Shenzhen Tuozhu Technology Co., Ltd. v. Stratasys, Inc.

1. Case Identification

• Case Number: IPR2025-00354
• Patent #: 8,747,097
• Filed: December 23, 2024
• Petitioner(s): Shenzhen Tuozhu Technology Co., Ltd.
• Patent Owner(s): Pettis
• Challenged Claims: 1-5 and 8-19

2. Patent Overview

• Title: Networked Three-Dimensional Printer with Three-Dimensional Scanner
• Brief Description: The ’097 patent describes a system for remotely managing and monitoring a three-dimensional (3D) printer using web-based servers. The system integrates a 3D scanner to capture information about the object during fabrication and transmits the status of the print job over a network to a remote client.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 4-5, 9-10, 12, 15-16, and 18-19 are obvious over Knighton in view of Luo and Anderson.

• Prior Art Relied Upon: Knighton (Patent 9,156,204), Luo (The Development of Internet Accessible Rapid Prototyping System, 1999), and Anderson (Application # 2004/0207662).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of Knighton, Luo, and Anderson taught all limitations of the challenged claims. Knighton was argued to disclose a 3D printer with a build volume and an integrated 3D scanner for analyzing the object during fabrication (meeting preamble, 1.a). Knighton’s control subsystem, which analyzes scan data relative to a model to identify variances and make corrections, was asserted to teach a machine vision system (1.b). Luo was asserted to teach adding a network interface and web server to a 3D printer’s local controller to allow remote monitoring and control via the internet (1.c, 1.d). Anderson was argued to supplement Luo by teaching the display of specific status information, such as percentage completion and a visual comparison of the fabricated part against a wireframe model.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Knighton with Luo and Anderson for several reasons. The primary motivation was to add well-known remote monitoring and control capabilities (from Luo) to Knighton's advanced in-process inspection system. This would enhance accessibility and efficiency, allowing users to manage expensive rapid prototyping machines remotely, identify defects from afar using the scanned data, and receive detailed status updates (from Anderson) to better manage the fabrication process. The combination was presented as a predictable application of known techniques to improve a known system.
  • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because all three references are directed to 3D printing, and the proposed combination involved integrating conventional components (web server, network interface) and software functionalities that were well-understood at the time.

Ground 2: Claims 1-5 and 9-19 are obvious over Mazumder in view of Bonassar.

• Prior Art Relied Upon: Mazumder (Patent 6,580,959) and Bonassar (Application # 2006/0160250).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued this combination also taught all limitations. Mazumder was asserted to teach a remotely controlled 3D printing system with a local computer that communicates over the internet with a remote computer, including a network interface and web server functionality for remote monitoring and control (preamble, 1.c, 1.d). Mazumder also taught using optical sensors to monitor the fabrication process. Bonassar was argued to supplement Mazumder by explicitly teaching the use of a 3D scanner as one such optical sensor to measure the geometry of the object during fabrication and compare it to a simulation to detect and correct errors, thereby teaching the scanner and machine vision system limitations (1.a, 1.b).
  • Motivation to Combine: A POSITA would be motivated to incorporate Bonassar’s detailed 3D scanning and error-correction techniques into Mazumder’s remote-controlled system. Mazumder taught using optical sensors for feedback, and Bonassar provided an advanced implementation of such a sensor (a 3D scanner) to achieve superior defect detection, online feedback control, and improved final part quality. This modification would allow for the detection of geometric flaws with minimal interruption and enable the system to automatically generate modified manufacturing plans to compensate for errors, a clear benefit for the remote fabrication system described by Mazumder.
  • Expectation of Success: Petitioner argued success would be expected because both references are in the 3D printing field and contemplate using sensors for feedback control. Integrating Bonassar's more detailed scanning method into Mazumder's system was framed as a predictable improvement that used known components to achieve foreseeable results.

• Additional Grounds: Petitioner asserted numerous additional obviousness challenges by combining the core prior art of Ground 1 (Knighton-Luo-Anderson) and Ground 2 (Mazumder-Bonassar) with single, additional references (e.g., Mamoto, Crampton, Chandhoke, Ridley, Biton, Bakhadyrov) to teach the specific limitations of various dependent claims, such as using stereolithography, structured light scanning, pass/fail evaluation, audible/visual alerts, and detection of specific defects like layer misalignment or surface holes.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) is inappropriate because the primary prior art, particularly Knighton and the specific combinations asserted, were never considered by the examiner during prosecution. Petitioner contended the examiner allowed the patent based on the mistaken belief that in-process 3D scanning was missing from the prior art, a belief directly contradicted by Knighton.
• Petitioner also argued against discretionary denial under Fintiv, asserting that the parallel district court case was in its earliest stages, with a motion to dismiss filed concurrently and no significant investment by the court. Furthermore, Petitioner submitted a stipulation agreeing not to pursue the same invalidity grounds in the district court if an inter partes review (IPR) is instituted, which weighs in favor of institution.

5. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-5 and 8-19 of the ’097 patent as unpatentable under 35 U.S.C. §103.