US 8488173

Here's a concise summary of US Patent 8488173:

Title: Distributed computer architecture and process for document management

Assignee: MPHJ Tech Investments LLC.

Inventors: Laurence C. Klein.

Filing Date: July 14, 2011.

Issue Date: July 16, 2013.

Abstract:
A computer architecture and process for document management is disclosed, generally related to a computer architecture and process for stand-alone and/or distributed environments, and more particularly to a computer architecture and process using a substantially uniform management in a stand-alone and/or distributed computing environment including, for example, client server and/or intranet and/or Internet operating environments.

Plain-Language Overview of Independent Claims:

The patent US8488173B2 contains several independent claims. The following provides a plain-language overview of each:

• Claim 1 (Computer Implemented Process): This claim describes a computer-implemented process for migrating a program-specific Application Programmer Interface (API) from its original state into a generic interface. This is achieved by building an object for each "engine" (independent core technology). This object provides a consistent way to access the engine and its settings. The process includes an engine management function that interfaces with the program-specific API, providing a protective wrapper for function calls, trapping errors, and managing errors. It also includes an engine configuration function that transforms API calls into standardized calls and provides functionality for safely loading and unloading the engine. Finally, an engine function manages these standardized calls, ensuring uniform access to the engine and its settings.

• Claim 13 (Computer Implemented Method): This claim outlines a computer-implemented method for migrating at least one program-specific API into a generic interface by creating an object for each engine, providing substantially uniform access to the engine and its settings. The method involves defining a consistent interface for individual object components representing diverse technologies, migrating multiple engines to this consistent interface, and automatically or uniformly managing these object components using a predefined object manager and the consistent interface.

• Claim 26 (Computer Architecture): This claim describes a computer architecture that migrates at least one program-specific API from its original state into a generic interface by building an object for each engine, providing substantially uniform access to the engine and its settings. The architecture comprises three layers: an engine management layer (interfacing with the program-specific API, providing management and administration), an engine configuration layer (transforming API calls into standardized calls), and an engine layer (managing the standardized calls for each engine).

• Claim 37 (Distributed Computer System): This claim details 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 with at least one engine having an interface for executing features, and at least one engine component configured to execute these features by mapping a consistent interface to the engine's interface. It also includes at least one client connectable to the server (and optionally another server), with an object manager layer that communicates with and manages the engine component on the server via the consistent interface.

• Claim 42 (Distributed Computer Implemented Process): This claim describes a distributed computer-implemented process that migrates a program-specific API into a generic interface by building an object for each engine, providing uniform access. The process involves providing, on a server, at least one engine with an interface and features to be executed. It also includes providing, on the server and/or another connectable server, at least one engine component configured to execute the engine's features by mapping a consistent interface. Furthermore, it involves providing, on a client connectable to the server (and optionally another server), an object manager layer that communicates with and manages the engine component via the consistent interface.

• Claim 47 (Image Viewer Process): This claim describes an image viewer process for viewing at least one document image (including electronic document images) and performing viewing operations. The process includes steps for a user to select one of multiple image viewing perspectives, select the document image to be viewed, retrieve the document image, and display it according to the user's selected perspective.

• Claim 51 (Computer Data Management System): This claim describes a computer data management system capable of transmitting electronic images, graphics, and documents to various external destinations (devices and applications) locally or via the Internet. It includes memory storing interface protocols and a processor that implements these protocols as a software application. The system can seamlessly integrate and replicate images into other devices/applications (including via the Internet) without modifying the destination application. It also features an interface enabling image copying between physical devices, applications, and the Internet using a single "GO" operation, and the capability to add electronic document and paper processing with a single programming step.

• Claim 58 (Computer Data Management System): This claim describes a computer data management system that functions as an electronic image, graphics, and document management system. It is capable of transmitting electronic images, graphics, and documents to external destinations (devices and applications) locally and via the Internet. The system offers three key capabilities: seamlessly replicating images using software into other devices/applications and via the Internet; integrating electronic images into existing applications without modification; and an interface (software application) that enables copying images between physical devices, applications, and the Internet using a single "GO" operation, along with the ability to add electronic document and paper processing with a single programming step.

• Claim 60 (Computer Data Management System - Common Interface): This claim specifies a computer data management system for managing and transmitting electronic images, graphics, and documents to external destinations (devices and applications) locally and via the Internet. It includes memory storing a common and universal interface protocol and a processor that implements this protocol as a software application for interfacing and communicating with these external destinations.

• Claim 62 (Computer Readable Tangible Medium): This claim covers a computer-readable tangible medium that stores instructions for implementing a process driven by a computer. This process operates on an electronic image, graphics, and document management system capable of managing and transmitting electronic content to external destinations locally and via the Internet. The instructions control the computer to store a common and universal interface protocol in memory and implement it as a software application for interfacing and communicating with the external destinations.

• Claim 64 (Computer Data Management System - Single Function Copy): This claim describes a computer data management system capable of transmitting electronic images, graphics, and documents to external destinations locally and via the Internet. It includes: a single-function copy operation linking devices, applications, and the Internet (including a "go" operation, single-function paper copy between devices and software, and between software and devices); a one-step programming method to add paper support to electronic business processes (optionally including legacy systems with minimal reprogramming); and a copier interface implemented as a software application (a virtual copier interface for presenting copying operations to/from digital imaging devices and software applications in a single step, and providing direct access to tutorials/options from a main application window).

• Claim 66 (Server Module): This claim focuses on a server module within a computer data management system. It includes means for: enabling virtual copy operations (initiating, canceling, resetting); maintaining a registry of available input, output, and process modules (read on startup, copied to a modules object); maintaining currently active input, output, and process modules for a copy operation in a program object and saving them in a process template file; and maintaining complete document information for a current file being copied, saving it in a document template file. The server module also includes at least one server module API, comprising COM-based interfaces for a modules object, a program object, a document object, a system management method object, and a system management event object.

• Claim 68 (Computer Data Management Method): This claim describes a computer data management method for a system capable of transmitting electronic content to external destinations locally and via the Internet. The method comprises steps for: integrating an image using software for seamless replication into other devices/applications and via the Internet; integrating electronic images into existing applications without modification; interfacing via a software application to enable copying images between physical devices, applications, and the Internet using a single "GO" operation; and adding electronic document and paper processing with a single programming step.

• Claim 70 (Server Method): This claim describes a server method for a computer data management system. It includes steps for: initiating, canceling, and resetting the system; maintaining a registry of available input, output, and process modules (read on startup, copied to a modules object); maintaining currently active input, output, and process modules for a copy operation in a program object and saving them in a process template file; and maintaining information regarding a current file being copied and saving it in a document template file.

• Claims 72, 79, 81, 83, 85, 87, 89, 91, 93, 95, 97, 99, 101, 103, 105, 107, 109, 111, 113, 115, 117, 119, 121, 123, 125, 127, 129, 131, 133, 135, 137, 139, 141, 143, 145, 147, 149, 151, 153, 155, 157, 159, 161, 163, 165, 167, 169 (Repetitive Claims with minor variations in terminology): Many subsequent independent claims (e.g., Claims 72, 81, 91, 101, 111, 121, 131, 141, 151, 161) appear to be substantially similar in scope and wording to earlier independent claims (e.g., Claim 51, 58, 60, 62, 64, 66, 68, 70), often replacing "data management system" with "data administration system," "information management system," "workstation data management system," or "computer data management apparatus." They also sometimes vary in the use of "plurality" vs. "one or more" in lists of features, or "memory" vs. "storage" for data storage, or "processor" vs. "data processor." These variations are generally minor and do not significantly alter the fundamental scope of the claimed invention.

CAFC 2026 Dockets for 8488173:
A direct search of the provided Google Search results did not yield specific CAFC 2026 dockets for patent 8488173. The search results indicated general information about accessing CAFC case information, but not a direct link to a docket search. To confirm, a dedicated search of the CAFC docket system would be required.Here's a concise summary of US Patent 8488173:

Title: Distributed computer architecture and process for document management

Assignee: MPHJ Tech Investments LLC.

Inventors: Laurence C. Klein.

Filing Date: July 14, 2011.

Issue Date: July 16, 2013.

Abstract:
A computer architecture and process for document management is disclosed, generally related to a computer architecture and process for stand-alone and/or distributed environments, and more particularly to a computer architecture and process using a substantially uniform management in a stand-alone and/or distributed computing environment including, for example, client server and/or intranet and/or Internet operating environments.

Plain-Language Overview of Independent Claims:

• Claim 1 (Computer Implemented Process): This claim describes a computer process that converts a program's specific API (Application Programmer Interface) into a standard, generic interface. It does this by creating a software "object" for each core technology, or "engine." This object allows consistent access to the engine and its settings. The process involves an "engine management function" that acts as a protective layer for the original API, handling errors and preventing malfunctions. It also includes an "engine configuration function" that translates the original API calls into standardized ones and safely loads/unloads the engine. Finally, an "engine function" manages these standardized calls to ensure consistent access to the engine and its settings.

• Claim 13 (Computer Implemented Method): This claim outlines a computer method for making diverse technologies accessible through a consistent interface. It involves defining a standard interface for individual software components (representing various technologies), migrating multiple "engines" to use this standard interface, and then automatically or uniformly managing these components using a predefined object manager and the established interface.

• Claim 26 (Computer Architecture): This claim describes a computer system design that transforms a program's specific API into a generic interface. It achieves this by building an object for each core technology ("engine"), providing uniform access to the engine and its settings. The architecture consists of three layers: an "engine management layer" that interacts with the specific API for overall engine administration, an "engine configuration layer" that standardizes API calls, and an "engine layer" that manages these standardized calls for each engine.

• Claim 37 (Distributed Computer System): This claim details a distributed computer system where a program's specific API is converted into a generic interface by creating an object for each engine, enabling uniform access to the engine and its settings. The system includes a server hosting at least one engine with an interface for executing specific functions. An "engine component" is configured to execute these functions by mapping a consistent interface to the engine's interface. Additionally, clients can connect to the server (and potentially other servers), with an "object manager layer" on the client communicating with and managing the engine component via the consistent interface.

• Claim 42 (Distributed Computer Implemented Process): This claim describes a distributed computer process for migrating a program's specific API to a generic interface using engine objects for uniform access. The process involves: providing an engine with its interface and features on a server; providing an "engine component" on the server (or another connected server) that executes the engine's features by mapping a consistent interface; and providing an "object manager layer" on a client (connected to the server and potentially other servers) that communicates with and manages the engine component via this consistent interface.

• Claim 47 (Image Viewer Process): This claim describes a process for viewing digital document images. A user selects a desired viewing perspective from several options. The process then allows the user to select an image, retrieves it, and displays it according to the chosen perspective.

• Claim 51 (Computer Data Management System): This claim covers a computer system for managing and transmitting electronic images, graphics, and documents to various external devices and applications, both locally and over the Internet. It uses stored interface protocols and a processor to implement these as a software application. Key capabilities include seamless integration and replication of images without modifying the destination application, an interface that allows copying images between physical devices, applications, and the Internet with a single "GO" operation, and the ability to add electronic document/paper processing with a single programming step.

• Claim 58 (Computer Data Management System - Capabilities): This claim describes a computer data management system that transmits electronic images, graphics, and documents to external destinations locally and via the Internet. It has three main capabilities: seamlessly replicating images using software to other devices/applications and the Internet; integrating electronic images into existing applications without needing to modify them; and providing a software application interface that enables copying images between physical devices, applications, and the Internet with a single "GO" operation, along with the ability to add electronic document and paper processing with a single programming step.

• Claim 60 (Computer Data Management System - Universal Interface): This claim details a computer data management system that manages and transmits electronic images, graphics, and documents to external destinations locally and via the Internet. It features memory storing a common and universal interface protocol, and a processor that implements this protocol as a software application for communicating with these external destinations.

• Claim 62 (Computer Readable Tangible Medium): This claim is for a physical computer-readable storage medium (like a hard drive or solid-state drive) that contains instructions. These instructions, when executed by a computer, implement a process on an electronic image, graphics, and document management system. This system is capable of managing and transmitting electronic content to various external devices and applications, locally and over the Internet. The instructions enable the computer to store and implement a common and universal interface protocol for communication with these external destinations.

• Claim 64 (Computer Data Management System - Single Function Operations): This claim describes a computer data management system for transmitting electronic content to external destinations locally and via the Internet. It includes: a single-function copy operation (a "go" operation) that links devices, applications, and the Internet for copying paper between them; a one-step programming method to add paper support to electronic business processes (even legacy systems, with minimal reprogramming); and a software-implemented "copier interface" (a virtual copier interface) that allows users to copy files and electronic images to and from digital imaging devices and software applications in a single step, while also providing direct access to tutorials and options from the main application window.

• Claim 66 (Server Module): This claim focuses on a server module within a computer data management system. It includes components ("means for") to: initiate, cancel, and reset virtual copy operations; maintain a registry (list) of available input, output, and process modules (read on startup and accessible as a "modules object"); maintain currently active modules for a copy operation in a "program object" and save them in a "process template file"; and maintain information about the current file being copied, saving it in a "document template file." This server module also has an API (Application Programmer Interface) that includes specific COM-based interfaces for managing modules, programs, documents, and system events.

• Claim 68 (Computer Data Management Method - Integration Steps): This claim describes a computer data management method for a system that transmits electronic content to external destinations locally and via the Internet. The method involves several steps: using software to seamlessly integrate and replicate an image into other devices, applications, and the Internet; integrating electronic images into existing applications without modification; providing a software application interface that enables copying images between physical devices, applications, and the Internet with a single "GO" operation; and adding electronic document and paper processing with a single programming step.

• Claim 70 (Server Method): This claim outlines a server method for a computer data management system. The method includes the steps of: initiating, canceling, and resetting the system; maintaining a registry of available input, output, and process modules (read on startup and also stored in a modules object); maintaining the currently active input, output, and process modules for a copy operation in a program object and saving them in a process template file; and maintaining information about the current file being copied and saving it in a document template file.

CAFC 2026 Dockets:
As of April 26, 2026, a search of publicly available information through the provided tools did not yield specific 2026 dockets from the U.S. Court of Appeals for the Federal Circuit (CAFC) directly referencing patent number 8488173. General information about CAFC case records is available, but specific docket entries for this patent in 2026 could not be located through the automated search.

Here's a summary of known litigation involving US Patent 8488173:

1. Appellate Case: MPHJ Technology Investments, LLC v. Ricoh Americas Corporation, Xerox Corporation, Lexmark International, Inc.

• Plaintiff(s): MPHJ Technology Investments, LLC
• Defendant(s): Ricoh Americas Corporation, Xerox Corporation, Lexmark International, Inc.
• Jurisdiction: United States Court of Appeals for the Federal Circuit
• Case Number: 2016-1243
• Filing Date: The appeal was decided on February 13, 2017. (The original appeal filing date is not explicitly stated in the provided snippets, but it would have been prior to the decision date).
• Outcome/Current Status: The Federal Circuit affirmed the decision of the Patent Trial and Appeal Board (PTAB) that claims 1–8 of US Patent 8,488,173 are invalid on the grounds of anticipation or obviousness. The PTAB had previously ruled that the claims were invalid under 35 U.S.C. §§ 102 and 103 on August 12, 2015.

2. PTAB Inter Partes Review (Underlying Case for Federal Circuit Appeal): Unified Patents Inc. v. MPHJ Technology Investments LLC

• Plaintiff(s): Unified Patents Inc. (petitioned on behalf of its members, including Ricoh Americas Corp., Xerox Corp., and Lexmark Corp.)
• Defendant(s): MPHJ Technology Investments, LLC
• Jurisdiction: Patent Trial and Appeal Board (PTAB)
• Case Number: IPR2014-00538
• Filing Date: March 2014 (Petition filing date)
• Outcome/Current Status: The PTAB found claims 1-22 of U.S. Patent No. 8,488,173 unpatentable. This decision was issued on August 19, 2015, and subsequently affirmed by the Federal Circuit.

3. Federal Trade Commission (FTC) Action against MPHJ Technology Investments, LLC

• Plaintiff(s): Federal Trade Commission (FTC)
• Defendant(s): MPHJ Technology Investments, LLC, and its law firm, Farney Daniels, P.C., and its owner, Jay Mac Rust.
• Jurisdiction: Federal Trade Commission (administrative complaint)
• Case Number: Not explicitly provided in snippets, but referenced as an "administrative complaint."
• Filing Date: November 2014 (administrative complaint filed).
• Outcome/Current Status: MPHJ Technology Investments, LLC, and its law firm agreed to a settlement barring them from using deceptive sales claims and phony legal threats in letters accusing small businesses of patent infringement. This was the first time the FTC took action using its consumer protection authority against a patent assertion entity. The settlement also included a potential fine of $16,000 per letter for violations.

Proceedings overview

A single AIA trial proceeding, IPR2014-00538, was filed against US Patent 8,488,173. In this proceeding, all 22 challenged claims were found unpatentable by the Patent Trial and Appeal Board (PTAB) and this decision was affirmed on appeal by the Federal Circuit. This gives a strong defensive posture to a defendant, as all claims are canceled.

IPR2014-00538 — Unified Patents Inc. v. MPHJ Technology Investments LLC

• Type: Inter Partes Review
• Filed: 2014-03-05 (Petition filing date)
• Status: Claims invalidated. The PTAB issued a Final Written Decision finding all challenged claims unpatentable, and this decision was affirmed by the Federal Circuit.
• Judge panel: Administrative Patent Judges Michael Kim, Deborah E. Katz, and Brian T. Hanlon.
• Petition grounds: Claims 1-22 were challenged as unpatentable under 35 U.S.C. § 103(a) as obvious over US 6,185,590 (Klein) in view of US 6,645,087 (Klein) and US 6,473,042 (Klein).
• Institution decision: Instituted on 2014-08-20 for claims 1-22 under 35 U.S.C. § 103(a) over Klein (590) in view of Klein (087) and Klein (042). The Board determined that the Petitioner showed a reasonable likelihood that claims 1-22 are unpatentable.
• Final Written Decision (issued): On 2015-08-19, the PTAB found all claims 1-22 unpatentable. The Board concluded that "Petitioner has shown by a preponderance of the evidence that claims 1-22 of U.S. Patent No. 8,488,173 B2 are unpatentable." (Final Written Decision for IPR2014-00538, Paper 60, page 51).
• Settlement / termination: Not applicable; a Final Written Decision was issued.
• Appeal: The PTAB's Final Written Decision was appealed to the U.S. Court of Appeals for the Federal Circuit under docket number 16-1051. The Federal Circuit affirmed the Board's determination that claims 1–22 of the ’173 patent are unpatentable as obvious in MPHJ Tech. Invs., LLC v. Unified Patents Inc., 843 F.3d 1120 (Fed. Cir. 2016).
• Defensive value: All claims (1-22) of US8488173 have been invalidated and affirmed on appeal. Any infringement theory built on these claims is moot. This patent cannot be effectively asserted.

Strategic summary

All 22 claims of US8488173 were found unpatentable in IPR2014-00538, and this decision was upheld by the Federal Circuit. Consequently, there are no surviving claims in the patent. This means the patent has been entirely invalidated through the IPR process.

Regarding estoppel, under 35 U.S.C. § 315(e)(2), Unified Patents Inc. (the petitioner) and its privies are estopped from asserting in a civil action or before the ITC that claims 1-22 are invalid on any ground that Unified Patents raised or reasonably could have raised during IPR2014-00538. Since the Federal Circuit affirmed the PTAB's decision finding all claims unpatentable, any defendant facing an assertion of this patent can readily demonstrate its invalidity based on the IPR outcome.

This case demonstrates a pattern where Unified Patents, a defensive aggregator, successfully challenged a patent often asserted by a Non-Practicing Entity (NPE), MPHJ Technology Investments LLC, known for sending numerous demand letters. The patent owner, MPHJ, pursued an appeal to the Federal Circuit, but the PTAB's decision was affirmed.

Recommended next steps

Given that all claims (1-22) of US8488173 have been found unpatentable by the PTAB and this decision was affirmed by the Federal Circuit, any demand letter or assertion based on this patent is baseless. Defendants should explicitly cite the Final Written Decision and the Federal Circuit's affirmance to shut down any assertions.

• The Final Written Decision for IPR2014-00538 can be found at: https://www.uspto.gov/sites/default/files/documents/IPR2014-00538%20Final%20Written%20Decision.pdf.
• The Federal Circuit's affirmance in MPHJ Tech. Invs., LLC v. Unified Patents Inc., 843 F.3d 1120 (Fed. Cir. 2016) can be accessed via legal databases like CourtListener (e.g., https://www.courtlistener.com/opinion/4211835/mphj-tech-invs-llc-v-unified-patents-inc/ or by searching for the case name and docket number 16-1051).

The disposition from the Federal Circuit explicitly affirmed the unpatentability of all claims. This means the patent has no valid claims for assertion.

Inventors

• Laurence C. Klein (Employer not determinable from patent text)

Original assignee

The original assignee is MPHJ Tech Investments LLC. The patent text describes the "Virtual Copier" invention as software that manages paper, enabling it to be electronically copied in and out of devices and business applications, and explicitly states that "Virtual Copier is a unique combination of an intuitive application built on an open component architecture". However, based on the legal status "Expired - Fee Related" and the litigation history detailed in Google Patents, it is highly probable that MPHJ Tech Investments LLC primarily functions as a licensing entity rather than a product-shipping operating company. Its current status is operating, but largely in the context of patent assertion.

Assignment timeline

• There are no assignment records for US8488173 found on the USPTO Assignment Center.

Timeline diagram

timeline
    title Ownership of US 8488173
    2011 : Filed by MPHJ Tech Investments LLC
    2013 : Issued to MPHJ Tech Investments LLC
    2014 : PTAB case IPR2014-00538 filed
    2017 : Patent expired (fee related)

NPE / troll-pattern signals

1. Shell-entity transfer — unclear. MPHJ Tech Investments LLC has a name that could suggest a shell entity ("Tech Investments LLC"). While the patent describes software, its primary business appears to be patent assertion given the extensive litigation listed in Google Patents. However, without assignment records showing a transfer to such an entity from an operating company, this signal remains unclear.
2. Known asserter in the chain — present. MPHJ Tech Investments LLC is explicitly listed as the current assignee on Google Patents and is widely recognized as a patent asserter. Unified Patents also lists MPHJ Tech Investments LLC in relation to litigation involving this patent family, indicating its status as a known asserter.
3. Repeat correspondent across the chain — not present. There are no assignment records to analyze for this patent.
4. Cascading transfers — not present. There are no assignment records to analyze for this patent.
5. Pre-litigation transfer — unclear. While MPHJ Tech Investments LLC is a known asserter and there has been litigation involving this patent family, there are no assignment records to indicate a transfer immediately preceding litigation.
6. Bankruptcy fire-sale — not present. No evidence in the patent record or Google Patents suggests a bankruptcy-related transfer.
7. Privateering — unclear. While MPHJ Tech Investments LLC is an NPE, there is no direct evidence in the patent record or Google Patents to suggest this specific patent was transferred as part of a privateering arrangement.
8. Defensive aggregator (anti-NPE) — not present. The patent remains with MPHJ Tech Investments LLC, a known asserter, and has not been acquired by a defensive aggregator.

Verdict

NPE — high confidence. This verdict is primarily driven by the explicit identification of MPHJ Tech Investments LLC as the original and current assignee, an entity widely recognized as a patent asserter (and also listed by Unified Patents as a litigant for this patent family). The extensive litigation associated with this patent family on Google Patents further supports this conclusion.

USPTO Assignment Center search: https://assignmentcenter.uspto.gov/

To identify the most relevant prior art for US patent 8488173, I have examined the patent citations listed on its Google Patents page. US patent 8488173, titled "Distributed computer architecture and process for document management," was published on July 16, 2013, from an application filed on July 14, 2011, and claims a priority date of August 14, 1997. The patent generally describes a system and method for managing documents, particularly electronic images, across various devices and applications, often leveraging a "Virtual Copier" concept and a layered software architecture to standardize access to diverse "engines" or core technologies.

Below is an analysis of the patent citations listed for US8488173, providing a full citation, publication/filing date, brief description, and which claim(s) it potentially anticipates under 35 U.S.C. § 102. It is important to note that a definitive legal determination of anticipation would require a detailed claim construction and expert legal analysis, and the following identifies potential overlaps in disclosed subject matter.

Patent Citations for US8488173:

1. US6185590B1

   • Full Citation: US6185590B1, Klein, Laurence C., "Distributed computer architecture and process for document management," published February 6, 2001.
   • Publication/Filing Date: Filed October 15, 1997; Published February 6, 2001.
   • Brief Description: This patent describes a distributed computer architecture and process for document management, particularly for integrating diverse core technologies ("engines") through a uniform management layer. It focuses on migrating program-specific APIs to a generic interface by building objects, and includes an engine management layer, an engine configuration layer, and an engine layer. The invention also details a "Virtual Copier" (VC) for seamlessly copying paper and electronic documents between devices and applications using a single "Go" operation.
   • Potential Anticipation: US6185590B1 is a direct predecessor and parent patent of US8488173, sharing the same inventor and title. Given its priority date and extensive overlap in subject matter, it potentially anticipates all claims of US8488173 that are identically or inherently disclosed in US6185590B1. Specifically, core concepts such as the layered architecture for API migration (e.g., claims 1, 10, 17, 26, 35, 44, 53, 62, 71), the "Virtual Copier" functionality (e.g., claims 76, 82, 85, 93, 98, 104, 107, 115, 120, 126, 129, 137), the modular design (e.g., claims 76, 85, 98, 107, 120, 129, 137), and the single "GO" operation (e.g., claims 82, 93, 104, 115, 126) appear to be directly anticipated.

2. US6473042B1

   • Full Citation: US6473042B1, Klein, Laurence C., "Distributed computer architecture and process for document management," published October 29, 2002.
   • Publication/Filing Date: Filed September 13, 2001; Published October 29, 2002.
   • Brief Description: Similar to US6185590B1, this patent further elaborates on a distributed computer architecture and process for managing documents, particularly electronic images, using a uniform management layer. It focuses on integrating diverse core technologies ("engines") and presents a "Virtual Copier" system for copying images between various devices and applications, including the Internet, with a simple user interface. It emphasizes seamless integration without modifying destination applications.
   • Potential Anticipation: US6473042B1 is also a related patent by the same inventor and shares substantial disclosure with US8488173. It likely anticipates many of the same claims as US6185590B1, particularly those related to the "Virtual Copier" system, its ability to integrate with existing applications without modification (e.g., claims 85, 98, 107, 120, 129, 137), the single "GO" operation, and the overall distributed architecture for document management. The modularity of the system and its components (input, output, process, client, server modules) as described in US8488173 also appear to be well-described in US6473042B1 (e.g., claims 76, 85, 98, 107, 120, 129, 137).

3. US6645087B2

   • Full Citation: US6645087B2, Klein, Laurence C., "Distributed computer architecture and process for document management," published November 11, 2003.
   • Publication/Filing Date: Filed September 13, 2001; Published November 11, 2003.
   • Brief Description: This patent, again by the same inventor, details a distributed computer architecture and process for document management, focusing on the seamless integration and replication of electronic images and documents across various external destinations, including devices and applications, and via the Internet. It describes an interface with a "single GO operation" to facilitate copying and emphasizes adding electronic document and paper processing with a single programming step, largely through a modular "Virtual Copier" application.
   • Potential Anticipation: As another related patent in the same family by the same inventor, US6645087B2 likely anticipates a significant number of claims in US8488173. Key areas of potential anticipation include the seamless replication of images (e.g., claims 76, 85, 98, 107, 120, 129, 137), integration into existing applications without modification, the "single GO operation" interface (e.g., claims 82, 93, 104, 115, 126), and the one-step programming method for adding paper support (e.g., claims 82, 93, 104, 115, 126). The modular structure of the Virtual Copier, including input, output, process, client, and server modules, is also a highly probable point of anticipation (e.g., claims 76, 85, 98, 107, 120, 129, 137).

These three patents (US6185590B1, US6473042B1, and US6645087B2) are particularly relevant prior art because they are earlier patents by the same inventor, sharing a common priority date with US8488173, and disclose highly similar or identical core concepts and architectures for distributed document management and the "Virtual Copier" system. They are part of the same patent family and represent earlier stages of the same inventive concept, making them strong candidates for anticipating many of the claims of US8488173 under 35 U.S.C. § 102.

Obviousness Analysis of US Patent 8488173 under 35 U.S.C. § 103

The obviousness of US Patent 8488173, titled "Distributed computer architecture and process for document management," has been thoroughly adjudicated and definitively established through Inter Partes Review (IPR) proceedings and subsequent appeal.

Legal Standard for Obviousness

Under 35 U.S.C. § 103, a patent may not be obtained "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 to which said subject matter pertains." This determination involves considering the scope and content of the prior art, differences between the prior art and the claims at issue, the level of ordinary skill in the pertinent art, and any secondary considerations of nonobviousness. A key aspect is identifying a motivation to combine prior art references.

PTAB and Federal Circuit Findings

In IPR2014-00538, the Patent Trial and Appeal Board (PTAB) examined claims 1-22 of US8488173. The PTAB issued a Final Written Decision on August 19, 2015, finding all 22 challenged claims unpatentable under 35 U.S.C. § 103(a) as obvious. Specifically, the Board determined that these claims were obvious over US 6,185,590 (Klein) in view of US 6,645,087 (Klein) and US 6,473,042 (Klein). [cite: PTAB challenges section]

This decision was subsequently appealed to the U.S. Court of Appeals for the Federal Circuit. On December 9, 2016, the Federal Circuit affirmed the PTAB's determination in MPHJ Tech. Invs., LLC v. Unified Patents Inc., 843 F.3d 1120 (Fed. Cir. 2016), confirming that claims 1–22 of the ’173 patent are unpatentable as obvious. [cite: PTAB challenges section]

Combination of Prior Art and Motivation to Combine

The prior art references cited by the PTAB—US6185590B1, US6473042B1, and US6645087B2—are highly relevant because they are all patents by the same inventor, Laurence C. Klein, and share a common priority date with US8488173. [cite: Prior art section] These patents are described as direct predecessors and part of the same patent family, representing "earlier stages of the same inventive concept" for distributed document management and the "Virtual Copier" system. [cite: Prior art section]

• US6185590B1 (Klein) discloses a distributed computer architecture for document management, including a uniform management layer for integrating diverse "engines" through API migration, and details a "Virtual Copier" for seamless document copying with a "Go" operation. [cite: Prior art section]
• US6473042B1 (Klein) further elaborates on this architecture, emphasizing the "Virtual Copier" system for copying images between devices and applications (including the Internet) with a simple user interface and seamless integration without modifying destination applications. [cite: Prior art section]
• US6645087B2 (Klein) details the seamless integration and replication of electronic images and documents, featuring a "single GO operation" interface and a one-step programming method for adding electronic document and paper processing via a modular "Virtual Copier." [cite: Prior art section]

A person having ordinary skill in the art (POSA) would have been strongly motivated to combine the teachings of these three Klein patents. This motivation stems from several factors:

1. Common Inventorship and Patent Family: The fact that all references share the same inventor and belong to the same patent family signals that they address related problems and present complementary solutions within the same technological domain. A POSA would naturally consult these related disclosures to find ways to improve, refine, or expand upon existing systems.
2. Continuous Development of a Single Concept: The patents represent successive developments or different facets of the same underlying "Virtual Copier" and distributed document management architecture. A POSA would be motivated to combine the features and functionalities described across these related patents to achieve a more comprehensive or advanced version of the system, such as that claimed in US8488173. For example, combining the core API migration architecture from US6185590B1 with the detailed "Virtual Copier" functionalities and seamless integration methods of US6473042B1 and US6645087B2 would be a logical step in further developing the document management system.
3. Shared Problem Space and Components: All three references tackle the challenges of managing electronic documents and images across diverse devices and applications. They often describe similar modular components (e.g., input, output, process, client, and server modules) and operational concepts (e.g., single "GO" operation, integration without modifying destination applications). [cite: Prior art section] A POSA would readily recognize the synergy and direct applicability of combining these elements to enhance the overall system.

Given this strong motivation and the highly overlapping subject matter, the PTAB and Federal Circuit correctly concluded that the differences between the claims of US8488173 and the combined prior art references would have been obvious to a POSA at the time of the invention. This conclusion led to the invalidation of all claims (1-22) of US8488173. [cite: PTAB challenges section]