PTAB

IPR2025-00668

Vertiv Corp v. Valtrus Innovations Ltd

Key Events

Petition

petition

Title: Atmospheric Control Within a Building
Brief Description: The ’277 patent discloses methods for controlling atmospheric conditions in a building, such as a data center. The method involves sensing an atmospheric parameter at multiple locations, generating an empirical map from the sensor data, comparing this map to a template map of ideal conditions, identifying pattern differentials, and adjusting the cooling system accordingly.

Prior Art Relied Upon: Nakanishi (Patent 6,283,380)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Nakanishi discloses every limitation of the challenged claims. Nakanishi teaches a method for controlling the temperature in a computer room by sensing temperatures at multiple locations, performing a simulation based on the sensor data to generate a temperature distribution (the "empirical map"), and comparing this distribution to a preset, optimal temperature range (the "template map"). This comparison identifies "high temperature region[s]" (the "pattern differentials"), which are then used to determine corrective actions, such as adjusting fan speed and direction to supply cooling air toward the hot spots.
- Key Aspects: Petitioner contended that Nakanishi’s "simulated temperature distribution," which can be image-displayed on a monitor, meets the patent's requirement for an "empirical atmospheric map." Similarly, the "preset temperature range" that defines an "optimum temperature state" in Nakanishi corresponds to the claimed "template atmospheric map."

Prior Art Relied Upon: Bishop (Application # 2002/0149911)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Bishop independently anticipates the challenged claims. Bishop describes a system for cooling electronic modules within cabinets in a data center. It teaches sensing temperatures at various locations, feeding the readings into a computer to generate a "three dimensional temperature graph" (the "empirical map"), and comparing the measured temperatures to low and high threshold temperatures that define an optimal range (the "template map"). When temperatures exceed the high threshold, a "hot spot" (a "pattern differential") is identified, and a controller takes corrective action by increasing the opening of a damper to provide more cooling air.
- Key Aspects: Petitioner highlighted that Bishop explicitly teaches using temperature readings from external sensors to "generate a three dimensional temperature graph for observation by an environment administrator," satisfying the visual "map" limitation under Petitioner’s proposed claim construction.

Prior Art Relied Upon: Nakanishi (Patent 6,283,380) and Bishop (Application # 2002/0149911)
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that, to the extent Nakanishi is found not to explicitly disclose a visual comparison of map images, combining Nakanishi with Bishop would have rendered this step obvious. Nakanishi provides a complete system for generating temperature distribution data and a template, while Bishop teaches the conventional practice of visually comparing such computer-generated thermal maps to evaluate cooling system adjustments and identify hot spots.
- Motivation to Combine: A POSITA would combine Bishop’s conventional visual comparison technique with Nakanishi’s automated control system to achieve the shared goal of effectively monitoring and correcting thermal issues in a computer room. Bishop is analogous art that addresses the same problem. Implementing this known technique in Nakanishi’s system would have been a routine step to improve monitoring and assessment.
- Expectation of Success: A POSITA would have had a reasonable expectation of success because Nakanishi's system already generates the necessary data for creating visual map images. Furthermore, software for performing such visual comparisons was commercially available, making the integration a low-cost, predictable improvement.

Petitioner argued for constructions of "empirical atmospheric map" and "template atmospheric map" that require the data to be "displayable as a visual representation of an area." This contrasts with the Patent Owner's implied construction from related litigation, which Petitioner characterized as broader, covering any "set of measured/model conditions" regardless of whether it is displayable. Petitioner asserted that the prior art anticipates the claims even under its narrower, more limiting construction.

Petitioner argued against discretionary denial under §314(a) and §325(d).
Fintiv (§314(a)): Petitioner contended that the parallel district court litigation is in a very early stage, with the trial scheduled after the statutory deadline for a Final Written Decision in the IPR. Petitioner also asserted that the grounds presented are compelling.
§325(d): Petitioner argued that the Board should not deny institution because the petition raises new issues of patentability. The Bishop reference was never before the Examiner during prosecution. While Nakanishi was cited in an Information Disclosure Statement (IDS), it was not substantively evaluated by the Examiner, who therefore erred by not considering its highly relevant teachings.

Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of the ’277 patent as unpatentable.