PTAB

IPR2025-00438

Shenzhen Tuozhu Technology Co Ltd v. Stratasys Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Tagged Build Material for Three-Dimensional Printing
  • Brief Description: The ’466 patent discloses methods and systems for automatically acquiring characteristics of a 3D printer build material. A supply of build material, such as a spool or cartridge, is equipped with a data tag containing information about the material, which a 3D printer reads to determine operational parameters for fabricating an object.

3. Grounds for Unpatentability

Ground 1A: Claims 1-5, 7-13, 16, 18, and 20 are obvious over Loughran and Dubois.

  • Prior Art Relied Upon: Loughran (Application # 2006/0091199) and Dubois (Application # 2008/0192074).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Loughran disclosed a networked solid freeform fabrication (SFF) system where a printer reads a material identifier from a tag on a material container and transmits this data to a remote client over a network. The client then generates and sends an SFF fabrication job to the printer. However, Loughran's fabrication job lacked specific operational parameters. Petitioner asserted that Dubois remedied this deficiency by teaching a 3D printing method where a CAD client device determines and communicates a detailed set of printing parameters (based on material characteristics) to the printer as part of the print job to control the dynamic production process.
    • Motivation to Combine: A POSITA would combine the teachings of Loughran and Dubois to enhance Loughran’s networked system with the detailed, material-specific operational parameters taught by Dubois. This combination would improve the quality, precision, and efficiency of the 3D printing process by enabling the printer to use optimal settings for the specific material identified, a known objective in the field.
    • Expectation of Success: As both references addressed layer-by-layer 3D printing systems, a POSITA would have reasonably expected success in integrating Dubois’s parameter-setting method into Loughran’s networked framework to achieve predictable improvements in print quality.

Ground 2: Claim 19 is obvious over Devos.

  • Prior Art Relied Upon: Devos (Application # 2007/0026102).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Devos alone taught every element of independent claim 19. Devos disclosed a 3D printer system comprising a controller and a tag sensor. A removable powder supply bin (a container of build material) included a memory mechanism (a tag) that stored information about the powder. Petitioner argued Devos showed coupling this container to the printer, reading data from the tag with the sensor, and transmitting the data to the controller. The controller then used this data to determine operational parameters, such as "powder settling coefficients" (which Petitioner mapped to the claimed "support structure requirement"), to control the printer and fabricate an object.

Ground 3A: Claims 1, 3-5, 7, 9-11, 19, and 20 are anticipated or rendered obvious by Menchik.

  • Prior Art Relied Upon: Menchik (Application # 2006/0127153).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Menchik disclosed a 3D printer system that meets the limitations of the challenged claims. Menchik's system included a printing apparatus and an external controller (a client, such as a personal computer) that communicates over a wire or wireless connection. Material supply cartridges were coupled to the printer and included memory chips (tags) storing material properties like color and optimal operating parameters. A memory chip reader (tag sensor) inside the printer read the data and transferred it to the external controller. The controller then used this data to compute operational parameters and sent a printing file to the printer to control the fabrication of an object, which Petitioner asserted meets the claim requirement of receiving operational parameters from the client.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Jazayeri (Application # 2011/0299110), KISSlicer (a 2012 software guide), and Dahlin (Patent 6,022,207). These references primarily added teachings for managing print requests in a networked environment, allowing user selection between multiple build materials, and performing diagnostic tests for material sufficiency before printing.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §325(d), asserting that the primary prior art references (Loughran, Dubois, Devos, and Menchik) were new and had not been considered during the original prosecution, which mistakenly concluded that certain claim elements were missing from the art.
  • Petitioner also argued that discretionary denial under Fintiv was unwarranted. The parallel district court litigation had a distant and uncertain trial date (estimated mid-2027), minimal court investment had occurred, and Petitioner stipulated not to pursue the same IPR grounds in the district court action, thereby avoiding significant overlap.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-5, 7-13, and 16-20 of the ’466 patent as unpatentable.