PTAB

IPR2025-01445

Liberty Energy Services LLC v. US Well Services LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Hydraulic Fracturing System with High Density Pumps
  • Brief Description: The ’162 patent relates to a hydraulic fracturing system comprising a fluid source, a plurality of electric-powered pumps, and a distribution system. The invention is particularly directed to a fitting that connects a hose from the fluid source to a pump, where the fitting has a first end for receiving the hose at a first diameter and a second end for coupling to the pump at a second, different diameter.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cicci, Coli, and Dixon - Claims 1-4, 8-10, and 14 are obvious over Cicci, Coli, and Dixon.

  • Prior Art Relied Upon: Cicci (Patent 11,549,348), Coli (Application # 2012/0255734), and Dixon (2018 Product Catalogs).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cicci disclosed a conventional hydraulic fracturing system with a fluid source, pumps, a distribution manifold, and flexible hoses with fittings connecting the hoses to the pumps. Coli taught improving such systems by using electric-powered, multi-plunger (e.g., quintuplex) pumps to increase efficiency, reduce footprint, and lower emissions. The Dixon product catalogs disclosed commercially available "Frac Fittings" for hydraulic fracturing, including one-piece fittings with a smaller diameter shank end for a hose and a larger diameter hammer union end for coupling to a pump, thereby teaching the claimed reducer fitting structure.
    • Motivation to Combine: A POSITA would combine Coli with Cicci to implement the known benefits of electric-powered pumps in a standard fracturing system. A POSITA would have been motivated to look to a commercial supplier like Dixon to find an appropriate, durable fitting to connect the hoses to the pumps as disclosed in Cicci, and would have found Dixon’s one-piece reducer fittings suitable for this purpose.
    • Expectation of Success: Petitioner asserted that combining these elements involved the application of known techniques (electric pumps, commercial fittings) to a known system (a fracturing spread) to achieve predictable improvements in efficiency and reliability.

Ground 2: Obviousness over Cicci, Coli, Dixon, and Liu - Claims 1-6, 8-12, and 14 are obvious over the combination for Ground 1 in view of Liu.

  • Prior Art Relied Upon: Cicci (’348 patent), Coli (’734 application), Dixon (2018 Product Catalogs), and Liu (Pipeline Engineering textbook, 2003).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the combination from Ground 1 and added the teachings of Liu. Petitioner argued that Liu, a standard textbook on fluid mechanics, provided the scientific rationale for using a smaller-diameter hose with a larger-diameter pump inlet. Liu explained that slurry flow velocity must be kept above a certain threshold to prevent proppant from "dropping out" and creating blockages. Since velocity is a function of flow rate and pipe diameter, Liu taught a POSITA how to calculate and select an appropriate hose diameter to maintain the required velocity.
    • Motivation to Combine: A POSITA designing the fracturing system of Cicci and Coli would have been motivated to consult an established reference like Liu to apply fundamental fluid dynamics principles. The goal would be to optimize the system by sizing hoses to prevent the well-known problem of proppant drop-out, which could lead to selecting a hose diameter smaller than the standard pump inlet, thus necessitating the reducer fitting taught by Dixon.
    • Expectation of Success: Applying established, predictable principles of fluid dynamics from a textbook (Liu) to a standard hydraulic fracturing system would have been a routine design optimization with a high expectation of success.

Ground 3: Obviousness over Cicci, Coli, Dixon, Liu, and Gardner-Denver - Claims 1-14 are obvious over the combination for Ground 2 in view of Gardner-Denver.

  • Prior Art Relied Upon: Cicci (’348 patent), Coli (’734 application), Dixon (2018 Product Catalogs), Liu (Pipeline Engineering textbook, 2003), and Gardner-Denver (pump operating manual, 2005).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added the Gardner-Denver pump manual to the prior art combination from Ground 2. Petitioner highlighted that Coli expressly identified a suitable pump as the “SWGS-2500 Well Service Pump sold by Gardner Denver.” The Gardner-Denver manual provided the specific technical details for this pump, disclosing that it came with standard 6-inch or 8-inch threaded inlet connections (for hammer unions). This disclosure confirmed that large-diameter pump inlets were standard, reinforcing the need for a reducer fitting to connect a smaller, optimally-sized hose.
    • Motivation to Combine: Coli provided an express motivation to consult Gardner-Denver’s materials by specifically naming its pump. A POSITA seeking to implement the system taught by Coli would naturally look to the manufacturer's documentation (Gardner-Denver) for pump specifications, including inlet connection sizes.
    • Expectation of Success: Using the specific operating parameters and connection sizes from the pump manual for the exact pump model identified in the primary reference was presented as a straightforward implementation step with no technical uncertainty.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 1-14 based on combinations that also included Kemper (a webpage disclosing union swages) and ANSI/HI 6.1 (an industry standard for reciprocating pumps) to further support the obviousness of using reducer fittings and selecting hose diameters based on fluid velocity constraints.

4. Key Technical Contentions (Beyond Claim Construction)

  • Hose Sizing as a Standard Engineering Trade-Off: A central technical argument, primarily supported by Liu, was that selecting hose and fitting diameters for a slurry system is a routine engineering optimization. A POSITA would need to balance competing factors: the hose must be narrow enough to maintain fluid velocity and prevent proppant drop-out, but wide enough to avoid excessive pressure drop, cavitation, and abrasion. Petitioner argued that this known trade-off would lead a POSITA to select a hose diameter based on flow parameters, which may differ from the standard pump inlet size, thus rendering the use of a reducer fitting obvious.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-14 of Patent 11,009,162 as unpatentable.