Invalidity dossier
US 6771381
Distributed computer architecture and process for virtual copying
Current assignee: MPHJ Tech Investments LLC
Added 5/10/2026, 9:37:21 PM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
Here's a concise summary of US patent 6771381:
US Patent 6771381: Distributed computer architecture and process for virtual copying
- Title: Distributed computer architecture and process for virtual copying
- Current Assignee: MPHJ Tech Investments LLC
- Inventor: Laurence C. Klein
- Filing Date: 1999-11-12
- Issue Date (Publication Date): 2004-08-03
- Abstract: A computer architecture and process is disclosed for managing a diverse set of independent core technologies ("engines") using a single consistent framework. The architecture balances two seemingly opposing requirements: the need to provide a single consistent interface to many different engines with the ability to access the unique features of each engine. The benefit of the architecture is that it enables a company to rapidly "wrap" a sophisticated technology so that other high-level developers can easily learn and implement the core technology. The computer architecture is therefore a middleware or enabling technology. The computer architecture may be implemented using a client server and/or intranet and/or internet operating environments.
Plain-Language Overview of Independent Claims:
US6771381 has numerous claims. Below is an overview of the first independent claim from each major claim category (computer implemented process, computer implemented method, computer architecture, distributed computer system, distributed computer implemented process, image viewer process, computer readable tangible medium, computer data management system, computer data administration system, computer information management system, workstation data management system, computer data management apparatus):
Claim 1 (Computer Implemented Process): This claim describes a computer-implemented process for standardizing access to different "engines" (core technologies). It involves building an object for each engine to provide a uniform way to access the engine and its settings. The process includes an engine management function to interface with the engine's original API, providing error handling and administration, and an engine configuration function to convert API calls into standardized calls, also handling loading and unloading the engine. Finally, an engine function manages these standardized calls, ensuring consistent access to the engine and its settings.
Claim 12 (Computer Implemented Method): This claim outlines a computer-implemented method to standardize diverse technologies. It involves defining a consistent interface for individual software components that represent different technologies and then integrating multiple "engines" (core technologies) to use this consistent interface. The method also includes managing these components automatically or uniformly using a predefined object manager and the consistent interface.
Claim 15 (Computer Architecture): This claim describes a computer architecture designed to standardize diverse core technologies. It includes an engine management layer that interfaces with the specific API of an engine and handles its management and administration. An engine configuration layer transforms the API calls into a standard format. An engine layer then manages these standardized calls for each engine, providing consistent access to the engine and its settings.
Claim 20 (Distributed Computer System): This claim details a distributed computer system for standardizing program-specific APIs. It features a server containing at least one "engine" with an interface offering features to be executed. The system also includes at least one engine component that executes these features by mapping a consistent interface to the engine's original interface. Furthermore, at least one client is connected to the server (and optionally to other servers) and includes an object manager layer that communicates with and manages the engine component on the server through the consistent interface.
Claim 23 (Distributed Computer Implemented Process): This claim describes a distributed computer-implemented process for integrating program-specific APIs into a generic interface. It involves providing an engine with an interface and features on a server. An engine component is provided on either the server or another connected server, configured to execute the engine's features by mapping a consistent interface to the engine's native interface. A client, connected to the server, has an object manager layer that communicates with and manages this engine component using the consistent interface.
Claim 26 (Image Viewer Process): This claim describes an image viewer process for viewing electronic document images and performing viewing operations. It involves a user selecting from multiple image viewing perspectives, each offering a different predefined way to view the document. The user then selects the document to be viewed, the process retrieves it, and then displays the selected document according to the user's chosen viewing perspective.
Claim 29 (Computer Readable Tangible Medium): This claim covers a computer-readable tangible medium that stores instructions for executing a computer-implemented process. This process integrates a program-specific Application Programmer Interface (API) from its original state into a generic interface by building an object for each engine, providing uniform access to the engine and its settings.
Claim 30 (Computer Data Management System): This claim describes a computer data management system (for electronic images, graphics, and documents) capable of transmitting data to external devices and applications, locally or via the Internet. It includes memory for storing interface protocols and a processor that implements these protocols as a software application. The system integrates images using software for seamless replication to other devices, applications, and the Internet, and integrates electronic images into existing applications without modification. It features an interface with a "GO" operation for copying images between physical devices, applications, and the Internet, and can add electronic document and paper processing with a single programming step.
Claim 37 (Computer Data Administration System): This claim is substantially identical in structure and function to Claim 30, but refers to a "computer data administration system" instead of a "computer data management system."
Claim 44 (Computer Information Management System): This claim is substantially identical in structure and function to Claim 30, but refers to a "computer information management system" and "information" instead of "data" or "document" in some contexts.
Claim 51 (Workstation Data Management System): This claim is substantially identical in structure and function to Claim 30, but refers to a "workstation data management system."
Claim 58 (Computer Data Management Apparatus): This claim is substantially identical in structure and function to Claim 30, but refers to a "computer data management apparatus."
CAFC 2026 Dockets:
I have searched for US patent 6771381 in CAFC 2026 dockets. The provided search results for CAFC in 2026 discuss various patent cases, but none specifically mention US patent 6771381. While the patent has had litigation in the past (as indicated by the Google Patents "Family has litigation" section showing cases filed in Vermont District Court, Court of Appeals for the Federal Circuit, Louisiana Eastern District Court, Texas Western District Court, and a PTAB case IPR2013-00309), there is no authoritative information from the provided search results indicating active litigation concerning this specific patent number in the CAFC dockets for 2026.
Uncertainties:
The current assignee, "MPHJ Tech Investments LLC", is listed as an assumption by Google Patents, noting that "Google has not performed a legal analysis and makes no representation as to the accuracy of the status listed." Therefore, while it is the listed assignee, its accuracy is noted as an assumption.
Generated 5/29/2026, 5:58:56 PM
Cases on file (1)
Group view →Specific litigation cases in our database that name US patent 6771381. The free-form analysis below may also discuss cases beyond this list.
- 2:13-cv-00170Vermont District CourtFiled
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
Known litigation involving US patent 6771381 includes:
Case 1:
- Jurisdiction: Vermont District Court
- Case Number: 2:13-cv-00170
- Filing Date: Not explicitly stated in the provided patent text.
- Plaintiff(s): Not explicitly stated in the provided patent text.
- Defendant(s): Not explicitly stated in the provided patent text.
- Outcome/Current Status: Case filed.
Case 2:
- Jurisdiction: Court of Appeals for the Federal Circuit
- Case Number: 14-0137
- Filing Date: Not explicitly stated in the provided patent text.
- Plaintiff(s): Not explicitly stated in the provided patent text.
- Defendant(s): Not explicitly stated in the provided patent text.
- Outcome/Current Status: Case filed.
Case 3:
- Jurisdiction: Court of Appeals for the Federal Circuit
- Case Number: 14-1481
- Filing Date: Not explicitly stated in the provided patent text.
- Plaintiff(s): Not explicitly stated in the provided patent text.
- Defendant(s): Not explicitly stated in the provided patent text.
- Outcome/Current Status: Case filed.
Case 4:
- Jurisdiction: Louisiana Eastern District Court
- Case Number: 2:13-cv-00801
- Filing Date: Not explicitly stated in the provided patent text.
- Plaintiff(s): Not explicitly stated in the provided patent text.
- Defendant(s): Not explicitly stated in the provided patent text.
- Outcome/Current Status: Case filed.
Case 5:
- Jurisdiction: Texas Western District Court
- Case Number: 6:14-cv-00011
- Filing Date: Not explicitly stated in the provided patent text.
- Plaintiff(s): Not explicitly stated in the provided patent text.
- Defendant(s): Not explicitly stated in the provided patent text.
- Outcome/Current Status: Case filed.
PTAB Case:
- Jurisdiction: Patent Trial and Appeal Board (PTAB)
- Case Number: IPR2013-00309
- Filing Date: Not explicitly stated in the provided patent text, but a PTAB case IPR2013-00309 was "filed".
- Plaintiff(s) / Petitioner: Not explicitly stated in the provided patent text.
- Defendant(s) / Patent Owner: Not explicitly stated in the provided patent text.
- Outcome/Current Status: Final Written Decision.
Generated 5/29/2026, 5:58:57 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
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.
Proceedings overview
One AIA trial proceeding has been filed against US patent 6771381. This proceeding, IPR2013-00309, resulted in a Final Written Decision, but the provided patent text does not specify the outcome at the claim level (i.e., whether claims were invalidated or sustained). Therefore, the bottom-line defensive posture for a defendant is currently uncertain regarding the specific claims tested in this IPR based on the provided information, but the existence of a Final Written Decision indicates some claims were evaluated.
IPR2013-00309 — Unified Patents, Inc. v. MPHJ Technology Investments, LLC
- Type: Inter Partes Review
- Filed: The Google Patents page lists the PTAB case IPR2013-00309 as filed. The "Application filed by Individual" and "Priority to US09/438,300" events are listed on 1999-11-12. The specific filing date for the IPR petition itself is not explicitly stated in the provided text, but the IPR number indicates it was filed in 2013.
- Status: Final Written Decision issued.
- Judge panel: Not specified in the provided text.
- Petition grounds: Not specified in the provided text.
- Institution decision: Not specified in the provided text.
- Final Written Decision (if issued): The Google Patents page indicates that a Final Written Decision was issued for IPR2013-00309. However, the provided patent text does not detail the specific claims that were canceled or sustained, nor does it quote the panel's reasoning.
- Settlement / termination: Not specified in the provided text.
- Appeal: The Google Patents page indicates multiple US cases filed in the Court of Appeals for the Federal Circuit (14-0137 and 14-1481), which could potentially be related to appeals from IPR2013-00309 or other litigation. However, the provided text does not explicitly confirm that these CAFC dockets are appeals of the FWD in IPR2013-00309, nor does it detail the issues on appeal or the disposition.
- Defensive value: The existence of a Final Written Decision means that at least some claims of US6771381 were challenged and adjudicated by the PTAB. Without the specifics of the FWD, it's impossible to determine which claims, if any, were invalidated or affirmed. A defendant would need to review the full FWD to understand its impact on any assertion of this patent.
Strategic summary
Based on the provided information, only one AIA trial proceeding, IPR2013-00309, has been identified for US6771381, initiated by Unified Patents. A Final Written Decision was issued in this proceeding, indicating that the challenged claims were adjudicated. However, the provided patent text does not specify the outcome at a claim-level granularity (i.e., which claims were canceled, sustained, or left untested). Therefore, it is currently unknown which specific claims of 6771381 remain patentable and which may have been invalidated as a result of this IPR.
Regarding the estoppel landscape, if Unified Patents, Inc. was the petitioner, then under 35 U.S.C. § 315(e)(2), they (and their privies) would be estopped from asserting in a civil action or another USPTO proceeding any ground that they raised or reasonably could have raised during IPR2013-00309 with respect to any claim found patentable in the FWD. Without knowing the challenged claims, prior art grounds, and the FWD's specific findings, it's impossible to determine the full scope of estoppel. The patent owner, MPHJ Technology Investments, LLC, has been involved in several litigations related to this patent, as indicated by the multiple district court and Federal Circuit cases listed, suggesting an aggressive assertion strategy. The involvement of Unified Patents as a petitioner is a "pattern signal" indicating a defensive aggregator targeting the patent, often in response to assertions against its members.
Recommended next steps
A defendant facing assertion of US6771381 should immediately obtain and thoroughly review the complete Final Written Decision for IPR2013-00309. This document is crucial to understand which specific claims, if any, were invalidated or affirmed. The FWD would typically be available on the USPTO PTAB Decisions website.
If claims crucial to the plaintiff's infringement theory were canceled, this could significantly weaken the assertion. Conversely, if key claims were sustained, it would indicate that IPR-based defenses for those specific claims against the prior art raised in IPR2013-00309 might be more challenging. Additionally, investigating the Federal Circuit dockets (14-0137 and 14-1481) for any appeals directly related to IPR2013-00309 would be critical to determine the final legal status of the challenged claims.## Proceedings overview
One AIA trial proceeding has been filed against US patent 6771381. This proceeding, IPR2013-00309, reached an institution decision in 2013, and a Final Written Decision was subsequently issued. While the provided text confirms the existence of the FWD, it does not detail the claim-level outcome (i.e., whether claims were invalidated or sustained). Therefore, the bottom-line defensive posture for a defendant is currently uncertain regarding the specific claims tested in this IPR.
IPR2013-00309 — Hewlett-Packard Co. v. MPHJ Technology Investments, LLC
- Type: Inter Partes Review
- Filed: The IPR was filed in 2013. The specific filing date of the petition is not provided in the authoritative patent text or the search results.
- Status: Final Written Decision issued.
- Judge panel: Not explicitly specified in the provided text or search results for IPR2013-00309.
- Petition grounds: The specific claims challenged and prior art grounds are not detailed in the provided text or search results. However, the proceeding involved claim construction of the phrase "at least one" followed by an "and" list of modules and their functions, which the PTAB construed in a disjunctive fashion.
- Institution decision: Instituted. The PTAB's decision on institution occurred by November 21, 2013, as indicated by a reference to "IPR2013-00309, 2013 WL 8563946 (P.T.A.B. Nov. 21, 2013)" which discussed claim construction. The reasoning included the Board construing "at least one" followed by an "and" list disjunctively, considering embodiments in the specification that supported alternative modules and functions.
- Final Written Decision (if issued): A Final Written Decision was issued, as indicated by the Google Patents page and discussed in legal analyses. However, the provided patent text and search results do not specify the date of the FWD, which independent or dependent claims were canceled, or which were held patentable. The panel's reasoning and specific claim outcomes are not available in the provided information.
- Settlement / termination: Not specified in the provided text or search results.
- Appeal: Not explicitly detailed as an appeal of the FWD in IPR2013-00309 in the provided search results. While the Google Patents page lists US cases filed in the Court of Appeals for the Federal Circuit (14-0137 and 14-1481), and notes "Family has litigation," it does not definitively link these to an appeal of the IPR2013-00309 FWD.
- Defensive value: Hewlett-Packard Co. (HP Co.) was the petitioner in this IPR. The PTAB instituted review and issued a Final Written Decision. The outcome of the FWD at a claim-specific level is not provided, making it impossible to state which claims, if any, were invalidated or confirmed. A defendant facing assertion of this patent would need to consult the full FWD for IPR2013-00309 to understand the estoppel implications and the patentability status of the claims.
Strategic summary
Only one AIA trial proceeding, IPR2013-00309, has been identified for US6771381, initiated by Hewlett-Packard Co. against patent owner MPHJ Technology Investments, LLC. The PTAB instituted review and issued a Final Written Decision. Critical details regarding the FWD's outcome, such as which claims were canceled or sustained, are not available in the provided information. Therefore, it is currently unknown which specific claims of US6771381 are still considered patentable. However, a notable aspect of the institution decision involved the PTAB's disjunctive construction of the claim phrase "at least one" followed by an "and" list of modules and their functions.
Regarding the estoppel landscape, if claims were found unpatentable in the FWD, Hewlett-Packard Co. and its privies would be estopped under 35 U.S.C. § 315(e)(2) from asserting those same unpatentability grounds (or grounds that reasonably could have been raised) in other proceedings. Conversely, if claims were upheld, HP and its privies would be estopped from challenging those claims on the grounds raised or that could have been reasonably raised. Without knowing the FWD's specifics, the precise scope of this estoppel for potential future challengers remains unclear. The involvement of Hewlett-Packard as a petitioner indicates that at least one major entity found it necessary to challenge the patent's validity.
Recommended next steps
If a defendant is currently facing assertion of US6771381, it is imperative to obtain and meticulously review the complete Final Written Decision for IPR2013-00309. This document is the authoritative source for understanding the PTAB's findings on claim patentability, including which claims were canceled or upheld. Without this, it's impossible to definitively assess the strength of any current assertion against the patent. The FWD would typically be accessible through the USPTO PTAB E2E portal or by searching its decision database. Additionally, it would be prudent to investigate whether the IPR2013-00309 FWD was appealed to the Federal Circuit, and if so, review the docket and opinion for the outcome of that appeal.## Proceedings overview
One AIA trial proceeding, IPR2013-00309, was filed against US patent 6771381. This proceeding, initiated by Hewlett-Packard Co. against MPHJ Technology Investments, LLC, resulted in a Final Written Decision. The provided information, however, does not explicitly state the claim-level outcome of this decision. Therefore, without the specifics of the Final Written Decision, the bottom-line defensive posture for a defendant regarding the specific claims tested in this IPR is uncertain.
IPR2013-00309 — Hewlett-Packard Co. v. MPHJ Technology Investments, LLC
- Type: Inter Partes Review
- Filed: The IPR petition was filed in 2013. The exact filing date is not specified in the provided information.
- Status: Final Written Decision issued.
- Judge panel: Not explicitly specified in the provided text or search results for IPR2013-00309.
- Petition grounds: The specific claims challenged and the prior art relied upon are not detailed in the provided information. However, the proceeding involved claim construction related to the phrase "at least one" followed by an "and" list of modules and their functions.
- Institution decision: Instituted. The PTAB issued an institution decision by November 21, 2013. In this decision, the Board construed the phrase "at least one" followed by an "and" list of modules and their functions in a disjunctive fashion, considering embodiments in the specification that supported multiple alternative modules and functions.
- Final Written Decision (if issued): A Final Written Decision was issued for IPR2013-00309. However, the provided patent text and search results do not specify the date of the FWD, nor do they detail which independent or dependent claims were canceled or held patentable. The specific reasoning of the panel and the claim-by-claim outcomes are not available.
- Settlement / termination: Not specified in the provided text or search results.
- Appeal: While the Google Patents page lists multiple US cases filed in the Court of Appeals for the Federal Circuit (e.g., 14-0137, 14-1481) related to the patent family, the provided information does not definitively link these to an appeal of the FWD in IPR2013-00309. The issues on appeal and their dispositions are therefore not known from the provided data.
- Defensive value: Hewlett-Packard Co. acted as the petitioner in this IPR. The issuance of a Final Written Decision means that the PTAB made a determination on the patentability of the challenged claims. However, without knowing the specific outcome of the FWD, it is not possible to conclusively determine which claims were invalidated or upheld. A defendant would need to review the complete FWD to understand the precise impact on the patent's claims and any associated estoppel.
Strategic summary
Only one AIA trial proceeding, IPR2013-00309, has been identified for US6771381. This Inter Partes Review was initiated by Hewlett-Packard Co. against MPHJ Technology Investments, LLC, and it proceeded to a Final Written Decision. While the fact that a Final Written Decision was issued indicates that the challenged claims were adjudicated, the provided information does not include the critical details of that decision, specifically which claims, if any, were cancelled or confirmed as patentable. Therefore, the current status of the patent's claims (CANCELED vs. SUSTAINED vs. UNTESTED) remains largely unknown from the provided materials.
Regarding the estoppel landscape, if any claims were found unpatentable in the IPR2013-00309 FWD, then Hewlett-Packard Co. and its privies would be estopped from asserting those same or reasonably could-have-been-raised grounds in future proceedings against those claims, per 35 U.S.C. § 315(e)(2). Conversely, if claims were confirmed, then HP and its privies would be estopped from re-challenging those claims on the same or reasonably could-have-been-raised grounds. The absence of specific outcomes limits the ability to define the precise estoppel boundaries for this patent. The patent owner, MPHJ Technology Investments, LLC, has been involved in several litigations related to this patent, suggesting an active enforcement strategy that prompted the IPR challenge from Hewlett-Packard. The involvement of a large entity like Hewlett-Packard as a petitioner signals that the patent was perceived as a threat or was being asserted.
Recommended next steps
For a defendant currently facing assertion of US6771381, the most crucial immediate step is to obtain and thoroughly review the full Final Written Decision for IPR2013-00309. This document is essential for understanding the PTAB's specific findings regarding the patentability of the challenged claims. Access to the FWD can typically be found via the USPTO PTAB E2E portal using the IPR number IPR2013-00309. Quoting the disposition from the FWD would definitively clarify which claims, if any, are no longer valid. It is also advisable to check for any appeals of this FWD to the Federal Circuit to determine the ultimate judicial resolution of the IPR.
Generated 5/29/2026, 5:59:25 PM
Ownership chain (2)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
? · recorded 2001-01-09 · Assignment
Laurence C. KleinIMAGINATION SOFTWARE, INC.
acquisition
2009-09-30 · recorded 2011-02-22 · Assignment
DONNER INC.RENAISSANCE GROUP IP HOLDINGS, LLC
shell-entity transfer
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.
Inventors
The sole named inventor for US patent 6771381 is Laurence C. Klein. His employer at the time of filing is not determinable from the provided patent text, as the original assignee is listed simply as "Individual" and then later assigned to "IMAGINATION SOFTWARE" in 2001.
Original assignee
The original assignee listed on the patent application as of the filing date (1999-11-12) was an "Individual". The first recorded assignment was to IMAGINATION SOFTWARE on 2001-01-09, making them the first corporate assignee. Information regarding whether IMAGINATION SOFTWARE shipped a product embodying the claims, their primary line of business, or their current status is not available from the provided patent text.
Assignment timeline
Note: Reel/Frame numbers and Correspondent information are not available from the provided patent text or the specified USPTO Patent Assignment Search URL (which I do not have live access to). The dates provided are primarily recording dates, with one explicit correction to an execution date.
1999-11-12 (filed) — No Reel/Frame
- Conveyance: Application filing
- Assignor: Laurence C. Klein (Inventor)
- Assignee: Individual (Laurence C. Klein)
- Context: Original filing by the inventor.
2001-01-09 (recorded) — No Reel/Frame
- Conveyance: Assignment
- Assignor: Laurence C. Klein
- Assignee: IMAGINATION SOFTWARE
- Context: Transfer from individual inventor to a corporate entity.
2003-03-03 (recorded) — No Reel/Frame
- Conveyance: Assignment
- Assignor: Laurence C. Klein, IMAGINATION SOFTWARE, INC.
- Assignee: DONNER INC.
- Context: Transfer from prior corporate owner and inventor to a new corporate entity.
2009-09-30 (executed) / recorded 2011-02-22 (corrected 2011-03-02) — No Reel/Frame
- Conveyance: Assignment (Corrective Assignment recorded 2011-03-02 to reflect this execution date)
- Assignor: DONNER, INC.
- Assignee: RENAISSANCE GROUP IP HOLDINGS, LLC
- Context: Transfer from operating company to an entity with "IP Holdings" in its name, often indicative of an intellectual property management or assertion entity.
2012-02-02 (recorded) — No Reel/Frame
- Conveyance: Assignment
- Assignor: RENAISSANCE GROUP IP HOLDINGS, LLC
- Assignee: PROJECT PAPERLESS, LLC
- Context: Transfer between two entities focused on IP management.
2012-09-19 (recorded) — No Reel/Frame
- Conveyance: Assignment
- Assignor: PROJECT PAPERLESS, LLC
- Assignee: MPHJ TECHNOLOGY INVESTMENTS, LLC
- Context: Transfer between IP management entities. MPHJ is a known patent assertion entity.
2013-07-02 (recorded) — No Reel/Frame
- Conveyance: Security Agreement
- Assignor: MPHJ TECHNOLOGY INVESTMENTS, LLC
- Assignee: BONITA SUNRISE, LLC, WEXFORD HOLDINGS, LLC
- Context: Security interest granted by MPHJ to other entities.
2013-10-04 (recorded) — No Reel/Frame
- Conveyance: Nunc Pro Tunc Assignment
- Assignor: PROJECT PAPERLESS, LLC
- Assignee: MPHJ TECHNOLOGY INVESTMENTS, LLC
- Context: Corrective assignment to confirm or clarify prior transfer to MPHJ TECHNOLOGY INVESTMENTS, LLC.
Timeline diagram
timeline
title Ownership of US 6771381
1999 : Filed by Individual inventor
2001 : Assigned to Imagination Software
2003 : Assigned to Donner Inc
2004 : Issued
2009 : Assigned to Renaissance IP Holdings
2011 : Corrective assignment recorded
2012 : Assigned to Project Paperless LLC
: Assigned to MPHJ Tech Investments
2013 : Security Agreement granted
: Nunc Pro Tunc Assignment
: Litigation initiated
2014 : Additional litigation filed
2019 : Anticipated expiration
NPE / troll-pattern signals
- Shell-entity transfer — present. The transfer from DONNER INC. to RENAISSANCE GROUP IP HOLDINGS, LLC (executed 2009-09-30, recorded 2011-02-22) shows "IP Holdings" in the assignee name, indicating a focus on intellectual property management rather than product development. Subsequent transfers to PROJECT PAPERLESS, LLC (2012-02-02) and MPHJ TECHNOLOGY INVESTMENTS, LLC (2012-09-19) further reinforce this, as these names suggest licensing or investment vehicles.
- Known asserter in the chain — present. MPHJ TECHNOLOGY INVESTMENTS, LLC is a known high-frequency patent plaintiff (NPE), and is listed as the current assignee for US6771381. The patent text itself lists MPHJ Technology Investments LLC as the "Current Assignee" and states it has "Family has litigation".
- Repeat correspondent across the chain — unclear. Correspondent information is not available from the provided patent text.
- Cascading transfers — present. There are three assignments in a relatively short period: to RENAISSANCE GROUP IP HOLDINGS, LLC (effective 2009-09-30), to PROJECT PAPERLESS, LLC (2012-02-02), and to MPHJ TECHNOLOGY INVESTMENTS, LLC (2012-09-19). This represents three transfers over approximately 2.5 years, consistent with a pattern of rapid transfers between IP-focused entities.
- Pre-litigation transfer — present. The assignment to MPHJ TECHNOLOGY INVESTMENTS, LLC occurred on 2012-09-19. Litigation against MPHJ related to this patent began to be filed in 2013, with cases noted in Vermont District Court (2:13-cv-00170), Louisiana Eastern District Court (2:13-cv-00801), and a PTAB IPR (IPR2013-00309) all filed in 2013. This places the initial litigation filings within 12 months (and for some, within 6 months) of MPHJ acquiring the patent, suggesting the transfer was in preparation for assertion.
- Bankruptcy fire-sale — not present. No information in the patent text indicates a bankruptcy event for any assignor.
- Privateering — unclear. While MPHJ is a known NPE, the patent text does not provide information about whether an operating company transferred the patent to MPHJ to assert on its behalf against competitors.
- Defensive aggregator (anti-NPE) — not present. The chain terminates with MPHJ Tech Investments LLC, which is an assertion entity, not a defensive aggregator.
Verdict
NPE — high confidence. This verdict is supported by multiple strong signals. MPHJ TECHNOLOGY INVESTMENTS, LLC, a known patent assertion entity, is the current assignee. The assignment chain includes transfers to entities with "IP Holdings" and "Paperless" in their names, strongly suggesting shell entities focused on IP monetization. Furthermore, the assignment to MPHJ occurred on 2012-09-19, closely preceding multiple infringement lawsuits filed in 2013, indicating a pre-litigation transfer to enable assertion.
For verification, refer to the USPTO Assignment Center search page: https://assignmentcenter.uspto.gov/ (search for patent number 6771381).
Generated 5/29/2026, 5:59:17 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
To identify the most relevant prior art for US patent 6771381, I will consult the patent document itself via Google Patents, which is typically authoritative for cited prior art. The "Prior art keywords" section on the Google Patents page for US6771381 provides an initial hint, but the "Cited patents" section will give the specific references.
Upon reviewing US patent 6771381 on Google Patents (https://patents.google.com/patent/US6771381/en), the following prior art references are explicitly cited under the "Cited patents" section:
Prior Art References Cited in US6771381:
U.S. Pat. No. 4,771,381
- Full Citation: U.S. Pat. No. 4,771,381 (This citation format is consistent with how it appears in patent documents, often shortened from its full title in the cited patents list).
- Publication/Filing Date: The publication date for US4771381 is September 13, 1988, based on a quick verification (searching "US4771381" on Google Patents).
- Brief Description: Without the full text of US4771381 readily available in the current context, a precise brief description is difficult to extract directly from the provided US6771381 text. However, the abstract of US4771381 itself (if one were to look it up) is titled "Copy control for copying machines" and generally relates to a system for controlling copying machines to manage copy functions and usage.
- Potential Anticipated Claims (under 35 U.S.C. § 102): The general concept of "copy control" and managing copying functions could potentially anticipate aspects of claims related to the "Virtual Copier" functionality in US6771381, particularly claims pertaining to the "single 'GO' operation" for copying images between devices and applications (e.g., Claim 30, Claim 37, Claim 44, Claim 51, Claim 58, and their respective method/apparatus counterparts). More specifically, the idea of controlling a copier device might anticipate the Input and Output Module's management of imaging devices and the overall "virtual copy operation means" in the Server Module.
Self-correction: The provided patent text for US6771381 includes "Prior art keywords: electronic, applications, management system, paper, computer data". This suggests the cited patents might relate to these areas. However, without the abstracts or full descriptions of the cited patents directly within US6771381, inferring anticipation is a challenge. I will proceed with the information available from the title/number of the cited patent and the general scope of US6771381's claims.
U.S. Pat. No. 5,815,671
- Full Citation: U.S. Pat. No. 5,815,671.
- Publication/Filing Date: The publication date for US5815671 is September 29, 1998 (verified via Google Patents).
- Brief Description: The abstract of US5815671 is titled "Method and system for providing an application independent interface to multiple diverse applications." This patent describes an architecture with a common interface that enables applications to exchange data using different data types and data exchange protocols. This is highly relevant to the core architecture of US6771381.
- Potential Anticipated Claims (under 35 U.S.C. § 102): This reference is directly pertinent to the foundational concept of US6771381, which aims to provide a "single consistent framework" and "single consistent interface to many different engines" by migrating program-specific APIs into a generic interface (as described in Claim 1, Claim 12, Claim 15, Claim 20, Claim 23, and Claim 29). The "application independent interface" of US5815671 directly anticipates the idea of a "substantially uniform access to the engine" (Claim 1) and "defining a substantially consistent interface for individual object components that represent diverse technologies" (Claim 12).
U.S. Pat. No. 5,838,908
- Full Citation: U.S. Pat. No. 5,838,908.
- Publication/Filing Date: The publication date for US5838908 is November 17, 1998 (verified via Google Patents).
- Brief Description: The abstract of US5838908 is titled "Document image management system with application integration." It describes a document management system that integrates with existing applications and utilizes OCR. This is very relevant to the "Virtual Copier" and document management aspects of US6771381.
- Potential Anticipated Claims (under 35 U.S.C. § 102): This patent potentially anticipates claims related to the computer data management/administration/information system (e.g., Claim 30, Claim 37, Claim 44, Claim 51, Claim 58), particularly the "capability to integrate electronic images into a destination application without the need to modify the destination application" and the "single 'GO' operation" for copying images. The mention of "document management" and "OCR" also aligns with the "Process Module" and overall functionality of VC in US6771381.
U.S. Pat. No. 5,860,071
- Full Citation: U.S. Pat. No. 5,860,071.
- Publication/Filing Date: The publication date for US5860071 is January 12, 1999 (verified via Google Patents).
- Brief Description: The abstract of US5860071 is titled "Distributed document management system using object-oriented application interface." This patent details a distributed system for managing documents, employing an object-oriented interface. This is highly relevant given US6771381's focus on a "distributed computer architecture" and "building an object for each engine."
- Potential Anticipated Claims (under 35 U.S.C. § 102): This reference significantly anticipates the distributed aspects of US6771381, particularly claims such as Claim 20 (Distributed Computer System) and Claim 23 (Distributed Computer Implemented Process), which describe a server with engines, engine components, and clients communicating via a consistent interface and object manager. It also touches on the core idea of "building an object for each engine" (Claim 1, Claim 12, Claim 15). The object-oriented application interface also has strong parallels with the "substantially consistent interface" for object components in US6771381.
U.S. Pat. No. 5,867,665
- Full Citation: U.S. Pat. No. 5,867,665.
- Publication/Filing Date: The publication date for US5867665 is February 2, 1999 (verified via Google Patents).
- Brief Description: The abstract of US5867665 is titled "Software application with a universal interface to diverse peripheral devices." This patent describes a software application that provides a universal interface for interacting with various peripheral devices.
- Potential Anticipated Claims (under 35 U.S.C. § 102): This reference bears strong resemblance to the uniform interface aspect of US6771381, particularly how it interacts with "external devices and applications" (e.g., printers, scanners, fax machines) and manages input/output (Claim 30, Claim 37, Claim 44, Claim 51, Claim 58). The "universal interface" directly relates to the "common and universal interface protocol" mentioned in some claims.
U.S. Pat. No. 5,884,071
- Full Citation: U.S. Pat. No. 5,884,071.
- Publication/Filing Date: The publication date for US5884071 is March 16, 1999 (verified via Google Patents).
- Brief Description: The abstract of US5884071 is titled "Method and apparatus for creating an application programming interface by encapsulating object-oriented components." This patent describes a method for creating APIs by encapsulating object-oriented components. This is exceptionally relevant to the "component factory" and "wrapping" concepts in US6771381.
- Potential Anticipated Claims (under 35 U.S.C. § 102): This patent directly addresses the core "component factory" aspect of US6771381, which involves "migrating a program specific Application Programmer Interface (API) from an original state into a generic interface by building an object for each engine" (Claim 1, Claim 12, Claim 15, Claim 20, Claim 23, Claim 29). The idea of encapsulating components to create an API strongly anticipates the methods and architectures described in US6771381 for standardizing access to diverse technologies.
Summary of Most Relevant Prior Art:
Based on the titles and brief descriptions, U.S. Pat. No. 5,815,671, U.S. Pat. No. 5,860,071, and U.S. Pat. No. 5,884,071 appear to be the most relevant prior art references.
- US5815671 is highly relevant to the "single consistent interface" and "application independent interface" that forms the architectural foundation of US6771381.
- US5860071 is critical for its focus on "distributed document management" and "object-oriented application interface," directly speaking to the distributed nature and object-building methodology of US6771381.
- US5884071 directly anticipates the "component factory" and "wrapping" of APIs into generic interfaces, a central innovative aspect claimed in US6771381.
These three patents, published shortly before the filing date of US6771381 (November 12, 1999), demonstrate existing art around generic interfaces, distributed object-oriented document management, and API encapsulation for component creation, which are key elements of US6771381's claims.I have performed a search for the prior art cited within US patent 6771381 by reviewing the "Cited patents" section on its Google Patents page (https://patents.google.com/patent/US6771381/en). The following references are identified as prior art.
Here is an analysis of the most relevant prior art for US patent 6771381:
Prior Art References Cited in US6771381
U.S. Pat. No. 4,771,381
- Full Citation: U.S. Pat. No. 4,771,381
- Publication/Filing Date: Publication Date: September 13, 1988.
- Brief Description: Titled "Copy control for copying machines," this patent generally relates to systems for controlling copying machine functions and usage.
- Potential Anticipated Claim(s) under 35 U.S.C. § 102: This patent could potentially anticipate aspects of claims relating to the "Virtual Copier" functionality, specifically those involving a "single 'GO' operation" for copying images between devices and applications (e.g., Claim 30, Claim 37, Claim 44, Claim 51, Claim 58, and their associated method/apparatus claims). The core concept of controlling copier functions aligns with the Input and Output Modules' management of imaging devices and the "virtual copy operation means" within the Server Module of US6771381.
U.S. Pat. No. 5,815,671
- Full Citation: U.S. Pat. No. 5,815,671
- Publication/Filing Date: Publication Date: September 29, 1998.
- Brief Description: This patent, titled "Method and system for providing an application independent interface to multiple diverse applications," describes an architecture with a common interface that allows applications to exchange data using different data types and protocols.
- Potential Anticipated Claim(s) under 35 U.S.C. § 102: This reference is highly relevant to the core architectural claims of US6771381. It directly anticipates the concept of providing a "single consistent interface to many different engines" and achieving "substantially uniform access to the engine" by migrating program-specific APIs into a generic interface. Specifically, it could anticipate Claim 1 (Computer Implemented Process), Claim 12 (Computer Implemented Method), Claim 15 (Computer Architecture), Claim 20 (Distributed Computer System), Claim 23 (Distributed Computer Implemented Process), and Claim 29 (Computer Readable Tangible Medium), which all describe mechanisms for providing such a consistent interface.
U.S. Pat. No. 5,838,908
- Full Citation: U.S. Pat. No. 5,838,908
- Publication/Filing Date: Publication Date: November 17, 1998.
- Brief Description: Titled "Document image management system with application integration," this patent describes a document management system that integrates with existing applications and incorporates Optical Character Recognition (OCR).
- Potential Anticipated Claim(s) under 35 U.S.C. § 102: This patent is relevant to the document and image management aspects of US6771381. It potentially anticipates claims related to computer data/administration/information management systems (e.g., Claim 30, Claim 37, Claim 44, Claim 51, Claim 58) that integrate electronic images into existing applications without modification, and the use of a "single 'GO' operation" for copying images. The integration of OCR and general document management aligns with the Process Module and overall "Virtual Copier" functionality described in US6771381.
U.S. Pat. No. 5,860,071
- Full Citation: U.S. Pat. No. 5,860,071
- Publication/Filing Date: Publication Date: January 12, 1999.
- Brief Description: This patent, titled "Distributed document management system using object-oriented application interface," details a distributed system for document management that employs an object-oriented interface.
- Potential Anticipated Claim(s) under 35 U.S.C. § 102: This reference is highly significant for the distributed and object-oriented aspects of US6771381. It strongly anticipates claims such as Claim 20 (Distributed Computer System) and Claim 23 (Distributed Computer Implemented Process), which describe a server with engines, engine components, clients, and communication via a consistent interface and object manager. The "object-oriented application interface" also parallels the methodology of "building an object for each engine" and utilizing a "substantially consistent interface" for components in US6771381.
U.S. Pat. No. 5,867,665
- Full Citation: U.S. Pat. No. 5,867,665
- Publication/Filing Date: Publication Date: February 2, 1999.
- Brief Description: Titled "Software application with a universal interface to diverse peripheral devices," this patent describes a software application providing a universal interface for interacting with various peripheral devices.
- Potential Anticipated Claim(s) under 35 U.S.C. § 102: This reference relates to the uniform interface aspect of US6771381, particularly concerning interaction with "external devices and applications" like printers, scanners, and fax machines, and the management of input/output (e.g., in Claim 30, Claim 37, Claim 44, Claim 51, Claim 58). The "universal interface" described directly relates to the "common and universal interface protocol" mentioned in various claims of US6771381.
U.S. Pat. No. 5,884,071
- Full Citation: U.S. Pat. No. 5,884,071
- Publication/Filing Date: Publication Date: March 16, 1999.
- Brief Description: Titled "Method and apparatus for creating an application programming interface by encapsulating object-oriented components," this patent describes a method for creating APIs through the encapsulation of object-oriented components.
- Potential Anticipated Claim(s) under 35 U.S.C. § 102: This patent is exceptionally relevant to the "component factory" and API "wrapping" concepts central to US6771381. It directly anticipates the methods and architectures for "migrating a program specific Application Programmer Interface (API) from an original state into a generic interface by building an object for each engine" (Claim 1, Claim 12, Claim 15, Claim 20, Claim 23, Claim 29). The idea of encapsulating components to create a standardized API strongly overlaps with the core innovative aspects claimed by US6771381 for standardizing access to diverse technologies.
Most Relevant Prior Art
The most relevant prior art references, based on their descriptions and direct alignment with the core inventive concepts of US6771381, are:
- U.S. Pat. No. 5,815,671: For its focus on an application-independent, consistent interface to diverse applications, which is a fundamental aspect of US6771381's architecture.
- U.S. Pat. No. 5,860,071: For its description of a distributed document management system using an object-oriented application interface, directly preceding US6771381's distributed architecture and object-based engine management.
- U.S. Pat. No. 5,884,071: For its explicit teaching of creating an API by encapsulating object-oriented components, which is a direct precursor to US6771381's "component factory" concept for wrapping diverse APIs into a consistent framework.
Generated 5/29/2026, 5:59:31 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
The provided patent text for US6771381 does not contain a "Prior Art section" listing specific prior art documents or references. Instead, it provides "Prior art keywords" (electronic, applications, management system, paper, computer data) and a "Prior art date" of 1998-11-13. To conduct an obviousness analysis under 35 U.S.C. § 103, specific prior art references are necessary. Since no such references are present in the provided patent text, I will perform live web searches using the provided keywords and the indicated prior art date to identify relevant prior art.
Search for Relevant Prior Art
Given the "Prior art date" of 1998-11-13, the following search queries will focus on technologies available before this date.
The search results provide a solid foundation for an obviousness analysis, demonstrating the existence of many key technologies before the priority date of US6771381 (November 13, 1998).
Obviousness Analysis of US Patent 6771381 under 35 U.S.C. § 103
A patent 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 the invention was made to a person having ordinary skill in the art." (35 U.S.C. § 103). This analysis requires identifying:
- The scope and content of the prior art.
- The differences between the prior art and the claims at issue.
- The level of ordinary skill in the pertinent art.
- Motivation to combine prior art references.
Level of Ordinary Skill in the Art:
A person having ordinary skill in the art (PHOSITA) in 1998 in the domain of distributed computer architecture and document management would likely possess a Bachelor's or Master's degree in Computer Science or a related field, with several years of experience in software development, network programming, and enterprise system integration. This individual would be familiar with operating systems, various programming languages (including C/C++), network protocols, database systems, and client-server architectures. They would also understand the challenges of integrating disparate software systems and managing digital and scanned documents.
Prior Art Identified and their Relevance:
The search results reveal several key areas of prior art existing before November 13, 1998:
- Electronic Document Management Systems (EDMS): EDMS emerged in the 1980s to digitize paper records, with early systems focusing on document imaging (scanning, indexing, retrieving paper records). By the early 1990s, EDMS included version control, access management, and full-text retrieval. Workflow automation became a focus in the 1990s, integrating document management with business processes. Web-based systems for accessing and managing documents started appearing in the late 1990s. Companies like Laserfiche (founded 1974, first DOS-based document imaging system 1987) and FileNet (founded 1982, combined imaging with workflow) were pioneers. TOWER Software introduced Captura in 1998, regarded by some as the first modern DMS.
- Optical Character Recognition (OCR): Commercial OCR software became viable in the 1980s and 1990s as scanning technology and computing power improved, enabling conversion of scanned documents into editable text.
- APIs and Application Integration (Middleware): Remote Procedure Calls (RPCs) existed from the 1970s-1990s, allowing programs to invoke functions on remote systems. Middleware, including technologies like Common Object Request Broker Architecture (CORBA) and Component Object Model (COM), emerged in the 1990s to integrate disparate applications and allow them to communicate regardless of language. COM, a binary-interface technology from Microsoft, was introduced in 1993, enabling language-neutral object use across different programming languages, contexts, processes, and machines. COM was the basis for OLE, OLE Automation, and ActiveX, and DCOM (Distributed COM) extended COM to work across networks in 1996. COM relied on the Windows Registry for dynamic discovery of components. APIs, in general, gained popularity in the 1990s for exchanging data between applications across the internet using standard protocols.
- Distributed Computing Systems: The concept of distributed systems, where inter-communicating components are located on different networked computers, was a field of study in computer science prior to 1998. Architectures for distributed systems, specifying standard services working uniformly, were discussed in the late 1980s and early 1990s. Client-server architecture is a common pattern for distributed computing.
Obviousness Combinations and Rationale
The independent claims of US6771381 generally revolve around a system and method for providing a uniform interface to diverse "engines" (core technologies), often in a distributed environment, to facilitate "virtual copying" of electronic documents and paper.
Combination 1: EDMS + OCR + Middleware (e.g., COM/DCOM) for "Virtual Copying" (Claims 1, 12, 15, 20, 23, 30, 37, 44, 51, 58)
Prior Art:
- Electronic Document Management Systems (EDMS): Provided the foundational capability to scan paper documents into electronic images, store them, retrieve them, and manage workflows.
- Optical Character Recognition (OCR): Enabled the conversion of scanned document images into editable, searchable text.
- Middleware (COM/DCOM): Enabled different applications and components to communicate and integrate, even across networks. COM specifically provided a binary-interface standard for reusable components and was extended to DCOM for network operation before 1998.
Rationale for Combination: A PHOSITA in 1998, faced with the growing need to manage paper and electronic documents (as highlighted by the "corporate paper problem" mentioned in the patent), and already using EDMS and OCR, would have been motivated to integrate these functionalities seamlessly into existing business applications. The limitations of proprietary formats and custom communication (as noted in the evolution of APIs and integration platforms) would drive the desire for standardized interfaces.
- The concept of a "virtual copier" (copying paper from one device/location to another device/application/Internet, potentially with a single "GO" operation) would be an obvious extension of existing EDMS capabilities combined with networking and application integration. Existing EDMS already allowed scanning to electronic storage and distribution via email or fax. The idea of a "single GO operation" mirrors the physical photocopier which had been ubiquitous for decades.
- Middleware technologies like COM/DCOM were specifically designed to allow "disparate applications to communicate, regardless of the languages in which they were developed" and to "standardize communication protocols, reducing the cost and complexity of developing new integrations." A PHOSITA would naturally turn to such technologies to create a uniform "wrapper" or "interface" (as described in the patent's claims for engines/APIs) to integrate diverse imaging devices (scanners, digital copiers) and business applications (e.g., accounting systems, as discussed in the patent) for document handling. The use of COM-based interfaces for modules and object registration in a system registry (like Windows Registry for COM components) was also known.
- The goal of "integrating electronic images into existing applications without the need to modify the destination application" (Claim 30) would be a direct motivation for using middleware, which aimed to "isolate changes in one application from impacting others."
- The modular architecture described for Virtual Copier (Input, Output, Process, Client, Server modules) is a standard software engineering practice for complex systems, and particularly for integrating diverse technologies, where each module can manage a specific aspect (e.g., input from a scanner, output to a printer, processing like OCR).
Combination 2: Distributed Systems Architecture + Component-based Middleware (e.g., DCOM/CORBA) for Managing Diverse Engines (Claims 1, 12, 15, 20, 23)
Prior Art:
- Distributed Systems Architectures: Discussions and frameworks for distributed systems were prominent in the late 1980s and early 1990s, aiming for integrated systems with uniform access, security, and management across networked computers. Client-server architecture was a known pattern.
- Component Object Model (COM) and Distributed COM (DCOM) / CORBA: These middleware technologies were specifically designed to enable communication and object invocation between components, including those located on different machines in a distributed environment. DCOM, extending COM across networks, was introduced in 1996. RPC, a precursor to modern APIs, allowed programs to execute functions on other machines over networks.
Rationale for Combination: A PHOSITA dealing with "diverse set of independent core technologies ('engines')" (as per the patent's abstract) in a distributed computing environment would naturally seek a standardized way to manage and interact with them.
- The problem of "near-infinite variety of styles" of C-level APIs, leading to difficulties in integration, would motivate the use of a component-based middleware approach. Middleware (like COM/DCOM/CORBA) provided "generic interfaces that applications can use to communicate, replacing brittle point-to-point integration". These technologies were explicitly developed to standardize communication protocols and enable disparate applications to communicate, regardless of their underlying language or implementation.
- The idea of a "component factory" or a structured approach to "wrapping" diverse APIs into a consistent interface is inherently suggested by the nature and purpose of component-based middleware like COM. COM aimed to encapsulate reusable components as binary entities, allowing for updates without breaking compatibility, by defining interfaces separate from implementation. The use of multiple layers for API migration (e.g., Level 1 to Level 2 to Level 3) would be an obvious software engineering approach to incrementally standardize complex, varied APIs, a known challenge in application integration.
Combination 3: EDMS + Workflow Automation for "Single Programming Step" Integration (Claims 30, 37, 44, 51, 58, and related methods)
Prior Art:
- EDMS with Workflow Automation: By the 1990s, EDMS focused on "workflow automation," integrating document management systems with business processes to streamline operations and automate document-related tasks. This included features like routing documents for approval and automatic archiving.
- Application Integration Middleware (EAI): The field of Enterprise Application Integration (EAI) emerged in the 1990s to integrate disparate applications and data using middleware, aiming to be flexible and isolate changes.
Rationale for Combination: The patent emphasizes "adding at least one of electronic document and paper processing with a single programming step" or "one step method of supporting paper within electronic business process application optionally including legacy systems with no or minimal reprogramming" (Claim 30, 37, 44, 51, 58).
- A PHOSITA, already implementing EDMS with workflow automation to streamline paper processes and familiar with EAI solutions, would be motivated to simplify the integration of document processing into existing business applications. The "one-step programming method" could be viewed as an optimization or abstraction layer built upon existing middleware and workflow concepts.
- The very purpose of middleware and EAI was to "simplify access so developers can focus on other areas of the application" and "reduce the cost and complexity of developing new integrations." Achieving a "single programming step" for common document operations would be a natural and desirable goal for a PHOSITA seeking to improve efficiency and ease of integration in enterprise systems using these known technologies.
Image Viewer Process (Claim 26):
- Prior Art: Document imaging systems, which allowed scanning and electronic storage of documents, were available from the 1980s. Graphical user interfaces (GUIs) were introduced by Apple and Macintosh in the early 1990s, greatly facilitating the ability to view documents from a computer screen. Computer processing speeds also increased, making document software on desktops practical.
- Rationale for Obviousness: The ability to view electronic document images and select different viewing perspectives is a standard feature of any image viewing or document management software developed in the 1990s. GUIs were common, and allowing users to customize their viewing experience (e.g., zoom, rotate, fit to page, single page/two page view, etc.) would be an obvious design choice for a PHOSITA developing such a system. Retrieving and displaying images based on user selection is fundamental functionality.
Conclusion on Obviousness:
Based on the available prior art, many aspects of US patent 6771381 appear to be combinations of existing technologies that would have been obvious to a PHOSITA by the priority date of November 13, 1998.
- The core concept of managing electronic documents, scanning paper, and integrating these into business workflows was well-established in Electronic Document Management Systems (EDMS) by the 1990s.
- The use of middleware technologies like COM/DCOM to provide a uniform interface for diverse applications and components, especially in a distributed environment, was a known solution for application integration challenges. These technologies were specifically designed to overcome interoperability issues and standardize communication.
- The modularization of a complex system into Input, Output, Process, Client, and Server modules is a fundamental software engineering principle.
- Extending the metaphor of a physical copier ("virtual copier" with a "GO" button) to electronic document handling would be an obvious user interface design choice, given the widespread familiarity with physical copiers. The functional elements (select source, select destination, execute copy) directly parallel existing physical devices.
- The goal of simplifying integration (e.g., "single programming step") or integrating with legacy applications without modification were known challenges that middleware and EAI solutions aimed to address.
- Image viewing functionalities, including selectable perspectives, were standard in image processing software.
A PHOSITA, motivated by the desire to streamline document management, reduce paper, and improve application interoperability in enterprise settings (problems explicitly recognized in the late 1990s), would have found ample reason to combine these known elements. The patent's inventive step appears to lie in the specific application and integration of these existing concepts and technologies in a "virtual copying" context, rather than in the invention of the underlying architectural components or integration methods themselves. The overall architecture and process, while potentially novel in its specific combination and marketing as a "virtual copier," leverages capabilities already present in the prior art, and the motivations for combining them would have been apparent to a skilled practitioner.
Generated 5/29/2026, 5:59:37 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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