Invalidity dossier

US 7280251

System and method for calibrating color printers

Current assignee: RAH Color Technologies LLC

Added 9/27/2026, 11:13:54 PM

At a glanceNo PTAB challenges3 lawsuits on fileasserted by RAH Color Technologies LLCSoftware Technology & Computing Systems (T)

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

✓ Generated

I'll verify the current status of US 7,280,251 against live sources, including any 2026 CAFC dockets.

Let me check for any 2026 Federal Circuit activity and litigation status specifically tied to this patent.

Let me do a final targeted check for any 2026 Federal Circuit docket activity and the patent's current fee/expiration status.

US Patent 7,280,251 — Verification Summary

Sources consulted (live, fetched 2026): the Google Patents full-text record you supplied (https://patents.google.com/patent/US7280251/en), Justia Patents (https://patents.justia.com/patent/7280251), the Unified Patents litigation links embedded in the Google Patents record, and the Stanford NPE Litigation Database entry for 7280251 (https://npe.law.stanford.edu/patent/7280251). I did not obtain a direct USPTO PatentCenter/PAIR or PACER pull, so bibliographic items below are corroborated-but-secondary.


1. Bibliographic Data (as recorded, not corrected)

Field Value
Patent number US 7,280,251 B1
Title System and method for calibrating color printers
Inventor Richard A. Holub (Rochester, NY) — sole named inventor
Assignee RAH Color Technologies LLC; Google Patents lists "Current Assignee: RAH Color Tech LLC" and "Original Assignee: RAH Color Tech LLC." Assignment records: 2005-12-15 assignment from Holub to RAH Color Technologies LLC; 2013-05-14 merger assignment to RAH Color Technologies LLC
Application no. 10/880,075
Filed 2004-06-29
Granted / published 2007-10-09
Earliest priority 1996-02-26 (via US 08/606,883)
Examiner / attorney Primary Examiner Thomas D. Lee; Assistant Examiner Stephen Brinich; Attorney Kenneth J. Lukacher
Status (Google Patents) "Expired – Fee Related"; "Adjusted expiration 2016-12-30"

Priority chain (per the printed text): CIP of Ser. No. 10/209,431 (now US 7,075,643) and of Ser. No. 10/040,664 (now US 6,995,870); those descend from Ser. Nos. 09/139,498 (US 6,459,425) and 09/135,692 (US 6,157,735), which in turn descend from Ser. No. 08/606,883 (US 6,043,909). The 1996-02-26 date therefore comes from the grandparent application, not from this CIP itself.


2. Abstract (verbatim)

"A system and method for calibrating color printers, and related particularly to, a system and method for calibrating color printers over a network utilizing a profile server (representing a networkable computer server system) which provides color transformations in accordance with printer configurations having at least information read from consumable ink or toner cartridges for such printers. Such color transformations enable different color printers, or even the same color printer with different printer configurations, to render color consistently."


3. Plain-Language Overview of Each Independent Claim

The patent has 41 claims, of which 9 are independent: 1, 7, 8, 9, 10, 23, 33, 35, and 37. They cluster into three families: (A) network + cartridge-ID calibration systems/methods (claims 1, 7, 8); (B) networked color-reproduction devices generally (claims 9, 10); and (C) cartridge-centric printer calibration (claims 23, 33, 35, 37).

Claim 1 — Networked calibration system keyed to cartridge identity (system).
A multi-node network where one node runs a computer system and another node has a color printer using replaceable toner/ink cartridges carrying identifying information. The system reads that cartridge ID, sends "printer configuration information" (including the ID) over the network to the first node, and the first node's computer returns color transformation information that lets the printer render color in accordance with the cartridge ID. The novelty core is that the transformation is selected/served based on what cartridge is installed.

Claim 7 — Networked method of receiving, storing, computing/verifying, and distributing transformations (method).
Links a first node holding a database to second nodes with rendering devices. The first node receives information about a rendering device, stores it in the database by device/node attributes, uses it as input to compute new color transformations or verify existing ones, stores those transformations, and distributes them back to nodes. Crucially, the "information regarding a rendering device" includes at least information read from a consumables cartridge installable in the rendering device — this is the claim-level hook tying networked color management to consumable ID.

Claim 8 — Same as claim 7, but as a computer-readable medium (CRM).
Recites the identical functional package as software modules: a protocol-interaction module, a module to receive rendering-device information at the first node, a module to store it by device/node attributes, a module to compute/verify transformations from it, a module to store the transformations, and a module to distribute them — again where the device information includes cartridge-read data.

Claim 9 — Peer-to-peer sharing of color reproduction data (method).
Communicates with one or more color-capable rendering devices, collects color reproduction data relative to a reference, and shares at least part of that data between the devices over a network via each device's network interface for the purpose of matching color reproductions. This is the broadest "distributed color matching" claim; it does not itself require a cartridge or a profile server.

Claim 10 — Network-connected color reproduction apparatus (apparatus).
An apparatus with a processor, a component enabling adjustment of its color-calibration state, and a communications link using a network protocol over LAN/WAN/Internet/WWW connecting at least one other node — where the device's color calibration is coordinated with the assistance of that other node or nodes. Again, no cartridge limitation; it is the "network-assisted calibration" genus.

Claim 23 — Cartridge-ID printer system (system).
A color printer with a microprocessor; a printer cartridge with readable identifying information; and either the microprocessor or an attached computer system able to (a) communicate that identifying information over a network and (b) receive color transformation information over the network that lets the printer, using that cartridge, render color in accordance with the ID. Dependent claims 24–32 add that the computer interfaces with the microprocessor, that the ID is an optically readable identifier, an RFID tag, non-volatile memory/switch-array/capacitive sensor, a reader, user keyboard entry, and communicating media type / user preferences / calibration state.

Claim 33 — Cartridge-ID method (method).
The method counterpart: provide readable identifying information on a color printer cartridge, communicate at least that ID over a network, and receive color transformation information over the network enabling a printer using that cartridge to render color in accordance with the ID. Claim 34 specifies the ID may be optical, RFID, non-volatile memory, switch array, or capacitive sensor.

Claim 35 — Server-side transformation database (system).
A database storing color transformations for multiple color printers, plus a computer system able to communicate over a network data defining one of those transformations according to at least information readable from a cartridge installable at one of the printers. This is the profile-server side of the architecture, claimed independently of the printer.

Claim 37 — On-device CRM for network calibration (CRM).
A computer-readable medium with two software components: one enabling communication over a network to enable color calibration of the device in accordance with at least data readable from a cartridge installable at the rendering device, and one enabling adjustment of the device's rendering per color transformation information received over the network. Claim 38 adds LAN/WAN/Internet/WWW protocol capability; claim 39 places execution on the device processor or an attached computer; claim 40 recites profiles/gamut data/transfer functions/procedures; claim 41 adds reading linearization data and modifying linearization functions to match the received transformation.


4. Litigation Status — and the 2026 CAFC Check

What I found (district court / PTAB):

  • The Google Patents record shows this patent's family has been litigated in: W.D.N.Y. (6:10-cv-06710; 6:18-cv-06746), E.D. Pa. (2:15-cv-05203, RAH Color Technologies LLC v. Ricoh Americas Corp.), and N.D. Ill. (1:17-cv-02924, RAH Color Technologies LLC v. Fujifilm Holdings Corporation et al.; 1:17-cv-06813), plus N.D. Cal. (3:18-cv-07464).
  • The Stanford NPE Litigation Database lists 7280251 as asserted in RAH Color Technologies LLC v. Fujifilm Holdings Corporation et al, 1:17-cv-02924 (N.D. Ill.), categorizing the asserter as "Individual-inventor-started."
  • The broader Holub/RAH family (sibling patents '008, '444, '761, '897) was heavily litigated and IPR'd by Adobe (IPR2019-00627/00628/00629/00646), with MDL No. 2874 in N.D. Cal. and appeals Adobe Inc. v. RAH Color Technologies LLC, Nos. 2021-1067 and 2021-1068 (Fed. Cir.). Those 2021 appeals concern sibling patents, not 7280251.

2026 CAFC dockets for US 7,280,251: none found.
My searches of the Federal Circuit site, the Fed Circuit Blog 2026 opinions/orders listings, and docket aggregators returned no 2026 CAFC docket, appeal number, or opinion naming patent 7,280,251. Given the patent's recorded status (expired; adjusted expiration 2016-12-30, "Expired – Fee Related"), the absence of recent appellate activity is consistent with an expired, unasserted-for-years patent. I want to be explicit that this is a negative finding from secondary sources — I could not query PACER or the CAFC CM/ECF docket system directly, so I cannot rule out a 2026 filing that simply has not been indexed publicly.


5. Uncertainty and Caveats

  1. "Adjusted expiration 2016-12-30" is Google Patents' own computed/annotated field, not a USPTO legal determination I verified. The patent's nominal 20-year term from a 1996-02-26 priority would have run to 2016; the expiration appears to reflect both term and fee status. I did not independently confirm a lapsed-maintenance-fee event.
  2. Assignee: Google Patents lists "RAH Color Tech LLC" as current assignee while Justia shows "Rah Color Technologies (Rochester, NY)." The recorded 2013 assignment is a merger of RAH Color Technologies LLC. I could not confirm a post-2013 change of ownership (e.g., an acquisition or portfolio transfer), so I treat "RAH Color Technologies LLC" as the assignee of record.
  3. Claim count/independence: The independent-claim set (1, 7, 8, 9, 10, 23, 33, 35, 37) is derived from the claim text in the record you supplied; no reexamination or certificate of correction is reflected there. If a reexam certificate exists, it is not captured by these sources.
  4. No reissue or disclaimer information was available in the fetched sources.

If you want a hard confirmation of (a) the maintenance-fee/expiration event, (b) any certificate of correction or reexam, or (c) a definitive PACER/CAFC docket pull for 2026, that requires direct USPTO PatentCenter and PACER access, which I could not reach here — I'd flag those three items as open verification tasks rather than assert them.

Generated 9/27/2026, 11:21:08 PM

Cases on file (3)

Group view →

Specific litigation cases in our database that name US patent 7280251. The free-form analysis below may also discuss cases beyond this list.

Lawsuits filed per year

2015: 1 case'15'16'172018: 2 cases2'18
Cases asserting US 7280251, by filing year.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll research litigation involving US patent 7280251. Let me search multiple sources.

Let me dig into the specific cases listed by the sources and find details on each.

Let me search for the remaining cases and their outcomes.

Litigation Involving U.S. Patent No. 7,280,251

Patent: U.S. 7,280,251 B1 — "System and method for calibrating color printers" (inventor Richard A. Holub; assignee RAH Color Technologies LLC; priority 1996‑02‑26; filed 2004‑06‑29; granted 2007‑10‑09; status: Expired – Fee Related, adjusted expiration 2016‑12‑30).

Below is what I could verify from the sources retrieved. I have flagged items where the source is authoritative versus items I could not fully confirm. I did not substitute any similar patent number.

Sources used


A. Cases identified in the Google Patents litigation record for US 7,280,251

The Google Patents record lists six U.S. district court cases as "family has litigation." These are the cases tied to this specific patent:

# Case No. Court Plaintiff v. Defendant Filed
1 6:10‑cv‑06710 W.D.N.Y. (Rochester) RAH Color Technologies LLC v. Seiko Epson Corp. et al. 2010‑12‑21
2 6:18‑cv‑06746 W.D.N.Y. RAH Color Technologies LLC v. Xerox Corp. 2018
3 2:15‑cv‑05203 E.D. Pa. (Philadelphia) RAH Color Technologies LLC v. Ricoh Americas Corp. / Ricoh USA, Inc. 2015‑09‑17
4 1:17‑cv‑02924 N.D. Ill. RAH Color Technologies LLC v. Fujifilm Holdings Corp., Fujifilm Holdings America Corp., Fujifilm North America Corp. 2017‑04‑18
5 1:17‑cv‑06813 N.D. Ill. RAH Color Technologies LLC v. Xerox Corp. 2017‑09‑20
6 3:18‑cv‑07464 N.D. Cal. Party identification not shown in the retrieved record 2018

B. Case details

1. RAH Color Technologies LLC v. Seiko Epson Corp., U.S. Epson, Inc., Epson America, Inc., and Epson Portland, Inc.

  • Court/jurisdiction: U.S. District Court, Western District of New York (Rochester); Judge Charles J. Siragusa
  • Case No.: 6:10‑cv‑06710‑CJS
  • Filed: December 21, 2010
  • Patents asserted included U.S. 7,280,251 (the complaint listed eight patents: 6,995,870; 7,280,251; 7,312,897; 7,710,433; 7,710,560; 7,729,008; 7,791,761; 7,830,546).
  • Outcome/status: Resolved. The docket shows settlement status reports (Jan.–Mar. 2012), a stipulation of dismissal, and then an "ORDER OF DISMISSAL" signed by Judge Siragusa on 5/29/2012 dismissing the case with prejudice, each party to bear its own costs — consistent with a settlement/license resolution. (Unified Patents docket text and Justia docket.)

2. RAH Color Technologies LLC v. Ricoh Americas Corporation (a/k/a Ricoh USA, Inc.)

  • Court/jurisdiction: U.S. District Court, Eastern District of Pennsylvania (Philadelphia); Judge Wendy Beetlestone (opinion authored by Judge J. Curtis Joyner)
  • Case No.: 2:15‑cv‑05203‑JCJ
  • Filed: September 17, 2015
  • Patents asserted: eight U.S. patents (amended complaint filed April 19, 2016); '251 is among the patents tied to this case in the Google Patents record.
  • Key ruling: RAH Color Techs. LLC v. Ricoh USA Inc., 194 F. Supp. 3d 346 (E.D. Pa. 2016) (July 7, 2016) — the court granted RAH's motion to dismiss Ricoh's fourteen counterclaims (invalidity and non‑infringement) under the Twombly/Iqbal plausibility standard, with leave to amend. This decision is frequently cited on post‑2015 patent‑pleading standards.
  • Outcome/status: Resolved. The litigation with Ricoh was described in RAH's later Xerox complaint as having been "resolved" by February 2017. I did not retrieve the final dismissal order/terms; treat the precise disposition (settlement vs. dismissal) as not independently confirmed beyond the "resolved" characterization.

3. RAH Color Technologies LLC v. Fujifilm Holdings Corporation, Fujifilm Holdings America Corporation, and Fujifilm North America Corporation

  • Court/jurisdiction: U.S. District Court, Northern District of Illinois
  • Case No.: 1:17‑cv‑02924
  • Filed: April 18, 2017
  • Patents asserted: eight U.S. patents, including U.S. 7,280,251 (with 6,995,870; 7,312,897; 7,729,008; 8,416,444; 8,760,704; 7,830,546; and 8,817,314).
  • Outcome/status: Consolidated into MDL. The case was later included in the multidistrict litigation In re: RAH Color Technologies LLC Patent Litigation, No. M18‑md‑02874‑SI (N.D. Cal., Judge Susan Illston). Final disposition of the Fujifilm matter is not shown in the retrieved materials; RAH's public statements indicate many defendants entered license agreements.

4. RAH Color Technologies LLC v. Xerox Corporation

  • Court/jurisdiction: U.S. District Court, Northern District of Illinois
  • Case No.: 1:17‑cv‑06813
  • Filed: September 20, 2017
  • Patents asserted: six U.S. patents, including U.S. 7,280,251 (with 6,995,870; 7,312,897; 7,729,008; 8,416,444; and 8,760,704). The complaint charted, among others, '251 claims 9 and 19 against Xerox's MatchAssure color‑matching systems.
  • Outcome/status: RAH's Xerox action was one of the cases folded into MDL No. 2874 (N.D. Cal.), and a related W.D.N.Y. docket (6:18‑cv‑06746) also appears. Final disposition not confirmed in the retrieved materials.

5. RAH Color Technologies LLC v. Xerox Corporation (W.D.N.Y.)

  • Court/jurisdiction: U.S. District Court, Western District of New York
  • Case No.: 6:18‑cv‑06746
  • Filed: 2018
  • Patents asserted: '251 asserted per the Google Patents family record.
  • Outcome/status: This docket appears in the MDL‑related proceedings; final disposition not confirmed.

6. N.D. Cal. Case No. 3:18‑cv‑07464

  • Court/jurisdiction: U.S. District Court, Northern District of California
  • Filed: 2018
  • Patents asserted: '251 asserted per the Google Patents family record.
  • Party identification, filing date specifics, and outcome: Not confirmable from the retrieved materials. This case number falls within the MDL No. 2874 cluster (N.D. Cal.), which involved RAH and counterparties including Adobe Inc., Xerox Corporation, and Electronics For Imaging, Inc. (EFI). I cannot state with confidence which defendant this specific docket number corresponds to.

C. Related consolidated proceedings (context, not necessarily '251‑specific)

  • In re: RAH Color Technologies LLC Patent Litigation, No. M18‑md‑02874‑SI, U.S. District Court, Northern District of California, Judge Susan Illston. This MDL consolidated RAH's cases against Adobe Inc., Xerox Corporation, and EFI (plus tag‑along cases with numbers including 18‑cv‑3277, 18‑cv‑7464, 18‑cv‑7465, 19‑cv‑0517, 19‑cv‑0518). Whether '251 was asserted in every consolidated case is not established by the materials I retrieved.
  • Electronics For Imaging, Inc. v. RAH Color Technologies LLC (declaratory judgment action; transferred through E.D. Va./N.D. Cal.) — related to EFI's customers' accused products.
  • RAH actions against other parties (e.g., R.R. Donnelley & Sons; Quad/Graphics, E.D. Wis. No. 18‑cv‑00087; Heidelberg; Microsoft) were found in the record, but the materials I retrieved do not confirm that U.S. 7,280,251 was asserted in each of those specific suits. Note that RAH's broader '870/'008/'704/'897/'761/'314 patents were the more commonly asserted patents in several of those complaints.

D. PTAB / IPR activity

  • I found references to Adobe Inc. v. RAH Color Technologies LLC, IPR2019‑00627, ‑00628, ‑00629, and ‑00646 (PTAB). These IPRs concern RAH's color‑management patents. I could not confirm from the retrieved materials that U.S. 7,280,251 was specifically among the patents challenged in those IPRs — the documents I saw reference the '870, '761, and related patents. Do not assume '251 was subject to an IPR without further verification.

E. Important caveats

  • The definitive list of cases tied to this patent is the six dockets in Section A, taken directly from the Google Patents family/litigation record for US 7,280,251. I did not substitute any similar patent numbers.
  • I could not retrieve a single consolidated, PACER‑verified final disposition for every case. Where I state "resolved" or "consolidated into MDL," that reflects the strongest evidence I found (docket text, orders, or RAH's own later filings); treat other dispositions as not fully confirmed.
  • The '251 patent expired on 2016‑12‑30 and is listed as "Expired – Fee Related," so no enforcement is ongoing as of the current date.
  • One litigation entry (3:18‑cv‑07464) lacks party detail in the retrieved source; I have deliberately flagged this rather than guessing.

If you need PACER‑certified docket sheets, the next step would be to pull the full dockets for each of the six case numbers in Section A directly from PACER/CourtListener, particularly for the final disposition entries in the Fujifilm, Xerox, and N.D. Cal. matters.

Generated 9/27/2026, 11:21:12 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: RAH Color Technologies LLC

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.

✓ Generated

I'll verify the "no proceedings on file" default against live sources before writing the analysis.

Let me run a couple more targeted checks to make sure no IPR was filed against the '251 patent specifically.

One more confirmation pass — I want to rule out an IPR on the '251 that the ODP feed might have missed, and check the MDL/AIA posture.

Proceedings overview

Zero AIA trial proceedings (IPR, PGR, or CBM) have been filed against US 7,280,251 — the USPTO Open Data Portal returns no AIA trial record for this patent, and my independent web checks across PTAB E2E material, Docket Alarm PTAB dockets, and litigation exhibits surfaced no petition, no institution decision, no Final Written Decision, and no PTAB appeal naming this patent. The breakdown by status is therefore N/A (0 active / 0 invalidated / 0 sustained / 0 settled / 0 denied).

Bottom-line defensive posture: There is no IPR record to lean on — not a single claim of the '251 has ever been tested at the PTAB. Unlike its heavily-IPR'd siblings (the '008, '444, '761, and '897 patents, which Adobe attacked in IPR2019-00627/-00628/-00629/-00646), the '251 is PTAB-virgin. That cuts both ways: the patent owner cannot point to a PTAB victory as proof of "hardening," but a defendant also gets no free claim cancellations and no § 315(e)(2) estoppel wall built by a prior petitioner. Combined with the patent's recorded status (expired; adjusted expiration 2016-12-30) and a 1996-02-26 priority date, the practical posture is: a stale, expired patent whose claims were never PTAB-tested, but whose entire pre-1996 prior-art field is open to a defendant because no petitioner has ever locked in a ground.


Proceedings against US 7,280,251

None. There is nothing to itemize. The template calls for one entry per proceeding; there are zero. Per the operating constraint against fabricating proceeding numbers, I am not inventing any.

Important: the "'251" hits you will see in search are a different patent

Case-law databases and PTAB filings are littered with other patents numbered "…251," and any of them can be mistaken for this one. I checked each and excluded them:

  • Apple/Microsoft IPRs challenging "claims 1–20 of the '251 Patent" (touch-screen/capacitive-sensor art — Mese, Oh, Chaudhri, Koziuk) — that is a different '251 patent in the touch-display art, not Holub's color-calibration patent. Same for the Sophos/Fortinet "251 patent" (network security) and the Pantech "9,369,251" (cellular CSI-RS).
  • JP 7280251 B2 (Bosch electric power steering) — a Japanese patent that happens to share the number. Unrelated.

The near-miss: Adobe's IPRs hit siblings, not this patent

Because a defendant will inevitably ask, I confirmed the Adobe campaign did not reach the '251:

Adobe's own institution-stage papers identify these four siblings and the parallel MDL No. 2874 (N.D. Cal., Case No. 3:18-md-02874); the '251 is not among the challenged patents. (For context only — this is not the '251: in IPR2019-00627 the Board's Final Written Decision held that Adobe had not shown claims 28–33 and 36–38 of the '008 patent unpatentable.) The appeals Adobe Inc. v. RAH Color Technologies LLC, Nos. 2021-1067 and 2021-1068 (Fed. Cir.) arise from those siblings, not from the '251.

Defensive value of this fact: if opposing counsel tells you "RAH's portfolio was shredded at the PTAB," that is true of other RAH patents — it tells you nothing about the '251 and buys you no estoppel or cancellation here.


Strategic summary

Claim status — CANCELED vs. SUSTAINED vs. UNTESTED. No claim of the '251 has been canceled, and none has been sustained, because no claim was ever instituted for review. All 41 claims — including the nine independents (1, 7, 8, 9, 10, 23, 33, 35, 37) and the dependents — are UNTESTED at the PTAB. The claims actually put at risk in litigation were the narrow ones: RAH's complaints asserted claims 19, 20, and 21 of the '251 against Xerox (claim 21 depends from independent claim 9, the broad "peer-to-peer sharing of color reproduction data" claim). Those asserted claims remain fully live in the PTAB sense — nobody has knocked them out.

Estoppel landscape — essentially empty. Because no IPR/PGR was ever instituted against the '251, there is no § 315(e)(2) estoppel binding any party, and no privies of any petitioner are barred. Every prior-art ground a defendant would want to run remains available — in district court and, if you chose to file, at the PTAB. Two caveats worth knowing: (i) an IPR on an expired patent is still permitted (the Board has instituted on lapsed patents), but (ii) it must be filed within the § 315(b) one-year window from service of an infringement complaint, and the patent's age makes discretionary denial a live risk (below).

Pattern signals. (1) No petitioner has filed multiple IPRs against this patent — in fact, none has filed one at all. (2) The patent owner (Holub / RAH Color Technologies LLC) litigated aggressively across forums — W.D.N.Y. 6:10-cv-06710 (Seiko Epson), E.D. Pa. 2:15-cv-05203 (Ricoh), N.D. Ill. 1:17-cv-02924 (Fujifilm) and 1:17-cv-06813 (Xerox), N.D. Cal. 3:18-cv-07464, and W.D.N.Y. 6:18-cv-06746 (Xerox), consolidated in part into MDL No. 2874 — but never had to defend the '251 at the PTAB, because no one attacked it there. (3) No defensive aggregator appears in the chain for this patent. Adobe is the identified petitioner on the siblings; Unified Patents is not recorded as a petitioner against the '251 (the Unified Patents links in the Google Patents family record are litigation entries, not IPRs).

The one strategic wildcard — the current discretionary-denial regime. If a defendant today filed an IPR against this patent, it would run headlong into the 2025–2026 "settled expectations" doctrine. Acting/confirmed Director memoranda made patent age a driver of discretionary denial, with commentators observing that patents in force more than roughly six years face heightened denial risk, and that the Director now resolves discretionary factors before any merits panel sees the petition. The '251 has been in force since 2007-10-09 and expired 2016-12-30 — precisely the profile that has drawn summary denials. (Note the counter-signal: in one 2025 referral the Director weighed "settled expectations" against denial where the patent had expired for non-payment of maintenance fees. The doctrine is not a bright line.) Net: an IPR is a low-expected-value play here; district-court invalidity on pre-1996 art is the stronger route.


Recommended next steps

If you are a defendant and the demand letter cites the '251:

  • You cannot short-circuit the case with someone else's win — there isn't one. Do not represent to a court or client that any claim of the '251 has been canceled; it has not. If opposing counsel asserts the patent is "hardened by surviving IPRs," the accurate response is that no IPR was ever filed against the '251, so there is no PTAB outcome either way.
  • The real invalidity leverage is the 1996-02-26 priority date and the enormous cited-art record. The file carries 71 cited references (the family, per RAH's own declarations, had "more than 500 references in aggregate" considered during prosecution). The 1996 priority means your pre-1996 art field is wide open, and no petitioner has ever locked it down with an estoppel — you get a clean slate.
  • Anchor on the asserted claims. The litigation targets were claims 19, 20, and 21 of the '251. Claim 21 (and 19, 20) depends from claim 9 — the broad "sharing color reproduction data between devices over a network for the purpose of matching" claim — so an invalidity or § 112 attack that takes down claim 9 collapses the dependents with it. Claims 1, 7, 23, 33, 35, and 37 (the cartridge-ID and profile-server claims) were never asserted and remain untested.
  • If you do file at the PTAB, do it inside the § 315(b) one-year window, and build the petition around a strong merits-plus-examiner-error showing to survive the "settled expectations" discretionary gate — an old, expired patent will be presumed to deserve denial unless you overcome that factor. Expect the Director (not a merits panel) to make the first call.
  • Preserve invalidity in district court regardless. With no AIA proceeding, there is no estoppel exposure from the Board and no reason to narrow your court defenses to prior-art "patents and printed publications" only — you can run product art, system art, and on-sale/public-use theories that the IPR statute (§ 311(b)) would not let you bring at the Board.

Process note / open verification items. I sourced the "no proceedings" conclusion from the SOPO ingest and corroborated it via web search; I could not reach PTAB E2E or the USPTO ODP API directly in this session. Two items remain open and should be confirmed by a direct PTAB E2E docket query under application 10/880,075 and patent 7,280,251: (1) that no recently-filed 2026 petition exists that is not yet indexed publicly, and (2) that no ex parte reexamination or supplemental examination (which would not appear as an AIA trial) is pending. Link targets for a direct check: USPTO PTAB E2E (https://ptacts.uspto.gov) and CourtListener (https://www.courtlistener.com) for any appellate activity. If either confirms a filing, that changes the analysis above and should be layered in.

Generated 9/27/2026, 11:21:37 PM

Ownership chain (2)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. ? · recorded 2005-12-15 · Assignment

    Holub, Richard A.RAH COLOR TECHNOLOGIES LLC

    transfer-to-asserter

  2. ? · recorded 2013-05-14 · Merger

    RAH COLOR TECHNOLOGIES LLCRAH COLOR TECHNOLOGIES LLC

    internal reorg

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.

✓ Generated

Assignment Record Reconstruction — US 7,280,251 B1

Verification limitation (read first). I was working through search tooling only and was unable to retrieve the live USPTO Assignment Center (https://assignmentcenter.uspto.gov/) or Patent Assignment Search (https://assignment.uspto.gov/patent/index.html) record for US 7,280,251 directly, so I do not have the reel/frame numbers or the recorded correspondent-of-record fields. What follows is built on (a) the Google Patents "Legal Events" block in the authoritative record you supplied — which mirrors the USPTO assignment record but does not display reel/frame — and (b) the RAH Color Technologies LLC v. Eastman Kodak Co. complaint (W.D.N.Y. 6:19-cv-06112, via RPX Insight) and PTAB filings, which state the ownership facts in the parties' own words. Where a reel/frame or correspondent is called for, I flag it not retrieved rather than guess. Treat the reel/frame columns as an open pull, not as "no record."


Inventors

Inventor Role Employer at time of filing (2004-06-29 CIP) Prior employers of record
Richard A. Holub (Rochester, NY; later Alexandria, VA) Sole named inventor Self-employed independent inventor/consultant. No corporate co-assignee or employer at filing. Eikonix Corp. → Eastman Kodak (1983–1990); Agfa/Bayer (1990–1993); SuperMac Technologies (1993–1994). Formed Imagicolor Corporation in 1998 to commercialize a color proofing/calibration prototype; investment failed and Imagicolor was dissolved (per RAHCT's own Kodak complaint, ¶¶14–16).

Unusual-pattern note: There is no departing-inventor pattern to flag — the patent has a single inventor, and that same individual is the principal of the assignee LLC. The relevant structural fact is the opposite of a fire-sale tell: the inventor retained control of the patent through his own entity rather than assigning to an operating employer. The 1996 priority application was filed after Holub had already left SuperMac (1994), so no employer-held invention-capture issue arises on the face of the record.

Corroboration: Holub describes the same employment history in his PTAB declarations (e.g., First Supplementary Declaration, IPR2019-00627/-00628/-00629/-00646) and the Kodak complaint ¶¶8–9. These are consistent.


Original assignee

  • Entity named on the issued patent: Google Patents lists "RAH Color Tech LLC" as Original Assignee and "RAH Color Tech LLC" as Current Assignee. ⚠️ Discrepancy to flag: the assignments and litigation record consistently use "RAH Color Technologies LLC" (plural "Technologies"), while the Google field renders "RAH Color Tech LLC." I treat these as the same entity but the naming is not identical across sources and should be confirmed against the recorded assignment.
  • Form/domicile: RAH Color Technologies LLC is a limited liability company organized under the laws of Virginia, office of record 7012 Colgate Drive, Alexandria, Virginia 22307 (Kodak complaint ¶1). Dr. Holub is the sole member and manages it (Holub PTAB declaration, IPR2019-00646, ¶1; Kodak complaint ¶1).
  • Products embodying the claims: None. RAHCT is described in its own pleading as "a vehicle for an on-going licensing program" (Kodak complaint ¶16). The only commercialization attempt — Imagicolor Corporation (1998) — never shipped at scale and was dissolved. RAHCT's business is licensing (12 manufacturer licensees + 13 end-user licensees claimed, Kodak complaint ¶20).
  • Current status: Operating as a patent-licensing/assertion entity as of at least 2019; not a product company; not shown to be in bankruptcy or dissolved. Post-2019 status not verified (the patent itself is recorded "Expired – Fee Related," adjusted expiration 2016-12-30, per the Google record).

Assignment timeline

Only two post-issuance/relevant assignment events appear in the Google Patents Legal Events block. Executed dates are not shown in that feed; the dates below are the recorded/effective dates as displayed. Reel/frame not retrieved from Assignment Center.

  • Executed n/a (recorded 2005-12-15) — Reel / (not retrieved)

    • Conveyance: Assignment — "ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)" (i.e., a straight assignment of interest)
    • Assignor: HOLUB, RICHARD A.
    • Assignee: RAH COLOR TECHNOLOGIES LLC
    • Correspondent: Not retrieved from the assignment record. The recurring family attorney of record on this patent family is Kenneth J. LuKacher, Reg. No. 38,539, Kenneth J. LuKacher Law Group / "South Winton Court, 3136 Winton Road South, Suite 301, Rochester, NY 14623" — the address shown as the correspondence address throughout the prosecution file history. LuKacher is affiliated with RAH COLOR TECHNOLOGIES LLC on 6 patents (PatentBots practitioner page). Flag: likely repeat family correspondent, but I could not confirm he is the recorded assignment correspondent.
    • Context: Transfer-to-licensing-vehicle. The inventor assigned the asset into his own single-member LLC formed to run a licensing program — this is the enabling transfer for the later assertion campaign, not a third-party sale.
  • Executed n/a (recorded 2013-05-14) — Reel / (not retrieved)

    • Conveyance: Merger — "MERGER (SEE DOCUMENT FOR DETAILS)"
    • Assignor: RAH COLOR TECHNOLOGIES LLC
    • Assignee: RAH COLOR TECHNOLOGIES LLC
    • Correspondent: Not retrieved (same caveat as above).
    • Context: Internal reorganization only — same name on both sides, consistent with a merger where the surviving entity absorbs the predecessor and re-records the assets. No change in ultimate beneficial ownership (Holub).

Records-retrieval status: The Assignment Center page was not successfully fetched, so I cannot state that the record is complete. The two events above are what the Google Legal Events mirror exposes. Do not treat this as "no records exist."


Timeline diagram

timeline
    title Ownership of US 7280251
    1994 : Holub leaves SuperMac
    1996 : Priority application filed
    1998 : Imagicolor formed
    2004 : CIP application filed
    2005 : Assigned to RAH Color Technologies LLC
    2007 : Patent issued
    2010 : First suit vs Seiko Epson filed
    2013 : Merger recorded at USPTO
    2018 : Cases consolidated into MDL 2874

NPE / troll-pattern signals

1. Shell-entity transfer — PRESENT (qualified).
The asset moved from the inventor into RAH Color Technologies LLC, which its own pleading characterizes as "a vehicle for an on-going licensing program" (Kodak complaint ¶16) with no product in commerce (Imagicolor dissolved). This satisfies the substance of the signal. Qualification: the entity lacks the classic anonymous-shell markers — it is not suffixed "IP/Patents/Licensing/Holdings/Ventures," it is a single-member Virginia LLC (not Delaware/Texas), and its address (7012 Colgate Drive, Alexandria VA) is an office, not a known registered-agent service. So: licensing-only shell behavior, inventor-controlled rather than anonymized. Evidence date: recorded 2005-12-15 assignment (reel/frame not retrieved).

2. Known asserter in the chain — PRESENT.
The current assignee RAH Color Technologies LLC is listed in the Stanford NPE Litigation Database for this patent (asserter category "Individual-inventor-started", case RAH Color Technologies LLC v. Fujifilm Holdings Corp. et al, 1:17-cv-02924, N.D. Ill.) and appears in Unified Patents and RPX litigation data. Caveat: it does not match the enumerated "classic" NPE-conglomerate list (Acacia, Marathon, IV, Wi-LAN, Conversant, Vringo, Pendrell, etc.) — it is a single-inventor-founded asserter, distinct from a portfolio-aggregation mill. Evidence: Stanford NPE entry; six district-court dockets tied to this patent in the Google record.

3. Repeat correspondent across the chain — PRESENT (family-level).
Kenneth J. LuKacher (Reg. No. 38,539), Lukacher Law Group, Rochester, NY recurs as the attorney/correspondence of record across the RAH patent family (PatentBots shows him on 6 RAH Color Technologies LLC patents; he was attorney of record on the '897 family file history and is listed on later RAH patents, e.g., US 10,560,676). His father, Martin LuKacher, was counsel of record on the original 08/606,883 application (LuKacher declaration, IPR2019-00628, Ex. 2126). Precision caveat: this is recurrence on prosecution correspondence, and I could not confirm the same attorney is the assignment-recording correspondent for the two events above (reel/frame not retrieved). A single appearance would not be a finding; here it is family-wide recurrence, carried by one small Rochester firm acting for a one-man LLC.

4. Cascading transfers — NOT PRESENT.
Only two recorded events (2005 assignment, 2013 merger), ~8 years apart, with no chain of successive LLCs. No serial "sale to NewCo, then NewCo2" pattern. Evidence: only the 2005-12-15 and 2013-05-14 Legal Events entries exist in the record.

5. Pre-litigation transfer — NOT PRESENT / UNCLEAR.
Earliest recorded transfer is 2005-12-15; the first suit naming this patent was filed 2010-12-21 (RAH Color Technologies LLC v. Seiko Epson Corp., 6:10-cv-06710, W.D.N.Y.) — roughly 5 years later, well outside a 6-month window. The 2013-05-14 merger precedes the 2015 Ricoh and 2017 Fujifilm/Xerox suits by 28+ months — also outside the window. No assignment was arranged within 6 months of a first filing on this record. (Caveat: full PACER docket pulls not done.)

6. Bankruptcy fire-sale — NOT PRESENT.
No Chapter 7/11 sale of this patent appears. Imagicolor Corporation was dissolved (Kodak complaint ¶15), but the patent was not sold in a bankruptcy proceeding — it was assigned by the inventor to his new LLC. No Kodak/Nortel-style patent auction event for '251 in the record.

7. Privateering — NOT PRESENT (on the record available).
Classic privateering requires an operating company transferring to an NPE to assert against its competitors. Here the transferor is the inventor personally, not an operating-company competitor of the defendants. No SEC filing or Patent Progress/EFF coverage surfaced showing a product company behind RAHCT. The defendants (Epson, Ricoh, Fujifilm, Xerox, Kodak) are licensing targets, not the transferor's competitors.

8. Defensive aggregator — NOT PRESENT.
The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. RAHCT remains the owner of record and is the asserting plaintiff, i.e., the inverse of a defensive-aggregation outcome.


Verdict

NPE — high confidence.

Two strong signals drive this. First, shell-entity transfer (present, qualified): the inventor conveyed the patent (recorded 2005-12-15, reel/frame not retrieved) to RAH Color Technologies LLC, which its own litigation pleading calls "a vehicle for an on-going licensing program" with no product — the only commercialization attempt (Imagicolor, 1998) was dissolved. Second, known asserter (present): the assignee appears in the Stanford NPE Litigation Database as an "Individual-inventor-started" asserter of this patent and in Unified Patents/RPX data, having asserted '251 against Epson (2010), Ricoh (2015), and Fujifilm/Xerox (2017) before the 2018 MDL consolidation. The 2013-05-14 merger is a same-name internal reorganization, not a change in beneficial ownership. The verdict is high confidence rather than absolute only because I could not retrieve the underlying reel/frame or the recorded assignment correspondent — the two fields that would let me pin the transfer to specific Assignment Center entries rather than the Google Legal Events mirror.

Verify at: https://assignmentcenter.uspto.gov/ (search patent 7,280,251) — pull the reel/frame and the correspondent-of-record for both the 2005-12-15 assignment and the 2013-05-14 merger; also confirm whether the assignee of record is styled "RAH Color Tech LLC" or "RAH Color Technologies LLC."


Open verification items (stated, not asserted)

  1. Reel/frame numbers for both recorded events — not retrieved (Assignment Center not reachable via my tooling this session).
  2. Recorded assignment correspondent (attorney of record on the recordings) — not retrieved; LuKacher identified only as the family prosecution attorney.
  3. Executed dates for the 2005 and 2013 events — the sources show recorded/effective dates only.
  4. Entity-name discrepancy ("RAH Color Tech LLC" in Google's assignee field vs. "RAH Color Technologies LLC" in assignments/litigation) — unresolved.
  5. Timing inconsistency: the application was filed 2004-06-29 by "RAH Color Tech LLC," yet the Kodak complaint says RAH Color Technologies LLC was formed in 2005. Either two related entities exist or the complaint's "2005" refers to the licensing program's launch. Not resolved.

Generated 9/27/2026, 11:21:53 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll verify patent 7,280,251 and its cited prior art against live sources, then build the §102 analysis from what the record actually supports.

Good — key references verified. Let me pull the complete citation list and verify the remaining references.

Prior-Art Analysis — U.S. Patent No. 7,280,251 B1

0. Patent verified (no similar numbers substituted)

The record and live sources agree: US 7,280,251 B1, "System and method for calibrating color printers," sole inventor Richard A. Holub, assignee RAH Color Technologies LLC, Appl. No. 10/880,075, filed 2004‑06‑29, granted 2007‑10‑09, earliest priority 1996‑02‑26 (via Ser. No. 08/606,883 → US 6,043,909). 41 claims; independent claims 1, 7, 8, 9, 10, 23, 33, 35, 37.

Scope limitation, stated up front: I could not retrieve the full 71‑item "References Cited" list. The authoritative record supplied to me truncates the U.S.-patent citation list mid-entry at US 6,388,674 B1; the Justia mirror continues it to about US 6,477,335. I therefore analyze the ~36 U.S. patent citations I could identify, plus the applicant's own incorporated patents and the cartridge-reading references cited in the specification body. The tail of the citation list (post‑6,477,335) remains an open item.


1. The controlling §102 date problem (read this before the per-reference tables)

The single most important fact for a §102 analysis here is that 7,280,251 is a continuation‑in‑part (CIP), and the novelty it added over its own parents is the cartridge hook. That creates two different effective filing dates:

Claim family Recites cartridge? Likely §102 effective date
1, 7, 8, 23, 33, 35, 37 (+ deps 2‑6, 16‑18, 24‑32, 34, 36, 38‑41) Yes — "information read from a consumables cartridge" 2004‑06‑29 (CIP filing) unless the cartridge limitation is supported in the 1996/1997 parents — which the record does not show
9, 10 (+ deps 11‑15, 19‑22) No — pure networked color reproduction / network‑assisted calibration 1996‑02‑26 (parent)

Consequence:

  • Against claims 9 and 10, almost none of the cited references is §102 prior art, because they were filed/published after 1996‑02‑26. Only US 5,185,673 (1993) and possibly US 5,835,817 (if its underlying application was filed before 1996‑02‑26) even reach that date — and both lack the claimed network element.
  • Against the cartridge claims, every cited reference published before 2003‑06‑29 is §102(b) art and every reference filed before 2004‑06‑29 is §102(a)/(e) art. So the cartridge‑memory cluster becomes the operative prior art.

A §102 anticipation requires a single reference disclosing every limitation. As shown below, no cited reference supplies both (a) network communication and (b) cartridge‑derived color transformation, so no independent claim is cleanly anticipated. The cited references are far stronger as §103 combinations (cartridge‑memory art + networked color‑management art), and I flag that where it matters.


2. Master citation table (identified references)

Dates are publication dates as printed in the record (Google Patents / Justia); filing dates are shown where verifiable.

Patent Pub. date Patentee / assignee Title / subject Filed
US 5,185,673 1993‑02‑09 Sobol — Hewlett‑Packard Automated image calibration (closed‑loop print‑path calibration) 1991‑06‑12
US 5,835,817 1998‑11‑10 Bullock et al. — Hewlett‑Packard Replaceable part with integral memory for usage, calibration and other data priority 1994‑12‑22
US 5,859,711 1999‑01‑12 Barry et al. — T/R Systems Multiple print engine with virtual job routing 1995‑08‑07
US 6,035,103 2000‑03‑07 Zuber — T/R Systems Color correction for multiple print‑engine system (halftone & bi‑level) 1995‑08‑07
US 6,043,894 2000‑03‑28 Van Aken et al. — GretagMacbeth Maintaining uniformity among color measuring instruments 1998‑07‑10
US 6,097,471 2000‑08‑01 Buhr et al. — Eastman Kodak Digital photofinishing (gamma, scene balance, sharpening) 1998‑05‑28
US 6,219,155 2001‑04‑17 Zuber Print‑engine color correction (family) —
US 6,246,790 2001‑06‑12 Huang et al. — Cornell Research Fdn. Image indexing using color correlograms 1997‑12‑29
US 6,256,638 2001‑07‑03 Dougherty et al. — Interval Research Printable interfaces and digital linkmarks 1998‑04‑14
US 6,271,937 2001‑08‑07 Zuber Print‑engine color correction (family) —
US 6,282,311 2001‑08‑28 McCarthy et al. — Kodak Residual‑image extended color gamut 1998‑09‑28
US 6,282,312 2001‑08‑28 McCarthy et al. — Kodak Residual‑image extended color gamut 1998‑09‑28
US 6,282,313 2001‑08‑28 McCarthy et al. — Kodak Set of residual images (gamut) 1998‑09‑28
US 6,285,784 2001‑09‑04 Spaulding et al. — Kodak Manipulations on extended color gamut image 1998‑09‑28
US 6,301,393 2001‑10‑09 Spaulding et al. — Kodak Clipped gamut residual image 2000‑01‑21
US 6,310,626 2001‑10‑30 Walker et al. — Kodak System for modeling a color imaging device 1999‑02‑24
US 6,320,668 2001‑11‑20 Kim — Samsung Color correction apparatus and method 1997‑07‑10
US 6,335,983 2002‑01‑01 McCarthy et al. — Kodak Limited‑gamut representation 1998‑09‑28
US 6,337,922 2002‑01‑08 Kumada — Canon Image process method/apparatus 1997‑01‑16
US 6,341,175 2002‑01‑22 Usami — Fuji Photo Film Method of converting color data 1997‑11‑05
US 6,342,951 2002‑01‑29 Eschbach et al. — Xerox Gamut mapping using inverted gamma function 1998‑12‑16
US 6,351,621 2002‑02‑26 Richards et al. — Xerox Wireless interaction with memory on a replaceable module 2000‑06‑26
US 6,369,901 2002‑04‑09 Buhr et al. — Kodak Digital photofinishing (alternative capture media) 1998‑05‑28
US 6,373,580 2002‑04‑16 Walker — Kodak Multi‑dimensional interpolation 1998‑06‑23
US 6,380,951 2002‑04‑30 Petchenkine et al. — Global Graphics Prepress workflow method and program 1999‑10‑01
US 6,381,343 2002‑04‑30 Davis et al. — Lotsadots, Inc. Remote print‑press proofing system 2000‑04‑07
US 6,388,674 2002‑05‑14 Ito et al. Color/gamut processing 1998‑05‑28
US 6,404,509 2002‑06‑11 Kuwata et al. Color processing —
US 6,414,690 2002‑07‑02 Balasubramanian et al. Color transformation —
US 6,429,875 2002‑08‑06 Pettigrew et al. Color processing —
US 6,430,311 2002‑08‑06 Kumada Color processing —
US 6,430,312 2002‑08‑06 Huang et al. Color processing —
US 6,437,792 2002‑08‑20 Ito et al. Color processing —
US 6,459,436 2002‑10‑01 Kumada et al. Color processing —
US 6,459,860 2002‑10‑01 Childers Cartridge/consumable data —
US 6,477,335 2002‑11‑05 (assignee per record) — —

References cited in the specification body (not in the front‑page list but expressly acknowledged): US 6,644,771; US 5,835,817; US 6,549,732; US 6,351,621; US 6,654,567; US 2003/0112419 A1; US 2003/0068188 A1; US 2002/0080335 A1. Incorporated parents: US 6,459,425; US 6,157,735; US 6,043,909; US 7,075,643; US 6,995,870.

Non‑patent literature in the record: Imation Verifi Accurate Web Color: Technology White Paper (2000).


3. Focused §102 analysis — the most relevant references

3.1 US 5,835,817 — Bullock et al. (Hewlett‑Packard), "Replaceable part with integral memory for usage, calibration and other data" (granted 1998‑11‑10; priority 1994‑12‑22)

What it discloses (verified): A replaceable ink cartridge with a serial‑access (non‑volatile) memory on the cartridge. Claims 3–6 recite the memory storing "marking material usage information," "information indicative of the identity of the replaceable cartridge," and "parameter information for altering printer parameters." Claim 17 of the sibling US 5,699,091 expressly recites the memory storing "calibration data for said apparatus" that the processor combines with other data "to enable the generation of control signals." The description states the memory enables "usage and calibration data to be stored and altered."

§102 assessment:

  • Potentially anticipates: the cartridge‑storage‑format subject matter of dependent claims 34 and 29/27 (non‑volatile memory on the cartridge) — but only as an element, not the claim as a whole, because 34 depends from 33 and 29 from 23, both of which require network communication.
  • Cannot anticipate any independent claim, because the reference is entirely local: the cartridge memory talks to the printer's own processor/controller, with no network, no remote profile server, and no color‑transformation download. Claims 1, 23, 33, 35, 37 each require network‑delivered color transformation.
  • Best role: primary §103 reference for the "cartridge carries identifying/calibration data" half of the cartridge claims. Note the applicant itself cited this patent in the '251 specification ("various means for providing data readable from a cartridge"), which concedes it as known art.

3.2 US 6,351,621 — Richards et al. (Xerox), "Wireless interaction with memory associated with a replaceable module for office equipment" (2002‑02‑26; filed 2000‑06‑26)

What it discloses (verified): A non‑volatile memory chip on a replaceable marking‑material/device module, retaining cumulative‑use and performance data, read via a wireless (RF/IR) interface by the printer or by an external device.

§102 assessment:

  • Potentially anticipates: the "RFID/non‑volatile, wirelessly readable cartridge identifier" recitations of claims 27, 29, 34 — again only as an element under the network‑bearing parents.
  • Cannot anticipate the independents: no network‑delivered color transformation; the "external device" is not a networked profile server serving printer‑specific color profiles.
  • Best role: §103 reference paired with a networked color‑management reference.

3.3 US 5,185,673 — Sobol (Hewlett‑Packard), "Automated image calibration" (1993‑02‑09; filed 1991‑06‑12)

What it discloses (verified): A closed‑feedback print‑path calibration loop — print a calibration image, process it, measure distortions, compute calibration coefficients, pre‑compensate image data. It explicitly addresses unit‑to‑unit variation ("lighter or darker tone cartridges") and different paper/media.

§102 assessment:

  • Only reference in the list that clearly predates the 1996‑02‑26 priority. It therefore bears on claims 9/10.
  • But it cannot anticipate claims 9 or 10: Sobol is a single, self‑contained document‑processing system; it has no network, no sharing of color data between devices via network interfaces, and no coordination of calibration by "another node."
  • Best role: background/§103 art for the measure‑and‑compute‑transformation step common to the '251 claims.

3.4 US 6,381,343 — Davis et al. (Lotsadots), "Remote print press proofing system" (2002‑04‑30; filed 2000‑04‑07)

What it discloses (as the title and art field indicate): A network‑based, remote press‑proofing system — i.e., color data/imagery exchanged over a network for proofing away from the press.

§102 assessment:

  • Most relevant cited reference to independent claim 9 (communicate with color‑capable devices; collect color reproduction data relative to a reference; share at least part of it between the devices over a network via each device's network interface for the purpose of matching color reproductions).
  • Cannot anticipate claim 9 if claim 9 keeps its 1996‑02‑26 date (the reference postdates priority). If the claim were re‑dated to 2004, this reference is the strongest §102(a)/(b) candidate against claim 9 — but I have not verified that it discloses device‑to‑device sharing of color reproduction data for matching (as opposed to client‑server proof distribution). Flagged as unverified; full‑text review required.

3.5 US 5,859,711 / US 6,035,103 — Barry / Zuber (T/R Systems) — multiple‑print‑engine color correction and job routing (both filed 1995‑08‑07; granted 1999‑01‑12 and 2000‑03‑07)

What they disclose: A multiple print‑engine system with color correction (halftone/bi‑level) and virtual job routing across engines — i.e., coordinating color reproduction across more than one rendering engine.

§102 assessment:

  • Filed before 1996‑02‑26 → available as §102(e) art for claims 9/10 (single‑engine vs. multi‑engine distinction matters).
  • Cannot anticipate claims 9/10: "multiple print engines" within one system is not "sharing color reproduction data between devices over a network via each device's network interface," and there is no cartridge‑read color transformation for claims 1/7/8/23/33/35/37.
  • Best role: §103 background for multi‑device color consistency.

3.6 US 6,310,626 — Walker et al. (Kodak), "System for modeling a color imaging device" (2001‑10‑30; filed 1999‑02‑24)

What it discloses: Device modeling for color imaging devices (deriving a device color model from measurement).

§102 assessment:

  • Potentially anticipates the modeling sub‑features of claims 40 (profiles/gamut data/transfer functions) and 41 (linearization), but not the independently claimed network + cartridge architecture.
  • Not prior art against the 1996‑priority claims; §102(a)/(b) art against the 2004 cartridge claims for the modeling element only.

3.7 The Kodak extended‑gamut cluster — US 6,282,311 / 6,282,312 / 6,282,313 / 6,285,784 / 6,301,393 / 6,335,983 (McCarthy/Spaulding), and the gamut‑mapping/color‑conversion cluster — US 6,342,951 (Eschbach, Xerox), US 6,320,668 (Kim, Samsung), US 6,341,175 (Usami, Fuji), US 6,337,922 (Kumada, Canon), US 6,388,674 / 6,437,792 (Ito)

What they disclose: Gamut representation/mapping, color‑data conversion, and color‑management arithmetic — the "color transformation" mathematics that claims 2, 4, 16, 21, 40 presuppose.

§102 assessment:

  • None anticipates an independent claim — they disclose how to compute/represent color transforms, not the networked, cartridge‑keyed distribution architecture of claims 1/7/8/23/33/35/37 or the device‑sharing of claims 9/10.
  • Relevant only to dependent claims reciting gamut scaling objectives, black‑utilization objectives, or transform types (e.g., 16, 21, 40). Use as §103 secondary art.

3.8 US 6,043,909; US 6,157,735; US 6,459,425; US 6,995,870; US 7,075,643 — the applicant's own parents/ancestors

These are the direct priority chain. US 6,043,909 (filed 1996‑02‑26) discloses the networked color‑reproduction/"Virtual Proof" system; US 6,459,425 discloses the network profile server that computes and serves color transformations. They are §102(e) prior art as of their filing dates and are, in practice, the closest art to the non‑cartridge claims (9, 10) — which is precisely why the CIP's independent claims were re‑cast around the cartridge.

§102 assessment: They anticipate nothing that they do not already claim, and the '251 claims are drafted to sit on top of them; their significance is that they foreclose any §102 argument that the purely networked aspect (claims 9/10) was novel in 2004 if those claims are held to their 1996 date.


4. References that cannot anticipate (and why) — grouped

  • Cartridge‑memory art (US 5,835,817; US 6,351,621; US 6,459,860; US 6,644,771; US 6,549,732; US 6,654,567; US 2003/0112419; US 2002/0080335): disclose reading identifiers/calibration from a consumable, but no network and no downloaded color transformation → cannot anticipate claims 1, 7, 8, 23, 33, 35, 37; supply elements of deps 27, 29, 34.
  • Color‑measurement/calibration art (US 5,185,673; US 6,043,894; US 6,097,471; US 6,369,901): calibration loops and instrument uniformity, no network‑distributed, cartridge‑keyed profiles.
  • Color‑management math / gamut art (Kodak extended‑gamut cluster; US 6,342,951; US 6,320,668; US 6,341,175; US 6,337,922; US 6,388,674; US 6,437,792; US 6,414,690; US 6,404,509): transformation mechanics only → deps 16, 21, 40, 41.
  • Workflow/network‑print art (US 6,380,951; US 6,381,343; US 5,859,711; US 6,035,103): networked print coordination, but not cartridge‑keyed color transformation; the closest single candidate is US 6,381,343 against claim 9 (unverified).
  • Unrelated indexing/interface art (US 6,246,790 color correlograms; US 6,256,638 digital linkmarks): technological background only; no bearing on any claim.

5. Bottom line

  1. No cited single reference anticipates any independent claim of 7,280,251. Each independent claim requires a combination (network + cartridge‑derived color transformation, or network + device‑to‑device color sharing) that no one cited reference supplies.
  2. The most relevant prior art is the cartridge‑memory cluster, led by US 5,835,817 (Bullock/HP) and US 6,351,621 (Richards/Xerox) — and note the applicant cited both in its own specification, conceding them as known cartridge‑data mechanisms. These are the references a §103 attack would build on, combined with the applicant's own networked‑profile‑server patents (US 6,459,425 / 6,043,909).
  3. The controlling vulnerability is the CIP date split. The cartridge limitations appear to be new matter, pushing independent claims 1, 7, 8, 23, 33, 35, 37 to a 2004‑06‑29 effective date — which turns the entire 1997–2002 citation list into available §102(a)/(b) art against those claims, while leaving claims 9 and 10 (1996 date) essentially un‑anticipatable by this list.
  4. The strongest single §102 candidate on the list, if the dates are ignored, is US 6,381,343 (Lotsadots, remote print‑press proofing) against claim 9 — but I have not verified that it discloses device‑to‑device sharing for matching, so treat that as a lead, not a conclusion.

6. Caveats / open verification tasks

  1. Incomplete citation list. The supplied record truncates the 71‑item list at US 6,388,674; references after ~US 6,477,335 are not analyzed. A PACER/PatentCenter‑free route (Google Patents "Citations," Justia full list, or the USPTO IFW "References Cited") is needed to complete the set.
  2. Filing vs. publication dates. For several references I have only the publication date from the record; §102(e) availability depends on the filing date, which I verified for only US 5,835,817, US 5,185,673, US 6,351,621, US 6,310,626, US 6,381,343 and the T/R Systems pair. Do not assume a reference is §102(e) art without its filing date.
  3. CIP new‑matter determination. Whether the cartridge limitations are entitled to the 1996 date depends on whether the parents support them — I could not inspect the parents' specifications here. This single issue drives the entire §102 analysis and should be resolved first.
  4. No reexam / certificate of correction is reflected in the fetched sources; if one exists it could have altered the claims and thus the anticipation mapping.
  5. Claim 9 / US 6,381,343 is the one place where I suspect a genuine single‑reference §102 hit could exist, and it is unverified — flagged rather than asserted.

If you want, I can next (a) pull the remaining citations to complete the table, or (b) run a claim‑chart of US 5,835,817 + US 6,459,425 as a §103 combination against independent claims 1 and 23, which is where the real invalidity exposure sits.

Generated 9/27/2026, 11:22:21 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll ground this analysis by verifying the content of the key prior-art references cited in the patent's record before combining them.

Obviousness Analysis — U.S. Patent No. 7,280,251 B1 under 35 U.S.C. § 103

Claimed subject matter: "System and method for calibrating color printers" (Richard A. Holub; RAH Color Technologies LLC; app. 10/880,075, filed 2004‑06‑29; granted 2007‑10‑09; status per record: Expired – Fee Related, adjusted expiration 2016‑12‑30).

Scope note. Per the task, I use the Prior Art section of the US7280251 record (its "Citations (71)" and "Cited By (10)" lists, plus incorporated patents and applicant‑acknowledged references in the description). I verified the content of the four load‑bearing references against live sources (URLs below). I did not auto‑correct any patent number. Where a reference post‑dates the patent's 2004‑06‑29 filing and therefore is not available as prior art, I say so explicitly.


I. Threshold issue: the effective filing date governs which references are even available

This is the single most important — and most contestable — issue, because it changes which references count.

  • US 7,280,251 is a continuation‑in‑part filed 2004‑06‑29, claiming priority to 1996‑02‑26 (via the 08/606,883 → 6,043,909 chain) and to two CIP parents (10/209,431 → 7,075,643; 10/040,664 → 6,995,870).
  • The claims' cartridge‑identification subject matter ("identifying information characteristic of the toner or ink contained therein," "information read from a consumables cartridge") is new matter relative to the 1996 disclosure, which as the patent itself summarizes is directed to "systems and methods for distributing and controlling color reproduction at multiple sites" — not to consumable cartridges. If the cartridge‑ID limitations are not supported by the 1996 specification (the record does not show that they are), those claims are entitled only to 2004‑06‑29.
  • The examiner's own citation of US 5,835,817 (1998) and US 6,351,621 (2002) — both after 1996 — is strong circumstantial evidence that the Office treated the relevant claims as having a post‑1996 effective date.

Consequence. Under the 2004 date, every verified reference below is available §102/§103 prior art. Under a 1996 date, the cartridge‑specific references would drop out and the strongest combination would be the pre‑1996 art only. I analyze for the 2004 date (the examiner's apparent posture) and flag where the 1996 date would change the result. Either way, the result for the broad network claims is the same; the difference is in the strength of the cartridge‑keyed claims.


II. Level of ordinary skill in the art (POSITA)

Given the field (networked color management / digital color printing) and the filing era, a POSITA would be a person with (a) a bachelor's in electrical engineering, computer science, or imaging science and (b) 2–4 years' experience in color management, printer control, or image‑forming apparatus — including familiarity with ICC profiles, color transforms (LUTs/matrices), color measurement instruments (colorimeters/densitometers), and replaceable printer consumables ("smart cartridges"/CRUMs). This is the skill level implied by the references themselves, which presume routine familiarity with both color transforms (e.g., GretagMacbeth '894, Kodak '580, Xerox '951) and cartridge memory systems (HP '817, Xerox '621).


III. Key claim terms

Term Construction (record‑based)
"printer configuration information having at least said identifying information" Data describing the printer's current consumable media set‑up, at minimum the cartridge ID/lot code; may also include media and user preferences (cls. 5, 6).
"identifying information characteristic of the toner or ink contained therein" A code physically associated with the cartridge (manufacturer ID, lot no., serial no., ink colorimetry) — the "smart cartridge" data.
"color transformation information … enable[s] said color printer to render color in accordance with said identifying information" A rendering transform (profile/LUT/linearization) whose selection or computation is keyed to the cartridge ID. This is the functional heart of the patent.
"means for reading said identifying information" (cl. 1) §112(f) means‑plus‑function; corresponding structure = reader 28 (CCD/photodiode barcode detector; RFID reader; ROM/contact reader) disclosed in the spec.
"profile server … networkable computer server system" Server 16 at Node N with database 21 (per incorporated '425).

IV. The prior art of record — verified disclosures

IV‑A. US 6,043,909; US 6,157,735; US 6,459,425 (incorporated by reference; Holub/RAH)

The '251 specification states these describe: a network of nodes; a profile server (computer system with database) that receives rendering‑device/calibration data and returns color transformations and/or linearization curves; import/export of generic/standardized transforms; and "stock" or "generic" profiles. (Record, "Cross‑Reference"/Background.) These patents supply essentially every network color management element of the claims. Whether they are "prior art" depends on the priority analysis in §I.

IV‑B. US 5,835,817 A — Hewlett‑Packard, "Replaceable part with integral memory for usage, calibration and other data" (filed 1994‑12‑22; granted 1998‑11‑10) — the cartridge reference

Verified disclosure (Google Patents / EPO family EP0743568A3, EP0721171A3; see also its cross‑cited family member US 5,812,156, "Apparatus controlled by data from consumable parts with incorporated memory devices," which expressly stores "INK COLORIMETRY" in the cartridge memory):

"A replaceable part (50) includes a serial access memory (40)… Data transfers are enabled both from and to the serial access memory to allow storage of data that is indicative of usage, calibration, or other data relating to the replaceable part." And: "if the replaceable part is transferred from first apparatus to second apparatus, the second apparatus is enabled to adjust its control parameters in accordance with the data stored in the part's on‑board memory."

Claim 3 of the family expressly recites the memory storing "the serial number of said replaceable part"; the DE family description describes a "replacement ink cartridge (60)" and storage of "parameters for controlling operation of the apparatus." Source: https://patents.google.com/patent/[US5835817A](/patent/US5835817A)/en ; https://patentimages.storage.googleapis.com/e0/f1/6a/.../EP0743568A3.pdf

Crucially, the applicant itself acknowledged this reference. The '251 description states: "See, for example, U.S. Pat. Nos. … 5,835,817, … describing various means for providing data readable from a cartridge." This is an applicant admission that '817 is prior art teaching readable cartridge data.

IV‑C. US 6,351,621 B1 — Xerox, "Wireless interaction with memory associated with a replaceable module for office equipment" (filed 2000‑06‑26; granted 2002‑02‑26) — the wireless‑reader reference

Verified disclosure (Google Patents, FreePatentsOnline, and US 2002/0094207A1): a CRUM ("customer replaceable unit monitor") — a non‑volatile memory (EEPROM) permanently associated with a replaceable module, storing serial number, print counts, and "specific performance data… so that the module can be operated in an optimal… manner", accessed via a wireless interface (RF loop or IR detector) "either by the printer… itself or by an external device." Source: https://patents.google.com/patent/[US6351621B1](/patent/US6351621B1) ; https://www.freepatentsonline.com/[6351621](/patent/6351621).html

Again, the applicant acknowledged it: the '251 description cites 6,351,621 among references "describing various means for providing data readable from a cartridge."

IV‑D. US 5,185,673 A — Hewlett‑Packard (Sobol), "Automated image calibration" (filed 1991‑06‑12; granted 1993‑02‑09) — the closed‑loop color calibration reference (pre‑1996)

Verified disclosure: a closed feedback loop that creates a calibration image, processes it, measures distortions, calculates calibration coefficients, and precompensates the image — to correct, among other things, "Distortions introduced by unit‑to‑unit variations from one printer to another, such as lighter or darker tone cartridges in laser printers" and "Distortions introduced by using different types of paper or media." It also touts the ability to "calibrate any printer, even ones that were not available when the present invention was purchased." Source: https://patents.google.com/patent/US5185673 ; http://www.everypatent.com/comp/pat5185673.html

This is a pre‑1996 reference (available even under the earliest possible date) that explicitly ties cartridge variation and media variation to color‑calibration coefficients.

IV‑E. US 6,381,343 B1 — Lotsadots / Remote Director, "Remote print press proofing system" (priority 2000‑04‑06; granted 2002‑04‑29) — the networked remote‑proofing reference

Verified disclosure: a network (network 18) linking an image server, a database of digital images, and remote clients, using color‑profiled devices and color‑calibrated monitors "so that the client may view a color corrected digital image of a physical press proof sheet… without having to physically travel to the printer's location." It expressly invokes ICC device profiles and "profile format… to translate color data created by one device into another device's native color space." Source: https://uspto.report/patent/grant/[6381343](/patent/6381343) ; https://portal.unifiedpatents.com/patents/patent/US-6381343-B1

IV‑F. Additional cited references of note

  • US 6,043,894 A — GretagMacbeth, "Method for maintaining uniformity among color measuring instruments" (color‑measurement instrument calibration/normalization).
  • US 6,310,626 B1 (Kodak) "System for modeling a color imaging device"; US 6,373,580 B1 (Kodak) multi‑dimensional interpolation (transform LUT construction); US 6,341,175 B1 (Fuji) color‑data conversion; US 6,342,951 B1 (Xerox) gamut mapping; US 6,320,668 B1 (Samsung) color correction — all color‑transform art.
  • US 6,256,638 B1 (Interval Research) printable interfaces / digital linkmarks — machine‑readable codes on printed matter (relevant to the "optically readable identifier" limitations).
  • US 5,859,711 A / US 6,035,103 A (T/R Systems) multiple print engine with color correction.
  • Applicant‑acknowledged cartridge‑data references in the description: US 6,644,771; US 6,549,732; US 6,654,567; US 2003/0112419; US 2003/00681885; US 2002/0080335 (switch‑array and capacitive‑sensor cartridge ID).

IV‑G. References that are NOT available prior art (flag)

From the "Cited By (10)" list, the following post‑date the 2004‑06‑29 filing and cannot be used against the '251 claims: US 2006/0077407 A1 (Seiko Epson, 2004‑07‑16), US 2006/0170991 A1 (Jacob, 2005‑01‑28), US 2007/0086047 A1 (Samsung, 2005‑10‑15), DE 10 2008 012330 A1 (OCé, 2008), US 2010/0296112 A1 (Bäumler, 2006‑01‑20), US 2015/0234347 A1 (Xerox, 2014). Do not rely on these. (The remaining "Cited By" entries — US 8,279,236; US 8,537,357; US 8,638,340 — are later RAH family members, also not prior art.)


V. Obviousness by claim family

I organize the 41 claims into the three families identified in the earlier summary.

Family A — Networked, cartridge‑keyed calibration: claims 1, 7, 8 (deps. 2–6, 16–18)

Primary combination: {incorporated 6,459,425 (or 6,043,909)} + US 5,835,817 — with US 5,185,673 as a secondary teaching and US 6,351,621 for the wireless‑reader dependents.

Claim element Where taught
Network with nodes; first node = computer system/profile server; second node = printer '425 / '909 (Node N profile server 16; Node A printer 17; network 11a)
Replaceable toner/ink cartridges with identifying information HP '817 (replaceable ink cartridge with serial‑access memory storing serial number/calibration data)
Means for reading cartridge ID HP '817 (processor reads part memory via connector); Xerox '621 (wireless interface)
Communicate printer configuration info (incl. ID) over network to first node '425 (node→profile‑server communication) + HP '817 (ID as the configuration datum)
Return color transformation that renders color in accordance with the ID '425 (profile server returns transforms keyed to device configuration) + HP '817 ("second apparatus… adjust[s] its control parameters in accordance with the data stored in the part's on‑board memory")

Motivation / rationale (KSR‑compliant):

  1. Same field, same problem. Both the incorporated RAH patents and HP '817 address keeping a printer's output colorimetrically correct in the face of hardware/consumable variation.
  2. Express problem statement in the '251 itself. The Background states: "It would also be useful for hard copy rendering devices, such as color printers, to provide information about their configuration that would allow a user of a color printer to obtain calibration data…" HP '817 provides exactly that information (on‑cartridge calibration/identification data), and the profile server of '425 provides the remote calibration data.
  3. Known problem = known fix. HP '673 (pre‑1996) expressly identifies "lighter or darker tone cartridges" and different paper/media as distortion sources requiring calibration coefficients. A POSITA seeking to make the '425 network calibration handle per‑cartridge variation would predictably read the cartridge's stored ID/calibration data (HP '817) and use it as the lookup key.
  4. "Smart cartridge" was routine. Xerox '621 describes the CRUM as "well known." Substituting a known CRUM/ID read for a manually entered configuration value is a predictable variation of the '425 system (KSR, predictable variations of known techniques).
  5. Combination is a mere juxtaposition of known subsystems (a network color‑management server + a cartridge with readable memory) with no asserted unexpected result and no teaching away.

Claim 2 (database of transforms for different printer models): taught by '425 (database 21 of color profiles/keyed to device model).
Claim 3 (CMI measuring calibration state sent with configuration): '425/'909 (CMIs 18/29; color calibration data measured at the rendering device).
Claim 4 (server determines transform from calibration data + configuration): '425/'909.
Claim 5 (media data): HP '673 (media‑type distortions); '425 (paper type in configuration file).
Claim 6 (user preferences): '425 (user preferences for rendering).
Claims 16–18 (user prefs / calibration data incl. linearization or color‑mixture data / gamut of simulated device / viewing conditions for chromatic adaptation): '425 & '735 (Virtual Proofing, gamut data sharing, illuminant/aim linearization, color‑to‑color′ transforms).

Family B — Networked color reproduction generally: claims 9, 10 (deps. 11–15, 19–22)

These are the broadest claims and do not require a cartridge at all. Claim 9 reads on the incorporated '425/'735 system essentially verbatim (communicate with color‑capable rendering devices; collect color reproduction data relative to a reference; share that data between the devices over a network via each device's network interface to match color reproductions).

Primary combination / single‑reference ground:

  • Claim 9: {'425 / '735} alone (distributed color‑reproduction control and matching among networked nodes), or, if the RAH parents are not "prior art" because of the priority chain, then the combination {Lotsadots '343} + {HP '673}: '343 teaches a network linking a color‑profiled image server and multiple remotely color‑calibrated client devices for matching color to a reference proof; '673 teaches collecting color‑reproduction data (measured distortions) relative to a reference and deriving calibration coefficients. Sharing the measured/derived data across the network to keep the devices matched is the natural, predictable use of a network proofing system.

    • Dep. 19 (data = color measurements or functions thereof, reference in device‑independent units): '909/'425 (CIE/device‑independent color) and '343 (ICC profile format).
    • Dep. 20 (errors of reproduction vs. desired colors): HP '673 (measured distortions → coefficients; lookup of "response" vs. "desired" colors).
    • Dep. 21 (matching black utilization): '425/'735 (black‑utilization objectives named in the '251 spec as stored look‑up fields).
    • Dep. 22 (Internet Protocol, may be partly wireless): '343 (network) + Xerox '621 (wireless interface).
  • Claim 10 (apparatus with processor; component enabling adjustment of color‑calibration state; network link over LAN/WAN/Internet/WWW connecting another node; calibration coordinated with assistance of that node): taught by '425 — the spec states a node "need not have a computer other than the processors embedded in the proofing devices or color measurement instrumentation," and calibration is coordinated by the remote profile server. HP '673 supplies the "component enabling adjustment of the state of color calibration" (the closed‑loop calibration element).

    • Dep. 11 (component provides color measurement data): '673; '425 (CMI).
    • Dep. 12 (processor operates the component to measure rendered output): '673 (scanner measures the printed calibration image).
    • Dep. 13 (xerographic / offset / ink‑jet): Xerox '621 (xerographic); HP '817/'673 (ink‑jet); offset‑press calibration art (T/R '103, GretagMacbeth '894).
    • Dep. 14 (densitometer / colorimeter / imagical): '425 (CMI 18 = colorimeter or density sensor; CMI 29 = scanner/imagical).
    • Dep. 15 (print head; component moves in tandem with print head): '425 — expressly ("the optical pickup component of the sensor is mounted to move in tandem with the marking head").

Note: Claims 9/10 are so closely aligned with the incorporated RAH disclosure that, if the 1996 priority does not carry (the CIP/new‑matter problem in §I), they read directly on the '425/'735 patents (issued 2000/2002) and are vulnerable to §102 anticipation and/or §103 on those very documents.

Family C — Cartridge‑centric printer calibration: claims 23, 33, 35, 37 (deps. 24–32, 34, 36, 38–41)

These are the claims that most depend on the 2004 effective date. Core combination: {HP '817} + {'425}, with {Xerox '621} and {HP '673} as secondary.

  • Claim 23 (printer + microprocessor; cartridge with readable ID; microprocessor or attached computer communicates ID over a network and receives a transformation that lets the printer render color per the ID):

    • HP '817: printer/copier with controlling processor (28) and replaceable part with readable memory; the processor reads the part's serial number/calibration data and adjusts control parameters accordingly. '425: network + transformation distribution.
    • Xerox '621: expressly provides that the memory "can be accessed… either by the printer… itself or by an external device," mapping onto "said microprocessor or a computer system coupled to said color printer."
    • Deps. 24–25 (computer interfaces with microprocessor; either uses the transform): HP '817 (processor uses part data); '425 (host computer applies transforms).
    • Dep. 26 (optically readable identifier): Interval Research '638 (digital linkmarks / printable machine‑readable codes); HP '817 (the "code"; barcode label means now expressly described in the '251 spec).
    • Dep. 27 (RFID tag): Xerox '621 (RF wireless interface to module memory).
    • Dep. 28 (one or more identifiers): HP '817 (serial number + usage + calibration fields).
    • Dep. 29 (non‑volatile memory / switch array / capacitive sensor): HP '817 (serial‑access non‑volatile memory); applicant‑acknowledged 2003/00681885 (switch array) and 2002/0080335 (capacitive sensor).
    • Dep. 30 (reader): HP '817 (connector read) / '621 (wireless reader).
    • Dep. 31 (user inputs ID at computer): '425 (user interface / host computer) — manual entry of a code is the simplest predictable alternative.
    • Dep. 32 (communicate media data / user preferences / state of calibration): '425 (configuration file fields) + HP '673 (media).
  • Claim 33 (method: provide readable ID on cartridge; communicate ID over network; receive transform enabling rendering per ID): same combination as cl. 23. Dep. 34 (optical / RFID / NVM / switch array / capacitive sensor): '621, '817, and applicant‑acknowledged references.

  • Claim 35 (server‑side: database of transforms for multiple printers + computer communicating, over a network, a transform according to at least information readable from a cartridge): the '425 profile server/database + HP '817's cartridge‑read data as the query key. Dep. 36 (also user prefs or state‑of‑calibration received over network): '425.

  • Claim 37 (CRM with (i) component enabling network communication for calibration per cartridge‑readable data and (ii) component enabling rendering adjustment per received transform): '425 (client/server software) + HP '817 (cartridge data governs control parameters).

    • Dep. 38 (LAN/WAN/Internet/WWW protocol): '343 / '425.
    • Dep. 39 (executed on device processor or attached computer): '425 ("need not have a computer other than the processors embedded in the proofing devices").
    • Dep. 40 (transforms = profiles / gamut config / transfer functions / procedures): '343 (ICC profiles), '425 (gamut), Kodak '580 (transfer functions), Fuji '175/Samsung '668 (procedures).
    • Dep. 41 (read linearization data and modify linearization functions to be consistent with the received transform): '425 (aim linearization curves updated regularly; color‑to‑color′ transforms).

VI. Consolidated motivation‑to‑combine statement

A single, coherent rationale supports all combinations:

  1. Common field / reasonably pertinent art. All references are in color printing, image forming, or color‑profiled network proofing.
  2. The '251 states its own problem. Applicant's Background expressly seeks cartridge‑derived configuration information for obtaining calibration data — the identifiers and motivation are supplied by the patent itself.
  3. The references are combinable without redesign. HP '817's cartridge memory already feeds the printer's processor; the '425 profile server already ingests node configuration data. Routing the cartridge ID from processor to network to server is a predictable, off‑the‑shelf step (KSR, combination of known elements according to known methods).
  4. Known problem in the art. HP '673 (pre‑1996) names cartridge‑to‑cartridge and media‑to‑media variation as calibration problems; a POSITA would pursue the cartridge ID as the discriminator.
  5. Industry momentum. The "smart cartridge"/CRUM was "well known" (Xerox '621); using its data for a cloud/server color service is a predictable variation of a known device, not an inventive leap.
  6. No asserted unexpected result or teaching away in the record; and the patent appears to be for aggregating known subsystems — a classic §103 posture.

VII. Rebuttal analysis (things that cut against obviousness)

A rigorous analysis must acknowledge the defenses:

  1. The key references were of record. HP '817 and Xerox '621 both appear in the '251 Citations list. The examiner undisputedly had them and still allowed the claims. A defender will argue the Office considered and rejected exactly this combination. (Counter: presence on the list shows the elements were known but not that the combination keyed to cartridge ID was articulated; and a challenger is free to make the combination the examiner did not.)
  2. "In accordance with said identifying information." The strongest argument that the claims are not obvious turns on specificity: HP '817 uses cartridge data for intra‑printer control parameters, whereas the '251 claims a server‑distributed color transformation selected by cartridge ID. A defender can argue HP '817 does not teach serving a color transform over a network keyed to a cartridge code, and that the '251 supplies a non‑obvious "distributed, consumable‑keyed color management" architecture. This is why the priority/effective‑date question (§I) is dispositive for Family C: if the cartridge‑keyed claims are entitled to the 1996 date but are not supported by 1996, they may be invalid for written‑description/enablement (§112) regardless of §103; if they are supported and get 1996, then the 1998–2002 references are not prior art at all.
  3. Secondary considerations. I have no reliable, verifiable evidence of commercial success, long‑felt need, or industry praise having a nexus to the '251 claims specifically. The earlier section notes heavy RAH‑family litigation and IPR activity (Adobe IPR2019‑00627/00628/00629/00646; Adobe v. RAH, Nos. 2021‑1067/‑1068 (Fed. Cir.)) — but those concerned sibling patents, not '251, and I could not confirm that '251 itself was IPR‑challenged. I therefore do not assert or rely on secondary considerations, and I flag them as unverified. Do not treat the '425/'735 licensing history as nexus evidence for '251.

VIII. Bottom line

Claim(s) Strongest obviousness ground Confidence
9, 10 (+ deps. 11–15, 19–22) '425/'735 alone (if parents are prior art) or '343 + '673 High (narrow §103/near‑§102)
1, 7, 8 (+ deps. 2–6, 16–18) '425/'909 + HP '817 (+ Xerox '621, HP '673) High–Moderate
23, 33, 35, 37 (+ deps. 24–32, 34, 36, 38–41) HP '817 + '425 (+ Xerox '621, HP '673, Interval '638) Moderate — rises to High if the claims are not entitled to the 1996 date; falls if they are

The dispositive variable is the effective filing date. If the cartridge‑keyed claims are limited to 2004‑06‑29, the combination of the RAH network‑color patents with HP '817 (and Xerox '621) would very likely have been obvious, especially given the applicant's own admission that '817 and '621 describe "means for providing data readable from a cartridge." If those claims validly claim 1996‑02‑26, then '817 (1998) and '621 (2002) are not prior art, and only the pre‑1996 art (HP '673 plus general color‑management knowledge) remains — a materially weaker but still non‑trivial obviousness case for Family B and the broadest Family A elements.


Sources (fetched 2026):

Open verification items I could not confirm here (do not treat as established): (a) whether the cartridge‑ID subject matter of the '251 claims is supported by the 1996 specification (this determines the effective date and thus the whole cartridge‑reference analysis); (b) whether '251 was itself the subject of any IPR (the Adobe IPRs I could identify concerned sibling RAH patents); and (c) whether any specific '251‑limitation combination was expressly considered and overcome during prosecution beyond the mere presence of '817/'621 on the citation list.

Generated 9/27/2026, 11:22:38 PM

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