PTAB
IPR2025-00652
TankLogix LLC v. SitePro Inc
Key Events
Petition
Table of Contents
petition
1. Case Identification
- Case #: IPR2025-00652
- Patent #: 11,294,403
- Filed: February 28, 2025
- Petitioner(s): TankLogix, LLC
- Patent Owner(s): SitePro, Inc.
- Challenged Claims: 1-23 and 25-30
2. Patent Overview
- Title: Remote Control of Fluid-Handling Devices
- Brief Description: The ’403 patent discloses a system for the remote monitoring and control of industrial fluid-handling sites. The system comprises a local computer system at a fluid site (including a pump, valve, and tank with a fluid-level sensor) that communicates with a remote server, which authenticates a user on a client device and then provides information and control commands to the local site.
3. Grounds for Unpatentability
Ground 1: Anticipation of Claims 1-2, 4-5, and 7 by Kahn
- Prior Art Relied Upon: Kahn (Patent 7,424,399).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Kahn, which discloses a remote monitoring and control system for fluid delivery, teaches every limitation of independent claim 1. Kahn’s “Sensor unit 110,” which can be placed at any point in a fluid distribution system, was alleged to be the claimed "first computer system" at a "first fluid handling site." Kahn’s disclosure of actuators controlling valves and pumps, sensors detecting fluid levels (e.g., via pipe pressure), and reservoirs or tanks was mapped to the claimed local site components. Kahn’s "centralized data collection points" were identified as the remote "server system" that receives sensor data. Further, Petitioner asserted Kahn’s requirement for users to log in with a username and password to access data from authorized sites meets the limitations of obtaining credentials and determining authorization. Finally, Kahn’s graphical user interface (GUI) on a remote computer for displaying sensor data was argued to meet the limitation of providing a user interface indicating the fluid level. Petitioner also mapped Kahn’s disclosures to dependent claims 2, 4, 5, and 7.
Ground 2: Obviousness of Claims 1-3, 6, 8-23, and 25-30 over Kahn in view of Almadi and Gutierrez
- Prior Art Relied Upon: Kahn (Patent 7,424,399), Almadi (Patent 8,667,091), and Gutierrez (Patent 9,709,995).
- Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that the challenged claims are obvious over Kahn as a primary reference, supplemented by the teachings of Almadi and Gutierrez. Kahn provided the foundational system for remote monitoring and control with user-specific access. Almadi was cited for its disclosure of modern automation architecture for industrial operations, specifically in oil and gas applications. Petitioner argued Almadi teaches an "integrated node" (the claimed server) that interfaces with remote subsystems and field devices (the claimed local computer system), which perform sensor functions (e.g., tank level) and actuator functions (e.g., pump control). Almadi also allegedly teaches the use of various communication protocols, including wireless cellular connections, and the use of a GUI for configuration and monitoring. Gutierrez was cited for its disclosure of a chemical injection system for oil and wastewater transport, providing further context and specific details for applying such remote control systems in the oil and gas industry, including the use of oil/water separation tanks.
- Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine these references because they address the same technical field of remote fluid handling control. A POSITA, starting with the general framework taught by Kahn, would be motivated to look to more detailed references like Almadi and Gutierrez for specific, known technologies to implement such a system in a modern oil and gas environment. The motivation would be to achieve the predictable benefits of enhanced efficiency, safety, and automation by integrating Almadi's specific automation architecture and Gutierrez's oil-field-specific systems into Kahn's foundational remote access and control platform.
- Expectation of Success: Petitioner argued there would be a high expectation of success because combining the references involved applying known, detailed automation technologies from Almadi and Gutierrez to the well-understood remote control architecture of Kahn. The combination was presented as the predictable integration of compatible technologies, not an inventive leap.
4. Arguments Regarding Discretionary Denial
- Advanced Bionics and §325(d): Petitioner argued against discretionary denial under §325(d), asserting that none of the cited prior art references (Kahn, Almadi, Gutierrez) were before the examiner during the prosecution of the ’403 patent. Petitioner further contended that the references are not cumulative to the art of record, as they explicitly teach claim elements, such as translating commands, that the applicant had argued were absent from the previously considered art.
- Fintiv Factors and §314(a): Petitioner argued that the Fintiv factors strongly favor institution. The expected final written decision date for the inter partes review (IPR) (approx. September 2026) is substantially before the median time-to-trial in the parallel district court litigation (approx. September 2027). The litigation was described as being in its very early stages, with minimal investment by the parties and no discovery or claim construction exchange having occurred. Petitioner also stipulated that, if the IPR is instituted, it will not pursue the same invalidity grounds in the district court, thus mitigating concerns of overlapping issues.
5. Relief Requested
- Petitioner requests institution of IPR and cancellation of claims 1-23 and 25-30 of the ’403 patent as unpatentable.
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