RAH Color Technologies LLC v. Fujifilm Holdings Corp.

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

Case Overview & Background — RAH Color Technologies LLC v. Fujifilm Holdings Corp., No. 1:17-cv-02924 (N.D. Ill.)

The parties. Plaintiff RAH Color Technologies LLC is a Virginia limited liability company operating out of an office at 7012 Colgate Drive, Alexandria, Virginia, and is wholly owned and managed by Dr. Richard A. Holub, a Ph.D. neurophysiologist and career color scientist (Kodak/Eikonix, Agfa/Bayer, SuperMac; longtime TAGA officer and RIT instructor) who is the named inventor on every asserted patent. Compl., Dkt. 1 ¶¶ 1, 16–19 (Apr. 18, 2017). Holub formed Imagicolor Corp. in 1998 to commercialize a display-calibration/soft-proofing prototype, dissolved it when investment failed, and in 2005 formed RAH as a licensing vehicle; he describes himself as RAH's "sole member." Holub Decl. ¶¶ 1, 14–15 (IPR2019-00646, Ex. 2121). RAH is therefore a classic individual-inventor-started PAE — the Stanford NPE Litigation Database categorizes it under "5 Individual-inventor-started" (https://npe.law.stanford.edu/patent/[7830546](/patent/7830546)-0) — though one with an asserted history of real licenses to a dozen large imaging manufacturers plus end-user licenses. Defendants are the Fujifilm group: Fujifilm Holdings Corp. (Tokyo), Fujifilm Holdings America Corp. (Del.), and Fujifilm North America Corp. (N.Y.), all pleaded as sharing a Valhalla, N.Y. address, with Fujifilm North America's Graphic Systems Division operating at 850 Central Ave., Hanover Park, Illinois — the hook for personal jurisdiction and venue. Dkt. 1 ¶¶ 2–7, 13–15.

The accused technology and patents. RAH targeted Fujifilm's prepress, workflow, and color-management stack rather than one product: "Fujifilm Accused Color Management Systems," specifically XMF Workflow (the RIP/workflow manager whose GUI lets users assemble graphical workflow steps) and XMF ColorPath Sync (cloud-based color management that drives color-measurement devices, builds ICC and device-link profiles, and carries black-separation/GCR settings between devices), together with the printers, digital presses, and workflow hardware/software that embody them. Dkt. 1, Counts re '444 claims 21–22 (XMF Workflow "workflow manager"); '251 claims 9, 20–21 (ColorPath Sync device-link profiles and black utilization). The complaint asserted eight patents, the largest set in RAH's 2017 filing wave: the '870, '251, '897, '008, '444, '704, '546, and '314 patents. Six of the eight ('870, '008, '444, '704, '546, '314) share the title and specification "System for Distributing and Controlling Color Reproduction at Multiple Sites" — a networked color-management architecture of nodes, each with a rendering device plus a color measurement instrument, that calibrates/profiles devices and exchanges device-independent color data so reproductions "appear substantially the same" across sites and presses (see claim-construction background in RAH v. Adobe, N.D. Cal. No. 3:18-cv-03277-SI, Dkt. 120, at 2–3). The '546 is a member of that family and issued in 2010 — a one-line sketch is: claims to networked, measurement-based control of color reproduction across multiple sites, invoked by RAH against workflow, print-server, and even camera gamut-processing functionality (in the parallel RAH v. Quad/Graphics case RAH mapped '546 claim 26 to in-camera "Picture Effect" gamut expansion). The '251 ("System and Method for Calibrating Color Printers") covers measurement-driven printer calibration and matching black utilization between devices; the '897 claims user-interface/software-medium aspects — screens for selecting sites, controlling color conversion per device, and verifying output against a device-independent reference (see '897 claim 61). RAH pleaded willfulness with pre-suit knowledge dates of October 3, 2014 and sought enhanced damages and fees under §§ 284–285. Dkt. 1 (Counts re '444, '251).

Posture, venue, and why it matters. Filed April 18, 2017 in the N.D. Ill. Chicago division and assigned to Judge John J. Tharp, Jr., with a jury demand and § 271 causes of action (Justia docket, https://dockets.justia.com/docket/illinois/ilndce/1:2017cv02924/[338964](/patent/338964)). The N.D. Ill. was RAH's preferred forum in this campaign — its attorneys were there, the district ran a patent case pilot program that specially reassigned patent suits, and defendants had Illinois facilities (Fujifilm's Hanover Park graphic-arts site; R.R. Donnelley's Chicago HQ; Quad/Graphics' Bolingbrook plant). That strategy partly collapsed: Judge Kennelly transferred RAH's Adobe suit to N.D. Cal., reasoning that the district had "no relationship to RAH's dispute with Adobe" and warning that the convenience factor "would permit a plaintiff in a patent infringement suit to pick its venue by its choice of attorneys" (RAH v. Adobe, N.D. Ill. No. 17-cv-06813, Dkt. 30), and in December 2018 the JPML created MDL No. 2874, In re RAH Color Technologies LLC Patent Litigation, before Judge Susan Illston in N.D. Cal., sweeping in the Adobe, Xerox, and EFI actions, with conditional transfers later finalized for Heidelberger, Dalim, and Kodak (Pretrial Order No. 1, 18-md-02874-SI, https://www.govinfo.gov/content/pkg/USCOURTS-cand-3_19-cv-00518/pdf/USCOURTS-cand-3_19-cv-00518-0.pdf; Adobe IPR2019-00629 Pet. § I.B). Notably, the Fujifilm case does not appear on the JPML/MDL transfer lists I reviewed, so on the available record it ran on its own track before Judge Tharp rather than being consolidated. The case is notable for three reasons. First, it exemplifies the 2016–2019 RAH campaign's dual-track pressure model: sue manufacturers and their printer/publisher customers (Quad/Graphics, R.R. Donnelley, Xerox), which provoked suppliers such as EFI to file declaratory-judgment actions over indemnity exposure. Second, it is tightly linked to the PTAB: RAH's Fujifilm complaint was itself filed as an exhibit (RAHCT 2224) in Adobe's four inter partes reviews (IPR2019-00627 ('008), -00628 ('444), -00629 ('897), -00646 ('761), all filed Feb. 1, 2019, instituted Aug. 20/Sept. 4, 2019), and Judge Illston stayed the MDL on Sept. 10, 2019 pending those IPRs; the Board's '008 final written decision found claims 28–33 and 36–38 not unpatentable, so the portfolio survived

I'll research this case systematically, starting with broad searches on the docket and then drilling into specific developments.

Now let me dig into the docket and the MDL that this case appears to have been swept into.

Let me pull the actual docket for the Fujifilm case.

Sourcing caveat up front

I hit tool limits before I could pull the complete PACER/RECAP docket sheet for 1:17-cv-02924. What follows separates (a) verified facts with citations from (b) reasoned inference clearly labeled. The single most important finding is that this case appears to have not travelled the full pretrial → Markman → trial path: it was one of roughly a dozen parallel RAH Color suits, and the center of gravity for the patent family shifted to MDL No. 2874 in N.D. Cal., which the Fujifilm case does not appear in.

---

1. Filing and initial pleadings

The complaint is broader than the case metadata suggests. It asserted eight patents, with the '546 patent only one of the set:

• '870 (6,995,870), '251 (7,280,251), '897 (7,312,897), '008 (7,729,008), '444 (8,416,444), '704 (8,760,704), '546 (7,830,546), '314 (8,817,314).

Defendants: Fujifilm Holdings Corp. (Japan), Fujifilm Holdings America Corp. (Del.), Fujifilm North America Corp. (N.Y.). Venue was premised on Fujifilm North America's Hanover Park, Illinois facility and on 28 U.S.C. § 1391(c)(3) for the Japanese parent.

Accused product families (from the counts): Fujifilm X-series digital cameras (X-T1 specifically, under the '314 patent), J Press digital inkjet press with integrated ILS, ColorPath Sync / ColorPath color-rendering systems, and prepress/workflow software. RAH pleaded pre-suit knowledge dates of 2014-10-03 ('704) and specific infringement notice from 2015-06-16, a willfulness predicate.

I could not retrieve an answer, counterclaims (likely declaratory judgment of invalidity/non-infringement plus inequitable conduct), or any Rule 12 motion from this docket. That gap is material and should be filled via PACER.

---

2. The structural event: MDL No. 2874

Rather than litigating Fujifilm as a standalone case, RAH's campaign was consolidated. In re: RAH Color Technologies LLC Patent Litigation, MDL No. 2874, N.D. Cal. No. 3:18-md-02874-SI (Judge Susan Illston). Pretrial Order #1 confirms the MDL covered "nine related patents owned by RAH in the field of color management technology" and set an initial status conference for 2019-01-15.

JPML transfer sequence (from the JPML docket, MDL 2874):

• Initial tranche: 4 actions — E.D. Wis. 2:18-cv-00087 (Quad/Graphics), N.D. Ill. 1:17-cv-06813 (Xerox), N.D. Cal. 3:18-cv-03277 (Adobe), N.D. Cal. 3:18-cv-01612 (EFI).
• 2019-01-17 CTO-1 filed (Heidelberger 1:19-cv-00193; Dalim 1:19-cv-00275); finalized 2019-01-25.
• 2019-02-13 CTO-2 filed (Kodak, W.D.N.Y. 6:19-cv-06112); finalized 2019-02-21.

Critically for your question: the Fujifilm case (1:17-cv-02924) appears in none of the JPML transfer orders, and it is absent from RAH's own "related matters" mandatory notices filed with the PTAB in February and April 2019, where RAH listed every then-live RAH suit ('008 notice, 2019-02-22; '761 amended notice, 2019-04-11). Inference (not independently confirmed): the Fujifilm case was dismissed, settled, or otherwise terminated before MDL formation in mid-2018 — consistent with RAH's pattern in the same window, where Judge Kennelly noted that RAH's Xerox suit was "in settlement discussions" and its Samsung suit (1:17-cv-05430) had an "agreement-in-principle to settle."

---

3. Pre-trial motions of substance

In this case: none verified. No transfer motion, no stay-pending-IPR motion, and no summary judgment motion is documented in the sources I reached. Note that Fujifilm never became an MDL tag-along, so there was no JPML-driven § 1404(a) fight here.

The comparable fights in sister cases (relevant because they show how the '546-family litigation was managed, and because the briefing repeatedly cites the Fujifilm complaint as evidence of RAH's notice/marketing conduct):

• § 1404(a) transfer, RAH v. Adobe, N.D. Ill. 1:18-cv-00733, Dkt. 30 (Judge Matthew Kennelly) — granted, transferring to N.D. Cal. Kennelly rejected RAH's "access to sources of proof" argument in unusually blunt terms ("There is no truck and, for the most part, there are not even hard copies"), and rejected RAH's fallback request for E.D. Va.
• **§

I'll research the counsel of record for RAH Color Technologies in this case.

Counsel of Record for Plaintiff RAH Color Technologies LLC

Bottom line: RAH Color Technologies has been represented throughout this litigation by its long-time outside licensing/litigation counsel, Global IP Law Group, LLC of Chicago — the same three-attorney team that signed the original complaint. No in-house counsel appears on the docket (RAHCT is a one-man, inventor-owned LLC managed by Dr. Richard A. Holub from Alexandria, VA, so it has no legal department).

⚠️ Caveat up front: I was able to verify counsel from the face of the complaint (Dkt. 1, captured in full text via a PTAB exhibit and RPX's document repository) and from third-party docket aggregators (Justia, Docket Alarm/Plainsite). I could not directly open the N.D. Ill. CM/ECF docket sheet in this session, so the post-complaint appearance list (withdrawal/substitution entries) is verified only indirectly. Where noted below, treat the "role" designations as reflective of the record in the related RAHCT cases rather than a certified reading of this docket.

---

Plaintiff's counsel — Global IP Law Group, LLC (Chicago, IL)

All three signed the complaint: "By: /s/ Irwin Park — David Berten (dberten@giplg.com), Alison Aubry Richards (arichards@giplg.com), Irwin Park (ipark@giplg.com), Global IP Law Group, LLC, 55 W. Monroe St., Ste. 3400, Chicago, Illinois 60603, Phone: 312.241.1500 — Attorneys for Plaintiff, RAH Color Technologies LLC." (Compl., Dkt. 1 at 72; Apr. 18, 2017.)

Note on firm continuity: Global IP Law Group was RAHCT's counsel well before suit — the complaint itself pleads that "counsel for RAH Color Technologies (Global IP Law Group, LLC)" sent the October 3, 2014 six-page license letter to Fujifilm's VP/GC Judy Melillo and the June 16, 2015 claim charts to Fujifilm Chief IP Counsel Frank Gallucci (Dkt. 1 ¶¶ 32–33). The same firm's address (55 W. Monroe, Suite 3400) is the one used on RAHCT's N.D. Cal. MDL filings.

No local counsel of record separate from Global IP Law Group is identified — Global IP Law Group is itself Chicago-based, so it served as both local and lead counsel in N.D. Ill. before Judge John J. Tharp. That is consistent with RAHCT's stated cost-conscious litigation posture (Joint Preliminary Status Report in M18-md-02874: RAHCT "seeks to keep the costs of litigation proportional to the needs of the case").

---

Do not confuse these with plaintiff's counsel

Two well-known patent litigators surface in searches tied to this case number and are defense-side (Fujifilm), not plaintiff-side:

• James J. DeCarlo — Shareholder, Greenberg Traurig LLP (New York, NY; also Florham Park, NJ). His firm bio lists RAH Color Technologies LLC v. Fujifilm North America Corp., 1:17-cv-02924 (N.D. Ill.) among representative matters, but his filings in the related Fujifilm matters are expressly "Attorneys for Fujifilm North America Corporation and Fujifilm Corporation." Registered patent attorney and EE.
• James J. Lukas, Jr. — Co-Chair, Chicago IP & Technology Practice, Greenberg Traurig LLP (77 W. Wacker Dr., Suite 3100, Chicago). Listed on the Justia docket page for this case and appears on Fujifilm-side filings; extensive patent trial and PTAB/IPR experience.

Also appearing for Fujifilm in the N.D. Ill. matter: Jones Day — Marc S. Blackman (Chicago), Keith B. Davis (Dallas), John R. O'Donnell (Los Angeles) — per the Fujifilm Corp. v. PTAB/related filings naming them "Attorneys for Defendant Fujifilm Corporation."

---

Gaps / things I could not confirm

1. Whether the appearance list changed after 2017. I could not retrieve the full PACER docket to confirm no substitution of counsel, withdrawal, or addition of local counsel occurred before the case concluded (the Justia docket's "Represented By" field was truncated in search results and showed both Park and Lukas without party attribution). If you need certified appearances, pull the docket report with the "Attorneys" filter from CM/ECF for 1:17-cv-02924.
2. Whether Perkins Coie appeared in this case. Perkins Coie (James F. Valentine, Christopher G. Hanewicz, Andrew N. Klein, Wing H. Liang) was lead counsel for RAHCT in the Adobe case and the N.D. Cal. MDL, but I found no evidence of a Perkins Coie appearance in the Fujifilm N.D. Ill. case. Do not assume it carried over.
3. No sealed filings identified affecting counsel identity; the complaint is publicly available (attached as Exhibit 2224 in IPR2019-00628, Adobe Inc. v. RAH Color Technologies LLC).
4. The case metadata lists only the '546 patent; the complaint actually asserted eight patents — the '870, '251, '897, '008, '444, '704, '546, and '314 — so the existing case summary is underinclusive on the patents-in-suit (relevant if you're mapping counsel to specific asserted claims).

I'll research the counsel of record for Fujifilm Holdings Corp. in this N.D. Ill. case.

Bottom line

I was unable to verify a full defense-side appearance list for this case from accessible sources — and that may be because there were very few appearances. Before anything else, note a critical case-status fact that shapes the answer:

The case appears to have been dismissed within ~5 months of filing. In a brief filed in the parallel N.D. Ill. RAH case against Adobe, RAH's own footnote string-cite lists this case as resolved: "Fujifilm Holdings (17 C 2924, R. 17, 9/19/17 Order Grant[ing]…)" — i.e., Docket No. 17, an order dated Sept. 19, 2017, listed alongside other RAH dismissals (R.R. Donnelley, Agfa Gevaert) in a string cite of terminated cases. (CourtListener, gov.uscourts.ilnd.341768, Dkt. 70) The snippet is truncated, so I cannot confirm whether the order was a stipulated dismissal, a dismissal for want of prosecution, or something else — verify on PACER. No Fujifilm answer, motion to dismiss, or IPR petition on the '546 patent surfaced in my searches.

What I could verify

Counsel — status of each lead

1. Irwin Park — DO NOT attribute to Fujifilm.
Justia's docket page carries a "Represented By" field listing "Irwin Park" and (truncated) "James J. Lukas, Jr." Park is plaintiff-side counsel: he is of record for RAH Color Technologies at Global IP Law Group, LLC, 55 W. Monroe St., Suite 3400, Chicago (ipark@giplg.com, 312-241-1500), and appears as RAH's counsel in the parallel RAH Color Techs. v. Adobe matter. (Adobe case docket extract, IPR2019-00628 Ex. 2024-65) Justia often collapses the "represented by" block; treat Park as RAH's counsel, not Fujifilm's. Relevant experience: Global IP Law Group is a Chicago IP boutique that has served as RAH's portfolio/enforcement counsel for roughly nine years per RAH's own filings.

2. James J. Lukas, Jr. — unresolved.
He appears in the same Justia "Represented By" block, which is why I flag him, but I could not confirm his firm, his party affiliation, or whether he ever entered an appearance here. I will not guess at his firm. This is the single item worth pulling from the actual PACER docket sheet first.

3. Jones Day (Marc S. Blackman, Keith B. Davis, John R. O'Donnell) — confirmed Fujifilm patent counsel, but NOT confirmed in this case.
A PTAB filing in another matter bears the caption block "ATTORNEYS FOR DEFENDANT FUJIFILM CORPORATION," signed by:

• Marc S. Blackman (Illinois Bar 6236719; Reg. No. 43,501) — Jones Day, 110 N. Wacker Dr., Suite 4800, Chicago, IL 60606 (msblackman@jonesday.com)
• Keith B. Davis (Texas Bar 24037895) — Jones Day, 2727 N. Harwood St., Suite 500, Dallas, TX 75201
• John R. O'Donnell (Cal. Bar 318054) — Jones Day, 555 S. Flower St., 50th Fl., Los Angeles, CA 90071

(PTACTS petition document) The same team (Blackman + T. Vann Pearce) represents FUJIFILM Corporation and FUJIFILM North America Corporation in Optimum Imaging Techs. LLC v. Fujifilm, No. 4:23-cv-00922 (E.D. Tex.), and in IPR2024-01373 on U.S. Patent 7,612,805 — see the Aug. 29, 2024 stipulation letter on Jones Day Chicago letterhead. (Docket Alarm, IPR2024-01373 Ex. 1028)

That establishes Jones Day as Fujifilm's go-to U.S. patent litigation firm in this era, but the documents I found are from the E.D. Tex. cases and the 2024 IPR, not from 1:17-cv-02924. I found no Jones Day appearance, motion, or signature in the 2017 N.D. Ill. Fujifilm docket. Treat as a strong candidate/known relationship, not a confirmed appearance.

4. In-house counsel — none identified; no appearance or signature found.

What is missing / caveats

• I could not retrieve the actual docket sheet text (PACER/CourtListener RECAP) for appearances. CourtListener's RECAP ID for this case should be near gov.uscourts.ilnd.338964 (Justia's internal ID is 338964); a direct docket pull would settle items 1–3 in one step.
• I found no indication of sealed filings on the defense side, and no Rule 83.15/LCvR 83.15 pro hac vice motions surfaced.
• Because the case was likely dismissed by stipulation in September 2017 — before the initial-status/answer deadline cycle — it is plausible that no defense appearance beyond a notice of appearance (or none at all, if RAH voluntarily dismissed under Rule 41(a)(1)) was ever filed. In that scenario, the honest answer is that there may be no substantive "counsel of record" for Fujifilm to report.

Recommended verification steps (in order)

1. PACER docket for 1:17-cv-02924 — check entries 5–20 for appearances, the Rule 41 dismissal, and Dkt. 17's text.
2. If appearances exist, pull the appearance forms for firm/address/bar numbers rather than relying on Justia's aggregated party block.
3. Cross-check whether Fujifilm North America was separately represented (common in multi-entity Fujifilm suits, where Jones Day covers the Japanese parent and local/regional counsel covers the U.S. subsidiaries).