PTAB

IPR2024-00740

Integration Group Of Americas Inc v. SitePro Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remote Control of Fluid-Handling Devices
  • Brief Description: The ’504 patent describes a fluid processing system that allows for remote control and monitoring of fluid-handling devices. The system comprises a local computer at a fluid handling site, which receives sensor data, and a remote server system that authenticates users, provides a user interface with fluid property data, and sends commands to control site equipment like pumps and valves.

3. Grounds for Unpatentability

Ground 1: Anticipation by Cardamone - Claims 1-16 and 20 are anticipated by or obvious over Cardamone.

  • Prior Art Relied Upon: Cardamone (Application # 2015/0308244).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cardamone discloses every element of the challenged claims. Cardamone teaches a deep well linear motor pump system with a surface-level control and communication computer (the claimed "first computer system") that receives sensory data (e.g., inlet pressure) from a downhole pump system. This system is remotely managed by a data server that provides a graphical user interface (GUI) on a remote computer for users to monitor data and adjust operating parameters. Petitioner asserted that Cardamone’s data server performs the claimed server functions, including receiving fluid property data from the site, obtaining credentials (username/password) from a client computer, providing a remote UI, and receiving commands to change the state of the fluid-handling device (e.g., adjusting the pump’s movement profile) to a sequence of different target states over time. The dependent claims were also allegedly disclosed, such as ramping pump speed (claim 2) and using PID controllers (claim 10).

Ground 2: Anticipation by Kahn - Claims 1, 17-20 are anticipated by or obvious over Kahn.

  • Prior Art Relied Upon: Kahn (Patent 7,424,399).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Kahn, which describes a well site data communication system for fluid distribution, anticipates the key claims. Kahn’s system includes sensor units at fluid handling sites (the "first computer system") that collect fluid property data and transmit it to a centralized data collection point (the "server system"). Petitioner argued this server authenticates users via login credentials, provides a GUI on a remote user's computer displaying sensor data, and includes actuators to manipulate fluid flow, thereby providing remote control. Kahn was also asserted to disclose a system with multiple fluids, computer systems, and fluid tanks at different sites (a water source and a water receptacle), meeting the limitations of dependent claims 17-19. As with Ground 1, Petitioner argued that the method limitations of claim 20 were inherent in the system disclosed by Kahn.

Ground 3: Obviousness over Cardamone or Kahn in view of SCADA - Claims 2, 8, and 13 are obvious.

  • Prior Art Relied Upon: Cardamone (Application # 2015/0308244), Kahn (Patent 7,424,399), and SCADA (a 2010 textbook titled SCADA: Supervisory Control and Data Acquisition, 4th Edition).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that to the extent Cardamone or Kahn do not explicitly teach every detail of certain dependent claims, a person of ordinary skill in the art (POSITA) would have found it obvious to combine their teachings with the industry-standard knowledge described in the SCADA textbook. For claim 2, SCADA explicitly teaches using PID controllers to control machine speed and stepper motors to ramp speed up or down, making it obvious to apply this to the pumps in Cardamone or Kahn. For claim 8, SCADA discloses using "transducers" to translate between different languages and protocols (e.g., electrical current to air pressure), teaching the claimed "steps for translating commands." For claim 13, SCADA describes various industry-standard formats, including command codes and on-off signals via analog/digital signals, which would have been obvious to implement in the systems of Cardamone or Kahn.
    • Motivation to Combine: A POSITA would combine these references because Cardamone and Kahn describe general remote fluid control systems, while SCADA provides specific, well-known details on how such industrial control systems are implemented. The combination would yield predictable results by applying standard control methods (from SCADA) to the known system architectures of Cardamone or Kahn.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involves applying conventional and widely used industrial control techniques described in SCADA to the general remote monitoring frameworks of Cardamone or Kahn.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §314(a) by stipulating that, if the IPR is instituted, it will not assert in parallel litigation any invalidity ground that was raised or reasonably could have been raised in the petition.
  • Petitioner also argued against denial under §325(d), contending that the petition relies on prior art (Cardamone, Kahn, and SCADA) that was never before the Examiner during prosecution. This art was argued to be non-cumulative because it explicitly teaches elements, such as translating commands, that the patent owner had previously argued were missing from the art of record.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’504 patent as unpatentable.