Schlumberger Technology Corp v. Integrated Drive Systems LLC

1. Case Identification

• Case #: IPR2018-00604
• 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 a stationary primary power supply. The purported improvement is an electrical subsystem that uses only a single intermediate conductor to connect the power supply to the rig, thereby eliminating the need for numerous intermediate cables and complex handling systems like drag links.

3. Grounds for Unpatentability

Ground 1: Obviousness over Joy, Lestz, and Nabors - Claims 1, 7-14, 21-26 are obvious over Joy, Lestz, and Nabors.

• Prior Art Relied Upon: Joy (a 2013 JoyGlobal product overview), Lestz (Application # 2014/0251623), and Nabors (a 2013 Nabors drilling rig brochure).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of these references discloses all elements of the independent claims. Joy taught a movable drilling rig on tracks with a mast and an intermediate power cable on a reel configured to carry 4160 VAC. Nabors taught a movable rig that drills multiple wells on a single pad, powered by a remote, stationary generator-based power supply subsystem. Lestz taught the specific electrical architecture of using transformers to step down power from a medium voltage (4160V) intermediate conductor to a low operating voltage (600V) at the rig, expressly for the purpose of minimizing the number of required cables.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these teachings for a predictable result. Joy’s rig was designed for tough, remote locations where a stable power grid may be unavailable. A POSITA would be motivated to replace Joy’s reliance on a power grid with a more reliable, on-site generator system as taught by Nabors. Lestz provided the known and logical method for connecting such a system, using a single medium-voltage cable and transformers to reduce cable clutter, a benefit explicitly described in Lestz.
  • Expectation of Success: The combination involved substituting one known power source (a grid) with another (generators) and using a conventional electrical distribution scheme (step-down transformers) to achieve the predictable outcome of a mobile rig with a reliable, remote power source.

Ground 2: Obviousness over Joy, Lestz, Nabors, and Caterpillar - Claims 2-6 are obvious over Joy, Lestz, Nabors, and Caterpillar.

• Prior Art Relied Upon: Joy (product overview), Lestz (application), Nabors (brochure), and Caterpillar (a 1999 power module specification).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added the Caterpillar reference to the combination from Ground 1 to address dependent claims requiring a primary power supply providing 600 VAC (claims 2-3) and housed in a "powerhouse unit" (claim 4). The Nabors reference explicitly disclosed using Caterpillar model 3512C and 3516 engines. The Caterpillar specification sheet for these exact models confirmed they were designed for "prime rig power on SCR electric drill rigs" and outputted alternating current at a standard 600 volts. Caterpillar and Nabors also depicted these generators within a rectangular housing, which Petitioner asserted meets the "powerhouse unit" limitation.
  • Motivation to Combine: A POSITA, having chosen to implement the generator system from Nabors, would have been motivated to consult the generator manufacturer’s (Caterpillar’s) specifications to determine its standard operational parameters, such as output voltage. The use of a standard 600 VAC output and housing the generators in a protective enclosure were presented as conventional and predictable design choices.

Ground 3: Obviousness over Joy, Lestz, Nabors, and Niemi - Claims 15-18 are obvious over Joy, Lestz, Nabors, and Niemi.

• Prior Art Relied Upon: Joy (product overview), Lestz (application), Nabors (brochure), and Niemi (Application # 2007/0096538).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground added Niemi to the base combination to address claims requiring control cabling. Claim 15 recites a "composite intermediate cable structure" that includes both the power conductor and control/data cabling. Niemi taught a movable mining rig (which may be a drilling rig) powered via a cable on a reel. Crucially, Niemi disclosed that this supply cable could be a composite structure containing both power conductors and optical fiber cables for data transmission between the rig and a remote control unit. This directly taught the limitations of claims 15 and 16. Niemi also disclosed an embodiment with only control cabling on a reel, which Petitioner mapped to claims 17 and 18.
  • Motivation to Combine: A POSITA designing the movable rig system from Joy/Nabors/Lestz would find it advantageous to add a means for remote communication and control. Niemi provided a known and interchangeable technique for achieving this by either integrating control cabling into the power cable (for a composite structure) or using a separate control cable reel, both yielding the predictable improvement of adding data communication capabilities.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 19 and 20 based on the combination of Joy, Lestz, Nabors, and McClung (Application # 2011/0280104). McClung was used to teach the inclusion of conventional rig equipment, such as a variable frequency drive (VFD) and a list of other components like a top drive and hoist.

4. Key Claim Construction Positions

• "relocation subsystem configured to relocate the movable drilling rig unit..." (Claims 1, 21, 24): Petitioner argued this term should be treated as a means-plus-function limitation under 35 U.S.C. §112(f). The argument was that "subsystem" is a "nonce" word, like "means," that fails to recite a sufficiently definite structure. Petitioner identified the only corresponding structure disclosed in the ’431 patent’s specification for performing the recited function as "a walking mechanism, a set of wheels, a set of tracks, or combinations thereof."
• "powerhouse unit" (Claim 4): Petitioner argued that based on the specification, the broadest reasonable interpretation (BRI) of this term is simply "a structure housing a power supply."

5. Arguments Regarding Discretionary Denial

• Petitioner disclosed that it was concurrently filing another IPR petition (IPR2018-00603) against the same patent based on different grounds. To preemptively argue against a discretionary denial for serial petitions, Petitioner requested that the Board exercise its discretion to institute review of both petitions, noting that no time had elapsed between the filings and the patent owner had not yet filed a preliminary response.

6. Relief Requested

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