PTAB

IPR2014-00511

Ac Dispensing Equipment Inc v. PrInce Castle LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Dispensing Method and Apparatus Utilizing a Sensor to Determine a Time That a Dispensing Valve is Open
  • Brief Description: The ’497 patent discloses a method and apparatus for dispensing a precise, user-specified volume of liquid from a container. The system determines the required valve open time by using a sensor, such as a load cell, to measure the amount of liquid remaining and then evaluating a polynomial equation that correlates this measurement to the liquid’s flow rate.

3. Grounds for Unpatentability

Ground 1: Obviousness over Pascoe and Wang - Claims 1-8 and 10 are obvious over Pascoe in view of Wang.

  • Prior Art Relied Upon: Pascoe (Australian Patent No. 728,683) and Wang (Chinese Publication No. 101446833).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pascoe disclosed the fundamental apparatus of a liquid dispenser, including a container, a pinch valve, and a load cell to measure the weight of the liquid. Pascoe taught that its microcontroller opens the valve for a "period suitable" to dispense a predetermined amount but failed to detail how this period is calculated. Petitioner asserted that Wang supplied this missing element by teaching the use of a polynomial equation to precisely calculate the required valve open time based on the amount of liquid in the container. Wang’s method involved using curve fitting on experimental data to derive the polynomial coefficients, a technique Petitioner contended was a well-known mathematical principle.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Wang's precise mathematical method with Pascoe's general apparatus to solve the very problem Pascoe left open: how to accurately determine the valve open time. The primary motivation was to achieve the improved dispensing accuracy explicitly taught by Wang, a predictable and desirable goal in the field of liquid dispensers.
    • Expectation of Success: Petitioner contended there was a high expectation of success, as the combination involved applying a known mathematical model for accuracy (from Wang) to a standard dispenser hardware configuration (from Pascoe).

Ground 2: Obviousness over Wang and Ring - Claims 1-4 and 6 are obvious over Wang in view of Ring.

  • Prior Art Relied Upon: Wang (Chinese Publication No. 101446833) and Ring (UK Patent No. 2,184,853).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Wang taught the core concept challenged: using a polynomial to determine valve open time to dispense a precise liquid volume. However, Wang's system specifically used liquid height, measured by a level sensor, as the input variable for its polynomial. Ring was cited to show that using liquid weight, measured by a load cell, was a well-known and interchangeable equivalent for determining liquid height (or "head"). Ring explicitly stated that with weight data from a load cell, the liquid head "can be readily ascertained."
    • Motivation to Combine: A POSITA would be motivated to modify Wang’s height-based system to use a weight-based input from a load cell, as suggested by Ring. The rationale was that load cells are often more precise and less susceptible to errors from environmental vibrations than the level sensors described in Wang. Therefore, this modification represented a simple substitution of one known measurement technique for an equivalent one to achieve the predictable result of improved reliability and accuracy.
    • Expectation of Success: The substitution of weight for height measurement was presented as a routine design choice with predictable outcomes, as both methods were known to be functionally equivalent for the purpose of determining flow rate.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on further combinations. These included adding Gardos (Patent 5,816,445) to the primary combinations to teach the obviousness of a pinch valve having both manual and computer-operable modes for increased versatility. Further grounds added Hernandez (Patent 5,377,868) to teach the known design choice of measuring only a partial weight of the container with the load cell for economic reasons.

4. Key Claim Construction Positions

  • polynomial: Petitioner proposed this term be construed according to its standard mathematical definition: "mathematical expression of one or more algebraic terms each of which consists of a constant multiplied by one or more variables raised to a nonnegative integral power (as a + bx + cx²)." This construction was central to Petitioner's argument that the patent's point of novelty was merely the application of well-known mathematics to a known problem.
  • manually opening the pinch valve: Petitioner argued this phrase should be construed as an operator causing the valve to open for an indeterminate time, without an automatically determined closing time. This was distinguished from a computer-controlled operation where the valve is opened for a precisely calculated duration. This distinction was critical for the obviousness arguments involving manual calibration steps (taught by Wang) and dual-mode operation (taught by Gardos).

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-12 of the ’497 patent as unpatentable under 35 U.S.C. §103.