PTAB

PGR2025-00055

AlMendra Pte Ltd v. Fienile AgRoneCócios Ltda

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and method of agricultural management
  • Brief Description: The ’543 patent discloses an agricultural management system and method using a modular, pivot-like irrigation device equipped with adjustable artificial lighting sources (LEDs). The system is designed to control crop cultivation by implementing irrigation and light supplementation routines based on various agricultural and environmental factors.

3. Grounds for Unpatentability

Ground 1: Indefiniteness - Claims 1-7 are invalid as indefinite under 35 U.S.C. §112.

  • Prior Art Relied Upon: Not applicable.
  • Core Argument for this Ground:
    • Petitioner argued that the challenged claims fail to inform a Person of Ordinary Skill in the Art (POSITA) about the scope of the invention with reasonable certainty. The petition identified several distinct bases for indefiniteness:
      • Amorphous Structural Limitations: The term "a predetermined distance above the aerial parts of the crop" is indefinite because the specification provides no objective reference point on the crop from which to measure, rendering the scope unclear.
      • Coined Terminology: Claims 1-3 recite a "dimerizer," a term Petitioner asserted was coined by the Patent Owner and is not defined in the specification or known in the art in this context, leaving its meaning and function entirely ambiguous.
      • Subjective Language: Claims 1, 4, and 7 depend on "one or more objective(s) intended for the crop," which Petitioner contended is a purely subjective standard that depends on the unpredictable opinion of a user rather than an objective criterion.
      • Lack of Antecedent Basis: Claim 7, which depends from claim 6, refers to "determining through the artificial intelligence model," but neither claim 6 nor its independent base claim 4 introduces an artificial intelligence model, creating ambiguity as to which model is being referenced.

Ground 2: Obviousness over Rosen - Claims 1-7 are obvious over Rosen.

  • Prior Art Relied Upon: Rosen (Application # 2019/0098843).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted Rosen, a single reference, discloses all limitations of the challenged claims. Rosen teaches an "intelligent horticulture light" system for use in environments including an agricultural "field." The system uses a processor and sensors to monitor plant characteristics (e.g., type, growth stage) and environmental conditions to automate and optimize crop growth. Rosen explicitly discloses controlling "watering" (an irrigation routine) and customizing light output by adjusting the "spectrum" of its LEDs. The system is also described as being modular and determining its actions based on "at least one objective" defined by a user or the system itself.
    • Motivation to Combine: Not applicable (single reference ground).
    • Expectation of Success: Not applicable (single reference ground).

Ground 3: Obviousness over Richardville and Rosen - Claims 1-7 are obvious over Richardville in view of Rosen.

  • Prior Art Relied Upon: Richardville (Application # 2021/0185945) and Rosen (Application # 2019/0098843).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Richardville provides the foundational physical structure, while Rosen supplies the claimed intelligence and control features. Richardville discloses a "light assembly" with LEDs mounted on a modular "center pivot type irrigation system" that includes a drive unit and sprinklers. Rosen discloses the intelligent control system, including a processor that uses artificial intelligence to monitor crops, determine appropriate actions based on objectives, and implement routines for lighting and watering. The combination of Richardville's physical irrigation and lighting platform with Rosen's intelligent control system renders the claims obvious.
    • Motivation to Combine: A POSITA would combine Rosen’s intelligent control system with Richardville’s physical apparatus to create a more autonomous and efficient agricultural management system. Richardville discloses a basic control logic, and a POSITA would have been motivated to enhance it with Rosen's more advanced, sensor-driven artificial intelligence capabilities. Petitioner further noted that Rosen teaches its horticulture light can be retrofitted into conventional fixtures, suggesting a straightforward integration into a system like Richardville's.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as it involved applying a known intelligent control system (Rosen) to a known mechanical platform (Richardville) to achieve the predictable result of an automated, integrated agricultural system.

  • Additional Grounds: Petitioner asserted additional grounds that claims 1-7 are invalid for lack of enablement under §112 and for being directed to ineligible subject matter under §101. The enablement challenge argued the patent fails to teach a POSITA how to "determine" the claimed routines without undue experimentation. The §101 challenge argued the claims are directed to the abstract idea of providing plants with light and water, without an inventive concept.

4. Key Claim Construction Positions

  • Petitioner’s indefiniteness arguments are based on the assertion that key claim terms lack the clarity required by §112.
    • "predetermined distance": Petitioner argued this term is indefinite as it lacks an objective and clear reference point for measurement on the "aerial parts of the crop."
    • "dimerizer": Petitioner asserted this is a coined term with no established meaning in the art or definition in the patent. Without intrinsic or extrinsic evidence to define it, a POSITA cannot determine its scope.

7. Relief Requested

  • Petitioner requests institution of post-grant review and cancellation of claims 1-7 of the ’543 patent as unpatentable.