Untitled case

I'll research this case thoroughly before writing the overview.

Now let me verify the specific defendant, docket history, and dismissal.

Case Overview: RAH Color Technologies LLC v. Agfa Gevaert N.V. & AGFA Corp., No. 1:17-cv-02145 (N.D. Ill.)

Parties and posture. The correct defendant — which the existing summary flagged as "not confirmed" — is Agfa: Agfa Gevaert N.V. (Belgium) and AGFA Corporation (U.S. subsidiary), sued in the Northern District of Illinois, Chicago division (Cook County), filed March 20, 2017, before Judge Rebecca R. Pallmeyer, with a jury demand. See Justia docket, https://dockets.justia.com/docket/illinois/ilndce/1:2017cv02145/[337903](/patent/337903). (Note: that docket lists the cause of action as "15 U.S.C. § 1126," which is a docketing artifact; the pleading is an ordinary 35 U.S.C. § 271 patent infringement complaint.) Plaintiff RAH Color Technologies LLC is a Virginia LLC with an office in Alexandria, Virginia, wholly owned and managed by Dr. Richard A. Holub, the named inventor of the entire portfolio — the textbook "individual-inventor-started" NPE/PAE profile (Stanford NPE Litigation Database classifies RAH's cases that way, https://npe.law.stanford.edu/patent/[7280251](/patent/7280251)). RAH never sold a product: Holub's 1998 startup, Imagicolor Corp., was dissolved, and RAH was formed in 2005 purely as "a vehicle for an on-going licensing program" (Compl. ¶¶18–20, reproduced at https://insight.rpxcorp.com/litigation_documents/[12379486](/patent/12379486)). Agfa is an operating company — a major graphic-arts/prepress vendor selling plates, presses, and the Apogee workflow software stack. The case did not last: it was closed by stipulated dismissal, order entered September 6, 2017 (Dkt. 40) — about five and a half months after filing — as recorded in a later N.D. Ill. opinion in a companion case (RAH Color Tech. v. R.R. Donnelley, 17 C 0894, R. 23 (June 5, 2017); Agfa, 17 C 2145, R. 40 (Sept. 6, 2017)), https://storage.courtlistener.com/recap/gov.uscourts.ilnd.[341768](/patent/341768)/gov.uscourts.ilnd.341768.70.0.pdf. The dismissal papers themselves are not in the free sources I could reach, so whether a paid license was taken is not confirmed — though a swift stipulated dismissal in a licensing-driven campaign strongly implies settlement.

Accused technology and asserted patents. The accused instrumentalities are the "Agfa Accused Color Workflow Systems," principally the Agfa Apogee Suite — Apogee Prepress, Color Quality Manager, Impose, DigitalPrint Link, InkSave, Proof, and WebApproval — alleged to infringe both by direct infringement and by inducement of Agfa's print-customer end users (Compl. ¶¶78–83, 74–75, at the RPX document link above). The theory is that Apogee's ICC-profile-based color management (including ICC v.4 / Perceptual Reference Medium Gamut-compliant profiles and the Apogee color management module) performs device-independent gamut mapping so that colors "appear substantially the same" across networked output devices — precisely the architecture claimed in the asserted family. The complaint pleads infringement count-by-count with verbatim claim charts; Count I asserts claim 34 of U.S. Patent No. 6,995,870, "System for Distributing and Controlling Color Reproduction at Multiple Sites" (issued Feb. 7, 2006) — a method claim covering a user interface for selecting multiple networked "sites," communication over a network interface, and provision of color-transformation information relating device gamuts plus user color preferences. That bit of the record is solid. The complaint ran to at least nineteen counts (Count XIX is referenced), asserting a package of Holub's related "multiple sites"/color-measurement patents; the public excerpts I retrieved truncate the exhibit list at "United States Patent No. 6,…", so the exact full patent list for this specific complaint is not verified. RAH's contemporaneous 2017 complaints in the same campaign asserted overlapping sets drawn from U.S. Patent Nos. 6,995,870 ('870), 7,280,251 ('251, calibrating color printers), 7,312,897 ('897), 7,729,008 ('008), 7,830,546 ('546), 8,416,444 ('444), 8,537,357 ('357, spectrophotometer apparatus), 8,760,704 ('704) and 8,817,314 ('314) — e.g., RAH v. Fujifilm, No. 1:17-cv-02924 (N.D. Ill. Apr. 18, 2017) (eight patents) and RAH v. R.R. Donnelley, No. 1:17-cv-00894 (N.D. Ill. Feb. 2, 2017) (seven patents). Substantively: the '870/'897/'008/'546/'444/'704/'314 family claims a networked color-management architecture of "prototype" and "production" nodes, each with a rendering device and a color measuring instrument, exchanging a "Virtual Proof" data structure so proofs and press output match across sites.

Why it matters / litigation context. This case is best read as one docket line in RAH's coordinated 2017–2020 enforcement wave against the entire graphic-arts value chain — printers (R.R. Donnelley, Quad/Graphics, Xerox), prepress/workflow vendors (Agfa, Heidelberg, Dalim, EFI, Fujifilm), and software/measurement companies (Adobe, X-Rite, Microsoft, Kodak, Ricoh, Epson). Agfa was an early and quickly-exiting target: RAH's counsel (Global IP Law Group, Chicago) opened licensing discussions in 2016 and, per the complaint, Agfa never counteroffered before suit was filed (Compl. ¶¶51, 72). Venue in N.D. Ill. was a deliberate plaintiff choice — RAH's lawyers are in Chicago, and the district hosted the bulk of the campaign; Judge Kennelly later called that motive out explicitly when he transferred the Adobe case to N.D. Cal., noting "the likelihood is that the case was filed here largely because RAH's primary attorneys are here" (RAH Color Techs. LLC v. Adobe Sys., Inc., No. 18 C 733 (N.D. Ill. May 28, 2018), https://www.casemine.com/judgement/us/5b0f783a80b53b49ad20620e). The campaign's center of gravity moved to MDL No. 2874 (N.D. Cal., Judge Susan Illston), which consolidated the Adobe, Xerox, EFI, Dalim and Heidelberg cases; Adobe's IPRs produced the key validity rulings — IPR2019-00627 ('008) and -00628 ('444) largely failed, IPR2019-00629 ('897) invalidated all challenged claims, and IPR2019-00646 ('761) invalidated claims 7–11 and 13 (final written decisions Aug. 19 and Sept. 3, 2020; see MDL claim construction order, 18-md-02874-SI, Dkt. 120 (Jan. 22, 2021), https://storage.courtlistener.com/recap/gov.uscourts.cand.[327437](/patent/327437)/gov.uscourts.cand.327437.120.0.pdf). The '870 — the sole patent this case's metadata attributes to the Agfa suit — was never subjected to an Adobe IPR and survived into the Dalim MDL case, making it the durable assertion vehicle. Finally, a notable (and, as far as I can tell, unexplored) wrinkle: Holub worked at Compugraphics/Agfa-Bayer from 1990 to ~1993, leading a group developing "device independent color technology," a period that pre-dates the asserted priority filings and sits right next to the accused technology — a fact RAH itself pleaded in the "Background Facts" section of every one of these complaints (Compl. ¶13; also recited in his IPR deposition, https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1523435](/patent/1523435)/download-documents?artifactId=OXyeIt6rTfG90-fsyL2IML3Akjb0HIyeBd7PVJ_Z1Iih5OOlp1HHV-8). Whether Agfa's dismissal had anything to do with that history, or with an existing cross-license, is not documented in the public record I could access — the settlement terms, if any, are unknown.

Sourcing caveats: party names, filing date, judge, and the September 6, 2017 dismissal are corroborated by Justia's docket and by the later N.D. Ill. opinion citing Dkt. 40. The accused products, asserted claim 34 of the '870, and pre-suit licensing contacts come from the complaint text as reproduced in PTAB/RPX exhibit copies, not from a PACER pull of the Agfa docket itself. The complete patent count and the settlement/license terms are unverified.

I'll research this case systematically, starting with the docket and party identification.

Key identification: 1:17-cv-02145 is RAH Color Technologies LLC v. Agfa-Gevaert N.V. and AGFA Corp. Let me dig into that docket.

Now let me trace the Agfa case's docket and disposition specifically.

Bottom line first — and a correction to the existing summary

Case No. 1:17-cv-02145 (N.D. Ill.) is RAH Color Technologies LLC v. Agfa-Gevaert N.V. and Agfa Corporation, filed 2017-03-20 in the Chicago (Eastern) Division before Judge Rebecca R. Pallmeyer, jury demand by plaintiff. Sources: Justia docket index (https://dockets.justia.com/docket/illinois/ilndce/1:2017cv02145/337903); the complaint itself is reproduced as an exhibit in the PTAB record (https://insight.rpxcorp.com/litigation_documents/12379486). The existing case summary ("defendant not confirmed") can now be closed out: the defendants are the Belgian parent Agfa-Gevaert N.V. and its U.S. subsidiary AGFA Corporation.

Two honesty flags before the chronology, because they shape everything below:

1. This is a thin-record case. It never produced a published opinion (no Markman order, no SJ order, no claim construction ruling on the public dockets I could reach). It is one of the ~10 suits in Dr. Richard Holub's color-management campaign, and unlike the Adobe, Xerox, EFI, Quad, Heidelberg, Dalim and Kodak cases, Agfa never appears in MDL No. 2874 — the consolidated RAH litigation in N.D. Cal. before Judge Susan Illston. That absence is the single most probative fact about the case's trajectory.
2. I could not verify the Agfa case's final disposition (dismissal, settlement, or transfer) from a primary source in this session. I ran out of search budget before pulling the actual CM/ECF docket. Below I separate what is documented from what is inference, and I flag exactly where the record goes dark.

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Chronology

1. Filing and initial pleadings — 2017-03-20

RAH Color Technologies LLC (Alexandria, VA; sole member Dr. Richard A. Holub) sued Agfa-Gevaert N.V. and AGFA Corporation in N.D. Ill. The complaint was one of a batch of RAH complaints filed that day, pleading infringement of a portfolio of Holub color-management patents, with the '870 patent (claim 34) asserted in Count I and the '008 patent (claims 28, 35, 37) in later counts (Counts XXII–XXIII).

Documented pleading content:

• Accused products: two families — "Agfa Accused Color Workflow Systems" (Apogee Suite, including Apogee Prepress, Color Quality Manager, Impose, DigitalPrint Link, InkSave, Proof, and WebApproval) and "Agfa Accused Wide Format Workflow Systems" using ICC v.4 profiles and Agfa's CMM.
• Notice / pre-suit dealings: RAH alleged Agfa had actual knowledge of the patents since at least 2015-03-17, and that RAH's counsel (Global IP Law Group, LLC) made a licensing/settlement approach on 2016-04-27 to which Agfa provided no counteroffer (Compl. ¶¶ 51, 71–72).
• Venue theory: notable, because it was pleading into a venue earthquake. RAH invoked 28 U.S

I'll research this case to identify plaintiff's counsel of record.

Now let me dig into the specific docket and counsel appearances.

Let me check the Justia docket page and confirm appearances and case outcome.

Plaintiff's Counsel of Record — RAH Color Technologies LLC v. Agfa Gevaert N.V. et al., No. 1:17-cv-02145 (N.D. Ill.)

Case confirmation first

The "untitled" case in the metadata resolves to RAH Color Technologies LLC v. Agfa Gevaert N V and AGFA Corporation, No. 1:17-cv-02145 (N.D. Ill., Chicago Office), filed March 20, 2017, before Judge Rebecca R. Pallmeyer, Nature of Suit: Patent, jury demand by plaintiff (Justia docket). The complaint asserts the '870 patent together with several related Holub color-management patents ('897, '008, '704, '546, '357, '444), and pleads willfulness dating to a March 17, 2015 notice (Dkt. 1).

Counsel of record for Plaintiff

All three signing attorneys are from Global IP Law Group, LLC, 55 W. Monroe Street, Suite 3400, Chicago, IL 60603 (312-241-1500). The firm is Chicago-based, so it acts as both lead and local counsel — no separate local-counsel firm appears on the complaint. Signature block on Dkt. 1 at p. 61 reads: "Attorneys for Plaintiff, RAH Color Technologies LLC."

Not counsel for plaintiff in this case: The Justia docket summary also lists a Michael Hartmann among entries, and separately lists Berten as "Represented By" for plaintiff. Hartmann's appearance is almost certainly on the defense side (Agfa), but I could not confirm that from a document I could open — treat it as unverified. Do not cite it as plaintiff's counsel.

Gaps and caveats I want to flag explicitly

1. I could not pull the full N.D. Ill. docket sheet directly. PACER was not reachable in this session; the identification of counsel rests on the signed complaint (Dkt. 1) plus Justia's docket summary, not on a complete run of appearance forms (Dkt. 5–20 range). There is a real possibility of substitution, withdrawal, or additional appearances later in the case (e.g., pro hac vice admissions of the same three lawyers, or a later addition of co-counsel) that I could not verify.
2. Nothing indicates sealed filings affecting counsel identity, but I cannot affirmatively rule out sealing.
3. Case outcome is unresolved in what I found. Notably, this Agfa case is absent from the list of tag-along cases swept into MDL No. 2874 (Adobe, Xerox, EFI, Heidelberg, Dalim, Kodak), which suggests it resolved or was dismissed before that consolidation — but that is my inference, not a sourced finding. Do not state an outcome for this case without pulling the docket.
4. The email/messaging exhibits in the IPRs show additional Global IP Law Group staff involved administratively (Kristina Martin, kmartin@giplg.com), but she signs correspondence, not pleadings, and should not be characterized as counsel of record.

Strategic note for your analysis

This matters because RAH's counsel lineup is identical across its entire ~2015–2019 campaign — the same three Global IP Law Group lawyers (Berten, Richards, Park) filed against Agfa, Ricoh, Quad/Graphics, Adobe, Xerox, EFI, Heidelberg, Dalim, and Kodak. That uniformity is why the Adobe IPR petitioners pursued real-party-in-interest discovery against a joint defense group anchored by Quad's counsel, and why RAH's counsel structure (a small Chicago IP boutique with in-house-style client loyalty) is itself relevant to any coordination/ privity argument you may be developing.

I'll research this case to identify the defendant and its counsel of record.

The case is RAH Color Technologies LLC v. Agfa Gevaert N.V. et al. Now let me find defense counsel.

Let me pull the docket and confirm defense counsel details.

Defendant(s) identified

The case metadata's "defendant not confirmed" gap can now be closed: No. 1:17-cv-02145 (N.D. Ill.) is RAH Color Technologies LLC v. Agfa Gevaert N.V. and AGFA Corporation, filed March 20, 2017 before Judge Rebecca R. Pallmeyer (Chicago office; Nature of Suit 830/Patent). The case did not proceed past the pleading stage — the docket reflects a stipulated order of dismissal entered September 6, 2017 (R. 40), noted in the venue opinion in the parallel Quad/Graphics case.[^1][^2]

Counsel of record for the Agfa defendants

For contrast, plaintiff RAH was represented by David P. Berten and Irwin Park of Global IP Law Group, LLC, Chicago — the same team that handled RAH's other suits (Adobe, Quad, Dalim, Xerox, Kodak, EFI) and the Adobe IPRs.[^6]

Sourcing caveats — please read

• Confidence on Hartmann is good but not PACER-verified. The Justia docket summary for 1:17-cv-02145 lists "Represented By: H. Michael Hartmann" for the Agfa defendants, and his representation of Agfa is independently corroborated by the complaint's account of his February 8, 2016 response letter on Agfa's behalf.[^3][^5] I could not pull the N.D. Ill. docket sheet itself (CM/ECF paywall), so additional appearances — local counsel, Leydig associates, or pro hac vice admissions — may exist that I could not verify. Given Leydig, Voit & Mayer's Chicago office, it is likely the firm served as both lead and local counsel, which is common for an IP boutique in N.D. Ill.
• No sealed-material issue. The dismissal was by stipulation, likely pursuant to a settlement/license; no indication counsel information is under seal.
• Do not attribute the Quad/Graphics defense team (Amy J. St. Eve's courtroom; Quad's venue affidavits) or the Adobe team (Perkins Coie — James F. Valentine, Christopher G. Hanewicz, Steven M. Lubezny of the Chicago office) to Agfa; those are separate defendants with separate counsel.
• The Federal Circuit case cited for Hartmann is nonprecedential and I could not confirm the full case name from the snippet; verify before citing.

[^1]: Justia Docket, RAH Color Techs. LLC v. Agfa Gevaert N.V., No. 1:17-cv-02145 (N.D. Ill.), https://dockets.justia.com/docket/illinois/ilndce/1:2017cv02145/337903
[^2]: RAH Color Techs., LLC v. Quad/Graphics, Inc., No. 17 C 4931 (N.D. Ill. Jan. 16, 2018) (St. Eve, J.), slip op. n.5 (citing "Agfa Gevaert (17 C 2145, R. 40, 9/06/17 Order Granting [Stip. to Dismiss])"), https://case-law.vlex.com/vid/rah-color-techs-llc-894429867
[^3]: Justia Docket, supra note 1 ("Represented By: … H. Michael Hartmann").
[^4]: Agfa-Gevaert N.V., No. 2009-1212 (Fed. Cir. Mar. 27, 2011) (nonprecedential), https://cases.justia.com/federal/appellate-courts/cafc/09-1212/09-1212-2011-03-27.pdf
[^5]: RAH's complaint allegations regarding pre-suit notice, reproduced at https://insight.rpxcorp.com/litigation_documents/12379486 (¶¶ 28–50, describing Santomassimo of Nicoll Davis & Spinella LLP, Hartmann of Leydig, Voit & Mayer, and Goedeweek of Agfa-Gevaert).
[^6]: Declaration of David P. Berten, IPR2019-00629 (Mar. 11, 2019), https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1523317](/patent/1523317)/download-documents (listing the six related RAH matters); Attorney list for RAH Color Techs. LLC v. Adobe Inc., No. 3:18-cv-03277-SI (N.D. Cal.).