PTAB

IPR2025-00139

Liberty Energy Inc v. US Well Services LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Modular Switchgear System and Power Distribution for Electric Oilfield Equipment
  • Brief Description: The ’878 patent discloses a modular hydraulic fracturing system for oilfield operations. The system uses switchgear to receive power from generators and distribute it to mobile pumping trailers, which contain equipment such as electric pumps, motors, variable frequency drives (VFDs), and transformers.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 and 6-8 are obvious over Morris in view of Oehring IV and Premset Catalog

  • Prior Art Relied Upon: Morris (Application # 2020/0040705), Oehring IV (Application # 2017/0222409), and Premset Catalog (a 2017 Schneider Electric product catalog).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Morris taught the foundational hydraulic fracturing system, including a mobile pump transport with an electric pump, motor, VFD (“drives”), and transformer, all mounted on a common support structure (the transport trailer). Oehring IV, which addresses similar operational challenges in the same field, was argued to supply the express teaching of a switchgear with a “common load sharing bus” to improve fleet versatility and efficiency. Premset Catalog was presented as a known, commercially available medium-voltage switchgear that a person of ordinary skill in the art (POSITA) would select, which explicitly teaches features like "front aligned, shielded cable connections," "integrated core units," and an isolating ground switch, thereby rendering obvious all limitations of the challenged claims.
    • Motivation to Combine: A POSITA would combine Morris and Oehring IV because they are from the same field (electric power for fracturing), identify identical problems (footprint, efficiency, flexibility), and propose similar solutions. Petitioner argued a POSITA would integrate Oehring IV’s load-sharing bus into Morris’s switchgear to achieve Morris’s stated goals of a “scalable and flexible” fleet. A POSITA would then look to the Premset Catalog to source a suitable medium-voltage switchgear, as used in both Morris and Oehring IV, to gain the catalog’s disclosed benefits of modularity, compact design, and reduced maintenance.
    • Expectation of Success: Petitioner contended a POSITA would have a reasonable expectation of success, as combining a known load-sharing bus and a commercially available, modular switchgear (Premset) into an existing mobile fracturing system (Morris) involves applying known principles to achieve predictable results.

Ground 2: Claim 5 is obvious over Morris in view of Oehring IV, Premset Catalog, and Orban

  • Prior Art Relied Upon: Morris (Application # 2020/0040705), Oehring IV (Application # 2017/0222409), Premset Catalog (a 2017 catalog), and Orban (WO 2018/201118).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the combination of Morris, Oehring IV, and Premset Catalog to establish the base system of claim 1. Petitioner argued that Orban supplied the remaining limitation of claim 5: a cooling system for the VFD. Orban discloses a “conventional water-cooled VFD” for use in fracturing systems and illustrates a system that pumps cooling fluid through channels via headers to cool the VFD.
    • Motivation to Combine: A POSITA, having assembled the system from the primary references, would recognize the need to manage heat generated by the VFD on Morris’s pump transport. Petitioner asserted it would be obvious to apply the conventional liquid cooling techniques taught in Orban, especially since Orban expressly teaches using its VFD cooling system in a “fracturing pumping system.”

Ground 3: Claim 9 is obvious over Morris in view of Oehring IV, Premset Catalog, and Pratt

  • Prior Art Relied Upon: Morris (Application # 2020/0040705), Oehring IV (Application # 2017/0222409), Premset Catalog (a 2017 catalog), and Pratt (Patent 5,042,756).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground uses the primary combination to teach the base system of claim 1. Petitioner argued Pratt renders obvious the limitations of claim 9, which requires "cable trays positioned below a walking surface... covered by a hinged cover that pivots to provide access." Pratt explicitly discloses a “cable tray walkway” with walkway members hingedly connected to provide access to cable trays located beneath.
    • Motivation to Combine: Petitioner contended that Morris’s mobile system, with its numerous electrical cables, presents a clear need for cable management. A POSITA would naturally look to known solutions like Pratt to manage these cables safely, reduce the operational footprint, and protect cables from damage. Implementing Pratt’s walkway on Morris’s pump transport was argued to be a straightforward application of a known solution to a known problem.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges. These grounds relied on the same core combinations but substituted the Premset Brochure for the Premset Catalog. Further grounds added references such as NEC (for grounding requirements in claim 4), Oehring II (for the human-machine interface in claim 10), and Payne (as an alternative to Morris for teaching components mounted on a common support structure).

4. Arguments Regarding Discretionary Denial

  • Fintiv Factors (§314(a)): Petitioner argued against discretionary denial under Fintiv, asserting that the parallel district court litigation is in its “infancy,” providing ample time for the IPR to conclude before trial. Petitioner also claimed it was diligent in filing the petition within four months of receiving infringement contentions and that the petition’s merits are particularly strong.
  • Prior Art and Issues (§325(d)): Petitioner argued that denial under §325(d) is improper because the primary prior art references, Morris and the Premset Catalog/Brochure, are new and were never considered by the examiner. Further, while Oehring IV was listed on the face of the ’878 patent, it was never applied by the examiner in any rejection, making the asserted grounds non-cumulative.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-10 of the ’878 patent as unpatentable.