PTAB

IPR2025-00669

Vertiv Corp v. Valtrus Innovations Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Partition for Varying the Supply of Cooling Fluid
  • Brief Description: The ’179 patent discloses methods and systems for cooling data center equipment racks. The invention uses temperature sensors to monitor rack temperatures and manipulates a "controllable partition" to vary the supply of cooling fluid to different zones within the data center, thereby optimizing cooling efficiency.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-15 by Bash

  • Prior Art Relied Upon: Bash (Application # 2004/0065097A1).
  • Core Argument for this Ground: Petitioner argued that Bash anticipates every limitation of claims 1-15. The argument relied on the Patent Owner’s anticipated construction of "partition" as any device capable of manipulating fluid flow. Under this broad construction, Bash’s disclosed "dynamically controllable vents" meet the "controllable partition" limitation.
    • Prior Art Mapping: Bash disclosed a data center cooling method that activates a cooling system and opens controllable vents (the alleged "partition") to supply cooling fluid from a raised-floor plenum to equipment racks. The system senses temperatures at the racks, determines if they are within a predetermined range, and manipulates the opening size of the vents to increase or decrease fluid flow in response to temperatures falling outside that range. Petitioner asserted that Bash also teaches the limitations of all dependent claims, including those related to pressure sensing, numerical modeling, and the use of mobile sensors.

Ground 2: Anticipation of Claims 1-7 and 10-15 by Patel

  • Prior Art Relied Upon: Patel (Patent 6,574,104).
  • Core Argument for this Ground: Similar to the argument against Bash, Petitioner contended that Patel anticipates the challenged claims. Patel, developed by the same applicant as Bash with overlapping inventors, discloses a nearly identical system. The argument again hinged on interpreting Patel’s "dynamically controllable vents" as the claimed "controllable partition."
    • Prior Art Mapping: Patel was shown to teach a cooling system that supplies fluid through a raised-floor plenum to racks via controllable vents. The system activates, senses temperatures and pressures, compares them to set point ranges, and manipulates the vents and fan output in response. Petitioner argued that Patel’s disclosure is essentially verbatim to Bash’s for many key limitations and teaches all elements of the challenged claims, including the methods of increasing or decreasing cooling output based on sensed conditions.

Ground 3: Obviousness of Claims 1-6 and 11-13 over Bishop, Feeney, and Kochavi

  • Prior Art Relied Upon: Bishop (Application # 2002/0149911), Feeney (Patent 5,467,609), and Kochavi (Patent 5,979,167).
  • Core Argument for this Ground: This ground was based on the plain and ordinary meaning of "partition" as a "barrier or wall that subdivides a space." Petitioner argued a person of ordinary skill in the art (POSITA) would combine the references to arrive at the claimed invention.
    • Prior Art Mapping: Bishop taught a system for cooling equipment cabinets using temperature-controlled dampers in floor tiles but did not expressly teach subdividing the under-floor plenum. Feeney taught a raised-floor system with a subdivided plenum using vertical panels to create defined airflow paths, addressing pressure imbalances—a problem Bishop acknowledged. Kochavi taught an air conditioning system that uses a pressure sensor to control a bypass damper to maintain constant pressure in a main duct.
    • Motivation to Combine: A POSITA would combine Bishop with Feeney to improve Bishop’s system by preventing the pressure imbalances caused by its individual dampers. Feeney’s use of subdividing barriers provided a known solution. A POSITA would have been motivated to integrate Bishop’s temperature-responsive dampers into Feeney’s plenum-dividing barriers to achieve zoned cooling with stable pressure. The POSITA would then incorporate Kochavi’s pressure-based control logic to further enhance system stability and efficiency, a routine step to optimize such systems.
    • Expectation of Success: The combination involved integrating known elements for their established functions, which would predictably result in a more flexible, reliable, and efficient cooling system capable of managing heat loads in distinct sub-zones.

4. Key Claim Construction Positions

  • "partition" (claims 1-15): This term was central to the petition’s alternative arguments.
    • Petitioner’s Proposed Construction: "a barrier or wall that subdivides a space." This construction supported the obviousness argument in Ground 3.
    • Patent Owner’s Implied Construction: "a device capable of manipulating cooling fluid flow." Petitioner used this broader construction, derived from infringement contentions in related litigation, to support the anticipation arguments in Grounds 1 and 2, where vents were argued to be partitions.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under both §314(a) (Fintiv) and §325(d).
    • Fintiv Factors: Petitioner argued the Fintiv factors favored institution, noting that the parallel district court litigation was at an early stage with minimal investment, and the trial date was scheduled less than four months before the statutory deadline for a Final Written Decision in the IPR. Petitioner also stated its intent to stipulate not to pursue the same invalidity grounds in district court if the IPR is instituted.
    • §325(d): Petitioner argued denial was improper because the prior art references asserted in the petition were not before the examiner during the original prosecution of the ’179 patent.

6. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-15 of the ’179 patent as unpatentable.