PTAB

IPR2025-01217

Aesthetic Management Partners LLC v. HydraFacial LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Skin Treatment Apparatus
  • Brief Description: The ’477 patent describes a skin treatment apparatus, such as for microdermabrasion, that includes a console housing a manifold system. The system is designed to connect to multiple containers of treatment materials and selectively deliver them through a supply conduit to a handpiece assembly, while a vacuum source removes waste.

3. Grounds for Unpatentability

Ground 1: Obviousness over Karasiuk and Palmer - Claims 1, 3, 6-10, 12, 14-16, 18, 20 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 Karasiuk disclosed a basic microdermabrasion system with a handpiece, a vacuum source, a waste conduit, and a single fluid reservoir for a treatment solution. Petitioner argued that Palmer disclosed a medical device for delivering selected fluids from multiple reservoirs via a selector valve (a manifold system) and housing these components in a mobile cart (a console). The combination of these references allegedly taught every element of independent claim 1, as a person of ordinary skill in the art (POSITA) would have replaced Karasiuk's single reservoir with Palmer’s multi-reservoir selector system and housed the combined components in Palmer's mobile cart.
    • Motivation to Combine: Petitioner argued a POSITA would combine these references to improve the flexibility and functionality of Karasiuk’s system. Karasiuk itself suggested the desirability of using various fluids like lotions and vitamins. Palmer directly addressed the inefficiency of using single-solution systems, teaching a selector means for easy switching between multiple treatment solutions. This combination would allow for sequential delivery of different treatments during a single procedure, reduce downtime, and provide portability and organization via Palmer’s modular cart design.
    • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success. Both references are directed to medical devices that deliver treatment solutions via a handpiece. Palmer’s teachings on multi-fluid delivery were asserted to be broadly applicable to other medical procedures like microdermabrasion. The combination was characterized as a simple substitution of a known element (a multi-container system for a single container) to achieve predictable results.

Ground 2: Obviousness over Karasiuk, Palmer, and Trueba - Claims 1-20 are obvious over Karasiuk and Palmer in view of Trueba.

  • Prior Art Relied Upon: Karasiuk (’415 application), Palmer (’604 patent), and Trueba (Patent 6,684,880).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds upon the Karasiuk-Palmer combination by adding the teachings of Trueba. Petitioner argued that Trueba disclosed a fluid delivery system controlled by a computer linked to a user input device, specifically a touch screen, for selecting and dispensing fluids. Adding Trueba’s teachings to the Karasiuk-Palmer system would render obvious claims requiring a “computing device” (e.g., claim 2), a “user input device” (e.g., claim 3), and a “touch screen” (e.g., claim 4). In the proposed combination, Trueba’s computer and touch screen would automate the control of Palmer’s manual selector valve.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Trueba's computer control to add precision, automation, and clarity to the Karasiuk-Palmer system. This modification would enable automated delivery following complex administration protocols, reduce the potential for human error associated with manual selection, and allow for programming of dosages and sequences.
    • Expectation of Success: Petitioner asserted a high expectation of success because automating a manual process with well-known computer control techniques was a common and predictable design choice. The technical principles of fluid delivery in all three references were similar, making the integration of Trueba’s control system into the Karasiuk-Palmer platform straightforward for a POSITA.

Ground 3: Obviousness over Greenberg - Claims 1, 3, 6-10, 12, 14-16, 18, 20 are obvious over Greenberg.

  • Prior Art Relied Upon: Greenberg (Application # 2003/0093089).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Greenberg alone disclosed all elements of the challenged claims. Greenberg described a microdermabrasion system (“apparatus 10,” argued to be a console) with a plurality of supply containers holding different treatment particulates, a hand tool, and a vacuum pump. Petitioner contended that Greenberg’s valve system (specifically valve 108), which selectively connected the pneumatic source and hand tool to a chosen supply container, constituted the claimed “manifold system.” Greenberg also allegedly taught sequential delivery by disclosing treatment with highly abrasive particles followed by organic ones. The argument relied on the ’477 patent’s own definition of “fluid” as including fine solids, thereby encompassing Greenberg’s particulates.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Karasiuk-Palmer with Wunsch (adding an automated manifold and sequencer); Karasiuk-Palmer-Wunsch with Trueba; and Greenberg with Trueba. These grounds relied on similar theories of improving functionality through automation and computer control.

4. Key Technical Contentions (Beyond Claim Construction)

  • "Particulates" as "Fluid": A central technical contention underpinning the Greenberg grounds was that Greenberg’s disclosure of applying treatment "particles" carried by an airflow met the ’477 patent’s definition of "fluid." Petitioner argued the patent’s specification defined "treatment material" and "fluid" synonymously and broadly to include "a plurality of fine solids," which corresponded directly to Greenberg’s abrasive particles. Therefore, Greenberg’s system, which delivered selectable particulates, was alleged to be a fluid-delivery system as claimed.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’477 patent as unpatentable.