Interference No. 103,587
areas of the exhibit, the white dots are clustered into pluralities of dots forming variable size
white dots.
The junior party did not file its patent application until February 6, 1990 due to a lack of
funds. While Levien worked on developing Dot 2, a complete commercial system using Dot 1
was marketed in order to raise funds. In a further effort to raise funds, Levien and his father
pursued licensing a previously filed patent application in another field. Funds to pay for the
filing of that application came from Levien’s father. They were successful in licensing that first
patent to a large U.S. corporation in about September 1989, and Raphael Levien used the funds
to pay for the filing of a patent application on Dot 2.
Jack Levien, the inventor’s father, testified to the following effect.
When his son, Raphael, was 16 years old, he became interested in image screening and in
error diffusion screening in particular. He received satellite news photos and printed out images
captured from television signals. Raphael used a digital camera to capture images for his
experiments and he was able to output small test images a few minutes after the images were
captured. The camera was attached to his 286 computer so that he could freeze the image and
print it out on a laser printer. The early printouts were recognizable but poor in quality.
His first significant improvement was called Dot 1. The improvement did not satisfy his
goals in that Dot 1 took too long to print out images. Dot 1 was an improvement in error
diffusion screening even though it took about an hour to produce an 8 by 10 inch screened
image. Raphael tried for six months to improve on Dot 1.
Raphael disclosed the idea for a system called Dot 2 to his father at a restaurant on
November 8, 1987, the date of his father’s wedding anniversary. Raphael sketched a plan on a
napkin of manipulating the pixel on top and both sides of a pixel using recursion and hysteresis.
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