PTAB

IPR2025-01169

Aesthetic Management Partners LLC v. HydraFacial LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Skin Treatment System
  • Brief Description: The ’052 patent discloses a skin treatment apparatus, such as for microdermabrasion, that includes a console housing a manifold system. The system is configured to releasably hold multiple fluid containers and selectively deliver different liquid treatment materials to a handpiece assembly for application to a subject's skin.

3. Grounds for Unpatentability

Ground 1: Obviousness over Karasiuk and Palmer - Claims 1, 4-12, and 15-17 are obvious over Karasiuk in view of Palmer.

  • Prior Art Relied Upon: Karasiuk (Application # 2003/0212415) and Palmer (Patent 5,199,604).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the combination of Karasiuk and Palmer disclosed every element of the challenged claims. Karasiuk was argued to teach a foundational microdermabrasion system with a handpiece (device 10), a single fluid reservoir, and a vacuum source that performs the dual functions of drawing treatment liquid to the handpiece and simultaneously removing waste from the treatment site. This dual-function vacuum was a key limitation cited by the Examiner during prosecution. Palmer was argued to teach a medical fluid delivery system comprising a console (mobile cart 170) that houses multiple fluid reservoirs and a selector means (manifold 16) allowing a user to choose which fluid to deliver to a handpiece. Petitioner contended that combining these teachings resulted in a system with a console, a manifold, multiple fluid containers, a handpiece, a vacuum source, and a user-selection mechanism, as recited in independent claims 1 and 11.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to modify Karasiuk's system with Palmer's multi-fluid delivery technology to enhance its functionality. Karasiuk itself suggested the use of various treatment solutions, creating a recognized need for a more flexible system. Palmer directly addressed this need by providing an apparatus for easy selection among multiple fluids, avoiding the "time-consuming and costly" process of swapping single containers. Furthermore, incorporating the components into Palmer's mobile cart console was a known method for improving the portability, organization, and usability of medical devices.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success in making this combination. Both references operate in the analogous field of delivering treatment fluids to a patient via a handpiece. The integration was presented as a simple substitution of one known component (Karasiuk's single reservoir) with another known component (Palmer's multi-reservoir and selector) to achieve the predictable and desired outcome of selective, multi-fluid microdermabrasion.

Ground 2: Obviousness over Karasiuk, Palmer, and Trueba - Claims 1-17 are obvious over Karasiuk in view of Palmer and Trueba.

  • Prior Art Relied Upon: Karasiuk (Application # 2003/0212415), Palmer (Patent 5,199,604), and Trueba (Patent 6,684,880).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground augmented the primary Karasiuk-Palmer combination with the teachings of Trueba to address limitations in dependent claims requiring a display and user input device, particularly a touch screen (claims 2-3 and 13-14). Trueba disclosed a fluid delivery system controlled by a computer (controller 100) linked to a touch screen user interface (105). Petitioner argued that integrating Trueba's controller and touch screen into the console of the Karasiuk-Palmer combination would satisfy the limitations of a console comprising a display that also serves as a user input device for controlling fluid flow.
    • Motivation to Combine: The motivation to add Trueba's technology was to introduce automation, precision, and a modern user interface. A POSITA would have sought to replace the manual selector knob of the Karasiuk-Palmer system with Trueba's computer-controlled system to enable automated delivery based on complex, pre-programmed protocols. This automation would reduce the cognitive load on the operator, minimize the risk of human error, and allow for more sophisticated and repeatable treatment regimens, such as the sequential delivery also addressed by claim 6.
    • Expectation of Success: Success was deemed highly likely because computer-controlled fluid delivery systems with touch screen interfaces were well-established technologies by the patent's critical date. The modification required only the application of known automation techniques to the manual selection mechanism of the base combination, a task well within the skill of a POSITA.

Ground 3: Obviousness over Karasiuk, Palmer, and Wunsch - Claims 1, 4-12, and 15-17 are obvious over Karasiuk in view of Palmer and Wunsch.

  • Prior Art Relied Upon: Karasiuk (Application # 2003/0212415), Palmer (Patent 5,199,604), and Wunsch (Patent 4,559,036).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground presented an alternative modification to the Karasiuk-Palmer system, where Palmer's manual selector means was replaced with Wunsch's automated manifold selector and sequencer-timer. Wunsch disclosed an apparatus for sequentially dispensing multiple intravenous solutions from separate containers through a manifold (22) with multiple valves (40). The flow was controlled automatically by a programmable sequencer-timer (13), which served as the user input device. This combination was argued to meet the limitations of a user-selectable, multi-fluid system. Wunsch also taught releasably coupled fluid containers (claim 4) and a manifold configured for at least four containers (claim 5).
    • Motivation to Combine: A POSITA would have been motivated to incorporate Wunsch’s system to achieve fully automated sequential fluid delivery, which offered greater convenience and accuracy than Palmer's manual knob. Wunsch provided additional compelling benefits, including a system for flushing the manifold to prevent cross-contamination between different treatment fluids and the use of a disposable manifold to ensure sterility between patients. These features directly addressed known challenges in multi-fluid medical systems.
    • Expectation of Success: The replacement of Palmer’s selector with Wunsch's manifold and sequencer was argued to be a straightforward substitution of one functional block for another, more advanced one. While Wunsch was directed to intravenous delivery, a POSITA would have readily understood its applicability to topical delivery systems like Karasiuk's, as the underlying principles of automated fluid selection and control are analogous.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Mercier (to teach an alternative handpiece design with specific connector locations for claim 9) and further combinations of Wunsch and Trueba. These grounds relied on similar design modification theories to address specific dependent claims.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-17 of Patent 9,550,052 as unpatentable under 35 U.S.C. §103.