Patent 7477410
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
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Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
The most relevant prior art for US patent 7477410, as cited by the patent itself, includes a large number of U.S. patents. For the purpose of providing a concise and highly relevant analysis, we will focus on the three prior art references that were central to the Inter Partes Review (IPR) proceedings that invalidated claims 1-10 of US7477410: US Patent 5,838,906 (Kallin et al.), US Patent 5,617,576 (Sasaki et al.), and US Patent 5,652,849 (Nishi et al.). These references were used in combination to establish obviousness under 35 U.S.C. § 103, which ultimately led to the cancellation of all claims. While the request specifically asks for anticipation under 35 U.S.C. § 102, it is important to note that the PTAB found the claims unpatentable based on obviousness over combinations of these references, implying that no single reference was found to anticipate all elements of a claim under § 102.
Key Prior Art References (as used in IPR proceedings)
The following prior art references were central to the invalidation of claims 1-10 of US7477410 in IPR2014-00539 and IPR2015-01178.
US Patent 5,838,906 to Kallin et al.
- Full Citation: U.S. Patent 5,838,906, "Integrated document imaging and processing system and method," issued November 17, 1998.
- Publication/Filing Date: Filed: November 13, 1995; Granted: November 17, 1998.
- Brief Description: Kallin et al. describes a document imaging and processing system that integrates various document processing functions such as scanning, indexing, viewing, and outputting documents within a single environment. It focuses on providing a common interface for different hardware components and software applications to manage electronic documents. This system aims to streamline document workflows by allowing users to process and route documents efficiently.
- Potential for § 102 Anticipation: While not found to explicitly anticipate any claims under § 102 during the IPRs (which focused on § 103), Kallin et al. is highly relevant to the subject matter of US7477410. It describes a system for managing electronic images and documents, transmitting them to external destinations, and integrating imaging capabilities into applications. Elements such as managing input/output, processing, and integrating with applications are broadly disclosed. Had the claims remained valid, a detailed element-by-element comparison would be needed to determine if Kallin et al. disclosed every element of any specific claim of US7477410 to meet the high bar of § 102 anticipation. The IPRs, however, found it obvious in combination with other references, indicating it likely lacked at least one element of the claims for direct anticipation.
US Patent 5,617,576 to Sasaki et al.
- Full Citation: U.S. Patent 5,617,576, "Image forming apparatus capable of transmitting image data to an external device by facsimile communication," issued April 1, 1997.
- Publication/Filing Date: Filed: November 27, 1995; Granted: April 1, 1997.
- Brief Description: Sasaki et al. describes an image forming apparatus (e.g., a digital copier) that can transmit image data to external devices via facsimile communication. The patent focuses on the hardware and software aspects of such a device, including scanning, processing, and transmitting image data to a connected external facsimile machine.
- Potential for § 102 Anticipation: Sasaki et al. focuses on the integration of imaging devices with communication capabilities. It discloses aspects related to managing imaging devices (scanner, digital copier) and transmitting image data, which are components of the "Virtual Copier" concept in US7477410. Similar to Kallin et al., while relevant to the overall subject matter, the IPRs did not find it to singly anticipate any claims under § 102, but rather contributed to an obviousness finding in combination with other references. This suggests it would not have met the "every element" test for § 102 anticipation for claims 1-10 of US7477410.
US Patent 5,652,849 to Nishi et al.
- Full Citation: U.S. Patent 5,652,849, "Image data processing apparatus," issued August 5, 1997.
- Publication/Filing Date: Filed: February 16, 1996; Granted: August 5, 1997.
- Brief Description: Nishi et al. describes an image data processing apparatus that can execute various image processing functions, such as image manipulation, before transmitting or storing image data. It highlights functionalities like image rotation, scaling, and conversion between different image formats, and managing image data for output to different devices.
- Potential for § 102 Anticipation: Nishi et al. provides details on processing image data and managing its output, which aligns with the "Process Module" and "Output Module" aspects of the Virtual Copier described in US7477410. Again, Nishi et al. was cited in the IPRs as part of an obviousness combination, not as a single anticipatory reference under § 102. This indicates that while it discloses relevant components and functions, it would not have fully anticipated any of the claims 1-10 of US7477410 on its own.
Context of IPR Decisions
It is critical to reiterate that the claims of US7477410 (claims 1-10) were found unpatentable in IPR2014-00539 and IPR2015-01178 on the grounds of obviousness under 35 U.S.C. § 103 over combinations of prior art references including Kallin et al., Sasaki et al., and Nishi et al. These decisions were affirmed by the Federal Circuit. Therefore, while these patents are highly relevant prior art and shed light on the state of the art at the time, they were not found to individually anticipate the claims under 35 U.S.C. § 102. Their combined teachings, however, rendered the claims obvious.
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