been registered with the computing device.
  • Sending, from the computing device to the remote printer, an indication of a number of data items to be printed and an indication of a number of print data items to be downloaded, where the printer is configured to download the print data items.

U.S. Patent No. 7,383,321 - "Method and system for communicating between a remote printer and a server," Issued June 3, 2008

The Invention Explained

• Problem Addressed: The ’321 Patent addresses the same problems as the ’105 Patent: the cumbersome nature of printing from the Web, which traditionally requires a host computer, and the unreliability of network connections that can interrupt data transfers (’321 Patent, col. 1:52-col. 2:65; col. 3:23-28).
• The Patented Solution: The invention describes a method for a mobile printer to download data from a server. The protocol involves establishing a communication channel, authenticating, requesting data, and receiving it in portions. A key feature is the use of a "security indicator" (such as a CRC) which is calculated by the server, sent to the printer, and then recalculated and compared by the printer to verify the integrity of the received data portion, making the transmission robust against errors and interruptions (’321 Patent, Abstract; col. 7:30-41; FIG. 6).
• Technical Importance: The described protocol enables reliable, restartable data transmission directly to a printer without a companion computer, enhancing data integrity and the user experience for remote printing (’321 Patent, col. 4:34-40).

Key Claims at a Glance

• The complaint does not identify the specific claims asserted, referring only to "one or more claims" (Compl. ¶23). Independent claim 1 is a representative method claim.
• Essential Elements of Claim 1:
  • Establishing an interprocess communication mechanism.
  • Communicating with a server, which includes sending an authentication request and receiving a response.
  • Requesting print data portions if authentication is successful.
  • Attempting to receive the print data portions, which includes receiving a server-calculated security indicator, calculating a printer-side security indicator, comparing the two, and generating a transmission failure status if they differ.
  • Repeating the attempt to receive data if it fails.
  • Notifying the server after print completion.

Multi-Patent Capsule: U.S. Patent No. 7,958,205

• Patent Identification: U.S. Patent No. 7,958,205, "Method and system for communicating between a remote printer and a server," Issued June 7, 2011.
• Technology Synopsis: This patent, from the same family as the ’105 and ’321 patents, describes a client-server communication protocol. The invention focuses on a printer-side method for establishing a connection with a server, authenticating, requesting and receiving print data in portions, and notifying the server of print completion to ensure reliable and restartable data transfer without a host computer (’205 Patent, Abstract).
• Asserted Claims: The complaint does not specify which claims of the ’205 Patent are asserted (Compl. ¶32).
• Accused Features: The complaint does not specify which features of the accused products allegedly infringe this patent, referring only to "Exemplary Defendant Products" detailed in an external exhibit (Compl. ¶32).

Multi-Patent Capsule: U.S. Patent No. 8,645,500

• Patent Identification: U.S. Patent No. 8,645,500, "Method and system for communicating between a remote printer and a server," Issued Feb. 4, 2014.
• Technology Synopsis: As a member of the same patent family, the ’500 Patent claims a server-side method for managing a remote printer. The method involves receiving a challenge phrase from a printer, running an algorithm to produce a server-calculated value, and comparing it to a printer-calculated value to authenticate the connection before allowing data transfer (’500 Patent, Abstract; Claim 1). This provides a security layer for the remote printing protocol.
• Asserted Claims: The complaint does not specify which claims of the ’500 Patent are asserted (Compl. ¶38).
• Accused Features: The complaint does not specify which features of the accused products allegedly infringe this patent, referring only to "Exemplary Defendant Products" detailed in an external exhibit (Compl. ¶38).

Multi-Patent Capsule: U.S. Patent No. 8,773,685

• Patent Identification: U.S. Patent No. 8,773,685, "High-speed digital image printing system," Issued July 8, 2014.
• Technology Synopsis: This patent addresses techniques for decreasing the total time required for a photo-printing kiosk to print multiple digital images. The invention includes methods such as transferring images from a client to a server's RAMdisk before printing begins, performing image processing on some images prior to initiating printing, and processing images in a specific order (e.g., by decreasing order of estimated processing time) to ensure a continuous flow of data to the print engine (’685 Patent, Abstract).
• Asserted Claims: The complaint does not specify which claims of the ’685 Patent are asserted (Compl. ¶44).
• Accused Features: The complaint does not specify which features of the accused products allegedly infringe this patent, referring only to "Exemplary Defendant Products" detailed in an external exhibit (Compl. ¶44).

Multi-Patent Capsule: U.S. Patent No. 9,448,750

• Patent Identification: U.S. Patent No. 9,448,750, "Method and system for communicating between a remote printer and a server," Issued Sep. 20, 2016.
• Technology Synopsis: This patent, also from the same family, claims a server-side method for managing communication with a remote printer. It covers receiving printer characteristics, verifying the printer's registration status in a database, and based on that verification, sending the printer an indication of the number of print jobs and data portions available for download (’750 Patent, Abstract; Claim 1).
• Asserted Claims: The complaint does not specify which claims of the ’750 Patent are asserted (Compl. ¶53).
• Accused Features: The complaint does not specify which features of the accused products allegedly infringe this patent, referring only to "Exemplary Defendant Products" detailed in an external exhibit (Compl. ¶53).

Multi-Patent Capsule: U.S. Patent No. 9,983,836

• Patent Identification: U.S. Patent No. 9,983,836, "Method and system for communicating between a remote printer and a server," Issued May 29, 2018.
• Technology Synopsis: This patent is another member of the core family and describes the server-side method for managing a remote printer. The claimed method includes receiving printer characteristics, verifying registration, and sending print job information to the remote printer, which is configured to then download the necessary print data (’836 Patent, Abstract).
• Asserted Claims: The complaint does not specify which claims of the ’836 Patent are asserted (Compl. ¶59).
• Accused Features: The complaint does not specify which features of the accused products allegedly infringe this patent, referring only to "Exemplary Defendant Products" detailed in an external exhibit (Compl. ¶59).

III. The Accused Instrumentality

The complaint does not identify the accused product(s) by name in the body of the document. It refers generally to "Exemplary Defendant Products" that are identified in claim chart exhibits (Compl. ¶17, ¶23). As these exhibits were not filed with the complaint, the complaint does not provide sufficient detail for analysis of the accused instrumentality's specific name, features, or functionality.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a narrative theory of infringement or specific factual allegations mapping accused product features to claim elements. Instead, it alleges infringement by incorporating by reference external claim chart exhibits (Exhibits 8 through 14), which were not provided with the pleading (Compl. ¶20, ¶29, ¶35, ¶41, ¶50, ¶56, ¶62). As such, a detailed infringement analysis based on the complaint's text is not possible.

• Identified Points of Contention:
  • Based on the representative claims analyzed in Section II, litigation may focus on several key technical and scope questions. For the server-side methods claimed in the ’105 Patent, a central question may be whether the accused system performs the claimed step of "verifying... that the remote printer has been registered with the computing device" in the manner required by the claim (Claim 1).
  • For the printer-side methods of the ’321 Patent, a technical dispute may arise over whether the accused products' general error-checking or data integrity protocols perform the specific, multi-step process of receiving a server-calculated "security indicator," generating a corresponding printer-calculated indicator, "comparing" the two, and "generating" a specific transmission failure status as claimed (Claim 1).

V. Key Claim Terms for Construction

• Term: "computing device" (from ’105 Patent, Claim 1)

  • Context and Importance: This term defines the entity performing the server-side method. Its construction is critical to determining whether the accused architecture, which may be a distributed or cloud-based system, falls within the scope of a claim described in the context of a single "server 10" (’105 Patent, FIG. 1).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the general term "computing device," which is not explicitly limited to a single, monolithic server.
    • Evidence for a Narrower Interpretation: The specification consistently illustrates the invention using a single "server 10" that performs the claimed functions, which may suggest that the term should be limited to such an architecture (’105 Patent, FIG. 1; col. 5:1-12).

• Term: "mobile printer" (from ’321 Patent, Claim 1)

  • Context and Importance: This term defines the device performing the claimed printer-side method. Practitioners may focus on this term because its definition will determine whether the claim is limited to physically portable devices or broadly covers any network-connected printer that operates without a host PC, regardless of its size or mobility.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims do not recite any limitations related to size, weight, or portability. The core functionality described—direct communication with a server—is applicable to both stationary and portable devices.
    • Evidence for a Narrower Interpretation: The background section frames the problem in the context of "mobile computer user[s]" and the limitations on where images "may be remotely printed," which could support an interpretation limiting the claim scope to devices designed for mobility (’321 Patent, col. 2:54-65).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement of the ’321 and ’685 Patents. The allegations are based on Defendant’s distribution of "product literature and website materials" that allegedly instruct end users on how to use the accused products in an infringing manner (Compl. ¶26, ¶47). Plaintiff alleges Defendant has had the requisite knowledge and intent to induce at least since the service of the complaint (Compl. ¶27, ¶48).
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that Defendant has had "Actual Knowledge of Infringement" for the ’321 and ’685 Patents since the service of the complaint and has continued its allegedly infringing activities despite this knowledge (Compl. ¶25-26, ¶46-47). These allegations may form the basis for a claim of post-suit willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

1. Evidentiary Sufficiency: A primary issue, preceding any technical analysis, will be one of pleading adequacy. As the complaint omits all specific factual allegations of infringement and identifying details of the accused products in favor of incorporating external exhibits by reference, a key question for the court will be whether the pleading provides sufficient notice to Defendant under the federal pleading standards established by Twombly and Iqbal.
2. Functional Equivalence: A key technical question will be whether the accused products’ communication and data-handling protocols perform the specific functions required by the asserted claims. For instance, does a standard network error-checking mechanism perform the distinct steps of calculating, comparing, and generating a status based on a "security indicator" as recited in the ’321 Patent, or is there a fundamental mismatch in technical operation?
3. Definitional Scope: The case may turn on a question of claim construction scope: can terms like "mobile printer" and "computing device," which are rooted in the patent's description of a portable printer communicating with a single server, be construed broadly enough to cover the architecture and nature of the Defendant's commercial products?