US 7715052

I'll search for authoritative information on this patent number.

Let me find the actual claim text for this patent.

US 7,715,052 B2 — Analyst Summary

Sources used: the full Google Patents record at https://patents.google.com/patent/US7715052/en (fetched 2026‑09‑27, and treated as authoritative over my training data), plus live web searches for USPTO/PTAB/CAFC materials. I flag below exactly where the record is silent.

1. Bibliographic data (as recorded)

Continuity (from the patent's own "Description" preamble): a continuation of Ser. No. 11/246,813 (filed Oct 7, 2005), which is a continuation of Ser. No. 10/040,664 (filed Jan 7, 2002, now U.S. Pat. No. 6,995,870), which is a divisional of abandoned Ser. No. 09/229,002 (filed Jan 12, 1999), which is a divisional of Ser. No. 08/606,883 (filed Feb 26, 1996, now U.S. Pat. No. 6,034,909). So the effective filing chain bottoms out at the Feb 26, 1996 parent — consistent with the "prior art date 1996‑02‑26" on the record.

Classification highlights: G06F3/12 (digital output to print unit, incl. 3/1202, 3/1223, 3/1267), G01J3/46–3/524 (colorimetry; color charts; colorimeter calibration), G01J3/462 (color management systems), H04N1/32502, 1/32523, 1/32545 (distributing jobs among multiple I/O devices), H04N1/60–1/6066 (color correction/control and gamut reduction, including image‑dependent gamut).

2. Abstract (verbatim from the record)

The system provides for controlling color reproduction of input color image data representing one or more pages or page constituents in a network having nodes (or sites). Each one of the nodes comprises at least one rendering device. The system distributes the input color image data from one of the nodes to other nodes, and provides a data structure (virtual proof) in the network. This data structure has components shared by the nodes and other components present only at each node. Next, the system has means for providing color calibration data at each node characterizing output colors (colorants) of the rendering device of the node, and means for producing at each node, responsive to the color calibration data of the rendering device of the node, information for transforming the input color image data into output color image data at the rendering device of the node. The information is then stored in the data structure in different ones of the shared and other components. Means are provided in the system for transforming at each node the input color image data into output color image data for the rendering device of the node responsive to the information in the data structure. The rendering device of each node renders a color reproduction of the page constituents responsive to the output color image data, wherein colors displayed in the reproduction at the rendering device of each node appear substantially the same within the output colors attainable by the rendering devices. The system further has means for verifying at each node that the information for the rendering device of the node properly transformed the input color image data into the output color image data, and means for revising the information stored in the data structure at the node responsive to results of the verifying means. Shared components of the data structure may also store color preferences selected by a user. The information producing means of the system may further operate responsive to both the color calibration data and the color preferences. The rendering devices in the system can provide color reproductions having three or four colorants, and may provide more than four output colors (color inks).

3. Plain-language overview of the independent claims — with an explicit limitation

I could not verify the claim text of US 7,715,052 in this session, and I will not reconstruct it.

• The Google Patents full text I retrieved renders this document up through the "Summary of the Invention"; the rendering terminates before the "Claims" section. No claim set, claim count, or independent-claim numbering for the '052 patent appears in the retrieved record.
• Targeted searches returned claim language for sibling family members — e.g., U.S. 6,034,909 (claims 34/36 method, 41, 63 apparatus), U.S. 6,157,735, and prosecution papers for Ser. Nos. 11/452,879 and 12/802,609 — not for US 7,715,052. Those siblings' claims must not be attributed to the '052 patent; they are separate patents with separate claim sets and separate prosecution histories.

What I can state with confidence, because it comes from the '052 record itself:

1. Subject matter: the claims are directed to a networked color‑reproduction system in which rendering devices at different nodes/sites are calibrated and driven so that color "appear[s] substantially the same within the output colors attainable by the rendering devices."
2. Claim categories, per the abstract: the abstract is written in claim‑style recitation, indicating (a) a system/apparatus class of claims (network having nodes; a data structure having shared and node‑local components; calibration‑data providing means; information‑producing means; transforming means; rendering means; verifying means; revising means) and likely (b) a method class of claims mirroring the same steps. The abstract's closing sentences indicate dependent scope covering user color preferences stored in shared components, and rendering devices with three, four, or more than four output colorants.
3. Architectural terms of art used in this family: the "Virtual Proof" (VP) data structure, "SOMs" (standard observer meters) and "imagicals" (imaging colorimeters), forward models (FMT), prototype gamut descriptors, proto‑SEP/prototype color‑to‑colorant tables, GCR/UCR black‑utilization data, conditioning transforms, and gamut filters/operators.

Bottom line: treat any statement about the number or precise wording of '052's independent claims as unverified. If you need verbatim claim language, pull the granted patent's claim column from USPTO PatentCenter/Patent Public Search (or the patentimages PDF) — the Google Patents web rendering I could reach did not include it.

4. Litigation / CAFC 2026 check

No CAFC 2026 docket or opinion involving US 7,715,052 was found. Specifically:

• Searches of Federal Circuit 2026 dispositions returned only unrelated cases (e.g., Centripetal Networks v. Keysight, No. 2024‑1930, Rule 36 judgment Jan 12, 2026; Global Tubing v. Tenaris; Magnolia Medical v. Kurin; Receivership Estate of AudienceScience v. Google; a Woodway PTAB affirmance). None names 7,715,052.
• PTAB/IPR materials returned hits on related but different Holub patents — notably U.S. 7,791,761 (IPR2019‑00646, Adobe v. RAH Color Technologies) and U.S. 8,416,444. I found no IPR, PGR, or CBM naming 7,715,052.
• District‑court activity: the '052 record links the family to a Michigan Western District case (1:14‑cv‑00638) and a Darts‑IP family. In the RAH v. Ricoh complaint excerpt I retrieved, the "Patents‑in‑Suit" are the '870, '251, '008, '546, '444, '704, and '314 patents — 7,715,052 is not listed there. I did not locate a complaint asserting '052 itself.

Caveat on legal status: the record's "Expired – Fee Related" annotation and the "Adjusted expiration 2018‑08‑29" entry are the platform's own status assumptions ("The legal status is an assumption and is not a legal conclusion"). I have not independently confirmed the maintenance‑fee/expiration posture through USPTO fee records.

5. Residual uncertainties (stated plainly)

• Claim text and claim count for US 7,715,052: not retrieved → not reported. Do not rely on any secondary source that paraphrases its claims without showing the claim column.
• Assignee name is rendered inconsistently ("RAH Color Tech LLC" vs. "RAH COLOR TECHNOLOGIES LLC") across the same record; the assignment entries use the latter.
• The "expires 2018‑08‑29" date is a platform "adjusted expiration" field; the underlying PTA and fee history were not verified.
• The "first worldwide family litigation filed" flag is a Darts‑IP third‑party annotation (family 24429880); I did not verify the docket contents.
• No 2026 CAFC activity was located — which is a negative finding from the searches I ran, not proof of absence.

I'll research litigation involving US Patent 7,715,052 using multiple sources.

Let me search more specifically for litigation asserting this exact patent number.

Litigation involving U.S. Patent No. 7,715,052

Important scoping note: I ran targeted searches on the exact number 7,715,052 / "7,715,052." Several other, unrelated patents share the shorthand "'052" (e.g., Pantech's U.S. 8,893,052 in Pantech v. OnePlus; Cellect's '052 patent in Cellect v. Samsung, D. Colo. 1:19-cv-00438). I excluded those. Everything below concerns U.S. 7,715,052 B2 (Holub, "System for Distributing and Controlling Color Reproduction at Multiple Sites"), assigned to RAH Color Technologies LLC.

The one confirmed case asserting this patent

Basis / grounding:

• The Google Patents page for US7715052 itself lists this case as the "US case filed in Michigan Western District Court" under the patent's litigation section, linking to case 1:14-cv-00638.
• The complaint in that action (preserved as Exhibit 2222 in PTAB IPR2019-00628, Adobe Inc. v. RAH Color Technologies LLC) names ten RAH patents-in-suit including "United States Patent No. 7,715,052 … (the '052 patent)" and contains a "FOURTH CLAIM FOR RELIEF (Infringement of the '052 patent)." The asserted claims were 9, 10, 12, 13, 14, 15, 16, 33, 34, 35, 36, 37, 38, 39, 40, and 41, directed at X-Rite products including ColorMunki Display, ColorMunki Photo, ColorMunki Design, i1Display Pro, i1Basic Pro 2, i1Photo Pro 2, and i1Publish Pro 2 (direct and induced infringement under 35 U.S.C. § 271).
• The Western District of Michigan docket (Dkt. 28–30) shows the stipulated dismissal and the order closing the case.

Related but NOT this patent (for completeness / to avoid conflation)

The larger RAH Color Technologies licensing campaign (MDL No. 2874, N.D. Cal., Judge Illston) and the related actions asserted RAH's other Holub patents — principally U.S. 6,995,870 ('870); 7,729,008 ('008); 7,791,761 ('761); 7,312,897 ('897); 8,416,444 ('444); 7,830,546 ('546); 8,760,704 ('704); 7,280,251 ('251); and 8,817,314 ('314). Those cases included:

• RAH Color Technologies LLC v. Adobe Inc., N.D. Cal. 3:18-cv-03277 (and consolidated MDL 3:18-md-02874)
• RAH Color Technologies LLC v. Xerox Corp., W.D.N.Y. 6:18-cv-06746 (and 6:19-cv-06112 re Kodak)
• Electronics For Imaging, Inc. v. RAH Color Technologies LLC, E.D. Va. 1:18-cv-01436
• RAH Color Technologies LLC v. Heidelberger Druckmaschinen AG, N.D. Ill. 1:19-cv-00193
• RAH Color Technologies LLC v. Dalim Software GmbH, N.D. Ill. 1:19-cv-00275
• RAH Color Technologies LLC v. [Microsoft Corp.](/litigations/by-plaintiff/Microsoft%20Corp.), E.D. Tex. 2:20-cv-00088
• RAH Color Technologies LLC v. Ricoh (E.D. Pa.)

Based on the complaints I reviewed, 7,715,052 was not among the patents asserted in those MDL-related actions, and it was not the subject of any of the Adobe IPRs (IPR2019-00627/-00628/-00629/-00646, which targeted the '008, '444, '897, and '761 patents). So no PTAB validity challenge to 7,715,052 appears in the record I could reach.

Caveats / confidence

• Confidence: high that the X-Rite/Michigan action asserted and disposed of the '052 patent.
• Confidence: moderate on the negative — i.e., that no other case asserted 7,715,052. My searches surfaced the RAH portfolio cases through secondary/aggregator sources (Google Patents, RPX Insight, Docket Alarm PTAB exhibits, UniCourt, Dockets.Justia, CourtListener) rather than a direct PACER or Unified Patents case-list query for every RAH filing. If you need an exhaustive, docket-verified negative, I'd recommend a docket-level search (PACER "patent number" field search, or Lex Machina/Docket Navigator) across RAH Color Technologies filings, since a small number of older RAH matters may not be fully indexed in the sources I could reach.
• The patent's own "Legal status" field ("Expired – Fee Related, expires 2018-08-29") reflects term/maintenance-fee status, not litigation; do not read it as a litigation outcome.
• I did not independently verify the Darts-ip "first worldwide family litigation" entry, which points to the same Michigan case family.

Bottom line: The only known litigation specifically asserting U.S. 7,715,052 is RAH Color Technologies LLC v. X-Rite, Inc., W.D. Mich. No. 1:14-cv-00638 (filed June 16, 2014), which was dismissed by stipulation/order in early 2015.

I'll research this patent's PTAB history now.

PTAB / AIA Trial Report — U.S. Patent No. 7,715,052

Patent: 7,715,052 B2 — "System for distributing and controlling color reproduction at multiple sites"
Patent owner / current assignee: RAH Color Technologies LLC (inventor Richard A. Holub)
Priority date: 1996-02-26 · Continuation filed: 2006-06-14 · Granted: 2010-05-11
Report date: 2026-09-27

Proceedings overview

There are zero AIA trial proceedings on file against U.S. 7,715,052 — no IPR, no PGR, no CBM — so the patent has never been tested at the Board as an issued claim set, and the "no PTAB activity" finding is the operative answer. The defensive posture this gives a defendant is therefore unusual and in one respect favorable: (a) there is no IPR estoppel to work around and no PTAB-friendly vehicle here — you cannot ride another petitioner's institution; if you want PTAB review you must file your own petition inside your § 315(b) window; and (b) more importantly, the patent is recorded as expired (adjusted expiration 2018-08-29 per the Google Patents legal-status data), which means any current assertion can only reach past damages, and the 35 U.S.C. § 286 six-year lookback appears to have closed as of 2024-08-29. That expiration point — not PTAB history — is likely the single most valuable defense fact about this patent, and it should be verified against the USPTO maintenance-fee/term record before anything else.

Source of the proceedings list. The structured "PTAB proceedings on file" block in the prompt — sourced from the USPTO Open Data Portal — returns no AIA trial proceedings for 7,715,052. That block is canonical for this report. Web search was used only to corroborate, and to capture litigation/related-patent context the ODP block does not carry. I found no petition, institution decision, FWD, or appeal naming 7,715,052 as the challenged patent.

No proceedings on file

There are no per-proceeding sections to write for this patent — no docket number, no petitioner, no panel, no institution decision, and no Final Written Decision exists for 7,715,052. I will not manufacture one. The absence is itself the finding, and it carries three consequences for a defendant:

1. No claim of 7,715,052 has ever been canceled, confirmed, or construed by the Board. No claim is "dead"; equally, no claim has been hardened by surviving an IPR. The patent's validity is untested at the PTAB.
2. Nothing here is estoppel-barred under § 315(e)(2), because no petitioner ever reached a final written decision on this patent. Any prior art you can find is fair game.
3. No PTAB timeline exists to hitch a stay to. A district court has no institution decision to wait on.

Related AIA proceedings on sibling patents — NOT proceedings on 7,715,052

These are included only as a cross-patent pattern signal, per the strategic brief. They are not proceedings on 7,715,052 and must not be cited as such; claim numbers below are for the other patents.

• IPR2019-00627 — Adobe Inc. v. RAH Color Technologies LLC (U.S. 7,729,008). Petition filed 2019-02-01. Institution granted 2019-09-04 (Paper 34). Panel: Ippolito, Hudalla, Engels (Docket Alarm also lists Lee and Mercader for the case). Consolidated oral hearing held 2020-05-28 with IPR2019-00628, -00629 and -00646. Final Written Decision 2020-08-31 (Paper 124): the Board determined petitioner had not shown by a preponderance that claims 28–33 and 36–38 of the '008 patent are unpatentable — i.e., Adobe lost on the merits in this one. The same paper granted a motion to exclude a declaration whose declarant refused to be deposed. Source: https://bannerwitcoff.com/wp-content/uploads/2020/09/PTAB-IPR2019-00627-124.pdf
• IPR2019-00646 — Adobe Inc. v. RAH Color Technologies LLC (U.S. 7,791,761). Petition filed 2019-02-01; claims 7, 8, 9, 10, 11, 13, and 15 challenged; institution granted 2019-09-04; panel Ippolito (writing), Hudalla, Mercader; decision date 2020-09-02; joint notice of redactions 2020-09-14 (no redactions needed). The N.D. Cal. court later referenced "the '761 Patent Final Written Decision with regard to the finding about claim 15," which implies the FWD made a claim-15-specific finding — I have not verified the claim-by-claim disposition of IPR2019-00646 and will not guess at it. Sources: https://www.docketalarm.com/cases/PTAB/IPR2019-00646/Inter_Partes_Review_of_U.S._Pat._7791761/ ; https://storage.courtlistener.com/recap/gov.uscourts.cand.[327437](/patent/327437)/gov.uscourts.cand.327437.120.0.pdf
• IPR2019-00628 (U.S. 8,416,444) and IPR2019-00629 (U.S. 7,312,897). Filed by Adobe alongside the above. Outcomes not verified in this research pass.

Distinction that matters: Adobe petitioned against the '008, '444, '897, and '761 patents — four siblings of the '052 in the same family, sharing the same specification — but did not petition against the '052 itself, even though the '052 was in the same assertion set. That is a specific, not a generic, omission, and it is consistent with the patent having already expired by the time the 2018–2019 campaign matured.

Strategic summary

Claims cancelled vs. sustained vs. untested. All claims of 7,715,052 are untested — there is no PTAB record of cancellation or confirmation. Contrast that with the sibling '008 patent, where the Board rejected Adobe's challenge to claims 28–33 and 36–38, and with the '761 patent, which went to an FWD on claims 7–11, 13, and 15 with at least one claim-15-specific finding. Those sibling outcomes are only persuasive here (different claims, different art, and no issue preclusion across patents), but because the family shares a specification, a future petitioner would study the Adobe FWDs closely — both for the Board's claim-construction reasoning and for which art the Board already rejected.

Estoppel landscape. No IPR-scoped estoppel under § 315(e)(2) attaches to 7,715,052, because no IPR on this patent ever reached an FWD. Estoppel from the Adobe sibling-patent IPRs does not transfer to a different patent's claims, so a defendant has the full universe of prior art available: § 102/§ 103, printed publications, patents, systems, and — importantly — a § 112 written-description/enablement attack on the 1996 priority claim, which is the kind of ground the Board cannot reach in an IPR and which therefore remains a district-court-only weapon regardless of anyone's estoppel. Note the reverse risk too: if you are sued and you do file an IPR, you will be estopped in the parallel case as to everything you raised or reasonably could have raised.

Pattern signals. (i) The petitioner of record across this family is Adobe Inc., which filed a coordinated four-petition set (IPR2019-00627/-00628/-00629/-00646) and consolidated the oral hearings — a classic parallel-petition campaign, not serial follow-ons. (ii) No defensive aggregator (e.g., Unified Patents) appears in the record I retrieved; the PTAB activity here was party-driven, not aggregator-driven. (iii) Patent owner RAH Color Technologies is a licensing entity managed by the inventor, and the '052 has been swept into broad multi-patent assertions — a ten-patent complaint naming 7,312,897 / 7,710,433 / 7,710,560 / 7,715,052 / 7,729,008 / 7,791,761 / 8,009,175 / 8,279,236 / 8,416,444 / 8,537,357 — plus MDL No. 2874 in N.D. Cal. (Adobe, Xerox, EFI, Heidelberger, Dalim coordinated pretrial proceedings). The Google Patents "Family has litigation" link records a W.D. Mich. case, No. 1:14-cv-00638; I was unable to confirm the parties/caption in this research pass, so treat that case number as unverified. (iv) The patent is flagged Expired – Fee Related, adjusted expiration 2018-08-29 — consistent with a 20-year term running from the 1996-02-26 priority date plus PTA — which means the enforcement value of this patent today is legacy/past-damages only.

Recommended next steps

1. Do not look for a PTAB decision — there isn't one. If a demand letter or complaint against you cites claims of 7,715,052, the letter is not citing a canceled claim, and there is no FWD to quote. Any argument that "the claims are already dead at the PTAB" would be false as to this patent and should not be made.
2. Verify expiration first — it likely ends the case on damages. Confirm with USPTO Patent Center / maintenance-fee records the precise expiration date and whether "2018-08-29" reflects term expiry (1996 priority + PTA) or a fee lapse. If the patent expired on or around 2018-08-29, then for a complaint filed on or after 2024-08-30 there is no pre-expiration infringement within the § 286 six-year recovery window, so recoverable damages are zero (absent equitable tolling arguments, which are disfavored). No injunction is available for an expired patent. This should be your first dispositive motion/letter point, and it should be run against the USPTO's authoritative term data, not the aggregator page.
3. If you intend to file at the PTAB, compute your § 315(b) bar now. The bar runs one year from service of a complaint alleging infringement of this patent. Because no earlier petitioner exists, you get no benefit from — and owe no deference to — anyone else's institution decision. Your petition must stand on its own, and you face no § 325(d)/General Plastic follow-on problem from prior petitions on this patent.
4. Set the statutory clock if you do file. Post-institution, the Board's FWD is due within one year (35 U.S.C. § 316(a)(11), extendable up to six months for good cause), with institution decided within six months of the petition's filing date.
5. Mine the sibling FWDs before drafting. Pull the IPR2019-00627 FWD (2020-08-31) and the IPR2019-00646 FWD (decision date 2020-09-02) from USPTO PTAB E2E / PTAB Decisions (https://www.uspto.gov/patents/ptab/decisions) and the N.D. Cal. claim construction order of 2021-01-22 in Case No. 3:18-cv-03277-SI (https://storage.courtlistener.com/recap/gov.uscourts.cand.327437/gov.uscourts.cand.327437.120.0.pdf), which construed "sites," "appear substantially the same," and "interactive conference" for the shared specification. Also check CourtListener for any Federal Circuit appeal from the Adobe FWDs; I found no appeal naming 7,715,052, and I am not aware of any CAFC appeal involving this patent.
6. Re-run the ODP query at filing time. The structured block is canonical and current as of the most recent ingest; the sibling-patent FWDs show RAH litigation settled or wound down in the 2020–2021 window, but the ODP record — not this narrative — governs.

Sources

• USPTO ODP "PTAB proceedings on file" block (canonical; zero proceedings) — as provided in the prompt.
• Google Patents, US7715052B2: https://patents.google.com/patent/[US7715052](/patent/US7715052)/en (legal status, litigation links, family data).
• IPR2019-00627 Final Written Decision (2020-08-31): https://bannerwitcoff.com/wp-content/uploads/2020/09/PTAB-IPR2019-00627-124.pdf
• IPR2019-00646 docket (Docket Alarm): https://www.docketalarm.com/cases/PTAB/IPR2019-00646/Inter_Partes_Review_of_U.S._Pat._7791761/
• N.D. Cal. claim construction order, Case No. 3:18-cv-03277-SI (2021-01-22): https://storage.courtlistener.com/recap/gov.uscourts.cand.327437/gov.uscourts.cand.327437.120.0.pdf
• IPR2019-00646 institution decision (2019-09-04, Paper 34): https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1523435](/patent/1523435)/download-documents

Confidence and gaps (stated plainly): High confidence that no AIA trial proceeding on 7,715,052 exists on the ODP record, and that Adobe's petitions targeted the '008, '444, '897, and '761 patents rather than the '052. Modest confidence on the outcome of IPR2019-00646 ('761) — I did not verify its claim-by-claim disposition and have not asserted one. The parties in W.D. Mich. 1:14-cv-00638 are unconfirmed. The expiration analysis is my inference from the Google Patents legal-status fields and the 1996 priority date; confirm against USPTO term and maintenance-fee records before relying on it.

I'll research this patent's ownership chain using the available sources.

Let me dig into the specific assignment records and reel/frame data.

Let me try to pin down the specific reel/frame records and the 2013 merger details.

Ownership & Assignment Record — US 7,715,052 B2

Methodological note up front: I could not pull the assignment records directly from USPTO Assignment Center / assignment.uspto.gov with the tools available (the site returned no machine-readable results), so I could not retrieve reel/frame numbers or the recorded correspondent-of-record for this patent's two assignment events. What follows is grounded in (a) the Google Patents "Legal Events" tab for US 7,715,052, (b) the patent's own chain-of-priority text, and (c) federal court and PTAB filings in which RAH Color Technologies' title was litigated. I have not fabricated any reel/frame or correspondent data. Where a field could not be verified, I say so explicitly. Verify directly at:

• https://assignmentcenter.uspto.gov/ (search "7715052" or "RAH Color Technologies")
• https://patents.google.com/patent/US7715052/en (Legal Events tab)

Inventors

Pattern flag: The name "Imagicolor" appears only as an unincorporated business at the 1996 filing date; Imagicolor Corporation was not organized until 1998, i.e., two years after the 08/606,883 filing. Holub testified to this under oath in IPR2019-00628 (Ex. 1053, Feb. 12, 2020 deposition: "I guess I became the president of an unincorporated entity that I called Imagicolor"). Imagicolor Corporation was later dissolved after investment failed to materialize. This is the unusual element: no operating-company employer ever held title; the inventor personally held it and later moved it into his own LLC. There is no "inventors departing the assignee within 12 months" pattern to assess, because no corporate assignee existed at filing.

Original assignee

Entity on the issued patent: RAH Color Technologies LLC (as rendered in Google Patents as "RAH Color Tech LLC"), Rochester, NY at issue, later Alexandria, VA.

• Did it ship a product embodying the claims? No. The only prototype was Holub's pre-1998 demonstration rig (automatic display calibration + soft-proofing), developed by unincorporated "Imagicolor" and then Imagicolor Corporation, which was dissolved. RAH Color Technologies LLC itself has never sold a product. This is not merely my inference — the N.D. Cal. court found it as fact: "RAH is a non-practicing entity that licenses and enforces the patents of its sole member, Dr. Richard Holub." (E.D. Cal./N.D. Cal. No. 18-cv-01612-WHO, Order Granting Motion to Dismiss, quoting Holub Decl. ¶¶3–4.)
• Primary line of business: patent licensing and enforcement of Dr. Holub's color-management portfolio. Holub has stated he is the sole member of the LLC (IPR2019-00646, Ex. 2121 ¶1: "I am the sole member of RAH Color Technologies LLC").
• Current status: Appears to remain an active asserting entity as of the 2019–2020 PTAB record; I found no evidence of dissolution, bankruptcy, or acquisition of the LLC. The patent itself, however, is lapsed: Google Patents lists legal status "Expired – Fee Related," expiration 2018-08-29 (i.e., the '052 went dead around the time RAH was consolidating its MDL). Note the entity address in later complaints is 7012 Colgate Drive, Alexandria, VA 22307, and later-issued family patents (e.g., US 9,500,527) list "Alexandria, VA" while earlier ones (e.g., US 8,917,394; US 8,279,236) list "Rochester, NY."

Title-chain nuance: Although the LLC is styled the assignee on the issued '052, the recorded assignment of 2010-10-04 runs from Holub personally to the LLC (Google Patents lists assignor "HOLUB, RICHARD A., PHD, DR."). So legal title originated with the inventor; the LLC is an inventor-controlled holding vehicle, not a purchaser from an operating company.

Assignment timeline

Google Patents' Legal Events tab for US 7,715,052 shows exactly two recorded assignment events. I could not obtain reel/frame or correspondent fields (see methodological note).

• 2010-10-04 (date as listed) / recorded date not separately retrievable — Reel/Frame NOT RETRIEVED
  • Conveyance: Assignment of assignors' interest ("ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS)")
  • Assignor: Richard A. Holub, Ph.D. (individual)
  • Assignee: RAH Color Technologies LLC
  • Correspondent: Not retrievable with available tools — not fabricated.
  • Context: Transfer-to-asserter / title-perfecting — the inventor moves personal patent rights into his own licensing LLC roughly 2.5 months before RAH's first identified infringement campaign (see signal 5).
• 2013-05-14 (date as listed) / recorded date not separately retrievable — Reel/Frame NOT RETRIEVED
  • Conveyance: Merger
  • Assignor: RAH Color Technologies LLC
  • Assignee: RAH Color Technologies LLC (same name on both sides)
  • Correspondent: Not retrievable with available tools — not fabricated.
  • Context: Internal reorganization / re-domiciliation of the same Holub-controlled entity (assignor and assignee share the identical legal name; beneficial ownership unchanged). Consistent with the observed Rochester, NY → Alexandria, VA address migration across the family, though the merger predates the address change on the printed patents.

No other assignments (no security interests, no licenses recorded, no third-party transfers, no releases) appear in the patent's legal events.

Timeline diagram

timeline
    title Ownership of US 7715052
    1996 : Filed by Richard A Holub
    2005 : RAH Color Technologies LLC formed
    2006 : Continuation application filed
    2010 : US 7715052 issues
         : Holub assigns rights to RAH LLC
         : RAH enforcement campaign begins
    2013 : Merger recorded within RAH entity
    2014 : First linked litigation W D Michigan
    2018 : Patent expires fee related

NPE / troll-pattern signals

1. Shell-entity transfer — PRESENT (qualified).
   The '052 sits with a licensing-only, single-member LLC with no products (RAH Color Technologies LLC; Holub sole member per Ex. 2121 ¶1; judicial NPE finding in 18-cv-01612-WHO). Tells present: single-member LLC, no products in commerce, licensing-only business model, principal address is a street address in Alexandria, VA rather than an operating facility. Tells absent: it is not a Delaware/Texas registered-agent mail-drop shell, and the transfer was from the inventor himself, not from a distressed operating company. Cite: Legal Events 2010-10-04 (Holub → RAH Color Technologies LLC).

2. Known asserter in the chain — PRESENT.
   RAH Color Technologies LLC is a high-volume, single-plaintiff patent enforcer (10+ suits; MDL No. 2874, In re RAH Color Technologies LLC Patent Litigation, N.D. Cal. 3:18-md-02874), and a federal court expressly characterized it as a non-practicing entity (18-cv-01612-WHO Order at 2). Caveat: I confirmed the assertion campaign and the judicial NPE finding, but I did not confirm RAH on any specific enumerated list (Acacia, Marathon, IV, Wi-LAN, etc.) — RAH is an independent, inventor-owned asserter, not a member of those families. Cite: MDL 2874 docket; RAH v. Seiko Epson (W.D.N.Y. 10-cv-06710, Dec. 21, 2010); RAH v. Adobe/Xerox/Ricoh/Kodak/Heidelberger/Dalim/X-Rite (2016–2019); Adobe IPRs IPR2019-00627/-628/-629/-646.

3. Repeat correspondent across the chain — UNCLEAR (not retrievable).
   The recorded assignment correspondent for the 2010-10-04 and 2013-05-14 events could not be retrieved, so I cannot test for recurrence and I will not guess. One adjacent datum that is verifiable but is not an assignment correspondent: RAH's litigation counsel of record has included David Berten, Global IP Law Group, LLC, 55 W. Monroe St., Suite 3400, Chicago (MDL 2874 Joint Preliminary Status Report, 2019), with Perkins Coie attorneys (Irwin Park, Alison Richards) also appearing for RAH at PTAB. Global IP Law Group is a monetization-side firm; treat this only as a lead to check against the Assignment Center's correspondent field, not as a finding.

4. Cascading transfers — NOT PRESENT.
   Only two recorded events, seven years apart, the second being a same-name internal merger. No chain of LLC-to-LLC hops, no shared-address cluster, no <24-month cascade. Cite: Legal Events 2010-10-04 and 2013-05-14.

5. Pre-litigation transfer — PRESENT.
   The Holub → RAH Color Technologies LLC assignment is listed 2010-10-04; RAH's earliest identified assertion, RAH Color Technologies LLC v. Seiko Epson Corp., W.D.N.Y. No. 10-cv-06710, was filed 2010-12-21 — roughly 2.5 months later, comfortably inside the 6-month window. (I could not positively confirm that the '052 itself was among the Epson patents-in-suit; the '052 issued 2010-05-11, five months before the assignment, and appears in RAH's later complaints including the X-Rite complaint. Treat the link as strong-but-not-perfectly-documented.)

6. Bankruptcy fire-sale — NOT PRESENT.
   No Chapter 7/11 proceeding for Holub or RAH appears in any record reviewed. The closest analog — Imagicolor Corporation's failure — involved no patent sale; the patents were never held by Imagicolor and remained with Holub personally. This is a "commercialization failure without bankruptcy," not a Kodak/Nortel-style fire-sale.

7. Privateering — NOT PRESENT.
   There is no operating-company sponsor behind RAH. The holder is the inventor; there is no evidence of a third-party manufacturer funding assertions against its competitors. This is the pure inventor-operator NPE model, not privateering.

8. Defensive aggregator (anti-NPE) — NOT PRESENT.
   The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. RAH itself is the asserter; the chain ends with the patent lapsing (expired fee-related, 2018-08-29) rather than being neutralized by a defensive buyer.

Verdict

NPE — high confidence.

RAH Color Technologies LLC is the assignee of record (Legal Events 2010-10-04, conveyance "Assignment of assignors' interest," assignor Richard A. Holub), and a federal court found it to be "a non-practicing entity that licenses and enforces the patents of its sole member, Dr. Richard Holub" (N.D. Cal. No. 18-cv-01612-WHO at 2). That gives two strong signals — a licensing-only single-member LLC with no products, and a known high-volume asserter — reinforced by a third: the assignment to the asserting entity was recorded 2010-10-04, only about two and a half months before RAH's first identified infringement suit (Seiko Epson, W.D.N.Y. 10-cv-06710, 2010-12-21), a textbook pre-litigation title-perfecting transfer. The 2013-05-14 "Merger" event is internal housekeeping between identically named RAH entities and does not change beneficial ownership; there are no cascading shell transfers, no bankruptcy sale, and no defensive-aggregator terminus.

Caveats to repeat: (i) reel/frame numbers and the recorded correspondent of record could not be retrieved and are not supplied; (ii) the "known asserter" call rests on the judicial NPE finding and the litigation record, not on confirmed membership in any specific published NPE list; (iii) the link between the 2010-10-04 assignment and the December 2010 Epson suit is chronological and strong but was not confirmed against the Epson patents-in-suit.

Verify at: https://assignmentcenter.uspto.gov/ · https://patents.google.com/patent/US7715052/en

I'll research this systematically, starting with the patent's own citation record and the USPTO record.

Let me try to retrieve the front-page "References Cited" list directly.

Let me pull the FreePatentsOnline and Justia records, which reproduce the front-page references for this exact patent.

Scope note before the answer

I attempted, in this session, to retrieve the front‑page (56) "References Cited" list that is printed on the face of US 7,715,052 B2 itself. I could not reach it:

• The Google Patents full text provided to me as authoritative renders the document through "Summary of the Invention" and stops before the Claims and before any citations table.
• My searches returned the citation tables of different documents — notably the sibling family members US 8,760,704 B2, US 8,917,394 B2, and US 8,537,357 B2, all also titled "System for distributing and controlling color reproduction at multiple sites," and the RAH portfolio generally. Those lists are not the '052 list and I do not attribute them to '052.

So below I give you (A) the prior‑art citations that are actually inside the '052 text I hold — i.e., the references the specification itself identifies and characterizes — and (B) a clearly labelled "cannot verify" statement about the examiner's front‑page list. I also refuse to fabricate a § 102 claim map, for the reason given in Section 3.

One literal‑ID caution: a search hit returned "EP 0775052 A,B". That is a European publication number, a different document. It is not US 7,715,052 and I do not treat it as such.

1. USPTO record for the specific number 7715052

Because the application was filed before 2012‑09‑16 and the claims trace to a 1996 disclosure, pre‑AIA 35 U.S.C. §§ 102/103 govern. That matters for how each reference below is categorized (102(a) vs. 102(b) vs. 102(e)).

2. Prior art cited within the '052 specification (verified — these appear in the text I hold)

The '052 patent carries a substantial "PRIOR ART" section in which the applicant names and characterizes each reference. These are citations of record in the specification, and they are the closest thing to "the citations for 7715052" that I can ground with confidence. I give them in groups keyed to what they teach.

2.1 Patent references

2.2 Non‑patent literature

2.3 What the record's own "prior art keywords" say

Google Patents indexes the '052 prior‑art keywords as: color, rendering, data, display, gamut. That is consistent with the subject matter above and is useful as a search seed for a proper prior‑art sweep.

3. Why I am not assigning references to specific claim numbers

You asked me to state, for each reference, "which claim(s) it potentially anticipates under 35 U.S.C. § 102." I cannot do that responsibly here, and I want to be explicit rather than invent it:

1. I do not have the claim text of US 7,715,052. As flagged in the earlier analysis, the rendering I hold terminates before the Claims section. I have no verified claim numbers, count, or wording — only the abstract (written in claim‑style) and the specification.
2. Anticipation under § 102 requires that a single reference disclose every element of a claim, arranged as in the claim. Without claim language, any "Reference X anticipates claim Y" statement would be fabrication.
3. What I can say from the specification is directional and should be read as § 103 (obviousness) fodder, not anticipation: the applicant affirmatively distinguished each of references 1–33 above, most of them on the ground that they lack (i) colorimetric/device‑independent calibration of a rendering device, (ii) a distributed data structure shared across nodes with node‑local components, (iii) gamut comparison/negotiation between devices, and (iv) verification of the calibration of the rendering device. Any § 102/§ 103 challenge to '052 would have to be built against the actual claim language and would likely be a combination argument.

If you need the verified § 102 map, obtain one of these, all of which reproduce the printed front page including box (56):

• USPTO Patent Public Search / PatentCenter for application 11/452,546 (gives the examiner's cited references with the examiner's claim rejections);
• the patentimages PDF for US 7,715,052 (front page, left column);
• the file wrapper for 11/452,546 and its parent 11/246,813, whose examiner's actions will show exactly which claims each reference was applied against.

4. Family‑overlap references (retrieved, but NOT verifiable as '052's list)

For completeness, the citation tables I did reach belong to sibling Holub patents sharing the '052 specification. Representative references appearing on those siblings' faces include U.S. Pat. No. 2,790,844 (Neugebauer), 4,500,919 (Schreiber), 4,987,496 (Greivenkamp), 5,107,332 (Chan), 5,272,518 (Vincent), 5,307,257/5,309,257 (Bonino), 5,736,xxx (McLaughlin et al.) (display calibration), 5,459,678 (Feasey), 5,363,318 (McCauley), 5,345,315 (Shalit), 5,333,069 (Spence), 5,319,437/5,319,437? (Van Aken), 5,313,291 (Appel), 5,307,082 (Bret), 5,303,165 (Ganz), 5,771,xxx (Goldstein), 5,767,980 (Wang), 5,850,472 (Alston), 5,835,817 (Bullock), plus foreign documents EP 0 562 973 and EP 0 579 224.

These are offered only as leads. I could not confirm that any of them appears on the face of US 7,715,052, and I do not represent that they do. Note also the internal inconsistency in the family renderings themselves (e.g., "Bonino 5,307,257" vs. "5,309,257"; "Grevenkamp"/"Giveonkamp"/"Gruvenkamp" for Greivenkamp) — spellings and digits in these OCR'd lists are unreliable and should be checked against the printed patent.

5. Bottom line

• Confirmed: US 7,715,052 B2 is the Holub "System for distributing and controlling color reproduction at multiple sites," application 11/452,546, priority chain to 08/606,883 (1996‑02‑26). Not to be confused with EP 0775052 or with any of the several unrelated "'052" patents (e.g., Pantech's 8,893,052, Cellect's '052) that appear in search results.
• Confirmed, with specific citations: 33 prior‑art references are named and characterized inside the '052 specification itself — listed and dated in Section 2 above, with pre‑AIA § 102(a)/(b) posture indicated. The most § 102‑relevant candidates (published more than one year before the 1996‑02‑26 priority) are Neugebauer '844, Schreiber '919, Greivenkamp '496, Chan '107,332, Sobol '185,673, Kipphan '182,721, Vincent '272,518, Eouzan '231,481, Bonino '309,257, Rose '200,816, and the 1993 MCT Specification.
• Not verified — do not rely on it: the examiner's box‑(56) citation list for US 7,715,052, and therefore any reference‑to‑claim number mapping. The Google Patents rendering I hold excludes both the claims and the citation table, and my searches returned sibling documents' tables instead. Pull the front page from USPTO PatentCenter or the patentimages PDF, or the 11/452,546 file wrapper, to close this gap.

I'll first try once more to obtain the actual claim text (the prior sections flagged it as unretrieved), then build the § 103 analysis on the Prior Art section of the record.

Let me check the outcome of the closest sibling-patent IPRs, since those are the best available real-world § 103 test of this specification.

Obviousness Analysis — U.S. Patent No. 7,715,052 B2 under 35 U.S.C. § 103

Prepared: April 26, 2026 · Analyst: technical patent analyst
Primary source: the full Google Patents record for US 7,715,052 B2 (https://patents.google.com/patent/US7715052/en), treated as authoritative, and specifically its Background of the Invention / PRIOR ART narrative and its "prior art keywords" field (color, rendering, data, display, gamut). Supplemented where noted by live-search materials, which I cite by URL.

0. Carry-forward from the prior sections — including one item I must flag

The earlier sections of this analysis established (and I do not repeat here): bibliographic data, the § 102 chain to the Feb. 26, 1996 parent, the assignee/expiry posture, and the litigation finding that the only case asserting '052 was RAH Color Technologies LLC v. X-Rite, Inc., W.D. Mich. 1:14-cv-00638.

Build-on point. This session's searches confirmed two prior findings and added three facts the earlier sections did not have:

1. Confirmed: No IPR, PGR, CBM, or CAFC proceeding names 7,715,052. The four Adobe IPRs were IPR2019-00627/-00628/-00629/-00646, targeting the '008, '444, '897, and '761 patents (Decision Granting Institution, https://www.docketalarm.com/cases/[PTAB](/ptab)/IPR2019-00646/.../Order-75-Decision_Granting_Institution_of_Inter_Partes_Review.pdf).
2. Confirmed: the X-Rite complaint lists the '052 as Patents-in-Suit "Exhibit 4" (https://www.docketalarm.com/cases/PTAB/IPR2019-00628/.../Exhibit-2222...Complaint__X_Rite.pdf).
3. New — the body's own words on '052's subject matter. The same complaint body states the '052 is "also entitled 'System for Distributing and Controlling Color Reproduction at Multiple Sites' (the '052 patent) (Exhibit 4)."
4. New — the '052 shares its specification with the '870 and '444. In the N.D. Cal. claim-construction order in RAH v. Adobe / MDL 3:18-md-02874 (https://storage.courtlistener.com/recap/gov.uscourts.cand.[327437](/patent/327437)/gov.uscourts.cand.327437.120.0.pdf), the court states: "Both patents are titled 'System for Distributing and Controlling Color Reproduction at Multiple Sites,' and they share a specification." The same order identifies only three construed family terms: "sites", "appear substantially the same", and "interactive conference" — and notes "None of the PTAB decisions construed any of these claim terms." This is directly usable here, because the '052 abstract uses the identical phrase "appear substantially the same."
5. New — the closest sibling § 103 outcomes. The '444 (same spec, same title) went to a Final Written Decision on Aug. 31, 2020: "Determining No Challenged Claims Unpatentable" — Adobe, on ICC v.3.01 + TIFF 6.0 + Beretta, lost (https://www.docketalarm.com/cases/PTAB/IPR2019-00628/Inter_Partes_Review_of_U.S._Pat._8416444/docs/08-31-2020-Board/Notice-125-JUDGMENT_Final_Written_Decision.pdf). The '008 FWD likewise found the challenged claims not unpatentable (https://bannerwitcoff.com/wp-content/uploads/2020/09/PTAB-IPR2019-00627-124.pdf). A later proceeding reached claims 2–4 of the '444 in 2022 and found them unpatentable over Tayloe + TI Datasheet, affirmed by Rule 36 judgment June 5, 2024 (https://www.supremecourt.gov/DocketPDF/24/24-518/[331105](/patent/331105)/20241104163210189_No.%2024-_____%20Petition.pdf).

Contradiction flag (none material). I found no statement that contradicts the prior sections. The only unresolved item is the claim list: the earlier section reported asserted claims 9, 10, 12–16, and 33–41 for '052. My retrieved excerpt of the X-Rite complaint shows the '052 among the ten Patents-in-Suit but does not itself display those claim numbers. I therefore treat 9–16 / 33–41 as second-hand and continue to refuse to recite '052 claim language. Everything below is therefore written at the limitation-cluster level, keyed to the '052 abstract (claim-style recitation), the specification, and the sibling claim numbering.

I. Framework and the governing law

Pre-AIA § 103 applies. The '052 was filed June 14, 2006 and claims pre-March-16-2013 priority throughout. Under AIA § 3(n)(1) it is examined and judged under pre-AIA 35 U.S.C. § 103(a) — no "obvious to try" overlay is required, and critical date is presumptively February 26, 1996. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) nonetheless supplies the operative rationales (MPEP 2143): (A) combining prior-art elements by known methods; (B) simple substitution; (C) use of a known technique to improve a similar device; (D) applying a known technique to a known device ready for improvement; (E) obvious to try; (F) known work in one field prompting variation in another. Graham v. John Deere supplies the four factual inquiries.

The priority-date lever (§ 112 → § 103). Because the '052 is a straight continuation — not a CIP — every claim must be supported by the 1996 disclosure to earn 1996 priority. Any claim that reads on subject matter first disclosed in the 1999, 2002, or 2005 intervening applications loses the 1996 date and becomes subject to 1996–2006 art: ICC v.3.0/3.01 follow-ons, Adobe Photoshop 5.0 (1998), the Zuber color-correction patents, Barry et al. multiple-print-engine patents, Petchenkine prepress-workflow patents, and — importantly — **Davis et al., "Remote print press proofing system" (U.S. 6,381,343, Apr. 30, 2002)**, which is a directly on-point "remote proofing over a network" reference. This is an independent, and often overlooked, § 103 route that does not require proving the 1996 date at all.

II. Level of ordinary skill (POSITA)

A POSITA at Feb. 1996 would have: a bachelor's in imaging science, color science, EE, or CS, plus 3–5 years in graphic-arts color reproduction — or an advanced degree plus 1–2 years. The POSITA would know, without invention: CIE 15.2 colorimetry and CIELAB/CIELUV; spectrophotometry and imaging colorimetry; polynomial/regression device models and their inversion by gradient descent; interpolation-table (LUT) evaluation of transforms; GCR/UCR and total-area-coverage limits; the ICC Profile Format (v.3.01, May 8, 1995) and the MCT specification; and LAN/WAN/ISDN/TCP-IP networking. Notably, the N.D. Cal. record shows the patentee's own expert (Dr. Vrhel) testifying to this baseline for the "appear substantially the same" limitation — "persons in the field were aware of the use of color errors and tolerance values for color accuracy" (Vrhel Decl. ¶¶ 42–45, cited at the above courtlistener URL). That testimony is POSITA-admission evidence usable against '052's broadest claims.

III. Prior-art inventory from the patent's own Prior Art section

Grouped by what each reference supplies. All are from the '052 record unless marked.

IV. Limitation clusters and mapping

I label the limitations (L1–L14) exactly as the '052 abstract and specification frame them, with the likely claim correspondence noted.

V. Combinations that would render the claims obvious

Ground A — Holub '88 + Vincent '518 + Södergård '91 (the core architecture) → L1–L3, L5–L7, L9

Why obvious. Holub '88 supplies, in one reference, colorimetric device calibration, imaging colorimetry, 4-colorant rendering transforms, and soft-proofing requirements. Vincent '518 supplies the measurement instrument and expressly gestures at network-wide consistency — the motivation language is in the reference itself. Södergård '91 supplies network distribution of color image data to a remote display for proofing, i.e., L2–L3. The combination is a textbook MPEP 2143(A)/(C) case: known elements (colorimeter + device model + network) assembled by known methods with a predictable result. Vincent's own silence on how distributed calibration would work is the classic "known gap prompting improvement" rationale, not a teaching away.

Ground B — ICC v3.01 + MCT + Södergård '91 (+ imagexpo) → L4, L11, L14

Why obvious — and this is the strongest ground, because the motivation is authored by the patentee.

• The '052 record expressly faults the ICC format: "The ICC Profile Format provides for embedding profiles with image data: This generates large data transfers over a network whenever profiles are updated." That is an admission that the art presented a known problem whose known solution is to separate the transformation data from the image data — which is precisely the shared/local Virtual Proof split of L4.
• The record further faults ICC for supporting only "scnr/mntr/prtr" and being "not readily extendable." Generalizing a data format to more device classes is MPEP 2143(C).
• MCT supplies the same "transformation data in files" concept.
• Södergård '91 transmits actual image data at display resolution; obviating that retransmission is the stated object of the invention ("revising color … without requiring re-transmission of large image data files").
• imagexpo supplies the shared remote annotation substrate for L11/L14; its own publicity admits the color-critical gap — an express invitation to fill it.

Ground C — Hardy–Wurzburg + Pobboravsky + Schwartz + Gallagher → L6, L7

Forward model (Pobboravsky polynomials) → iterative gradient inversion with feedback (Hardy–Wurzburg, digitized by Schwartz) → sparse-table interpolation for speed (Gallagher). Motivation: polynomial evaluation is too slow for real-time inversion, which is the express reason Gallagher exists; Schwartz's own work is presented in the record as the digital implementation of Hardy–Wurzburg.

Ground D — Neugebauer '56 + Gordon '87 + Bonino '257 (+ Holub '88) → L8, L13

Colorimetric gamut descriptions (Neugebauer '56), explicit input-gamut→output-gamut operators (Gordon '87), and harmonization of multiple devices to a commonly achievable maximum (Bonino '257) together yield L8's "appear substantially the same within the output colors attainable." Bonino's photometric-only (non-colorimetric) teaching is a quality difference, not a patentable one — "better alternatives exist" does not defeat obviousness (Adobe made exactly this point at the '761 hearing: "a piece of prior art doesn't have to be superior implementation").

Ground E — Vincent '518 + Kipphan '721 + Chan '332/Sobol '673 → L9, L10

This is the cleanest motivational chain in the record. Vincent: no self-checking. Kipphan: CIELAB-vs-aim comparisons and corrections into the ink keys, but "the operator must be pro-active … the calorimeter [may go] out of calibration, since it is not capable of calibration self-check," and it does not read image area. The '052's own Background recites these deficiencies verbatim. Combining them to obtain automatic, image-area, closed-loop verification and revision is MPEP 2143(A)/(C) with the motivation stated by the patentee.

Ground F — Boll '94 + Schwartz '85 + Holub '88 + MCT/ICC → L12

Seven-colorant "supergamut," 4-color GCR, and the print-device class. The record's criticism of Boll ("severely limits flexibility in performing GCR") is a preference between known alternatives, and the claimed subject matter is merely "more than four colorants" — not any particular GCR allocation. Under In re Merck / In re Keller, the patentee's own disclosure cannot be used to show the prior art was inferior for the claimed purpose.

Ground G — Kipphan '721 + Södergård '93/'95 + Greivenkamp '496 → production-node control

On-press image-area colorimetry (Södergård '93/'95) + aim-value feedback to press controls (Kipphan) + descreening for screening/rosette aliasing (Greivenkamp). Motivation: Kipphan's color-bar blind spot, expressly noted in the record.

Ground H — Neugebauer '844 + Eouzan '481 + Bonino '257 + Schreiber '919 → soft proof at prototype nodes

Projection of a video image onto printing paper with matched viewing conditions (Neugebauer '844) + camera-based display calibration (Eouzan '481) + hard-copy-to-monitor matching (Schreiber '919).

Ground I — Rose '816 + Holub '88 (neural nets) and Garini/Shnitser/Hoyt (spectral imaging)

Alternative, enablement-supporting teachings for the forward model and for imaging colorimetry. These are weak as primary § 103 references but useful as "the POSITA had a finite, known set of options" evidence under KSR.

Ground J — the § 112 escape hatch: post-1996 art on any claim lacking 1996 support

If any of asserted claims 9–16 / 33–41 reads on subject matter first added in the 1999 ('002), 2002 ('664/'870), or 2005 ('813) applications, the critical date slides forward and Davis et al. (U.S. 6,381,343, "Remote print press proofing system," 2002) and the ICC v3.0/Adobe Photoshop 5.0 family become available — with a very short obviousness bridge.

VI. Secondary considerations — and why they are weak here

• Licensing/industry praise. Already litigated and discounted: in the '444 institution decision the Board held the licensing evidence did not show nexus to "recognition and acceptance of the claimed subject matter," giving it "little or no weight" (IPR2019-00628 Institution, URL above). Adobe's expert Poynton testified that many of the 17 licensees took licenses to avoid litigation cost. Any '052 obviousness defense should expect the same treatment.
• Unexpected results. None suggested by the record; the stated benefits (uniform appearance, reduced waste, no retransmission of image data) are the predictable consequences of combining the cited art.
• Teaching away. None. The closest candidate — Bonino's photometric (non-colorimetric) approach — is a deficiency, not a contrary teaching.

VII. Where the § 103 case is weakest (the honest counterweight)

1. The '444 and '008 died on exactly this kind of ground. In IPR2019-00628, Adobe attacked the same-specification '444 with ICC v3.01 + TIFF 6.0 + Beretta — all pre-1996 art squarely on the shared/local data-structure and profile points — and the Board's Final Written Decision of Aug. 31, 2020 held "no challenged claims unpatentable." IPR2019-00627 on the '008 reached the same result. The '052's asserted claims are, on the present record, at least as strong as the '444's. That is the single most important fact in this analysis, and it cuts hard against a confident invalidity prediction.
2. The "identify every limitation" trap. In Ex parte Edge, Appeal 2006-3279, App. 10/039,668 (https://law.onecle.com/board-of-patent-appeals/2007/fd2006327903-20-[2007004](/patent/2007004).html), the Board reversed a rejection that relied on exactly this "Holub" specification, because "the rejection … does not identify what may be considered a 'view condition' for an image in the cited portions of Holub." Rejections built on the Holub disclosure have a documented history of failing the specificity requirement.
3. The '444's later loss shows the flip side. A 2022 FWD found the '444's claims 2–4 unpatentable over Tayloe + TI Datasheet (Rule 36 aff'd June 5, 2024). So the family's narrower/later claims are demonstrably vulnerable to different, post-1996 art — reinforcing Ground J.
4. Unclaimed-but-load-bearing features. The specification's genuinely distinctive allocations — e.g., verifying integrity by comparing summaries of calibration data accumulated from multiple prior calibration operations (this appears as a family limitation, e.g., CA 2,247,005 cl. 126), or reciprocal/smooth gamut operators ('870 cl. 37), or exchangeable neutral colorants ('761 cl. 7) — are not shown in any single one of the record's Prior Art references and were the subject of the PTAB's non-institution-favorable rulings. If any of asserted claims 9–16 / 33–41 carries such a limitation, Grounds A–I fail as to that claim.
5. The threshold uncertainty. I still cannot read the '052 claim column. Every ground above is mapped to the abstract's claim-style recitation and the specification; none is mapped to verified '052 claim language. That limitation governs the weight of everything in § V.

VIII. Bottom line

1. On the record's own Prior Art section, a POSITA would have found it obvious to build a multi-node, network-distributed color-reproduction system in which each node's rendering device is colorimetrically calibrated by a spectral/imaging colorimeter, driven by a stored color transformation generated from that calibration, and harmonized to a common aim within each device's attainable gamut. The combination that best does this is Holub et al. (1988) + Vincent U.S. 5,272,518 + Södergård et al. (1991), with Pobboravsky + Schwartz + Gallagher supplying the transformation-generation steps and Kipphan U.S. 5,182,721 + Chan U.S. 5,107,332 supplying verification/revision.
2. The strongest single ground is the data-structure ground (B): ICC Profile Format v3.01 + MCT + Södergård (1991) + imagexpo, because the motivation to separate transformation data from image data is admitted in the '052 record itself ("large data transfers over a network whenever profiles are updated").
3. But the empirical evidence from this very specification is that these grounds fail in practice. Adobe's ICC/TIFF/Beretta attack on the same-specification '444 failed outright (FWD Aug. 31, 2020), as did the attack on the '008. Absent verified '052 claim text showing that its claims are materially broader than the '444's — or a successful priority-date challenge under Ground J opening up 1996–2006 art such as Davis U.S. 6,381,343 — I would not predict a § 103 invalidation of the asserted '052 claims on the Prior Art section alone. My confidence in that negative is moderate, and it would rise or fall materially the moment the '052 claim column is pulled from USPTO Patent Public Search or the patentimages PDF.