PTAB

IPR2019-00618

VRG Controls LLC v. Dresser LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Fluid Control Valve
  • Brief Description: The ’843 patent discloses a fluid control valve for regulating fluids like natural gas. The valve uses a throttling ball containing a "ball plate" with multiple orifices to create staged pressure drops and a downstream "shoe member" to straighten the fluid path, with the combined goal of reducing noise, vibration, and cavitation while increasing laminar flow.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, 6, 11, 17-18, and 23-25 are anticipated by Davenport.

  • Prior Art Relied Upon: Davenport (Patent 5,070,909).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Davenport, which teaches a rotary control valve for reducing noise and cavitation, discloses every element of the challenged claims. Petitioner argued that Davenport’s throttling ball with its internal "trim 35" (comprising parallel and transverse ducts) is the claimed "throttling ball" with a "ball plate including a plurality of orifices." Furthermore, Petitioner contended that Davenport’s upstream and downstream "seat/trim assemblies," which have a partial hemisphere interior surface that tracks the ball, are functionally and structurally identical to the claimed "shoe member." The detailed mapping extended to dependent claims, arguing Davenport’s trim structure inherently includes features like a diffuser, multiple flow plates, and support plates.

Ground 2: Claims 19-21 are obvious over Davenport in view of Partridge.

  • Prior Art Relied Upon: Davenport (Patent 5,070,909) and Partridge (Application # 2007/0034267).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the anticipation argument for claims 17 and 18, which Davenport allegedly discloses. The additional limitations in claim 19 require an internal trim with a plurality of flow plates aligned parallel to the axis of rotation. While Davenport teaches an internal trim, Petitioner argued Partridge explicitly discloses an internal trim with multiple parallel flow plates to create staged pressure drops. Claims 20 and 21 add limitations regarding specific rotation angles (45-60 degrees), which Petitioner asserted are disclosed in Davenport’s description of its partially open positions.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Partridge’s internal trim of parallel plates with Davenport’s valve. Both references address the same well-known problems of cavitation and noise in fluid valves by using components to disperse pressure drop. Using Partridge’s known plate-based solution in Davenport’s valve was presented as an obvious design choice to enhance its noise-reduction capabilities.
    • Expectation of Success: A POSITA would have a high expectation of success because combining these known components for their intended purposes would predictably improve the valve's performance in managing pressure drops and reducing noise.

Ground 3: Claims 1, 2, 4, 6, 11, 17-21, 23, and 25 are obvious over EP’269 in view of Leinen, Durco, Carlson, and/or Neles Q-Ball.

  • Prior Art Relied Upon: EP’269 (European Patent Application No. EP 0889269 A1), Leinen (Patent 5,437,305), Durco (The DurcoTrim Publication, June 1987), Carlson (Patent 6,039,304), and Neles Q-Ball (Neles Q-Ball Publication, May 1986).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that EP’269 teaches a base rotary control valve with a throttling ball and a downstream throttling member that meets the limitations of the claimed "shoe member." However, EP’269 does not explicitly disclose a "ball plate" disposed in a downstream transverse passage. Petitioner contended this missing element was a well-known feature in the art. Leinen and Durco were cited as teaching this exact feature: a throttling ball with a transverse passage containing a ball plate with multiple orifices to optimize pressure drops and reduce noise. Carlson was cited as an alternative or supplementary reference teaching a concave disk (shoe member) detachably secured to the valve body. For dependent claims requiring multiple internal diffuser plates (e.g., claims 2, 4, 18), Petitioner relied on Neles Q-Ball, which explicitly teaches using trims with multiple internal flow/diffuser plates to manage pressure drops.
    • Motivation to Combine: A POSITA would combine the teachings of Leinen or Durco (for the ball plate) and Carlson (for a specific shoe design) with the base valve of EP’269. The motivation was to incorporate conventional, well-known noise and cavitation reduction techniques into a standard ball valve design. All references address the identical problem of controlling fluid flow while minimizing adverse effects, making the combination of their respective features a predictable and common-sense design improvement.
    • Expectation of Success: The combination of these known elements from analogous prior art to solve a persistent industry problem would have been straightforward, with a high expectation of achieving the desired reduction in noise and cavitation.

4. Key Claim Construction Positions

  • "shoe member...detachably secured to the body": Petitioner contended this term is not enabled and lacks written description under 35 U.S.C. §112. It was argued that while the claims require the shoe member to be secured to the "body," the patent’s specification and all corresponding figures exclusively describe and illustrate the shoe member as being detachably secured to the "outlet closure," a separate component. Petitioner asserted that no embodiment shows the shoe secured directly to the valve body, rendering the claim language unsupported by the disclosure.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1, 2, 4, 6, 11, 17-21, and 23-25 of the ’843 patent as unpatentable.