PTAB

IPR2013-00474

Printing Industries Of America v. CTP Innovations LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: System And Method Of Generating A Printing Plate File In Real Time Using A Communication Network
  • Brief Description: The ’349 patent describes a system and method for managing remote printing and publishing services over a communication network. The system connects an end-user facility, a central service facility, and a printing company facility to generate a "plate-ready file" from data provided remotely in real time.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claim 1 - Claim 1 is anticipated by Lucivero under 35 U.S.C. §102.

  • Prior Art Relied Upon: Lucivero (Patent 7,242,487).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lucivero, which discloses an imagesetting and electronic prepress system, teaches every limitation of claim 1. Lucivero’s system operates in a standard network environment and includes components that map directly to the claimed "end user facility," "central service facility," and "printing company facility." It describes processing raster or bitmap data for output to devices like platemakers and digital proofers, inherently disclosing the generation of a high-resolution, plate-ready file and the production of a printing plate. The petition provided a detailed chart mapping each element of claim 1 to specific column and line citations in Lucivero.

Ground 2: Obviousness of Claim 1 - Claim 1 is obvious over Nusbickel in view of Lucivero under 35 U.S.C. §103.

  • Prior Art Relied Upon: Nusbickel (Patent 6,119,133) and Lucivero (Patent 7,242,487).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Nusbickel, which was the primary prior art reference cited during prosecution, discloses all limitations of claim 1 except for the "wherein" clause detailing the end-user facility. This clause requires a communication routing device, a computer for page building, and a proofer for printed samples. Petitioner argued this sole remaining limitation was explicitly disclosed in Lucivero’s prepress system, which teaches an end-user front-end computer for preparing image data and output devices including digital proofers.
    • Motivation to Combine: A POSITA would combine Nusbickel and Lucivero because both patents disclose networked printing and publishing systems for generating a plate-ready file from remote data. A POSITA seeking to implement Nusbickel's system would have looked to known prepress system components, such as the proofer and page-building computer described in Lucivero, to complete the end-user facility.
    • Expectation of Success: The combination involved applying known prepress system components (from Lucivero) to a known networked publishing system (Nusbickel), which would have yielded predictable results.

Ground 3: Obviousness of Claim 2 - Claim 2 is obvious over Nusbickel and Lucivero, further in view of Seybold and Adams II under §103.

  • Prior Art Relied Upon: Nusbickel (’133 patent), Lucivero (’487 patent), Seybold (The Seybold Report on Publishing Systems, Oct. 27, 1997), and Adams II ("Computer-to-Plate" Automating the Printing Industry, 1996).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the base combination of Nusbickel and Lucivero renders the main body of claim 2 obvious for the same reasons as claim 1. Claim 2 adds the limitation of "performing open prepress interface (OPI) operations." Petitioner contended that OPI was a well-known technique for enhancing workflow in computer-to-plate technology. Seybold and Adams II were cited as explicitly disclosing the use of OPI for swapping low-resolution placeholder images with high-resolution graphics on a server, which is the core of the claimed OPI operation.
    • Motivation to Combine: A POSITA implementing the printing system of Nusbickel/Lucivero would have been motivated to incorporate OPI operations as taught by Seybold and Adams II to improve system efficiency and speed up page output, a common goal in the art at the time.
    • Expectation of Success: Integrating standard OPI workflow enhancements into a digital prepress system was a known practice with predictable benefits.

Ground 4: Obviousness of Claim 10 - Claim 10 is obvious over Lucivero in view of Sands, Zilles, and Andersson under §103.

  • Prior Art Relied Upon: Lucivero (’487 patent), Sands (Patent 5,634,091), Zilles (“Using PDF for Digital Data Exchange”, 1997), and Andersson (PDF Printing and Publishing, 1997).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner challenged independent method claim 10, which recites generating low-resolution files corresponding to high-resolution files and providing them to a remote client for page layout. Petitioner argued that Lucivero and Sands teach storing high-resolution files on a server and generating low-resolution thumbnails or representations. Zilles and Andersson further teach the use of an OPI workflow where low-resolution "placement only" images are sent to a designer, who then outputs a file (e.g., PDF) that retains links to the high-resolution images stored at the printer.
    • Motivation to Combine: A POSITA would combine these references to create an efficient remote workflow. Using low-resolution files for layout (as taught by Zilles and Andersson) in a networked printing system (like Lucivero's and Sands') was a known method to reduce data transfer times while maintaining final print quality.
    • Expectation of Success: Combining OPI-based remote proofing with digital page imaging systems was a well-understood process that would have been expected to work as intended.

  • Additional Grounds: Petitioner asserted numerous other obviousness grounds against all challenged claims (1-14). These included additional combinations, such as Nusbickel in view of Sands and Benson (European Application # EP0878303) for claim 1, and various combinations including Dorfman (European Application # EP0920667) for the dependent claims. The arguments for dependent claims largely relied on showing the added features (e.g., communicating a PDF for proofing, using a web browser) were also well-known elements in the art.

4. Key Claim Construction Positions

  • Petitioner argued that the Patent Owner acted as its own lexicographer, providing express definitions for key terms in the specification, and these definitions should be used for claim construction.
  • "end user facility": Proposed construction based on the specification is a facility providing "page building operations allowing the design and construction of pages from images, text, and data available via a communication network."
  • "plate-ready file": Proposed construction is "a file format capable of high resolution and is ready for creation of a printing plate," further described as a digital file for producing a printing plate.
  • "thin Postscript file" / "fat Postscript file": Petitioner noted that claim 4 defines these terms functionally. A "thin" file contains low-resolution images, while a "fat" file is formed after replacing them with high-resolution data.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-14 of the ’349 patent as unpatentable.