PTAB

IPR2025-00649

TankLogix LLC v. SitePro Inc

Key Events

Petition

petition

Title: Remote Control of Fluid-Handling Device
Brief Description: The ’078 patent describes a system for the remote control and data collection of fluid-handling devices, such as those used at oil wells or petroleum facilities. The system features a central command center that sends instructions to an on-site controller, which can operate even when disconnected from the command center, by translating commands into device-specific protocols to achieve a target state.

Prior Art Relied Upon: Almadi (Patent 8,887,901).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Almadi anticipates every limitation of independent claim 1. Almadi taught an integrated node that interfaces between a remote host server and multiple remote subsystems (e.g., fluid-handling devices at oil and gas fields). Petitioner asserted that Almadi’s system receives user-directed instructions via a network, obtains a target state for a device, and determines different target states over time by monitoring time-stamped process data. Crucially, Almadi’s integrated node included a “protocol translator” that selected and translated communications from a shared protocol into various different messaging protocols required by the remote subsystems, and then sent these translated instructions to the appropriate devices. This mapping was extended to dependent claims, arguing, for example, that Almadi’s disclosure of modeling objects to identify process streams taught the parsing and retrieving limitations of claim 2.
- Motivation to Combine (for §103 grounds): This ground was primarily asserted as anticipation under 35 U.S.C. §102. The obviousness argument was presented as an alternative, contending that to the extent any minor difference was found, a person of ordinary skill in the art (POSITA) would have found it obvious to implement the teachings of Almadi to arrive at the claimed invention.

Prior Art Relied Upon: Gutierrez (Patent 9,709,995).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Gutierrez, which discloses a remote chemical injection system for hydrocarbon production, anticipated the challenged claims. Gutierrez taught a system with a remote computing device using a graphical user interface (GUI) to send commands to controllers at uniquely addressable production sites. Petitioner mapped this to claim 1 by arguing Gutierrez receives user instructions via a network to control fluid-handling devices. The system obtained target states (e.g., adjusting motor speed), determined different target states over time based on operational parameters, and used a “translation module” to convert communication protocols into a secondary protocol understood by the local motor controller. The translated commands were then sent to the device to achieve the target state. For dependent claims, Petitioner argued Gutierrez taught parsing device identifiers for uniquely addressable sites (claim 2) and using a smartphone as the user device (claim 17).

Prior Art Relied Upon: SCADA (Supervisory Control and Data Acquisition, 4th Edition (2010)).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that the fundamental, well-known architecture of Supervisory Control and Data Acquisition (SCADA) systems, as described in the SCADA reference, anticipated the key claims. The SCADA reference described a standard system with a central human operator, a master terminal unit (MTU), and remote terminal units (RTUs) that interface with field actuators (fluid-handling devices). Petitioner argued this system inherently receives user-directed instructions, obtains target states for devices (e.g., a set point for a PID controller), and determines different target states over time. The SCADA reference’s disclosure of “transducers” that change signals from one format (e.g., electrical current) to another (e.g., air pressure) was argued to teach the claimed “translating” of protocols. The reference also disclosed both automatic and manual remote control modes, allegedly anticipating claims 11 and 12, respectively.

§325(d) Factors: Petitioner argued against discretionary denial under 35 U.S.C. §325(d), asserting that the prior art references (Almadi, Gutierrez, and SCADA) were not before the Examiner during prosecution. Petitioner further contended the references were not cumulative of the examined art, as they explicitly teach the "translating" and "sending" limitations that the Applicant relied upon to overcome prior art rejections and that the Examiner cited as reasons for allowance.
Fintiv Factors: Petitioner argued that the Fintiv factors weighed strongly in favor of institution. The parallel district court proceeding was in its earliest stages with no trial date set; the expected trial date (September 2027) was well after the statutory deadline for a Final Written Decision (FWD). Petitioner also noted minimal investment in the parallel case and stipulated that, if the inter partes review (IPR) is instituted, it will not pursue the same invalidity grounds in district court, thereby avoiding significant overlap.

Petitioner requested the institution of an IPR and the cancellation of claims 1-8, 11-13, and 15-19 of the ’078 patent as unpatentable.