PTAB

IPR2025-00611

Shenzhen Tuozhu Technology Co Ltd v. Stratasys Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Detection and Use of Printer Configuration Information
  • Brief Description: The ’774 patent discloses a method for fabricating objects with a 3D printer by first querying a target printer for its specific configuration information. This information is then used to create a "fabrication profile" for generating a machine-ready representation of a 3D model that is executable by that specific printer.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Douglas and Mark - Claims 1-5, 9-10, 12-13, and 20 are obvious over Douglas in view of Mark.

  • Prior Art Relied Upon: Douglas (Application # 2014/0117585) and Mark (Patent 9,694,544).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Douglas disclosed a networked 3D printing environment where a central print server determined a suitable printer for a job by querying it for configuration information, such as build material properties contained in a "data tag." This process established a set of operational parameters. Petitioner asserted that Mark taught the missing implementation detail: the conventional process of using slicer and toolpath generator software to process a 3D model into machine-ready instructions (G-code) based on such operational parameters.
    • Motivation to Combine: A POSITA implementing Douglas’s networked system would combine it with Mark's well-known slicing techniques to generate the actual executable files needed for printing. Petitioner contended this was a predictable combination of a system-level concept with a standard implementation, motivated by the desire to create a functional printing system. Both references concerned Fused Filament Fabrication (FFF), further encouraging their combination.
    • Expectation of Success: The combination involved applying known methods (slicing) to a known type of system (networked printing) to achieve a predictable result (generating machine-ready code from printer properties), leading to a high expectation of success.

Ground 1C: Obviousness over Douglas, Mark, and Batchelder - Claim 8 is obvious over Douglas and Mark in view of Batchelder.

  • Prior Art Relied Upon: Douglas (Application # 2014/0117585), Mark (Patent 9,694,544), and Batchelder (Application # 2014/0127524).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Douglas/Mark combination to address the "firmware configuration" limitation of claim 8. Petitioner argued Batchelder disclosed that encoded markings on consumable materials could provide information to the printer, including "software and firmware updates."
    • Motivation to Combine: Given the critical role of firmware in interpreting G-code and controlling printer hardware, a POSITA would be motivated to include the printer's firmware configuration, as suggested by Batchelder, into the set of properties queried by the Douglas system. This would ensure that the G-code generated by the Mark process was compatible with the target printer, thereby improving print quality and user experience.
    • Expectation of Success: Petitioner asserted success would be predictable, as adding firmware information to a list of queried printer properties was a simple and logical extension for ensuring system compatibility.

Ground 2A: Obviousness over Hamilton and Evans - Claims 1-5, 9-10, and 12-13 are obvious over Hamilton in view of Evans (with or without KISSlicer).

  • Prior Art Relied Upon: Hamilton (Application # 2014/0236773) and Evans (Practical 3D Printers, The Science and Art of 3D Printing).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Hamilton, like Douglas, described a high-level product delivery system where a user's 3D printer was queried for its "accuracy and material capabilities" before a design was sent for fabrication. Evans, a "how-to" manual on 3D printing, provided the specific implementation details Hamilton lacked, explaining how slicer software uses these exact printer capabilities (e.g., filament diameter, nozzle size) to create a fabrication profile and generate executable G-code.
    • Motivation to Combine: A POSITA seeking to implement the system described in Hamilton would naturally turn to a standard technical guide like Evans to understand the well-known underlying processes for converting a 3D model into machine-ready code. The combination served to fill in the necessary, conventional details that Hamilton's system-level disclosure omitted.
    • Expectation of Success: Success was highly probable because Evans provided a detailed, practical roadmap for implementing the very functions required by Hamilton’s conceptual system, using standard, commercially available tools.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Douglas/Mark/Dahlin (for claims related to hardware reconfiguration), Douglas/Mark/Pax (for claims related to descriptive metadata), Hamilton/Evans/Pax (for claims on hardware reconfiguration and metadata), and combinations involving Pettis, Batchelder, and Wang to address other specific claim limitations.

4. Arguments Regarding Discretionary Denial

  • §325(d): Petitioner argued denial would be improper because the core prior art combinations relied upon in the petition were not considered during prosecution of the ’774 patent. While one reference (Pettis) was previously cited, it was presented here in a new combination with different teachings that were not before the Examiner.
  • Fintiv: Petitioner argued that the Fintiv factors strongly favored institution. The petition was filed before an answer in the parallel district court action, a motion to dismiss was pending in that case, and the trial date was more than two years away. Petitioner also highlighted its stipulation not to pursue the same invalidity grounds in the district court, which would prevent overlap and preserve resources.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-10, 12-13, and 19-20 of the ’774 patent as unpatentable under 35 U.S.C. §103.