Heidelberg Harris v. MAN Roland

CourtDistrict Court, D. New Hampshire
DecidedMarch 25, 1998
DocketCV-95-309-B
StatusPublished

This text of Heidelberg Harris v. MAN Roland (Heidelberg Harris v. MAN Roland) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heidelberg Harris v. MAN Roland, (D.N.H. 1998).

Opinion

Heidelberg Harris v. MAN Roland CV-95-309-B 03/25/98

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Heidelberg Harris, Inc., et a l .

v. C-95-309-B

MAN Roland, Inc., et a l .

MEMORANDUM AND ORDER

Heidelberg Harris, Inc. manufactures and sells the Sunday

Press, a high-speed offset printing press. A competitor, MAN

Roland, Inc., contends that the Sunday Press infringes U.S.

Reissue Patent No. 34,970 (the "'970 patent") both literally and

under the doctrine of eguivalents. Heidelberg challenges both

claims in a motion for summary judgment. It argues that the

Sunday Press does not literally infringe the '970 patent because

the Sunday Press employs a print cylinder with a clamping channel

to secure the printing plate to the print cylinder whereas the

'970 patent covers only presses with clampless print cylinders.

Heidelberg also claims that MAN Roland cannot succeed with its

infringement by eguivalents claim because the patent's inventor surrendered the right to claim that the patent covered print

cylinders with clamping channels when he obtained the patent.

As I explain below, Heidelberg is correct on both counts.

Accordingly, I grant its motion for summary judgment.

I. BACKGROUND

A. Offset Printing

Offset printing is a process in which ink is applied to a

printing plate (also called the printing form or print form), the

inked image is printed onto a rubber-covered cylinder, and the

image is transferred from the cylinder to paper or another

material. Offset presses typically employ three rotating

cylinders to accomplish the printing process: a print cylinder to

which the printing plate is affixed; a transfer cylinder covered

by a rubber transfer form onto which the inked image is printed;

and an impression cylinder that brings the paper into contact

with the transfer cylinder. The typical arrangement of these

three cylinders is depicted in Figure 1.

2 Figure 1

Printing plates traditionally have been mounted on print

cylinders through the use of a clamp extending the length of the

cylinder. This mounting method has limitations, however, because

when a print cylinder includes a clamp, it loses its balanced

configuration, which in turn causes vibratory stresses when the

press is operated at high speeds. In addition, the point at

3 which the ends of the printing plate are clamped to the print

cylinder produces a gap that prevents "endless printing."

B. The Sunday Press

The Sunday Press's print cylinder represents a refinement in

the traditional means of mounting printing forms. Although a

clamp extends the length of the print cylinder, the clamp is much

less cumbersome than in other offset presses, interrupting the

surface only to a negligible extent. The less cumbersome clamp

also results in less weight differential in the print cylinder,

allowing the press to operate at a much higher speed than earlier

offset presses.

C. The '970 Patent

MAN Roland acguired the '97 0 patent from the inventor, Udo

Tittgemeyer. The patent, issued in June 1995, purports to

describe: "[a] printing method and apparatus which uses a sleeve­

shaped printing form attached to a rotating body. The sleeve­

shaped form conveniently permits the printing operation to be

performed continuously and on both sides of the print carrier

simultaneously." All of the patent's pertinent claims describe

the print cylinder as a "cylindrical rotating body." The '970

patent is a reissue of U.S. Patent No. 4,913,048 (the "'048

patent") which also describes the print cylinder as a "cylin­

drical rotating body."

4 1. The Patent Claims

Although the '970 patent contains several independent claims

(each claiming a separate, patented invention), claim 24 is the

only independent claim added as a result of the patent's re­

issuance and the only one MAN Roland asserts that the Sunday

Press infringes. The other claims MAN Roland contends are

infringed -- i.e., claims 25 through 27 -- depend on and,

therefore, include all of the elements recited in claim 24.

Claim 24 reads in pertinent part:

An offset printing apparatus comprising:

a frame;

a cylindrical rotating body supported in said frame;

a replaceable print form comprising at least a first water absorbing layer and a second ink retaining layer defining an ink transferring pattern deposited on an outer surface; said replaceable print form is mounted and radially supported on said cylindrical rotating body;

an ink transfer cylinder rotatingly mounted in said frame adjacent to said replaceable print form; [and]

a transfer sleeve [(i.e., a transfer form)] mounted and radially supported on said ink transfer cylinder

(Def.'s A p p . Supp. Summ. J. at 10-11) (emphases added).

Claim 25 reads: "An apparatus according to claim 24 wherein

said replaceable printing form is a sleeve-shaped print form."

(Def.'s App. Supp. Summ. J. at 11.) Claim 2 6 reads: "An appara-

5 tus according to claim 24 wherein said transfer sleeve exhibits

an outer rubber layer." (Def.'s App. Supp. Summ. J. at 11.)

Claim 27 reads: "An apparatus according to claim 24 further

comprising an air cushion between said transfer cylinder and said

transfer sleeve actuable for lifting said transfer sleeve for

mounting." (Def.'s App. Supp. Summ. J. at 11.)

Although not asserted as infringed, the '970 patent's other

independent claims also describe the print cylinder contemplated

by the inventor as a "cylindrical rotating body." Claim 1 reads:

"A method for offset printing comprising: releasably mounting a

sleeve-shaped print form to a cylindrical routing [sic] body,

said sleeve-shaped print form comprising a first material layer

for absorbing water and a second material layer for absorbing ink

. . . ." (Def.'s App. Supp. Summ. J. at 9) (emphasis added) .

Claim 7 reads: "An offset printing apparatus comprising: a

cylindrical rotating body bearing supported in a frame; ... a

sleeve-shaped print form comprising a first water absorbing layer

and a second ink retaining layer defining an ink transferring

pattern . . . ." (Def.'s App. Supp. Summ. J. at 10) (emphasis

added). Claim 21 reads: "An offset printing apparatus compri­

sing: a frame; ... [a bearing releasably] connected to said

frame and releasably connected to said cylindrical rotating body;

a sleeve-shaped print form comprising at least a first water

6 absorbing layer and a second ink retaining layer defining an ink

transferring pattern . . . (Def.'s App. Supp. Summ. J. at 10)

(emphasis added).

2. The Patent Specification

The '970 patent's specification compares the form and

function of offset printing presses described by the prior art

with the form and function of the various inventions claimed

within the patent. Specifically, it describes how in the prior

art, the clamping mechanism used to secure a flat print form to a

print cylinder prevented seamless printing and caused vibrational

stresses that limited printing velocity. To cure both deficien­

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