Trials@uspto. gov
`Tel: 571-272-7822
`
`Paper 1 1
`Entered: June 29, 2018
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`10X GENOMICS, INC.,
`Petitioner,
`
`V.
`
`BIO-RAD LABORATORIES, INC.,
`Patent Owner.
`
`Case IPR201 8-005 87
`
`Patent 9,636,682 B2
`
`Before KRISTINA M. KALAN, JON B. TORNQUIST, and
`DEBRA L. DENNETT, Administrative Patent Judges.
`
`DENNET T, A dministrative PatentJudge.
`
`DECISION
`
`Denying Institution of Inter Partes Review
`35 US. C. §3I4(a)
`
`
`Tel: 571-272-7822
`
`Paper 1 1
`Entered: June 29, 2018
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`10X GENOMICS, INC.,
`Petitioner,
`
`V.
`
`BIO-RAD LABORATORIES, INC.,
`Patent Owner.
`
`Case IPR201 8-005 87
`
`Patent 9,636,682 B2
`
`Before KRISTINA M. KALAN, JON B. TORNQUIST, and
`DEBRA L. DENNETT, Administrative Patent Judges.
`
`DENNET T, A dministrative PatentJudge.
`
`DECISION
`
`Denying Institution of Inter Partes Review
`35 US. C. §3I4(a)
`
`
`
`IPR2018-00587
`
`Patent 9,636,682 B2
`
`I.
`
`INTRODUCTION
`
`10X Genomics, Inc. (“Petitioner”) filed a Petition (Paper 2, “P et.”)
`
`requesting interpartes review of claims 1—12 and 14—21 of US. Patent
`
`No. 9,636,682 B2 (Ex. 1001, “the ’682 patent”). Bio-Rad Laboratories, Inc.
`
`(“Patent Owner”) filed a Preliminary Response to the Petition (Paper 7,
`
`“Prelim. Resp”).
`
`We have authority to determine whether to institute an interpartes
`
`review. 3 5 U. S.C. § 314. The standard for instituting an interpartes review
`
`is set forth in 35 U.S.C. § 314(a), which provides that an interpartes review
`
`may not be instituted “unless the Director determines. .
`
`. there is a
`
`reasonable likelihood that the petitioner would prevail with respect to at
`
`least 1 of the claims challenged in the petition.”
`
`After considering the Petition, the Preliminary Response, and the
`
`evidence of record, we determine that Petitioner has not demonstrated a
`
`reasonable likelihood that it would prevail with respect to at least one claim
`
`challenged in the Petition. Accordingly, we deny the Petition, and do not
`
`institute an interpartes review.
`
`I . Related Proceedings
`
`The parties identify 32' o-Rad Laboratories, Inc. v. 1 OXGenomics, Inc,
`
`Case No. 3:17-cv-4339 (N .D. Cal.) and Re: Certain Microfluidic Devices,
`
`Investigation Number 337-TA—1068 (ITC) as related matters. Pet. 1; Paper
`
`4, 1. The parties also note that the ’682 patent is at issue in IPR2018-005 86.
`
`Pet. 1; Paper 4, 1.
`
`B. The ’682 Patent
`
`The ’682 patent discloses a system for forming emulsions. Ex. 1001,
`
`3:39—40. The system comprises an instrument and a microfluidic cassette.
`
`
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`IPR2018-00587
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`Patent 9,636,682 BZ
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`Id. at 6:64—67. The instrument applies pressure to emulsion phases held by a
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`microfluidic chip of the cassette to drive formation and collection of
`
`emulsions in the chip. Id. at 4:67—5 :2. The cassette may include a cartridge,
`
`a microfluidic chip, and a gasket. Id. at 9267—102. Figure 4 is reproduced
`
`below:
`
`
`
`Figure 4 is a plan view of cassette 52 showing microfluidic chip 54
`
`and cartridge 150. Id. at 43—6. Figure 6 is reproduced below:
`
`Fig. 6 A
`
`
`
`The microfluidic chip illustrated in Figure 6 forms a plurality ofwells
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`that serve as input containers for prospective emulsion phases and output
`
`
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`IPR2018-00587
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`Patent 9,636,682 B2
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`containers for collected emulsions. Id. at 10:37—40. Figure 9 is reproduced
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`below:
`
`Fig. 9
`
`
`
`Figure 9 is a schematic bottom view of a single emulsion formation
`
`unit 200 of microfluidic chip 152. Id. at 12:59—60. Input reservoirs 194,
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`196 (wells 168, 170 in Figure 4) hold and supply emulsion phases such as
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`oil phase 206 and aqueous sample 208. Id. at 12259—63. Collection
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`container 172 (well 172 in Figure 4) receives and collects emulsion 209
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`formed by droplet generator 198 from oil phase 206 and sample 208. Id. at
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`12:63-66. The reservoirs and collection container are fluidically
`
`interconnected via channels 210—216 that intersect at droplet generator 198,
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`and include one or a pair of oil inlet channels 210, 212, a sample inlet
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`channel 214, and an emulsion outlet channel 216. Id. at 12266—133.
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`A fluidics assembly of the instrument operates on the cassette to form
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`and concentrate emulsions. Id. at 15:41—44. Figure 16, reproduced below,
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`is a schematic View of fluidics assembly 58 operatively interfaced with chip
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`152 via cassette interface structure 74 (manifold 72 with ports 76) (id. at
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`15 :45-47):
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`
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`IPR2018-00587
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`Patent 9,636,682 B2
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`Fig. 16
`
`
`6°
`
`PUMP 2
`
`(W'RESSURE)
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`+ PRESSURE
`OONTROLLER
`
`
`
`
`
`PUMP 1
`
`(VACUUM)
`
`
`Each port 76 may be fluidically connected to one or more wells 172 of
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`chip 152. Id. at 15:47—49. Pressure may be applied to the chip with a
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`negative pressure portion 300 and a positive pressure portion 302 of the
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`fluidics assembly to form and concentrate a set of emulsions. Id. at 15:49—
`
`57.
`
`C. Illustrative Claims
`
`Petitioner challenges claims 1—12 and 14—21 of the ’682 patent.
`
`Independent claims land 14, reproduced below, are illustrative of the
`
`challenged claims:
`
`1. A system for generating droplets, comprising:
`
`a device including a sample well configured to receive sample-
`containing fluid, a continuous-phase well configured to receive
`continuous-phase fluid, and a droplet well, the device also
`including a channelnetwork having a first channel, a second
`channel, and a third channel that meet one another in a droplet-
`generation region;
`
`
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`IPR2018-00587
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`Patent 9,636,682 B2
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`a holder for the device; and
`
`an instrument configured to operatively receive an assembly
`including the device and the holder and to drive sample-
`containing fluid from the sample well to the droplet- generation
`region via the first channel, continuous-phase fluid from the
`continuous-phase well to the droplet-generation region via the
`second channel, and sample-containing droplets from the
`droplet-generation region to the droplet well via the third
`channel.
`
`14. A system for generating droplets, comprising:
`
`a device including a row of sample wells each configured to
`receive sample-containing fluid, a row of continuous-phase
`wells each configured to receive continuous-phase fluid, and a
`row of droplet wells, the device also including a corresponding
`channel network for each sample well, the channel network
`including a droplet-generation region and fluidically
`connecting the sample well to one of the continuous-phase
`wells and one of the droplet wells;
`
`a holder for the device;
`
`a gasket configured to be attached directly to the holder, such
`that the gasket extends over each sample well, each
`continuous-phase well, and each droplet well; and
`
`an instrument configured to
`
`(a) receive an assembly including the device, the holder, and
`the gasket,
`
`(b) engage the gasket with a manifold, and
`
`(c) apply positive pressure and/or negative pressure to the
`device via the manifold, such that sample-containing fluid
`flows from each sample well to the corresponding droplet-
`generation region, continuous-phase fluid flows from each
`continuous-phase well to the corresponding droplet-generation
`region, and sample-containing droplets flow from each droplet-
`generation region to the corresponding droplet well.
`
`
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`IPR2018-00587
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`Patent 9,636,682 B2
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`Ex. 1001, 33:29—46; 34:20—45. Claim 20 is the only other
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`independent claim and is substantially similar to claim 1 except for
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`additional recitations of “detect that the holder has been received”
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`and “create a pressure differential.” Id. at 34:65—35 :1 5.
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`D. The Asserted Grounds of Unpatentabilz'ty
`
`Petitioner contends claims l—l 2 and 14—21 of the ’682 patent are
`
`unpatentable based on the following grounds (Pet. 17, 54, 71, 74, 76, 77):‘
`
`
`
`
`
`
`
`
`
`Quakez, Chien I3, and Chien 114
`
`§ 103
`
`1, 2, 6, 8, 11, and 20
`
`Quake, Chien I, Chien II, and
`Weinberger5
`
`§ 103
`
`3—5, 9, 10, 14—16, and
`18
`
`Claims Challen-ed
`
`Quake, Chien I, Chien 11, and Li6
`
`§ 103
`
`Quake, Chien I, Chien II, and
`Bennett7
`
`§ 103
`
`12 and 21
`
`Quake, Chien I, Chien II,
`Weinberger, and Li
`
`Quake, Chien I, Chien 11,
`Weinberger, and Bennett
`
`1
`
`7
`
`19
`
`§ 103
`
`§ 103
`
`
`
`'
`
`
`
`
`
`
`
`
`
`1 Petitioner also relies on a declaration from Dr. Khushroo Gandhi
`
`(Ex. 1003).
`2 US 2002/005 8332 A1, published May 16, 2002 (Ex. 1004).
`3 US 6,915,679 B2, issued July 12, 2005 (Ex. 1005).
`4 Ring-ng Chien and J. Wallace Parce, Multz‘portflow-control systemfor
`lab-on-a—chip microfluz’dic devices, Fresenius J. Anal. Chem. 371 :1 06—1 1 l
`(2001) (Ex. 1006).
`5 US 7,046,357 B2, issued May 16, 2006 (Ex. 1009).
`6 US 2010/0200402 A1, published Aug. 12, 2010 (Ex. 1008).
`7 US 8,061,211 B1, issuedNov. 22, 2011 (Ex. 1011).
`
`7
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`
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`IPR2018-00587
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`Patent 9,636,682 B2
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`II.
`
`ANALYSIS
`
`A. Claim Construction
`
`In an interpartes review, claim terms in an unexpired patent are
`
`construed according to their broadest reasonable interpretation in light of the
`
`specification of the patent in which they appear. 37 C.F.R. § 42.100(b);
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`Cuozzo Speed Techs, LLC v. Lee, 136 S. Ct. 2131, 2144—46 (2016)
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`(upholding the use of the broadest reasonable interpretation standard).
`
`Upon review of the parties’ arguments and supporting evidence, we
`
`determine that no claim terms of the ’682 patent require express construction
`
`for purposes ofthis decision. See Nidec Motor Corp. v. Zhongshan Broad
`
`Ocean Motor Co. , 868 F.3d 1013, 1017 (Fed. Cir. 2017) (citing Vivid Techs,
`
`Inc. v. Am. Sci. & Eng ’g, Inc. , 200 F.3d 795, 803 (Fed. Cir. 1999) (“[O]nly
`
`those terms need be construed that are in controversy, and only to the extent
`
`necessary to resolve the controversy.”)).
`
`B. Claims I, 2, 6, 8, 11, and 20 over Quake, Chien], and Chien II
`
`Petitioner contends the subject matter of claims 1, 2, 6, 8, 11, and 20
`
`would have been obvious over the combined disclosures of Quake, Chien I,
`
`and Chien 11. Pet. 17—53.
`
`I . Quake
`
`Quake discloses a device and methods for analyzing and/or sorting
`
`biological materials, including, proteins, enzymes, viruses, and cells.
`
`Ex. 1004, Abstract. The devices and methods of Quake comprise “at least
`
`one analysis unit having an inlet region in communication with a main
`
`channel at a droplet extrusion region (e. g., for introducing droplets of sample
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`into the main channel),” a detection region, and a detector associated with
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`the detection region. Id. 11 76. As the droplets pass into the detection region,
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`
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`Patent 9,636,682 B2
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`they are examined by the detector for a predetermined characteristic. Id.
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`7 78. Quake teaches that some embodiments may include multiple detection
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`regions and detectors, as well as “a discrimination region or branch point in
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`communication with the main channel and with branch channels, and a flow
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`control responsive to the detector” for sorting droplets. Id. 111] 77, 79 (noting
`
`that a “plurality of analysis units of the invention may be combined in one
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`device,” and that such a multiplexed system “can be adapted to provide a
`
`very high throughput”). Quake further discloses the option of using “a
`
`plurality of inlet regions, each of which introduces droplets of a different
`
`sample .
`
`.
`
`. into the main channel.” Id. 1[ 77.
`
`Quake’s droplet extrusion regions “are designed to compartmentalize
`
`small droplets of aqueous solution within microfluidic channels filled with
`
`oil.” Id. fl 3. Specifically, Quake explains
`
`[t]he droplet extrusion region generally comprises a junction
`between the sample inlet and the main channel such that a
`pressurized solution of a sample (i.e., a fluid containing a sample
`such as cells, virions or molecules) is introduced to the main
`channel in droplets. Preferably, the sample inlet intersects the
`main channel such that
`the pressurized sample solution is
`introduced into the main channel at an angle perpendicular to a
`stream of fluid passing through the main channel. For example,
`in preferred embodiments, the sample inlet and main channel
`intercept at a T-shaped junction; i.e., such that the sample inlet is
`perpendicular (90 degrees) to the main channel.
`
`Id. 1[ 84.
`
`Figure 16B of Quake, reproduced below, shows an exemplary
`
`architecture for droplet extrusion regions in a microfabricated device. Id.
`
`11 39.
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`
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`IPR2018-00587
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`Patent 9,636,682 B2
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`- 1603
`
`1604
`
`.7 1636
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`In Figure 16B, inlet channel 1603 intersects main channel 1605, forming a
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`T-shaped junction. Id. 11'” 15, 299—300. As an aqueous solution is
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`pneumatically driven through channel 1603 it is sheared into droplets as it
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`enters the oil stream in main channel 1605. Id. W 290, 299—300. These
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`droplets then are driven through outlet channel 1604, and may subsequently
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`be routed through different channel architectures to allow individual droplets
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`to be sorted and/or analyzed. Id. 111] 16, 290, 294, 300.
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`Quake explains that, in this process of droplet generation, the required
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`fluids may be loaded into the microfabricated device via separate syringes
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`that are fitted with high-pressure connection fittings.
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`Id. 11 288. “The
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`pressures ofthe different fluids are then adjusted so that their pressures are
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`balanced at the droplet extrusion region.” Id. 1] 290. “Droplet extrusion can
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`then be initiated by slightly adjusting the pressure difference between the
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`different fluids” so that the droplet fluid is sheared off at a fixed frequency.
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`Id. Quake explains that this frequency of droplet generation “can be readily
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`adjusted by simply adjusting the pressures ofthe individual fluid lines.” Id.
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`2. Chien I
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`Chien I discloses devices, systems, and methods for flexibly and
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`selectively transporting“fluids within microfluidic channels of a
`
`10
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`
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`IPR2018—00587
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`Patent 9,636,682 B2
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`microfluidic network by applying, controlling, and varying pressures at a
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`plurality of reservoirs or ports.” Ex. 1005, 2:56—61. Figure 1 of Chien I is
`
`reproduced below:
`
`
`
`As shownin Figure 1, microfluidic system 10 includes microfluidic
`device 12 coupled to a bank of pressure modulators 14. Id. at 9:43—46.
`
`Each pressure modulator is in fluid communication with reservoir 18 of
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`microfluidic device 12 via associated tube 20. Id. at 9:51—52.
`
`Figure 2 of ChienI, reproduced below, shows microfluidic device 12
`
`(id. at 10:35):
`
`
`
`Flg. 2
`
`Microfluidic device 12 includes an array of reservoirs 18a, 18b, etc. coupled
`
`together by microscale channels defining microfluidic network 30. Id.
`
`at 10:36—38. ChienI explains that the microfluidic devices of the invention
`
`11
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`
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`Patent 9,636,682 B2
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`typically include at least one microscale channel and usually “at least two
`
`intersecting microscale channel segments’tdisposed within a single body
`
`structure. Id. at 10 :5 7—6 1.
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`3. Chien II
`
`Chien 11 describes the same embodiment as Chien 1. Pet. 21. Chien 11
`
`notes that, although hydrodynamic flow has been used in microfluidic
`
`systems, its use may have certain limitations:
`
`The use of external pumps to force liquids directly through
`microfluidic
`channels
`has
`previously
`been
`proposed.
`Incorporation of mechanical micro pumps and valves within a
`microfluidic device to move the fluids within a microfluidic
`channel has also been tested. Unfortunately, the flow rate in the
`microfluidic systems is usually on the order of nL s". Accurate
`control of such a tiny flow of an incompressible liquid is
`extremely difficult. Lack of proper control of small pressure
`differences will yield irreproducible and erratic results. A system
`that controls the pressure of a compressible gas at the fluid-air
`interface directly on top of the wells ofthe microfluidic device is
`a more practical design.
`
`Ex. 1006, 106.
`
`4. Analysis
`
`Petitioner contends one of ordinary skill in the art would have found it
`
`obvious to combine the teachings of Quake, Chien I, and Chien II8 to form a
`
`“Combined System” that includes every limitation of independent claim 1.
`
`Pet. 19, 23—41. Petitioner contends that Quake discloses microfluidic
`
`droplet generators that are provided on a microfluidic chip. 1d. at 19—20.
`
`Petitioner contends that Chien teaches preferably driving fluids through
`
`microfluidic circuits (such as those taught in Quake) by mounting the chip to
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`8 We refer to Chien I and Chien II collectively as “Chien.”
`
`12
`
`
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`Patent 9,636,682 B2
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`a pneumatic manifold that provides air pressure to drive fluids between
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`wells. Id. at 20—21. Petitioner argues that one of ordinary skill in the art
`
`would have considered it obvious to use Chien’s system to drive the fluids
`
`through Quake’s emulsion generators. Id. at 23. The Combined System is
`
`depicted below, reproduced from the Petition (id. at 18):
`
`
`
`
`
`Holder
`
`12
`
`Combined
`
`System
`
`Patent Owner argues Petitioner has failed to provide a reasonable
`
`explanation as to why one of ordinary skill in the art would have sought to
`
`combine Quake and Chien. Prelim. Resp. 20—22. Patent Owner asserts
`
`Petitioner does not explain why Chien would have motivated one of ordinary
`
`skill in the art to modify Quake to incorporate its fluid drive technique. Id.
`
`Upon review of the parties’ arguments and supporting evidence, as
`
`well as Dr. Gandhi’s declaration testimony, we determine that Petitioner has
`
`not sufficiently demonstrated that one of ordinary skill in the art would have
`
`combined Quake and Chien to arrive at the subject matter of the challenged
`
`claims.
`
`13
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`As noted above, Quake teaches driving fluids through its system using
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`syringes pressurized with air. Ex. 1004 11 288. Petitioner provides three
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`reasons why it contends one of ordinary skill in the art would have sought to
`
`abandon Quake’s fluid drive system and adopt Chien’s multi-reservoir plate
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`and pressure control system. Pet. 27-30.
`
`First, Petitioner contends one of ordinary skill in the art would have
`
`abandoned Quake’s pressurized air and syringe system in favor of “Chien’s
`
`multi—reservoir plate and pressure control system,” in View of Chien’s
`
`disclosure that “the use of extemal pumps to force liquids directly through
`’9’
`
`microfluidic channels” produces “irreproducible and erratic results
`
`and in
`
`view of Chien’s disclosure that the use of a compressible gas at the fluid-air
`
`interface on the top of the wells “is a more practical design.” Pet. 28
`
`(quoting Ex. 1006, 106).
`
`Consistent with Petitioner’s assertions, Chien indicates that accurate
`
`control of flow rate in microfluidic systems is extremely difficult and that a
`
`lack ofproper control of small pressure differences will yield irreproducible
`
`and erratic results. Ex. 1006, 106. Chien does not disclose, however, that
`
`all external pumps yield irreproducible and erratic results in microfluidic
`
`systems, and neither Petitioner nor Dr. Gandhi asserts that Quake’s system
`
`suffers from a lack of pressure control or from irreproducible and erratic
`
`results. Indeed, any suggestion that Quake’s system lacks sufficient pressure
`
`control would appear to be expressly contradicted by Quake itself, which
`
`explains that the frequency of droplet production is “readily adjusted by
`
`simply adjusting the pressures of the individual fluid lines.” Ex. 1004
`
`111] 290, 296 (“As demonstrated here, the size and frequency of droplets
`
`formed in a main channel of such devices may be precisely controlled by
`
`14
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`modifying the relative pressure of the incompatible fluids (e.g., water and
`
`oil) in the device”); see also id 11 79 (“Microfluidic pumps and valves are a
`
`preferred way of controlling fluid and sample flow.”). Thus, Petitioner has
`
`not demonstrated sufficiently that Chien’s disclosures would have motivated
`
`one of ordinary skill in the art to use Chien’s plate and pressure control
`
`system to drive fluid droplet generation in the emulsion generators of Quake.
`
`Second, Petitioner argues that modifying Quake to use Chien’s fluid
`
`drive system would allow an ordinary artisan to omit Quake’s external fluid
`
`reservoirs and pumps, which Dr. Gandhi testifies are expensive and need
`
`periodic cleaning. Pet. 28; Ex. 1003 1] 65 (“[E]liminating tubing and pumps
`
`reduces cost and greatly reduces the risk of contamination”). We are not
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`persuaded by this argument because, as noted by Patent Owner, Quake
`
`discloses that “the sorting devices ofthe invention are inexpensive and
`
`disposable, which obviates the need for cleaning and sterilization and
`
`prevents cross-contamination.” Ex. 1004 fl 14; Prelim. Resp. 21.
`
`Third, Petitioner argues that a skilled artisan would have been
`
`“strongly inclined to improve the Quake device” by implementing Chien’s
`
`fluid drive system, because “the syringe pumps, tubing, and wells of the
`
`Chien device were configured in a similar manner to Quake’s.” Pet. 28—29.
`
`As Patent Owner notes, however, a general similarity in structure or design
`
`between two devices is not a reason, in itself, to combine them. Prelim.
`
`Resp. 22. Thus, we are not persuaded that an alleged similarity in
`
`configuration is sufficient to demonstrate that one of ordinary skill in the art
`
`would have been motivated to combine Quake and Chien.
`
`In view of the foregoing, Petitioner has not explained sufficiently why
`
`one of ordinary skill in the art would have sought to use Chien’s pressure
`
`15
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`IPR2018-00587
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`Patent 9,636,682 B2
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`control system to drive fluids through Quake’s droplet generators.
`
`Accordingly, Petitioner has not demonstrated a reasonable likelihood that
`
`independent claim 1 would have been obvious over the combined
`
`disclosures of Quake and Chien.
`
`Because claims 2—12 depend from claim 1, and because Petitioner’s
`
`arguments and evidence with respect to these claims do not remedy the
`
`defects identified above, Petitioner also has not demonstrated a reasonable
`
`likelihood that these claims would have been obvious over the combined
`
`disclosures of Quake and Chien.
`
`Petitioner’s remaining challenges to claims 14—21 require
`modification ofthe Combined System formed from Quake and Chien.
`
`Pet. 54—77. Petitioner’s arguments with respect to these remaining
`
`challenges do not resolve the deficiencies noted above with respect to the
`
`combined teachings of Quake and Chien. Accordingly, Petitioner has not
`
`demonstrated areasonable likelihood that claims 14—21 would have been
`
`obvious over the teachings of Quake and Chien, alone or in combination
`
`with Weinberger, Li, and/or Bennett.
`
`III.
`
`CONCLUSION
`
`For the reasons discussed above, Petitioner has not demonstrated a
`
`reasonable likelihood that it would prevail with respect to at least one claim
`
`challenged in the Petition. Accordingly, we do not institute interpartes
`
`review.
`
`IV. ORDER
`
`It is hereby,
`
`ORDERED that no interpartes review is instituted.
`
`l6
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`IPR2018-00587
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`Patent 9,636,682 B2
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`PETITIONER:
`
`Greg H. Gardella
`Natalie J. Grace
`
`GARDELLA GRACE P .A.
`
`ggardella@gardellaggace.com
`nggace@gardellag1_race.com
`
`David J. Ball
`
`Jennifer H. Wu
`
`Megan Raymond
`Josephine Young
`PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
`dball@paulweiss.com
`jwu@paulweiss.com
`mraymond@paulweiss.com
`' oun
`. aulweiss.com
`
`Sarah Brashears
`
`sbrashears@convergentlaw.com
`
`PATENT OWNER:
`
`James M. Glass
`
`Kevin Johnson
`QUINN EMANUEL URQUHART & SULLIVAN LLP
`1' img!ass@guinnemanuel. corn
`kevinj ohnson@_quinnemanuel. com
`
`17
`
`
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