PTAB

IPR2025-00585

Shenzhen Tuozhu Technology Co Ltd v. Stratasys Inc

Key Events

Petition

petition

Title: Tagged Build Material for Three-Dimensional Printing
Brief Description: The ’464 patent describes methods and systems for three-dimensional (3D) printing where a supply of build material (e.g., a spool or cartridge) includes a data tag. A 3D printer reads information from the tag to automatically acquire material characteristics and determine operational parameters for fabricating an object.

Prior Art Relied Upon: Dahlin (Patent 6,022,207) and Menchik (Application # 2006/0127153).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Dahlin disclosed a 3D printing system with a filament spool having an associated circuit (an electronic tag) that stores data, including the type and amount of filament. The system uses this data to perform a diagnostic test to determine if sufficient material exists for a job. Menchik disclosed a 3D printing system where a memory chip on a material cartridge stores optimal operational parameters (e.g., jetting temperature) and material properties. The combination of Dahlin's tagged material system with Menchik's teaching of storing a wider range of operational parameters on the tag rendered the independent claims obvious.
- Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Dahlin and Menchik to improve the efficiency and reliability of the 3D printing process. Storing optimal parameters directly on the material supply, as taught by Menchik, would allow Dahlin's system to automate printer setup, ensure continuous operation, and produce higher-quality parts, representing a predictable improvement.
- Expectation of Success: Given that both references address automated material management in the 3D printing field, a POSITA would have had a high expectation of success in combining their teachings.

Prior Art Relied Upon: Dahlin (Patent 6,022,207), Menchik (Application # 2006/0127153), and Loughran (Application # 2006/0091199).
Core Argument for this Ground:
- Prior Art Mapping: This ground built upon the combination of Dahlin and Menchik by adding Loughran's disclosure of using a radio frequency identification (RFID) tag on a material container to store a unique material identifier. Loughran taught that an RFID reader on the printer could wirelessly retrieve this identifier. This combination specifically addressed dependent claims reciting RFID tags and readers. The combination also covered claims reciting retrieval of additional data using a material ID number, as Loughran taught using the ID to fetch more information from a server.
- Motivation to Combine: A POSITA would incorporate Loughran's RFID technology into the Dahlin/Menchik system as an obvious design choice. RFID was a well-known technology offering advantages over Dahlin's contact-based EEPROM system, such as no requirement for physical contact, less constrained tag placement, and greater durability against dust and damage.

Prior Art Relied Upon: Loughran (Application # 2006/0091199) and Toshiki (Japanese Application # JP2013-67018A).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Loughran provided the foundational system of reading a material identifier from a tag and retrieving operational parameters. Toshiki supplied the limitations related to performing a specific diagnostic test before fabrication. Toshiki disclosed a 3D printer that calculates the estimated material usage for a job, compares it to the remaining material in the cartridge, and displays a determination of whether a replacement is needed before the printing process begins. This pre-fabrication suitability check directly mapped to the "diagnostic test" and conditional control limitations of the challenged claims.
- Motivation to Combine: A POSITA would combine Toshiki's pre-print material check with Loughran's tagged material system to enhance functionality and prevent print failures. Adding this diagnostic step would ensure a continuous and uninterrupted supply of material, negating the need for manual monitoring and allowing an operator to replace a cartridge before a long job starts, which was a simple and predictable improvement.
- Expectation of Success: Both references relate to fabricating 3D objects and managing material supply, so implementing Toshiki's diagnostic method within Loughran's framework would have been a straightforward integration for a POSITA.

Priority Date Challenge: Petitioner dedicated a significant portion of the petition to arguing that the ’464 patent was not entitled to the filing date of its provisional application. The argument centered on the claim limitations requiring "performing a diagnostic test to determine whether the operational parameter is suitable for the three-dimensional printer." Petitioner contended the provisional application lacked written description support for this feature, as its disclosure of "diagnostic tests" related only to material properties (e.g., filament diameter), not to the suitability of an operational parameter (e.g., build temperature) for the printer itself. Consequently, Petitioner argued the patent's effective filing date was October 28, 2013, making all asserted prior art references available under §102.

§325(d) - Same or Substantially Same Art: Petitioner argued against discretionary denial under §325(d), asserting that none of the primary references (Dahlin, Menchik, Loughran, Toshiki) were applied or substantively addressed by the Examiner during the original prosecution. Petitioner contended that the Examiner made a material error by overlooking the teachings in these references, which provided the very claim elements (specifically the diagnostic test) added to overcome a §102 rejection.
§314(a) - Fintiv Factors: Petitioner argued that the Fintiv factors weighed in favor of institution. Key arguments included that the parallel district court litigation trial date (June 2026) was distant and highly uncertain, little investment had been made by the court, and Petitioner had filed a stipulation agreeing not to pursue the same invalidity grounds in the district court action, mitigating concerns of overlapping efforts.

Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 10-19 of the ’464 patent as unpatentable.