PTAB

IPR2019-00307

Lindsay Corp v. Valmont Industries Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remote User Interface for Irrigation Equipment
  • Brief Description: The ’883 patent describes an apparatus and method for remotely monitoring and controlling mechanized irrigation equipment. The system uses a single, handheld wireless remote user interface (RUI) with a display and keypad to read equipment status, directly transmit control telemetry, and display the status to a user in the field.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 are obvious over Scott in view of Pyotsia

  • Prior Art Relied Upon: Scott (WO 99/39567) and Pyotsia (Patent 7,010,294).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Scott taught a computer-controlled irrigation management system that used a laptop with a display and keyboard to directly control irrigation components (e.g., valves, pumps) via a wireless radio link. While Scott’s system met the direct control and status display limitations, its use of a laptop was not handheld. Petitioner asserted that Pyotsia remedied this deficiency by disclosing a handheld mobile terminal (such as a mobile phone or PDA) for wirelessly monitoring and controlling industrial field devices, including control valves. The combination of Scott's direct wireless control architecture with Pyotsia's handheld form factor allegedly rendered the claimed invention obvious.
    • Motivation to Combine: A POSITA would combine Scott and Pyotsia to gain the significant, known benefits of improved portability and mobility offered by Pyotsia’s handheld device over Scott’s laptop. This would allow a user to more conveniently control and monitor the irrigation system from anywhere in the field. Petitioner noted that the PTAB and Federal Circuit had previously found this combination obvious in a related IPR concerning a child patent.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination was a predictable substitution of one known user interface (a laptop) for another (a handheld PDA/phone) to achieve the known benefit of portability. The displays on Pyotsia’s handheld devices were readily capable of displaying the status information as taught by Scott.

Ground 2: Claims 1-4 are obvious over Abts in view of Mauney

  • Prior Art Relied Upon: Abts (Patent 6,337,971) and Mauney (Patent 6,484,027).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Abts disclosed a system for remotely monitoring and controlling agricultural irrigation equipment using two separate handheld devices: a pager to receive status updates and a cellular phone to send commands. Critically, Abts's system relied on indirect communication, as commands were routed through a central computer. Petitioner argued that Mauney taught the missing elements by disclosing an enhanced wireless handset capable of a “direct handset-to-handset communication mode” that is independent of any wireless network infrastructure. Combining these references involved replacing Abts’s two-device, indirect system with a single, unitary handset based on Mauney that was capable of direct communication.
    • Motivation to Combine: A POSITA would combine the references to create a simpler, more efficient, and more reliable system. Mauney’s single device would replace Abts’s separate pager and phone, reducing the number of devices required. Furthermore, substituting Mauney's direct communication for Abts's indirect telemetry would simplify system infrastructure, reduce complexity and potential failure points, and lower operational costs by avoiding cellular network fees, a benefit explicitly taught by Mauney. This combination directly addressed the arguments for patentability made during prosecution, which relied on the prior art’s failure to show a single RUI with direct transmission.
    • Expectation of Success: The combination involved applying Mauney's known direct-communication technology to Abts's known irrigation control system, which was a predictable integration of existing technologies. A POSITA would understand that Mauney’s direct telemetry was readily capable of being employed for general data transmission between a mobile phone and any wireless device, such as the controllers in Abts.

Ground 3: Claims 1-4 are obvious over Irrigation Advances in view of Mauney

  • Prior Art Relied Upon: Irrigation Advances (a Spring 1996 magazine publication) and Mauney (Patent 6,484,027).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Irrigation Advances disclosed two remote irrigation control systems: the “R-MAC” system, which used a cell phone to control pivots, and the “AIMS Telemetry Network,” a computer-based software package that users were adapting for mobile use with laptops and cellular phones. Both systems communicated indirectly through existing network infrastructure. As in Ground 2, Petitioner argued Mauney supplied the teaching of a single handheld device capable of direct, point-to-point wireless communication. The proposed combination would modify the systems in Irrigation Advances to use a single, Mauney-type handset for direct control of irrigation equipment.
    • Motivation to Combine: A POSITA would be motivated to integrate Mauney’s technology to improve upon the systems in Irrigation Advances. The motivation was to enhance portability by replacing a laptop/cell phone combination with a single handheld device and to simplify the communication architecture by using Mauney’s direct telemetry instead of relying on a cellular network. This would reduce costs, decrease latency, and allow for operation in areas without cellular coverage.
    • Expectation of Success: A POSITA would reasonably expect success because Irrigation Advances already established the utility of using portable devices (cell phones, laptops) for remote irrigation control. Implementing this control using Mauney’s more efficient direct-communication protocol was a straightforward and predictable improvement.

4. Key Claim Construction Positions

  • “single wireless RUI”: Petitioner argued this term should be construed to mean a unitary, or single-piece, handheld device with a display and keypad that communicates wirelessly. This construction was central to distinguishing prior art like Abts, which used separate devices (a pager and a phone).
  • “directly transmitting telemetry”: Citing the prosecution history where this phrase was added to overcome Abts, Petitioner argued for a construction of "with no intermediary." This means a direct, point-to-point wireless link between the handheld RUI and the irrigation equipment controller, without passing through a central computer, paging terminal, or other intermediate communication link. This construction was critical to Petitioner’s arguments that Mauney and Scott supplied this missing element to other prior art.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-4 of the ’883 patent as unpatentable based on the grounds presented.