PTAB

IPR2025-00653

TankLogix LLC v. SitePro Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remote Control of Fluid-Handling Devices
  • Brief Description: The ’504 patent describes a fluid processing system that uses a computer system at a fluid handling site to receive data from sensors in a fluid tank. A remote server system receives this data, authenticates a user on a client device, and provides a user interface to remotely control fluid-handling devices (e.g., pumps, valves) at the site.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-16 and 20 by Cardamone

  • Prior Art Relied Upon: Cardamone (Application # 2015/0308244).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cardamone discloses every limitation of independent claims 1 and 20. Cardamone’s deep well pump system was mapped to the claimed invention, with its on-site “control and communication computer 126” corresponding to the claimed “first computer system,” its remote “data server 134” corresponding to the “server system,” and its “GUI computer 130” corresponding to the “client computing device.” Cardamone’s system receives sensor data (e.g., pressure, temperature), provides for user authentication via username and password, presents a user interface via a web application, receives commands to adjust operating parameters, and causes the on-site computer to change the pump’s state through a sequence of target states (e.g., controlling motor drive based on sensory data). Petitioner asserted that Cardamone’s disclosure of various communication protocols (e.g., Modbus), operating modes, and control algorithms anticipates the features of the dependent claims.

Ground 2: Anticipation of Claims 1 and 17-20 by Kahn

  • Prior Art Relied Upon: Kahn (Patent 7,424,399).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Kahn, which describes a fluid distribution monitoring system, anticipates claims 1 and 17-20. Kahn’s “Sensor unit 110” with an integrated processor was mapped to the “first computer system,” and its “centralized data collection points” were mapped to the claimed “server system.” Petitioner argued Kahn discloses a system that receives fluid property data from sensors at a fluid handling site (e.g., a water treatment plant), includes fluid-handling devices like pumps and valves, and provides for remote control via actuators. The Kahn server authenticates users with different access levels, presents data on a remote GUI, and receives commands to effectuate changes, such as for recalibration. Petitioner further argued that Kahn’s disclosure of multiple distributed sensor units, computers, and tanks across a water system anticipates the “plurality” limitations of dependent claims 17-19.

Ground 3: Obviousness of Claims 2, 8, and 13 over Cardamone or Kahn in view of SCADA

  • Prior Art Relied Upon: Cardamone (Application # 2015/0308244) or Kahn (Patent 7,424,399), in view of SCADA (Supervisory Control and Data Acquisition, 4th Edition, 2010).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that even if Cardamone or Kahn do not explicitly disclose every detail of claims 2, 8, and 13, a person of ordinary skill in the art (POSITA) would find it obvious to implement the general systems of Cardamone or Kahn using the well-known, industry-standard techniques taught by SCADA.
      • For claim 2 (ramping speed), SCADA explicitly teaches using PID controllers to control machine speed and stepper motors to increment or decrement speed, which a POSITA would apply to the pumps in Cardamone or Kahn.
      • For claim 8 (translating commands), SCADA teaches using transducers to translate between different communication languages and protocols (e.g., electrical current to air pressure) used between field instruments and remote terminal units (RTUs), which addresses the claimed "steps for translating commands."
      • For claim 13 (signal formats), SCADA discloses using various formats including command codes, on-off signals (e.g., for stepper motors), and application-program interfaces for supervisory control, which a POSITA would use to implement the systems of the primary references.
    • Motivation to Combine: A POSITA would combine the references because Cardamone and Kahn describe general remote fluid control systems, while SCADA provides specific, conventional details on how such industrial control systems are implemented. A POSITA would look to a standard reference like SCADA to implement the functionalities described in Cardamone or Kahn, leading to predictable results.
    • Expectation of Success: Success would be expected as the combination involves applying standard industrial control techniques (SCADA) to known types of remote monitoring systems (Cardamone/Kahn).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) or §314(a) is inappropriate.
    • Advanced Bionics Factors: Petitioner asserted that the relied-upon prior art (Cardamone, Kahn, SCADA) was not before the Examiner during prosecution and is not cumulative of the prosecution art.
    • Fintiv Factors: Petitioner argued the factors weigh against denial because: (1) the parallel district court proceeding is in its earliest stages with minimal investment; (2) the court’s median time to trial (Sept. 2027) is substantially after the expected Final Written Decision (FWD) date (Sept. 2026); and (3) Petitioner stipulated that, if IPR is instituted, it will not pursue the same invalidity grounds in the district court litigation.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-20 of the ’504 patent as unpatentable.