PTAB

IPR2019-00307

Lindsay Corporation v. Valmont Industries, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Remote Irrigation Control System
  • Brief Description: The ’883 patent describes an apparatus and method for using a single wireless remote user interface (RUI) with a handheld display and keypad for remotely determining the status of and controlling mechanized irrigation equipment. The RUI directly transmits telemetry to and reads the status from irrigation components (e.g., pivots) and ancillary equipment (e.g., valves).

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 system for remotely controlling and monitoring an irrigation system using a laptop computer, which functions as a single wireless RUI. Scott disclosed directly transmitting commands to and reading status from irrigation components (sprinkler heads) and ancillary equipment (pumps, valves). To the extent Scott’s laptop was not considered "handheld," Petitioner asserted that Pyotsia supplied this element. Pyotsia disclosed a handheld mobile terminal (e.g., a mobile phone or PDA) for wirelessly monitoring and controlling industrial field devices, such as control valves.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Scott’s irrigation control system with Pyotsia’s handheld terminal to achieve greater portability and mobility than offered by Scott's laptop. Petitioner noted that the PTAB and Federal Circuit had already affirmed this motivation and combination in a related IPR (IPR2015-01039) involving a child of the ’883 patent.
    • Expectation of Success: A POSITA would have reasonably expected success in this combination because it involved applying the known concept of a handheld controller (Pyotsia) to an existing remote control system (Scott). The combination merely required implementing Scott's direct radio control concept in Pyotsia's handheld device, a task well within the skill of a POSITA.

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 asserted this combination overcame arguments made during the original prosecution of the ’883 patent. Abts disclosed a system for monitoring agricultural irrigation equipment with a handheld pager and controlling it with a separate handheld cellular phone. However, communications in Abts were indirect, routing through a central computer. Mauney disclosed an enhanced wireless handset capable of a "direct handset-to-handset communication mode" that is independent of any wireless network infrastructure, using technology like the unlicensed ISM band.
    • Motivation to Combine: A POSITA would have been motivated to replace the two-device, indirect communication system of Abts with the single, integrated handset of Mauney that is capable of direct communication. This combination would simplify the system, reduce the number of devices for a user to carry, eliminate reliance on intermediary network infrastructure, and reduce costs and latency. Mauney’s direct telemetry provided precisely what the Patent Owner argued Abts lacked during prosecution: a single wireless RUI that directly transmits telemetry.
    • Expectation of Success: A POSITA would have expected success in substituting Mauney's more advanced, direct-communication handset for the separate pager and phone in Abts. Mauney’s direct telemetry was described as suitable for general data transmission between a phone and other wireless devices, making its application to Abts' irrigation equipment a predictable and logical improvement.

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

  • Prior Art Relied Upon: Irrigation Advances (a Spring 1996 publication) and Mauney (Patent 6,484,027).
  • Core Argument for this Ground:
    • Prior Art Mapping: Irrigation Advances, a magazine article, disclosed two remote irrigation control systems: the R-MAC system, which used a handheld cell phone for control, and the AIMS Telemetry Network, which used a computer for monitoring and control but noted a user was adapting a laptop for mobile access via a cell phone. These systems taught remote control and status monitoring of irrigation components and ancillary equipment (pivots, pumps). Mauney, as in Ground 2, provided the teaching of a single handheld device capable of direct, network-independent communication.
    • Motivation to Combine: A POSITA would have been motivated to enhance the systems in Irrigation Advances with Mauney’s direct-communication handset. This would improve upon the R-MAC system by enabling direct telemetry instead of relying on a business band radio or phone network. It would also improve upon the AIMS system by replacing the cumbersome laptop/cell phone combination with a single, more portable handheld device, fulfilling the stated desire for increased mobility.
    • Expectation of Success: The combination was argued to be a predictable integration of known technologies. Irrigation Advances established the need for portable, remote irrigation control, and Mauney provided an improved technology (a single handset with direct communication) to achieve that goal more efficiently. A POSITA would have readily understood that Mauney's direct telemetry could be used for general data transfer to control the equipment described in Irrigation Advances.

4. Key Claim Construction Positions

  • "directly transmitting telemetry": Petitioner argued this term, added during prosecution to overcome prior art, should be construed as "without any intervening agency or instrumentality or determining influence: without any intermediate step." This construction, meaning communication with no intermediary, was supported by the prosecution history where the applicant distinguished over Abts’s multi-hop communication path, and by a prior PTAB decision on a related patent.
  • "single wireless RUI": Petitioner asserted this term should be construed as "any unitary device with a handheld display and keypad that can communicate wirelessly." This construction was also central to the patentability arguments during prosecution, where the applicant distinguished Abts for using a separate pager and mobile phone.
  • "mechanized irrigation components": Petitioner argued this term should be interpreted broadly as "designed to implement a process or task with machinery," without being limited to "agricultural" equipment. This was based on a dictionary definition and the patent's general description, preventing the Patent Owner from improperly narrowing the claims to exclude prior art from adjacent fields like residential or golf course irrigation.

5. Relief Requested

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