PTAB

IPR2019-01050

Precision Planting LLC v. Deere & Co

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Seeding Machine with Controlled Seed Delivery
  • Brief Description: The ’922 patent describes an improved seed planting system for agricultural row units. The invention aims to solve the problem of inaccurate seed spacing, which is exacerbated at higher planting speeds, by providing a "controlled descent" for seeds from the meter to the furrow using a seed delivery apparatus with an endless member (e.g., a brush belt) and a stationary loading surface to prevent unwanted seed movement.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4-11, and 13 are obvious over Hedderwick in view of Yamahata and Koning.

  • Prior Art Relied Upon: Hedderwick (UK Published Application GB 2 057 835A), Yamahata (Utility Model Laid-open Publication No. S56-24815), and Koning (Patent 4,193,523).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that the combination of these three prior art references teaches every element of the challenged claims under 35 U.S.C. §103. Hedderwick was presented as the primary reference, establishing the foundational system of a "precision seeder" that includes a vacuum seed meter, an elongated housing with first and second openings, and an endless belt with fins disposed on pulleys within the housing. The petition asserted that this base system met many limitations of independent claim 1.
    • To this base, Petitioner proposed two key modifications. First, incorporating the stationary "guiding device" taught by Yamahata. Yamahata disclosed this guide to contact seeds on a vacuum meter disk and ensure their reliable release at a predetermined point. Petitioner argued this directly teaches the claimed "loading surface stationary relative to the elongated housing and positioned to contact and guide seed toward the endless member."
    • Second, Petitioner argued for replacing Hedderwick's finned belt with the brush belt from Koning. While Hedderwick’s belt conveys seeds, it allows them to bounce between fins. Koning taught an endless member with brush hairs specifically to "hold" seeds securely until the moment they leave the belt. This, Petitioner asserted, teaches the claimed "endless member" that grips and controls seeds for a more uniform distribution, as described in the ’922 patent. The petition detailed how this combination maps to every element of independent claims 1 and 9. It further argued that dependent claims 2 and 4-8 were obvious, as Yamahata explicitly teaches the loading surface as an "insert" (claim 4) that is "adjacent the first opening" (claim 2), has a "contoured contact surface" (claim 6), and is configured to "guide seed into the first opening" (claim 8).
    • Motivation to Combine: The petition asserted a clear and compelling motivation for a person of ordinary skill in the art (POSITA) to combine these references. All three documents originate from the same technical field of agricultural seed planting and explicitly address the same long-standing problem: achieving precise, uniform seed spacing by controlling seed descent. A POSITA would combine these known techniques to improve the performance of a conventional planter like Hedderwick's.
    • The first motivation was to improve seed release reliability. Yamahata specifically addressed the problem of seeds getting stuck in the apertures of vacuum seed meters, which causes irregular planting intervals. A POSITA would have been motivated to incorporate Yamahata's stationary guide into Hedderwick's similar vacuum meter system to achieve Yamahata's stated benefit of reliable seed release from the meter disc.
    • The second motivation was to improve seed control during conveyance. The petition argued that a POSITA would recognize that Hedderwick’s finned belt was suboptimal because it allowed seeds to ricochet, undermining precise spacing. Koning taught its brush belt as a direct solution to this issue, explaining that its brush hairs "hold the potatoes or the like...till the very last moment" ensuring their velocity is "completely defined." A POSITA would thus be motivated to replace Hedderwick's finned belt with Koning's superior brush belt to achieve this finer control and predictable seed placement.
    • Expectation of Success: Petitioner argued that a POSITA would have had a high and reasonable expectation of success in making this combination. The proposed modifications involved the straightforward application of known mechanical solutions (a stationary guide, a brush belt) to a known type of system (a planter) to solve well-understood problems. The petition characterized Yamahata's guide and Koning's brush belt as established "tools in the POSITA's toolbox," the integration of which into Hedderwick's planter would have been a predictable variation yielding the expected benefits of improved seed release and placement control.

4. Relief Requested

  • Petitioner requested that the Board institute an inter partes review of claims 1-2, 4-11, and 13 of the ’922 patent and find those claims unpatentable and canceled.