`BLD Services, LLC v. LMK Technologies, LLC
`IPR2014-00770
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`1
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`lateral host pipe
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`groundwater
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`
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`hydrophilic
`main hOSt pipe
`dispersed
`chemical grout
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`
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`, CIPP main liner
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`29.
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`The process of chemical grouting is one of the oldest forms of
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`trenchless pipe rehabilitation and is usually performed by pumping the chemical
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`grout from a truck above ground through hoses that are strung through the main
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`pipe to the lateral connection whereby the chemical grout is dispensed through
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`inflatable bladders under pressure to penetrate pipe defects. Shown below is an
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`illustration of such a chemical grouting operation using inflatable bladders from
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`the website of Avanti International, www.avantigrout.com. Avanti is an industry
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`leader in providing chemical grout for sealing sewer pipes.
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`14
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`2
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`30. Our use of chemical grout in the ‘663 patent approach was intended to
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`perform the same end; it’s just that our process avoided the need for expensive
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`pumps, hoses and inflatable bladders. We were trying to grout the pipe defect using
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`an extremely compressible low cost piece of foam While simultaneously renewing
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`the pipe using CIPP. The open cell foam does not penetrate the pipe defects, but
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`only the chemical grout does, as described in the ‘663 patent. (12:43—47) The
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`chemical grout expelled from the foam forms the seal, not the foam carrier.
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`31.
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`The ‘663 patent approach embodies a principle that a seal is to be
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`created by enveloping the damaged pipe areas and penetrating the surrounding soil
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`with chemical grout in order to keep groundwater out of the pipe, as illustrated in a
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`picture of a mocked up sample (shown below) prepared at LMK.
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`3
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`Photographs that are fair and accurate representations of the sample (prepared
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`under my direction at LMK) are attached as EX. E to my Declaration.
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`32.
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`I made attempts to implement the ‘663 patent approach. Plagued by
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`practical problems,
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`the approach produced inconsistent results. One of these
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`problems was that there was a limit on the amount of liquid hydrophilic chemical
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`grout that could be delivered to the juncture region for dispersal based on the size
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`of the open cell foam carrier in order to effectively form a seal. Another problem
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`was that there was little control over the dispersal of the grout upon inflation of the
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`bladder(s). The technicians are unable to see through the pipe and know exactly
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`where the grout is traveling to and often the grout did not penetrate all of the areas
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`necessary to form the seal. The difficulties were compounded by the widely
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`variable and unpredictable pipe defect/damage conditions at
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`the junctures.
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`Ultimately,
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`these difficulties led me to abandon the technique and to seek to
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`develop a better solution.
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`16
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`4
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