Schlumberger Technology Corp v. Integrated Drive Systems LLC

1. Case Identification

• Case #: IPR2018-00603
• Patent #: 9,644,431
• Filed: February 12, 2018
• Petitioner(s): Schlumberger Technology Corporation
• Patent Owner(s): Integrated Drive Systems LLC
• Challenged Claims: 1-26

2. Patent Overview

• Title: Movable Drilling Rig with Stationary Power Supply
• Brief Description: The ’431 patent relates to a movable drilling rig system with an improved electrical subsystem. The system uses a single intermediate conductor to convey power from a stationary, remote power supply to the movable rig, aiming to reduce the complexity and number of cables required for operation.

3. Grounds for Unpatentability

Ground 1: Anticipation over Joy - Claims 1, 7-11, 13, 14, and 21-26 are anticipated under 35 U.S.C. §102 by Joy.

• Prior Art Relied Upon: Joy (JoyGlobal 320XPC Rotary Blasthole Drill Product Overview).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the Joy product overview, describing a commercially available rotary blasthole drill, disclosed every element of the independent claims. Joy taught a movable drilling rig unit on crawlers (a relocation subsystem) that could move between drilling locations. The rig was powered by a remote, stationary power grid via a single intermediate power cable spooled on a conductor carrier reel. Petitioner asserted that Joy’s electrical system explicitly specified an incoming power supply of 4160V, which was stepped down on the rig by a main transformer, thus meeting the limitations for the primary power supply, intermediate electrical subsystem, and rig electrical subsystem recited in the claims.

Ground 2: Obviousness over Joy, Lestz, and Caterpillar - Claims 2, 3, 5, and 6 are obvious over Joy in view of Lestz and Caterpillar.

• Prior Art Relied Upon: Joy (JoyGlobal 320XPC Product Overview), Lestz (Application # 2014/0251623), and Caterpillar (Caterpillar Land Rig SCR Power Modules Specification).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that these dependent claims added nothing more than conventional, well-known power supply configurations to the base system disclosed by Joy. While Joy taught a grid-based power supply, claim 3’s limitation of a generator-based supply was taught by Lestz, which disclosed the interchangeability of grid power and generator power for drilling systems. Caterpillar provided a specific, off-the-shelf generator for drilling rigs that supplied power at 600 VAC, meeting the limitation of claim 2. For claims 5 and 6, Lestz taught using a step-up transformer to convert lower voltage generator power (e.g., 600 VAC from Caterpillar) to a medium voltage (4160 VAC) for efficient transmission over the intermediate conductor.
  • Motivation to Combine: A POSITA would combine these references to adapt Joy’s rig for use in remote locations where a power grid is unavailable, a scenario explicitly contemplated by the Joy reference (e.g., arctic or high-altitude operations). Lestz provided the known design choice of substituting a generator for the grid, and Caterpillar offered a suitable, standard-voltage generator. The combination was a predictable implementation of known technologies to solve a known problem.
  • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved substituting known power sources and using standard transformers, representing a routine and predictable design modification.

Ground 3: Obviousness over Joy and Niemi - Claims 15-18 are obvious over Joy in view of Niemi.

• Prior Art Relied Upon: Joy (JoyGlobal 320XPC Product Overview) and Niemi (Application # 2007/0096538).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that adding control and data cabling to the power system of Joy would have been obvious in light of Niemi. Joy taught the movable rig with its power cable on a reel. Niemi taught a movable mining vehicle (disclosed as potentially being a "rock drilling rig") that used a composite cable structure on a reel, which included both a power conductor and control cabling (e.g., optical fibers for data transmission) for communicating with a remote control room. This composite structure directly teaches claim 15. For claims 17 and 18, which recite discrete control cabling, Petitioner pointed to other embodiments in Niemi where control cabling is spooled on a reel without an integrated power conductor.
  • Motivation to Combine: A POSITA designing the movable rig of Joy would be motivated to enable remote communication for operational control, monitoring, and safety. Niemi provided a known and directly applicable method for achieving this by either integrating control cabling into the power cable (a composite structure) or adding a second reel for discrete control cabling.
  • Expectation of Success: Integrating control cabling with power cables for mobile industrial equipment was a well-established practice, and a POSITA would have reasonably expected this modification to function as intended.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Joy, Lestz, Caterpillar, and Orgeron for claim 4 (housing the generator); Joy and Orgeron for claim 12 (using a foundation pad); and Joy and McClung for claims 19-20 (adding a variable frequency drive and specific rig equipment).

4. Key Claim Construction Positions

• Petitioner argued that the term “relocation subsystem configured to relocate the movable drilling rig unit between plural discrete drilling locations,” found in all independent claims, should be treated as a means-plus-function limitation under 35 U.S.C. §112(f).
• The argument was based on the assertion that "subsystem" is a nonce word, like "system," that fails to recite sufficiently definite structure for performing the claimed function of relocation.
• Petitioner identified the only corresponding structure disclosed in the ’431 patent’s specification as "a walking mechanism, a set of wheels, a set of tracks, or combinations thereof." This construction was central to the anticipation argument, as the crawler tracks of the Joy reference constituted a disclosed corresponding structure.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-26 of the ’431 patent as unpatentable.