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IPR2018-00961

Seabed Geosolutions US Inc v. Fairfield Industries Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Ocean Bottom Seismometer Package
  • Brief Description: The ’761 patent discloses self-contained, continuous-recording ocean bottom seismometers (OBSs). The invention is characterized by a low-profile, symmetrical, and disk-shaped casing that houses core OBS components, including geophones, a power source, a data recorder, and a clock.

3. Grounds for Unpatentability

Ground 1: Obviousness over Mattaboni, Sutton, Schmalfeldt, and Jones - Claims 1, 3-6, 8, 9, and 11-22 are obvious over the combination of these references.

  • Prior Art Relied Upon: Mattaboni (a 1977 journal article), Sutton (a 1987 journal article), Schmalfeldt (a 1983 technical report), and Jones (Patent 6,951,138).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Mattaboni disclosed a self-contained OBS with all the internal components required by independent claim 1 (geophone, clock, power source, recorder), but housed them in a tall, cylindrical pressure case. Sutton taught that the optimal shape for an OBS case to minimize noise from ocean currents is a "low profile" with "maximum symmetry about the vertical axis," directly teaching the shape claimed in the ’761 patent. Schmalfeldt and Jones were cited as teaching self-contained OBSs that implemented Sutton's optimal design principles, disclosing low-profile, disk-shaped, symmetrical casings ("discoid in shape" per Jones) containing the necessary internal components. Thus, the combination disclosed all limitations of claim 1 and its challenged dependents.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve OBS performance. Sutton explicitly identified the problem of noise and distortion caused by the non-optimal shape of prior art OBSs like Mattaboni's tall cylinder. Sutton provided the solution: modifying the case to be low-profile and symmetrical. A POSITA would have been motivated to apply Sutton’s clear teachings to a known OBS system like Mattaboni to improve its data quality. Schmalfeldt and Jones, which both disclose OBSs with the optimal form factor, would have confirmed the feasibility and advantages of this combination.
    • Expectation of Success: A POSITA would have a high expectation of success. The combination involved modifying the shape of a known device's housing based on established principles of fluid dynamics, not redesigning complex internal electronics. Petitioner noted that by the patent's 2003 priority date, advances in battery technology and solid-state memory made it even easier to package the components of an older system like Mattaboni into the more compact, low-profile form factor taught by Sutton and exemplified by Schmalfeldt and Jones.

Ground 2: Obviousness over Cranford, Sutton, Schmalfeldt, and Jones - Claims 1, 2, and 10 are obvious over the combination of these references.

  • Prior Art Relied Upon: Cranford (a 1976 journal article), Sutton (a 1987 journal article), Schmalfeldt (a 1983 technical report), and Jones (Patent 6,951,138).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a similar argument to Ground 1, but substituted Cranford for Mattaboni as the primary reference disclosing the internal OBS components. Petitioner asserted that Cranford, like Mattaboni, disclosed a self-contained OBS with a geophone, clock, batteries, and data recorder housed within a tall, cylindrical, water-tight pressure case. The teachings of Sutton, Schmalfeldt, and Jones were then applied to Cranford in the same manner as they were to Mattaboni in Ground 1 to arrive at the claimed low-profile, disk-shaped OBS.
    • Motivation to Combine: The motivation was identical to that in Ground 1. Petitioner argued that because the OBSs in Cranford and Mattaboni were highly similar, a POSITA would have been motivated to apply Sutton's teachings on optimal case design to Cranford for the same reasons: to reduce noise and improve coupling with the seafloor.

Ground 3: Obviousness over Mattaboni, Sutton, Schmalfeldt, Jones, and Carrack - Claims 7 and 24 are obvious over the combination of these references.

  • Prior Art Relied Upon: Mattaboni (a 1977 journal article), Sutton (a 1987 journal article), Schmalfeldt (a 1983 technical report), Jones (Patent 6,951,138), and Carrack (a website publicly available in 1999).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination in Ground 1 to address the limitations of claims 7 and 24, which require the OBS case to have a plate with external ribs, grooves, or coupling ridges. Petitioner argued that the primary combination of Mattaboni, Sutton, Schmalfeldt, and Jones taught the base OBS system. Carrack was added because it explicitly disclosed an OBS geophone package with a baseplate featuring a pattern of ridges and grooves "optimised for shear wave coupling." This baseplate design was argued to be nearly identical to that shown in the ’761 patent.
    • Motivation to Combine: A POSITA seeking to further optimize the OBS design from Ground 1 would have been motivated to incorporate Carrack's teachings. The desire to improve the coupling between an OBS and the seafloor was a well-known objective in the art. Carrack directly addressed this by teaching the use of a baseplate with ridges and grooves. A POSITA would combine Carrack's baseplate design with the optimally-shaped OBS to enhance its stability and the quality of seismic data recording.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claim 23 based on the primary combination of Mattaboni, Sutton, Schmalfeldt, and Jones, further in view of Willoughby (a 1993 journal article). This ground focused on Willoughby's disclosure of a "triaxial seismometer" to teach the "multi-component geophone" limitation of claim 23.

4. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-24 of Patent 8,228,761 as unpatentable.