PTAB

IPR2018-00960

Seabed Geosolutions US Inc v. Fairfield Industries Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Apparatus for Seismic Data Acquisition
  • Brief Description: The ’268 patent relates to self-contained seismic data collection units designed for autonomous operation on the seafloor. The invention describes a single, fully enclosed case housing all necessary electronics, including geophones, a data recorder, a clock, and a power source, and may also include components like a compass and tilt meters for determining the unit's position and orientation.

3. Grounds for Unpatentability

Ground 1: Anticipation over Cranford - Claims 1, 22, 29, and 30 are anticipated by Cranford under 35 U.S.C. §102.

  • Prior Art Relied Upon: Cranford (a 1976 article titled "A Direct-Recording Ocean-Bottom Seismograph").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cranford disclosed every element of independent claims 1 and 22. Cranford described a self-contained ocean-bottom seismograph housed in a small-diameter cylindrical pressure case, which Petitioner asserted is a "fully enclosed, single case" and a "non-spherical pod" as required by the claims. This case was formed from aluminum tubing with two endcaps, meeting the limitation of a first and second plate joined by a circular wall. Petitioner contended that all internal components were disclosed and contained within this single housing, including a gimbal-mounted geophone, a crystal clock, a power source (9 D-cell batteries), and a seismic data recorder (tape deck), with all electrical connections contained therein.

Ground 2: Anticipation over Mattaboni - Claims 1-3, 5-7, 15, 18, 22-24, and 32 are anticipated by Mattaboni under 35 U.S.C. §102.

  • Prior Art Relied Upon: Mattaboni (a 1977 article titled "MITOBs: A Seismometer System for Ocean-Bottom Earthquake Studies").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mattaboni's free-fall, pop-up ocean-bottom seismometer ("MITOBS") disclosed all limitations of the challenged claims. The MITOBS unit housed its sensors, electronics, and recorder in a single, cylindrical pressure vessel with aluminum endcaps and double O-ring seals, which was pressure tested and thus watertight (claim 3). Petitioner asserted this met the "single case" and "non-spherical pod" limitations. Internally, the MITOBS unit contained all requisite components within the pressure capsule, including triaxial seismometers (geophones), a real-time clock, lithium batteries (power source), and a magnetic tape recorder. The system was described as "entirely self-contained" and designed for long-term deployment, thus requiring no external communications or controls during recording (claims 2 and 23). The device also included a radio beacon (claim 15).

Ground 3: Obviousness over Mattaboni and Carrack - Claims 10, 25, and 26 are obvious over Mattaboni in view of Carrack under 35 U.S.C. §103.

  • Prior Art Relied Upon: Mattaboni (a 1977 article) and Carrack (a commercial website describing ocean-bottom seismometers, publicly available since 1999).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Mattaboni provided the base self-contained seismometer unit, as detailed in Ground 2. Carrack taught a geophone package with a baseplate featuring a distinct pattern of ridges and grooves. Petitioner asserted that this baseplate design, which Carrack described as "optimised for shear wave coupling," directly taught the limitations of claims 10, 25, and 26, which require ridges or projections on an external surface to enhance coupling with the earth. The chevron pattern shown in Carrack was argued to be nearly identical to that depicted in Figure 4 of the ’268 patent.
    • Motivation to Combine: A POSITA would combine these references as both pertain to the same field of seafloor seismometers for earthquake detection. A POSITA seeking to improve the seismic data quality of a device like Mattaboni's would be motivated to optimize its physical coupling with the seafloor, a well-known factor in performance. In doing so, it would be obvious to incorporate known and effective baseplate designs, such as the one explicitly taught by Carrack for this exact purpose.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination. Carrack expressly stated that its baseplate was "optimised" and that "high performance" seismometers incorporating such designs had already been successfully built and deployed across a wide range of marine environments, confirming the design's efficacy and predictability.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Mattaboni in view of Willoughby (to add orientation sensors like a compass and tiltmeters, and multicomponent geophones); Mattaboni in view of Willoughby and Jones (to add positional electronics for active navigation); Cranford in view of Willoughby and Prothero (to add a covered, recessed external electrical connector); and Cranford in view of Johnson (to add internal partitions for organizing components within the housing).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5-7, 10, 12, 13, 15-18, 21-30, 32-34, and 38-43 of the ’268 patent as unpatentable.