Syngenta Crop Protection AG v. INFLexion Point Technologies LLC

1. Case Identification

• Case #: PGR2025-00045
• Patent #: 12,102,027
• Filed: July 1, 2025
• Petitioner(s): Syngenta Crop Protection AG
• Patent Owner(s): Inflexion Point Technologies, LLC
• Challenged Claims: 1-19

2. Patent Overview

• Title: System and Method for Prescriptive Seed Treatment
• Brief Description: The ’027 patent is directed to a method for prescriptive seed treatment using a planter. The method involves calculating a planting location, selecting a specific combination of seed type and a substance to apply based on field conditions, calculating a variable application amount of the substance, and applying it to each seed as the treated seed is delivered to the soil.

3. Grounds for Unpatentability

Ground 1: Anticipation over Wagers - Claims 1-4, 6, 7, 11, and 13-16 are anticipated by Wagers under 35 U.S.C. §102.

• Prior Art Relied Upon: Wagers (Application # 2014/0277959).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wagers discloses every element of the challenged claims. Wagers teaches a multi-row unit planter with a control system that uses a "prescription map" to select a seed type and an agricultural product (e.g., fertilizer, herbicide) based on the planter's location in a field. The system dynamically changes planting characteristics, including the type and application rate of the agricultural product, based on the selected seed type and location. Petitioner contended Wagers discloses applying the substance to each seed contemporaneously with delivery to the planting location via sprayers or pneumatic dispensers associated with each row unit. Petitioner also asserted that while not explicitly shown, seed drop tubes are a necessary and ubiquitous component of the planter system described in Wagers.

Ground 2: Obviousness over Wagers and Mitchell - Claims 1-7 and 11-16 are obvious over Wagers in view of Mitchell under 35 U.S.C. §103.

• Prior Art Relied Upon: Wagers (Application # 2014/0277959) and Mitchell (Patent 1,409,564).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wagers teaches the primary system for prescriptive, location-based planting with variable seed and substance application. To the extent Wagers is found not to explicitly disclose applying a substance to each seed as it is delivered through a seed drop tube, Mitchell supplies this teaching. Mitchell, a 1922 patent, discloses an "ordinary" planter with hollow teeth (seed drop tubes) and spouts equipped with spray nozzles to apply a substance (e.g., formalin) to grain "as it falls" and is "in transit from a source of supply to the ground."
  • Motivation to Combine: A POSITA would combine Wagers and Mitchell to improve the planting precision of Wagers' advanced prescriptive system. Wagers' express goal was to improve planting, and Mitchell provided a well-understood method for treating seeds in transit just prior to soil placement. Incorporating Mitchell's spray nozzle configuration into Wagers' planter would have been a straightforward way to ensure precise application of the selected substance to individual seeds, furthering the goals of both references.
  • Expectation of Success: A POSITA would have had a high expectation of success, as incorporating a known seed treatment mechanism like Mitchell's into a planter system like Wagers' was a standard integration of known technologies.

Ground 3: Lack of Enablement - Claims 1-19 are unpatentable for lack of enablement under 35 U.S.C. §112(a).

• Core Argument for this Ground: Petitioner argued the ’027 patent fails to enable a person of ordinary skill in the art (POSA) to practice the full scope of the claimed invention without undue experimentation. The claims broadly cover a prescriptive method for any seed, any seed-applied substance, and at any level of granularity (e.g., seed-by-seed, field-by-field), but the specification provides no guidance for the vast majority of these embodiments.

  • Key Aspects:
    • Seed Variability: The patent claims applicability to all seeds but provides no teaching on how to handle the vast physical differences between them, such as a tobacco seed versus a corn seed (a ~2,000x size difference), which fundamentally alters their travel through a seed drop tube and the requirements for substance application.
    • "Individually Applying": The specification fails to enable the "seed-by-seed" treatment contemplated by the claims. It does not teach how to overcome the inherent variability and randomness of seed movement in a gravity-fed drop tube, which makes accurate, individual application nearly impossible with the disclosed technology.
    • Lack of Technical Guidance: The patent lacks disclosure of critical components and parameters, such as sensor types and locations, nozzle designs for "pico" scale application, or control systems necessary to manage the myriad variables across different seeds, substances, and planting conditions. Petitioner contended this lack of detail leaves a POSA with only a "wishful roadmap" requiring extensive, undue experimentation to achieve the claimed method.

• Additional Grounds: Petitioner asserted additional obviousness challenges against various claims based on Wagers in view of Wilkerson (Application # 2004/0231575), Batcheller (Application # 2014/0379228), Memory (Patent 6,155,185), and Garner (Patent 8,850,995). These grounds relied on similar theories of combining Wagers' prescriptive system with secondary references that teach specific, well-known planter components, such as timing mechanisms (Wilkerson), substance mixers (Batcheller), air tubes (Memory), and brush tubes (Garner).

4. Relief Requested

• Petitioner requests institution of post-grant review and cancellation of claims 1-19 of the ’027 patent as unpatentable.