Invalidity dossier
US 6312106
Method and apparatus for transferring information between a replaceable consumable and a printing device
Current assignee: Hewlett Packard Development Co LP
Added 9/30/2026, 10:11:02 AM
Active provider: DeepSeek · deepseek-flash
Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll run targeted searches for this patent, including litigation/docket checks.
Now let me check for litigation and any 2026 CAFC activity.
One more check for PTAB/IPR or district court activity.
Search Report — US Patent 6,312,106
Search scope note: I searched for this exact number (both "6312106" and the formatted "6,312,106") against Google Patents, USPTO-report, Unified Patents portal, EPO/INPADOC family data, and generally for litigation, PTAB and CAFC activity. I did not have direct PACER/CAFC docket-system access — only open web search. No USPTO or CAFC 2026 docket entry, infringement suit, IPR, or appeal involving this patent surfaced. I therefore cannot state affirmatively that none exists; I can only report that nothing appeared in these searches. All bibliographic data below is taken from the patent's own front-page/Google Patents record, which is the authoritative source here.
Bibliographic data
| Field | Value |
|---|---|
| Patent number | US 6,312,106 B1 |
| Title | Method and apparatus for transferring information between a replaceable consumable and a printing device |
| Inventor | Ray A. Walker (Eugene, Oregon, per the Official Gazette record for the continuation) |
| Original assignee | Hewlett-Packard Company |
| Current assignee | Hewlett-Packard Development Company, L.P. (Houston, TX) |
| Application number | US 09/295,080 |
| Filing date | 1999-04-20 |
| Priority date | 1999-04-20 (per the record's stated assumption) |
| Issue / publication date | 2001-11-06 |
| Claims | 22 (5 independent: 1, 7, 15, 19, 22) |
| Status | Expired – Lifetime (anticipated expiration 2019-04-20) |
| Classifications | B41J 2/17546; B41J 2/17503 (ink cartridge presence/type identification, electronic) |
Family / prosecution: The application is recorded as a continuation-in-part of US 09/148,039 (filed 1998-09-03, granted as US 6,039,430). Its own continuation is US 09/943,477, filed 2001-08-30, granted as US 6,676,240 B2 (2004-01-13) under the same title and with the same specification; that continuation is recorded as subject to a terminal disclaimer. Caveat: the database listing also shows US 09/410,989 as a "related parent," but that application was filed 1999-10-01 — after this patent's 1999-04-20 filing — so that parent/child label appears internally inconsistent and I'd treat it as a record-keeping artifact rather than a real priority link.
Cited prior art (7): US 5,049,898; US 5,266,968; US 5,396,078; US 5,699,091; US 6,027,195; WO 1998052762 A2 (Encad, "Intelligent Printer Components and Printing System"); US 6,039,430 A. Non-patent literature: Motorola, "RFID: Everything You Need to Know," 11/11/97, pp. 1–19.
Abstract (as issued)
"The present invention relates to a marking engine for use in a marking machine. The marking engine is responsive to control signals for selectively depositing marking material on media. The marking engine includes a housing associated with the marking engine. The housing is configured for docking with the printing system. The housing has an undocked position and a docked position wherein the housing is secured to a receiving station associated with the marking machine. Also included is a radio frequency linking device mounted to the housing so that there is substantially no relative movement between the radio frequency linking device and a corresponding radio frequency linking device associated with the receiving station when the marking engine is in the docked position with the marking machine. The radio frequency linking device provides a radio frequency link for transferring information between the marking engine and the marking machine."
Note that the abstract describes only the RF linking device and the no-relative-movement geometry; it does not mention the electrical storage device that claim 1 requires.
Plain-language overview of the independent claims
Claim 1 — Replaceable marking engine with RF link (apparatus).
A replaceable "marking engine" (e.g., toner cartridge/electrophotographic engine, or an ink-ejection engine) has a housing that docks into a receiving station, with an undocked and a docked position. Mounted on the housing are (a) an electrical storage device holding information, and (b) an RF linking device coupled to that storage device. The RF device is positioned so that, when docked, it sits within a "capture region" of, and at a specific controlled orientation relative to, a mating RF device in the receiving station. It then provides a wireless RF link that transfers the stored information without electrical conductors directly connecting the two units — and only when that capture-region/orientation condition is met. Being outside the capture region, or mis-oriented, prevents information transfer.
Literal-text note: the issued claim reads "a housing associated with the marking canine," which is an evident typographical/OCR error for "marking engine" (it recurs in the granted text). I am preserving it as written rather than silently correcting it.
Claim 7 — Replaceable consumable with wireless communication device (apparatus).
Same structural idea, broader vocabulary: a replaceable consumable with a docking housing, a storage device, and a wireless communication device (not limited to RF) that moves information through the atmosphere with no direct electrical connection. Again, information transfer occurs only when the device is inside a capture region and at a particular controlled orientation of the corresponding wireless device in the printing system.
Claim 15 — Method of transferring information (process).
Method steps: (1) insert the consumable into the docking station so that its wireless device lands within the capture region and at the specific controlled orientation; (2) provide a time-varying voltage to a signal terminal of that wireless device sufficient to induce a supply voltage at a power conditioner — i.e., the consumable side is passively powered by the printer's field; and (3) transmit the stored data wirelessly to the printing system, without a direct electrical connection, and only when the capture-region/orientation condition is satisfied.
Claim 19 — Method of preparing a consumable for communication (manufacturing/configuration process).
Steps: store consumable-related information in a storage device associated with an RF linking device, then affix that storage device and RF linking device to the consumable at a location chosen so that, upon insertion, the RF device is within the capture region and at the specific controlled orientation of the printer-side RF device — again with transfer occurring only when that positional/orientational condition is met.
Literal-text note: dependent claim 20 recites the RF device being capable of receiving "inflation" from the corresponding RF device — evidently a typographical artifact of "information." Flagging rather than correcting.
Claim 22 — Printing system with consumable (system).
A printer portion with a docking station containing a first RF linking device, plus a replaceable consumable containing a second RF linking device. Proper insertion places the second device within the capture region and at the specific controlled orientation of the first, allowing wireless information transfer without electrical connectors, and only under that condition. The claim expressly ties this to an advantage: it permits the use of relatively low-cost short-range RF devices.
Technical gist (from the specification)
The patent addresses reliability problems of contact-based memories on replaceable printer consumables — contamination/corrosion from inks and skin oils, mechanical damage to contacts, and ESD damage to CMOS storage. It replaces exposed contacts with a short-range wireless (RFID-style) link, preferably 125 kHz–13.56 MHz (spec. at FIG. 4 discussion). The consumable side can be passive, deriving its supply voltage from the induced field via a power conditioner (rectifier + filter), eliminating any direct power/ground connection. The claimed novelty is positional rather than merely wireless: the consumable's RF device is fixed on the housing so that docking places it in a fixed, closely-spaced, correctly-oriented relationship with the printer's RF device (FIGS. 5–6 illustrate why mis-orientation (38′) or excessive spacing (38″) defeats the link). The stated benefits are lower RF power, smaller antennas, lower device cost, reduced radiated emissions/RFI, and relaxed mechanical alignment tolerances versus multi-contact interconnects. The specification also distinguishes the Encad WO '762 media-roll RFID system on the ground that a moving media roll has continuously changing spacing/orientation, unlike the stationary docked consumable here.
Uncertainty flags
- Litigation/docket: No 2026 CAFC or district-court activity found in open-web searches. This is a negative search result, not confirmation of no activity; a PACER/CAFC docket query would be needed to be authoritative.
- Priority: The recorded priority date (1999-04-20) is expressly stated in the record as an assumption, not a legal conclusion. Given the CIP relationship to US 09/148,039 (1998-09-03), actual effective filing dates for particular claims may differ.
- Claim-text artifacts: "marking canine" (claim 1) and "inflation" (claim 20) appear to be typographical errors in the granted/OCR text; I have quoted them literally rather than correcting them, per the instruction to interpret identifiers literally.
Generated 9/30/2026, 10:32:58 AM
Cases on file (0)
Specific litigation cases in our database that name US patent 6312106. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll search litigation databases for US patent 6,312,106.
Let me search more specifically for litigation records.
Let me try more targeted litigation-specific searches.
Litigation Search: U.S. Patent No. 6,312,106
Bottom line
I found no litigation involving U.S. Patent No. 6,312,106. My searches returned no district court complaints, no CAFC appeals, no PTAB proceedings (IPR/PGR/CBM), and no ITC investigations in which this patent was asserted or challenged.
Because I could not complete the full set of searches I intended (I hit a tool limit partway through — see "Search limitations" below), I want to be precise about what I did and did not confirm.
Patent identity (to avoid number confusion)
Per the authoritative patent text provided:
| Field | Value |
|---|---|
| Patent No. | US 6,312,106 B1 |
| Title | "Method and apparatus for transferring information between a replaceable consumable and a printing device" |
| Inventor | Ray A. Walker |
| Original assignee | Hewlett-Packard Company |
| Current assignee | Hewlett-Packard Development Co. LP |
| Application No. | US 09/295,080 |
| Filed | 1999-04-20 |
| Granted | 2001-11-06 |
| Status | Expired – Lifetime (anticipated expiration 2019-04-20) |
Note: this is not the same as its sibling US 6,302,527 ("…between a printer portion and a replaceable printing component," App. 09/415,331), nor its continuation US 6,676,240 (App. 09/943,477), nor its parent US 6,039,430. Those are distinct patents with their own litigation histories. Do not conflate search hits for those numbers with the '106 patent.
What the searches returned
- Unified Patents portal — The patent page (
portal.unifiedpatents.com/patents/patent/US-6312106-B1) exists and was indexed, but the content surfaced was only the patent's own bibliographic/prior-art data (e.g., Motorola "RFID: Everything You Need to Know," US 5,049,898, US 5,266,968, US 5,396,078, US 5,699,091, WO 1998/052762, US 6,027,195, US 6,039,430). No litigation or PTAB entries appeared attached to this patent. - Other results were false positives about different patents (e.g., Intertrust '106, Barkan '312/'284/'638, MCOM '508, Orange/道通 '064, DePuy '678). None involved US 6,312,106.
- Google Patents family data confirms only prosecution/family relationships (continuations-in-part and continuations), no litigation field entries.
Why no litigation is plausible here
- Expiration. The patent expired 2019-04-20. Damages windows closed years ago, which sharply discourages new assertions.
- Assignee profile. HP is a large operating company, not a litigious NPE; it generally cross-licenses rather than sues on cartridge-RFID patents of this vintage.
- Technical scope. The claims cover RF/memory linking between a replaceable consumable and printer with docking capture-region/orientation limitations — later cartridge-RFID disputes generally turned on other HP/Seiko Epson/Canon patents, not this one.
Search limitations (please read)
I was cut off before I could run the remaining planned queries (Docket Alarm, Justia Dockets, CourtListener/RECAP full-text, PACER, and CAFC docket searches). Therefore:
- My negative result is "not found in the sources I searched," not a verified statement that no case ever existed.
- Pre-2005 filings may not be fully digitized in free databases, and cases settled early or transferred may not surface in keyword searches.
- Unified Patents' portal lists PTAB activity well but does not comprehensively cover district court filings for every patent.
Recommended next steps to close the gap
- Unified Patents litigation caselist —
https://portal.unifiedpatents.com/litigation/caselistand the patent page itself; verify the "Litigation" tab is empty. - CourtListener / RECAP — full-text search "
6,312,106," "6312106," and "US09/295,080." - PACER — search the patent number across all districts (note fees; also check the CAFC docket for appeals naming the '106 patent).
- Docket Alarm / Justia — search the plain number
6312106and theB1variant. - USPTO Patent Center / Global Dossier — confirm there are no reexaminations, IPRs, or terminal disclaimers tied to the '106 that hint at prior disputes.
- HP litigation history — check whether HP ever asserted this family (e.g., in its cartridge refill cases), which would show up under sibling patents rather than the '106 itself.
If you need a definitive answer, run searches 1–3 above; those three together would conclusively confirm or refute the existence of any case for US 6,312,106.
I'd rather flag the gap than assert "no litigation ever existed" without having queried PACER and the CAFC docket directly.
Generated 9/30/2026, 10:33:01 AM
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.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll start by verifying the structured data against live web search for any AIA trial proceedings, Federal Circuit appeals, or district court activity that the ODP may not have indexed.
Let me run additional targeted searches to be thorough about any AIA proceedings, appeals, or Unified Patents activity.
Let me do a final verification pass on litigation history and the Unified Patents portal, plus confirm the expiration status.
Proceedings overview
Zero AIA trial proceedings on file. The USPTO Open Data Portal returns no IPR, PGR, or CBM petitions against US 6,312,106, and my corroborating web searches (Google Patents, Unified Patents' patent portal, PTAB/CAFC-focused queries) surfaced no petition, institution decision, final written decision, or Federal Circuit appeal for this patent number. The breakdown is therefore: 0 active / 0 claims invalidated / 0 claims sustained / 0 settled / 0 institution-denied — i.e., the patent has never been tested at the PTAB.
The bottom line for a defendant is not the usual "hardened by surviving IPRs" story. It is more fundamental: US 6,312,106 expired on 2019-04-20 (Google Patents lists legal status "Expired – Lifetime," anticipated expiration 2019-04-20; filing/priority date 1999-04-20, granted 2001-11-06). An expired patent cannot ground prospective (ongoing) infringement, only backward-looking damages — and only if a qualifying suit was filed within the six-year lookback of 35 U.S.C. § 286. Any assertion today should be stress-tested first on expiration and § 286 timeliness before you spend a dollar on invalidity contentions.
Caveat on method: I was able to run only a limited set of live queries before hitting a tool-call ceiling. Absence of search hits is corroborating, not dispositive — the canonical negative is the structured ODP block, which is what I'm relying on. If you need a belt-and-suspenders record, pull the patent's PTAB E2E docket and the CAFC docket directly.
Proceedings
(No proceedings to report. Per instruction, most-impactful-first ordering does not apply because there are none. I am expressly declining to invent proceeding numbers, panels, or dispositions.)
No AIA trial proceedings identified — US 6,312,106
- Type: N/A (no Inter Partes Review, Post-Grant Review, or Covered Business Method review on file)
- Filed: N/A
- Status: "No PTAB activity on file" (ODP structured data; web search corroborates)
- Judge panel: N/A
- Petition grounds: N/A
- Institution decision: N/A
- Final Written Decision: N/A
- Settlement / termination: N/A
- Appeal: No Federal Circuit appeal of any PTAB or district-court validity ruling on this patent was found. (Note: US 6,676,240 B2 — see family, below — is a continuation of the application that issued as '106, not an appeal.)
- Defensive value: The relevant defensive posture is expiration, not PTAB history. A patent that expired on 2019-04-20 cannot support an injunction or ongoing-royalty theory; recovery, if any, is limited to past damages within the § 286 window. Before treating a demand letter as credible, demand the accused-device sales dates and the complaint date the sender relies on.
Strategic summary
Claim-by-claim status: no claim has ever been canceled, narrowed, or sustained by the PTAB. All 22 claims of US 6,312,106 (independent claims 1, 7, 15, 19, and 22, plus dependents 2–6, 8–14, 16–18, 20–21) remain exactly as issued on 2001-11-06 — not because they were defended and survived, but because no one ever filed against them. So the honest categorization is UNTESTED (all claims), with no CANCELED and no FWD-SUSTAINED claims. Independent claim 1 (replaceable marking engine with a housing, an electrical storage device, and an RF linking device within a capture region at a specific controlled orientation in the docked position) and independent claim 22 (the system-level counterpart) are the broadest assertions, and neither has been construed by the Board.
Estoppel landscape: essentially none from the PTAB side. Because no IPR/PGR was instituted, there is no § 315(e)(2) estoppel tying any petitioner's hands, and no petitioner exists to be estopped. That cuts both ways for a defendant: (a) nothing forecloses you from filing your own IPR, and (b) you get no free ride on someone else's prior art. The practical prior-art universe is drawn from the '106 file and its family: US 5,049,898 (Printhead having memory element), US 5,266,968 (Non-volatile memory thermal printer cartridge), US 5,396,078 (Printer with optical data link to carriage), US 5,699,091 (Replaceable part with integral memory — the parent-family reference), WO 1998/052762 (Encad, "Intelligent printer components and printing system" — the media-roll RFID system the '106 specification itself distinguishes), and the non-patent literature Motorola, "RFID: Everything You Need to Know," 11/11/97, pp. 1–19. Note the specification repeatedly stakes its novelty on fixed, close-spacing/controlled-orientation coupling versus Encad's moving media roll — a useful § 103 narrative if you ever have to built a ground.
Pattern signals. There is no serial-petitioner pattern and no defensive aggregator in the chain. The patent was filed by Hewlett-Packard Company (inventor Ray A. Walker; assigned 1999-06-01), reassigned to Hewlett-Packard Development Company, L.P. (2011-09-22), and it is a portfolio/operating-company patent, not a litigation-vehicle patent. That is consistent with the total absence of PTAB activity: HP has historically asserted its print-supply patents in district court rather than being the target of IPRs, and this particular patent expired in 2019. It sits in a dense family — continuations/continuations-in-part including US 6,676,240 B2 (continuation of the '106 application, filed 2001-08-30, subject to a terminal disclaimer, expiring on the same schedule), US 6,494,562 B1, US 6,302,527 B1, US 7,110,127 B2, and US 6,863,377 B2 — so if someone is asserting "the HP RFID-consumable family," identify the specific patent number; the '106's expiration says nothing about its siblings' terms.
Recommended next steps
- Lead with expiration, not invalidity. Confirm the face of the patent and the maintenance-fee record show US 6,312,106 lapsed at the end of its term on 2019-04-20 ("Expired – Lifetime"). If a demand letter cites the '106 for ongoing activity after that date, the theory is legally unavailable. Ask the sender to identify (a) the accused products and their sale dates and (b) the earlier complaint, if any, establishing their § 286 window.
- Check the sibling patents before conceding the family. US 6,676,240 B2 is a continuation of the '106 application under a terminal disclaimer; if the sender pivots to it, verify its expiration and disclaimer chain independently rather than assuming it tracks the '106.
- If an IPR is ever warranted (e.g., a live sibling patent or a § 286-window damages claim on the '106), the institution/eligibility limits are the usual ones — an IPR on a pre-AIA patent can only use § 102/§ 103 grounds on patents and printed publications, and a PGR is unavailable because the patent predates the AIA first-inventor-to-file regime; CBM is closed as of the AIA § 18 sunset. Start from US 5,699,091, US 5,266,968, US 5,396,078, and WO 1998/052762, and build the § 103 case around the specification's own fixed-orientation-versus-moving-roll distinction.
- Preserve the negative record. Download the PTAB E2E docket for US 6,312,106 and, if the sender claims a validity battle, a CAFC docket check, and file them — the ODP "no proceedings" result plus a clean E2E docket is your proof that any "the patent survived IPR" representation is false.
No FWD exists to link, and I will not fabricate one. If your matter turns on a specific sibling patent or a district-court docket I could not reach within this session, tell me the patent/case number and I'll run it down.
Generated 9/30/2026, 10:33:15 AM
Ownership chain (2)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
1999-04-20 · recorded 1999-06-01 · Assignment
2011-09-22 · Assignment
Hewlett-Packard CompanyHewlett-Packard Development Company, L.P.
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.
I'll verify the ownership record for US 6312106 using live sources before reconstructing the chain.
Let me attempt to retrieve the specific reel/frame records and check for any later transfers.
Ownership & Assignment Analysis — US 6,312,106 B1
Patent: Method and apparatus for transferring information between a replaceable consumable and a printing device
App. No.: 09/295,080 · Filed: 1999-04-20 · Issued: 2001-11-06 · Priority: 1999-04-20 · Status: Expired – Lifetime (anticipated expiration 2019-04-20)
Data-quality caveat up front: I was unable to retrieve the specific reel/frame numbers for this patent's recorded assignments from live sources in this session. The Google Patents legal-events record lists the reassignments by date and party but does not expose reel/frame, and the Assignment Center / assignment.uspto.gov record pages did not render in my retrievals. Per the operating rules, I have not invented reel/frame values. Where the section template asks for a reel/frame, I have written
[reel/frame not retrieved]and grounded the entry on the dated legal-event record instead. Anyone needing the exact reel/frame should query the primary source directly.
Inventors
| Inventor | Employer at filing | Notes |
|---|---|---|
| Ray A. Walker (Eugene, Oregon, US) | Hewlett-Packard Company — assignor of record on the 1999-06-01 recorded assignment | Sole named inventor. Residence given as Eugene, Oreg. in the Official Gazette entry for the continuation US 6,676,240 B2, which claims priority to this application. |
Unusual patterns: None detected. This is a single-inventor case, so the classic "all inventors departed the assignee within 12 months" fire-sale precursor cannot apply. There is no evidence in the record of inventor departure, no follow-on assignment by Walker to any third party, and Walker appears only as an assignor to Hewlett-Packard. The related family members (US 6,676,240; US 6,302,527; US 7,110,127; US 6,494,562; US 6,863,377) all list Walker and remain in HP hands, further indicating no inventor-side divestiture.
Original assignee
Hewlett-Packard Company (original assignee, recorded 1999-06-01; assignor: Walker, Ray A.). Current listed assignee: Hewlett-Packard Development Company, L.P. (Houston, Texas), the HP subsidiary that holds the bulk of HP's patent estate.
- Line of business: Computer hardware, printers, and printing supplies. The patent is squarely in HP's core inkjet business — it claims a replaceable marking engine / consumable with an RF linking device that transfers stored information to the printer.
- Shipped a product embodying the claims? Yes, in substance. The claimed subject matter (replaceable printhead/ink container/toner cartridge carrying a memory that communicates with the printer when docked) is the direct ancestor of HP's smart-cartridge architecture; the specification's own prior art (US 5,699,091, Replaceable part with integral memory, assigned to the same assignee) is HP's own work. HP has shipped ink and toner cartridges with on-board memory for decades.
- Current status: Operating. HP Development Company, L.P. is an active operating subsidiary of HP Inc. (the printing/PC company spun from the 2015 Hewlett-Packard split). Not in bankruptcy. The patent itself is expired.
Assignment timeline
The chain is short and entirely intra-HP. Per the Google Patents legal-events record for US 6,312,106:
1999-04-20 (executed) / recorded 1999-06-01 — Reel
[not retrieved]- Conveyance: Assignment (inventor-to-company)
- Assignor: Ray A. Walker
- Assignee: Hewlett-Packard Company
- Correspondent:
[not retrieved]— no distinct outside correspondent is associated with this filing. - Context: Standard employee invention assignment; the patent was filed and prosecuted as an HP-owned application (Application No. 09/295,080). Not a third-party acquisition.
2011-09-22 (executed/recorded per legal-events entry) — Reel
[not retrieved]- Conveyance: Assignment / internal corporate transfer (HP recordation)
- Assignor: Hewlett-Packard Company
- Assignee: Hewlett-Packard Development Company, L.P.
- Correspondent:
[not retrieved]; HP's patent recordation correspondence is historically handled in-house via HP IP Administration (3404 E. Harmony Road, Fort Collins, CO), the address that appears on HP-side chain-of-title papers elsewhere in the portfolio. - Context: Internal reorg / recordation of title into HP's operating patent-holding entity. Not a sale; no consideration flowing to a third party and no licensing-only entity on either side.
2019-04-20 — Anticipated expiration (statutory 20-year term from filing). This is a legal-status event, not an assignment.
No further assignments are recorded. In particular, there is no transfer to any IP-holding LLC, no security agreement, no merger-related recordation, and no assignment to an assertion entity.
Timeline diagram
timeline
title Ownership of US 6312106
1999 : Filed by Hewlett-Packard Company
: Walker assigns rights to Hewlett-Packard
2001 : Patent issued on November 6
2011 : Title recorded to HP Development Company LP
2019 : Patent expires on April 20
NPE / troll-pattern signals
Shell-entity transfer — Not present. The only post-issuance transfer is Hewlett-Packard Company → Hewlett-Packard Development Company, L.P. (recorded 2011-09-22). HPDC is HP's own operating patent-holding subsidiary, not a licensing-only shell: the assignee address is HP's operating address in Houston, Texas, the entity is a well-known operating-company subsidiary, and there is no single-member Delaware/Texas LLC or registered-agent service address anywhere in the chain. No "IP / Patents / Licensing / Holdings / Ventures" suffix appears.
Known asserter in the chain — Not present. Neither Hewlett-Packard Company nor Hewlett-Packard Development Company, L.P. appears on any NPE list (Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, Spangenberg entities). No RPX/Unified high-frequency-plaintiff match. I found no litigation naming US 6,312,106 in the searches performed.
Repeat correspondent across the chain — Unclear / no basis. Correspondent data could not be retrieved for either recorded event (
[reel/frame and correspondent not retrieved]). Because there is only one post-issuance link and it is intra-HP, there is no recurrence pattern to assess even if the correspondent were known. This signal cannot be scored as a finding.Cascading transfers — Not present. One transfer in 1999 (inventor→HP) and one in 2011 (HP→HPDC), twelve years apart. There is no chain of LLCs, no shared correspondent address across multiple assignees, and no transfers within any 24-month window beyond the initial filing-period assignment.
Pre-litigation transfer — Not present. No infringement suit naming this patent was located, and the last transfer (2011) postdates the patent's commercial relevance by a decade. Nothing in the record is timed to a filing date of a complaint.
Bankruptcy fire-sale — Not present. No Chapter 7/11 record for Hewlett-Packard Company or Hewlett-Packard Development Company, L.P. affecting this patent. The 2015 HP Inc./Hewlett Packard Enterprise split was a corporate separation, not an insolvency; this patent stayed with the HP Inc. printing side.
Privateering — Not present. No transfer to an NPE asserting on HP's behalf. HP retained the asset and the patent simply ran to expiration on 2019-04-20.
Defensive aggregator (anti-NPE) — Not present (as a terminal assignee). The chain does not end at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at HP Development Company, L.P. and then at statutory expiration.
Verdict
Insufficient data — read as a negative finding, not a gap in the ownership record.
The chain is fully accounted for and contains zero NPE indicia: Ray A. Walker assigned to Hewlett-Packard Company (executed 1999-04-20, recorded 1999-06-01), and title was later recorded to HP's own operating subsidiary Hewlett-Packard Development Company, L.P. (recorded 2011-09-22), after which the patent expired on 2019-04-20. Neither assignee is a shell or a known asserter, there is no second transfer window, no security interest, and no litigation naming the patent. The only reason this is not scored as an affirmative "non-asserting operating-company" verdict is that the option set has no such label and I could not retrieve the reel/frame or correspondent fields needed to fully complete the record — the substantive conclusion is that this patent never left HP and was never asserted.
Verify at: https://assignmentcenter.uspto.gov/ (search patent number 6312106) — and cross-check the legal-events block at https://patents.google.com/patent/[US6312106B1](/patent/US6312106B1)/en.
Generated 9/30/2026, 10:33:22 AM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll verify the patent and its cited references against live sources before analyzing. Let me run targeted searches.
Let me verify the remaining cited references.
Prior-Art Analysis — US 6,312,106 B1
0. Number verification (done first, as required)
Before analyzing citations I confirmed the target is US 6,312,106 B1 exactly — not a look‑alike number. It appears consistently at:
- Google Patents:
patents.google.com/patent/US6312106— "Method and apparatus for transferring information between a replaceable consumable and a printing device," application US 09/295,080, filed 1999‑04‑20, granted 2001‑11‑06, Hewlett‑Packard Company → HP Development Co. LP. - USPTO-report:
uspto.report/patent/grant/6312106 - Unified Patents portal:
portal.unifiedpatents.com/patents/patent/US-6312106-B1
All three agree on the number, title, filing/grant dates, and assignee. No similar number (e.g., 6312110, 6312096) was returned for these queries. Search-scope limitation: I could not retrieve the full text/claims of three of the seven cited references (US 6,027,195; WO 98/52762; US 6,039,430) within my search budget; for those I rely on the patent's own front-page citation list (authoritative for bibliographic data) and on specification passages that characterize them. This is stated per-record below.
1. How § 102 fits these claims (method note)
Every independent claim (1, 7, 15, 19, 22) of US 6,312,106 contains the same novel kernel: the wireless/RF device must be positioned so that, once docked, it lies "within a capture region of and at a specific controlled orientation relative to" the mating device in the printer, and transfer occurs "only when" that positional/orientational condition is met. Anticipation requires every element of a claim in a single reference. Consequently, a reference anticipates a given claim only if it discloses that capture-region/controlled-orientation limitation. That is the razor I apply below. (This is analysis, not a legal opinion.)
2. The seven cited patent references
2.1 US 5,049,898 A — the closest reference
- Full citation: Printhead having memory element, Hewlett-Packard Company (inventor Arthur et al.), US 5,049,898 A.
- Dates: filed 1989‑03‑20; published/issued 1991‑09‑17.
- Description: A printing apparatus with one or more replaceable ink-jet printheads; a memory element 14 on the printhead housing stores characterizing data (identity, ink color, ink level, orifice-plate alignment). The memory may be magnetic media, semiconductor memory, or optical medium, read/written by a read/write head 44; the specification states "a radio coupling to the printhead may be used" as an alternative. Printer circuitry counts drops and can update ink-level data.
- Anticipation assessment: This is the most structurally similar art — replaceable marking component + onboard memory + (optionally) radio read. Independent claim 1 is not fully anticipated, because US '898 does not expressly disclose the "docked/undocked position" test or the "capture region of and at a specific controlled orientation" limitation, and its primary embodiments are magnetic/optical rather than RF-with-power-conditioner. Claims 3 and 4 (electrophotographic / ink-ejection engine) add nothing the reference lacks, but they depend from claim 1, so they rise or fall with it. Corroborating third-party ruling: the UK IPO, in an Opinion dated 10 Aug 2016 (Patents Act 1977 §74A, re EP 0 877 666 B1, requester Domino / observer Markem‑Imaje), treated US 5,049,898 (cited as "D8") as disclosing a printhead memory element read by radio-type waves, and held it to anticipate a claim directed to a "contactless link by means of radio-type electromagnetic waves." That is strong evidence US '898 discloses the RF-on-printhead idea — but that EP claim did not contain the capture-region/controlled-orientation limitation, so the Opinion does not establish anticipation of US 6,312,106. Source:
assets.publishing.service.gov.uk/.../op1616.pdf.
2.2 US 5,266,968 A
- Full citation: Non-volatile memory thermal printer cartridge, Eastman Kodak Company (inventor Stephenson), US 5,266,968 A (EP counterpart EP 0 562 979 B1).
- Dates: filed 1992‑03‑27; issued 1993‑11‑30.
- Description: A thermal-printer dye-carrier cartridge carrying a non‑volatile memory 60 (battery-backed RAM / Dallas Semiconductor "Memory Button") storing defective-dye-frame location and color-correction data. Communication to the printer is via two electrically separated contacts, and the spec adds that communication "can be accomplished using two or more wires or by the use of opto-electrical or radio frequency communication."
- Anticipation assessment: Discloses a replaceable consumable with onboard memory + the option of RF. It does not disclose docking geometry, a capture region, or controlled orientation; its RF mention is a bare alternative. No independent claim is anticipated; potentially relevant to § 103 as showing RF-on-cartridge was known.
2.3 US 5,396,078 A
- Full citation: Printer with optical data link to carriage, Hewlett-Packard Company, US 5,396,078 A.
- Dates: filed 1993‑09‑22; issued 1995‑03‑07.
- Description: Replaces the printhead ribbon cable with an optical data link 44 (free-air IR, or fiber-optic) between the fixed controller and the reciprocating carriage/printhead; supplies power over the carriage rails; cites reduced RFI/ESD/EMI.
- Anticipation assessment: Different modality (optical, not RF), no onboard consumable memory, no docking/capture-region geometry. Anticipates none of the claims; background art only.
2.4 US 5,699,091 A — the "parent framework" reference
- Full citation: Replaceable part with integral memory for usage, calibration and other data, Hewlett-Packard Company (Bullock, Childers, Hirst, Stephens, Gil), US 5,699,091 A (EP counterpart EP 0 789 322 B1).
- Dates: priority 1994‑12‑22; filed (Ser. No. 08/584,499) 1996‑01‑08; issued 1997‑12‑16. (This is the application the '106 specification expressly identifies as its related parent art.)
- Description: A replaceable part/consumable with an integral serial-access memory on a single data wire replacing a pre-existing fuse, storing usage and calibration data; the printer reads/updates it on cartridge insertion.
- Anticipation assessment: Establishes the "memory-on-consumable storing usage/calibration parameters" concept — which the '106 claims take as a given — but the link is a wired (single-wire) contact, the antithesis of the claimed contactless link. Anticipates none of the claims.
2.5 US 6,027,195 A
- Full citation: System and method for synchronizing the piezoelectric clock sources of a plurality of ink jet printheads, Varis Corporation, US 6,027,195 A.
- Dates: filed 1996‑11‑12; issued 2000‑02‑22.
- Description (limited retrieval): Directed to synchronizing the piezoelectric drive/clock sources across multiple ink-jet printheads. It is a control/synchronization reference, not a memory-on-consumable or wireless-link reference.
- Anticipation assessment: Contains no electrical storage device on a docking housing and no capture-region/orientation teaching. Anticipates none of the claims. (I flag: full text not retrieved within budget — conclusion rests on the citation title/field and the patent's own citation context.)
2.6 WO 1998/052762 A2 — the closest "RFID-on-consumable" art
- Full citation: Intelligent printer components and printing system, Encad, Inc., WO 98/52762 A2 (PCT/US98/07324).
- Dates: filed 1997‑05‑20; published 1998‑11‑26.
- Description: A printing system using a media roll bearing an RFID tag storing media-related information, interrogated by an RF transceiver in the printer as the media roll is in motion.
- Anticipation assessment: This is the reference the '106 specification itself distinguishes: Encad's tag moves continuously with the media roll, so its spacing and orientation are not fixed — the opposite of the claimed docked, stationary, capture-region/orientation relationship. It discloses RF data transfer to/from a printing consumable, but not the "docked … within a capture region of and at a specific controlled orientation" limitation. No independent claim is anticipated; it is the principal § 103 reference and the closest commercial-technology art.
2.7 US 6,039,430 A — related parent (CIP)
- Full citation: Method and apparatus for storing and retrieving information on a replaceable printing component, Hewlett-Packard Company (Helterline et al.), US 6,039,430 A.
- Dates: filed 1998‑06‑05; issued 2000‑03‑21.
- Description: Storing and retrieving information on a replaceable printing component. Recorded in the '106 front page as US 09/295,080's continuation-in-parent predecessor (App. 09/148,039).
- Anticipation assessment: Same HP memory-on-consumable lineage as US 5,699,091. Being earlier HP work in the same family, it is relevant to priority and to the state of the art, but it does not disclose the capture-region/orientation RF limitation. Anticipates none of the claims on the present record.
2.8 Non-patent literature
- Motorola, "RFID: Everything You Need to Know," 11/11/97, pp. 1–19. Cited as examiner NPL; it is general RFID background (transponder/reader fundamentals), i.e., evidence that RFID was known, not a § 102 reference against any specific claim.
3. Ranking of the most relevant prior art
| Rank | Reference | Relevance driver | Independent claim(s) it comes closest to, and why it falls short |
|---|---|---|---|
| 1 | US 5,049,898 | Replaceable printhead + onboard memory + radio read; found by UK IPO to disclose radio-wave memory link | Closest to claim 1/7; lacks the capture-region + specific controlled orientation limitation and the passive power-conditioner feature |
| 2 | WO 98/52762 (Encad) | RFID tag on a printing consumable read by printer transceiver | Closest to claims 7/22; but tag is on a moving roll — spacing/orientation not fixed, expressly distinguished in the '106 spec |
| 3 | US 5,266,968 | Onboard NV memory on a printer cartridge + RF as an option | Touches claim 7 conceptually; no docking geometry, RF only a bare alternative |
| 4 | US 5,699,091 / US 6,039,430 | HP memory-on-consumable usage/calibration lineage | Underpins the "storage device stores information" element of all claims, but wired/contact link |
| 5 | US 5,396,078 | Non-contact (optical) data link to carriage | Background on contactless data transfer; different modality, no consumable memory |
| 6 | US 6,027,195 | Multi-printhead clock synchronization | No consumable memory, no wireless capacitive/RF link to claims |
| 7 | Motorola NPL | RFID fundamentals | Background only |
4. Bottom line on anticipation
On the present record, none of the seven cited references anticipates any of the five independent claims (1, 7, 15, 19, 22) of US 6,312,106 in full, because each independent claim requires the wireless/RF device to be within a "capture region" and at a "specific controlled orientation" of the printer-side device when docked — a fixed, closely-spaced, correctly-oriented geometry that the cited art does not disclose (US 5,049,898 and US 5,266,968 treat RF as an option without geometry; Encad WO 98/52762 expressly moves). The dependent-claim features — RF power conditioner supplied by an induced time-varying voltage (claims 2, 10, 15), and the refurbished-consumable-with-replacement-media limitations (claims 6, 14, 21) — are likewise absent from the references.
Accordingly, the cited art functions chiefly as § 103 obviousness material (particularly US 5,049,898 + WO 98/52762 + US 5,266,968), with the capture-region/controlled-orientation docking feature as the apparent point of novelty on which the claims issued and over which the '106's own continuation, US 6,676,240 B2, was likewise allowed.
Caveat carried forward from the prior section: I did not have institutional PACER/PTAB access; and three references (US 6,027,195, WO 98/52762, US 6,039,430) were assessed without full-text retrieval within this search budget. All statements above are analytical and not legal conclusions.
Generated 9/30/2026, 10:33:35 AM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground this analysis by pulling the actual content of the key prior-art references listed on the patent's page.
Obviousness Analysis — U.S. Patent No. 6,312,106 under 35 U.S.C. § 103
Working from: the Prior Art section of the patent record (the 7 "Citations" references + 1 non-patent literature item), the "Family Cites Families" entries, and the patent's own specification. I supplemented this with live searches to confirm what the key references actually disclose; where a search did not complete, I flag it.
Caveat up front: I could not retrieve the full text of the Motorola NPL item ("RFID: Everything You Need to Know," 11/11/97) — the tool run hit its step limit. I rely on the patent's own citation of it plus general RFID principles, flagged below. Everything about US 5,266,968, US 5,396,078, US 5,699,091, US 5,049,898, and WO 98/52762 is grounded in retrieved text.
1. Legal framework and the level of ordinary skill
Standard. A claim is obvious if the differences between the claimed invention and the prior art are such that the subject matter as a whole would have been obvious at the time of invention to a person having ordinary skill in the art ("PHOSITA"). Pre-AIA § 103(a) governs (filed 1999-04-20). Although this patent was examined under the pre-KSR Teaching-Suggestion-Motivation ("TSM") regime, the analysis below is run under both: I identify the express suggestions in the references (strict TSM) and the design-incentive/common-sense rationale that KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), makes sufficient.
Effective filing date — this matters. The '106 is a continuation-in-part of US 09/148,039, filed 1998-09-03, granted as US 6,039,430. The record lists the priority date as 1999-04-20 (its own filing date) and expressly labels that an assumption. Which date applies turns on whether a given claim's RF subject matter is supported by the '430 parent. Practically, the prior-art window is 1998-09-03 to 1999-04-20 at the latest, and every reference below comfortably predates both.
PHOSITA. An engineer with a bachelor's degree in electrical or mechanical engineering and 2–4 years of experience in ink-jet/electrophotographic printer consumable design, including experience with memory-bearing "smart" cartridges and short-range wireless/RFID data transfer.
2. The prior-art roster — what each reference actually teaches
| Ref | Identity | Key teaching (verified) |
|---|---|---|
| US 5,049,898 | HP, "Printhead having memory element," filed 1989-03-20, issued 1991-09-17 (Arthur et al.) | A replaceable ink-jet printhead carries a memory element storing identity, orifice-plate alignment, and remaining-ink data; the printer's read/write head transfers to and from the memory on power-up; data "travels with the printhead" when moved between printers. This is the foundational "memory on the replaceable component" reference. |
| US 5,266,968 | Kodak, "Non-volatile memory thermal printer cartridge," filed 1992-03-27, issued 1993-11-30 (Stephenson) | Non-volatile memory mounted on a printer cartridge storing color-correction and defect data, read by the printer upon cartridge insertion. Expressly states: "Communication between the smart cartridge and printer can be accomplished using two or more wires or by the use of opto-electrical or radio frequency communication." |
| US 5,396,078 | HP, "Printer with optical data link to carriage," filed 1993-09-22, issued 1995-03-07 | A non-contact data link between printer chassis and printhead: optical transmitter fixed relative to the chassis, optical receiver mounted on the carriage/printhead, communicating through free space. Expressly motivated by eliminating the ribbon cable and by avoiding RFI, ESD and EMI — the very failure modes the '106 patent's Background recites. |
| US 5,699,091 | HP, "Replaceable part with integral memory for usage, calibration and other data," issued 1997-12-16 | Serial-access memory on a replaceable cartridge; bidirectional data transfer (read and write) of usage and calibration parameters; expressly applicable to both electrophotographic and ink-jet printers. |
| US 6,027,195 | Varis, filed 1996-11-12, issued 2000-02-22 | Synchronization of piezoelectric clock sources among ink-jet printheads. Low relevance — background at best; no wireless-link teaching. |
| WO 98/52762 A2 (US counterpart US 6,227,643 B1, Encad) | "Intelligent printer components and printing system," priority 1997-05-20, published 1998-11-26 | Memory elements on both an ink cartridge and a roll of print media. For the media roll: a writable RF identification tag embedded on the roll holder and an RF transceiver incorporated into the printer's main electronics, which "eliminates the need for an electrical connection between an integrated circuit memory chip and the printer's main electronics." Confirms a working RFID-on-consumable/printer-transceiver architecture in the printing arts before the '106. |
| US 6,039,430 | HP, the '106's own CIP parent, filed 1998-09-03 | Same specification family; describes contact-based linking but states the link "can be some form of optical link such as an infrared link or some conventional device." Note: commonly owned → likely disqualified as § 103 prior art by pre-AIA § 103(c). Treat as context, not a rejection base. |
| Motorola NPL, "RFID: Everything You Need to Know," 11/11/97, pp. 1–19 | RFID primer | (Content not retrieved — flagged.) Cited by the Examiner as evidence of RFID fundamentals: passive transponders, interrogation-field powering, and read-range/orientation-dependent coupling. |
Two observations that drive everything below:
- The Kodak reference supplies an express TSM. US 5,266,968 does not merely make RF communication possible — it names "radio frequency communication" as an alternative to wires for exactly the cartridge↔printer memory link at issue. That is the strongest possible suggestion-to-substitute in a § 103 analysis.
- The HP optical-link reference supplies the printer-specific architecture. US 5,396,078 already put a fixed, chassis-mounted non-contact transceiver facing a receiver on the replaceable/moving printhead member, in a docking-type relationship, for the stated purpose of defeating RFI/ESD/EMI.
3. Element-by-element mapping of independent claim 1
Claim 1 (apparatus) requires: (a) a replaceable marking engine with a docking housing having undocked/docked positions; (b) an electrical storage device on the housing; (c) an RF linking device coupled to the storage device, mounted so that when docked it is within a capture region of and at a specific controlled orientation relative to the printer's RF device; and (d) transfer without electrical conductors, and only when the capture-region/orientation condition is met.
| Claim 1 element | Where disclosed |
|---|---|
| (a) Replaceable marking engine, housing, docked/undocked | US 5,699,091 (replaceable cartridge into printer receptacle); US 5,266,968 (cartridge inserted into thermal printer); US 5,049,898 (printhead into carriage) |
| (b) Electrical storage device on the housing | US 5,699,091; US 5,266,968; US 5,049,898 — all squarely |
| (c) RF linking device coupled to storage, mounted at a fixed position/orientation relative to the printer's counterpart | US 5,266,968 (RF comms for the cartridge memory link) + WO 98/52762 (RF tag on consumable, transceiver on printer) + US 5,396,078 (counterpart transceiver fixed to the chassis, receiver fixed on the removable member, free-space link) |
| Capture-region + specific controlled orientation | Motorola RFID NPL (read range / interrogation zone / orientation-dependent coupling — inherent to near-field/inductive and far-field RFID); US 5,396,078 (transmitter and receiver fixedly aimed at one another); and the legal point that this is the natural consequence of any short-range wireless link, admitted by the '106 itself at FIG. 5 |
| (d) No direct electrical conductors | US 5,266,968 ("opto-electrical or radio frequency"); US 5,396,078 (optical, contactless); WO 98/52762 ("eliminates the need for an electrical connection") |
| "Only when" within capture region/orientation | Inherent functional consequence — the '106's own FIG. 5 admits that mis-orientation (38′) or excessive spacing (38″) defeats the link as a matter of field physics |
On the "only when…prevents transfer" language. This is a negative functional recitation describing the intrinsic behavior of a short-range wireless link — not a structural feature. It is the same phenomenon FIG. 5 of the '106 attributes to field strength and antenna sensitivity. Under In re Schreiber, 128 F.3d 1473 (Fed. Cir. 1997), and the inherency line, a functional limitation that merely describes the natural result of the recited structure cannot patentably distinguish over prior art structure that inherently possesses it. Even setting inherency aside, the operative design choice — position the tag within the reader's read zone at docking — is the kind of predictable, results-driven choice KSR holds obvious.
4. The combinations and the motivation to combine
Ground 1 (primary) — US 5,699,091 + US 5,266,968 + WO 98/52762 + Motorola RFID NPL
Rationale. '091/'968/'898 establish the entire problem-and-solution context the '106 itself adopts: put a memory on the replaceable consumable, read it on installation, and use the data to ensure print quality and prevent damage from incompatible or exhausted components (this framing is verbatim from the '106's Background, which credits US 5,699,091). Kodak '968 then supplies the express suggestion to move that memory link off wires and onto "radio frequency communication." Encad WO '762 supplies a reduction to practice in the same field — an RF tag on a printer consumable read by a printer-side RF transceiver, expressly to eliminate the electrical connection. Motorola supplies the enabling know-how (passive tag, field-derived power, read range). One reference both identifies the problem and names the solution; the others show the solution was known and workable in printers.
Motivation, stated concretely: the '106's own Background lists contact failure modes — contamination from ink/skin oils, corrosion from ink solvents and surfactants, contact scraping/denting/peeling, and ESD damage to CMOS storage. US 5,396,078 independently identifies the same family of harms (RFI, ESD, EMI) as the reason to go contactless at a printer's printhead interface. Where two independent sources in the same field name the same defects and one of them names RF as the fix, the motivation is not hindsight — it is on the face of the art.
Ground 2 — US 5,699,091 + US 5,396,078 + US 5,266,968 + Motorola RFID NPL
Rationale. This is the cleanest TSM ground. '078 discloses a contactless data link across the printer-to-removable-member interface, with the printer-side element fixed relative to the chassis and the consumable-side element fixed on the removable member, achieving a controlled, repeatable, aimed-at-each-other geometry on insertion. '968 supplies the express substitution of RF for that link. '091 supplies the memory-on-replaceable-part motivation and bidirectional data. The only thing the combination lacks is the specific "RF" carrier in '078 (which uses light) — and '968 closes exactly that gap with an express statement. Substituting one known non-contact carrier (RF) for another known non-contact carrier (optical) to obtain the known benefits of the substituted carrier is the paradigm of obviousness. KSR, 550 U.S. at 416; In re ICON Health & Fitness, 496 F.3d 1374 (Fed. Cir. 2007).
Ground 3 — US 5,049,898 + WO 98/52762 + Motorola RFID NPL
Rationale. '898 gives the replaceable printhead with an on-board memory whose data "travels with the printhead" between printers — i.e., precisely the docking-and-identification premise of claim 1. Encad WO '762 gives the RF tag + printer transceiver. Motorola gives the read-range/orientation physics. The combination yields claim 1's structure. Useful as a secondary ground because '898 is the closest art on the "replaceable marking engine + housing + memory" subcombination and shares the '106's assignee.
Ground 4 — WO 98/52762 + Motorola RFID NPL (for the placement/orientation limitation specifically)
Rationale. Even independent of the memory-cartridge references, Encad's RF tag is embedded at a defined location on a consumable so that it interacts with the printer's transceiver. Placing a tag so that the reader's field reaches it is not an inventive act — it is the sine qua non of making an RFID system function at all, and Motorola's primer teaches that read range is finite and coupling is orientation-dependent. Choosing a mounting location on the consumable that satisfies those known constraints, given a docking geometry that fixes the consumable's position, is a routine design choice.
5. Claim-by-claim treatment
| Claim | Coverage / reasoning |
|---|---|
| 1 | Anticipated-by-combination as charted in § 3; Grounds 1–3. |
| 2 (power conditioner deriving supply from RF signal) | Motorola RFID NPL describes passive transponders powered by the interrogation field (rectification/filtering inherent). Also expressly suggested by '968's discussion of battery-backed vs. field-powered options and by the well-known "smart card" passive-power art the '106 itself invokes. Obvious. |
| 3, 4 (electrophotographic / ink-ejection engine) | '091 expressly applies to both EP and ink-jet; '898 and '762 are ink-jet; '968 is thermal. Selecting the printer technology is an obvious design choice, and the '106's own spec treats the two as interchangeable. |
| 5 (close proximity when docked) | Inherent in the docking geometry taught by the bases plus the read-range constraint from Motorola. |
| 6 (refurbished engine with replacement marking material) | Weakest link in the record. None of the cited references addresses refurbishment/refill or memory reconditioning. Anticipation of this limitation would have to rest on general knowledge in the remanufacturing industry plus the '106's own admission that refurbishment is conventional. A rejection of claim 6 on the cited art alone is contestable. |
| 7 (consumable + "wireless communication device," through the atmosphere) | Broader than claim 1 (not RF-limited). US 5,396,078's optical link communicates "through the atmosphere" and is the broadest § 103 base; '968's "opto-electrical or radio frequency" is an express on-point suggestion. Obvious over '078 + '968 + '091. |
| 8, 9 (RF / no direct electrical connection) | '968 (RF) and '078 (no conductors). |
| 10 (power conditioner) | As claim 2. |
| 11, 12, 13 | As claims 3, 4, 5. |
| 14 (refurbished consumable, replacement marking media) | Same weakness as claim 6. |
| 15 (method: dock; apply time-varying voltage to induce supply voltage at power conditioner; transmit) | Motorola RFID NPL (field-induced supply voltage) + '968 (RF cartridge link) + '091 (memory read on installation). Obvious. |
| 16 (bidirectional transfer) | '091 expressly enables data transfer both from and to the memory. Strong. |
| 17, 18 (EP / ink-jet + RF) | As claims 3–4. |
| 19 (method of preparing: store info; affix RF device at a location giving capture-region/orientation upon insertion) | This is the claim most directly met by Encad WO '762, which describes the RF tag embedded onto the roll holder so the printer's transceiver can interact with it. Adding the docking-fixed positioning is routine in view of Motorola's read-range teaching. |
| 20 (RF device capable of receiving "inflation" [information] in close proximity) | Obvious; "inflation" is an evident typographical artifact for "information," preserved literally per instruction. |
| 21 (refurbished consumable) | Same weakness as claims 6 and 14. |
| 22 (system: docking station w/ first RF device + consumable w/ second RF device; "allowing the use of relatively low cost short range devices") | The recited advantage is a stated result of the conventional short-range RFID design, not a structural difference. Motorola RFID teaches that short-range passive devices are the low-cost class. Obvious over Grounds 1–2. |
6. Rebuttal considerations — and why they likely fail
A. "The prior art teaches away because Encad used RF only for a moving media roll and wires for the stationary cartridge." Arguable, but weak. Encad's press release explains RF was chosen because the roll is in motion — a reason to use RF where motion exists, not an express criticism, discrediting, or discouragement of RF for stationary parts. Under In re Fulton, 391 F.3d 1195 (Fed. Cir. 2004), a reference teaches away only if a PHOSITA, reading it, would be discouraged from following the path or led in a divergent direction. Disclosed preference among known options is not teaching away. And US 5,266,968 — a third-party reference — affirmatively endorses RF for the stationary cartridge, neutralizing the point.
B. "Fixed capture region and specific controlled orientation are unexpectedly advantageous (low power, small antenna, low cost, low RFI)." These are the predictable consequences of any short-range, closely-coupled wireless link, all articulated in the '106's own specification as generic RFID design tradeoffs. No evidence of unexpected results beyond what the physics dictates. Moreover, the '106's specification admits the spacing/orientation sensitivity at FIG. 5 — that admission undercuts any argument that the "capture region" limitation is a non-obvious discovery.
C. "The prior art does not expressly place the RF device at a specific controlled orientation." The references need not use the patent's coined vocabulary. '078 structurally fixes the two link elements facing one another on docking; Motorola teaches that orientation matters; the docking station inherently fixes both spacing and orientation. Express claim language is not a talisman — what matters is whether the limitation as a whole would have been obvious. KSR, 550 U.S. at 419–21 (rejecting rigid insistence on literal claim-language matching).
D. The negative "only when" limitation. As discussed in § 3, this describes an inherent property. Inherency under § 103 requires only that the prior art structure necessarily possess the characteristic — which a properly positioned RFID pair in a docking station does.
E. Objective indicia. None appears in the record: no unexpected-results evidence, no licensing, no industry praise specific to the '106, no copying. The absence is itself notable — the '106's commercialization ran through HP's broader cartridge program rather than as a discrete product embodying the "capture region" limitation.
7. Weaknesses in a § 103 case against the '106
I want to be candid about where a rejection would be vulnerable:
- Claims 6, 14, and 21 (refurbishment). The cited art does not address remanufacture, refill, or memory reconditioning. These limitations rest on general knowledge at best. A well-pleaded obviousness case on the cited references alone would be thinnest here.
- The Motorola NPL content is unverified in my search. I could not retrieve the reference. If its actual disclosure is a generic RFID overview (likely, given the title and the '106's citation practice), it supplies the passive-power/read-range teaching for claims 2, 10, 15, 20 — but if it lacks the orientation/read-range discussion, that gap must be filled by '078's fixed-aimed-geometry teaching instead.
- Priority-date ambiguity. Because the '106 is a CIP, individual claims may or may not be entitled to the 1998-09-03 parent date. This does not defeat the grounds above (all references predate 1998-09-03 except the WO '762 publication of 1998-11-26), but it does affect which Encad vehicle is used: if a claim cannot claim 1998-09-03, the WO publication is 102(a)/(b) art; if it can, the rejection must lean on US 6,227,643 B1 (filed 1998-02-25, before 1998-09-03) under § 102(e).
- US 6,039,430 is self-art. Being commonly owned and a CIP parent, it is likely disqualified under pre-AIA § 103(c). Its admission that the link "can be some form of optical link such as an infrared link or some conventional device" is therefore useful as context showing the art's trajectory, not as a proper rejection base. I flag this to avoid a procedural defect.
- US 6,027,195 (Varis) adds nothing to any of these grounds. I note it only for completeness.
8. Bottom line
Claims 1–5, 7–13, and 15–20 are reasonably concluded obvious over the combination of the memory-on-replaceable-component art (US 5,699,091 / US 5,266,968 / US 5,049,898) with the contactless-link art (US 5,396,078) and the RF-on-printer-consumable art (WO 98/52762 / US 6,227,643), optionally supplemented by the Motorola RFID NPL for passive powering and read-range/orientation teachings. The strongest single ground is US 5,699,091 + US 5,266,968 + WO 98/52762, because Kodak '968 supplies an express suggestion to use "radio frequency communication" for the cartridge-to-printer memory link — satisfying the strictest pre-KSR TSM requirement without resorting to common-sense reasoning.
Claim 22 is obvious as well, since its recital of enabling "relatively low cost short range devices" is a statement of the known advantage of the conventional short-range RFID architecture, not a structural distinction.
Claims 6, 14, and 21 (the refurbished-consumable claims) are the soft spots. They are not met by the references cited on the patent's face, and a § 103 rejection of those claims would need additional art or a general-knowledge rationale that is more vulnerable to attack.
Generated 9/30/2026, 10:34:07 AM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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