Invalidity dossier
US 6157436
Image printing
Current assignee: Xerox Corporation
Added 9/29/2026, 2:11:21 PM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for authoritative information on this patent.
Let me check the litigation dockets and assignment history for this specific patent.
US Patent 6,157,436 — Summary
Sources used: Google Patents full-text record (https://patents.google.com/patent/[US6157436A](/patent/US6157436A)/en), W.D.N.Y. docket 6:20‑cv‑06263 (Xerox Corp. v. Monument Peak Ventures, LLC), and Unified Patents / Darts‑IP litigation data reported on the Google Patents page.
Bibliographic data
| Field | Value |
|---|---|
| Patent number | US 6,157,436 A |
| Title | "Image printing" |
| Inventor | Ronald S. Cok |
| Original assignee | Eastman Kodak Company |
| Current assignee (per Google Patents) | Monument Peak Ventures, LLC |
| Application no. | US 09/143,842 |
| Filing date | 1998‑08‑31 |
| Priority date | 1998‑08‑31 |
| Issue/publication date | 2000‑12‑05 |
| Claims | 31 (5 independent) |
| Status | Expired – Lifetime; anticipated expiration 2018‑08‑31 |
| Classification | G03D 15/001 (counting, classifying, marking); G03D 15/005 (order systems, e.g. print sorter) |
| Family | EP0984326B1, DE69918501T2, JP4558860B2, AU754128B2 |
Assignment chain (per the Google Patents reassignment records): Eastman Kodak → Intellectual Ventures Fund 83 LLC (2013‑04‑17) → Monument Peak Ventures, LLC (2017‑03‑09). Note that a December 2000 issue date on a 1998 filing means the patent term ran out on 2018‑08‑31 (20 years from filing), consistent with the "Expired – Lifetime" status.
Abstract (verbatim)
"An image printing system for generating multiple printed image copies in response to an order. A processor can divide the order into multiple sub-orders for respective image printers, each sub-order having a sub-order header which includes a unique order identification and an indication of the number of copies of the image to be printed by the corresponding printer. A plurality of image printers are connected to the processor, to each receive a corresponding sub-order and print the corresponding sub-order header, and the numbers of image copies indicated in that header. A method which can be executed by such a system and a computer program product which can execute the method on a programmable computer, are also provided."
Plain-language overview of the independent claims
Claim 1 — System (image printing system).
A processor splits a single customer order into several "sub-orders," one per printer. Each sub-order carries a header containing (i) a unique order ID, (ii) an image characteristic identification — i.e., something identifying a characteristic of the image to be printed by that printer (the spec's preferred form is a reduced-resolution "thumbnail" of the image), and (iii) how many copies of the image that printer should print. Several printers are connected to the processor; each receives its sub-order, prints the header, and prints the indicated number of copies. Notably, the image-characteristic identification is a required element of claim 1, which is a limitation the related claim 31 does not contain.
Claim 14 — Photofinishing laboratory.
A "photofinishing laboratory" apparatus claim covering the whole lab: a chemical developer that develops latent film images; a scanner producing image signals; memory storing those signals; an order receiver taking an order for multiple prints; plus the claim‑1 image printing system (processor dividing orders into sub-orders with headers, and multiple printers printing headers and copies).
Claim 16 — Method.
The method counterpart to claim 1: divide the order into sub-orders for respective printers, each sub-order having a header with a unique order ID, an image characteristic identification of an image of the sub-order to be printed by the corresponding printer, and a copy-count indication; then at each of several printers, print the corresponding sub-order header and the indicated number of image copies.
Claim 25 — Computer program product.
A computer-readable storage medium storing a program for a programmable processor that talks to an order-input source and multiple printers. The program (a) divides a received order into sub-orders for respective printers, generating a sub-order header having a unique order ID and a copy-count indication, and (b) forwards the generated headers to the respective printers. Caution: as printed, claim 25 recites only the unique order identification and the copy-count indication — it does not recite the "image characteristic identification" that claims 1, 14, and 16 require. That asymmetry is worth flagging for any claim-charting or validity analysis.
Claim 31 — System (alternative independent form).
Substantively similar to claim 1 but, instead of the image-characteristic identification, it requires that the processor provide a sub-order header for each corresponding printer that additionally identifies each other printer to which sub-orders of the order are sent (i.e., a cross-printer routing listing on every header).
Dependent-claim themes (for context, not claimed as independent)
- Cross‑printer awareness: identification of other printers / their print characteristics (claims 2, 3, 7, 8, 17, 18, 19, 26, 27, 28).
- Print status monitoring: a monitor determines sub-order print status (including estimated completion time) and forwards it to other printers, which print it — particularly printers that have not yet printed their own header (claims 4, 5, 6, 12, 23, 24, 29, 30).
- Reduced-resolution ("thumbnail") identification of the image (claims 9, 20).
- Sub-order containing the actual image signal, and/or an index of sub-orders forwarded to a printer (claims 10, 11, 21, 22).
- Sequential printing or a common printed identification for the sub-order's images (claim 13).
- Order receiver as a code reader reading machine-readable film codes (claim 15).
Litigation and CAFC status — important caveats
No CAFC appeal involving US 6,157,436 was found. I searched Federal Circuit 2026 dockets and could not locate any 2026 (or other) CAFC docket in which 6,157,436 is a patent-in-suit or a decision subject. I am explicitly noting this as a negative finding rather than asserting the patent has never been on appeal — I do not have authoritative confirmation either way.
W.D.N.Y. 6:20‑cv‑06263, Xerox Corp. v. Monument Peak Ventures, LLC — a declaratory-judgment action filed 2020‑04‑23 by Xerox. US Patent No. 6,157,436 appears as Exhibit #2 to Xerox's complaint (docket entry 1). The case was closed 2021‑08‑31 when the court granted MPV's motion to dismiss for lack of personal jurisdiction (the court's decision discusses Trimble v. PerDiemCo and the "ordinary cease-and-desist" line of authority). So this patent was cited as a DJ subject patent, but was not adjudicated on infringement or validity in that case.
E.D. Tex. 4:21‑cv‑00683 — Google Patents lists a Texas Eastern District case involving this patent family (Unified Patents litigation data). I was unable to retrieve the docket details before reaching my search limit; treat the parties, patents asserted, and outcome as unverified.
Google Patents also flags "First worldwide family litigation filed" via the Darts‑IP family record (family ID 22505908), again without details I could verify.
Bottom line
US 6,157,436 is Ronald S. Cok's 1998 Eastman Kodak invention for photofinishing workflow control: a central processor splits a customer order across multiple image printers and gives each printer a printed "sub-order header" (order ID, thumbnail of the image, copy count, and often routing/status info for the other printers) so an operator can collate multi-printer orders without marking every individual print. It issued 2000‑12‑05, expired 2018‑08‑31, and — through Kodak's portfolio sales — is now held by Monument Peak Ventures, LLC. The only litigation I could authoritatively confirm is the 2020 W.D.N.Y. declaratory-judgment action in which the patent was an exhibit and which was dismissed on personal-jurisdiction grounds; I found no CAFC 2026 docket for this patent, and the E.D. Tex. 4:21‑cv‑00683 matter remains unverified.
Generated 9/29/2026, 2:24:03 PM
Cases on file (2)
Group view →Specific litigation cases in our database that name US patent 6157436. The free-form analysis below may also discuss cases beyond this list.
- Xerox Corporation v. Monument Peak Ventures, LLCfiled Apr 23, 20206:20-cv-06263U.S. District Court for the Western District of New Yorkterminated Aug 31, 2021transferred
Defendants: Monument Peak Ventures, LLC
Other patents asserted: 6873336, 5923908, 6215559, 6396599, 7006890, 7092966, 7684090
- 4:21-cv-00683U.S. District Court for the Eastern District of Texas, Sherman Divisionunverified
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll research litigation involving US patent 6157436. Let me start with several targeted searches.
Let me search for the specific case numbers identified on the patent page and check the Unified Patents litigation portal.
I found the W.D.N.Y. declaratory judgment case. Now let me look into the Texas case and search for any affirmative infringement suits asserting the '436 patent.
I hit my search-step limit while trying to pin down the second case, so here is what I was able to verify, with clear flags on what I could not confirm.
Litigation involving U.S. Patent No. 6,157,436 ("Image printing")
Note on numbering: the patent is US 6,157,436 B1, application 09/143,842, filed Aug. 31, 1998, granted Dec. 5, 2000, inventor Ronald S. Cok, original assignee Eastman Kodak Company, current assignee Monument Peak Ventures, LLC. It expired (anticipated) Aug. 31, 2018. Any infringement recovery would therefore be limited to pre-expiration conduct and the §286 six-year lookback — relevant context for the 2020–2021 filings below.
Google Patents' "Family has litigation" section (populated from Unified Patents litigation data) flags two U.S. cases:
1. Xerox Corporation v. Monument Peak Ventures, LLC
- Court / jurisdiction: U.S. District Court for the Western District of New York (Judge Frank P. Geraci, Jr.)
- Case No.: 6:20-cv-06263 (sometimes shown as 6:20-cv-06263-FPG)
- Filed: April 23, 2020
- Plaintiff: Xerox Corporation
- Defendant: Monument Peak Ventures, LLC (MPV) — characterized in the complaint as a non-practicing entity associated with Dominion Harbor Enterprises, LLC, which acquired the Kodak-origin patents via Intellectual Ventures in 2017
- Posture: This was not an MPV infringement suit; it was a declaratory judgment action by Xerox seeking declarations of non-infringement of eight MPV patents. The '436 patent was expressly among the "Patents-in-Suit" (Compl. ¶5), and Exhibit 1 to the complaint is the '436 patent (U.S. Patent No. 6,157,436). The other patents were 5,923,908; 6,215,559; 6,396,599; 6,873,336; 7,006,890; 7,092,966; and 7,684,090.
- Outcome / status: The court addressed personal jurisdiction (Decision and Order Aug. 18, 2020, and a further Decision and Order on reconsideration Aug. 31, 2021 following jurisdictional discovery and the Federal Circuit's Trimble, Inc. v. PerDiemCo LLC, 997 F.3d 1147 (Fed. Cir. 2021)). The court again found the contacts insufficient to confer specific personal jurisdiction over MPV. Secondary sources list the case as Closed (08/31/2021). (I could not verify from the sources retrieved whether the dismissal was with or without prejudice.)
- Sources: https://www.docketalarm.com/cases/New_York_Western_District_Court/6--20-cv-06263/Xerox_Corporation_v._Monument_Peak_Ventures_LLC/docs/1/2.pdf ; https://www.docketalarm.com/cases/New_York_Western_District_Court/6--20-cv-06263/Xerox_Corporation_v._Monument_Peak_Ventures_LLC/48/ ; https://ai-lab.exparte.com/case/dct/nywd/6:20-cv-06263/xerox-corp-v-monument-peak-ventures-llc ; https://www.law.com/radar/card/xerox-corporation-v-monument-peak-ventures-llc-33718859-0/
2. Eastern District of Texas case 4:21-cv-00683
- Court / jurisdiction: U.S. District Court for the Eastern District of Texas (the "4:" prefix corresponds to the Sherman Division)
- Case No.: 4:21-cv-00683
- Listing source: https://portal.unifiedpatents.com/litigation/Texas%20Eastern%20District%20Court/case/4%3A21-cv-00683 (cited on the patent's Google Patents page)
- Parties, filing date, and outcome: Not confirmed. I was unable to retrieve the docket sheet or a case card for this number before exhausting my search budget. I am not able to state the plaintiff, defendant, exact filing date, or disposition for this case without fabricating, so I am flagging it as unverified rather than guessing. Given the pattern above, it plausibly involves Monument Peak Ventures, but I have not verified that.
Other flags
- Google Patents also reports a first worldwide family litigation flag via Darts-IP (family ID 22505908): https://patents.darts-ip.com/?family=22505908 — the underlying foreign/parallel proceedings were not retrieved.
- I saw a reference to a PTAB proceeding IPR2022-00318 involving Xerox Corporation in a related MPV patent dispute, but I could not confirm that it concerns the '436 patent specifically; the '436 patent's Google Patents page does not list any IPR/reissue/reexam for it.
Summary
The two U.S. litigation matters tied to US 6,157,436 on the record sources are the W.D.N.Y. declaratory judgment action (Xerox v. Monument Peak Ventures, 6:20-cv-06263, filed 4/23/2020, dismissed/closed 8/31/2021 on personal-jurisdiction grounds) and an E.D. Tex. case, 4:21-cv-00683, whose party details and outcome remain unverified. No affirmative MPV infringement action asserting the '436 patent against a specific defendant was confirmed in the sources retrieved.
Caveat on the strict rule: all identifiers above (6,157,436 / 09/143,842 / 6:20-cv-06263 / 4:21-cv-00683) are reproduced literally as found; I have not auto-corrected any patent or case number, and where a number returned no confirming source I said so rather than supplying a substitute.
Generated 9/29/2026, 2:24:14 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
Current assignee: Xerox Corporation
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll verify the structured data against live sources before drafting.
Let me investigate the Monument Peak Ventures PTAB cases that could plausibly map to this patent.
Now let me run targeted checks for any PTAB filing that specifically names this patent.
Proceedings overview
One sentence: The USPTO Open Data Portal structured block reports zero AIA trial proceedings (IPR/PGR/CBM) on US 6,157,436 — 0 active, 0 with claims invalidated, 0 with claims sustained, 0 settled, 0 institution denials — meaning there is no PTAB record of any kind against this patent; the only outcome-bearing data points are district-court facts (a declaratory-judgment action that was dismissed without prejudice), not PTAB outcomes, so nothing about the patent's validity has ever been adjudicated at the Board.
Bottom line for a defendant: there is no invalidating FWD to lean on and no estoppel shield to claim, but there is also no litigation-tested validity. The patent is untested at the PTAB, not "hardened." Critically, the patent's term expired on 2018-08-31 (Google Patents "Anticipated expiration"), which means an IPR/PGR/CBM today is largely academic, and PGR and CBM are unavailable as of right (PGR window closed 9 months after 2000-12-05; CBM sunset for new petitions on 2020-09-16).
Verified: no proceedings exist on this patent
The canonical structured data ("PTAB proceedings on file") returns no AIA trial proceedings for US 6,157,436. I independently corroborated this with web research and found no IPR, PGR, or CBM naming U.S. Patent No. 6,157,436 or application 09/143,842. Because there are no proceedings, the per-proceeding template below is produced for the two near-miss proceedings that a defendant will inevitably encounter in searching "Monument Peak Ventures + Xerox + printer patents," so they can be ruled out rather than mistaken for '436 proceedings.
IPR2022-00318 — Xerox Corporation v. Monument Peak Ventures, LLC
- Type: Inter Partes Review
- Filed: 2021-12-15 (filing date accorded 2021-12-30). Note: this is NOT a proceeding on the '436 patent.
- Patent at issue: U.S. Patent No. 7,684,090 B2 ("Digital Printer for Use with Docked Display Device"), claims 1–3, 5, 7, and 10.
- Status: Terminated-Settled (termination due to settlement after institution, 35 U.S.C. § 317; filed by joint motion as business confidential information)
- Judge panel: Not confirmed in the sources retrieved
- Petition grounds: § 103 obviousness-type grounds (petition excerpt addresses motivation-to-combine / predictable-results arguments)
- Institution decision: Instituted 2022-06-09 (Institution Decision Grant)
- Final Written Decision: None — the trial terminated on settlement before any FWD
- Settlement / termination: Joint motion to file settlement agreement as business confidential information under § 317; termination decision 2022-07-11
- Appeal: None
- Defensive value: Irrelevant to '436 at the claim level. Its only relevance is strategic: Xerox, the same party that put '436 at issue in district court, chose a different patent to attack at the PTAB — and then settled before FWD, so it generated no estoppel and no invalidity holding.
IPR2021-00330 — Toshiba America Electronic Components, Inc. v. Monument Peak Ventures, LLC
- Type: Inter Partes Review
- Filed: 2020-12-21 (accorded filing date; petitioner moved, unsuccessfully, to correct it to 2020-12-16)
- Patent at issue: U.S. Patent No. 7,583,294 B2, claims 1, 5, 10, 11, and 19. Not '436.
- Status: Institution Denied (followed by POP review and rehearing denial — denial affirmed)
- Judge panel: Joni Y. Chang, Michael R. Zecher, Juliet Mitchell Dirba (Dirba dissenting on the filing-date issue); POP panel: Andrew Hirshfeld, Scott R. Boalick, Jacqueline Wright Bonilla
- Petition grounds: § 103-style IPR grounds on claims 1, 5, 10, 11, 19 (grounds not reached on the merits)
- Institution decision: Denied 2021-06-25 — the panel held the petition was time-barred under § 315(b) because the filing fee was not received until 2020-12-18, more than one year after service of the infringement complaint (2019-12-17). "The Petition is filed more than one year after service of the complaint. Accordingly, the Petition is time-barred under § 315(b)." (Paper 9, at 13.) A dissenting opinion (Dirba, APJ) would have excused the USPTO's internal delay in processing the wire transfer.
- POP review: Ordered 2021-09-24 on the issue "Does Fedwire confirmation of payment constitute sufficient evidence of payment under 35 U.S.C. § 312(a) and 37 C.F.R. § 42.103(a)?"; POP decision 2022-01-14 affirmed the denial (this became a precedential-adjacent ruling on § 312(a) fee-payment timing).
- Final Written Decision: None (never instituted)
- Settlement / termination: N/A — statutory denial, no settlement
- Appeal: No CAFC appeal of the PTAB denial identified. (Separately, CAFC No. 21-1052, Monument Peak Ventures, LLC v. Toshiba America Business Solutions, issued a Rule 36 affirmance of a district-court § 101 invalidity ruling on the '294 claims — a different patent and a different tribunal.)
- Defensive value: Confirms the MPV-Xerox/Toshiba printer-portfolio fight ran through other patents. It also hands a defendant a useful § 315(b)/§ 312(a) fee-timing precedent, but it says nothing about '436's claims.
Rule-out note: I also reviewed the publicly listed PTAB dockets involving Monument Peak Ventures, LLC (including IPR2019-00993, -01020, -01029 (General Electric) and IPR2019-01472 through -01476 (Robert Bosch)); none is directed to U.S. 6,157,436.
The district-court footprint on '436 (context, not PTAB)
'436's only identified litigation exposure is a declaratory-judgment action Xerox filed against Monument Peak Ventures, attaching '436 as an exhibit:
- Xerox Corp. v. Monument Peak Ventures, LLC, No. 6:20-cv-06263 (W.D.N.Y.), complaint for declaratory judgment filed 2020-04-23, listing eight patents as exhibits including U.S. Patent No. 6,157,436 (Exhibit 2).
- On 2021-08-31, Judge Frank P. Geraci, Jr. granted Xerox's motion to dismiss for lack of jurisdiction and transferred the action to the Eastern District of Texas.
- The transferred case (No. 4:21-cv-00683, E.D. Tex., Judge Sean D. Jordan) was voluntarily dismissed without prejudice on 2021-09-01/2021-09-02 under Fed. R. Civ. P. 41(a)(1)(A)(i).
- In the parallel MPV offensive case (No. 2:21-cv-00345, E.D. Tex., filed 2021-09-01), MPV asserted six different patents — 6,810,149; 6,873,336; 7,006,890; 7,092,573; 7,092,966; and 7,684,090 — and did not assert 6,157,436.
Sources: UniCourt docket, 4:21-cv-00683 | UniCourt docket, MPV v. Xerox 2:21-cv-00345 | IPR2022-00318 docket, Docket Alarm | IPR2021-00330 institution denial, USPTO | IPR2021-00330 POP grant order, USPTO
Strategic summary
Claim status: all 31 claims are UNTESTED at the PTAB. No claim of 6,157,436 has been canceled, confirmed, or even challenged in an instituted AIA trial. Claims 1–31 stand exactly as issued on 2000-12-05 (plus any district-court narrowing, of which I found none). Independent claim 1 (processor dividing an order into sub-orders, each with a sub-order header carrying a unique order ID, an image-characteristic identification, and a per-printer copy count; multiple printers printing the header plus the indicated copies) and the parallel independent claims (claim 14, the photofinishing-laboratory claim; claim 16, the method claim; claim 25, the computer-program-product claim; claim 31, the operator-index/system claim) are all live on paper but have never been stress-tested — the strongest and weakest "signal" here is the absence of data.
Estoppel landscape: effectively empty, in both directions. Because no IPR reached a Final Written Decision on this patent, no § 315(e)(2) estoppel attached to any party — not to Xerox, not to Toshiba, not to GE or Bosch. That cuts two ways for a defendant being asserted against today: (1) you are not barred by anyone else's prior art (estoppel is party-specific; a third party's IPR would never bind you anyway), and (2) you get no free ride on an existing invalidity record. The cost is that all § 102/§ 103 art is still open to you — including the art cited in the '436 file history (US 4,791,456 (Hope); US 4,970,554 (Rourke); US 5,459,819 (Watkins); US 5,559,933 (Boswell); US 5,761,558 (Patton); US 5,859,711 (Barry); EP 0 628 874) and the applications cited against the family (JP H04-289840, JP H04-314047, JP H09-265141, EP 0 793 142, EP 0 933 679). The only hard bar is § 315(b): anyone served with a complaint alleging infringement of '436 more than one year before filing a petition is time-barred — as IPR2021-00330 demonstrates was fatal to Toshiba on a sister patent.
Pattern signals. (i) No petitioner ever filed more than zero IPRs on this patent — the "multiple-IPR" pattern does not exist here. (ii) The patent owner (Monument Peak Ventures, formerly Eastman Kodak → Intellectual Ventures Fund 83) did not appeal any PTAB outcome on '436, because there was none; its litigation posture on '436 was purely defensive-of-the-assertion-set, and it never made '436 the centerpiece of a suit. (iii) No defensive aggregator (Unified Patents, RPX, etc.) appears anywhere in the '436 chain — the Google Patents "family has litigation" entries and the Darts-ip link point only to the Xerox DJ and the E.D. Tex. transfer, not to an aggregator challenge. (iv) The patent expired 2018-08-31 (anticipated expiration), and its E.D. Tex. assertion window closed with dismissals. The realistic current posture is a stale, expired, never-PTAB-tested patent, not a "hardened survivor."
Caveat, stated plainly: my search tooling prevented me from running a direct live PTAB E2E / PATS query on this docket within this task. I therefore rely on (a) the authoritative ODP structured block in the prompt, which reports no AIA proceedings, and (b) web corroboration that surfaced no '436 petition. If you need a belt-and-suspenders confirmation, run a party and patent-number search in PTAB E2E / PTAB Center for "6157436" and for "Image Printing" as a patent title before you finalize any invalidity opinion relying on the absence of proceedings.
Recommended next steps
- If you are a defendant: do not draft an argument that "claims 1–5 are canceled — the FWD kills this case." No FWD exists. There is no disposition to quote, and no link to a PTAB decision on '436 because none was ever issued. Any brief representing otherwise is sanction-exposed.
- Check the expiration clock first. '436 expired on 2018-08-31. Under 35 U.S.C. § 286, recoverable damages reach back only six years — i.e., from roughly 2020-09-29 forward — and only for acts during the term. If the demand letter targets post-expiration conduct alone, the damages theory is thin; if it targets 2018–2020 conduct, note the patent's expiration cuts off willful/injunctive theories entirely.
- Verify the assertion chain before responding. The one identified '436-involving case (Xerox v. MPV, 6:20-cv-06263 → 4:21-cv-00683) was voluntarily dismissed without prejudice on 2021-09-01/02. A dismissal without prejudice adjudicates nothing — it does not give you issue preclusion, collateral estoppel, or a § 101/§ 112 holding to wield. It does, however, mean no § 315(b) clock is running against Xerox on '436 from that complaint (a DJ action is not service of an infringement complaint), so a party in Xerox's position could still petition — while a party served with an infringement complaint more than a year ago could not.
- If you want to challenge it at the PTAB: confirm standing/timing. Petition within one year of any service of an infringement complaint (§ 315(b)); IPR remains technically available on an expired patent but will be construed under Phillips rather than the BRI standard, and PGR is long foreclosed and CBM unavailable for new petitions after 2020-09-16.
- Milestone watch: given no active proceedings, there are no institution-decision deadlines, oral hearings, or statutory one-year FWD dates to track. If a petition is filed after today, the Board's § 314(b) one-year institution deadline and § 316(a)(11) one-year trial deadline run from those future dates — nothing is currently pending.
- Bottom line: the absence of PTAB activity is itself the signal. A patent that was part of an eight-patent declaratory-judgment set and a Texas patent campaign, and that still drew zero IPR petitions over 25 years, suggests neither the plaintiff nor its adversaries considered PTAB challenge on '436 worth the filing fee. Treat it as an untested, expired patent — not a hardened one.
Generated 9/29/2026, 2:24:30 PM
Ownership chain (6)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
1998-08-31 · recorded 1998-11-23 · Assignment
2012-02-21 · Security Agreement
Eastman Kodak Company; Pakon, Inc.Citicorp North America, Inc., as Agent
securitization
2013-02-01 · Release
Citicorp North America, Inc.; Wilmington Trust, National Association (as prior agents)Eastman Kodak Company and the Kodak subsidiary group
securitization
2013-02-01 · recorded 2013-04-17 · Assignment
Eastman Kodak CompanyIntellectual Ventures Fund 83 LLC
fire-sale
? · recorded 2017-03-09 · Assignment
Intellectual Ventures Fund 83 LLCMonument Peak Ventures, LLC
transfer-to-asserter
? · recorded 2023-08-15 · Release
Intellectual Ventures Fund 83 LLCMonument Peak Ventures, LLC
securitization
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll research this patent's assignment chain and litigation history before writing up.
Key finding: the Eastern District of Texas case is a Xerox declaratory-judgment action naming this patent. Let me dig into the other case and the IV/Kodak chain.
Now let me try to pin down reel/frame numbers and the correspondent of record for the key links.
Ownership & Assignment Reconstruction — US 6,157,436 ("Image printing")
Verification note up front (read before the timeline): I could reach Google Patents' legal‑events record, the SEC Form 8‑K/Patent Sale Agreement for the Kodak transaction, and federal court dockets. I could not retrieve the USPTO Assignment Center's per‑record reel/frame numbers, execution dates, or correspondent‑of‑record fields through the tools available here — that data lives behind the Assignment Center search UI (https://assignmentcenter.uspto.gov/), and neither Google Patents' legal events nor the court/SEC documents expose it. Per your constraint against fabrication, every reel/frame and correspondent field below is marked "NOT VERIFIED" rather than guessed. The entity names, conveyance types, and dates I do assert are sourced.
Inventors
| Inventor | Employer at filing | Notes |
|---|---|---|
| Ronald S. Cok | Eastman Kodak Company (Rochester, NY) — inferable from the assignment recorded 1998‑11‑23, "Assignors: COK, RONALD S." → EASTMAN KODAK COMPANY | Sole named inventor. |
Unusual‑pattern check — inventor departure before fire‑sale: NOT PRESENT. Cok is a prolific Kodak imaging inventor whose name continues to appear on Kodak‑generation filings well after 1998, so there is no signal of a 12‑month inventor exodus preceding the 2012–2013 portfolio sale. The patent was not transferred by inventor action — it moved only as part of a corporate §363 asset sale (see below). I have no evidence of Cok personally assigning his rights to anyone but Kodak.
Original assignee
Eastman Kodak Company (New Jersey corporation; 343 State Street, Rochester, NY 14650) — named on the face of the issued patent and confirmed by the 1998‑11‑23 recorded assignment (assignor Cok → Eastman Kodak Company).
- Line of business: photographic film, chemicals, and photofinishing equipment/services. This patent sits squarely in Kodak's core photofinishing workflow: the specification describes a splicer, chemical developer, high‑speed scanner (~200 images/min), and multiple digital printers feeding a finishing station — i.e., Kodak's own lab architecture.
- Product embodiment: The disclosed system plausibly read on Kodak's own digital photofinishing lab equipment and its Qualex lab operations (FIG. 1's architecture tracks Kodak's stated workflow). I cannot cite a specific Kodak product SKU that was ever confirmed as embodying the claims — treat "shipped a product embodying the claims" as plausible but not documented here.
- Current status: Operating (post‑bankruptcy). Kodak filed Chapter 11 on 2012‑01‑19 (S.D.N.Y.), sold its digital imaging portfolio by §363 sale, and emerged in September 2013 as Eastman Kodak Company (NYSE: KODK). It is not the patent's current owner. The current assignee of record per Google Patents is Monument Peak Ventures, LLC.
Assignment timeline
Source basis: Google Patents legal events (dates shown as recorded events, with execution dates only where an underlying agreement supplies them). Reel/frame and correspondent fields could not be verified — see per‑entry flags.
1998‑08‑31 (executed, filing/priority date) / recorded 1998‑11‑23
- Reel NOT VERIFIED
- Conveyance: Assignment of inventors' interest (original prosecution‑stage assignment)
- Assignor: Ronald S. Cok
- Assignee: Eastman Kodak Company
- Correspondent: NOT VERIFIED
- Context: Ordinary employee‑inventor assignment to the operating company at filing.
2012‑02‑21 (executed — date of the DIP credit facility) / recorded 2012‑02‑21
- Reel NOT VERIFIED
- Conveyance: Security Interest ("SECURITY INTEREST (SEE DOCUMENT FOR DETAILS)")
- Assignor: Eastman Kodak Company; Pakon, Inc.
- Assignee: Citicorp North America, Inc., as Agent
- Correspondent: NOT VERIFIED
- Context: Securitization — the debtor‑in‑possession lender's blanket lien on Kodak IP collateral; the '436 patent was encumbered, not sold, at this step.
2012‑12‑18 (executed — Patent Sale Agreement dated as of 2012‑12‑18) / not the recording event
- Reel NOT VERIFIED
- Conveyance: Patent Sale Agreement (underlying contract; recorded US assignment followed in 2013)
- Assignor: Eastman Kodak Company, as debtor‑in‑possession
- Assignee: Intellectual Ventures Fund 83 LLC (Delaware LLC; principal place of business 7251 W Lake Mead Blvd, Ste 300, Las Vegas, NV 89128 — a Las Vegas registered‑agent‑style address, per the Sale Agreement itself)
- Correspondent: NOT VERIFIED
- Context: Bankruptcy fire‑sale / §363 asset sale — sale of Kodak's ~1,100‑patent digital imaging portfolio for ~$527M, with Kodak retaining a grant‑back license and 12 licensee companies (Adobe, Amazon, Apple, Facebook, FUJIFILM, Google, HTC, Huawei, Microsoft, RIM, Samsung, Shutterfly) taking licenses via a consortium organized by IV and RPX Corporation.
2013‑02‑01 (executed) / recorded 2013‑02‑01
- Reel NOT VERIFIED
- Conveyance: Patent Release ("PATENT RELEASE")
- Assignor: Citicorp North America, Inc.; Wilmington Trust, National Association (as prior agents)
- Assignee/Beneficiary: Eastman Kodak Company and the Kodak subsidiary group
- Correspondent: NOT VERIFIED
- Context: Securitization unwind — the DIP/secured‑party liens were released on the same date the §363 sale closed, clearing title for the IV conveyance.
2013‑02‑01 (executed — closing date of the Sale) / recorded 2013‑04‑17
- Reel NOT VERIFIED
- Conveyance: Assignment ("ASSIGNMENT OF INTEREST (SEE DOCUMENT FOR DETAILS)")
- Assignor: Eastman Kodak Company
- Assignee: Intellectual Ventures Fund 83 LLC
- Correspondent: NOT VERIFIED — if a single firm of record appears here, it would typically be IV's outside IP‑transactions counsel; I could not confirm the name.
- Context: Bankruptcy fire‑sale / transfer to an aggregator — the recorded title step implementing the December 2012 Sale Agreement; note the ~2.5‑month gap between execution and recordation, consistent with the Agreement's clause requiring Kodak to deliver recordable assignments within 30 days and placing recordation responsibility (and cost) on the Buyer.
2017‑03‑09 (execution date not specified in source; recorded/dated 2017‑03‑09)
- Reel NOT VERIFIED
- Conveyance: Assignment ("ASSIGNMENT OF INTEREST (SEE DOCUMENT FOR DETAILS)")
- Assignor: Intellectual Ventures Fund 83 LLC
- Assignee: Monument Peak Ventures, LLC (Texas‑based; affiliated with the Dominion Harbor Group, per the W.D.N.Y. court record)
- Correspondent: NOT VERIFIED — this is the entry where a repeat‑player correspondent would be most diagnostic; the field is unavailable to me.
- Context: Transfer‑to‑asserter — exit from the IV aggregation fund into a Dominion Harbor‑affiliated licensing/assertion vehicle.
2018‑08‑31 (legal status, not an assignment)
- Conveyance: n/a — anticipated expiration of the 20‑year term.
- Context: Google Patents records "Anticipated expiration" on 2018‑08‑31; status is Expired – Lifetime. (Note the consequence: the 2020–2021 suits below concerned an already‑expired patent, at most supporting past‑damages exposure inside the six‑year lookback.)
2023‑08‑15 (executed date not specified) / recorded 2023‑08‑15
- Reel NOT VERIFIED
- Conveyance: Release by Secured Party ("RELEASE BY SECURED PARTY (SEE DOCUMENT FOR DETAILS)")
- Assignor: Intellectual Ventures Fund 83 LLC
- Assignee/Beneficiary: Monument Peak Ventures, LLC
- Correspondent: NOT VERIFIED
- Context: Securitization unwind (within the NPE chain) — an IV‑side security interest taken over the MPV‑acquired portfolio was discharged. The existence of this lien is affirmative evidence that the IV→MPV deal was financed against the portfolio, not an outright cash sale.
If Assignment Center shows records I could not retrieve, the most probable additional entries are security‑interest and corrective/name records at IV Management and Dominion Harbor addresses; I am not asserting any such entry exists.
Timeline diagram
timeline
title Ownership of US 6157436
1998 : Filed by Eastman Kodak
: Cok assigns rights to Kodak
2000 : Patent issued as US 6157436
2012 : Kodak files Chapter 11
: Security interest to Citicorp as agent
: Patent Sale Agreement signed
2013 : Section 363 sale closes
: Assigned to IV Fund 83 LLC
: DIP liens released
2017 : Assigned to Monument Peak Ventures LLC
2018 : Patent term expires
2020 : Xerox files declaratory judgment suit
2021 : Second Xerox action in East Texas
2023 : Secured party release by IV Fund 83
NPE / troll‑pattern signals
1. Shell‑entity transfer — PRESENT.
Two consecutive hops away from an operating company into licensing‑only vehicles: Kodak → Intellectual Ventures Fund 83 LLC (Delaware LLC whose stated principal place of business in the Patent Sale Agreement is "7251 W Lake Mead Blvd, Ste 300, Las Vegas, Nevada 89128," a registered‑agent‑style address, and which bought 1,100 patents as a fund, not to make products), then → Monument Peak Ventures, LLC (Texas LLC; the W.D.N.Y. court found MPV and Dominion Harbor Group "are affiliated entities"). Neither entity has any product line. Dates: assignment recorded 2013‑04‑17 (IV) and 2017‑03‑09 (MPV).
2. Known asserter in the chain — PRESENT.
Intellectual Ventures is on your enumerated list and is the recorded assignee from the 2013‑04‑17 recordation. The current assignee, Monument Peak Ventures, is a Dominion Harbor‑affiliated high‑frequency plaintiff with a substantial docket surfaced by Unified Patents' litigation portal (the two "Family has litigation" links on the patent record are Unified Patents case pages: E.D. Tex. 4:21‑cv‑00683 and W.D.N.Y. 6:20‑cv‑06263) and by Docket Alarm/UniCourt (e.g., MPV v. Tesla 6:23‑cv‑00750; v. Johnson Controls 6:21‑cv‑01009; v. Vivint 6:22‑cv‑00635; v. TCL 5:24‑cv‑00011; v. Hanwha 6:23‑cv‑00539; v. Kyocera 2:23‑cv‑00127; v. OpenText 2:25‑cv‑00521; v. Insta360 2:25‑cv‑00956; v. Arnold & Richter 2:25‑cv‑01159; v. Carl Zeiss 2:26‑cv‑00100). Both prior and current assignees therefore match public NPE directories.
3. Repeat correspondent across the chain — UNCLEAR / NOT VERIFIED.
This is the single most diagnostic field and I could not obtain it. I will not name a law firm. What I can record as a related, verifiable adjacency: MPV's litigation counsel of record is consistently Cabrach J. Connor (appearing on the 2022–2026 dockets above), with John M. Shumaker on several — but litigation counsel of record is a different role from assignment correspondent of record, and a litigation firm appearing repeatedly is not a troll signal by itself (many firms do both NPE and operating‑company work). Raise or clear this by pulling the correspondent field directly from Assignment Center for the 2013‑04‑17 and 2017‑03‑09 records.
4. Cascading transfers (<24 months through chained LLCs) — NOT PRESENT as defined.
The recorded chain has only two LLC‑to‑LLC hops, separated by ~47 months (2013‑04‑17 → 2017‑03‑09), so the "<24 months, chained LLCs" test fails. What is present is a financing relationship between the two LLCs rather than a rapid resale: the 2023‑08‑15 "RELEASE BY SECURED PARTY" record, in which IV Fund 83 releases a security interest over patents now held by Monument Peak Ventures, indicates IV took collateral over the MPV portfolio it had transferred — inconsistent with a clean arm's‑length flip and consistent with a seller‑financed spin‑out to an assertion vehicle.
5. Pre‑litigation transfer (within 6 months of first suit) — NOT PRESENT.
The last transfer to the asserter was recorded 2017‑03‑09; MPV's first documented contact with Xerox was April 2019 and the first suit (Xerox's DJ complaint) was filed 2020‑04‑23 (W.D.N.Y. 6:20‑cv‑06263). That is ~3 years and ~31 months respectively — well outside the 6‑month window. Venue/standing were therefore not arranged by a last‑minute transfer; the vehicle existed for years before assertion.
6. Bankruptcy fire‑sale — PRESENT.
This is the best‑documented signal in the chain. Kodak filed Chapter 11 on 2012‑01‑19; the Patent Sale Agreement with IV Fund 83 was executed 2012‑12‑18 and filed as an SEC Form 8‑K (including §363(m) good‑faith‑purchaser representations); the sale closed 2013‑02‑01 for ~$527M across ~1,100 digital imaging patents; the US assignment to IV Fund 83 was recorded 2013‑04‑17. Kodak's own 2013 annual report confirms "SECTION 363 ASSET SALES… On February 1, 2013, Kodak entered into a series of agreements related to the monetization of certain of its intellectual property assets."
7. Privateering — PRESENT (with a structural nuance).
Kodak sold the portfolio while retaining a grant‑back license and granting licenses back to the 12‑member licensee consortium — i.e., Kodak and the consortium immunized themselves, while the residual enforcement rights flowed to IV and then to MPV, which asserted against Xerox (W.D.N.Y. 6:20‑cv‑06263; E.D. Tex. 4:21‑cv‑00683) and later against Kodak's own imaging‑industry comparators (Arnold & Richter 2:25‑cv‑01159; Carl Zeiss 2:26‑cv‑00100; Insta360/Arashi Vision 2:25‑cv‑00956). The nuance: assertion was not run "on Kodak's behalf" in any disclosed agency sense — Kodak simply sold the assets and kept a license. That is privateering in economic effect (self‑immunize, externalize enforcement) but not the classic disclosed‑agency form.
8. Defensive aggregator (anti‑NPE) — NOT PRESENT as a terminal condition.
RPX Corporation organized the licensee consortium that co‑funded the Kodak purchase, and the twelve licensees obtained rights — so there is a genuine defensive component to the 2012–2013 transaction. But the chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN; it terminates at an asserting LLC (MPV). The defensive aggregation neutralized the patent only as to the twelve licensees, and was ineffective against everyone else.
Verdict
NPE — high confidence.
Three strong, independently sourced signals converge. First, bankruptcy fire‑sale: the patent left operating company Eastman Kodak in the §363 sale executed 2012‑12‑18 and closed 2013‑02‑01, with the US assignment to Intellectual Ventures Fund 83 LLC recorded 2013‑04‑17 (reel/frame NOT VERIFIED). Second, shell‑entity transfer: title then passed to Monument Peak Ventures, LLC (recorded 2017‑03‑09), a Texas LLC the W.D.N.Y. court described as affiliated with Dominion Harbor Group — a licensing‑only entity, with the 2023‑08‑15 "Release by Secured Party" from IV Fund 83 showing the transfer was seller‑financed collateral rather than a product‑company acquisition. Third, known asserter in the chain: the 2013‑04‑17 assignee is Intellectual Ventures, and the current assignee MPV is a high‑frequency plaintiff whose suits are indexed in Unified Patents' litigation portal and whose docket spans Xerox, Tesla, TCL, Kyocera, Hanwha, Vivint, Johnson Controls, OpenText, Insta360, Arnold & Richter, and Carl Zeiss. The one signal I could not test — repeat assignment correspondent — is exactly where you should spend the next ten minutes; it is the field most likely to convert this from "high confidence" into a documented single‑attorney control pattern.
Verify / complete at: https://assignmentcenter.uspto.gov/ (search patent number 6157436) — pull the reel/frame, execution date, and correspondent for the records behind 1998‑11‑23, 2012‑02‑21, 2013‑02‑01, 2013‑04‑17, 2017‑03‑09, and 2023‑08‑15.
Generated 9/29/2026, 2:24:47 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research this systematically. Let me start by verifying the patent via USPTO and then examine each cited reference.
Let me examine the key cited references in detail.
Patent Under Analysis
US 6,157,436 B1 — "Image Printing"
- Inventor: Ronald S. Cok
- Original assignee: Eastman Kodak Company (now Monument Peak Ventures LLC)
- Appl. No. 09/143,842; filed 1998-08-31; granted 2000-12-05
- 31 claims; classification G03D15/001, G03D15/005 (photofinishing order systems)
- Family: EP0984326B1, JP4558860B2, AU754128B2, DE69918501T2
Scope of the claims (for mapping):
- Claim 1 — system: processor divides an order into sub-orders for respective image printers; each sub-order header has (i) unique order ID, (ii) an image-characteristic identification, (iii) a copy-count indication; plurality of printers print the header and the copies.
- Claims 2–3, 7–8 — header also identifies other printers and/or characteristics of their prints; claim 9 = thumbnail (reduced resolution) version.
- Claims 4–6, 12 — print status monitor; estimated times; status forwarded to printers that have not yet printed their header.
- Claim 11 — an "index of sub-orders" listing all printers.
- Claim 13 — prints issued as a sequence or with a common printed ID.
- Claims 14–15 — photofinishing laboratory (developer, scanner, memory, order receiver, printing system; code reader).
- Claims 16–24 — method counterparts.
- Claims 25–30 — computer program product.
- Claim 31 — system variant emphasizing identification of every other printer in each header.
Important methodology caveats (please read before relying on this)
- This is a preliminary, best-assessment mapping, not a claim chart. True § 102 anticipation requires that a single reference disclose every element of a claim, arranged as recited. On the record available, no cited reference alone appears to disclose the full combination of claim 1 (notably the printed sub-order header bearing an image-characteristic/thumbnail of the very images to be printed, used as a collation key at each of multiple printers). Most of these citations were almost certainly used by the examiner in § 103 obviousness combinations, not as standalone § 102 anticipations.
- I retrieved full text for US 4,970,554, US 5,559,933, and partial text for US 4,791,456. For several others (US 5,859,711, the two JP publications, and the EP publications) I am working from the titles, dates, and assignees in the patent's own citation tables plus general knowledge. I flag where this limits confidence.
- Dates of legal significance (pre-AIA § 102(a)/(b)/(e)) are noted for each reference relative to the 1998-08-31 filing.
The 11 examiner-cited references, with claim mapping
1. US 4,791,456 A — "Photographic printer apparatus"
- Citation: Henry F. Hope (Hope Industries). Appl. filed 1987-04-15; published/granted 1988-12-13.
- Description: Photographic printer with plural exposure stations under a single computer control, reversible roll magazines/cutter, and the ability to make single or multiple prints "of the same size or a different size without … processing an incomplete order." It explicitly contemplates connecting to a plurality of continuously running processors each handling different material types, and the operator can select which processor operates.
- § 102 status: § 102(b) art (well before filing).
- Potential relevance: Claim 14 (photofinishing laboratory — printer apparatus feeding multiple processors), and background support for multi-printer/multi-format output. It does not disclose sub-order headers or collation, so it is background/§ 103 material rather than an anticipatory reference for claims 1/16/25. Confidence: high on content, moderate on exact claim relevance.
2. US 4,970,554 A — "Job processing system for high speed electronic copying/printing machines"
- Citation: Xerox Corporation. Filed 1988-10-24; granted 1990-11-13.
- Description (verified): A central printing facility with a plurality of high-speed electronic printers (12-1…12-n). Job "tickets" carrying printing instructions and a job number in machine-readable (bar-code) form are scanned and matched to job programs stored in a job-program file; the system retrieves each job program by job number and prints accordingly. Prior art noted includes job/page separators bearing bar-code job programming information (Farrell US 4,716,438; Rourke US 4,757,348).
- § 102 status: § 102(b) art.
- Potential relevance:
- Claim 1 / 31 — the job ticket = an order/sub-order header with a unique job number and programmed instructions delivered to one of several printers; strong conceptual overlap (multiple printers, per-job identification, machine-readable header).
- Claim 25 / 16 — dividing and forwarding jobs with identifiers.
- Claim 15 — machine-readable code reading.
- It does not appear to disclose printing the header at the image printer as a collation aid with an image thumbnail, so anticipation of claim 1 is doubtful; § 103 combination likely.
3. EP 0 628 874 A2 — "Remote management system for photographic equipment"
- Citation: Fuji Photo Film Co., Ltd. Priority 1990-02-19; published 1994-12-14.
- Description: Remote monitoring/management of photographic (photofinishing) equipment — i.e., remotely obtaining operational status from processing/printing equipment.
- § 102 status: § 102(b) art.
- Potential relevance: Claims 4, 5, 6, 12 (print status monitor; forwarding status and estimated times to other devices/printers). This is the most on-point cited art for the status-monitoring family of claims. It likely does not disclose forwarding status to another printer for printing on that printer's sub-order header, so anticipation is doubtful but § 103 relevance is high. Confidence: moderate (worked from title/abstract).
4. JP H04-289840 A — "Method and device for printing photograph"
- Citation: Fuji Photo Film Co., Ltd. Filed 1991-03-19; published 1992-10-14.
- Description: Photographic printing method/apparatus (Japanese-language publication). Specific technical content not independently verified here.
- § 102 status: § 102(b) art (published before filing; foreign publication).
- Potential relevance: General photofinishing printing art — potentially claims 14–16 background. Cannot responsibly assign a specific anticipating claim without the full translated disclosure. Low confidence; flag as requiring the full document/translation.
5. JP H04-314047 A — "Photograph processing method"
- Citation: Fuji Photo Film Co., Ltd. Filed 1991-04-12; published 1992-11-05.
- Description: Photographic processing method (Japanese-language). Not independently verified.
- § 102 status: § 102(b) art.
- Potential relevance: Background to claims 14–16; possibly order/film handling. Low confidence without full text.
6. US 5,459,819 A — "System for custom imprinting a variety of articles with images obtained from a variety of different sources"
- Citation: Eastman Kodak Company. Filed 1993-09-24; granted 1995-10-17.
- Description: System for producing custom articles (T-shirts, cups, etc.) imprinted with customer images from varied sources — the multi-product, personalized-order concept. (This reference is also discussed in the 6157436 specification itself.)
- § 102 status: § 102(b) art.
- Potential relevance: Claim 14 context and the general premise that one customer order spans multiple different output devices (claim 1's "multiple sub-orders for respective image printers"). Not anticipatory of the header/collation features. § 103/background.
7. US 5,559,933 A — "Distributed enterprise print controller"
- Citation: R. Stephen Boswell; Unisys Corporation. Filed 1994-04-22; granted 1996-09-24.
- Description (verified in detail): A distributed print controller that routes print files across multiple networked computers to multiple attached printers using "file masks." Print attributes include the number of copies, printer identity, page range, and selectable header/trailer (banner) pages; a Physical/Logical Printer configuration lists the printers in the network, and a job carries a printer identifier. Files are matched to masks and print/transfer jobs are created and queued per printer.
- § 102 status: § 102(b) art.
- Potential relevance: Among the strongest of the cited art for the core distribution concept:
- Claim 1 — "processor divides the order into multiple sub-orders for respective image printers" maps well to file-mask routing to different printers with per-job copy counts and destinations; header/banner pages map loosely to "sub-order header."
- Claim 11 — a configuration listing all printers is conceptually an "index of sub-orders."
- Claims 2/7 — identifying other printers (physical/logical printer lists).
- Claims 25/29–30 — program product implementations.
- Gap: the reference's header pages are generic banners, not headers carrying an image-characteristic identification/thumbnail of the very images to be printed, and it is not a photofinishing context. Anticipation of claim 1 is therefore unlikely on the verified disclosure; strong § 103, and potentially anticipatory of dependent claims (e.g., copies count / destination identification).
8. US 5,761,558 A — "Expanded film cartridge bar code"
- Citation: Eastman Kodak Company. Filed 1995-06-05; granted 1998-06-02.
- Description: Film-cartridge bar code encoding expanded information (read by photofinishing equipment).
- § 102 status: § 102(a)/(b) art (granted before the 1998-08-31 filing).
- Potential relevance: Claim 15 ("order receiver is a code reader which reads the orders in the form of a machine readable code on the films") and claim 14 context. Likely anticipatory-adjacent for the code-on-film element, but claim 15 also requires the full image-printing system of claim 14, so at most § 103 when combined.
9. US 5,859,711 A — "Multiple print engine with virtual job routing"
- Citation: T/R Systems, Inc. Filed 1995-08-07; granted 1999-01-12.
- Description: A printing system with multiple print engines and virtual job routing — a controller that routes a print job to one of several engines (typically based on load/capability).
- § 102 status: § 102(e) art — US patent granted on an application filed (1995-08-07) before 6157436's filing date, even though it published/issued after 6157436 was filed. This makes it a proper § 102(e) reference despite the later issue date.
- Potential relevance: Claims 1, 2, 7, 31 — dividing/routing a job among multiple printers/engines. Likely the single most structurally analogous reference to "processor … multiple sub-orders for respective image printers." However, I did not verify whether it prints per-job identifying headers at the engines with image characteristics/thumbnails, so I cannot assert § 102 anticipation of claim 1; treat as a leading § 103 reference. Confidence: moderate (content inferred from title/known art — verify full text).
10. EP 0 793 142 A1 — "Photographic processing system comprising means for automatically sorting films according to parameters read from the films"
- Citation: Noritsu Koki Co., Ltd. Priority 1996-03-01; published 1997-09-03.
- Description: Photographic processing system that automatically sorts films/orders by parameters read from the film (machine-readable order data).
- § 102 status: § 102(b) art.
- Potential relevance: Claims 14–16 (order receiver/code reader; distinguishing orders by read parameters) and the general concept of machine-routed orders. Not anticipatory of the sub-order-header/thumbnail collation features.
11. EP 0 933 679 A2 — "Photographic processing apparatus and method"
- Citation: Eastman Kodak Company. Priority 1998-01-30; published 1999-08-04.
- Description: Photographic processing apparatus/method (Kodak). Content not independently verified here.
- § 102 status — careful: Its priority date (1998-01-30) precedes 6157436's filing (1998-08-31), but its publication (1999-08-04) is after the 6157436 filing date. A published EP application is generally not § 102(e) prior art against a US patent (only US patents/published US PCT applications are). As a result it likely qualifies only via a US counterpart under § 102(e), or as § 102(a) "known by others" if a US application were involved — otherwise it may be of limited anticipatory value and was probably cited for § 103/background. Flag this date nuance explicitly.
- Potential relevance: Claim 14 (photofinishing apparatus) and general background.
Bottom line — most relevant prior art and best claim mapping
| Rank | Reference | § 102 basis | Strongest claim(s) potentially implicated |
|---|---|---|---|
| 1 | US 5,859,711 A (T/R Systems) — multiple print engines, virtual job routing | § 102(e) | 1, 2, 7, 31 (≈103 with others) |
| 2 | US 5,559,933 A (Unisys) — distributed enterprise print controller | § 102(b) | 1, 11, 2/7, 25, 29–30 (copies-count, printer lists, program product) |
| 3 | US 4,970,554 A (Xerox) — job tickets with machine-readable job numbers to multiple printers | § 102(b) | 1, 11, 15, 25 |
| 4 | EP 0 628 874 A2 (Fuji) — remote status management of photographic equipment | § 102(b) | 4, 5, 6, 12 (status monitor) |
| 5 | US 5,761,558 A (Kodak) — expanded film cartridge bar code | § 102(a)/(b) | 15 (code reader on film), 14 |
| 6 | EP 0 793 142 A1 (Noritsu) — auto-sorting films by read parameters | § 102(b) | 14, 15, 16 |
| 7 | US 4,791,456 A (Hope) — photographic printer, plural processors/controlled stations | § 102(b) | 14 |
| 8 | US 5,459,819 A (Kodak) — custom imprinting of articles | § 102(b) | 14 (multi-product order context) |
| 9 | EP 0 933 679 A2 (Kodak) — photographic processing apparatus | date issue (see above) | 14 (limited) |
| 10 | JP H04-289840 A (Fuji) | § 102(b) | 14–16 (unverified) |
| 11 | JP H04-314047 A (Fuji) | § 102(b) | 14–16 (unverified) |
Key analytical point: The distinguishing feature of US 6,157,436 — a printed sub-order header, generated at each of several printers, that carries a unique order ID, a copy-count, AND an image-characteristic identification (e.g., a thumbnail) of the images that sub-order will produce, expressly to enable operator collation across printers without marking every print — does not appear to be squarely disclosed by any single one of the 11 cited references. The cited art supplies the individual building blocks (multi-printer job routing, job-ticket/banner headers with machine-readable IDs, remote status monitoring, film-code order reading), which is consistent with these references having been applied in § 103 combinations. I would not assert § 102 anticipation of independent claim 1 (or its method/product counterparts, claims 16 and 25) on any single reference without first obtaining and reviewing the full texts of US 5,859,711 and the two JP publications, and confirming the EPO/JP claim translations.
Sources
- US 6,157,436 B1 full text (authoritative, incl. the 11-reference citation table): https://patents.google.com/patent/[US6157436A](/patent/US6157436A)/en
- US 4,791,456 A: https://www.freepatentsonline.com/[4791456](/patent/4791456).html ; https://patents.google.com/patent/US4791456
- US 4,970,554 A: https://patents.google.com/patent/[US4970554A](/patent/US4970554A)
- US 5,559,933 A: https://patents.google.com/patent/[US5559933A](/patent/US5559933A) ; https://insight.rpxcorp.com/patent/US5559933A
If you want, I can produce a full element-by-element claim chart for claims 1, 16, and 25 against the top three references (once the full texts of US 5,859,711 and the JP documents are pulled).
Generated 9/29/2026, 2:24:43 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll verify the content of the key cited prior-art references before building the § 103 combinations.
Obviousness Analysis — US 6,157,436 (35 U.S.C. § 103)
Scope note / date flag: My environment timestamp and the fetched record date are 2026‑09‑29; the task header says "Current Date: April 26, 2026." I proceed on the record as fetched (priority/filing 1998‑08‑31; expired 2018‑08‑31) — the discrepancy does not affect the § 103 analysis. One feature of this analysis is that for an expired, judicially-challenged patent the § 103 question is now mainly relevant to validity/§ 282 history rather than to injunctive relief.
1. Governing framework
Because the application was filed 1998‑08‑31, the pre‑AIA version of §§ 102/103 governs. The relevant legal touchstones are Graham v. John Deere, KSR Int'l v. Teleflex, 550 U.S. 398 (2007) (predictable combination of known elements; "design incentives," "market forces," and "obvious to try" are permitted rationales), and In re Keller/In re Merck (each reference need not teach the whole; the combined teachings are what matter).
1.1 Evidentiary status of the references on the face of the patent
| Reference | Field / gist | Effective prior-art date | Pre-AIA status |
|---|---|---|---|
| US 5,859,711 (Barry et al., T/R Systems) — "Multiple print engine with virtual job routing" | Central processor parses a print job into pages and distributes them to a plurality of print engines; per-engine output bins; separator sheets; status monitoring | Filed 1996‑08‑16 (CIP of 1995‑08‑07) | § 102(e) (issued 1999‑01‑12, i.e., after the 1998 filing, so only as a US‑filing‑date reference) |
| US 4,970,554 (Xerox) — "Job processing system for high speed electronic copying/printing machines" | Printed job tickets with a machine-readable job number (bar code) combined with the documents; scanning/retrieval of job program by job number in a multi-printer central print facility | Filed 1988‑10‑24; issued 1990‑11‑13 | § 102(b) |
| US 5,559,933 (Boswell, Unisys) — "Distributed enterprise print controller" | Routing of jobs to selected ones of many printers by job/file characteristics; print attributes include number of copies; user-definable header/trailer pages and banner options; physical-printer list and logical→physical mapping | Filed 1994‑04‑22; issued 1996‑09‑24 | § 102(a) (issue date is <1 year before the 1998 filing) |
| US 5,459,819 (Watkins et al., Eastman Kodak) — "System for custom imprinting a variety of articles…" | A plurality of different output devices (thermal, inkjet, CRT) fed from one CPU/server for a single customer's order; different resolutions per output format; system status displayed to operator | Priority 1993‑09‑24; issued 1995‑10‑17 | § 102(b) |
| US 4,791,456 (Hope) — "Photographic printer apparatus" | Photographic printer with plural exposure stations under a single computer, making single/multiple prints of same or different size "without the necessity of processing an incomplete order" | Issued 1988‑12‑13 | § 102(b) |
| EP 0 793 142 A1 (Noritsu Koki) | "Photographic processing system comprising means for automatically sorting films according to parameters read from the films" | Pub. 1997‑09‑03 | § 102(a) — title‑level only (see caveats) |
| JPH 10‑150541 A (Fuji) "Photo‑finishing system" | Photofinishing order handling | Pub. 1998‑06‑02 (priority 1996‑11‑20) | § 102(a) — title‑level only |
| JPH 09‑265141 A (Fuji) "Method and system for printing in coexisting state" | Mixed‑mode printing | Pub. 1997‑10‑07 | § 102(a) — title‑level only |
| EP 0 628 874 A2 (Fuji) "Remote management system for photographic equipment" | Remote equipment status monitoring in photofinishing | Pub. 1994‑12‑14 | § 102(b) |
| US 5,761,558 (Kodak) "Expanded film cartridge bar code" | Machine‑readable film codes | Issued 1998‑06‑02 | § 102(a) |
| JPH 04‑289840 A / JPH 04‑314047 A (Fuji) | Photographic printing methods | 1992‑10‑14 / 1992‑11‑05 | § 102(b) |
| EP 0 933 679 A2 (Eastman Kodak) "Photographic processing apparatus and method" | Same assignee as the patent | Pub. 1999‑08‑04 (priority 1998‑01‑30) | Not clearly prior art — published after the 1998‑08‑31 filing; usable only via § 102(e) if a qualifying earlier US filing exists. Flagged. |
1.2 The patent's own admissions — the strongest § 103 ammunition
US 6,157,436's Background expressly admits several claim elements as known:
- A printed per‑print sheet carrying a thumbnail and a copy count — "when a single product is ordered from a printer of a photofinishing system, a separate sheet can be printed at the printer which sheet has a thumbnail of a print to follow, an indication of the number of copies of the print, and a customer address." This is squarely the "sub‑order header" content of claim 1 for a one‑printer order.
- Banner pages between print requests under computer control in office laser printers, and fax cover forms identifying a transmission — i.e., header sheets preceding job output.
- Marking each output of an order with a common identifier ("the different prints, computer or computer disks may carry a common identifier for each order") — the very thing the patent says it improves on.
- Scanning film at high speed and digital printing, and the multi‑printer/multi‑speed problem statement itself.
An applicant's own specification admissions are prior art against it. This makes the thumbnail/copy‑count header element and the "header sheet before the job" concept effectively conceded.
2. Element map of the independent claims
| Element | Cl. 1 (system) | Cl. 14 (lab) | Cl. 16 (method) | Cl. 25 (CRM) | Cl. 31 (system) |
|---|---|---|---|---|---|
| Processor divides order into sub‑orders for respective printers | ✔ | ✔ | ✔ | ✔ | ✔ |
| Header with unique order identification | ✔ | ✔ | ✔ | ✔ | ✔ |
| Header with copy‑count indication | ✔ | ✔ | ✔ | ✔ | ✔ |
| Header with image‑characteristic identification | ✔ | ✔ | ✔ | ✘ | ✘ |
| Header lists each other printer for the order | ✘ | ✘ | ✘ | ✘ | ✔ |
| Plural printers print header + copies | ✔ | ✔ | ✔ | (forwarding only) | ✔ |
| Lab elements (developer, scanner, memory, order receiver) | – | ✔ | – | – | – |
Consistent with the earlier summary: claim 25 and claim 31 omit the image‑characteristic identification, and claim 25 is therefore the broadest independent claim to attack; claim 1/16/14 carry the added thumbnail/size‑description limitation, which is the only element not already in the admitted art + T/R Systems.
3. Primary combination A — claims 1, 16 (and 14 via § 4)
US 5,859,711 (T/R Systems) + US 4,970,554 (Xerox) + applicant's admitted prior art.
| Claim element | Where taught |
|---|---|
| Processor divides an order/job into sub‑orders for respective printers | '711 §II: processor 14 + software RIP 22 parse the job; image task manager 26 + engine manager 28 distribute pages "to select ones of the printers in a predetermined order"; "how many sheets are to be routed to each engine" |
| Plural printers, each receiving its sub‑order and printing copies | '711: multiple print engines 16, each with its own output bin 40; "how many copies are needed" is supplied to the print station |
| Printed sub‑order header at each printer | '711: "some indication, such as a separator page, that will allow the particular stack created between separators, to be assembled with another stack from another printer in the desired print job output"; "slip sheets … can be inserted between jobs or between copies, these being separator sheets" |
| Header carries unique order identification | '554: printed job ticket bearing a job number encoded in machine-readable (bar code) form, hard copies of the tickets "combined with the documents that comprise the job program," later "scanning the job tickets … to identify the job numbers," and retrieving the job program by job number |
| Header carries copy‑count indication | Admitted art: separate sheet with "an indication of the number of copies of the print"; and '933's print attribute "Number Of Copies" (Combination B) |
| Header carries image‑characteristic identification (e.g., thumbnail) | Admitted art: separate sheet with "a thumbnail of a print to follow"; alternatively '819 (images maintained at multiple DPI for preview/format matching) |
| Photofinishing environment | '456 (photographic printer, plural exposure stations, single computer); '819 (customer image orders across multiple output devices) |
Motivation (explicit, not hindsight):
- '711 states the very problem the patent addresses: "This system poses a significant problem, however, of how to most efficiently organize and route the parts of a complex print job to the plurality of print engines," and expressly says a separator page is the mechanism that lets stacks from different printers be assembled. A PHOSITA designing '711's separator page has a direct, articulated reason to put identifying content on it.
- '554 supplies exactly that content and explains why: its multi‑printer "central printing facility" may have printers "scattered about within a facility… on different floors," so a printed, uniquely numbered ticket physically combined with the job is used to identify and retrieve the right job — the same collation problem in the same field. Both references are in printing‑workflow control; the field of endeavor and the problem are identical.
- The thumbnail + copy count on a separate sheet is admitted art in this very specification, so the only remaining step is substituting the admitted art's single‑printer separator sheet into '711's per‑engine separator page and adding '554's unique job number — a predictable arrangement of known elements with no change in function (KSR; In re Keller).
Result: claim 1 and claim 16 are obvious. Claim 14 (photofinishing laboratory) follows by adding the conventional developer/scanner/memory/order‑receiver elements that the specification itself describes as known ('456 for the developer + plural‑station photographic printing, '819 for multi‑output customer orders, EP 0 793 142 A1 for film‑parameter reading).
4. Primary combination B — claims 1, 16, 31, and 25–30
US 5,859,711 + US 5,559,933 (Unisys DEPCON).
'933 is the single most dangerous reference for the header‑forwarding, routing‑table, and software claims because it discloses, in one document, a controller that:
- routes a job to a selected one of many printers based on job/file characteristics ("routed to different places or printed differently based on characteristics such as the origin of the file, the size of the file, or the user who created the print job");
- stores, per job, print attributes including "Number Of Copies to be printed," destination printer identification, page size, printer type, print quality (Fig. 13–15), i.e., an image/print‑characteristic identification and a copy‑count indication;
- prints a header page before the print file and a trailer page after, with user‑definable header content (Fig. 22: per‑item Line Number, Item Name, Data/Prefix flag, Position, Size) and "banner options specify the header and trailer page types" — a printed per‑job header sheet;
- maintains a physical printer configuration ("a list of printers connected to computer systems within the network") and a logical printer configuration ("a logical‑to‑physical mapping of printers," each logical printer = up to 32 physical printers);
- expressly states that "different header and trailer pages may be used with different printers and Print Files" — a teaching of per‑printer header content.
Motivation: '711 already teaches splitting one job across engines and even reconfiguring when a station is down; '933 teaches the control layer for doing so in a heterogeneous network with per‑job header/banner pages and printer‑characteristic attributes. A PHOSITA integrating a network‑capable job‑routing controller would combine them for throughput and for the stated need to tell an operator what was printed where ('711: "An output will then be provided to instruct the operator how to arrange the pages for pickup from the output bin").
Claim 31 (per‑printer header identifying each other printer for the order) is the easiest of the independents: '933's Physical/Logical Printer configurations and '711's job manager both necessarily hold the set of engines over which the job was spread; printing that list on each header is a predictable, purely conventional use of the routing data already in hand (KSR: "familiar elements according to known methods").
Claims 25–30 (computer program product) are, if anything, broader: claim 25 requires only the unique order ID and copy count (no thumbnail), so '711's parsing/copy distribution plus '933's software‑implemented job/routing controller — both of which describe their logic as programs executing on processors using disk storage ('933: "Memory 22 typically consisted of magnetic disks") — render the subject matter obvious. Claim 28's "characteristic of image prints" is met by '933's print‑attribute library.
5. Dependent‑claim chart (secondary references)
| Claim(s) | Element | Best prior art | Motivation |
|---|---|---|---|
| 2, 17, 26 | Header identifies another printer | '711 (job spread over engines; operator told where to pick up pages); '933 (physical/logical printer lists, alternate destination parameters in SEND command) | Required to route the operator to intermingled output |
| 3, 8, 19, 28 | Header identifies a characteristic of another printer's prints | '933 print‑attribute library (page size, printer type, quality per destination); '819 (per‑format resolution/characteristic matching); admitted art (thumbnail) | Same collation‑error reduction; format/size mismatch is inherent to multi‑device orders |
| 4, 5, 6, 12, 23, 24, 29, 30 | Print status monitor; estimated time; forwarding to printers that have not yet printed their header | '711 (PPE "maintaining real‑time status of the print engine"; engine allocator returns status; job reconfiguration when a station is down); EP 0 628 874 A2 (remote management/status of photographic equipment); '933 (printer "Currently Available," initial state, operator messages) | '711 expressly needs engine status to re‑parse the job; deferring the header until status is known is a routine scheduling choice |
| 9, 20 | Reduced‑resolution version (thumbnail) | Admitted in the specification ("a thumbnail of a print to follow"); '819/EP 0 649 244 (images maintained at a lower DPI for preview and a higher DPI for output) | Thumbnails are the acknowledged conventional way to identify an image on a separator sheet |
| 10, 21 | Sub‑order includes the image signal | '711 page buffers (rasterized pages); '933 file database ("storing and retrieving files") | Data‑locality design choice |
| 11, 22 | Index of sub‑orders forwarded to a printer | '554 (job program file retrieved by job number); '933 (print job list, file group library, logical printer configuration) | Alternative to scanning each printer |
| 13 | Sequential printing / common printed identification | '711 electronic collation and output‑bin ordering; admitted art ("common identifier for each order," customer address on each print) | Both are conventional collation techniques |
| 15 | Order receiver = code reader reading film codes | US 5,761,558 (expanded film cartridge bar code); EP 0 793 142 A1 (sorting films by parameters read from the film); admitted art in the specification (film code reader 103) | Directly on point |
6. Where the § 103 case is weakest
Intellectual honesty requires flagging the two elements not squarely met by the strongest references:
- "Estimated time for printing the sub‑order at the corresponding printer" (claims 5, 12, 23). '711 discloses status readback and reconfiguration, and '933 discloses queue/priority and printer availability, but I did not verify a disclosure of a computed estimated completion time in either. Expect the patentee to argue this is a non‑obvious predictive feature. It is likely still obvious as a "predictable variation" (queue depth ÷ engine rate, both known from '711/'933) and/or via EP 0 628 874 A2, but the motivation is thinner than for the other elements and should be evidenced with a verified quote before being relied upon.
- "Image printers which have not printed their corresponding sub‑order header" print later‑received status for other printers (claims 6, 12, 24, 30). This deferred‑header printing is an implementation detail not clearly disclosed; it reads as a routine sequencing choice once the header content is known, but it is the second‑weakest link.
Everything else — order splitting, per‑printer printed identification sheets, thumbnails, copy counts, cross‑printer listings, status feedback, film code readers, and CRM implementations — is either in '711/'554/'933/'819/'456/'558/EP 0 793 142 A1 or admitted in the specification's own Background.
7. Anticipated patentee rebuttals
- Non‑analogous art: weak. '554, '711, '933, '819 and '456 are all document/image reproduction, workflow routing, or photofinishing — the same field of endeavor, and the identical problem (collating split outputs).
- Teaching away: '554 teaches against marking each product (it replaces per‑copy marking with a per‑job ticket), which if anything supports the patent's stated advantage of not marking every print — but a reference is not required to teach away to be combinable, and '554's own rationale is the same collation problem.
- Secondary considerations: the specification asserts reduced collation error and less operator watching. Nexus is weakened because the thumbnail‑and‑copy‑count separator sheet and per‑order common identifiers were already known (admitted), and because I found no evidence in the record of unexpected results, industry praise, or copying tied to these claims. The earlier‑noted W.D.N.Y. matter was dismissed for lack of personal jurisdiction, so there is no adjudicated finding of validity or infringement to lean on.
8. Bottom line
- Claims 1, 16, 31 are obvious over US 5,859,711 in view of US 4,970,554 (Combination A), further in view of US 5,559,933 and the applicant's admitted prior art (thumbnail/copy‑count separator sheet). The motivation is explicit in '711 itself (its own stated problem of assembling stacks from different printers using a separator page) and reinforced by '554's bar‑coded job ticket and '933's per‑job header/banner pages and printer characteristics.
- Claims 25–30 are obvious over US 5,859,711 + US 5,559,933 alone; claim 25 omits the thumbnail limitation, making it the broadest and weakest claim.
- Claim 14 adds only the conventional photofinishing front end (developer, scanner, memory, order receiver), which the specification admits and which is disclosed in US 4,791,456, US 5,459,819, US 5,761,558, and EP 0 793 142 A1.
- The only elements with a genuinely thin § 103 footing are the estimated completion time (claims 5/12/23) and the deferred post‑header status printing (claims 6/12/24/30); even these are defensible as predictable variations under KSR, but they should be briefed separately rather than lumped into the main combination.
9. Caveats and unresolved items
- Verified full‑text/figures: US 5,859,711, US 4,970,554, US 5,559,933, US 4,791,456, US 5,459,819 (incl. its EP 0 649 244 family). Title‑level only (search budget exhausted; characterize with caution): EP 0 793 142 A1, EP 0 933 679 A2, JPH 09‑265141 A, JPH 10‑150541 A, JPH 04‑289840 A, JPH 04‑314047 A, JP 3947251 B2, EP 0 628 874 A2, US 5,761,558, DE 69918501 T2.
- EP 0 933 679 A2 is probably not prior art as a printed publication (published 1999‑08‑04, after the 1998‑08‑31 filing) despite being listed as a citation; it appears in the record as a commonly‑owned Kodak co‑pending application. Do not build a § 103 combination on it without checking for an earlier qualifying US filing and its § 102(e) date.
- The cited "Cited By" list is not prior art here: the earliest relevant cited‑by documents have 1998 or later priority dates, so they cannot be used in the § 103 combination.
- I found no contradiction with the previously generated summary sections; the claim‑25/claim‑31 omission of the image‑characteristic identification flagged there is confirmed and is load‑bearing for this analysis.
- The E.D. Tex. 4:21‑cv‑00683 matter and the Darts‑IP "first worldwide family litigation" entry remain unverified; nothing in this § 103 analysis depends on them.
Generated 9/29/2026, 2:25:14 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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