US 8817314

I'll search for authoritative information on this specific patent number and any 2026 CAFC activity.

Now let me pull the actual claim set for this specific patent and check for any 2026 Federal Circuit activity.

US 8,817,314 — Search Report

Scope note up front: I searched for the literal number 8817314 and excluded near-miss numbers. I found no Federal Circuit 2026 docket, opinion, or appeal involving US 8,817,314. Details and caveats below.

1. Bibliographic data (from Google Patents / FreePatentsOnline / Espacenet)

Sources: https://patents.google.com/patent/US8817314/en ; https://www.freepatentsonline.com/8817314.html ; https://be.espacenet.com/publicationDetails/originalDocument?...NR=[8817314B2](/patent/8817314B2)

Term caveat: The 2016-02-26 expiration is Google's assumption (20 years from the 1996-02-26 earliest priority), not a legal conclusion — the patent issued in 2014. This is a known quirk of this family.

2. Abstract (as returned for this number)

"The system provides for controlling color reproduction of input color image data in a network having nodes (or sites). The system distributes the input color image data from one of the nodes to other nodes, and provides data structures in the network. The system has means for providing color calibration data at each node characterizing output colors (colorants) of the rendering device of the node, and means for producing at each node, responsive to the color calibration data of the rendering device of the node, information for transforming the input color image data into output color image data at the rendering device of the node. … The rendering device of each node renders a color reproduction responsive to the output color image data, wherein colors displayed in the reproduction at the rendering device of each node appear substantially the same within the output colors attainable by the rendering devices."

(FreePatentsOnline renders the abstract as ending: "The rendering device of each node renders a color reproduction responsive to the output color image data, wherein colors displayed in the reproduction at the rendering device of each node appear substantially the same within the output colors attainable by the rendering devices.")

Note: the abstract above is the network/"Virtual Proof" abstract. This distinguishes '314 from its sibling US 8,917,394 (application 13/843,355, also filed 2013-03-15), whose abstract is instead about color measurement instruments, spectrographs, and self-calibrating non-contact sensors.

3. Plain-language overview of the disclosure / independent claims

Important uncertainty flag: The authoritative full text supplied to me was truncated inside the Detailed Description ("…as shown latter in FIG…"), so I could not retrieve the verbatim claim set of US 8,817,314 itself. The following is drawn from (a) the patent's own Summary of the Invention, and (b) the parallel claim language of closely related family members (e.g., the Canadian family member CA2247005C, and related US 6,157,735 / 8,760,704). Treat it as an accurate characterization of the invention's claim scope, not as a verbatim quotation of '314's claims.

The specification's stated independent concepts are:

1. Networked color-reproduction system (the core independent system claim). A network with nodes/sites, each node having a processor and at least one rendering device (press, proofer, or display). Input color image data for one or more pages (or page constituents) is distributed from one node to the others. Each node stores color calibration data characterizing that node's rendering device colorants; from it the node produces information for transforming the input image data into output image data for that device. The colors reproduced at every node appear substantially the same, within the output colors actually attainable by each device (i.e., matching to the extent each device's gamut permits).

2. "Virtual Proof" (VP) data structure. A file/data structure that holds and transmits the color transformation information between nodes. It has shared components (used by more than one node — e.g., user color preferences) and local components (specific to each node's device). Image data travels separately from the VP, so color preferences/transforms can be revised without re-transmitting the bulky page image data.

3. Calibration, verification, and revision. Means for producing calibration data per node; means for verifying that the transform actually converted image data correctly (verification forms rendered and measured by a color measurement instrument, "SOM"/"imagical"); and means for revising the stored information at that node in response.

4. Gamut / proofer-client handling. Building a forward model (colorants → device-independent CIE coordinates), inverting it to get a color→colorant "prototype SEP" table, computing black utilization (GCR/UCR, maximum black), and concatenating with a color→color′ "conditioning" transform that performs gamut scaling/clipping so one device can accurately proof or simulate another.

5. More-than-four-colorant rendering devices are expressly supported, as is a GUI and user-selectable color preferences and black-utilization parameters.

Family relationship (for context, not the '314 claims): Related continuations/divisionals in the same family include US 6,043,909; 6,157,735; 6,459,425; 7,075,643; 7,710,560; 7,729,008; 7,791,761; 7,830,546; 8,416,444; 8,537,357; 8,760,704; 8,917,394; 9,036,209; 9,057,645. Sibling claims in these family members recite "a system for controlling color reproduction at multiple sites comprising: a computer at a site; memory storing … data representing tonal transfer curves … one or more color transformations … and a data structure expressing colors that are in or out of gamut"; a chromatic adaptation transform; and a network interface communicating that information to at least one other site.

4. Known litigation / post-grant activity (not 2026 CAFC)

Google's litigation panel flags three US district court cases: E.D. Pa. 2:15-cv-05203; N.D. Ill. 1:17-cv-02924; and N.D. Ill. 1:17-cv-00894.

Post-grant challenges in this patent family (Adobe Inc. as petitioner before the PTAB) targeted other family members, not '314 — e.g., IPR2019-00627 ('008), IPR2019-00628 ('444), IPR2019-00629 ('897), IPR2019-00646 ('761), with Adobe's subsequent Federal Circuit appeal docketed as 21-1067 (Adobe Inc. v. RAH Color Technologies LLC, filed Oct. 2020). A parallel MDL (N.D. Cal. MDL No. 2874, Case 3:18-md-02874) consolidated the Adobe, Xerox, EFI, Heidelberger, and Dalim actions.

5. 2026 CAFC dockets — specific finding

No 2026 Court of Appeals for the Federal Circuit docket, opinion, order, or argument involving US 8,817,314 was located. My searches surfaced a prominent 2026 CAFC decision — Constellation Designs, LLC v. [LG Electronics Inc.](/litigations/by-plaintiff/LG%20Electronics%20Inc.), Nos. 2024-1822 (Fed. Cir. Apr. 28, 2026) (Lourie, Stoll, Oetken, D.J.), vacating summary judgment of §101 eligibility for the optimization claims of US 8,842,761 and US 10,693,700 while affirming eligibility of specific-constellation claims of US 11,019,509 and US 11,018,922 — but that case concerns non-uniform digital-broadcast constellations (ATSC 3.0), an unrelated technology and unrelated patent numbers. It should not be reported as activity on '314.

6. Confidence / uncertainty summary

• High confidence: number, title, inventor, assignee, application number, filing date, issue date, publication number, abstract, and the three flagged district court cases — all corroborated by multiple sources.
• Moderate confidence: the exact independent-claim wording of '314. I could not verify it verbatim; the claim overview is reconstructed from the specification's Summary and parallel family claim language.
• Low/none: any 2026 CAFC docket for '314. I found none and cannot confirm one exists.

If you need verbatim claim text for '314, the reliable sources are the USPTO PatentCenter/Patent Full-Text (USPAT: 08817314) or the granted-PDF claim column, which I was unable to open within this search session.

I'll research litigation involving US 8,817,314 using multiple searches.

Let me dig into the specific cases referenced and the MDL.

Let me confirm outcomes and check for additional cases involving the '314 patent.

Litigation Involving U.S. Patent No. 8,817,314 ("'314 patent")

Important framing note: U.S. 8,817,314 ("System for Distributing and Controlling Color Reproduction at Multiple Sites," inventor Richard A. Holub, assignee RAH Color Technologies LLC) issued August 26, 2014 and expired February 26, 2016 (fee-related expiration per the patent record). It is one of a large family of Holub/RAH Color patents sharing the same specification. Because RAH filed many overlapping suits, I have distinguished below between (a) cases where the '314 patent itself was asserted, and (b) related RAH campaigns/MDLs in which the '314 was not a patent-in-suit (to avoid returning results for similar numbers/cases, as you instructed).

A. Cases in which the '314 patent WAS asserted as a patent-in-suit

These are the three matters flagged by the patent record itself (Google Patents "Family has litigation" links):

Grounding: The patent record's litigation links (portal.unifiedpatents.com/litigation/Pennsylvania Eastern/case/2:15-cv-05203; .../case/1:17-cv-02924; .../case/1:17-cv-00894). The Ricoh complaint (E.D. Pa. Dkt. 33, filed 04/19/16) contains a dedicated "SEVENTH CLAIM FOR RELIEF (Infringement of the '314 patent)," accusing Pentax 645Z/645D, K-series, Q-series, X-series, and WG-series cameras. The R.R. Donnelley and Fujifilm complaints each list the '314 patent among the Patents-in-Suit.

B. Related RAH Color Technologies matters in which the '314 patent was NOT asserted (for disambiguation)

Do not attribute these to the '314 patent; they cover sibling patents:

• In re: RAH Color Technologies LLC Patent Litigation, MDL No. 2874, N.D. Cal. (3:18-md-02874-SI; Judge Susan Illston). Consolidated RAH v. Adobe (3:18-cv-03277), RAH v. Xerox (W.D.N.Y. 6:18-cv-06746), RAH v. Kodak (W.D.N.Y. 6:19-cv-06112), RAH v. Heidelberger Druckmaschinen (N.D. Ill. 1:19-cv-00193), RAH v. Dalim Software (N.D. Ill. 1:19-cv-00275), and Electronics For Imaging, Inc. v. RAH Color Technologies (E.D. Va. 1:18-cv-01436). The patents litigated were '870, '008, '444, '704, '897, and '761 — not the '314. MDL closed (final judgment order; docket entry noting "THIS MDL IS CLOSED").
• IPRs against RAH patents (Adobe, Inc. v. RAH Color Technologies LLC): IPR2019-00627 ('008), IPR2019-00628 ('444), IPR2019-00629 ('897), IPR2019-00646 ('761). No IPR petition was filed against the '314 patent in the sources retrieved.
• RAH v. Quad/Graphics, Inc. (N.D. Ill. 1:17-cv-02945 → transferred to E.D. Wis. 2:18-cv-00087) — asserted '870, '897, '704, '008, not the '314.
• RAH v. [Microsoft Corp.](/litigations/by-plaintiff/Microsoft%20Corp.) (E.D. Tex. 2:20-cv-00088 and 4:20-cv-00176) — voluntarily dismissed 2020.

C. Confidence and caveats

• High confidence on the three cases in Section A (plaintiff, defendant, jurisdiction, case numbers, filing dates) — these are directly documented in the complaints and the patent record.
• Lower confidence / not confirmed on the precise dispositions of the R.R. Donnelley and Fujifilm cases. I could not retrieve a final judgment, settlement, or dismissal order for those two in this session, so I am not asserting an outcome. The Ricoh case is documented as closed/terminated on 2017-02-16, but the underlying disposition document was not retrieved.
• I found no CAFC appeal, and no IPR/PGR, directed at the '314 patent specifically.
• If you need the exact termination documents (Rule 41 dismissals, settlement agreements, or consolidated-judgment entries), the next step would be PACER dockets for 2:15-cv-05203 (E.D. Pa.), 1:17-cv-00894 and 1:17-cv-02924 (N.D. Ill.).

Sources: Google Patents record for US8817314B2 and its litigation links; Unified Patents litigation portal (E.D. Pa. 2:15-cv-05203, E.D. Tex. 2:20-cv-00088); RPX Insight (RAH complaints); CourtListener/Justia MDL 2874 claim-construction order (N.D. Cal. 3:18-cv-03277-SI, Dkt. 120); PTAB records for IPR2019-00627/-628/-629/-646.

I'll verify the structured "no PTAB activity" default against live sources before writing.

Let me run targeted searches on the specific patent number and on the RAH family's full IPR history.

Let me confirm there's no third-party or aggregator proceeding on '314 specifically, and check for reexamination activity.

Proceedings overview

Zero AIA trial proceedings. The USPTO Open Data Portal's structured "PTAB proceedings on file" block returns no IPR, PGR, or CBM for US 8,817,314, and my independent searches of PTAB E2E / PTABS, the Unified Patents litigation portal, and the family's litigation record found no AIA trial (and no ex parte reexamination) ever instituted or even petitioned on the '314 patent specifically. All claims of '314 are UNTESTED at the PTAB — nothing has been canceled and nothing has been adjudicated patentable. The defensive posture is therefore not "the patent has survived IPRs and is hardened," nor "claims X–Y are dead." It is: the patent was never attacked at the Board, but it also appears expired/lapsed — so the real defense is temporal, not invalidity-based. Treat any demand letter asserting '314 today as a claim for past damages only, at best.

(No proceedings to report on US 8,817,314)

There is accordingly no petitioner, no panel, no institution decision, no FWD, no settlement, and no Federal Circuit appeal to itemize for this patent. I am reporting the absence rather than manufacturing a docket.

One important scope caveat, flagged explicitly: the enormous Adobe/RAH IPR cluster that dominates search results is not about '314. Adobe Inc. petitioned against four sibling patents in the same Holub family — IPR2019-00627 (US 7,729,008), IPR2019-00628 (US 8,416,444), IPR2019-00629 (US 7,312,897), and IPR2019-00646 (US 7,791,761) — all filed 2019-01-31/02-01. '314 (application 13/843,030) was not among the challenged patents. The four Adobe petitions were consolidated for a single oral hearing on 2020-05-28. Source: https://www.docketalarm.com/cases/PTAB/IPR2019-00646/Inter_Partes_Review_of_U.S._Pat._7791761/docs/10-08-2020-Board/Notice-119 (FWD, Paper 119) and the institution decision at https://www.docketalarm.com/cases/PTAB/IPR2019-00646/Inter_Partes_Review_of_U.S._Pat._7791761/docs/02-27-2020-Board/Order-75.

Adjacent family proceedings — CONTEXT ONLY, not proceedings on '314

These matter to a defendant for estoppel and pattern analysis, not because they changed any '314 claim. I am labeling the confidence on each because my search results were incomplete on some.

Note on the record above: some PTAB documents transcribe the consolidated-hearing caption as "IPR2020-00629" and "IPR2020-00646." Those are transcription artifacts; the docketed numbers are IPR2019-00629 and IPR2019-00646. Do not cite the 2020 forms.

A related procedural point that recurs across these four cases and may be useful to a defendant: RAH fought hard on real-parties-in-interest, arguing Quad/Graphics, Dalim, Xerox, Heidelberger, and EFI should have been named as RPIs; the Board rejected that at institution and again at FWD ("Petitioner has sufficiently shown that Quad, Dalim, Xerox, Heidelberger, and EFI are not RPIs"). Source: FWD text in https://ptacts.uspto.gov/ptacts/public-informations/petitions/1523317/download-documents?artifactId=dWQYzSy8yHtdm60fwWOQmZPRzytdgelbTrRIHzgiWlhj9E-y-x2wwRw

Strategic summary

Claim status for '314. There is nothing to list under "canceled" or "sustained" — the patent went through prosecution untouched by the Board and its entire issued claim set (as originally granted) remains formally intact. I could not retrieve and verify '314's verbatim claim set (the authoritative full text supplied to me was truncated in the Detailed Description; the prior section of this analysis flagged the same gap), so I will not quote claim numbers for '314. What I can state with high confidence is narrower and more useful: no claim of '314 has ever been canceled, narrowed, or confirmed by the PTAB. Any assertion that "claims 1–5 of '314 were canceled" would be false, and any assertion that "the PTAB upheld '314" would also be false. Both directions of over-claiming are unsupported.

Estoppel landscape. Because no IPR or PGR was ever instituted on '314, no § 315(e)(2) estoppel attaches to this patent at all. Estoppel under § 315(e)(2) runs patent-by-patent against the petitioner and its privies based on grounds raised or reasonably raisable in that petitioner's own proceeding. Adobe's wins on the '444, '897, and '761 siblings generate estoppel only as to those patents. A defendant facing '314 is not blocked from raising any § 102/§ 103 ground — including art Adobe used against the siblings — against '314, subject to ordinary IPR-filing-time bars and the Board's discretionary-denial practice. Practically, that means the invalidity runway on '314 is wide open for a party that decides to attack it — subject to the expiration caveat below.

Pattern signals. Adobe was the aggressor and filed a coordinated four-petition campaign against the family, but deliberately did not petition on '314 — even though '314 had been asserted in the Ricoh action (E.D. Pa. 2:15-cv-05203, filed 2015-09-16) and in RAH Color Technologies LLC v. R.R. Donnelley & Sons, N.D. Ill. 1:17-cv-00894, filed 2017-02-02, where '314 was named among the Patents-in-Suit. The most likely explanation is temporal: by the 2019 petition window '314 was already near or past the end of its term (see below), making it a poor IPR target. I found no defensive-aggregator (Unified Patents, RPX, etc.) petition on '314, and no indication RAH appealed any IPR to the Federal Circuit on '314 — its appellate activity, if any, concerns the sibling patents. RAH's own posture was as a serial plaintiff across E.D. Pa., N.D. Ill., W.D.N.Y., E.D. Va., and N.D. Cal. (MDL No. 2874), not as a PTAB appellant on this patent.

The dominant fact for any defendant: term. The Google Patents record for '314 (supplied as authoritative in this matter) shows anticipated expiration 2016-02-26 and legal status "Expired – Fee Related." The 20-year term runs from the earliest priority (1996-02-26), and the "Fee Related" label indicates a maintenance-fee lapse as well. Either way, '314 appears expired, with no prospective damages. This is why the absence of IPRs is not the reassuring signal it usually is — for this patent, there was little for a petitioner to gain. Caveat, stated plainly: I am reporting the record's status field, and expiration/lapse is a legal determination I have not independently adjudicated; confirm against USPTO PatentCenter maintenance-fee records before relying on it.

Recommended next steps

1. If you received a demand citing '314, lead with the expiration/lapse point, not invalidity. Confirm the maintenance-fee and term status at USPTO PatentCenter for application 13/843,030 / patent 8,817,314. If the patent lapsed, prospective relief (injunction, ongoing royalties) is off the table; the exposure is limited to past damages within the 6-year § 286 lookback for pre-expiration conduct — and RAH's own record of near-contemporaneous assertions (Ricoh 2:15-cv-05203, terminated 2017-02-16; R.R. Donnelley 1:17-cv-00894, filed 2017-02-02) gives you the notice-date anchor to litigate that window.

2. Do not accept a claim-status representation at face value. Because there is no PTAB FWD on '314, there is no official claim-level disposition to link to and no Board opinion to quote. Ask opposing counsel to identify the specific claims asserted and their verbatim text — consistent with my inability to verify '314's claim set here, a defendant should not treat any second-hand characterization of its claims as reliable.

3. If you want an invalidity/eligibility attack, understand it must be run in district court, not the PTAB. No § 315(e)(2) estoppel blocks you, and there is no prior IPR record constraining claim construction. Two cautions: (a) an expired patent can still be challenged (for past-damages purposes) and a § 101 or § 112 defense is entirely available; but (b) the prior-art posture is favorable precisely because the Board never construed these claims — the Federal Circuit's RAH family precedents, if any, touch other patents.

4. Monitor the sibling appeals for leverage, not estoppel. If Adobe v. RAH Color Technologies, No. 2021-1067 (or any related appeal) produced a Federal Circuit ruling on the shared specification or claim terms, that reasoning could be persuasive as to '314's parallel limitations even though it cannot bind on estoppel. I was unable to confirm the disposition of 21-1067 in this session — verify on CourtListener and the CAFC docket before relying on it: https://www.courtlistener.com/?q=%22RAH+Color+Technologies%22

5. Re-verify the "no PTAB activity" default before filing. The structured ODP block is canonical and I found nothing to contradict it, but RAH Color Technologies is an active serial litigant and Director-review/rehearing practice has shifted materially since 2025-10-16 (Director Squires' institution memorandum). A fresh IPR, PGR, or ex parte reexamination could exist that predates ODP ingest. A 30-second check of PTAB E2E for patent 8,817,314 is cheap insurance before you commit to a position in a brief.

Confidence: High that no AIA trial proceeding exists on 8,817,314 and that no claim of it was ever canceled or sustained. High on the four sibling IPR numbers and on the '008, '897, and '761 FWD dispositions quoted above. Moderate-to-low on the '444 (IPR2019-00628) claim-level outcome and the CAFC disposition of 21-1067 — both unverified here. I have not stated any '314 claim numbers because I could not verify the claim set, and I will not invent them.

I'll research the ownership chain for US 8,817,314 using the USPTO assignment records and cross-reference sources.

Let me search for the specific assignment records and the chain of title.

Ownership reconstruction — US 8,817,314 ("System for distributing and controlling color reproduction at multiple sites")

Scope / source-access caveat (read first)

I attempted to pull the USPTO Assignment Center (assignmentcenter.uspto.gov) and assignment.uspto.gov records for 8817314 directly. The search session did not return a parsed assignment-record table with reel/frame, execution date, recording date, and correspondent for this patent. I therefore have no verified reel/frame numbers for US 8,817,314 and will not invent any. What follows is (a) what the patent record itself and litigated-chain-of-title statements establish, and (b) an explicit flag where the Assignment Center data is a gap you should fill via the link at the end.

This is a material gap, not a "no records exist" finding — the Google Patents legal-events panel does show a recorded merger for this patent, so records exist; I simply could not open the underlying reel/frame entries.

Inventors

• Employment history (from Holub's own IPR testimony and RAH's complaints): Eikonix Corp./Eastman Kodak (1983–1990), Agfa/Compugraphics (1990–1993), SuperMac Technologies (1993–1994, Sunnyvale CA). Holub left SuperMac in 1994 and moved to Rochester, NY, where he began the work that led to the 1996 priority filing — renting lab space from RIT Research Corp., hiring RIT students and contractors, and teaching part-time at RIT (1995–1998).
• Pattern note: This is an unassigned, solo-inventor origin — there is no corporate co-assignee on the 1996 priority application. That is the opposite of the "all inventors depart the original assignee within 12 months" fire-sale tell: here there was never a corporate employer in the chain at filing. The classic fire-sale inference does not apply.
• Holub is also the sole member of the current owner (confirmed by his own sworn declaration: "I am the sole member of RAH Color Technologies LLC" — Ex. 2121, Adobe v. RAH, IPR2019-00646). Inventor = 100% owner is itself a notable pattern, addressed under NPE signals.

Original assignee

Entity named on the issued '314 patent: RAH Color Technologies LLC (also spelled "RAH Color Tech LLC" on the application/filing record; Google Patents lists "RAH Color Tech LLC" as original assignee and "RAH Color Tech LLC" as current assignee; FreePatentsOnline lists "RAH Color Technologies LLC"). Treat the two spellings as the same entity pending reel/frame verification.

• Line of business: Patent licensing only. RAH's own complaints describe it as formed in 2005 "as a vehicle for an on-going licensing program for companies whose products depend on Dr. Holub's innovations." It is owned entirely by Holub and ships no product.
• Predecessor commercial entity: Imagicolor Corporation, formed by Holub in 1998 to commercialize his prototype (automatic display calibration + soft-proofing). Investment did not materialize and Imagicolor was dissolved (RAH's verified statement of facts). The root patent of this family, US 6,043,909 (issued 2000-03-28), is recorded as issued to Imagicolor Corporation.
• Current status: Operating as an active licensing/assertion vehicle, not dissolved. RAH has filed and maintained dozens of infringement suits since 2010 (Seiko Epson, X-Rite, Kodak, EFI, Adobe, Xerox, Heidelberger, Dalim, R.R. Donnelley, Fujifilm, Ricoh, Quad/Graphics, Microsoft). Its own declarations state RAH holds 35 U.S. patents + 1 allowed application (2019).
• Domicile drift (relevant to shell-entity analysis): RAH was pleaded as a New York LLC with an office at 261 Hollywood Avenue, Rochester, NY 14618 (2010 Seiko Epson complaint) and later as a Virginia LLC with an office at 7012 Colgate Drive, Alexandria, VA 22307 (2018 X-Rite complaint). Same sole member throughout.

Assignment timeline

USPTO Assignment Center records could not be opened in this session, so reel/frame, execution date, recording date, and correspondent are UNVERIFIED for every entry below. The entries are reconstructed from the patent's own legal-events panel and from chain-of-title statements made in RAH litigation papers (which are admissions, not assignment records).

1. 1996-02-26 (constructive) / recorded — Reel UNVERIFIED

   • Conveyance: Original filing — inventor-owned (no corporate assignee named at filing)
   • Assignor: Richard A. Holub
   • Assignee: Dr. Holub / later Imagicolor Corporation (root patent '909 issued to Imagicolor Corporation)
   • Correspondent: UNVERIFIED (prosecution filer of record for the family is Kenneth Jay Lukacher, Customer No. 24902 — see signal 3)
   • Context: Inventor-origin; no employer assignee. Holub's own business entity (Imagicolor, 1998) becomes the holder of the family root.

2. 2005 (year only) / recorded UNVERIFIED

   • Conveyance: Formation of licensing vehicle / transfer of portfolio
   • Assignor: Imagicolor Corporation (dissolved) / Dr. Holub
   • Assignee: RAH Color Technologies LLC
   • Correspondent: UNVERIFIED
   • Context: Transfer to asserter. Holub forms RAH as a pure licensing vehicle after his operating entity fails.

3. 2013-03-15 (asynchronous) / recorded UNVERIFIED

   • Conveyance: New continuation application filed (application 13/843,030, which issued as the '314)
   • Assignor: n/a (applicant: "RAH Color Tech LLC")
   • Assignee: RAH Color Tech LLC
   • Correspondent: UNVERIFIED
   • Context: Internal continuation filing within the Holub family; '314 is a later continuation sharing the 1996-02-26 priority.

4. 2013-05-14 (recorded; execution date UNVERIFIED) / Reel UNVERIFIED

   • Conveyance: MERGER (see document for details) — recorded as MERGER (SEE DOCUMENT FOR DETAILS), per Google Patents legal events
   • Assignor: RAH COLOR TECHNOLOGIES LLC
   • Assignee: RAH COLOR TECHNOLOGIES LLC
   • Correspondent: UNVERIFIED
   • Context: Internal reorg / re-domiciliation. Assignor and assignee names are identical on the index; the operative merger document must be pulled to identify the disappearing entity (likely a New York → Virginia re-domiciliation or a like-named predecessor LLC merge). This is the only post-issuance-ish assignment visible on the '314 record.

5. 2014-08-26 — issue of US 8,817,314 B2 to RAH Color Technologies LLC (no intervening assignee; confirms RAH held it at grant).

No further assignment events after the 2013 merger appear in the patent record. On the current evidence, RAH Color Technologies LLC still owns '314, and the chain is effectively Holub/inventor → Imagicolor (dissolved) → RAH Color Technologies LLC (licensing-only), with a 2013 internal merger on top.

Verify / complete this table here: https://assignmentcenter.uspto.gov/ (search by patent number 8817314; the record's reel/frame entries and the correspondent of record are exactly what is missing above).

Timeline diagram

timeline
    title Ownership of US 8817314
    1996 : Priority application filed by Holub
    1998 : Imagicolor Corp formed
    2000 : US 6043909 issued to Imagicolor
    2005 : RAH Color Technologies LLC formed
    2013 : Continuation filed by RAH Color Tech
         : Merger recorded to RAH Color Technologies LLC
    2014 : US 8817314 issued
    2015 : First suit asserting the 314 filed

NPE / troll-pattern signals

1. Shell-entity transfer — PRESENT (as a licensing-only holder, not a name-suffix shell).
   The patent sits in RAH Color Technologies LLC, a single-member LLC owned by the inventor, which by its own admission "was formed as a vehicle for an on-going licensing program" and ships no product. The prior operating entity, Imagicolor Corporation, was dissolved. Caveat: the name suffix is "Technologies LLC," not "IP/Licensing/Holdings," and the address is a residential-style office (7012 Colgate Drive, Alexandria, VA), not a registered-agent storefront — so the naming tell is absent; the function tell is present.

2. Known asserter in the chain — PRESENT (high-frequency plaintiff), but not on the classic named lists.
   RAH Color Technologies is a prolific serial plaintiff documented by RPX and Unified Patents (Seiko Epson 6:10-cv-06710; X-Rite; Kodak; Adobe 3:18-cv-03277; Xerox 6:18-cv-06746; EFI 1:18-cv-01436; Heidelberger 1:19-cv-00193; Dalim 1:19-cv-00275; plus MDL 2874). RAH's own filings refer to "dozens of cease-and-desist letters" and licensing revenue. It does not match Acacia, Marathon, IV, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Round Rock, etc., so name-match against those lists is negative — the high-frequency-plaintiff match is the operative evidence. No reel/frame cited because the entity identity is established by the patent's (73) and by RAH's own sworn declarations, not by an assignment record I could open.

3. Repeat correspondent across the chain — UNCLEAR / not verifiable here.
   I could not retrieve the assignment-record correspondent (the attorney who filed each recording) for '314 — this is precisely the field the Assignment Center would supply. Do not treat the following as an assignment-correspondent finding: the prosecution filer of record across this family is Kenneth Jay Lukacher (Customer No. 24902), and Martin LuKacher appears in RAH's IPR papers reviewing a 1995 draft specification. That is a prosecution/agent recurrence, not a recording-correspondent recurrence, and I flag it as a lead only. Action item: pull the correspondent field on every '314 reel/frame and compare.

4. Cascading transfers — NOT PRESENT (on available evidence).
   Only one recorded event (the 2013-05-14 merger) appears on the '314 record. There is no chain of LLC-to-LLC hops in <24 months; the ownership has been stable with RAH since 2005. The absence of a cascade is a genuine negative finding and should not be dressed up as one.

5. Pre-litigation transfer — NOT PRESENT.
   The first suit naming '314 was E.D. Pa. 2:15-cv-05203 (filed Sept. 2015). The nearest preceding transfer, the 2013-05-14 merger, is ~28 months earlier — outside the 6-month window. No transfer was arranged immediately pre-suit.

6. Bankruptcy fire-sale — NOT PRESENT.
   Imagicolor Corporation was dissolved for lack of investment, but the record reflects dissolution, not a Chapter 7/11 sale of patents. No court-supervised patent sale (Kodak/Nortel/Polaroid style) is evidenced.

7. Privateering — NOT PRESENT.
   The classic pattern (operating company → NPE asserting on the operating company's behalf) does not fit: the transferor here is the inventor's own failed startup, and the transferee is the inventor's own LLC — the same person sits on both sides. There is no third-party operating-company principal behind RAH.

8. Defensive aggregator — NOT PRESENT / inverse.
   The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN. To the contrary, Adobe filed IPRs against four sibling RAH patents (IPR2019-00627/-628/-629/-646) — i.e., RAH is a target of defensive aggregation, not a member of it. (Note: those IPRs did not target '314.)

Verdict

NPE — high confidence.

US 8,817,314 is owned by RAH Color Technologies LLC, a single-member LLC owned 100% by the sole inventor, which by its own admission is "a vehicle for an on-going licensing program" and has never shipped a commercial product (its predecessor operating entity, Imagicolor Corporation, was dissolved). RAH is a documented high-frequency patent plaintiff that has asserted the family against Seiko Epson, X-Rite, Kodak, Adobe, Xerox, EFI, Heidelberger, Dalim, R.R. Donnelley, Fujifilm and Ricoh — the two strong signals (licensing-only holder + prolific asserter) are both supported by the patent's own (73) designation and by RAH's sworn litigation statements. Caveat driving this to "high" rather than "certain": I could not open the USPTO Assignment Center reel/frame entries, so the recording-correspondent recurrence test (signal 3) and the execution dates of the 2013 merger remain unverified — pull those here: https://assignmentcenter.uspto.gov/ (search 8817314).

Key sources: Google Patents legal events for US8817314B2 (incl. the 2013-05-14 MERGER event) — https://patents.google.com/patent/US8817314/en ; FreePatentsOnline record — https://www.freepatentsonline.com/[8817314](/patent/8817314).html ; RAH complaint background facts (RPX docket docs) — https://insight.rpxcorp.com/litigation_documents/[12841124](/patent/12841124) ; RAH v. Seiko Epson 6:10-cv-06710 first amended complaint; Ex. 2121 Declaration of Richard A. Holub, Adobe v. RAH, IPR2019-00646 ("I am the sole member of RAH Color Technologies LLC").

I'll research the prior-art citations for US 8,817,314. Let me pull the citation lists from USPTO/Google Patents and verify each reference.

Let me pull the full citation list from FreePatentsOnline and the Google Patents "References Cited" section for this specific number.

Let me try to retrieve the actual "References Cited" section from Justia and FreePatentsOnline for this exact number.

Prior-Art Analysis — US 8,817,314 ("'314")

0. Method, scope, and two honesty flags up front

Flag 1 — the front-page "References Cited" list could not be retrieved. My searches for the literal number 8817314 confirmed the patent record and the three district-court cases already reported, but I was not able to open the granted patent's front-page "(56) References Cited" field (the examiner/applicant-cited list of U.S. patent documents, foreign documents, and non-patent literature) in this session. USPTO PatentCenter/Patent Full-Text (USPAT 08817314) and the granted PDF were not retrievable through the tools available. What I can ground authoritatively is the full specification text supplied to me, whose Background/Definitions section expressly discusses prior art and names specific references. I therefore report the references the '314 specification itself cites/discusses, and I flag separately (Section 4) which other references likely appear on the front page but that I could not verify for '314.

Flag 2 — no verbatim claim set, so no true element-by-element § 102 test. As noted in the earlier summary, the full text supplied to me was truncated inside the Detailed Description and I could not retrieve '314's verbatim claims. A proper 35 U.S.C. § 102 anticipation analysis requires matching a reference element-by-element against a specific claim. I cannot honestly complete that element-by-element test. Below I map each reference to the claim concepts the '314 Summary identifies (networked rendering system; Virtual Proof shared/local data structure; calibration/verification/revision; forward model → SEP → gamut/conditioning; >4-colorant; GUI), and I say explicitly where a reference is at most relevant versus where it could anticipate. Do not treat the concept mapping as a legal § 102 conclusion.

Legal framework (important nuance): '314 (application 13/843,030) was filed 2013-03-15 — one day before the AIA first-inventor-to-file changeover of 2013-03-16 — and claims priority to 1996-02-26. It is therefore governed by pre-AIA § 102, not AIA § 102. The § 102(b) critical date is 1995-02-26 (one year before the 1996 priority). Art before that date is a § 102(b) bar; art between 1995-02-26 and 1996-02-26 is § 102(a)/(e); art after 1996-02-26 is not prior art.[^1]

1. U.S. patent references cited/discussed in the '314 specification

These four are the patent documents expressly named in the '314 specification text I have. Exact issue dates are given with confidence flags because the supplied text names the patents and inventors but not their dates; I did not independently verify the dates in this session.

Also named (no U.S. number given in the text):

2. Non-patent literature cited/discussed in the '314 specification

These are printed publications and standards; all listed dates precede the 1996 priority and most precede the 1995-02-26 § 102(b) critical date.

Note on provenance: The NPL items in the list above that are expressly named within the supplied '314 text (Neugebauer, Gordon et al., CIE 15.2, MCT, ICC Profile Format, Sodergard, Garini, Eouzan, Bonino, Johnson & Wichern, Grievenkamp, Shnitser & Hoyt, ANSI IT8.7/2, Holub & Rose) are directly grounded. The Holub/Kearsley/Pearson 1988 papers and several other journal/manual references are drawn from the sibling family member's cited-references list (see Section 4) because they are the inventor's own canonical background works; treat their appearance on '314's own front page as inference, not verified.

3. Concept-level § 102 bottom line

For every reference above, the same structural gap recurs: none discloses the combination that '314's independent concepts require — a network of nodes each with a rendering device, distribution of input image data across those nodes, per-node calibration data, per-node production of transforming information, and rendering so that colors appear substantially the same within each device's attainable output colors (the "Virtual Proof" architecture). The closest single references are:

• Vincent '518 — closest on "consistent color across a network," but the spec itself states it lacks distributed-calibration implementation and any verification — i.e., missing elements of the independent claim.
• ICC Profile Format v3.01 (1995) and MCT (1993) — closest on the color-transformation data file, but both are non-extensible/limited and are distinguished in the spec for exactly the distributed-production/remote-proofing features '314 claims.
• Gordon et al. (1987) — closest on the gamut-operator mathematics, but is a colorimetric teaching, not a system.

Under § 102, a single reference must disclose all elements arranged as claimed. On the available record no cited reference appears to anticipate any independent claim on its own; these references are best characterized as § 102(b)/(a) art bearing on individual claim elements and on the obviousness (§ 103) backdrop — not as anticipatory art. And note the references were cited in the specification's background discussion, not necessarily applied as rejections; '314 issued, so the examiner did not find them anticipatory against the granted claims.

4. What I could NOT verify for '314 specifically (do not attribute to '314)

The following surfaced in my searches but belong to other patents — not to '314's own cited-reference list — and must be disambiguated:

1. Sibling-family cited references. The Justia page for Holub's US 9,516,288 / 9,227,282-family patent lists a long NPL set (e.g., Vanhala et al., "A General Teleproofing System," TAGA Proceedings, May 1991; Cowan, "An Inexpensive Scheme for Calibration of a Colour Monitor…," Computer Graphics vol. 17, No. 3 (1983); Berns et al., "CRT Colorimetry Parts I & II" (1993); Swain et al., "Color Indexing" (1991); Funt et al., "Color Constant Color Indexing" (1995); Radius PressView User's Manuals (1995); Ocean Optics spectrometer data sheet (Mar. 1995); Holub, "Colorimetric Aspects of Image Capture," IS&T 48th Annual Conf. (May 1995)). Vanhala's "A General Teleproofing System" (1991) is, substantively, the most on-point remote-proofing prior art and would be highly relevant if it is on '314's list — but I could not confirm that for '314. Flagged as unverified for '314.
2. Citations to '314, not by '314. Justia lists for US 9,224,074 and US 9,204,016 show 8,817,314 (Holub, Aug. 26, 2014) among their cited references. That is the reverse direction (later patents citing '314); it is not '314's prior art.
3. Litigation/PTAB material is already reported in the earlier sections and is not prior art. Consistent with those sections, I again found no IPR/PGR against '314 and no 2026 CAFC docket for '314.

5. Contradictions / corrections to prior sections

• None found with the bibliographic and litigation data already generated. The claim-scope uncertainty flagged earlier (no verbatim '314 claims) is confirmed and is the binding limitation on this § 102 task. The '314 issued 2014-08-26, expired 2016-02-26 (fee-related, per the record) — consistent.

6. Confidence summary

Recommended next step to close the gap: pull the granted PDF's front page (columns 1–2, "References Cited") from USPTO PatentCenter or the Espacenet original document for US8817314B2 to obtain the examiner-cited U.S./foreign patent documents and full NPL list, then re-run a true element-by-element § 102 chart against the verbatim claims (column 15+ of the granted PDF).

[^1]: Pre-AIA vs. AIA applicability is based on the application's actual filing date (2013-03-15, before the 2013-03-16 changeover); the 1996-02-26 priority date further supports pre-AIA treatment. I state this as the applicable framework but note it is a legal determination, not a legal conclusion.

I'll ground this analysis in the actual claim language and the prior-art references identified in the patent's own background section. Let me verify the claim set and check the cited references.

Let me try to pull the actual granted claim text and the key IPR record for a sibling, which shows how the family's claims map to prior art.

Let me pull the granted claim set specifically — the earlier sections flagged that they couldn't verify it.

Obviousness Analysis — US 8,817,314 B2 under 35 U.S.C. § 103

0. Threshold caveats (read these before using any element mapping below)

(a) Claim-text uncertainty — inheritance plus a new discrepancy. The prior "Patent summary" section of this analysis states that it could not retrieve the verbatim granted claim set of '314 and reconstructed the claim scope from the specification's Summary and parallel family claims. I was likewise unable to open the granted claim column. However, my searches surfaced two data points that the earlier section did not have, and they partly contradict its characterization:

1. The pre-grant publication of the same application — US 2013/0301064 A1 (the publication of application 13/843,030, which issued as '314) — carries claims 55–68, and those claims are not the network/"Virtual Proof" claims. They are "[a] digital imaging system comprising: an input device comprising one or more sensors which capture an image…" and "[a] digital system for capturing a color image…" (Justia, US 2013/0301064).
2. The earlier "Litigation summary" section records that in RAH v. Ricoh (E.D. Pa. 2:15-cv-05203) the '314 was asserted against standalone cameras (Pentax 645Z/645D, K-series, Q-series, X-series, WG-series) — consistent with input-device/capture claims, not with a network-of-presses claim.

Conclusion I would draw (moderate confidence): the granted '314 claims are most likely directed to the input-imaging / sensor-gamut-to-output-gamut mapping aspect (the published claims 55–68 type scope), not the "Virtual Proof network" scope the prior section assumed. Because I cannot verify the granted claims verbatim, I analyze both scopes below — Set A (input-imaging claims, my primary hypothesis) and Set B (network/Virtual Proof claims, per the prior section) — and I flag this as a contradiction between sections rather than silently resolving it.

(b) Priority date / prior-art window. Earliest priority is 1996-02-26 (Google Patents), tracing to application 08/606,883 (issued as US 6,043,909). This is a pre-AIA continuation, so the critical date is 1996-02-26 and § 102(b)/§ 103 art must predate it. This matters: several references that appear on the face of '314 are dated after 1996 — e.g., Zuber US 6,275,937 (Aug. 2001), US 6,219,155 (Apr. 2001), US 6,636,326 (Oct. 2003); Barry et al. US 6,606,165 (Aug. 2003); Bullock et al. US 5,835,817 (Nov. 1998). These cannot be § 102(b) art against a 1996 priority claim (they could only be § 102(e)/pre-AIA art if earlier-filed, which the face dates do not establish). Any invalidity theory built on them is date-fragile. By contrast, the references the specification itself cites in its background/definitions section all predate 1996 — that is where a § 103 case should be built.

(c) Sources. Full text: https://patents.google.com/patent/US8817314/en (as supplied, truncated in the Detailed Description). Publication claims: https://patents.justia.com/patent/20130301064. PTAB record for the sibling family: IPR2019-00628 Final Written Decision (Aug. 31, 2020), https://www.docketalarm.com/cases/PTAB/IPR2019-00628/.

1. Legal framework and level of ordinary skill

• Governing standard: Graham v. John Deere (scope/content of claims; differences over prior art; PHOSITA level; secondary considerations); KSR Int'l v. Teleflex, 550 U.S. 398 (2007) (predictable combinations; "finite number of identified, predictable solutions"; "obvious to try"; a known technique improving a similar device in the same way).
• PHOSITA (proposed): a person with a bachelor's degree in electrical engineering, computer science, or imaging science, plus 3–5 years of experience in color imaging/color management (graphic arts color, device characterization, spectrophotometry), or equivalent. This is a mature, crowded art — the patent's own background section cites work going back to Neugebauer (1956) and lists numerous competing commercial and standards efforts as of 1993–1995. A high level of ordinary skill raises the quantum of knowledge attributable to the artisan and, under KSR, strengthens obviousness.
• Claim-construction posture: several independent claims recite functional language ("enables conversion," "useable in preparation of a rendering transformation… capable of occurring without explicit user intervention," "means for…"), inviting § 112(f) treatment (cf. the MIT v. Abacus constructions surfaced in my search: "aesthetic correction circuitry"/"colorant selection mechanism" construed as means-plus-function with corresponding structures in modules/LUTs — a closely analogous art and a reminder that such terms are construed to the disclosed structures).

2. Element mapping — Set A (input-imaging claims; primary hypothesis)

Using the published claim 55/62 language as the best available proxy (flagged above as unverified against the grant):

Dependent-claim concepts: dynamic-range/saturation/hue mapping (claim 56) → ICC rendering intents + Bonino; gamut descriptors whose inputs are hue and lightness and whose outputs are surface saturation (claim 57) → Gordon et al. and, notably, the ICC Perceptual Reference Medium Gamut (PRMG) — RAH itself asserted that the PRMG is "structured as an array having inputs corresponding to lightness and hue, and having outputs corresponding to gamut surface chroma" in the Xerox complaint (surfaced in my search), which is RAH's admission that the gamut-descriptor structure pre-existed in a 1990s standard; conditioning transformation (claim 58) → ICC/MCT; file-with-header (claim 59) → MCT/TIFF; multiple sensors for illumination (claims 60, 64) → spec's own camera-plus-unitary-colorimeter disclosure and illuminant-substitution (CIE 15.2); GUI (claim 61) → admitted prior art / Photoshop-type UIs.

3. Element mapping — Set B (network / "Virtual Proof" claims; per prior section, if that is the granted scope)

4. The specific combinations and the motivation to combine them

I set out four candidate § 103 grounds. Each is a prima facie case; none is a certainty (see § 6).

Ground 1 — Gordon et al. 1987 + Vincent '518 + ICC Profile Format v3.01 (+ Holub et al. 1988).
Covers Set A. Gordon et al. supplies explicit gamut operators that map an input gamut to an output gamut (unprintable-color rendition) — i.e., the core "map an input gamut onto an output gamut" element. Vincent supplies the sensor/colorimeter and, critically, the express purpose of insuring consistent color across a network. ICC v3.01 (May 8, 1995, in force before the 1996 critical date) supplies the scanner ("scnr") profile, the file structure with header/tags, the stored transform record, and the rendering-intent gamut-mapping mechanism, including invertibility. Holub et al. 1988 supplies the LUT + matrix colorimetric calibration pipeline the claims call "conversion."
Motivation: (i) all three are in the same field (color imaging/management) and address the same problem — color fidelity across devices; (ii) Vincent states the network-consistency objective; (iii) ICC's express purpose is interoperability between independently manufactured devices, which is the very gap Gordon's operators were developed to bridge; (iv) KSR: combining a known colorimetric calibration pipeline with a known gamut operator to produce scanner data representable across devices is the use of known techniques for their known purposes with predictable results.

Ground 2 — Kipphan et al. + Sodergard et al. + Vincent '518 (+ Chan '332 / Sobol '673).
Covers Set B's calibration/verification half. Kipphan teaches spectral colorimeter readings of printed sheets, comparison to aim CIELAB values, generation of color errors, and conversion into ink-density corrections fed to a press control panel. Sodergard teaches on-line frame capture from a moving web for color/registration/defect control. Chan '332 and Sobol '673 teach scanner-in-the-loop closed-loop printer calibration using standardized calibration forms and correction coefficients. Vincent supplies the spectral instrument and network-consistency purpose.
Motivation: (i) all three are press/printer color-control systems — same field, same problem; (ii) each addresses a limitation the others have (Kipphan: color bars only, off-line, no image area, no self-check; Sodergard: insufficient precision; Chan/Sobol: no colorimetric criterion and no gamut/proofing relationship) — KSR "a known technique to improve a similar device in the same way"; (iii) combining what is known to work (automated color-error feedback) with network distribution is a predictable, ergonomic improvement; (iv) the art was motivated by a recognized market need for remote/soft proofing and reduced pressroom waste (the spec's own statement of the problem).

Ground 3 — ICC Profile Format + MCT Spec + Swen '081 (+ Vanhala teleproofing).
Covers the "Virtual Proof" data-structure claim. ICC supplies a standardized, shareable file containing color transforms for defined device classes; MCT (EFI, 1993) supplies the tag/metadata concept for color management; Swen '081 teaches embedding/extracting a device profile into a document — the selfsame practice the spec criticizes (profiles embedded with image data). Vanhala's teleproofing paper supplies distributed proofing.
Motivation: (i) the need to share color transforms between sites so remote parties can view the same color — the express purpose of both ICC and MCT; (ii) optimizing the shared/local split to avoid re-transmitting bulky image data is a routine engineering trade-off the spec itself articulates; (iii) KSR: arranging known information into shared and local files according to which node needs it is a predictable design choice, not an inventive one.

Ground 4 — Giorgianni (+ Tajika) for the capture/transform and multi-colorant claims.
Giorgianni supplies device-independent ("Database Color Encoding") representation of scanner-captured images and colorimetric transforms to output drive values; Tajika supplies a printer with dark/light neutral colorants and UCR. This is the combination Adobe actually litigated at the PTAB against sibling members of this family — useful both as a template and as a caution (§ 6).

Cross-cutting motivations (KSR rationales) common to all grounds:

1. Same field / same problem — every reference is a color-measurement, color-management, or color-reproduction reference; the problem (device-to-device color consistency) is identical.
2. Express statement of intended use — Vincent '518 expressly names "insuring consistent color across a network," supplying motivation to combine it with a multi-node system.
3. Finite, predictable solutions — by 1995 the art had converged on a small set of techniques: spectrophotometry/colorimetry, LUT + matrix linearization, ICC/MCT file formats, gamut operators, GCR/UCR for black, and closed-loop press control. KSR teaches that a finite number of identified, predictable solutions renders the combination obvious.
4. Interoperability pressure — the ICC (1993–95) and MCT (1993) standards existed precisely to let independent devices exchange color meaning; a PHOSITA had strong market motivation to adopt them.
5. Express admissions in the specification — object-oriented coding, GCR, gamut operators, Standard Observer colorimetry, and the LUT/matrix calibration pipeline are all admitted as known; admissions are usable as prior art.
6. Design choice / obvious-not-to-try — segregating transforms from image data, adding a file header, adding a GUI, and providing user color preferences are routine programming/design choices with predictable results.

5. Real-world counter-evidence you must weigh (this cuts against the case above)

The same prior-art family was actually tested at the PTAB, and the Petitioner lost:

• IPR2019-00628 (US 8,416,444), Final Written Decision Aug. 31, 2020 — "Determining No Challenged Claims Unpatentable." Adobe's grounds (Giorgianni+Tajika; ICC v3.01+TIFF 6.0+Beretta+User Guide+Photoshop 3.0; ICC v3.01+TIFF 6.0+Beretta+Herzog; Stone+Tajika) failed, at least in part because RAH successfully argued that the asserted references did not disclose the "plurality of neutral colorants" limitation and its exchangeability with non-neutral colorants (only Tajika's dark/light black did, and the Board was not persuaded the other references could be combined to reach it). Parallel IPRs are IPR2019-00627 ('008), -00629 ('897), -00646 ('761).
• Adobe's appeal of these outcomes was docketed as 21-1067 (Fed. Cir.).

Implication: any § 103 challenge to '314 will be judged against RAH's demonstrated playbook — narrow, limitation-specific distinctions ("the references do not disclose this recited structure") and challenges to the motivation/rationale for combination — not broad "all color management was known" arguments. If '314's granted claims are of the input-imaging/gamut-mapping type (my primary hypothesis), the relevant lesson from -00628 is that generic ICC + generic camera references may be held insufficient unless the record expressly ties them to the recited receptive-gamut → output-gamut mapping and the invertible record limitations; Gordon et al. 1987 and RAH's own admissions about the ICC PRMG are the most direct answers to those two limitations.

6. Where the invalidity case is weak (Patent Owner's likely counter-arguments)

1. Claim-text mismatch. Because the granted claims cannot be verified here, any element-by-element mapping in Sets A or B may be attacking the wrong claim. This is the single biggest risk. Verbatim claim text is the prerequisite (USPTO PatentCenter / granted-PDF claim column, or the litigation claim charts in 2:15-cv-05203 and 1:17-cv-00894).
2. Date problems. On-face references such as Zuber (2001/2003), Barry et al. (2003), and Bullock (1998) postdate the 1996 critical date and cannot support § 102(b)/§ 103 unless proven earlier-filed. A ground built on them fails on the priority date.
3. Teaching away / different objective. The spec distinguishes Chan, Sobol, Kipphan, and Sodergard on the ground that none performs colorimetric calibration to a device-independent criterion in support of proofing; RAH will characterize the prior art as "closed-loop control" rather than "colorimetric characterization + proofing relationship." A robust rebuttal requires a reference (e.g., Giorgianni, ICC) that explicitly couples colorimetry to cross-device rendering, not merely to press consistency.
4. Bonino's gap. Bonino is photometric (single-channel luminance), which the spec argues is insufficient for colorimetric characterization — so Bonino alone cannot supply the colorimetric limitation; it must be paired with Vincent or Van Aken.
5. Secondary considerations. RAH's pleadings assert extensive licensing (five large manufacturers plus 13 end-user licensees) and industry recognition — potentially probative of non-obviousness, though licensing is generally weak evidence absent a nexus (and note that the litigation is license-driven, which cuts against nexus).
6. Specification "anti-teaching." The spec argues ICC's device-class limitation to scnr/mntr/prtr and its embedding of profiles are deficiencies — RAH may argue this teaches away from the ICC route. This is a weak teaching-away argument (identifying a limitation is not teaching away), but it should be pre-empted.

7. Bottom line and confidence

• The strongest § 103 theory is Ground 1 (Gordon et al. 1987 + Vincent '518 + ICC v3.01 + Holub et al. 1988) for the input-imaging/gamut claims, and Ground 2 (Kipphan + Sodergard + Vincent [+ Chan/Sobol]) for the calibration/verification claims. All references predate 1996-02-26; Vincent expressly supplies the network-consistency motivation; RAH's own assertions concede that a hue/lightness-in, surface-saturation-out gamut descriptor existed in the ICC PRMG.
• Confidence: moderate. The technical fit between the cited references and the claim concepts is strong and the motivations are well supported. But (i) I could not verify the verbatim granted claims, and (ii) the analogous PTAB challenges in this family failed on limitation-specific grounds, which is a material caution that a paper obviousness case is not the same as a winnable one.
• Contradiction to flag for the record: the prior "Patent summary" characterizes '314's claims as the network/"Virtual Proof" claims; the publication of the same application (US 2013/0301064) carries input-device claims, and RAH sued Ricoh over cameras. These cannot both be the full story, and the resolution (amendment during 2013–14 prosecution) should be confirmed from the granted claim column before this analysis is relied upon.

What I would do next (if more research were authorized): (1) pull the granted claim 1 exactly from PatentCenter (USPAT 08817314); (2) pull RAH's infringement contentions in 2:15-cv-05203 and 1:17-cv-00894 to see which claims and structures RAH itself maps; (3) obtain the IPR2019-00628 FWD full text and Adobe's Ground 3 (ICC v3.01 + TIFF 6.0 + Beretta + Photoshop 3.0) to test whether that combination reaches the gamut-map-record/invertibility limitations.