PTAB

PGR2025-00060

TankLogix LLC v. SitePro Inc

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remote Control of Fluid-Handling Devices
  • Brief Description: The ’184 patent describes systems and methods for remotely controlling fluid-handling devices like pumps and valves in geographically dispersed industrial settings. The technology enables users to issue commands through a central server, which are then translated and executed by local "site master-controllers," maintaining functionality even during intermittent network outages.

3. Grounds for Unpatentability

Ground 1: Patent Ineligibility under 35 U.S.C. §101 - Claims 1-31 are directed to an abstract idea.

  • Core Argument: Petitioner argued that the challenged claims are directed to the patent-ineligible abstract idea of controlling fluid-handling devices. This concept, Petitioner asserted, is a fundamental practice analogous to a mental process a technician could perform manually by traveling to a site to gather data and make adjustments.
    • Prior Art Mapping: Under Alice Step 1, Petitioner contended that the claims merely recite the abstract idea implemented on generic, conventional computer components. The claims describe functions such as receiving remote commands, authorizing users, translating protocols, and buffering data, all of which were argued to be abstract concepts themselves. The recitation of a computing system, network interface, and data store does not transform the abstract idea into a patent-eligible application.
    • Key Aspects: Under Alice Step 2, Petitioner argued the claims lack an inventive concept. The limitations, viewed individually and as an ordered combination, do not amount to "significantly more" than the abstract idea. The use of generic computer components to automate the longstanding practice of remote monitoring and control was described as a routine and conventional activity, not a specific technical improvement to computer functionality.

Ground 2: Obviousness under 35 U.S.C. §103 - Claims 1-31 are obvious over the combination of Kahn, Gutierrez, Almadi, and SCADA.

  • Prior Art Relied Upon: Kahn (Patent 7,424,399), Gutierrez (Patent 9,709,995), Almadi (Patent 8,667,091), and SCADA (a 2010 publication titled "Supervisory Control and Data Acquisition, 4th Edition").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner alleged that the combination of references taught every element of the challenged claims. Independent claim 1 recites a system for receiving remote commands, translating them, and sending them to local controllers. Petitioner mapped that Gutierrez, Almadi, and SCADA collectively disclosed a computing system at a fluid-handling site that receives commands via a network interface to control various devices. Kahn and Gutierrez were cited for disclosing a remote user command interface. The user authorization limitation was taught by Kahn and Almadi, which describe verifying user credentials before granting access. The claims’ requirement to maintain control during network outages was allegedly taught by Almadi’s disclosure of buffering data during bandwidth starvation or communication failures. Finally, Gutierrez and Almadi were asserted to teach translating commands between different protocols and receiving feedback from local devices.
    • Motivation to Combine: A POSITA would combine these references because they all address the same field of remote monitoring and control of fluid handling systems. Petitioner argued a POSITA would look to the specific user differentiation features in Kahn, the general system architecture in Gutierrez, the modern automation details in Almadi, and the standard industry implementation protocols in SCADA to create a more efficient, comprehensive, and automated control system. The combination would yield predictable results.
    • Expectation of Success: The petition asserted a POSITA would have a high expectation of success, as the references provide complementary details for implementing a well-known architecture rather than describing alternative or incompatible approaches.

Ground 3: Lack of Written Description under 35 U.S.C. §112 - Claims 2, 11, 14, and 31 lack adequate written description support in the priority application.

  • Core Argument: Petitioner argued that several claims of the ’184 patent are not entitled to their pre-AIA priority date because the original specification fails to provide adequate written description for newly added limitations, making the patent eligible for Post-Grant Review (PGR).
    • Prior Art Mapping: The argument focused on specific limitations introduced during prosecution that were allegedly not supported by the pre-AIA ’557 application.
      • Claim 2: This claim recites granular user permissions (e.g., command vs. view-only rights), but the priority application allegedly only disclosed general account-level authorization to interact with a site, not different permission levels for individual users.
      • Claim 11: This claim recites a "water handling facility," but the priority application was argued to focus exclusively on petroleum-related applications (oil wells, petro-water disposal), mentioning water only as a byproduct, not as the basis for a standalone facility.
      • Claim 14: This claim recites determining a target state "in response to a rate of change" in a fluid level. Petitioner contended the priority application never mentioned or suggested using a "rate of change" calculation for control logic.

4. Relief Requested

  • Petitioner requests institution of post-grant review and cancellation of claims 1-31 of the ’184 patent as unpatentable.