PTAB

IPR2024-00850

Exotec Product France SAS v. Opex Corp

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1. Case Identification

2. Patent Overview

  • Title: Material Handling System and Method
  • Brief Description: The ’632 patent discloses a material handling system and method for delivering and retrieving items in a warehouse. The system uses autonomous delivery vehicles that can travel horizontally along the floor and vertically up storage racks to access storage locations.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3-12, 14, and 23-27 are obvious over Raizer in view of Hangzhou.

  • Prior Art Relied Upon: Raizer (Application # 2017/0158430) and Hangzhou (CN Publication # 109987366A).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Raizer discloses the foundational elements of the challenged claims, including a warehouse system with storage racks, aisles, and a plurality of autonomous mobile robots. Raizer’s robots feature both a horizontal drive system for ground travel and a vertical drive system enabling them to engage and climb a network of rails attached to the shelving units to access items at various heights. Raizer also teaches a gripper mechanism for transferring items. Petitioner contended that Raizer teaches every element of the independent claims except for the specific vehicle routing path of traveling under a storage rack.

      To address this limitation, Petitioner asserted that Hangzhou teaches an unmanned warehousing system where auto-guided trolleys travel in dedicated passage spaces created beneath elevated storage racks. Hangzhou explicitly discloses this under-rack travel as a means to reduce congestion and avoid bottlenecks. The trolleys in Hangzhou are disclosed as being capable of turning in place (e.g., 90 degrees) while under the racks to switch between row and column travel directions, thereby allowing them to travel under a rack and then exit into an aisle. Petitioner argued that combining Hangzhou's under-rack routing and turning capabilities with Raizer's versatile, vertically-climbing robots renders the methods claimed in the ’632 patent obvious. For example, claim 1’s steps of driving a vehicle under a rack, turning the vehicle while under the rack, and then driving it into an aisle are disclosed by the combination. Similarly, system claims reciting paths under the racks are met by this combination.

    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to combine the teachings of Raizer and Hangzhou to improve the efficiency and throughput of an automated warehouse. As a system like Raizer's scales with taller shelves and more robots, traffic congestion becomes a primary design challenge. Hangzhou addresses this exact problem by teaching the use of under-shelf passage spaces, a known technique for creating additional travel ways. A POSITA would combine Hangzhou’s efficient routing solution with Raizer’s advanced three-dimensional robot capabilities to reduce congestion, avoid traffic jams, and maximize space utilization. The combination would allow Raizer’s robots to choose among more possible paths, leading to a more robust and efficient system.

    • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success. The combination involves applying a known routing strategy (under-rack travel from Hangzhou) to a known type of warehouse robot system (Raizer) to achieve the predictable result of improved traffic flow. Implementing the under-rack pathways of Hangzhou for Raizer's autonomous robots would have been a straightforward integration of known elements.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not deny institution under 35 U.S.C. §325(d). It was asserted that neither Raizer nor Hangzhou was cited or considered by the Examiner during the prosecution of the ’632 patent. Therefore, the petition raises art and arguments that are not cumulative to those previously evaluated by the Patent Office, weighing against discretionary denial.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1, 3-12, 14, and 23-27 of the ’632 patent as unpatentable.