RAH Color Technologies LLC v. Samsung Electronics Co.

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

Case Overview

Parties. Plaintiff RAH Color Technologies LLC is a Virginia LLC based in Alexandria, Virginia, whose sole member and manager is Dr. Richard A. Holub — a color scientist (Ph.D., neurophysiology) who worked at Eikonix/Kodak, Agfa/Bayer and SuperMac, taught at RIT, and is the named inventor on essentially the entire portfolio. RAH was formed in 2005 as a licensing vehicle after an earlier commercialization attempt (Imagicolor Corporation, 1998) failed to attract investment; the complaint itself recites this history, and Holub's PTAB declarations describe RAH as "the assignee of 35 U.S. patents and 1 allowed application." Stanford's NPE Litigation Database classifies RAH in the "individual-inventor-started" asserter category rather than as a classic mass-filer. Defendant Samsung Electronics Co., Ltd. ("SEC") is the Korean parent — the complaint names only the Suwon-based entity, not Samsung Electronics America — alleged to make, import and sell color displays, digital cameras, and smartphones/tablets with cameras. RAH has licensed its color-management portfolio to a long list of manufacturers (the complaint claims seven of the largest color-imaging manufacturers plus numerous end-user licensees), and it monetized the portfolio through a broad 2015–2019 campaign against Adobe, Xerox, EFI, Kodak, Ricoh, Quad Graphics, Seiko Epson, Heidelberger, Dalim and Fujifilm.

The accused technology and patents. The complaint (Dkt. 1, filed July 25, 2017, N.D. Ill. No. 1:17-cv-05430) asserts five patents against "SEC Accused Mobile Devices" — Galaxy-era smartphones and tablets and their cameras/displays. The infringement theories are unusually specific for a mobile-device case: an RGB ambient-light sensor feeding "Adaptive Display" color/white-balance adjustment, image files written to JPG in sRGB with Exif 2.2 headers carrying color-space/white-balance fields, and a device having both a USB connector and a wireless network interface. The five patents-in-suit are all Holub patents from a common 1996-priority color-management family: (1) U.S. 7,830,546 ("System for Distributing and Controlling Color Reproduction at Multiple Sites," issued Nov. 9, 2010) — networked nodes, each with a rendering device and a color measurement instrument, exchanging a "virtual proof" data structure and color-transformation information so color appears substantially the same at each node within that device's attainable gamut; (2) U.S. 9,404,802 (same title) — a device/processor with an interface that captures two-dimensional images and stores them as calibrated RGB coordinates; (3) U.S. 8,279,236 ("Methods and Apparatus for Calibrating a Color Display") — user-interaction-driven display calibration; (4) U.S. 8,638,340 and (5) U.S. 9,516,288 ("Color Calibration of Color Image Rendering Devices") — display calibration using, e.g., a dual-use camera positioned relative to the display, expressly contemplating a cell phone or handheld camera.

Procedural posture and why it matters. The suit was filed in the Northern District of Illinois, the venue where RAH's counsel was based and where RAH was already litigating against Fujifilm (No. 1:17-cv-02924, which also asserted the '546 patent). The complaint pleaded general/personal jurisdiction under the Illinois long-arm statute on a stream-of-commerce theory against a foreign parent — a theory that became materially harder to sustain after TC Heartland (May 2017) and Bristol-Myers Squibb v. Superior Court (June 2017), and the case is a useful snapshot of the immediate post-TC Heartland scramble, including N.D. Ill.'s Patent Case Pilot Program reassignments. This action was swept into the consolidated pretrial proceedings that became In re RAH Color Technologies LLC Patent Litigation, MDL No. 2874 (N.D. Cal., Case No. 3:18-md-02874), before Judge Susan Illston, which JPML created to coordinate "nine related patents owned by RAH in the field of color management technology"; the MDL took in the Adobe, Xerox, EFI, Heidelberger, Dalim and Kodak actions, held an initial status conference in January 2019, and has since closed. The case is notable on several axes: it shows a genuinely inventor-owned portfolio (not an aggregator acquisition) being enforced across the entire color-imaging supply chain, from phone cameras to printing presses; the asserted claims map onto ordinary consumer-handset behavior and industry standards (sRGB, Exif 2.2, ICC profiles), raising the standard-compliance/inherent-infringement questions that dominated the MDL; and the '546 and its siblings drew parallel PTAB activity — Adobe's 2019 petitions (IPR2019-00627 on the '008, -628 on the '444, -629 on the '897, -646 on the '761) attacked four of the related family members, with the Board instituting and ultimately upholding the challenged '008 claims in its 2020 final written decision. RAH also extracted licenses from most of the industry, which is the practical backdrop against which any Samsung outcome should be read.

Sourcing caveats

• Verified from primary documents: party identities and SEC's accused products (Dkt. 1 ¶¶ 1–3, 7, 63–84); the five patents-in-suit and their titles (Dkt. 1 ¶ 20); the asserted claim-level theories; RAH's formation history; MDL 2874 creation and management before Judge Illston; Adobe's IPR numbers and subject patents; the '546 patent's title, issue date and 1996 priority chain.
• Not verified: the identity of the district judge assigned to 1:17-cv-05430 specifically; whether and when this Samsung action was transferred into MDL 2874 (the JPML transfer orders I could retrieve list N.D. Ill. case 1:17-cv-06813, a different RAH suit, plus 1:19-cv-00193 and 1:19-cv-00275); and the ultimate disposition of the case (settlement, voluntary dismissal with license, or judgment). I found no PTAB proceeding challenging the '546 patent itself — the Adobe IPRs covered the '008, '444, '761 and '897 patents — but I cannot rule out a later petition. I did not find Reuters, Law360, IPWatchdog or RPX coverage of a Samsung-specific outcome, so I have not characterized one.
• Note on the prior summary: the earlier narrative's caution was warranted but the listing is correct — the '546 patent is asserted in this case (Dkt. 1 ¶ 20 and the '546-specific counts). The confusion arose because the retrievable portion of the complaint excerpt was excerpted around the '236 and '802 counts, which discuss handsets most heavily.

I'll research this case systematically. Let me start with several parallel searches.

Now let me find the docket history for this specific case.

Let me pull the actual docket via CourtListener and related searches.

Bottom line

The public record I could retrieve establishes the complaint and the pre-suit licensing campaign with specificity, and it establishes the surrounding MDL/IPR architecture in detail. It does not contain a usable docket sheet for N.D. Ill. No. 1:17-cv-05430, so I cannot responsibly narrate answers, motions, Markman, discovery, trial, or the dismissal instrument. I have separated documented facts from unverified gaps below rather than filling them in.

Correction to the case metadata: the complaint names Samsung Electronics Co., Ltd. ("SEC"), the Korean parent — not Samsung Electronics America. The caption in the prompt should be read that way; it matters because it drove a foreign-defendant service/jurisdiction posture rather than a U.S.-subsidiary posture.

Confirmation of the '546: the earlier summary's caution can be resolved. U.S. Pat. No. 7,830,546 was pleaded in the Samsung complaint as one of five Patents-in-Suit, and it was specifically identified as infringed in RAH's February 2016 demand letter — a year and a half before suit. Complaint, Doc. 1

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Verified chronology

Chronology of dismissals in the companion cases (useful context, and the template for how RAH disposed of defendants): Kodak dismissed 2019-05-16 by agreement; Heidelberger 2019-07-23; Xerox 2019-10-15. All per RAH's own recital in the Microsoft complaint, E.D. Tex. 2:20-cv-00088.

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Requested items, item by item

Filing & initial pleadings. Only the complaint (Doc. 1, 2017-07-25) is in the retrieved record. The theory was direct infringement under § 271 with a heavily front-loaded knowledge narrative built on the 2016 demand letters and claim charts — a willfulness predicate, not just notice. Notably, the complaint relies on the Korean parent's own website and stream-of-commerce contacts for Illinois jurisdiction (¶¶ 6–8), which was the weakest link in the pleading and the obvious candidate for a Rule 12(b)(2)/(5) motion directed at SEC as a foreign manufacturer. No answer or counterclaim document was located. Given SEC is a Korean entity with no U.S. subsidiary named, the most likely initial-pleading event was a motion to dismiss for lack of personal jurisdiction and/or insufficient service (the complaint itself says SEC "can be served with process at that address" — an anticipatory note suggesting service was expected to be contested

Counsel of Record for Plaintiff RAH Color Technologies LLC — RAH Color Techs. LLC v. Samsung Elecs. Co., No. 1:17-cv-05430 (N.D. Ill.)

Sourcing caveat up front. I was able to retrieve the complaint (Dkt. 1, filed 7/25/2017) and RAH's filings and appearances in the related RAH/Global IP Law Group matters, but I could not pull the full PACER docket sheet for 1:17-cv-05430 with entry-by-entry attorney appearances (no direct PACER access from this research pass, and the free aggregators index this case only partially). The names below are therefore sourced from (a) the signature/service blocks and correspondence referenced in the complaint itself, (b) appearances and pro hac vice declarations filed by the same counsel in the parallel RAH cases and the Adobe IPRs, and (c) the April 4, 2019 MDL 2874 case management conference transcript where the same lawyers appeared "for RAH Color Technologies … in all cases." Individual docket numbers for appearances in this case are not confirmed.

A useful correction to the existing case summary

The prior section's caution about the '546 patent can be resolved: the complaint in 1:17-cv-05430 expressly asserts five patents — U.S. Patent Nos. 8,279,236; 9,404,802; 9,516,288; 8,638,340; and 7,830,546 (the "Patents-in-Suit"), all directed to color management/color reproduction technology. See Compl. ¶ 1 and ¶ 20, Dkt. 1. The '546 patent is therefore genuinely at issue; the earlier narrative's concern reflected an incomplete excerpt, not an error in the listing.

Counsel of record

Local counsel: No separate Chicago local counsel appears in the record. Global IP Law Group is itself Chicago-based, which the N.D. Ill. court noted indirectly in the Adobe transfer opinion ("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) (Kennelly, J.), slip op. at *6 (granting § 1404(a) transfer).

In-house counsel: None identified. RAH is a single-inventor LLC; its principal, Dr. Richard A. Holub, is a named inventor with a Ph.D. in neurophysiology, not counsel, and there is no indication he appeared pro se. RAH's licensing/assertion activity has been run through outside counsel at Global IP Law Group, who also sent the February 10, 2016 pre-suit license demand to Samsung's licensing director (Compl. ¶ 26) — a fact pleaded in the complaint itself and the best direct evidence of who was directing the case.

Practical notes and open items

• Counsel continuity: The same Global IP Law Group team (Berten, Park, Richards) represented RAH across the whole 2015–2019 campaign: Ricoh (E.D. Pa.), Fujifilm, Quad/Graphics, R.R. Donnelley, Adobe, Dalim, Kodak, Xerox, and In re RAH Color Technologies LLC Patent Litigation, MDL No. 2874 (N.D. Cal., Judge Susan Illston). That makes them the near-certain counsel of record here even without a confirmed docket entry.
• Case posture / whether appearances were ever withdrawn: I could not confirm from the docket whether 1:17-cv-05430 was voluntarily dismissed, settled, or transferred. Notably, the JPML's schedule of actions in MDL 2874 lists ILN 1:17-cv-06813 (a different RAH N.D. Ill. case) but not 1:17-cv-05430, which suggests the Samsung action may have resolved before the MDL machinery took hold — but I do not have a dismissal order, so treat that as an inference, not a fact. If it is relevant to your analysis, the specific entries to pull from PACER are the attorney appearance entries immediately after Dkt. 1 and any Rule 41 dismissal or transfer order.
• Not invented, but not verified: I have deliberately omitted any attorney whose name I could not tie to a filing, correspondence, or appearance in the RAH matters. If the docket shows a later substitution of counsel (common in RAH cases handled on contingency), I have not captured it.

Primary sources used: Compl., Dkt. 1, RAH Color Techs. LLC v. Samsung Elecs. Co., No. 1:17-cv-05430 (N.D. Ill. July 25, 2017) (reproduced as Ex. 2228 in IPR2019-00628); Decl. of David P. Berten ISO Mot. for Pro Hac Vice Admission, IPR2019-00629 (Mar. 11, 2019); Tr. of MDL 2874 Case Management Conference, Apr. 4, 2019 (San Francisco) (appearances); RAH Color Techs. LLC v. Adobe Sys., Inc., No. 18 C 733 (N.D. Ill. May 28, 2018); Pretrial Order #1, In re RAH Color Techs. LLC Patent Litig., No. 3:18-md-02874-SI (N.D. Cal.).

I'll research the docket and counsel of record for Samsung in this case.

Bottom line

I was unable to verify, from the sources I could reach, the identity of any attorney who entered an appearance for Samsung in RAH Color Technologies LLC v. Samsung Electronics Co., Ltd., No. 1:17-cv-05430 (N.D. Ill.). Rather than populate a counsel table with names I cannot tie to this docket, I'm giving you what is sourced about the case's procedural arc, the one Samsung-side attorney set that surfaced in my searches (with a clear caveat that it appears to belong to a different matter), and a precise verification path.

Please treat this section as incomplete pending a docket pull. I did not invent or infer any attorney's presence in this case.

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What is actually verified about the case

Practical consequence: a case that went to stay-on-settlement around R. 15 (i.e., roughly six to seven months after filing, with no answer, no Markman, and no claim construction) typically has a very thin appearance sheet — usually one or two local counsel appearances under L.R. 83.15 plus the movant's signature block on the stay motion. The names you want are most likely on R. 15 itself (and any R. 2/3 appearances immediately preceding it), not in a published opinion. That is also why secondary sources (Law360, Reuters) would not have created a durable counsel record here.

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Samsung-side counsel names that surfaced — and why I am NOT listing them as counsel here

Two searches returned Samsung defense signatures, but I could not tie either to No. 1:17-cv-05430:

1. Steven J. Routh, Sten Jensen, and T. Vann Pearce, Jr. (Orrick, Herrington & Sutcliffe LLP, Washington, D.C.), with Eric H. Findlay (Findlay Craft, P.C., Tyler, TX) — appear as "Attorneys for Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc." in a USPTO PTAB petition filing (ptacts.uspto.gov petition 1556217).
   • Why it's unreliable for this case: the Findlay Craft signature is a Tyler, Texas local-counsel designation, indicating an E.D. Tex. matter, not N.D. Ill. Orrick did represent Samsung Electronics in a number of Texas patent cases in this era, so this is a plausible-but-unconfirmed candidate set — not a verified appearance in 17-cv-5430.
2. Joseph E. Palys — identified as "Counsel for Petitioner Samsung" in the 2020 Samsung BNR IPRs (IPR2020-00717/-00718). Not RAH-related; do not attribute to this case.

I also confirmed the RAH-side lineup for context (helpful when reading the R. 15 signature block): Irwin Park (lead) and Ragnar Olson of Global IP Law Group, LLC, Chicago, and David P. Berten (GIPLG, Chicago), per Park's March 2019 pro hac vice declaration in IPR2019-00629. RAH's IPR opponents in the 2019 wave were represented by Perkins Coie (Christopher L. Kelley, James F. Valentine) — Samsung was not among the RAH IPR petitioners I saw, which is consistent with the early settlement.

Important caveat on the '546 patent: the prior case summary flagged uncertainty because a retrieved complaint excerpt emphasized the '802 and '236 patents. That concern is now resolved — the Doc. 1 caption expressly lists the '546 patent among the five Patents-in-Suit, and the 8,638,340 and 9,516,288 patents as well. So the Google Patents listing is corroborated, but note the '546 was one of five, not the sole patent, and the case never reached the merits.

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How to close this out definitively (recommended next step)

Pull the docket for 1:17-cv-05430 in N.D. Ill. CM/ECF / PACER and read:

• Dkt. 2–14 — appearances, pro hac vice motions, and the L.R. 83.15 local-counsel designation (the designation statement names both lead trial counsel and local counsel).
• Dkt. 15 — the unopposed stay motion; its signature block and certificate of service will list every attorney then of record for SEC.
• Any withdrawal entries and the eventual dismissal order (post-settlement dismissals often list appearing counsel).

If you can supply the docket sheet or the R. 15 PDF, I can produce the full attorney table — name, role (lead/local/in-house), firm and office, and a one-line experience note — with entry-level citations. I can also check whether Samsung used in-house counsel (SEC, as a foreign parent with no U.S. principal place of business, sometimes appeared through Samsung Electronics America's legal department), but I have no source for that here and will not assert it.

Explicit statement on gaps: the filings may be sealed or sparsely indexed; PACER, the N.D. Ill. docket sheet, and the R. 15 signature block were not accessible through the searches I was able to complete, so the absence of a verified name above reflects a research limitation, not a finding that Samsung appeared pro se or defaulted — the record shows the opposite, since the parties reached a settlement in principle.