Untitled case

I'll research this case and the patent systematically.

Case Overview — RAH Color Technologies LLC v. Samsung Electronics Co., Ltd., No. 1:17-cv-05430 (N.D. Ill.)

Parties. The plaintiff, RAH Color Technologies LLC, is a Virginia limited liability company with a listed office in Alexandria, Virginia, formed in 2005 as "a vehicle for an on-going licensing program" for inventions of its founder and manager, Dr. Richard A. Holub (Ph.D. in neurophysiology; former Eikonix/Kodak, Agfa and SuperMac color scientist, and a long-time TAGA officer). RAH Color is, in substance, a patent-holding/licensing entity rather than an operating company — its earlier commercialization venture, Imagicolor Corporation, was dissolved after funding failed, and RAH's own MDL filings state that 27 companies had taken licenses averaging under $1 million. The defendant in this docket is [Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd. ("SEC"), the Korean parent — not Samsung Electronics America — with its principal place of business in Suwon, Republic of Korea, sued over "color displays, digital cameras, smartphones and tablets with cameras, and other hardware and software that employ color measurement and management techniques in the U.S." (Compl., Dkt. 1 ¶¶ 1–3, filed 7/25/2017, https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2019-00628/Adobe_Inc._v._RAH_Color_Technologies_LLC/docs/12-13-2019-Patent_Owner/Exhibit-2228-Exhibit_2228__Complaint__Samsung.pdf). Note the tension between RAH's public framing (a inventor-owned portfolio with an established licensing history) and its litigation conduct, which is the classic PAE assertion model: a long tail of suits against OEMs and their customers in a preferred forum.

Accused technology. The complaint targets Samsung's mobile-device ecosystem rather than a single SKU: "SEC Accused Mobile Devices" (Galaxy phones/tablets) that use an RGB sensor to measure ambient light and a processor running "Adaptive Display" mode to adjust color and white balance to viewing conditions; cameras that write Exif 2.2 image files with color-space, exposure, scene-type and white-balance fields; conversion of camera data to sRGB for display; storage of JPEGs in calibrated sRGB coordinates; and devices having both a USB interface and a wireless network interface (Compl. ¶¶ 68–84; RPX litigation document 12548038, https://insight.rpxcorp.com/litigation_documents/12548038). In other words, the theory is that ordinary smartphone color pipelines — sensor-driven white balance, Exif tagging, sRGB JPEG encoding, USB-plus-Wi-Fi connectivity — practice the asserted claims. That is a notably broad read of a portfolio originally aimed at graphic-arts and prepress color management.

Patents asserted. The metadata flags only U.S. Patent No. 9,516,288, but the complaint actually asserted five patents: the '288 ("Color Calibration of Color Image Rendering Devices" — calibration of displays/printers using captured color image data, including using a portable device's camera in a dual-use mode to image a screen for calibration, spatial-uniformity correction and virtual proofing); the '340, a family member with the same title; the '236 ("Methods and Apparatus for Calibrating a Color Display" — user-interactive display calibration screens plus sensor calibration, priority back to the 2000 application that became U.S. Pat. No. 7,102,648); and the '802 and '546 ("System for Distributing and Controlling Color Reproduction at Multiple Sites" — networked, device-independent color reproduction across remote sites, with the '802 claims adding USB/wireless interfaces and calibrated-RGB file storage). The Google Patents litigation listing that generated the case metadata evidently captured only the '288, so any summary built solely from that record will understate the asserted patent set (compare the parallel complaints, e.g., RAH v. Fujifilm, No. 1:17-cv-02924, Dkt. 1 (N.D. Ill. Apr. 18, 2017), asserting eight patents).

Posture and venue significance. Filed July 25, 2017 in the Chicago office of the Northern District of Illinois — i.e., roughly two months after TC Heartland — this was one of a coordinated wave of 2017 RAH filings in that district (Agfa, No. 1:17-cv-02145, Judge Pallmeyer; Fujifilm, No. 1:17-cv-02924, Judge Tharp; Xerox, No. 1:17-cv-06813, Judge St. Eve; and later Quad/Graphics, Adobe, Heidelberger and Dalim). Venue strategy is the story: against foreign defendants such as Samsung, RAH invoked 28 U.S.C. § 1391(c)(3) (a non-resident alien defendant "may be sued in any judicial district"), while its domestic-defendant cases were vulnerable — Judge Kennelly transferred the Adobe case to N.D. Cal. (RAH Color Techs. LLC v. Adobe Sys., Inc., No. 18 C 733 (N.D. Ill. May 28, 2018)), Quad was sent to E.D. Wis. after a § 1400(b) fight (see RAH Color Techs., LLC v. Quad/Graphics, Inc. venue opinion), and the JPML consolidated the Adobe, Xerox, EFI, Kodak, Dalim and Heidelberger cases into In re RAH Color Technologies LLC Patent Litigation, No. 3:18-md-02874-SI (N.D. Cal., Judge Susan Illston). The assigned district judge in 1:17-cv-05430 and the disposition of the Samsung case could not be confirmed from the sources available to me; the docket does not appear in the commonly indexed free dockets, and I found no opinion, transfer order, or dismissal entry. Given RAH's stated licensing history, a confidential settlement/license is a plausible but unverified explanation — treat that as speculation.

Why it matters. Three reasons. First, it is the clearest illustration of RAH's escalation from graphic-arts defendants (Fujifilm, Agfa, Xerox, Quad, Heidelberg, Dalim) into consumer handsets, where the '288/'340 "use the phone's own camera to calibrate the display" claims potentially reach every flagship smartphone — a dramatically larger damages base than prepress licenses averaging under $1 million. Second, it sits at the center of the IPR linkage: Adobe filed IPR2019-00627, -00628 and -00629 against RAH patents (the '008, '444 and related), and RAH's patent-owner exhibits in those IPRs are the very complaints from this campaign, including the Samsung complaint (Exhibit 2228) — so the district-court pleadings became the record establishing the scope of the earlier litigation for § 315(b) timing and estoppel purposes. Third, the venue arc — foreign-defendant suits parked in N.D. Ill. under § 1391(c)(3), domestic defendants transferred or MDL'd to N.D. Cal. — makes this docket a useful data point on how NPEs re-engineered filing strategy in the immediate post-TC Heartland window; RPX and Unified Patents both track the RAH portfolio in that frame.

Caveats: the complaint text, patent lists, accused-product descriptions, MDL composition and the Adobe transfer are well sourced (pleadings and the MDL 2874 joint status report, https://www.docketalarm.com/cases/PTAB/IPR2019-00646/Inter_Partes_Review_of_U.S._Pat._7791761/docs/04-12-2019-Patent_Owner/Exhibit-2012-46-Exhibit_2012_Jan_7_MDL_Report.pdf). The Samsung case's assigned judge, docket activity after filing, and final outcome are not verified here and should be confirmed against PACER before being relied on.

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

Let me identify the specific defendant for case 1:17-cv-05430.

The defendant is Samsung Electronics Co., Ltd. Now let me pull the docket and disposition.

Case identification (correcting/completing the prior summary)

RAH Color Technologies LLC v. Samsung Electronics Co., Ltd., No. 1:17-cv-05430 (N.D. Ill.), complaint filed 2017-07-25 (Dkt. 1, 34 pp.). The defendant named in the complaint is the Korean parent, Samsung Electronics Co., Ltd. ("SEC"), not Samsung Electronics America. Patents asserted: U.S. 8,279,236; 9,404,802; 9,516,288; 8,638,340; 7,830,546 — so the '288 was one of five patents in this case, not the sole patent. The complaint is reproduced verbatim as an exhibit in Adobe's later IPR (Ex. 2228), which is the best public source for it.

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Chronology of substantive developments

1. Filing and pleadings

Structural/strategic point: RAH sued only the foreign parent. That pleading choice invited threshold Rule 12(b)(2)/(5) and Hague Convention service fights rather than an early merits ruling — contrast RAH's contemporaneous Fujifilm complaint (No. 1:17-cv-02924), which named Fujifilm Holdings plus two U.S. subsidiaries. For a Korean-only defendant with no U.S. place of business, personal jurisdiction and venue under TC Heartland (decided 2017-05-22, five weeks before this suit) were the obvious early battleground.

I could not retrieve the answer, counterclaims, or any Rule 12 motion from this docket. PACER entries beyond Dkt. 1 were not accessible through the sources available to me; the '288 patent's Google Patents litigation record (the source of the original case summary) apparently lists the docket without further entries, and no opinion, Markman order, or judgment from 1:17-cv-05430 surfaced in any search. Any statement about Samsung's answer or counterclaims would be speculation, so I am not offering one.

2. Disposition — settlement/license, not adjudication

The case did not reach claim construction, summary judgment, or trial. The strongest available evidence of its resolution is a footnote in RAH's parallel N.D. Ill. venue litigation against Quad/Graphics:

"RAH maintains that it has reached agreements with Sony and Samsung about the licensing of its patents, therefore, RAH's allegations concerning the infringement of claim 26 of the '546 patent are not relevant to the present Rule 12(b)(3) motion or motion to transfer venue…"

That footnote appears in RAH Color Techs., LLC v. Quad/Graphics, Inc., issued before RAH filed its First Amended Complaint in the E.D. Wis. on 2018-03-15 — i.e., the Samsung license existed by early 2018 at the latest. Consistent with that, RAH's 2019-01-07 Joint Preliminary Status Report in the MDL does not list Samsung among the pending cases, and RAH there describes its business model as ~27 licenses averaging under $1 million per license.

Conclusion: the case was resolved by a license and dismissal in or before early 2018 — a business resolution, not a merits ruling. I could not verify the precise dismissal date, whether it was with or without prejudice, or the license terms. Note the commercial logic: Samsung was the only mobile/consumer-device defendant in RAH's 2017 campaign, so the '288 and '802 (mobile-imaging claims) dropped out of the litigation program entirely once Samsung took a license; the later MDL and 2019–2020 suits were about graphic-arts/print-workflow patents ('870, '008, '761, '444, '357, '546).

3. Markman, discovery, trial, post-trial, appeal

**None occurred in this docket as far as

I'll research this docket and the plaintiff's counsel of record.

Case identification first (necessary because the caption in the file was incomplete)

The docket number resolves to RAH Color Technologies LLC v. Samsung Electronics Co., Ltd., No. 1:17-cv-05430 (N.D. Ill.). The complaint (Doc. 1) was filed July 25, 2017 and asserts five RAH patents — the '236, '802, '288 (the patent in this file), '340 and '546 patents — against Samsung Electronics Co., Ltd. of Suwon, Korea. The case did not go to judgment: RAH and Samsung reached an "agreement-in-principle to settle," and RAH moved to stay the proceedings (R. 15, Unopposed Motion to Stay Proceedings as a Result of Agreement-in-Principle), a fact recited in a later N.D. Ill. opinion. (Complaint, Dkt. 1; N.D. Ill. opinion referencing 17 C 5430, R. 15)

Plaintiff's counsel of record

RAH Color Technologies has been represented throughout this campaign — the 2017 N.D. Ill. Samsung case, the parallel N.D. Ill. cases against Quad/Graphics, Fujifilm, Heidelberger and Dalim, the N.D. Cal. MDL, and the Adobe IPRs — by its own Chicago boutique, Global IP Law Group, LLC, 55 W. Monroe Street, Suite 3400, Chicago, IL 60603. Because GIPLG is Chicago-based and its lead attorney is admitted in the Northern District of Illinois, the firm served as both lead and local counsel here (no separate local-counsel firm was needed, unlike in the N.D. Cal. MDL where Ms. Richards appeared pro hac vice).

In-house: Dr. Richard A. Holub, RAH's sole member and the named inventor, is the client decision-maker (his declarations state "I am the sole member of RAH Color Technologies LLC, and I am authorized to speak on its behalf") but he is not counsel of record.

Sourcing caveats — please read

• The individual appearance docket for 1:17-cv-05430 was not directly retrievable. PACER is paywalled and the case is long closed/stayed; CourtListener's RECAP and Docket Alarm do not expose a per-attorney appearance list for this docket in free search. The attribution above rests on (a) the complaint filed in this very case by GIPLG, (b) GIPLG's contemporaneous appearances in RAH's other 2017–2019 N.D. Ill. cases (Quad/Graphics, Fujifilm, Heidelberger, Dalim) and the MDL, and (c) the PTAB pro hac vice declarations naming Berten as RAH's lead counsel. Berten as lead and GIPLG as firm of record is high-confidence; the exact roster of additional appearances is medium-confidence.
• I found no evidence of any second law firm (e.g., a separate local-counsel or co-counsel arrangement) for RAH in this case — consistent with GIPLG being Chicago-based.
• Nothing in the record I reviewed indicates sealed filings regarding counsel, and no pro hac vice motion would have been needed for the GIPLG Chicago attorneys in N.D. Ill.
• I did not find a Law360 or Reuters report on this specific docket; it appears to have settled quietly in early 2018 (the stay motion, R. 15, is dated on or about January 2018 based on the related docket's description).

Practical note for the litigation team

The '288 patent asserted here was not among the patents Adobe challenged in the IPR2019-00627/628/629/646 series (those covered the '897, '008, '444 and '761 patents), so there is no PTAB validity ruling on the '288 patent to work from; the Samsung case ended at the stay/settlement stage, meaning no claim construction or invalidity ruling on the '288 patent was ever issued in this docket. If you need the '288 patent's actual prosecution/validity exposure, look to the later MDL (No. 3:18-md-02874-SI) and the Kodak/Heidelberger/Dalim tag-along cases, where the same GIPLG team (Berten, Park, Richards) continued to appear.

I'll start by identifying the defendant(s) and docket entries for this case.

Key lead: the complaint in 1:17-cv-05430 references "SEC Accused Mobile Devices." Let me confirm the defendant and pull the docket.

Confirmed the defendant is Samsung Electronics Co., Ltd. Now I need the docket and counsel appearances.

Bottom line

I was able to confirm the case's identity but not the defendant's counsel of record. My searches surfaced the complaint and the related MDL record, but I could not retrieve the docket sheet entries (answers, appearances, Rule 7.1 statements, or dismissal papers), and I will not guess at attorney names. Here is what is verified, what is not, and how to close the gap.

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1. Case identification (verified)

Note that no U.S. subsidiary (Samsung Electronics America, Inc.) was named — the complaint targeted only the Korean parent, which matters for the service/counsel question below. The '288 patent at issue here is "Color Calibration of Color Image Rendering Devices." The full complaint is reproduced as an exhibit in the Adobe IPRs (RAHCT Exhibit 2228 in IPR2019-00628), which is where the text is publicly available: https://www.docketalarm.com/cases/PTAB/IPR2019-00628/Adobe_Inc._v._RAH_Color_Technologies_LLC/docs/12-13-2019-Patent_Owner/Exhibit-2228-Exhibit_2228__Complaint__Samsung.pdf

2. Defendant's counsel of record — NOT VERIFIED

I could not locate any docket entry, opinion, Law360/Reuters report, or firm biography naming counsel who appeared for Samsung Electronics Co., Ltd. in this action. Accordingly:

• Lead counsel: unknown / unverified
• Local counsel (N.D. Ill.): unknown / unverified
• In-house: none identified
• Firm and office: unknown / unverified

I am explicitly declining to name candidates from memory (e.g., firms that commonly represent Samsung in N.D. Ill. patent matters) because doing so would be fabrication dressed as research, and Samsung's outside-counsel assignments vary case by case and year by year.

Two substantive reasons counsel may be thin or absent on the public record, both of which are inferences I am flagging as such rather than findings:

1. Service on a foreign parent. Suing only the Korean entity creates a Hague Convention / service-of-process lag, which frequently delays an appearance by many months.
2. Probable short case life. This case does not appear in the In re RAH Color Technologies LLC Patent Litigation MDL No. 2874 (N.D. Cal.) party list — the MDL covered Adobe, Xerox, EFI, Kodak, Dalim, and Heidelberger, not Samsung. That is consistent with the Samsung case having terminated before the MDL formed in December 2018, but I could not confirm a dismissal order. Case outcome remains unconfirmed.

3. Verified counsel on the other side (context only)

The plaintiff's side is documented, and it is useful for cross-referencing any appearance you pull:

• David S. Berten (IL Bar #6200898), Global IP Law Group, LLC, Chicago — attorney for RAH Color Technologies LLC, listed as such on the In re RAH Color Technologies MDL joint status report (N.D. Cal. MDL No. 2874-SI, Dkt. 46, Ex. 2012 at 1). Global IP Law Group was RAH's litigation counsel across the portfolio campaign.
• Dr. Richard A. Holub is RAH's principal and the named inventor; he is not counsel.

4. How to confirm in one step

The definitive answer lives in a narrow set of PACER entries. Pull the N.D. Ill. docket for 1:17-cv-05430 and look for:

• "ATTORNEY Appearance" entries — the first one after service is the defendant's lead counsel; N.D. Ill. requires local counsel, so expect at minimum one Illinois-barred attorney plus an out-of-state firm.
• Rule 7.1 corporate disclosure statement — usually filed the same day as the appearance and identifies outside counsel of record.
• Any "Notice of Voluntary Dismissal" or Rule 41(a) stipulation — would explain the absence of merits rulings.
• Any motion to dismiss under Rule 12(b)(2)/(5) challenging service on the Korean parent, which is the most likely early filing given the complaint's service allegations (Compl. ¶ 2: "On information and belief, SEC can be served with process at that address").

Recap/CourtListener (courtlistener.com/?q=%221%3A17-cv-05430%22) and Docket Alarm both index this district; the docket did not surface in my searches, which is itself a hint the case generated few entries before terminating.

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Confidence summary: Case number, filing date, defendant identity, and patents-in-suit are high-confidence (read directly off the filed complaint). Defendant's counsel of record is unknown; I found no source establishing it and have not supplied names. If you can supply a single docket PDF or the appearance-entry text, I can profile each attorney's patent-litigation background immediately.