TankLogix LLC v. SitePro Inc

1. Case Identification

• Case #: IPR2025-00761
• Patent #: 12,019,461
• Filed: April 11, 2025
• Petitioner(s): TankLogix, LLC
• Patent Owner(s): SitePro, Inc.
• Challenged Claims: 1-17

2. Patent Overview

• Title: Remote Control of Fluid-Handling Devices
• Brief Description: The ’461 patent describes a method and system for the remote monitoring and control of industrial fluid-handling devices, such as those used in the oil and gas industry. The system involves a local computer at a fluid-handling site, a remote server that receives data and user commands, and a remote client device for user interaction, with a focus on authenticating users before allowing control.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kahn, Gutierrez, Almadi, and SCADA - Claims 1-17 are obvious over Kahn in view of Gutierrez, Almadi, and SCADA.

• Prior Art Relied Upon: Kahn (Patent 7,424,399), Gutierrez (Patent 9,709,995), Almadi (Patent 8,667,091), and SCADA (Supervisory Control and Data Acquisition, 4th Edition, 2010).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that the combination of references taught every limitation of the challenged claims. Independent claim 1, which is representative, recites a fluid processing method comprising multiple steps performed by local and server computer systems. Petitioner mapped these steps as follows:
    • Kahn was asserted as the primary reference, teaching a remote monitoring and control system for fluid delivery. It disclosed a local computer system receiving fluid property data from sensors at a fluid-handling site (e.g., a water treatment plant), a centralized server system receiving this data over a network, and a remote client device. Critically, Kahn taught obtaining credentials from a user, determining authorization based on those credentials (including hosting data for sites the user is not authorized to interact with), and providing a user interface to visualize the fluid property data after authorization.
    • Gutierrez was cited for teaching specific remote control functionalities in the oil and gas context. It disclosed a central controller (server) receiving commands from a remote user to control a fluid-handling device (a chemical injection pump), thereby teaching the limitations of receiving a command from a client and causing the local computer to effectuate that command. Gutierrez also disclosed changing the state of the pump through a sequence of target states, such as ramping speed up or down to mitigate shocks, addressing limitations in dependent claims 2 and 3.
    • Almadi was used to provide further detail on modern industrial automation systems. It taught an integrated node (server) interfacing with remote subsystems (local computers/devices) in an oil and gas environment. Almadi disclosed using various industrial communication protocols (e.g., Modbus RTU), translating between protocols, and employing intelligent field devices that could self-monitor and self-regulate, mapping to limitations in dependent claims 7, 9, 11, and 14.
    • SCADA, a technical publication, was used to demonstrate the general knowledge of a POSITA regarding standard industrial control systems. It provided background on common practices, including the use of Remote Terminal Units (RTUs), master-slave communication protocols like Modbus, and the use of redundant bits (e.g., Cyclic Redundancy Check) for data integrity, which mapped to limitations in dependent claims 15 and 16.
  • Motivation to Combine: Petitioner argued a POSITA would combine these references because they all address the same technical field of remote industrial process control. A POSITA starting with Kahn’s general framework for a remote monitoring system with user authorization would naturally look to well-known systems and components described in Gutierrez, Almadi, and SCADA to implement a robust and efficient system for the oil and gas industry. Combining these known elements—such as Gutierrez's pump control methods, Almadi's protocol translation, and SCADA's standard communication protocols—was argued to be a simple and predictable application of known technologies to improve Kahn's system.
  • Expectation of Success: Petitioner asserted that a POSITA would have a high expectation of success because the combination involved applying conventional technologies for their intended purposes. The references were not mutually exclusive but rather provided complementary details for building a comprehensive remote control system, leading to the predictable result of an automated, secure fluid-handling system.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) based on the Fintiv factors would be inappropriate.
• Factor 1 (Stay): Petitioner stated it will seek a stay of the co-pending district court litigation, favoring institution.
• Factor 2 (Trial Date): No trial date was set in the parallel proceeding, and the court's median time-to-trial statistics suggested a trial would occur in September 2027, substantially after the expected Final Written Decision date of September 2026.
• Factor 3 (Investment): The co-pending litigation was in its early stages with minimal investment, as claim construction positions and invalidity contentions had not been exchanged and discovery had not opened.
• Factor 4 (Stipulation): Petitioner stipulated that it would not pursue in district court any invalidity ground raised or that reasonably could have been raised in the IPR, weighing strongly against denial.
• Factor 6 (Merits): Petitioner contended that the strong merits of the unpatentability grounds, as laid out in the petition, favored institution.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of the ’461 patent as unpatentable under 35 U.S.C. §103.