PTAB

IPR2019-00646

Adobe Inc v. RAH Color Technologies LLC

Log In
Key Events
Petition
petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: System for Distributing and Controlling Color Reproduction at Multiple Sites
  • Brief Description: The ’761 patent discloses a networked system for controlling color reproduction across multiple, geographically separated sites. The system uses "Virtual Proof" data structures containing transformation information to mediate color conversions, allowing the appearance of an image to be substantially the same when rendered on different devices (e.g., monitors, printers) at each site.

3. Grounds for Unpatentability

Ground 1: Obviousness over Stewart and Tajika - Claims 7-9 and 15 are obvious over Stewart in view of Tajika.

  • Prior Art Relied Upon: Stewart (Patent 5,283,671) and Tajika (Patent 5,142,374).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Stewart taught a color printing system with a user interface for customizing color transformations to generate CMYK data. These transformations included user controls for undercolor removal (UCR) and black generation. Petitioner asserted that the input image data on Stewart's monitor is "expressible" in device-independent units because the monitor is capable of calibration. Tajika was presented as teaching a high-quality inkjet printer that uses multiple neutral colorants (light and dark black) and multiple non-neutral colorants, driven by CMYK data. The combination, therefore, allegedly met the claim 7 limitation of transforming device-independent input data into output data for a printer having pluralities of neutral and non-neutral colorants. The user interface in Stewart for controlling black generation was argued to meet the preference limitations of dependent claims 9 and 15.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Stewart's flexible color management system with a high-quality printer like Tajika to achieve the predictable, high-quality output Stewart describes. Petitioner contended that the references share common process steps (image capture, processing, printing), which would motivate a POSITA to combine Tajika's superior print resolution with Stewart's sophisticated user control over image rendering.
    • Expectation of Success: The combination was argued to be a predictable implementation of known methods to achieve a predictable result: a high-quality printed image with user-defined color characteristics.

Ground 2: Obviousness over ICC Specification and Tajika - Claims 7, 8, 10, and 11 are obvious over the ICC Specification in view of Tajika.

  • Prior Art Relied Upon: ICC Specification (InterColor Profile Format, version 3.0) and Tajika (Patent 5,142,374).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the ICC Specification disclosed a standardized color management framework using device profiles and a device-independent Profile Connection Space (PCS) to ensure consistent color across different devices. This framework inherently teaches transforming an input image (e.g., RGB data converted to the PCS) into device-dependent output data (CMYK) for a printer. Tajika's multi-ink printer was presented as a suitable output device to be managed by this framework. Petitioner asserted the ICC Specification explicitly teaches performing conversions to compensate for viewing conditions (claim 10) and using gamut operations (e.g., clipping or compression) to improve the color match between different device reproductions (claim 11).
    • Motivation to Combine: A POSITA would combine a high-quality printer like Tajika with the ICC framework because the framework is expressly designed to manage color for various devices, including printers. The common CMYK interface between the ICC-compliant Color Management Module (CMM) and the printer provides a natural and intended point of integration.
    • Expectation of Success: Deploying a known printer type within a standardized color management system was a straightforward implementation. A POSITA would have a high expectation of success in achieving consistent color reproduction, which is the primary goal of the ICC Specification.

Ground 3: Obviousness over Stone and Tajika - Claims 7, 8, 10, 11, 13, and 15 are obvious over Stone in view of Tajika.

  • Prior Art Relied Upon: Stone (a 1988 journal article on color gamut mapping) and Tajika (Patent 5,142,374).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Stone taught a complete color correction workflow, including converting an input RGB image to a device-independent XYZ space, performing gamut mapping transformations within that space, and converting the result to CMYK for printing. Tajika was again presented as the high-quality printer for rendering the output. Petitioner contended that Stone's teachings met numerous claim limitations, including considering viewing environments during gamut mapping (claim 10), performing gamut operations to improve color match for "cross-rendering" (claim 11), providing a data structure to store text comments with an image (claim 13), and allowing user preferences to define neutrals via gray-axis preservation and rotation (claim 15).
    • Motivation to Combine: Stone's system was designed to generate color separations for proofing printers. A POSITA would be motivated to use a high-quality printer like Tajika to accurately proof the results of Stone's advanced color correction and gamut mapping tools.
    • Expectation of Success: Combining Stone's established color processing pipeline with a suitable high-resolution printer like Tajika was a predictable path to achieving accurate color proofs, a stated objective of the Stone system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Stewart/Tajika/Scott-Taggart (adding remote proofing capabilities) and Giorgianni/Tajika but relied on similar color management and transformation theories.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 7-11, 13, and 15 of the ’761 patent as unpatentable under 35 U.S.C. §103.