Obviousness

An analysis of the claims of US patent 5,768,384 in light of the cited prior art indicates that the patent's claims would likely be rendered obvious under 35 U.S.C. § 103. The core invention—applying a secure, network-connected metering device to general manufacturing for anti-counterfeiting and tracking—represents a combination of existing technologies that a person having ordinary skill in the art (PHOSITA) would have been motivated to assemble.

The primary argument for obviousness rests on combining the teachings of secure metering systems, such as those for postage (US 5,666,421A) or identification cards (US 5,384,846A), with the known problem of product counterfeiting (addressed in US 5,592,561A) and methods for document verification (US 5,426,700A).

Combination of References Rendering Claims Obvious

A combination of US 5,666,421A (hereafter '421) or US 5,384,846A (hereafter '846) as the primary reference, modified by the teachings of US 5,592,561A (hereafter '561) and US 5,426,700A (hereafter '700), would render the independent claims (1 and 19) and their dependent claims obvious.

1. The Base System: Secure Metering and Authentication

The Pitney Bowes patents, '421 and '846, disclose the fundamental architecture of the system claimed in US 5,768,384.

• US '421 teaches a secure postage meter that generates unique, encrypted information for each mailpiece. This meter is a direct analogue to the "manufacturing meter" in claim 1. It communicates with a remote data center for verification and to maintain forensic integrity (addressing claims 2 and 4). The meter contains ascending and descending registers to account for postage value, which is functionally identical to the registers for counting authorized articles in claim 3. The encrypted data includes a date, anticipating the time stamp of claim 5.
• US '846 teaches a similar system with a secure "authenticator" device that controls a printer to produce ID cards. It also uses a data center for authorization and tracks the number of cards produced with ascending/descending registers (claims 2, 3, 4). Critically, it generates an encrypted number based on personal data, establishing the principle of linking the encrypted data to a specific individual, a key step toward including operator information as claimed.

These patents establish the use of a secure, remote, network-controlled device for generating and affixing unique, encrypted identifiers onto items for authentication and accounting purposes. The primary difference is the application: mailpieces and ID cards, not general "articles of manufacture."

2. Motivation to Combine and Modify

A person of ordinary skill in the art in 1996, aware of the secure metering technology in '421 and '846, would have been motivated to apply it to solve the well-known and widespread problem of product counterfeiting and supply chain diversion.

• Applying the System to General Manufacturing: The '561 patent explicitly addresses the need for an anti-counterfeiting system for general products. It describes generating a unique, encrypted number for each product and storing it in a central database for later verification. A PHOSITA, tasked with building the system described in '561, would seek a secure and robust method for generating these encrypted numbers at the point of manufacture. The secure, tamper-resistant metering hardware from '421 and '846, already proven in high-security applications like postage and identification, would be an obvious and logical choice to implement the concept of '561. This combination provides a clear motivation to adapt the postage/ID meter for use as a "manufacturing meter."

• Including Operator Information: Claim 1 specifies that the encrypted data is associated with both the article and the "operator of the equipment." The '846 patent already teaches associating the encrypted data with a person (the cardholder). In adapting this system to a manufacturing context, including identifiers for the operator, the specific machine used (claim 7), or other production data would be an obvious extension for purposes of quality control, accountability, and enhanced tracking. This is not an inventive leap but rather a logical application of the system's capabilities to the new environment. Therefore, adding operator information (claims 1, 8, 16, 17, 18) would have been an obvious design choice.

• Implementing the Verification Step: Claim 1 concludes with a means for authentication "by comparing the encrypted information printed on the article with the information produced by said producing means" (e.g., an invoice or shipping manifest). Method claim 19 describes a similar comparison. The '700 patent directly teaches this verification concept. It describes authenticating a document by comparing an encrypted number on the document with a newly generated encrypted number derived from the document's content. A PHOSITA would have been motivated to incorporate this verification method into the system to create a closed-loop authentication process. It would be obvious to use the method from '700 to verify that the manufactured article (identified by the meter's code from '421/'846) correctly corresponds to an associated document, such as a shipping manifest (claim 11) or other form (claim 12), thereby confirming its authenticity and place in the supply chain.

Conclusion on Obviousness

The independent claims of US 5,768,384 are obvious over a combination of the prior art. The system described is essentially the secure metering and data center architecture from US '421 or US '846, applied to the general anti-counterfeiting purpose taught by US '561, and utilizing the verification-by-comparison method taught by US '700. A person of ordinary skill in the art would have found it obvious to combine these elements to arrive at the claimed invention, as it represents applying a known technological solution (secure metering) to a known problem (product counterfeiting) using a known verification technique. The dependent claims merely add further details (e.g., type of information to be encrypted, use of invisible ink) that are either taught by the references or would have been obvious design choices.