PTAB

IPR2021-00146

Haas Automation Inc v. OlATI LLC

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1. Case Identification

2. Patent Overview

  • Title: Closed-Loop Feedback Control Machining System
  • Brief Description: The ’432 patent describes a closed-loop feedback control system for machining operations. The system aims to correct qualitative issues like tool vibration ("chatter") by measuring physical properties of the tool (e.g., force, vibration) in real-time and responsively adjusting machining parameters, such as spindle speed or feed rate.

3. Grounds for Unpatentability

Ground 1: Anticipation over Oraby - Claims 1-2, 4, and 6 are anticipated by Oraby under 35 U.S.C. §102.

  • Prior Art Relied Upon: Oraby (a 1989 Ph.D. Thesis from the University of Sheffield titled "Mathematical Modelling and In-Process Monitoring Techniques for Cutting Tools").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Oraby, a publicly available thesis, discloses every element of the challenged claims. Oraby described an adaptive control lathe system with a "closed-loop feedback circuit" for real-time process control. The system included a Colchester centre-lathe (the "machine"), a tool holder, a spindle drive, and a feed drive system. Oraby’s system used a "strain-gauge dynamometer" as a sensor to measure tool forces, an analog-to-digital converter (ADC) as a signal converter, and a microcomputer as a signal analyzer and controller. This controller adjusted the cutting speed and feed rate (i.e., the power exerted by the drives) in real-time based on the measured force values to optimize the machining process. Petitioner contended Oraby also discloses the specific sensor type of claim 4 ("analog electronic strain gauges") and the CNC controller of claim 6.

Ground 2: Obviousness over Oraby in view of Bartow - Claims 4-5 are obvious over Oraby in view of Bartow under 35 U.S.C. §103.

  • Prior Art Relied Upon: Oraby (a 1989 Ph.D. Thesis) and Bartow (a 2003 publication titled "Fiber Bragg Grating Sensors for Dynamic Machining Applications").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Oraby discloses the base system of a lathe with real-time feedback control, as detailed in Ground 1. Bartow, which is incorporated by reference into the ’432 patent, teaches using a fiber optic sensor (specifically, a fiber Bragg grating strain sensor) embedded in a tool to measure tool vibration. This combination allegedly renders claim 4 obvious by providing the "fiber optic sensor" option. The combination further renders claim 5 obvious, as Bartow’s sensor inherently receives an "optical signal" from the tool.
    • Motivation to Combine: A POSITA would combine Oraby and Bartow because both are analogous references directed to improving machining applications. Since Oraby already used sensors to monitor tool vibration, a POSITA would be motivated to seek out more advanced sensors like those in Bartow to increase detection accuracy, tool life, and efficiency, as Bartow expressly notes the "significant advantages" of fiber Bragg sensors over conventional methods.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in incorporating Bartow's sensor into Oraby’s system. The ’432 patent itself admits that a POSITA would understand the operation of such a sensor, making the integration a routine modification.

Ground 3: Obviousness over Oraby in view of Edie - Claims 7-8 are obvious over Oraby in view of Edie under §103.

  • Prior Art Relied Upon: Oraby (a 1989 Ph.D. Thesis) and Edie (Patent 6,845,340).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that while Oraby teaches the base adaptive control system, Edie discloses the remaining limitations of claims 7 and 8. Edie describes a data management system for CNC machine tools that collects operational data and can output it to a "portable display device," specifically a "personal digital assistant (PDA)." This directly maps to the claim language requiring a portable display to inform a user of adjustments made by the controller.
    • Motivation to Combine: A POSITA would combine these references to enhance the usability of Oraby's system. Oraby's system generates significant real-time data, and a POSITA would seek an effective way to display and analyze it. Edie provides a known solution for displaying such data on a portable device, which would be advantageous for monitoring multiple machines remotely and improving efficiency, a goal shared by both references.
    • Expectation of Success: The combination would be a simple and predictable substitution of one known element (Oraby’s basic display unit) for another (Edie’s portable PDA). This modification uses a known technique to improve a known system and would have yielded predictable results.

  • Additional Grounds: Petitioner asserted additional anticipation and obviousness challenges (Grounds 5-8) based on Delio (Patent 5,170,358), both alone and in combination with Bartow and Edie, arguing Delio discloses a similar closed-loop system for controlling chatter in a milling machine.

4. Key Claim Construction Positions

  • Petitioner argued that the claim term "at least one controller … adjusts the power" from claim 1 should be construed under 35 U.S.C. §112(6) as a means-plus-function limitation.
  • Petitioner contended the word "controller" is a nonce term that fails to recite a sufficiently definite structure. Because the ’432 patent specification generically refers to an "algorithm" but fails to disclose a specific algorithm for performing the "adjusting" function, the term lacks the corresponding structure required by the statute.
  • For the purposes of the IPR, Petitioner proposed a broad construction encompassing "any microprocessor instituting a feedback loop with a CNC machine controller and any algorithm that can perform the recited function of 'adjust[ing] the power...'"

5. Relief Requested

  • Petitioner requested institution of an IPR for claims 1-8 of the ’432 patent and cancellation of all challenged claims as unpatentable.