PTAB
IPR2025-00651
TankLogix LLC v. SitePro Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2025-00651
- Patent #: 11,175,680
- Filed: February 28, 2025
- Petitioner(s): TankLogix, LLC
- Patent Owner(s): SitePro, Inc.
- Challenged Claims: 1-20
2. Patent Overview
- Title: Remote Control of Fluid-Handling Devices
- Brief Description: The ’680 patent describes a system and method for remotely controlling fluid-handling devices. The process involves a server receiving a command to change a device's state, determining the device's network address, and sending a target value to a local controller, which then monitors the device via sensors and controls an actuator to achieve the target state.
3. Grounds for Unpatentability
Ground 1: Claims 1-3, 6, 14, 17, and 19-20 are anticipated by or obvious over Almadi.
- Prior Art Relied Upon: Almadi (Patent 8,887,901).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Almadi, which discloses an integrated node for interfacing between a remote host server and remote subsystems in a process automation environment, teaches every element of the challenged claims. Petitioner mapped Almadi’s remote host computer to the claimed server, which receives commands from a user. Almadi’s integrated node, connected to remote subsystems (e.g., pumps, flow meters), was identified as the claimed controller that determines network addresses, accesses sensors, and controls actuators. Petitioner asserted that Almadi’s system of receiving commands, processing data from field devices, and controlling subsystems based on that data (e.g., switching a pump off if flow is below a limit) meets the claim limitations of receiving a target value, monitoring a measurement, and controlling an actuator based on a set point. For dependent claims, Petitioner argued Almadi’s disclosure of controlling multiple subsystems like pumps and monitoring systems inherently teaches a site master-controller architecture (claim 2) and the use of level sensors in tanks for oil processing teaches the separation tank limitation (claim 14).
Ground 2: Claims 1, 9-13, 15-18, and 20 are anticipated by or obvious over Cardamone.
- Prior Art Relied Upon: Cardamone (Application # 2015/0308244).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner contended that Cardamone, which describes a remote monitoring and control system for a deep well pump, discloses all limitations. Cardamone’s data server, which includes a web application for user interface, was mapped to the claimed server that receives commands. Its on-site control and communication computer was mapped to the claimed controller. Petitioner argued that a user adjusting pump operating parameters (e.g., frequency) via Cardamone's command interface constitutes receiving a command with a target value. The control computer then receives sensor data (e.g., inlet pressure, temperature) and controls the pump motor (the actuator) based on a control algorithm, thereby meeting the core limitations of claim 1. Petitioner further asserted that Cardamone's disclosure of temperature and pressure sensors (claim 9), wireless network components like WiFi and satellite modems (claim 11), and a distinct data server and on-site control computer (claim 15) explicitly teach the limitations of various dependent claims.
Ground 3: Claims 1, 7, and 20 are anticipated by or obvious over Gutierrez.
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Gutierrez, teaching a remote chemical injection system, discloses all elements of the challenged claims. Gutierrez’s central controller and remote computing device were mapped to the claimed server, which receives user commands via a GUI. The local motor controller for the pump system was mapped to the claimed controller. Petitioner asserted that Gutierrez’s system allows a remote user to send commands to adjust operational parameters (e.g., motor speed), which are transmitted to the local controller that monitors sensor data and controls pump actuators. This closed-loop control, where the controller determines if measurements satisfy a target value and adjusts accordingly, was argued to meet the limitations of independent claims 1 and 20. The system’s ability to send sensor data back to a user-associated record was argued to satisfy the limitations of claim 7.
Additional Grounds: Petitioner asserted an additional anticipation/obviousness challenge against claim 1 based on SCADA (a 2010 textbook on Supervisory Control and Data Acquisition systems), arguing that foundational SCADA principles disclose all elements of the claim.
4. Arguments Regarding Discretionary Denial
- Petitioner argued against discretionary denial under 35 U.S.C. §325(d), stating that the asserted prior art (Almadi, Cardamone, Gutierrez, SCADA) was not before the examiner during prosecution and is not cumulative of the prosecution art. The references allegedly teach claim elements that the applicant had previously argued were missing from the prior art of record.
- Petitioner argued against discretionary denial under Fintiv, asserting that the factors weigh in favor of institution. Key arguments included that the parallel district court proceeding is in its earliest stages with no trial date set, minimal investment has occurred, and the expected trial date (estimated September 2027) is substantially after the statutory deadline for a Final Written Decision in the IPR (estimated September 2026). Petitioner also stipulated it would not pursue the same invalidity grounds in district court if the IPR is instituted.
5. Relief Requested
- Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 11,175,680 as unpatentable.
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