Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., No. 13-1600 (Fed. Cir. 2014)Annotate this Case
Digital image processing involves electronically capturing an image of a scene with a “source device,” such as a digital camera, altering the image in a desired fashion, and transferring the altered image to an “output device,” such as a color printer. According to the 414 patent, all imaging devices impose some level of distortion on color and spatial properties because different devices allow for slightly different ranges of colors and spatial information to be displayed or reproduced. Prior art attempted to correct distortions using device-dependent solutions that calibrate and modify the color and spatial properties of the devices and device independent solutions that translate an image’s pixel data from a device dependent format into an independent color space, which can then be translated to output devices at a reduced level of distortion. The patent expands the device independent paradigm to disclose an improved device profile that includes both chromatic characteristic information and spatial characteristic information. Digitech filed infringement suits against 32 defendants. The district court found that all of the asserted claims were subject matter ineligible and invalid under 35 U.S.C. 101: the device profile claims are directed to a collection of numerical data that lacks a physical component or physical manifestation and the asserted method claims for generating a device profile encompass the abstract idea of organizing data through mathematical correlations. The Federal Circuit affirmed.