`PATENT TRIAL & APPEAL BOARD
`
`
`
`Rosenlund et al.
`In re Patent of:
`U.S. Patent No.: 6,738,155
`Issue Date:
`May 18, 2004
`Appl. No.:
`
`09/364,935
`Filing Date:
`July 30, 1999
`Title:
`System and Method of Providing Publishing
`And Printing Services Via a Communication
`Network
`
`
`
`(1.)
`
`DECLARATION OF PROFESSOR BRIAN P. LAWLER
`
`I am Professor Brian P. Lawler. This declaration is submitted in
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`support of the inter partes review of U.S. Patent No. 6,738,155 (“the ‘155 patent”)
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`filed in the names of Eastman Kodak Company (“Kodak”), Agfa Corporation
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`(“Agfa”), Esko Software BVBA (“Esko”), and Heidelberg (collectively,
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`“Petitioners”).
`
`I.
`
`INTRODUCTION
`
`A.
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` Qualifications
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`(2.) My professional career has spanned close to 50 years. During these
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`years, I have continually gained extensive experience in design, analysis, research,
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`and teaching in general fields of printing and publishing technologies.
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`(3.)
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`I am currently a tenured Associate Professor in the Graphic
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`Communication Department at California Polytechnic State University in San Luis
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`Obispo, California. I was previously the Chairman and a member of the
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`PETITIONERS Ex. 1021, p. 1
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`Instructional Advisory Committee on Computing at California Polytechnic State
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`University, which is the committee responsible for making policy regarding
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`computer services used by the faculty of the University. I am also a faculty
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`advisor to the Shakespeare Press Museum, a working collection of historic printing
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`machinery, and to University Graphic Systems, the management seminar for the
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`student-run printing enterprise.
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`(4.)
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`I was awarded a Masters of Science (M.Sc.) degree in industrial and
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`technical studies from California Polytechnic State University in 2005. I received
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`a Bachelors of Science (B.Sc.) degree in graphic communication from California
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`Polytechnic State University in 1975. I also hold a California Secondary Teaching
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`Credential.
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`(5.) For close to 50 years, I have studied, designed, and worked in the
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`general fields of printing and publishing technologies with a focus on graphic arts
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`technologies, prepress, and photography. For my work in the graphic arts industry,
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`I was named Educator of the Year in 2010 by the Electronic Document Systems
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`Foundation, a graphic arts industry scholarship foundation. I was also honored by
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`the International Graphic arts Education Association in 2006 for my work on
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`developing a taxonomy for the printing industry. I have also received two Awards
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`of Excellence for graphic design from Communication Arts magazine. I am a
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`PETITIONERS Ex. 1021, p. 2
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`member of the board of directors of the Technical Association for the Graphic
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`Arts, an international organization of scientists in the graphic arts industry.
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`(6.) Prior to my current position, I was a Lecturer and an Assistant
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`Professor at California Polytechnic State University and, from 1993-2003, I
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`researched, wrote, and illustrated editorial content for Apple Computer, Inc. on
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`color management and proofing technologies. In 2003, I developed a suite of test
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`documents for Hewlett Packard Company for testing variable-data projects for
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`their Indigo printing press. In 2001, I wrote and illustrated booklets and electronic
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`content for Adobe Systems Incorporated related to the Adobe Trapping
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`Technologies. In 2000, I developed documentation for Hewlett-Packard Company
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`on color management of their wide-format ink-jet printers. In 2001, I developed
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`the online help system for the Nikon SuperCoolScan film scanner. Also between
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`2000 and 2003 I prepared documentation for Nikon to promote their digital
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`cameras to professional photographers. In 2002, I wrote a white paper on the OS
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`X operating system for Apple Computer, Inc. From 1995-1998 I was a trainer for
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`Eastman Kodak Company’s PhotoCD technology. PhotoCD was a product for
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`scanning film to disk and I traveled across the country and abroad to explain this
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`technology to professional photo lab owners. From 1992-2005, I was a partner in
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`the Imaging Prepress and Multimedia Forum and Digital Imaging Seminars, a
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`seminar series sponsored by Apple Computer, Eastman Kodak, and SuperMac
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`PETITIONERS Ex. 1021, p. 3
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`Technologies. My partners and I similarly traveled the country promoting
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`different products from our sponsors—primarily Apple Quadra computers and
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`Kodak scanners. From 1973-1992, I was the Founder, Vice President, and general
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`manager of Tintype Graphic Arts in San Luis Obispo, which was a graphic design,
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`photography, typography, and prepress business.
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`(7.)
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`I have designed and implemented numerous digitized workflow
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`printing systems including a script-based system for automated business card
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`printing using cathode-ray-tube typesetting machines and a similar system for
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`automating the production of professional résumés. I also wrote a meta-language
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`for creating typesetting code for book composition. In 1992, working with another
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`consultant, I converted a large garment printing company from analog printing
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`processes to a full digital system using Macintosh computers, Agfa imagesetters,
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`inline processing machines, and a precision pin-register system for making screen-
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`printing stencils for garment printing. As a consultant, I have made numerous
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`recommendations for commercial offset printing companies for the implementation
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`of digital prepress systems, and methods for managing color in printing production.
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`(8.)
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`I have published a book through Adobe Press, entitled the “Print
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`Publishing Guide,” which is a reference book for those who prepare artwork for
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`printing. I have also published an electronic book, called “Beep!,” which is now in
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`its fifth edition and explains how to use AppleScript. I am the author of “The
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`4
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`PETITIONERS Ex. 1021, p. 4
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`Complete Guide to Trapping,” a book on the subject of color trapping for file
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`preparation in printing (trapping is the intentional overlap of colors to prevent
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`visible register error on a printing press). That book, now out of print, sold nearly
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`10,000 copies. I have also published technical papers in the field of printing and
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`publishing technologies.
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`(9.)
`
`I make this declaration based on personal knowledge and I am
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`competent to testify about the matters set forth herein.
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`(10.) A copy of my lasted curriculum vitae (CV) is attached to this
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`declaration as Appendix A.
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`B.
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`
`
`Basis of My Opinion and Materials Considered
`
`(11.) I have reviewed the ‘155 patent and its file history. I have reviewed
`
`the prior art and other documents and materials cited herein. My opinions are also
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`based in part upon my education, training, research, knowledge, and experience.
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`For ease of reference, the full list of information that I have considered is included
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`in Appendix B.
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`C.
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` Understanding of Legal Standards
`
`1. Obviousness
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`(12.) A patent claim is invalid if the differences between the patented
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`subject matter and the prior art are such that the subject matter as a whole would
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`PETITIONERS Ex. 1021, p. 5
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`have been obvious at the time the invention was made to a person of ordinary skill
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`in the art. I am informed that this standard is set forth in 35 U.S.C. § 103(a).
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`(13.) When considering the issues of obviousness, I am to do the following:
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`(i) determine the scope and content of the prior art; (ii) ascertain the differences
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`between the prior art and the claims at issue; (iii) resolve the level of ordinary skill
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`in the pertinent art; and (iv) consider objective evidence of non-obviousness. I
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`appreciate that secondary considerations must be assessed as part of the overall
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`obviousness analysis (i.e. as opposed to analyzing the prior art, reaching a tentative
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`conclusion, and then assessing whether objective indicia alter that conclusion).
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`(14.) Put another way, my understanding is that not all innovations are
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`patentable. Even if a claimed product or method is not explicitly described in its
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`entirety in a single prior art reference, the patent claim will still be denied if the
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`claim would have been obvious to a person of ordinary skill in the art at the time of
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`the patent application filing.
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`(15.) In determining whether the subject matter as a whole would have been
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`considered obvious at the time that the patent application was filed by a person of
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`ordinary skill in the art, I have been informed of several principles regarding the
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`combination of elements of the prior art:
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`a. First, a combination of familiar elements according to known
`methods is likely to be obvious when it yields predictable results.
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`6
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`PETITIONERS Ex. 1021, p. 6
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`b. Second, if a person of ordinary skill in the art can implement a
`“predictable variation” in a prior art device, and would see the
`benefit from doing so, such a variation would be obvious. In
`particular, when there is pressure to solve a problem and there are
`a finite number of identifiable, predictable solutions, it would be
`reasonable for a person of ordinary skill to pursue those options
`that fall within his or her technical grasp. If such a process leads to
`the claimed invention, then the latter is not an innovation, but more
`the result of ordinary skill and common sense.
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`(16.) The “teaching, suggestion, or motivation” test is a useful guide in
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`establishing a rationale for combining elements of the prior art. This test poses the
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`question as to whether there is an explicit teaching, suggestion, or motivation in the
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`prior art to combine prior art elements in a way that realizes the claimed invention.
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`Though useful to the obviousness inquiry, I understand that this test should not be
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`treated as a rigid rule. It is not necessary to seek out precise teachings; it is
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`permissible to consider the inferences and creative steps that a person of ordinary
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`skill in the art (who is considered to have an ordinary level of creativity and is not
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`an “automaton”) would employ.
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`II.
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`Description of the Relevant Field and the Relevant Timeframe
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`(17.) I have carefully reviewed the ‘155 patent .
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`(18.) Based on my review of this material, I believe that the relevant field
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`for the purposes of the ‘155 patent is printing and publishing systems. I have been
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`informed that the relevant timeframe is on or before July 30, 1999.
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`
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`7
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`PETITIONERS Ex. 1021, p. 7
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`(19.) As described in Section I above and as shown in my CV, I have
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`extensive experience in the field of printing and publishing. Based on my
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`experience, I have a good understanding of the relevant field in the relevant
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`timeframe.
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`III.
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`The Person of Ordinary Skill in the Relevant Field in the Relevant
`Timeframe
`(20.) I have been informed that “a person of ordinary skill in the relevant
`
`field” is a hypothetical person to whom an expert in the relevant field could assign
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`a routine task with reasonable confidence that the task would be successfully
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`carried out. I have been informed that the level of skill in the art is evidenced by
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`prior art references. The prior art discussed herein demonstrates that a person of
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`ordinary skill in the field, at the time the ‘155 patent was effectively filed, would
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`have been familiar with digital workflows, networked printing and publishing
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`systems, and the page design, prepress, and printing activities incorporated into
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`digitized workflows.
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`(21.) Based on my experience, I have an understanding of the capabilities
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`of a person of ordinary skill in the relevant field. I have supervised and directed
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`many such persons over the course of my career. Further, I had those capabilities
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`myself at the time the patent was effectively filed.
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`8
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`PETITIONERS Ex. 1021, p. 8
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`IV.
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`Engineering Principles Underlying the ‘155 Patent
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`(22.) The ‘155 patent relates to a system and method for providing printing
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`and publishing services over a communication network, such as the internet. 1
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`More particularly, the ‘155 patent claims the basic and widely published idea of
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`using a communication network to connect the creative or front-end of the printing
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`and publishing industry (e.g., graphic artists, publishers, and those creating page
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`designs) with the services end (e.g., service bureaus and printing facilities that
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`actually prepare for printing, and print, the designs created by the front-end users).
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`In other words, the ‘155 patent claims a digitized workflow connecting end-users
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`performing page building operations to the companies that perform prepress and
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`printing operations, such as an intermediary service bureau and a printer, or a
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`company performing both functions. For this to be appreciated, a background of
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`the three relevant aspects of the claimed invention – page building, prepress, and
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`printing operations – is provided below.
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`(23.) I will sometimes refer to the state of the art as “before the ‘155
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`patent.” Accordingly, when I speak about the state of the art “before the ‘155
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`patent,” I mean at least before July 30, 1999.
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`1 See, e.g., Ex. 1001 at 1:7-10.
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`PETITIONERS Ex. 1021, p. 9
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`A.
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` Overview of Printing Operations
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`(24.) From the time of Johannes Gutenberg, who brought movable type and
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`mass-produced printing to Western Europe in the mid-15th century, to the mid-
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`20th century, the printing industry relied primarily on a printing process, called
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`relief printing or letterpress, that uses a relief image pressed against a piece of
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`paper to make a printed image. Other printing processes were developed in the late
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`18th century and into the 19th century, but the majority of printed pieces produced
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`well into the 20th century were printed by the same process used by Gutenberg
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`hundreds of years earlier.
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`
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`Figure 1 – “Type” case from type metal. The image is raised in relief above the body of
`the letters. Illustration by the author from a forthcoming book on printing processes.
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`(25.) In 1796, the invention of lithographic printing – printing an image
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`from a slab of limestone – changed the character of illustrative printing, because
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`the image on the limestone could be painted or lettered directly onto the stone.
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`PETITIONERS Ex. 1021, p. 10
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`This form of printing became very popular, but still remained a minority producer
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`because of the complexity of making the image on the stone (backwards!), and the
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`complexity of printing with lithographic stones. The invention of offset
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`lithography in the early 20th century set the stage for the massive shift in printing
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`production that took place over the following 50 years. Offset lithography changed
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`the lithographic process from imaging on slabs of limestone to imaging on thin and
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`light sheets of aluminum, which were subsequently wrapped around the cylinder of
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`a printing press, as shown in Figure 2 (below).
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`
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`Figure 2 – Two printing units of a modern offset lithographic press, showing how sheets of paper
`are printed between the Blanket cylinder and the Impression cylinder. Illustration from
`Print Publishing Guide, by Brian P. Lawler, published by Adobe Press, 2005.
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`(26.) By the mid-1960s, offset lithography was becoming the predominant
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`printing process around the world. Printing plates were inexpensive and easy to
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`PETITIONERS Ex. 1021, p. 11
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`handle, and the processes for making images on those plates were relatively
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`simple. The quality of offset printing is also superior to most relief printing.
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`Offset, as it began to be known, quickly pushed relief printing into the back shop,
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`and ultimately into museums.
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`
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`Figure 3 - A paste-up was made-up of type from letterpress proofs or photocomposition
`machines, and the other line art was added as pasted “photostat” copies of line art made on a
`process camera. Illustration by Brian P. Lawler.
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`(27.) In its early days, offset lithography required typography made by
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`letterpress typesetting (relief images), which were then printed on a smooth white
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`“repro” proofing material with black ink. These images, and other line art were
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`subsequently assembled by an artist onto a heavy paper sheet called a “paste-up”
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`which was comprised of all the parts of a printing project that were strictly black
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`and white (no tonality). The paste-up was then photographed onto a large sheet of
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`film using a large camera called a “process camera.” Photographs, called
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`PETITIONERS Ex. 1021, p. 12
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`“continuous tone” images (or “CT”), were separately re-photographed on the same
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`process cameras. This involved putting a special glass or plastic screen between
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`the image and the photosensitive film in the camera. Light traveling through the
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`lens of the process camera had to pass through the special screen – called a
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`halftone screen – on its way to the film. The continuous-tone image was broken
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`into thousands of microscopically small dots, the size of these dots being
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`proportional to the tones in the original photo. Each dot is solid black, but the size
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`of the dots vary to create the illusion of tonality. After a bit of retouching, the
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`negative was then positioned for exposure to a printing plate, done in a vacuum
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`frame with an ultraviolet light source to expose the printing plate.
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`(28.) For early offset printing, the marriage of the two films was an
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`important step in making a printing plate and the printed product. Men and women
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`skilled in the trade worked over large light tables (glass-topped tables with a light
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`source underneath), assembling the two (or more) films to make a set of “flats”
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`with which a printing plate would be made. The steps involved the accurate
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`positioning of the film pieces, retouching photographic defects (called
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`“opaquing”), masking non-image areas with photo-safe materials (photo-safe red
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`gelatin film and orange paper), and making openings in these same materials to
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`allow light to show through when making the printing plates. The pieces of film,
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`and their plastic and paper carriers, were positioned using small steel register pins,
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`PETITIONERS Ex. 1021, p. 13
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`which allowed the quick and accurate positioning of the various film overlays and
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`masks.
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`(29.) Once the films were completed, a printing plate could be made. These
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`plates are typically made of a porous aluminum sheet, usually 0.012 in. thick. The
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`plate is coated in manufacture with an emulsion that is sensitive to ultraviolet light.
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`In a separate step, the plates are placed face-up in a frame, with the film materials
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`(called “flats”) hung on the register pins on top. A glass cover is closed over the
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`top of the sandwich of materials, a vacuum pump is activated, and the air between
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`the film and the plate is removed. Once the air is removed, the two are said to be
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`in intimate contact. The operator then activated an ultraviolet light to expose the
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`photosensitive areas of the plate through the clear areas of the negative. These
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`exposures were typically from one to three minutes in duration.
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`(30.) If the printed project included photographs, those were exposed in a
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`second exposure on the same plate (called a “double-burn”) in the same vacuum
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`device. Some jobs required several layers of film negatives to be exposed in series
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`to make a complete image on the plate. Once the exposure was complete, the plate
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`was processed to remove the non-image areas (those not exposed to ultraviolet
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`light). The resulting printing plate had a visible image where the parts that print
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`are visible as a green-colored, smooth image, while the non-image areas are
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`smooth to the touch, but show bare aluminum. The finished plates are punched for
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`PETITIONERS Ex. 1021, p. 14
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`press register on a large and very accurate punch table, then bent along one edge to
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`create what is known as a “gripper edge.” Once these modifications are made, the
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`plates are wrapped around the plate cylinder of the offset press, clamped to that
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`cylinder, and prepared for printing by adding ink and water. An offset printing
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`plate will typically last for 50,000 to 100,000 impressions without any special
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`treatment. Plates needed for longer runs can be baked in a special oven that
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`hardens the image area on the plate, giving it greater resistance to wear, and
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`allowing it to be run longer on the press.
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`(31.) In the 1960s, the printing industry put its engineers and inventors to
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`work to eliminate the tedious process of setting type with metal characters,
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`proofing, and making paste-ups of the images (then discarding the metal type).
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`Over the next ten years, manufacturers came to market with ever-better
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`technologies for making type photographically. Several generations of these
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`machines allowed for improvements in quality – optical sharpness, specifically –
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`and speed. Unfortunately, there was no method available for making photographic
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`images with these machines. Photos continued to be handled the same way, by re-
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`photographing them with the big process cameras, making separate film sheets for
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`the photos, and assembling these with the type later on the light table.
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`(32.) As computers became more commonplace in the field of graphic
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`design, companies sought to create an electronic version of the graphic arts
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`PETITIONERS Ex. 1021, p. 15
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`industry. The first desktop computer software for page layout and typography was
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`PageMaker, developed in 1984. The next essential piece in the electronic
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`publishing puzzle was the creation of a page description language (“PDL”), which
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`became PostScript developed by Adobe Systems. These software advancements
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`resulted in the need for an output device capable of high-resolution output. This
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`device, was an imagesetter. An imagesetter is capable of making typographic
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`images and photos on photographic film or photographic paper from PostScript
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`language files, something that had never been done before. The film generated by
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`these imagesetters was almost always used to expose aluminum printing plates for
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`offset lithographic printing.
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`(33.) Imagesetters gave way to machines that bypassed the film, and made
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`marks directly onto the aluminum printing plate. Called platesetters, these devices
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`take the very high-resolution graphic information necessary for a printing job, and
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`use the instructions to modulate various kinds of laser beams to expose (by a
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`variety of means) the image areas of a printing plate directly. The result is higher
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`resolution, tremendous precision, and impressive speed.
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`(34.) The economics of conventional printing, e.g., offset, benefitted from
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`the reduction of labor in making film negatives ready for plate exposure. All of the
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`steps required to position, correct, and expose film flats to aluminum printing
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`plates were reduced essentially to one step: expose the plate.
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`PETITIONERS Ex. 1021, p. 16
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`Figure 4 - This is a cut-away illustration of the Kodak Trendsetter platesetter. Illustration
`by Brian P. Lawler.
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`(35.) Additionally, as a graphic designer worked, he or she would
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`occasionally need to make a printed proof of a graphic file to show to the client or
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`send for copy editing and proofreading. Various technologies worked for this
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`process over the years. Color proofs were sometimes difficult and costly to make,
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`due to the printers and consumable supplies used to make them. For example,
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`similar to imagesetting, color-sensitive films and printing plates were used as color
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`proofing systems. DuPont introduced its Cromalin film-to-plate product in 1972.
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`As a result, most small graphic arts firms used black and white laser printers to
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`make inexpensive proofs of their projects. Eventually, color printers came down
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`PETITIONERS Ex. 1021, p. 17
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`in price, and the quality rose to the point where today most graphic design firms
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`have very capable color laser printers for proofing, and medium-format (up to 24-
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`inch) ink-jet proof printers for making high quality color proofs to show their
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`clients.
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`(36.) In the 1990s, the most common color proof printers used a technology
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`called dye-sublimation, where the image was imparted to a print by a thermal
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`imaging head applied through a series of color ribbons in four successive stages.2
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`The printers were Moderately expensive – about $20,000, and the materials were
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`quite costly – about $10 in supplies for a two page proof. The end product was
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`usually very nice, and it allowed a client to see a facsimile of their project while it
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`was in-process.
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`(37.) With few exceptions, the prepress house would generate the final
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`color proof for the client. This proof, sometimes called a contract proof, would
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`show both the photos and the text at high resolution, and with color as accurate as
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`possible. When the client reviewed this proof, they were expected to sign it,
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`creating a contract with the prepress firm, and the designer. An effort has also
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`been made over the past decade to move proofing off of printed materials and onto
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`2 Ex. 1010 at pp. 69 and 70.
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`PETITIONERS Ex. 1021, p. 18
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`the displays of computers. Called soft proofs, the final document is made in a PDF
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`form that can be displayed on a computer display to get the client’s approval.3
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`B.
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`
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`Electronic Publishing
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`1.
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`Page Building Operations
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`(38.) As discussed above, as computers became more commonplace in the
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`field of graphic design, companies sought to create an electronic version of the
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`graphic arts industry. The first desktop computer software for page layout and
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`typography was PageMaker, developed in 1984.
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`(39.) PageMaker was a computer program from Aldus Corporation, first
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`running on a Macintosh computer, which provided graphic artists the ability to
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`position text and graphics (but not photos in the earliest editions) on a page created
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`on the computer screen. It was the digital equivalent of a paste-up. Among its
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`features was the ability to render an on-screen image of typography in the correct
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`choice of font, size, and position. Several years later, with the invention of digital
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`scanners to convert photographic film to digital images, PageMaker allowed a
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`designer to place a photo into a page layout along with the text. This made it
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`possible, for the first time in history, to create film for a printing plate in one piece
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`– the text and images combined into one sheet of film from an imagesetter.
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`3 Ex. 1009 at p. 83 (discussing how in 1997 Agfa designed a digital workflow that
`allowed for soft proofing); see also id. at pp. 167-168 (discussing the generation of
`PDF soft-proofs using PDFWriter or Distiller).
`19
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`PETITIONERS Ex. 1021, p. 19
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`(40.) One of the issues with page-building is the sheer size of the finished
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`product incorporating digital photos at an adequate resolution for offset printing.
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`A one-square-inch digital photo of adequate resolution for printing on an offset
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`press is 360,000 kilobytes (often referred to as KB) of data. When producing a
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`simple brochure, for example, of 16 pages, it’s not uncommon to have several
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`photos on each page. If every page of a brochure had three images on it, each
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`approximately 3 x 4 in., the volume of photo data would be approximately 13
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`megabytes (usually expressed as MB) of data per page. The volume of photo data
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`alone would total about 210 MB for the 16 page brochure. Text and other graphics
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`would add a small amount to each page, as these items occupy much less space in
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`computer memory and storage. When photos are included in a digital document,
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`the file size grows very quickly.
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`2. PostScript
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`(41.) Defined as a PDL, PostScript is both a programming language and a
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`page description language, one which can control imaging on photo paper, film,
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`paper, or aluminum printing plates. If you want to carry out a simple mathematical
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`process, perhaps multiply 3 times 8, PostScript can do that. It has all of the
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`trappings of a programming language: variables, mathematical operators, Boolean
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`operators (logic functions), pointers, subroutines, storage routines, libraries, etc.
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`PostScript can take the calculations of a page of printing and cause a specific
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`
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`20
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`PETITIONERS Ex. 1021, p. 20
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`
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`machine to put marks onto a substrate – photographic or otherwise. PostScript is
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`also resolution-independent – a very important component of its design – so the
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`same files that printed as a proof also printed as plate-ready negatives on an
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`imagesetter (at graphic arts quality 2,540 ppi resolution).
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`(42.) The PostScript language uses plain-English commands (or close-to-
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`plain-English), it uses simple geometric instructions, Cartesian coordinates, and it
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`can be learned at a very basic level in minutes. For example, the commands to
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`draw a rectangle are:
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`newpath
`144 144 moveto
`144 0 rlineto
`0 144 rlineto
`-144 0 rlineto
`closepath
`stroke
`showpage
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`(43.) This will draw a two-inch square, two inches from the lower-left
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`corner of a page, then print the page. (The unit of measure in PostScript is the
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`Point, which is 1/72 in. or 0.0138 in. The “144” values above are two inches
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`each). In the early days of PostScript there were various software tools for
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`downloading this code to the PostScript device (a laser printer, an imagesetter, or a
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`platesetter). The method for “printing” that page today, and at the time the ‘155
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`patent was filed, is to distill the code into a PDF file using an Adobe application
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`
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`21
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`PETITIONERS Ex. 1021, p. 21
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`
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`called Acrobat Distiller. Once it’s distilled into PDF, it can be opened in Adobe
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`Acrobat or Adobe Reader (or any other PDF-capable program).
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`3. PDF
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`(44.) Adobe upgraded the PostScript language twice in the 1990s to
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`incorporate some of the problems with the language, and then realized that they
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`had to make a fresh start to keep up with the demand for high-quality and high-
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`resolution color graphic arts output. Adobe’s Portable Document Format (PDF)
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`file encoding scheme, released in 1993, became the foundation of the language that
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`has replaced PostScript. PDF has, since before the filing of the ‘155 patent and to
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`this day, the ability to encode documents with PostScript language operators
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`embedded, and various interpreters have been created that convert PDF documents
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`into the control language that makes high-resolution output possible. When you
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`look at the internal code of a PDF file, you will still find some PostScript language
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`functions. Additionally, like PostScript files, PDF files are also PDL files.
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`(45.) PDF supports all of PostScript’s functionality, and then adds support
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`for embedded type fonts, object transparency, object-level and document-level
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`color management, layers, non-printing objects, color trapping, and support for
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`colors beyond the traditional four process colors to support “spot” colors and high
`
`definition color printing (printing with more than the traditional four colors). 4
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`4 See generally Ex. 1013.
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`
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`22
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`PETITIONERS Ex. 1021, p. 22
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`
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`(46.) Rasterizers are the devices that interpret high-level commands in
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`various programming environments, and convert the commands into pixel-based
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`files by applying a matrix grid at the desired resolution over the virtual objects
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`desired to determine which machine spots are to be drawn and which are not.5 A
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`rasterizer is often called a RIP, which stands for Raster Image Processor.
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`4.
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`Storage and Networks
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`(47.) The storage and processing capacity of computers as well as the
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`ability to network computers together also played a large role in the development
`
`of electronic publishing. Files of many gigabytes are needed to expose a printing
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`plate in one pass. The processors, memory chips, and hard drives necessary for the
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`speedy transfer of information from high-level instructions to a spot-by-spot
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`instruction set required maturity. As such, computing power of this magnitude
`
`took years to develop at prices that were acceptable to the graphic arts industry.
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`(48.) One of the main issues was storing the images, text, and other data
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`that would be used for graphic design. Graphic arts scanners were i