`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`EASTMAN KODAK COMPANY, AGFA CORPORATION,
`ESKO SOFTWARE BVBA, and HEIDELBERG, USA
`Petitioners
`
`v.
`
`CTP INNOVATIONS, LLC
`Patent Owner
`___________________________
`
`Case IPR2014-00789
`Patent 6,738,155
`___________________________
`
`
`
`DECLARATION OF ROBERT L. STEVENSON
`IN SUPPORT OF VALIDITY OF U.S. PATENT NO. 6,738,155
`
`
`
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 1
`
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`QUALIFICATIONS ........................................................................................ 3
`
`II. MATERIALS CONSIDERED ........................................................................ 5
`
`III. SUMMARY OF OPINIONS ........................................................................... 6
`
`IV. OPINIONS AND BASES FOR THOSE OPINIONS ..................................... 9
`
`A. One of Ordinary Skill in the Art. .......................................................... 9
`
`B.
`
`C.
`
`D.
`
`Claims 1-9 Are Not Obvious from Jebens, Apogee and OPI
`White Paper ......................................................................................... 10
`
`Claims 1-2. 4-5 and 9 Are Not Obvious from Dorfman,
`Apogee, OPI White Paper and Andersson .......................................... 17
`
`Claims 3 and 6-8 Are Not Obvious from Dorfman, Apogee,
`OPI White Paper, Andersson and Adams II........................................ 26
`
`V.
`
`CONCLUSIONS ........................................................................................... 29
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 2
`
`
`
`
`
`
`
`
`
`I, Robert L. Stevenson, have been retained to testify as an expert on behalf
`
`of CTP Innovations, LLC in this matter. I declare as follows:
`
`
`
`I. QUALIFICATIONS
`
`
`
`1.
`
`I am a professor of electric of electrical engineering and computer
`
`science at the University of Notre Dame, where I have been employed for the last
`
`24 years. I was granted tenure in 1996 as an Associate Professor and promoted to
`
`the academic rank of full Professor in 2002. I serve concurrently on the faculties
`
`of the Department of Electrical Engineering and the Department of Computer
`
`Science and Engineering. I also presently serve as the Associate Chair and
`
`Director of Undergraduate Studies in the Department of Electrical Engineering.
`
`
`
`2.
`
`I received my bachelor's degree from the University of Delaware in
`
`1986 and my Ph.D. from Purdue University in 1990, both in electrical engineering.
`
`My Ph.D. research was in the area of communications and signal processing. I
`
`have been actively engaged in the field of electrical engineering for over 30 years
`
`and in the field of image processing since 1986.
`
`
`
`3.
`
`I am a member of the Institute of Electronics and Electrical Engineers
`
`(IEEE), the Society of Photographic Instrumentation Engineers (SPIE), and the
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 3
`
`
`
`Society for Imaging Science and Technology (IS&T). In addition, I am a panel
`
`member and reviewer for the National Science Foundation.
`
`
`
`4.
`
`For the past 20 years my work has focused on the design of
`
`techniques, hardware, and software for the processing of digital signals using
`
`digital computing devices, such as image processing. My academic research
`
`focuses on developing novel ideas for systems, then publishing and presenting
`
`those ideas to the technical community.
`
`
`
`5. My early work on digital techniques for printing and image capture
`
`devices led to significant interaction with companies developing consumer
`
`products in the early 1990s as they worked to incorporate those ideas into their
`
`products.
`
`
`
`6.
`
`Several
`
`leading computing companies,
`
`including
`
`Intel, Sun
`
`Microsystems, Apple, and Microsoft, have been involved with and supported my
`
`research at Notre Dame. I have also received significant support for my research
`
`from several U.S. Department of Defense agencies.
`
`
`
`7.
`
`I have published over 100 technical papers related to the field of
`
`image processing and digital systems. In addition, I am an inventor of U.S. Patent
`
`No. 6,081,552, “Video Coding Using A Maximum A Posteriori Loop Filter,”
`
`which issued June 27, 2000.
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 4
`
`
`
`
`
`
`
`8.
`
`A copy of my curriculum vitae is attached to this declaration as an
`
`appendix. It includes additional detail regarding my academic and professional
`
`background, and listings of various honors and awards I have received,
`
`professional activities with which I have been involved, papers and other
`
`publications I have authored or co-authored, and matters in which I have testified
`
`during the previous four (4) years.
`
`
`
`9.
`
`I am being compensated for my time working on this case at my
`
`customary hourly rate for all work performed on the case. My compensation is not
`
`in any way related to the outcome of the case.
`
`
`
`II. MATERIALS CONSIDERED
`
`10.
`
`I base the opinions that I express in this declaration on my education
`
`and decades of experience in the fields of electrical engineering and image
`
`processing. I also base my opinions on a review of the materials provided by the
`
`parties in this trial, including a review of United States Patent Nos. 6,611,349 (“the
`
`’349 patent”), 6,738,155 (“the ’155 patent”), and 6,321,231 (“Jebens”), PCT
`
`International Application Publication No. WO 98/08176 (“Dorfman”), as well as
`
`the AGFA Apogee: The PDF-based Production System paper (“Apogee”), Apple
`
`Computer's OPI White Paper (“OPI White Paper”), the PDF Printing and
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 5
`
`
`
`
`
`Publishing guide by Mattias Andersson and others (“Andersson”), and Computer-
`
`to-Plate: Automating the Printing Industry by Richard M. Adams II and Frank J.
`
`Romano (“Adams II”).
`
`
`
`11. The list of materials I reviewed in formulating my opinions consists of
`
`Petitioners’ Corrected Petition (Paper 4) and associated Exhibits (Exhibits 1001-
`
`1022), Patent Owner's Preliminary Response (Paper 8) and associated exhibits
`
`(Exhibits 2001-2013), the Institution Decision (Paper 9), the Deposition Transcript
`
`of Professor Brian P. Lawler (Ex. 2017), and Chapter 8 ("Digital Printing") in The
`
`Columbia Guide to Digital Publishing (Ex.2015).
`
`
`
`III. SUMMARY OF OPINIONS
`
`
`
`12.
`
`I submit this declaration in response to the May 20, 2014 Declaration
`
`of Brian P. Lawler (Ex. 1021), and respond to Professor Lawler's allegations that
`
`certain claims of the ’155 patent are invalid on the following grounds:
`
`
`
`
`
`a. Claims 1-9: obviousness based on Jebens, Apogee and OPI White Paper;
`
`b. Claims 1-2, 4-5, and 9: obviousness based on Dorfman, Apogee, OPI
`
`White Paper and Andersson;
`
`
`
`c. Claims 3 and 6-8: obviousness based on Dorfman, Apogee, OPI White
`
`Paper, Andersson and Adams II.
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 6
`
`
`
`
`
`I understand that the trial is limited to the three grounds identified above. This
`
`declaration is limited to responding to the arguments and testimony related to the
`
`grounds set forth above. Should Petitioners attempt to rely upon an argument or
`
`testimony not previously identified as relevant to the above grounds, I reserve the
`
`right to supplement this declaration to address any such argument or testimony.
`
`Paragraphs 13-15 below summarize my opinion as to the patentability of claims 1-
`
`9 of the ’155 patent.
`
`
`
`13. Claims 1-9 of the ’155 patent are not obvious in light of the
`
`combination of Jebens, Apogee and OPI White Paper because it would not have
`
`been obvious to a person of ordinary skill in the art at the time of the ’155 patent
`
`effective filing date, i.e., July 30, 1999, (“POSITA”) to modify the system of
`
`Jebens to replace the job order developer and conduit function of the central
`
`service facility of Jebens with the Apogee PDF RIP process. More specifically:
`
`
`
`
`
`(a)
`
`Jebens does not disclose that the end-user facility, the printing
`
`company facility, and the central service facility are all coupled to the same
`
`communication network.
`
`
`
`
`
`(b) Neither Apogee nor OPI White Paper disclose an end-user
`
`facility, printing company facility, and central service facility all coupled to the
`
`same communication network.
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 7
`
`
`
`
`
`
`
`14. Claims 1-2, 4-5 and 9 of the ’155 patent are not obvious in light of the
`
`combination of Dorfman, Apogee, OPI White Paper and Andersson because it
`
`would not have been obvious to a POSITA to modify a digital printing system with
`
`variable data and short-run features, as disclosed in Dorfman, to incorporate
`
`printing plates or plate-ready files. More specifically:
`
`
`
`
`
`(a) Dorfman discloses a digital printing system with variable data
`
`and short-run features. These systems do not use printing plates or plate-ready
`
`files. The suggested modification would require modifying the principle of
`
`operation of Dorfman, and render it unfit for its intended purposes.
`
`
`
`
`
`(b) Dorfman does not describe a separate central service facility
`
`and printing company facility. Dorfman describes these functions as all being
`
`present at the same remote location: i.e., the facilities of a commercial printing
`
`service.
`
`
`
`15. Claims 3 and 6-8 of the ’155 patent are not obvious in light of the
`
`combination of Dorfman, Apogee, OPI White Paper, Andersson and Adams II
`
`because, as discussed above with regard to claims 1-2, 4-5 and 9, it would not have
`
`been obvious to a POSITA to modify the digital printing system of Dorfman,
`
`which does not involve printing plates or plate-ready files, to incorporate printing
`
`plates or plate-ready files. More specifically:
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 8
`
`
`
`
`
`
`
`
`
`(a) Dorfman discloses a digital printing system with variable data
`
`and short-run features. These systems do not use printing plates or plate-ready
`
`files. The suggested modification would require modifying the principle of
`
`operation of Dorfman, and render it unfit for its intended purposes.
`
`
`
`
`
`(b) Dorfman does not describe a separate central service facility
`
`and printing company facility. Dorfman describes these functions as all being
`
`present at the same remote location: i.e., the facilities of a commercial printing
`
`service.
`
`
`
`IV. OPINIONS AND BASES FOR THOSE OPINIONS
`
`
`
`
`
`A. One of Ordinary Skill in the Art
`
`16. Professor Lawler expresses the opinion that “a person of ordinary skill
`
`in the field, at the time the ’155 patent was effectively filed, would have been
`
`familiar with digital workflows, networked printing and publishing systems, and
`
`the page design, prepress, and printing activities incorporated into digitized
`
`workflows.” Lawler Decl. (Ex. 1021), at ¶ 20. I accept this definition for purposes
`
`of this trial. At the time of the invention, I possessed at least these minimum
`
`credentials, as well as others. I am therefor well qualified to testify regarding what
`
`one of skill in the art would have understood at the time of the invention.
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 9
`
`
`
`
`
`B. Claims 1-9 Are Not Obvious from Jebens, Apogee and OPI White
`
`Paper
`
`17.
`
`I understand that a patent claim is invalid for obviousness if the
`
`
`
`
`
`
`differences between the subject matter of the claim and the prior art are such that
`
`the subject matter as a whole would have been obvious at the time the invention
`
`was made to a POSITA to which the subject matter pertains. I understand that an
`
`obviousness analysis may also take into account certain objective indicia of
`
`nonobviousness, such as copying, commercial success, and long-felt need.
`
`
`
`18. A POSITA would recognize that claim 1 requires an end user facility,
`
`a central service facility, and a printing company facility coupled to the same
`
`communication network. A POSITA also would recognize that claim 1 also
`
`requires that the central service facility provide storage, file processing, remote
`
`access, and content management operations. A POSITA further would recognize
`
`that claim 1 requires that the printing company facility provide printing operations,
`
`including providing imposition operations and generating a plate-ready file from a
`
`PDF file. See ’155 Patent (Ex. 1001), claim 1, elements (a), (c) and (e).
`
`
`
`19. Claim 1 is careful to specify that the end user facility is coupled to a
`
`communication network, the printing company facility is coupled to said
`
`communication network, and the central service facility also is coupled to said
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 10
`
`
`
`communication network. See id., claim 1, elements (a), (c) and (e). The
`
`specification supports this interpretation, and notes that the network can be a
`
`private network or a public network. Id. at 4:25-33. As the specification notes, the
`
`intent is to integrate various processes into "one real time system." Id. This
`
`addresses the problem with delays and the fragmented nature of convention
`
`printing production systems. Id. at 1:52-65. This integration is reflected in the
`
`preamble to claim 1, and is made a part of the claims through the requirement of a
`
`single communication network.
`
`
`
`20.
`
`Jebens does not disclose an end user facility, a central service facility,
`
`and a printing company facility all coupled to a single communication network.
`
`Jebens speaks about communications between an advertising agency and a host
`
`system, and between the host system and jobbers or suppliers (i.e., printers and the
`
`like). Jebens (Ex. 1005), at 4:52-65. Jebens, however, does not disclose or
`
`suggest that the first user (e.g., advertising agency) directly communicates with the
`
`second user (e.g., printing facility). Figure 1 of Jebens (reproduced below) depicts
`
`an embodiment of Jebens's data management and work-order delivery system:
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 11
`
`
`
`
`
`Id. at 4:20–23. The system comprises a host system 10 in communication with a
`
`variety of users, such as browsers and client orderers 12, image providers 14, and
`
`suppliers 16. Id. at 6:52–65. The host system software includes, inter alia, an
`
`image database that archives low and high resolution copies of digital image files.
`
`Id. at 8:9–13. The system is “ideally suited for facilitating publication and the
`
`like.” Id. at 4:66–67. Image providers 14 may include a corporation that stores
`
`digital images of its products on host system 10 to more efficiently use its in-house
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 12
`
`
`
`computer storage facilities. Id. at 4:67–5:5, 6:55–60. Browsers and client orderers
`
`12 may include an advertising agency that the corporation hires to create a
`
`brochure using the stored images, and suppliers 16 may include the printer that will
`
`print the finished brochure. Id. at 5:5–10, 6:54–65.
`
`
`
`21.
`
`Jebens discloses that communication between host system 10 and
`
`users 12 and 16 “can be effected by any known means of connectivity,” such as
`
`“through local area networks or wide area networks,” or “hardwired to one another
`
`as an intranet.” Id. at 6:66–7:4–20. Users 12 and 16 (corresponding to the
`
`advertising agency and several options for printing companies, respectively) do not
`
`disclose the use of a single network. Instead, as shown on Figure 1 of Jebens, user
`
`12 communicates with the hosting system via a network separate and apart from
`
`the communication network used by hosting system to communicate with one of
`
`the several printing companies that are separate users 16. Jebens shows no
`
`communication network established between user 12 and users 16. Once user 12
`
`sends the work order to the host site, the host system must establish a second
`
`communication network by dialing or sending a network request to the supplier,
`
`establishing a valid communication link, passing log in information before it can
`
`transmit the job order. Id. at 2:40-42, 60-63. Such separate and distinct networks
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 13
`
`
`
`make sense in Jebens because the host system is logging into the communication
`
`network for a specific printing company as selected by user 12 or the host system.
`
`
`
`22. Jebens further discusses this in the context of “work orders” and “job
`
`orders.” A “work order" is the set of data transmitted from the first user to the
`
`host system requesting routing to a second user (e.g., printing facility). Id. at
`
`14:11-19. The work order includes a set of instructions identifying the second
`
`user, and identifying any files to be sent from the database. Id. at 14:15-18. The
`
`work order also includes local files created outside of the system (such as the PDL
`
`file or other document created by the first user). Id. at 14:11-25; 14:36-54; 22:51-
`
`55. A “job order” is a collection of data assembled or other developed by the host
`
`system for routing to the second user. Id. at 14:27-29. The job order includes the
`
`created document received from the first user, other local files received from the
`
`first user, and any original data files (such as high resolution image files identified
`
`in the work order). Id. at 14: 27-34; 14:45-50. The local documents contained in
`
`the work order, and the original high resolution data files, are compressed and
`
`forwarded to the receiving user (i.e., printing facility). Id. at 14:55-66. The
`
`Abstract of Jebens refers to this process as routing a job order compiled by the job
`
`order developer. Id. at Abstract; see also id. at 4:59-62 (“As explained below, the
`
`system is also adapted to serve as a job order developer and conduit for routing
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 14
`
`
`
`
`
`files from a browser or client such as an advertising agency to a jobber or supplier
`
`such as a printer.”).
`
`
`
`23. Thus, the first user logs into the host site to browse and download
`
`images, and to upload a work order to the work site. Id. at 20:19-33; 21:29-36.
`
`Once the first user sends the work order to the host site, id. at 22:36-43, the host
`
`site prepares a job order for transmission to the second user, id. at 22:44-55. The
`
`host site must establish a second communication network to connect to the
`
`destination site by dialing or sending a network request, establishing a valid
`
`communication
`
`link, and then passing log in information before finally
`
`transmitting the job order. Id. at 22:59-63. It is the host system of Jebens that
`
`sends an email or fax to the second user to notify them that a job order is being
`
`sent, and it is the host system that sends an email to the first user notifying them
`
`that the order has been sent and received by the specified destination. Id. at 15:1-
`
`17; 23:3-8. There is no communication between the first user and the second
`
`users, and no communication network established between the first user and the
`
`second users.
`
`
`
`24.
`
`Jebens thus directs a particular job order to a particular supplier (e.g.,
`
`printer facility) by having the host site logging into each particular supplier's local
`
`network or system independently as needed. While the communications between
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 15
`
`
`
`
`
`the host system and the suppliers may occur over the Internet, or private networks,
`
`this should not be confused with an end user facility, a central service facility, and
`
`a printing company facility all coupled to a single communication network. In
`
`fact, changing the system of Jebens to do so would change the principle of
`
`operation of Jebens, and render it unfit for its intended purpose as a job order
`
`developer and conduit for routing files from a browser or client such as an
`
`advertising agency to a jobber or supplier such as a printer. Id. at Abstract; see
`
`also id. at 4:59-62. Jebens makes readily apparent that its system is intended to
`
`enable the first user to cause the host system to transit documents created by the
`
`first user and copies of high resolution images stored by the host system to one of a
`
`number of potential suppliers, who each have their own, local communications
`
`networks for receiving submission of job orders. Id. at 22:26-31; 23:36-44.
`
`
`
`25.
`
`I note that Apogee is used to provide a teaching of normalizing
`
`incoming files into PDF digital master files and subsequently rendering those files
`
`through the PDF RIP process into PIF files. See Apogee (Ex. 1007), at 6-7. It
`
`does not disclose an end user facility, a central service facility, and a printing
`
`company facility all coupled to a single communication network, and thus does not
`
`cure the defect discussed above for Jebens.
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 16
`
`
`
`
`
`26.
`
`I note that OPI White Paper is used to provide a teaching of
`
`performing imposition operations at a printing company facility. See OPI White
`
`Paper (Ex. 1008), at pp. 33, 40. It does not disclose an end user facility, a central
`
`service facility, and a printing company facility all coupled to a single
`
`communication network, and thus does not cure the defect discussed above for
`
`Jebens.
`
`
`
`27. A POSITA would recognize that claims 2-9 require the same elements
`
`as claim 1 as described above, and thus would not find it obvious to combine
`
`Jebens, Apogee and OPI White Paper in the suggested manner for these claims for
`
`the same reasons given above with regard to claim 1.
`
`C. Claims 1-2, 4-5 and 9 Are Not Obvious from Dorfman, Apogee,
`
`OPI White Paper and Andersson
`
`28. A POSITA would recognize that the Dorfman reference describes a
`
`
`
`
`
`
`“response on demand” digital printing system with variable data. A digital printing
`
`system is one where a digital-based file is printed directly to a variety of media
`
`without the use of printing plates. Digital printing systems are an alternative to
`
`traditional offset printing methods which require the creation and use of printing
`
`plates. Because it does not involve printing plates, it allows for on-demand
`
`printing, short turnaround times, and variable data or variable information printing.
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 17
`
`
`
`Digital printing systems also are often used for customized printing or personalized
`
`printing.
`
`
`
`29. Chapter 8 (“Digital Printing”) in The Columbia Guide to Digital
`
`Publishing (Ex. 2015) (a true and correct copy of which is filed herewith) provides
`
`a comprehensive overview of digital printing, and
`
`the advantages and
`
`disadvantages of digital printing as opposed to traditional offset printing methods
`
`using printing plates. One such factor is cost:
`
`
`
`Offset has a higher cost for starting up a job, because plates
`
`must be prepared and some paper is wasted during the initial run-up to
`
`the first good sheet. The binding process that goes with offset (print
`
`in signatures, fold, gather, bind, and trim) can also be more expensive
`
`than the binding process for digital printing, where large signatures
`
`and gathering are not required. But, at present, the cost per page of
`
`the actual printing is lower for offset, and this is the dominant cost in
`
`long runs. So short runs are more economical with digital printing,
`
`and longer runs are more economical with offset.
`
`Id. at p. 53 (original page 378). More specifically, with regard to short-run
`
`printing:
`
`
`
`Some costs are incurred in offset printing before the first good
`
`sheet comes off the press. Two such cost areas, the cost associated
`
`with platemaking and the cost associated with the wasted sheets used
`
`in getting the press “up to color,” are avoided entirely in digital
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 18
`
`
`
`
`
`printing. A digital device needs no plate and switches instantly from
`
`one job to the next. Normally, neither paper nor time is wasted during
`
`the switch. This means that if the print run is short, the overall cost
`
`for printing a job digitally can be less than offset even though the cost
`
`per page is higher with digital printing.
`
`Id. at p. 55 (original page 380).
`
`
`
`30. The Columbia Guide also notes that digital printing is used for “on
`
`demand” printing:
`
`Printing on demand is one of two types of printing (the other is
`
`variable-data printing)
`
`that digital printing can address but
`
`conventional printing, which is restricted to producing multiple copies
`
`of the same document, cannot.
`
`
`
`Most printing that is done in the office and the home could be
`
`classified as printing on demand. Items are printed as the need arises,
`
`and only the quantity that can be immediately used in produced--often
`
`just one copy.
`
`Id. at p. 53 (original page 378).
`
`
`
`31. Dorfman clearly describes a “response on demand” digital printing
`
`system with variable data capabilities. Dorfman addresses a problem for users
`
`building dynamic HTML pages in the context of a digital printing system for
`
`producing customized printed materials with variable data. Dorfman specifically
`
`refers to “[v]ariable printing capabilities …for response-on-demand applications,”
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 19
`
`
`
`and to the user “providing some variable or selectable data that would be used to
`
`create a form based on the layout instructions.” Dorfman (Ex. 1006), at p. 2:21-28.
`
`The “user provided variable data” is fed into the system and inserted into a
`
`template for the final printing. Id. at p. 3:10-14. This allows the production of
`
`“customized printing materials”:
`
`
`
`In accordance with one aspect of the present invention, users
`
`are provided with a visual representation of a template for customized
`
`printed materials before user data is entered so the user can better
`
`understand and visualize how the data will ultimately be placed in the
`
`final document.
`
`Id. at p. 3:24-27.
`
`
`
`33. Dorfman describes this as a “response on demand” system:
`
`
`
`The present invention relates to a technique for creating
`
`customized documents or other printed materials. More particularly,
`
`the present invention relates to a technique for creating customized
`
`printed materials utilizing
`
`template
`
`formats, stored
`
`reference
`
`information and user input data.
`
`
`
`It is desirable in modern printing systems to allow a user to
`
`readily customize printed materials for a particular need. For
`
`example, a user may select stored images and combine them with user
`
`specified input data to produce a point of sale (POS) display or the
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 20
`
`
`
`like. Such a “response on demand” system increases production
`
`flexibility and simplifies the design process. …
`
`Id. at p. 1:13-21.
`
`
`
`33. Dorfman also clearly describes examples of applications of such a
`
`system:
`
`
`
`The need for customized printed materials, of course, extends
`
`beyond point of sale displays. For example, direct mail marketers
`
`continually develop advertising flyers and coupons which are sent
`
`through the mail to prospective customers. Event planners and
`
`promoters may need printed materials for use in promoting concerts,
`
`sporting events, live theatrical performances, etcetera. Similarly,
`
`various organizations sometimes utilize custom printed materials to
`
`announce seminars, annual meetings, and the like. In other words, the
`
`possible applications for customized printed materials are virtually
`
`unlimited.
`
`Id. at p. 1:31-32; p. 2:1-6.
`
`
`
`34. The process for the generation of customized printed materials is
`
`shown in Figure 1A of Dorfman (reproduced below):
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 21
`
`
`
`
`
`
`
`35.
`
`I further note that Figure 1 of Dorfman (reproduced below) shows the
`
`printer at the production printing system (reference numeral 10) as a digital printer,
`
`not as a traditional offset printing press that would use printing plates. The use of
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 22
`
`
`
`this image, in conjunction with the textual description of the system in Dorfman,
`
`establishes that Dorfman is describing a digital printing system.
`
`
`
`36. This ability to vary some of the elements in the printed document to
`
`
`
`achieve some level of customization and response-on-demand printing is
`
`fundamentally different from the computer-to-plate (“CTP”) system in the ’155
`
`patent. The production of a printing plate is relatively expensive and as a result is
`
`only used when producing a large volume of identical documents. The printing
`
`
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 23
`
`
`
`plate approach to large volume printing is not applicable to situations involving on-
`
`demand or customized printing materials, as described in Dorfman. As Dorfman
`
`notes, it is common for a user to need the materials in a short time frame, or desire
`
`changes at the last minute. Further, custom promotional materials often change on
`
`a frequent basis. Id. at p. 2:1-12. So, while printing plates are inexpensive when
`
`producing many identical copies of a document, they would be extremely
`
`expensive if one were to attempt to produce multiple unique documents, or smaller
`
`runs of documents requiring frequent changes or variable data. As a result, a
`
`POSITA would not use a digital printing system as disclosed in Dorfman to
`
`produce printing plates or plate-ready files, which is the raison d’être of the CTP
`
`system in the ’155 patent.
`
`
`
`37. Because Dorfman is a “response on demand” digital printing system
`
`using variable data, a POSITA would understand that the system of Dorfman does
`
`not and would not involve the generation of printing plates or plate ready files.
`
`Apogee is used for the teaching of generating a plate-ready file, Apogee (Ex.
`
`1007), at pp. 6-7, and thus there would be no motivation to modify Dorfman in
`
`view of Apogee. In fact, attempting to modify Dorfman to involve the generation
`
`of printing plates or plate ready files would change its principle of operation. It
`
`would no longer be a “response on demand” digital printing system, and thus
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 24
`
`
`
`
`
`would be unfit for its intended purpose of providing on-demand or customized
`
`printing materials. Accordingly, a POSITA would not find it obvious to combine
`
`Dorfman with Apogee to add the generation of printing plates or plate ready files
`
`to a “response on demand” digital printing system using variable data.
`
`
`
`38.
`
`I note that OPI White Paper is used to provide a teaching of
`
`performing imposition operations at a printing company facility. See OPI White
`
`Paper (Ex. 1008), at pp. 33, 40. It does not cure the defects listed above for the
`
`suggested combination of Dorfman and Apogee, and provides no teaching,
`
`suggestion or motivation to add the generation of printing plates or plate ready files
`
`to a “response on demand” digital printing system using variable data.
`
`
`
`39.
`
`I note that Andersson is used to provide a teaching of digital content
`
`management elements and types of servers. Andersson (Ex. 1009), at pp. 59-69,
`
`188. It does not cure the defects listed above for the suggested combination of
`
`Dorfman, Apogee, and OPI White Paper, and provides no teaching, suggestion or
`
`motivation to add the generation of printing plates or plate ready files to a
`
`“response on demand” digital printing system using variable data.
`
`
`
`40.
`
`I further observe that Dorfman equates the central service facility and
`
`the printing company facility, which are described as all being present at the same
`
`remote location, e.g., the facilities of a commercial printing service. The
`
`CTP Exhibit 2014
`Eastman Kodak v. CTP Innovations
`IPR 2014-00789
`Page 25
`
`
`
`
`
`commercial printing service facility thus includes (i) a memory that stores a
`
`reference library, low resolution images, high