PTAB

IPR2025-01445

Liberty Energy Services LLC v. U.S. Well Services, LLC

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1. Case Identification

2. Patent Overview

  • Title: Hydraulic Fracturing System with Fitting
  • Brief Description: The ’162 patent discloses a hydraulic fracturing system comprising an electric-powered pump and a flexible hose connected by a special fitting. The fitting is designed with a first end for receiving the hose at a first diameter and a second end for coupling to the pump at a larger, second diameter.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cicci, Coli, and Dixon - Claims 1-4, 8-10, and 14 are obvious over Cicci in view of 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 pumps, flexible hoses, and fittings connecting the pumps to a manifold. While Cicci taught the general arrangement, Coli supplied the specific teaching of an electric-powered, multi-plunger (quintuplex) pump suitable for fracturing operations. Dixon, a catalog of commercially available fracturing components, disclosed the claimed fitting: a "Frac Fitting" with a smaller diameter shank end for a hose and a larger diameter hammer union end for a pump connection, including an integral reducer between the two ends.
    • Motivation to Combine: A POSITA would combine Cicci and Coli to incorporate the known benefits of electric pumps (e.g., increased efficiency, reduced emissions, smaller footprint) into a standard fracturing system. Motivated by Cicci’s disclosure of using fittings, a POSITA would look to a well-known supplier like Dixon for an appropriate off-the-shelf component. Dixon’s frac fittings were designed for this exact purpose, and using a reducing fitting would have been a simple, known solution to the common task of connecting a standard-sized hose to a pump with a different, often larger, standard inlet size.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination merely involved assembling known components for their intended purposes. Combining an electric pump from Coli with the system of Cicci was applying a known improvement, and using a standard fitting from Dixon to connect a hose to a pump was a routine design choice.

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

  • Prior Art Relied Upon: Cicci (Patent 11,549,348), Coli (Application # 2012/0255734), Dixon (2018 Product Catalogs), and Liu (a 2003 textbook on Pipeline Engineering).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon Ground 1, adding the teachings of Liu to address claim limitations related to selecting specific diameters to optimize fluid flow (claims 5-6). Liu taught well-known scientific principles of slurry flow in pipes, explaining the critical need to maintain fluid velocity above a certain threshold to prevent proppant (sand) from "dropping out" of the slurry and clogging the hose.
    • Motivation to Combine: A POSITA designing the fracturing system of Cicci/Coli/Dixon would have been motivated to consult a standard reference like Liu to address the known problem of proppant drop-out. Liu provided the scientific basis for why a POSITA would choose a smaller diameter hose connected to a larger pump inlet: a smaller hose increases slurry velocity for a given flow rate, preventing drop-out. This provided a direct motivation to select the specific reducing fitting taught by Dixon and to size the hose diameter based on flow rate calculations to avoid known failure modes.
    • Expectation of Success: Applying the established fluid dynamics principles from Liu to a known hydraulic fracturing system was a standard engineering task that would yield predictable results. Sizing hoses to maintain adequate slurry velocity was a routine optimization problem for a POSITA.

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

  • Prior Art Relied Upon: The combination from Ground 2, plus Gardner-Denver (an operating manual for the GD-2500Q pump).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added Gardner-Denver to provide specific, concrete details for the pump system. Coli expressly identified the "SWGS-2500 Well Service Pump sold by Gardner Denver" as a suitable pump. The Gardner-Denver manual provided the technical specifications for this pump, including its performance charts and its standard 6-inch and 8-inch inlet headers.
    • Motivation to Combine: A POSITA implementing the system described in Coli would be directly motivated to consult the Gardner-Denver manual for the exact pump referenced. This manual confirmed the existence of standard, large-diameter pump inlets (e.g., 6 inches), reinforcing the motivation to use a commercially available reducing fitting (like Dixon's) to connect a smaller, optimally-sized hose (e.g., 5 inches, per Liu's principles) to the pump. This provided a complete, practical roadmap for arriving at the claimed invention.
    • Expectation of Success: The expectation of success was high, as this step represented the final implementation detail: consulting the manufacturer’s own manual for a specified component to confirm its connection interface. This is a routine step in any system design and integration process.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Kemper (disclosing union swages) and ANSI/HI 6.1 (an industry standard for pump design providing slurry velocity ranges) but relied on similar design modification and optimization theories.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-14 of Patent 11,009,162 as unpatentable.