PTAB

IPR2025-01539

Liberty Energy Services LLC v. US Well Services LLC

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1. Case Identification

2. Patent Overview

  • Title: Hydraulic Fracturing System with Hose and Fitting
  • Brief Description: The ’420 patent describes a hydraulic fracturing system that uses an electric-powered, multi-plunger pump. The invention focuses on a flexible hose and a pair of fittings that connect a fluid source to the pump’s inlet, where the hose body has a specific diameter relative to the diameters of the end fittings to optimize fluid flow.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 9-16, and 18-19 are obvious over Cicci, Coli, Dixon, and Liu.

  • Prior Art Relied Upon: Cicci (Patent 11,549,348), Coli (Application # 2012/0255734), Dixon (2018 product catalogs), and Liu (a 2003 engineering textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination discloses all limitations of the challenged claims. Cicci taught a conventional hydraulic fracturing system with pumps, a fluid manifold, and flexible hoses with fittings connecting them. Coli taught using electric-powered, multi-plunger (quintuplex or triplex) pumps in such systems to improve efficiency and reduce the equipment footprint. Dixon, a catalog for fracturing components, disclosed commercially available “Frac Fittings” with different end diameters, such as a fitting with a 3-inch shank end to receive a hose and a 4-inch hammer union end to connect to a pump. Petitioner asserted this directly taught the claimed fitting structure with different first and second diameters.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the base system of Cicci with the improved electric, multi-plunger pumps of Coli to gain known benefits like reduced noise, emissions, and parasitic power losses. To connect these components, a POSITA would look to commercially available parts like the specialized fittings in the Dixon catalog. Finally, a POSITA would consult established engineering principles, as detailed in Liu’s textbook on slurry pipeline flow, to properly size the system’s hoses.
    • Expectation of Success: Petitioner contended that a POSITA would have a high expectation of success. The combination involved applying known technologies (electric pumps, commercial fittings) and fundamental engineering principles (slurry fluid dynamics) to a conventional system to achieve the predictable result of an efficient fracturing operation that avoids common problems like proppant dropout and pump cavitation. The key technical argument, based on Liu, was that a POSITA would have been motivated to select a hose diameter smaller than the connection diameters to maintain sufficient slurry velocity, preventing proppant from settling and creating blockages.

Ground 2: Claims 1-19 are obvious over Cicci, Coli, Dixon, Liu, and Gardner-Denver.

  • Prior Art Relied Upon: Cicci (Patent 11,549,348), Coli (Application # 2012/0255734), Dixon (2018 product catalogs), Liu (a 2003 engineering textbook), and Gardner-Denver (an operating manual for a GD-2500Q pump).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 by adding the Gardner-Denver reference. Petitioner argued that Coli expressly identified a Gardner-Denver "SWGS-2500" pump as a suitable example of a quintuplex pump. The Gardner-Denver manual provided the specific technical details for this commercially available pump, disclosing that it used standard 6-inch and 8-inch suction manifold connections. This disclosure provided a specific, concrete basis for the claimed fitting and connection diameters, such as the approximately 6-inch pump connection recited in dependent claim 2.
    • Motivation to Combine: The motivation was explicit. A POSITA implementing the system taught by Coli would be directly motivated to consult the Gardner-Denver manual to find the operating parameters and connection specifications for the very pump Coli recommended.
    • Expectation of Success: The expectation of success was high, as this combination merely involved using the manufacturer's own technical specifications for a component expressly identified in the primary prior art. It confirmed the obviousness of using standard, commercially available component sizes.

Ground 3: Claim 20 is obvious over the combination of Cicci, Coli, Dixon, and Liu, further in view of Kajaria (with or without Gardner-Denver).

  • Prior Art Relied Upon: The combination from Ground 1 or Ground 2, plus Kajaria (Patent 9,127,545).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued this combination rendered claim 20, which related to a hose with a third end for coupling to a second pump, obvious. Kajaria taught a hydraulic fracturing system layout where a single, common low-pressure pipeline from a fluid source feeds the inlets of multiple pumps. This contrasted with Cicci's layout, which used a separate hose for each pump connected to a central manifold.
    • Motivation to Combine: A POSITA would combine Kajaria’s single-line feed design with the Cicci-Coli system to gain significant benefits in operational efficiency. Kajaria’s design reduced clutter at the well site, required fewer hoses and manifold connections, and simplified assembly. Critically, by consolidating flow from multiple pumps into one line, it increased fluid velocity, reducing the likelihood of proppant settling and forming a blockage, especially during low-flow conditions.
    • Expectation of Success: The combination was a straightforward application of one known fluid distribution architecture (Kajaria) to another known fracturing system (Cicci-Coli) to achieve predictable benefits of simpler assembly and more reliable slurry transport.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 8 and 17 based on the further combination of ANSI/HI 6.1, a technical standard for reciprocating pumps. This reference was used to provide specific, known velocity ranges for slurry flow to avoid both proppant dropout (too slow) and excessive erosion (too fast), reinforcing the obviousness of selecting hose diameters based on these known engineering constraints.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-20 of the ’420 patent as unpatentable.