Adobe Inc v. RAH Color Technologies LLC

1. Case Identification

• Case #: IPR2019-00629
• Patent #: 7,312,897
• Filed: February 1, 2019
• Petitioner(s): Adobe Inc.
• Patent Owner(s): RAH Color Technologies LLC
• Challenged Claims: 32, 33, and 37

2. Patent Overview

• Title: System for Distributing and Controlling Color Reproduction at Multiple Sites
• Brief Description: The ’897 patent discloses a system for controlling color reproduction across a network of geographically separated nodes, or "sites." The system aims to ensure that colors appear substantially the same on different rendering devices by using a proprietary "Virtual Proof" data structure to mediate color conversions, allowing a device at one node to represent the output of equipment at another.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claim 32 over Sugiura and Beretta

• Prior Art Relied Upon: Sugiura (Patent 6,177,934) and Beretta (Patent 5,416,890).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Sugiura disclosed a network system that allows printers to be shared between host computers, with the scanner/printer (SP) servers functioning as the claimed "sites." Sugiura provided an application window for users to select a printer from available network printers. Beretta disclosed a graphical user interface (GUI) for constructing and previewing gamut mappings to adapt an image's colors for a specific printer. Petitioner asserted that running Beretta's GUI as an application on Sugiura's host computer meets the limitations of claim 32, where Sugiura provides the interface for selecting a site (printer) and Beretta provides the information for transforming color data via its gamut mapping capabilities.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to integrate Beretta’s sophisticated color management GUI into Sugiura’s established network printing architecture. Petitioner argued that Sugiura's system was designed to run applications, and Beretta's GUI was designed for use on standard computers to solve the exact problem of mapping colors for printing, making the combination a predictable application of known technologies.
  • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved uniting old elements with no change in their respective functions to achieve the predictable result of improved, user-controlled color management within a networked printing environment.

Ground 2: Obviousness of Claims 32 and 33 over Sugiura and Stone

• Prior Art Relied Upon: Sugiura (Patent 6,177,934) and Stone (a 1988 article from ACM Transactions on Graphics).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground again relied on Sugiura for the networked system of "sites" with selectable printers. It substituted Beretta with Stone, which described a more advanced gamut mapping procedure involving not just scaling but also translation and rotation of the color space to better fit the destination gamut while preserving the gray axis. For dependent claim 33, Petitioner argued that Stone’s teachings on Gray Component Replacement (GCR), which involves "aesthetic judgment" to determine the amount of black (K) ink to use, met the claim limitation regarding user preferences for the utilization of neutral colorants.
  • Motivation to Combine: Petitioner contended a POSITA would be motivated to replace Sugiura’s simpler linear color transformation with Stone’s more capable gamut mapping methods. The goal would be to achieve a predictably better match between the source image and the final printed output, a well-known objective in the graphic arts field.
  • Expectation of Success: Success was expected because this was a substitution of one known color conversion technique (Sugiura's) with a more advanced but still well-known technique (Stone's). This substitution would predictably yield the known benefit of improved color fidelity.

Ground 3: Obviousness of Claims 32 and 33 over Newman and Kuwamoto

• Prior Art Relied Upon: Newman (Patent 5,208,911) and Kuwamoto (Patent 5,353,399).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Newman taught a color processing system for transforming data between various input and output devices using user-configurable "compound" transforms. However, Newman lacked a specific user-friendly interface for selecting devices on a network. Kuwamoto was cited to provide this missing element, as it disclosed a graphical interface that allows a user to select networked I/O devices (scanners, printers) from a visual map of a physical location (e.g., floors in a building). Petitioner asserted that these mapped locations in Kuwamoto constituted the claimed "sites," and that combining Kuwamoto's device selection map with Newman's color processing system would meet all limitations of claim 32.
  • Motivation to Combine: A POSITA would be motivated to integrate Kuwamoto's intuitive, map-based device selection interface into Newman's system to satisfy the clear design need for a user-friendly mechanism for selecting network printers. Petitioner argued this was a simple and predictable design choice among a limited number of known options.
  • Expectation of Success: The combination was presented as a mere substitution of a generic selection requirement in Newman with a specific, known, and more intuitive selection technique from Kuwamoto. This would predictably result in an improved user interface without altering the fundamental functions of either system.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including a combination of Sugiura, Beretta, and Anderson (Patent 5,581,682) to add separable annotations (for claim 37), and a combination of Newman, Kuwamoto, and the Photoshop 3.0 User Guide to add annotation capabilities and more refined GCR control.

4. Key Claim Construction Positions

• Petitioner argued that the term "site(s)" as used in claim 32 should be construed as "physical location(s)."
• This construction was asserted to be consistent with standard dictionary definitions and the patent's own specification, which describes "sites" as geographically separated business entities. This interpretation was central to Petitioner's strategy of mapping prior art systems with networked devices in different physical locations (such as different SP servers in Sugiura or different floors in Kuwamoto) to the claims.

7. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 32, 33, and 37 of Patent 7,312,897 as unpatentable under 35 U.S.C. §103.