Only last month, HP Inc. settled cross patent-infringement lawsuits with Memjet involving page-wide inkjet printing, but now another firm, Rampage LLC of Sharon, Massachusetts, is suing HP for patent-infringement involving Raster Image Processor (RIP) software used by an HP PageWide inkjet press for commercial production printing.
In a lawsuit filed on August 17, 2016 with the U.S. District Court for Massachusetts, Rampage contends that it’s the sole owner of U.S. Patent No. 9,053,410, “Raster Image Processor With Printhead Profile Compensation For a Multi-Level Digital Printing Machine,” which was issued on June 9, 2015. The patent names Rampage LLC’s Mitchell J. Bogart as the inventor.
Raster image processor (RIP) software is used by digital printers to produce a raster image also known as a bitmap. Bitmaps are used at a later stage of the printing system to produce the printed output. The input may be a page description language such as PostScript, Portable Document Format, or XPS. The RIP applies either image smoothing or interpolation algorithms to the input bitmap to generate the output bitmap.
In the complaint, Rampage alleges that HP “has and continues to make, use, test, offer to sell, and/or sell within the United States a digital press under the mark PageWide” and that the press “uses a software raster image processor supplied by Global Graphics SE under the mark Harlequin Host Renderer.”
Rampage contends that HP does not have access to the source code of the RIP.
The firm explains that Global Graphics, which provides solutions for printing, PDF technology, and document software, developed an initial method for multi-level screening, but it had significant problems resulting in artifacts displayed in the printed image. Global Graphics shared this problem with Rampage LLC’s Mitchell Bogart. Bogart is said to have invented a solution to the screening problem that he provided to Global Graphics under confidentiality. The solution has two parts that may be practiced alone or together, but ideally together to obtain the highest-quality printed image: “First, change the size of the tonal sub-ranges based upon density measurements of the actual dot sizes for each colorant. Second, overlap each tonal sub-range by a small amount, for example two percent.”
The complaint states that Global Graphics never sold a product for a digital press that included a multi-level screening option until after it learned of the MLS Solution provided to it by Mitchell Bogart.
Rampage claims that HP directly infringed on its patents as currently based upon public information disseminated by Global Graphics by using the technology in its PageWide digital press.
Requested Relief
Rampage is seeking a jury trial, and requesting that the court bar HP from selling within the United States any digital press that infringe on Rampage’s U.S. Patent No. 9,053,410. It is also requesting HP pay Rampage damages, as well as a “reasonable royalty” and costs.
More Resources
- August 2016: HP-Memjet Page-Wide Inkjet-Printing Investigation Formally Dismissed
- July 2016: It’s Over: Memjet and HP Agree to Settle Page-Wide Inkjet-Printing Patent Dispute
- June 2016: U.S. International Trade Commission to Investigate HP’s Memjet Patent-Infringement Claims
- June 2016: HP Names Memjet, Distributors, and OEMs in Complaint with U.S. International Trade Commission
- May 2016: HP Files Complaint with U.S. International Trade Commission, Seeks to Ban Importation of Memjet-Powered Products