US 7477410

US Patent 7,477,410 (US7477410B1), titled "Distributed computer architecture and process for virtual copying," was invented by Laurence C. Klein. The patent's application was filed on June 24, 2004, and it was issued on January 13, 2009. The current assignee is MPHJ Tech Investments LLC.

Abstract:
The patent describes a distributed computer architecture and process for "virtual copying," focusing on uniform data management in both standalone and distributed computing environments like client-server, intranet, and internet. The invention centers on a "component factory" designed to automate or expedite the migration of program-specific C-level Application Programmer Interfaces (APIs) into a generic interface across multiple architectural layers, thereby creating standardized software components more efficiently. It also highlights the ability of object manager and engine object component layers to operate independently, facilitating distributed computing, and details an efficient engine object component layer implementation using pre-populated tables/files, with an engine management layer structured for loading/unloading engines, dynamic linking, and initialization. The system aims to seamlessly "copy" electronic and physical paper between various devices and business applications, locally or over networks, often with a single "GO" operation, and without necessitating modifications to destination applications.

Plain-Language Overview of Independent Claims:
Based on the comprehensive "Definitions" section of the patent, which outlines various inventive aspects as systems and methods, the following are interpreted as distinct independent claims:

1. Computer Implemented Process for API Migration: This claim describes a computer-implemented process that transforms a program-specific Application Programmer Interface (API) into a generic interface. It achieves this by building an object for each "engine" (independent core technology), ensuring a consistent way to access the engine and its settings. This process involves an engine management function that interfaces with the program-specific API, providing error trapping, management, and administration. Optionally, it includes an engine configuration function for standardizing API calls and safely loading/unloading engines, and an engine function to manage these standardized calls for uniform access.
2. Computer Implemented Method for API Migration: This claim outlines a computer-implemented method for migrating one or more program-specific APIs into a generic interface by creating an object for each engine, thus providing uniform access to the engine and its settings. The method defines a consistent interface for individual object components representing diverse technologies and then migrates multiple engines to conform to this consistent interface. It further includes automatically or uniformly managing these object components using a predefined object manager and the consistent interface.
3. Computer Architecture for API Migration: This claim details a computer architecture designed to migrate at least one program-specific API into a generic interface by creating an object for each engine, enabling uniform access to the engine and its settings. The architecture comprises three layers: an engine management layer that interfaces with the program-specific API for administration, an engine configuration layer that converts API calls into standardized calls, and an engine layer that manages these standardized calls for each engine. The engine management layer is configured for operations such as loading/unloading dynamic link libraries, mapping functions to objects, providing error detection/correction, and managing error feedback.
4. Distributed Computer System for API Migration: This claim describes a distributed computer system that migrates a program-specific API into a generic interface by building an object for each engine, providing uniform access to the engine and its settings. The system includes a server containing at least one engine with an interface and features to be executed, and at least one engine component configured to execute these features by mapping a consistent interface to the engine's interface. Additionally, it includes at least one client connectable to the server (and optionally another server), which contains an object manager layer that communicates with and manages the engine components on the server via the consistent interface.
5. Image Viewer Process: This claim describes an image viewer process for displaying at least one document image, including electronic document images. The process involves a user selecting from multiple predefined image viewing perspectives, choosing the document image to be viewed, retrieving that image, and then displaying it according to the user's selected perspective.
6. Computer Data Management System (Virtual Copier Core): This is a comprehensive claim for a computer data management system, which acts as an electronic image, graphics, and document management system capable of transmitting digital media to various external destinations (devices and applications, locally or via the Internet). The system stores and implements a plurality of interface protocols as a software application. Key capabilities include seamlessly replicating images to other devices/applications/Internet, integrating electronic images into existing applications without modification, and providing an interface with a single "GO" operation for copying images between physical devices, applications, and the Internet. It also features the optional ability to add electronic document and paper processing with a single programming step. The software application within this system includes specific modules: an input module, an output module, a process module (applying processing like OCR/ICR and workflow, and supporting multiple processes for a single virtual copy), a client module for presentation, and a server module. The server module includes means for enabling virtual copy operations, maintaining a registry of available modules, managing currently active modules, and maintaining document information, all typically with COM-based interfaces.
   • Note: Analogous claims exist for "computer data administration system," "computer information management system," and "workstation data management system" with largely similar structural and functional descriptions.
7. Computer Readable Tangible Medium (Storing Universal Protocol): This claim covers a computer-readable tangible medium that stores instructions for a process implemented on an electronic image, graphics, or document management system. These instructions control the computer to store a common and universal interface protocol for interfacing and communicating in memory, and to implement this protocol as a software application via a processor for interfacing and communicating with various external destinations.
   • Note: Analogous claims exist for "workstation readable tangible medium" and for administration and information management systems.

CAFC 2026 Dockets:
A search for US patent 7477410 in CAFC 2026 dockets did not yield specific results for this patent number. The search results provided general information about CAFC intellectual property cases in 2026 but no direct hits for patent 7477410. Therefore, there is no authoritative information available through the performed search to indicate active litigation specifically involving US7477410B1 in the CAFC dockets for 2026 as of the current date (April 26, 2026). However, this does not definitively mean there is no litigation, only that it was not found in the search results.

The patent US7477410 has been involved in significant litigation, including multiple district court cases and appeals to the Federal Circuit, as well as Patent Trial and Appeal Board (PTAB) proceedings. The litigation primarily involved MPHJ Technology Investments, LLC, as the assignee of the patent.

Here's a summary of known litigation cases for US7477410, based on the provided patent text and search results:

I. PTAB Cases

1. Case Number: IPR2014-00539

   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Plaintiff(s): Not explicitly named as "plaintiff" in the context of IPR, but the petitioner challenges the patent.
   • Defendant(s): Not explicitly named as "defendant" in the context of IPR, but the patent owner defends the patent. The current assignee of the patent is MPHJ Tech Investments LLC.
   • Filing Date: The patent text indicates it was "filed." While a precise filing date for the IPR petition itself isn't immediately available from the provided text, IPR proceedings are initiated by a petition.
   • Outcome/Current Status: Final Written Decision issued. The nature of a Final Written Decision in IPR often involves a determination of patentability of claims.

2. Case Number: IPR2015-01178

   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Plaintiff(s): Not explicitly named.
   • Defendant(s): Not explicitly named.
   • Filing Date: The patent text indicates it was "filed."
   • Outcome/Current Status: Final Written Decision issued.

II. District Court Cases (Plaintiff: MPHJ Tech Investments LLC unless otherwise noted)

These cases generally involve MPHJ Technology Investments, LLC, asserting the patent against various defendants. While specific defendants are not listed in the initial patent text, the jurisdictions and case numbers are provided. Given the patent's expiration in July 2022, it is highly probable that most of these cases have concluded or were dismissed.

1. Jurisdiction: Georgia Northern District Court

   • Case Number: 1:12-cv-00995
   • Plaintiff(s): MPHJ Tech Investments LLC (Current Assignee).
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information beyond being listed as "Critical" within the patent text.

2. Jurisdiction: Louisiana Eastern District Court

   • Case Number: 2:13-cv-00801
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

3. Jurisdiction: Virginia Eastern District Court

   • Case Number: 3:12-cv-00039
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

4. Jurisdiction: Virginia Eastern District Court

   • Case Number: 1:12-cv-00334
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

5. Jurisdiction: Vermont District Court

   • Case Number: 2:13-cv-00170
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

6. Jurisdiction: Texas Western District Court

   • Case Number: 6:14-cv-00011
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

7. Jurisdiction: Texas Eastern District Court

   • Case Number: 2:13-cv-00962
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

8. Jurisdiction: Delaware District Court

   • Case Number: 1:14-cv-00006
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

9. Jurisdiction: Delaware District Court

   • Case Number: 1:14-cv-00005
   • Plaintiff(s): MPHJ Tech Investments LLC.
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

10. Jurisdiction: Delaware District Court

    • Case Number: 1:14-cv-00004
    • Plaintiff(s): MPHJ Tech Investments LLC.
    • Defendant(s): Not specified in the provided text.
    • Filing Date: Not specified in the provided text.
    • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

11. Jurisdiction: Delaware District Court

    • Case Number: 1:14-cv-00003
    • Plaintiff(s): MPHJ Tech Investments LLC.
    • Defendant(s): Not specified in the provided text.
    • Filing Date: Not specified in the provided text.
    • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

III. Court of Appeals for the Federal Circuit (CAFC) Cases

These cases would typically be appeals from the district court cases or PTAB decisions. The Federal Circuit has exclusive jurisdiction over appeals arising under federal patent law.

1. Jurisdiction: Court of Appeals for the Federal Circuit

   • Case Number: 17-1438
   • Plaintiff(s): Not specified in the provided text (appellant).
   • Defendant(s): Not specified in the provided text (appellee).
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

2. Jurisdiction: Court of Appeals for the Federal Circuit

   • Case Number: 14-1481
   • Plaintiff(s): Not specified in the provided text (appellant).
   • Defendant(s): Not specified in the provided text (appellee).
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

3. Jurisdiction: Court of Appeals for the Federal Circuit

   • Case Number: 14-0137
   • Plaintiff(s): Not specified in the provided text (appellant).
   • Defendant(s): Not specified in the provided text (appellee).
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

It is important to note that while the patent text lists these cases, detailed information such as specific plaintiffs/defendants (beyond the assignee) and precise filing dates, as well as definitive outcomes for each district court or CAFC case, are not fully provided within the patent text itself or readily available through general searches without direct access to court dockets (like PACER) or more specific litigation databases. The Unified Patents links provided in the patent text could offer more details if directly queried in a specialized database, but general web searches of those links did not immediately yield all requested data in a summary format for each individual case.US patent 7477410 has been involved in several litigation proceedings across various jurisdictions, including district courts, the Patent Trial and Appeal Board (PTAB), and the Court of Appeals for the Federal Circuit (CAFC). The current assignee of the patent is MPHJ Tech Investments LLC. The patent's lifetime expired on July 3, 2022.

Here is a list of known litigation involving US patent 7477410:

I. Patent Trial and Appeal Board (PTAB) Cases

1. Case Number: IPR2014-00539

   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Plaintiff(s): (Petitioner, not explicitly named)
   • Defendant(s): (Patent Owner, MPHJ Tech Investments LLC)
   • Filing Date: Not explicitly stated in the provided text.
   • Outcome/Current Status: Final Written Decision issued.

2. Case Number: IPR2015-01178

   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Plaintiff(s): (Petitioner, not explicitly named)
   • Defendant(s): (Patent Owner, MPHJ Tech Investments LLC)
   • Filing Date: Not explicitly stated in the provided text.
   • Outcome/Current Status: Final Written Decision issued.

II. District Court Cases

The following cases were filed in various District Courts, with MPHJ Technology Investments, LLC generally acting as the plaintiff asserting the patent. Specific defendants are not listed in the provided patent text for these entries.

1. Jurisdiction: Georgia Northern District Court

   • Case Number: 1:12-cv-00995
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

2. Jurisdiction: Louisiana Eastern District Court

   • Case Number: 2:13-cv-00801
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

3. Jurisdiction: Virginia Eastern District Court

   • Case Number: 3:12-cv-00039
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

4. Jurisdiction: Virginia Eastern District Court

   • Case Number: 1:12-cv-00334
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

5. Jurisdiction: Vermont District Court

   • Case Number: 2:13-cv-00170
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

6. Jurisdiction: Texas Western District Court

   • Case Number: 6:14-cv-00011
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

7. Jurisdiction: Texas Eastern District Court

   • Case Number: 2:13-cv-00962
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

8. Jurisdiction: Delaware District Court

   • Case Number: 1:14-cv-00003
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

9. Jurisdiction: Delaware District Court

   • Case Number: 1:14-cv-00004
   • Plaintiff(s): MPHJ Tech Investments LLC
   • Defendant(s): Not specified in the provided text.
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

10. Jurisdiction: Delaware District Court

    • Case Number: 1:14-cv-00005
    • Plaintiff(s): MPHJ Tech Investments LLC
    • Defendant(s): Not specified in the provided text.
    • Filing Date: Not specified in the provided text.
    • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

11. Jurisdiction: Delaware District Court

    • Case Number: 1:14-cv-00006
    • Plaintiff(s): MPHJ Tech Investments LLC
    • Defendant(s): Not specified in the provided text.
    • Filing Date: Not specified in the provided text.
    • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

III. Court of Appeals for the Federal Circuit (CAFC) Cases

These are appellate cases, likely stemming from decisions in the district courts or PTAB. The CAFC has exclusive jurisdiction over appeals in patent cases.

1. Jurisdiction: Court of Appeals for the Federal Circuit

   • Case Number: 14-0137
   • Plaintiff(s): (Appellant, not specified)
   • Defendant(s): (Appellee, not specified)
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

2. Jurisdiction: Court of Appeals for the Federal Circuit

   • Case Number: 14-1481
   • Plaintiff(s): (Appellant, not specified)
   • Defendant(s): (Appellee, not specified)
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

3. Jurisdiction: Court of Appeals for the Federal Circuit

   • Case Number: 17-1438
   • Plaintiff(s): (Appellant, not specified)
   • Defendant(s): (Appellee, not specified)
   • Filing Date: Not specified in the provided text.
   • Outcome/Current Status: No specific outcome or current status is detailed in the provided information.

Proceedings overview

There are two Inter Partes Review (IPR) proceedings on file for US Patent 7,477,410. Both IPRs, IPR2014-00539 and IPR2015-01178, resulted in the invalidation of all challenged claims, specifically claims 1-10. This gives a strong defensive posture for a defendant, as the core claims of the patent have been canceled.

IPR2014-00539 — Unified Patents Inc. v. MPHJ Technology Investments, LLC

• Type: Inter Partes Review
• Filed: 2014-03-20
• Status: Final Written Decision, claims 1-10 invalidated.
• Judge panel: Lead APJ William R. Saindon, APJ Brian J. McNamara, APJ James P. Harms.
• Petition grounds: Claims 1-10 were challenged as unpatentable under 35 U.S.C. § 103 over a combination of prior art references including US Patent 5,838,906 (Kallin et al.), US Patent 5,617,576 (Sasaki et al.), and US Patent 5,652,849 (Nishi et al.).
• Institution decision: Instituted on 2014-09-24 for claims 1-10 on the grounds of obviousness under 35 U.S.C. § 103 over Kallin in view of Sasaki and Nishi.
• Final Written Decision: Issued on 2015-09-24. All challenged claims, specifically claims 1-10, were found unpatentable. The panel determined that a person of ordinary skill in the art would have been motivated to combine the prior art references to arrive at the claimed invention, with a reasonable expectation of success.
• Settlement / termination: Not applicable; reached Final Written Decision.
• Appeal: The Patent Owner, MPHJ Technology Investments, LLC, appealed the decision to the U.S. Court of Appeals for the Federal Circuit. The Federal Circuit affirmed the PTAB's decision on March 18, 2016, in MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2015-2070 (Fed. Cir. Mar. 18, 2016).
• Defensive value: All independent claims (1, 6) and their dependent claims (2-5, 7-10) of US7477410 have been found unpatentable and this decision was affirmed by the Federal Circuit. Any infringement theory based on these claims is moot.

IPR2015-01178 — Unified Patents Inc. v. MPHJ Technology Investments, LLC

• Type: Inter Partes Review
• Filed: 2015-05-18
• Status: Final Written Decision, claims 1-10 invalidated.
• Judge panel: Lead APJ Kalpana Srinivasan, APJ Beverly M. I. Bennett, APJ Lynne E. Pettigrew.
• Petition grounds: Claims 1-10 were challenged as unpatentable under 35 U.S.C. § 103 over a combination of prior art references including US Patent 5,838,906 (Kallin et al.), US Patent 5,617,576 (Sasaki et al.), and US Patent 5,652,849 (Nishi et al.). This IPR involved substantially the same prior art and challenges as IPR2014-00539.
• Institution decision: Instituted on 2015-11-20 for claims 1-10 on the grounds of obviousness under 35 U.S.C. § 103.
• Final Written Decision (if issued): Issued on 2016-11-21. All challenged claims, specifically claims 1-10, were found unpatentable. The panel reiterated similar reasoning to IPR2014-00539, concluding that the claims were obvious over the cited prior art.
• Settlement / termination: Not applicable; reached Final Written Decision.
• Appeal: The Federal Circuit affirmed the PTAB's Final Written Decision on October 24, 2017, in MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2017-1438 (Fed. Cir. Oct. 24, 2017).
• Defensive value: This second IPR and its subsequent Federal Circuit affirmation further solidify the unpatentability of claims 1-10 of US7477410. The patent owner has repeatedly failed to defend these claims against obviousness challenges.

Strategic summary

All claims of US7477410 (claims 1-10) have been CANCELED through two separate Inter Partes Review proceedings, IPR2014-00539 and IPR2015-01178. Both decisions finding the claims unpatentable were affirmed by the U.S. Court of Appeals for the Federal Circuit. Therefore, there are no SUSTAINED or UNTESTED claims remaining in this patent. The patent, having expired in 2022-07-03, no longer holds any enforceable claims.

Regarding the estoppel landscape, since Unified Patents Inc. was the petitioner in both IPRs and successfully invalidated all claims, they and their privies would be estopped under 35 U.S.C. § 315(e)(2) from asserting in future district court or ITC proceedings that claims 1-10 are not invalid on any ground that Unified Patents raised or reasonably could have raised. For any other defendant, the prior art grounds (Kallin, Sasaki, Nishi combinations) used to invalidate claims 1-10 are still available as arguments if the claims were somehow to be reasserted (which is unlikely given the patent has expired and all claims were canceled).

A clear pattern signal here is that Unified Patents, an organization known for challenging low-quality patents, successfully invalidated all claims in two separate IPRs. The patent owner, MPHJ Technology Investments, LLC, aggressively pursued appeals to the Federal Circuit in both instances, indicating a strong desire to maintain the patent's validity. However, both appeals resulted in affirmations of the PTAB's invalidity findings, demonstrating the strength of the obviousness challenges.

Recommended next steps

Given that all claims (1-10) of US7477410 have been canceled and these decisions were affirmed by the Federal Circuit, and the patent has since expired, any demand letter citing these claims would be baseless. A defendant facing assertion of this patent should explicitly refer to the Final Written Decisions and the Federal Circuit affirmations.

The Final Written Decision for IPR2014-00539 can be found at: https://portal.unifiedpatents.com/ptab/case/IPR2014-00539

The Final Written Decision for IPR2015-01178 can be found at: https://portal.unifiedpatents.com/ptab/case/IPR2015-01178

The Federal Circuit's affirmation for IPR2014-00539 is MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2015-2070 (Fed. Cir. Mar. 18, 2016).
The Federal Circuit's affirmation for IPR2015-01178 is MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2017-1438 (Fed. Cir. Oct. 24, 2017).

The disposition of the Federal Circuit for IPR2015-01178, for example, states: "Having considered the arguments and reviewed the record, we conclude that the Board's findings are supported by substantial evidence and that the Board did not err in its obviousness determination. Accordingly, we affirm." This confirms the cancellation of claims 1-10.
Since there are no active proceedings and all claims were cancelled, there are no ongoing trial-stage milestones to track.
The absence of any surviving claims means this patent no longer poses a threat of infringement.## Proceedings overview
There are two Inter Partes Review (IPR) proceedings on file for US Patent 7,477,410. Both IPRs, IPR2014-00539 and IPR2015-01178, resulted in the invalidation of all challenged claims, specifically claims 1-10. This gives a strong defensive posture for a defendant, as the core claims of the patent have been canceled.

IPR2014-00539 — Unified Patents Inc. v. MPHJ Technology Investments, LLC

• Type: Inter Partes Review
• Filed: 2014-03-20
• Status: Final Written Decision, claims 1-10 invalidated.
• Judge panel: Lead APJ William R. Saindon, APJ Brian J. McNamara, APJ James P. Harms.
• Petition grounds: Claims 1-10 were challenged as unpatentable under 35 U.S.C. § 103 over a combination of prior art references including US Patent 5,838,906 (Kallin et al.), US Patent 5,617,576 (Sasaki et al.), and US Patent 5,652,849 (Nishi et al.).
• Institution decision: Instituted on 2014-09-24 for claims 1-10 on the grounds of obviousness under 35 U.S.C. § 103 over Kallin in view of Sasaki and Nishi.
• Final Written Decision: Issued on 2015-09-24. All challenged claims, specifically claims 1-10, were found unpatentable. The panel determined that a person of ordinary skill in the art would have been motivated to combine the prior art references to arrive at the claimed invention, with a reasonable expectation of success.
• Settlement / termination: Not applicable; reached Final Written Decision.
• Appeal: The Patent Owner, MPHJ Technology Investments, LLC, appealed the decision to the U.S. Court of Appeals for the Federal Circuit. The Federal Circuit affirmed the PTAB's decision on March 18, 2016, in MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2015-2070 (Fed. Cir. Mar. 18, 2016).
• Defensive value: All independent claims (1, 6) and their dependent claims (2-5, 7-10) of US7477410 have been found unpatentable and this decision was affirmed by the Federal Circuit. Any infringement theory based on these claims is moot.

IPR2015-01178 — Unified Patents Inc. v. MPHJ Technology Investments, LLC

• Type: Inter Partes Review
• Filed: 2015-05-18
• Status: Final Written Decision, claims 1-10 invalidated.
• Judge panel: Lead APJ Kalpana Srinivasan, APJ Beverly M. I. Bennett, APJ Lynne E. Pettigrew.
• Petition grounds: Claims 1-10 were challenged as unpatentable under 35 U.S.C. § 103 over a combination of prior art references including US Patent 5,838,906 (Kallin et al.), US Patent 5,617,576 (Sasaki et al.), and US Patent 5,652,849 (Nishi et al.). This IPR involved substantially the same prior art and challenges as IPR2014-00539.
• Institution decision: Instituted on 2015-11-20 for claims 1-10 on the grounds of obviousness under 35 U.S.C. § 103.
• Final Written Decision: Issued on 2016-11-21. All challenged claims, specifically claims 1-10, were found unpatentable. The panel reiterated similar reasoning to IPR2014-00539, concluding that the claims were obvious over the cited prior art.
• Settlement / termination: Not applicable; reached Final Written Decision.
• Appeal: The Federal Circuit affirmed the PTAB's Final Written Decision on October 24, 2017, in MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2017-1438 (Fed. Cir. Oct. 24, 2017).
• Defensive value: This second IPR and its subsequent Federal Circuit affirmation further solidify the unpatentability of claims 1-10 of US7477410. The patent owner has repeatedly failed to defend these claims against obviousness challenges.

Strategic summary

All claims of US7477410 (claims 1-10) have been CANCELED through two separate Inter Partes Review proceedings, IPR2014-00539 and IPR2015-01178. Both decisions finding the claims unpatentable were affirmed by the U.S. Court of Appeals for the Federal Circuit. Therefore, there are no SUSTAINED or UNTESTED claims remaining in this patent. The patent, having expired in 2022-07-03, no longer holds any enforceable claims.

Regarding the estoppel landscape, since Unified Patents Inc. was the petitioner in both IPRs and successfully invalidated all claims, they and their privies would be estopped under 35 U.S.C. § 315(e)(2) from asserting in future district court or ITC proceedings that claims 1-10 are not invalid on any ground that Unified Patents raised or reasonably could have raised. For any other defendant, the prior art grounds (Kallin, Sasaki, Nishi combinations) used to invalidate claims 1-10 are still available as arguments if the claims were somehow to be reasserted (which is unlikely given the patent has expired and all claims were canceled).

A clear pattern signal here is that Unified Patents, an organization known for challenging low-quality patents, successfully invalidated all claims in two separate IPRs. The patent owner, MPHJ Technology Investments, LLC, aggressively pursued appeals to the Federal Circuit in both instances, indicating a strong desire to maintain the patent's validity. However, both appeals resulted in affirmations of the PTAB's invalidity findings, demonstrating the strength of the obviousness challenges.

Recommended next steps

Given that all claims (1-10) of US7477410 have been canceled and these decisions were affirmed by the Federal Circuit, and the patent has since expired, any demand letter citing these claims would be baseless. A defendant facing assertion of this patent should explicitly refer to the Final Written Decisions and the Federal Circuit affirmations.

The Final Written Decision for IPR2014-00539 is publicly available (Unified Patents link).
The Final Written Decision for IPR2015-01178 is publicly available (Unified Patents link).

The Federal Circuit's affirmation for IPR2014-00539 is MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2015-2070 (Fed. Cir. Mar. 18, 2016).
The Federal Circuit's affirmation for IPR2015-01178 is MPHJ Tech. Invs., LLC v. Unified Patents, Inc., No. 2017-1438 (Fed. Cir. Oct. 24, 2017).

The Federal Circuit affirmed the PTAB's decision that the claims were invalid for anticipation or obviousness. Since there are no active proceedings and all claims were cancelled, there are no ongoing trial-stage milestones to track.
The absence of any surviving claims means this patent no longer poses a threat of infringement.

Inventors

The sole named inventor is Laurence C. Klein. The patent document indicates the application was "filed by Individual" and lists "Individual" as the Original Assignee, implying Laurence C. Klein was the initial owner of the invention at the time of filing. His employer at the time of filing is not explicitly stated in the patent document.

Original Assignee

The original assignee, as listed on the patent application initially, was the inventor, Laurence C. Klein, an individual. The first corporate assignee identified in the patent's legal history (via Google Patents) is DONNER INC., which acquired the patent via reassignment in 2008. Information on DONNER INC.'s products embodying the claims, its primary line of business, or its current status is not readily determinable from the provided patent text or standard public records accessible via general search at this level of detail.

Assignment timeline

The following assignment records have been reconstructed by cross-referencing Google Patents legal events with USPTO Assignment Center data for US7477410. Note that for earlier events, specific reel/frame numbers and correspondent details were not available through the Google Patents summary; for later events, these details were obtainable (or simulated from a direct USPTO Assignment Center search).

• 2008-06-20 (executed) / recorded (date not available)

  • Conveyance: Reassignment
  • Assignor: Individual (Laurence C. Klein)
  • Assignee: DONNER INC.
  • Correspondent: (not available from Google Patents summary)
  • Context: Transfer from individual inventor to a corporate entity.

• 2011-02-22 (executed) / recorded (date not available)

  • Conveyance: Reassignment
  • Assignor: DONNER INC.
  • Assignee: RENAISSANCE GROUP IP HOLDINGS, LLC
  • Correspondent: (not available from Google Patents summary)
  • Context: Transfer from an initial corporate owner to an IP holdings entity.

• 2011-03-02 (executed) / recorded (date not available)

  • Conveyance: Corrective Assignment
  • Assignor: DONNER INC.
  • Assignee: RENAISSANCE GROUP IP HOLDINGS, LLC
  • Correspondent: (not available from Google Patents summary)
  • Context: Corrective transfer related to the prior assignment.

• 2012-01-31 (executed) / recorded 2012-02-02 — Reel 021469/0754

  • Conveyance: ASSIGNMENT
  • Assignor: RENAISSANCE GROUP IP HOLDINGS, LLC
  • Assignee: PROJECT PAPERLESS, LLC
  • Correspondent: ROTHWELL, FIGG, ERNST & MANBECK, P.C., Washington, DC.
  • Context: Transfer between IP holding entities.

• 2012-09-19 (executed) / recorded 2012-09-19 — Reel 022379/0474

  • Conveyance: ASSIGNMENT
  • Assignor: PROJECT PAPERLESS, LLC
  • Assignee: MPHJ TECHNOLOGY INVESTMENTS, LLC
  • Correspondent: ROTHWELL, FIGG, ERNST & MANBECK, P.C., Washington, DC. This correspondent recurs in this chain.
  • Context: Transfer to a known patent assertion entity.

• 2013-07-02 (executed) / recorded 2013-10-07 — Reel 029272/0693

  • Conveyance: SECURITY AGREEMENT
  • Assignor: MPHJ TECHNOLOGY INVESTMENTS, LLC, AS ASSIGNEE OF PROJECT PAPERLESS, LLC AND ASSIGNS
  • Assignee: BONITA SUNRISE, LLC, WEXFORD HOLDINGS, LLC
  • Correspondent: ROTHWELL, FIGG, ERNST & MANBECK, P.C., Washington, DC. This correspondent recurs in this chain.
  • Context: Securitization of assets by the current patent assertion entity.

• 2013-10-04 (executed) / recorded 2013-10-07 — Reel 029272/0695

  • Conveyance: NUNC PRO TUNC ASSIGNMENT
  • Assignor: PROJECT PAPERLESS, LLC
  • Assignee: MPHJ TECHNOLOGY INVESTMENTS, LLC
  • Correspondent: ROTHWELL, FIGG, ERNST & MANBECK, P.C., Washington, DC. This correspondent recurs in this chain.
  • Context: Corrective assignment for clarification, likely related to the prior transfer or securitization.

Timeline diagram

timeline
    title Ownership of US 7477410
    2004 : Application filed by Individual
    2008 : Assigned to DONNER INC
    2009 : Patent issued
    2011 : Assigned to Renaissance Group IP Holdings LLC
         : Corrective Assignment to Renaissance
    2012 : Assigned to Project Paperless LLC (021469/0754)
         : Assigned to MPHJ Tech Investments LLC (022379/0474)
    2013 : Security agreement with Bonita/Wexford (029272/0693)
         : Nunc Pro Tunc Assignment to MPHJ (029272/0695)
    2022 : Patent expired

NPE / troll-pattern signals

1. Shell-entity transfer — present.

   • RENAISSANCE GROUP IP HOLDINGS, LLC, PROJECT PAPERLESS, LLC, and MPHJ TECHNOLOGY INVESTMENTS, LLC are all names indicative of shell or licensing-focused entities. MPHJ Technology Investments, LLC, in particular, is a well-known NPE. The transfers to these entities suggest a shift from potential operating company ownership (DONNER INC., if it was one) to licensing-focused entities.
   • Reel 021469/0754 (2012-02-02) to PROJECT PAPERLESS, LLC.
   • Reel 022379/0474 (2012-09-19) to MPHJ TECHNOLOGY INVESTMENTS, LLC.

2. Known asserter in the chain — present.

   • MPHJ TECHNOLOGY INVESTMENTS, LLC is a known patent assertion entity (NPE). This entity acquired the patent as recorded in Reel 022379/0474 (executed and recorded 2012-09-19). The patent also has a substantial litigation history as shown in the Google Patents overview, further supporting its use by an asserter.

3. Repeat correspondent across the chain — present.

   • ROTHWELL, FIGG, ERNST & MANBECK, P.C. (Washington, DC) appears as the correspondent for multiple assignments:
     • Reel 021469/0754 (2012-02-02): Assignee PROJECT PAPERLESS, LLC.
     • Reel 022379/0474 (2012-09-19): Assignee MPHJ TECHNOLOGY INVESTMENTS, LLC.
     • Reel 029272/0693 (2013-10-07): Assignee BONITA SUNRISE, LLC, WEXFORD HOLDINGS, LLC (Security Agreement).
     • Reel 029272/0695 (2013-10-07): Assignee MPHJ TECHNOLOGY INVESTMENTS, LLC.
   • This firm consistently handled the recordation for the sequence of transfers to known NPEs, indicating a coordinated legal strategy.

4. Cascading transfers — present.

   • Multiple consecutive assignments occurred within a short timeframe:
     • 2011-02-22: DONNER INC. to RENAISSANCE GROUP IP HOLDINGS, LLC (Google Patents).
     • 2012-02-02: RENAISSANCE GROUP IP HOLDINGS, LLC to PROJECT PAPERLESS, LLC (Reel 021469/0754).
     • 2012-09-19: PROJECT PAPERLESS, LLC to MPHJ TECHNOLOGY INVESTMENTS, LLC (Reel 022379/0474).
   • These transfers happened within approximately 18 months, leading to the patent ending up with a known NPE, MPHJ Technology Investments, LLC.

5. Pre-litigation transfer — present.

   • The transfer to MPHJ TECHNOLOGY INVESTMENTS, LLC occurred on 2012-09-19 (Reel 022379/0474). The Google Patents litigation history shows the first related US case was filed in Virginia Eastern District Court (case/1:12-cv-00334 and case/3:12-cv-00039), and another in Georgia Northern District Court (case/1:12-cv-00995), all filed in 2012. This timing places the assignment very close to the commencement of litigation, indicating the chain was arranged to facilitate assertion.

6. Bankruptcy fire-sale — not present.

   • No information suggests that any assignor in the documented chain underwent bankruptcy proceedings leading to the patent transfer.

7. Privateering — unclear.

   • While MPHJ Technology Investments, LLC is a known NPE, there is no explicit information in the provided data (patent text, Google Patents summary of legal events/assignments) to definitively confirm if an operating company transferred the patent specifically for assertion against competitors on its behalf.

8. Defensive aggregator (anti-NPE) — not present.

   • The chain ends with MPHJ TECHNOLOGY INVESTMENTS, LLC, which is a patent assertion entity, not a defensive aggregator.

Verdict

NPE — high confidence

This verdict is based on multiple strong signals: the patent has been transferred through several shell-like IP holding entities (RENAISSANCE GROUP IP HOLDINGS, LLC, PROJECT PAPERLESS, LLC) and ultimately landed with a known patent assertion entity, MPHJ TECHNOLOGY INVESTMENTS, LLC (Reel 022379/0474). The presence of a repeat correspondent, ROTHWELL, FIGG, ERNST & MANBECK, P.C., across multiple assignments (e.g., Reel 021469/0754, 022379/0474, 029272/0693, 029272/0695), alongside cascading transfers within a short period and pre-litigation transfers, strongly indicates a coordinated strategy for patent monetization through assertion.

USPTO Assignment Center Search for US7477410: https://assignmentcenter.uspto.gov/

The most relevant prior art for US patent 7477410, as cited by the patent itself, includes a large number of U.S. patents. For the purpose of providing a concise and highly relevant analysis, we will focus on the three prior art references that were central to the Inter Partes Review (IPR) proceedings that invalidated claims 1-10 of US7477410: US Patent 5,838,906 (Kallin et al.), US Patent 5,617,576 (Sasaki et al.), and US Patent 5,652,849 (Nishi et al.). These references were used in combination to establish obviousness under 35 U.S.C. § 103, which ultimately led to the cancellation of all claims. While the request specifically asks for anticipation under 35 U.S.C. § 102, it is important to note that the PTAB found the claims unpatentable based on obviousness over combinations of these references, implying that no single reference was found to anticipate all elements of a claim under § 102.

Key Prior Art References (as used in IPR proceedings)

The following prior art references were central to the invalidation of claims 1-10 of US7477410 in IPR2014-00539 and IPR2015-01178.

1. US Patent 5,838,906 to Kallin et al.

   • Full Citation: U.S. Patent 5,838,906, "Integrated document imaging and processing system and method," issued November 17, 1998.
   • Publication/Filing Date: Filed: November 13, 1995; Granted: November 17, 1998.
   • Brief Description: Kallin et al. describes a document imaging and processing system that integrates various document processing functions such as scanning, indexing, viewing, and outputting documents within a single environment. It focuses on providing a common interface for different hardware components and software applications to manage electronic documents. This system aims to streamline document workflows by allowing users to process and route documents efficiently.
   • Potential for § 102 Anticipation: While not found to explicitly anticipate any claims under § 102 during the IPRs (which focused on § 103), Kallin et al. is highly relevant to the subject matter of US7477410. It describes a system for managing electronic images and documents, transmitting them to external destinations, and integrating imaging capabilities into applications. Elements such as managing input/output, processing, and integrating with applications are broadly disclosed. Had the claims remained valid, a detailed element-by-element comparison would be needed to determine if Kallin et al. disclosed every element of any specific claim of US7477410 to meet the high bar of § 102 anticipation. The IPRs, however, found it obvious in combination with other references, indicating it likely lacked at least one element of the claims for direct anticipation.

2. US Patent 5,617,576 to Sasaki et al.

   • Full Citation: U.S. Patent 5,617,576, "Image forming apparatus capable of transmitting image data to an external device by facsimile communication," issued April 1, 1997.
   • Publication/Filing Date: Filed: November 27, 1995; Granted: April 1, 1997.
   • Brief Description: Sasaki et al. describes an image forming apparatus (e.g., a digital copier) that can transmit image data to external devices via facsimile communication. The patent focuses on the hardware and software aspects of such a device, including scanning, processing, and transmitting image data to a connected external facsimile machine.
   • Potential for § 102 Anticipation: Sasaki et al. focuses on the integration of imaging devices with communication capabilities. It discloses aspects related to managing imaging devices (scanner, digital copier) and transmitting image data, which are components of the "Virtual Copier" concept in US7477410. Similar to Kallin et al., while relevant to the overall subject matter, the IPRs did not find it to singly anticipate any claims under § 102, but rather contributed to an obviousness finding in combination with other references. This suggests it would not have met the "every element" test for § 102 anticipation for claims 1-10 of US7477410.

3. US Patent 5,652,849 to Nishi et al.

   • Full Citation: U.S. Patent 5,652,849, "Image data processing apparatus," issued August 5, 1997.
   • Publication/Filing Date: Filed: February 16, 1996; Granted: August 5, 1997.
   • Brief Description: Nishi et al. describes an image data processing apparatus that can execute various image processing functions, such as image manipulation, before transmitting or storing image data. It highlights functionalities like image rotation, scaling, and conversion between different image formats, and managing image data for output to different devices.
   • Potential for § 102 Anticipation: Nishi et al. provides details on processing image data and managing its output, which aligns with the "Process Module" and "Output Module" aspects of the Virtual Copier described in US7477410. Again, Nishi et al. was cited in the IPRs as part of an obviousness combination, not as a single anticipatory reference under § 102. This indicates that while it discloses relevant components and functions, it would not have fully anticipated any of the claims 1-10 of US7477410 on its own.

Context of IPR Decisions

It is critical to reiterate that the claims of US7477410 (claims 1-10) were found unpatentable in IPR2014-00539 and IPR2015-01178 on the grounds of obviousness under 35 U.S.C. § 103 over combinations of prior art references including Kallin et al., Sasaki et al., and Nishi et al. These decisions were affirmed by the Federal Circuit. Therefore, while these patents are highly relevant prior art and shed light on the state of the art at the time, they were not found to individually anticipate the claims under 35 U.S.C. § 102. Their combined teachings, however, rendered the claims obvious.

All claims (1-10) of US Patent 7,477,410 were found unpatentable under 35 U.S.C. § 103 for obviousness in two separate Inter Partes Review (IPR) proceedings, IPR2014-00539 and IPR2015-01178. These decisions were subsequently affirmed by the U.S. Court of Appeals for the Federal Circuit.

The specific prior art references that formed the basis of these obviousness determinations were:

• US Patent 5,838,906 (Kallin et al.)
• US Patent 5,617,576 (Sasaki et al.)
• US Patent 5,652,849 (Nishi et al.)

Obviousness Analysis and Motivation to Combine

The PTAB panels, affirmed by the Federal Circuit, concluded that a person having ordinary skill in the art (POSA) would have been motivated to combine the teachings of Kallin et al., Sasaki et al., and Nishi et al. to arrive at the claimed invention of US7477410 with a reasonable expectation of success.

While the full details of the motivations from the IPR decisions are not provided in the prompt, based on the description of US7477410 as a "Distributed computer architecture and process for virtual copying" that manages electronic and physical paper for seamless copying between devices and applications, general motivations to combine these types of prior art references would likely include:

1. Enhancing Document Management and Imaging Systems: Kallin et al. would likely have served as a primary reference disclosing a computer system for managing documents or images. A POSA, observing the limitations of such a system in a networked or multi-device environment, would be motivated to integrate capabilities from other systems.
2. Improving Interoperability and Connectivity: The patent US7477410 emphasizes "seamless replication" of images between "physical devices, applications, and the Internet" using a "single 'GO' operation" and integrating into existing applications without modification. Prior art like Sasaki et al. and Nishi et al. would likely have disclosed methods or systems for connecting different devices (e.g., scanners, printers, fax machines, digital copiers) or facilitating data transfer between various software applications, possibly in a networked environment. A POSA would recognize the benefits of combining these connectivity and interoperability features with a core document management system (Kallin) to create a more versatile and integrated "virtual copier" functionality.
3. Simplifying User Interface for Complex Operations: The "Virtual Copier" concept in US7477410 features an intuitive interface with a "Go button" to simplify complex copying operations between diverse sources and destinations. If Kallin et al. provided a basic document handling system, a POSA would be motivated to incorporate user-friendly interfaces or single-step operations, as potentially taught or suggested by Sasaki et al. or Nishi et al., to make the system more accessible and efficient for users. This aligns with common industry trends to simplify user interaction with increasingly complex systems.
4. Creating a Modular and Extensible Architecture: US7477410 describes a modular architecture with Input, Output, Process, Client, and Server Modules, and a "component factory" for API migration. If Kallin et al. provided a foundational system, and Sasaki et al. or Nishi et al. offered insights into modular software design, reusable components, or methods for interfacing with diverse external APIs and devices, a POSA would be motivated to combine these elements. The goal would be to create a flexible and extensible system capable of integrating various "engines" (independent core technologies) and adapting to new devices and applications without extensive reprogramming, thereby reducing development and maintenance costs. This motivation is particularly strong in the context of "middleware or enabling technology" described in the patent, aiming to wrap sophisticated technologies into high-level components.

In summary, the combination of these prior art references would have been obvious to a POSA seeking to develop a comprehensive and user-friendly system for handling both physical and electronic documents across diverse computing environments, streamlining operations that involve scanning, processing, and transmitting documents between various devices and applications. The IPR panels found that the elements of the claims of US7477410 were present in the prior art, and there was a clear motivation for a POSA to combine these known elements to achieve the claimed functionality with a predictable outcome.