1:25-cv-00145
Comanche Gas Solutions LLC v. Nacelle Logistics LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Comanche Gas Solutions, LLC (Delaware)
- Defendant: Nacelle Logistics, LLC (Delaware)
- Plaintiff’s Counsel: Young Conaway Stargatt & Taylor, LLP; Stinson LLP
- Case Identification: 1:25-cv-00145, D. Del., 02/05/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware limited liability company and therefore resides in the district.
- Core Dispute: Plaintiff alleges that Defendant’s portable natural gas distribution systems infringe a patent related to modular, safe systems for fueling industrial equipment at oil and gas sites.
- Technical Context: The technology at issue involves mobile, trailer-mounted systems that facilitate the use of natural gas instead of diesel to power equipment for hydraulic fracturing fleets.
- Key Procedural History: The complaint alleges a history of direct competition, including a period where both parties serviced the same customer project. During this time, Defendant allegedly observed Plaintiff's system, which was marked "patent pending," and subsequently hired Plaintiff's former employees. These allegations form the basis for claims of willful infringement, suggesting Defendant had pre-suit knowledge of the technology and its protected status.
Case Timeline
| Date | Event |
|---|---|
| 2021-10-15 | '551 Patent Priority Date (Application Filing Date) |
| 2022-07-01 | Approximate start of "Mutual Customer Fleet Project" |
| 2023-05-31 | Approximate end of "Mutual Customer Fleet Project" |
| 2023-09-01 | Nacelle allegedly began marketing GOALIE system |
| 2023-10-23 | Nacelle allegedly began marketing GOALIE system on its website |
| 2023-11-01 | Plaintiff's systems allegedly marked "patent pending" |
| 2024-10-22 | '551 Patent Issue Date |
| 2025-02-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,123,551 - “Portable Natural Gas Distribution System,”
The Invention Explained
- Problem Addressed: The patent’s background section describes the challenges of using natural gas to fuel hydraulic fracturing fleets, noting that conventional “daisy chain” systems suffer from inefficient gas flow, a lack of operational flexibility (a single problem can shut down the entire fuel line), and limited safety features ('551 Patent, col. 1:29-35).
- The Patented Solution: The invention is a self-contained, portable natural gas distribution system mounted on a mobile trailer. It improves upon prior methods by incorporating coalescing filters to purify the gas and, critically, a manifold system where each output port is equipped with its own low-pressure "slam shut" valve. This modular architecture enhances safety by automatically shutting a single line if pressure drops, without disrupting fuel flow to other engines, while an internal diffuser helps balance pressure to maximize system-wide flow ('551 Patent, col. 4:15-30; Fig. 1).
- Technical Importance: The technology provides a mobile, efficient, and safer “last mile” fuel delivery solution, making it more practical for operators to displace diesel with natural gas at temporary, remote industrial sites ('551 Patent, col. 3:51-58).
Key Claims at a Glance
- The complaint asserts independent claim 15 of the ’551 Patent (Compl. ¶37).
- The essential elements of Claim 15 are:
- One or more coalescing filters coupled to a pressure reducer, with each filter including a first filter to remove water.
- One or more manifolds coupled to the filters, with each manifold having a plurality of ports.
- A low-pressure slam shut valve coupled to each port, which is configured to sense a pressure decrease and close below a certain threshold.
- A diffuser included in each manifold.
- At least one hose coupled to a respective low-pressure slam shut valve.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Defendant Nacelle’s "GOALIE" natural gas distribution system (Compl. ¶26).
Functionality and Market Context
The GOALIE system is described as a mobile, trailer-mounted system used to deliver natural gas to hydraulic fracturing fleets (Compl. ¶27, ¶41.a). The complaint alleges that the GOALIE system incorporates features directly corresponding to the patented invention, including a "two-stage filtration process, incorporating coalescing filters," "diffusers for pressure balancing," manifolds that support "10-20 ports," and "remote-controlled emergency shut-off valves" (Compl. ¶41.b, ¶41.d, ¶41.h). Plaintiff alleges that Defendant is a direct competitor and that the GOALIE system was developed and marketed only after Defendant was exposed to Plaintiff's patented system (Compl. ¶19, ¶29). To illustrate the alleged copying, the complaint includes a photograph of the accused GOALIE system, which it asserts is "virtually identical" to its own patented system (Compl. p. 9).
IV. Analysis of Infringement Allegations
’551 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| one or more coalescing filters each having a first side coupled to a second side of a pressure reducer supplying input gas, wherein each coalescing filter includes a first filter to remove water | The GOALIE system allegedly utilizes a "two-stage filtration process, incorporating coalescing filters" and positions the input gas line, pressure reducer, and filters on the front of the trailer. | ¶41.b, ¶41.k | col. 10:36-40 |
| one or more manifolds having a first side coupled to a second side of the one or more coalescing filters respectively, each manifold having a plurality of ports | The GOALIE system allegedly includes a manifold that "supports 10-20 ports to supply multiple engines." | ¶41.d | col. 10:40-42 |
| wherein each port is coupled to a low-pressure slam shut valve that is configured to sense a decrease in a pressure of a gas and will close when the pressure of the gas decreases below a threshold | The GOALIE system allegedly includes "remote-controlled emergency shut-off valves" and "actuated valve responses" which are purported to meet this limitation. | ¶41.h | col. 10:42-46 |
| and wherein each manifold includes a diffuser | The GOALIE system is alleged to incorporate "diffusers for pressure balancing." | ¶41.b | col. 10:46-47 |
| and at least one hose having a first end and a second end, wherein the first end of the at least one hose is coupled to a respective low-pressure slam shut valve | The GOALIE system is alleged to have multiple hoses on reels and utilizes "quick-connect hoses." Photographic evidence is provided to show the arrangement of hoses, reels, and valves. | ¶41.e, ¶41.f, p. 9 | col. 10:47-50 |
Identified Points of Contention
- Technical Questions: A primary technical question will be whether Nacelle's "remote-controlled emergency shut-off valves" (Compl. ¶41.h) operate in the same way as the claimed "low-pressure slam shut valve." The claim requires a valve that automatically "sense[s] a decrease in a pressure" and closes when it "decreases below a threshold" ('551 Patent, col. 10:42-46). The complaint does not specify if the accused valves operate automatically based on pressure sensing or if they are solely manually or electronically triggered by a remote operator.
- Scope Questions: The complaint's visual evidence, which presents side-by-side photos of the "Exemplary Patented Comanche System" (Compl. p. 8) and "Nacelle's GOALIE System" (Compl. p. 9), raises the question of direct copying. The degree of similarity shown in the photographs may be used to argue for a broader interpretation of the claims to cover the accused system and to support allegations of willfulness.
V. Key Claim Terms for Construction
The Term
"low-pressure slam shut valve that is configured to sense a decrease in a pressure of a gas and will close when the pressure of the gas decreases below a threshold"
Context and Importance
This functional language describes the core safety feature of the invention. The infringement analysis will depend heavily on whether the valves in Nacelle's GOALIE system perform this specific, automatic, pressure-sensing function. Practitioners may focus on this term because the complaint identifies a potentially different feature—"remote-controlled emergency shut-off valves"—as the infringing component (Compl. ¶41.h).
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: A party may argue that the claim term is purely functional and should cover any valve structure that achieves the stated result of sensing a pressure drop and automatically closing. The claim itself does not recite a specific valve structure.
- Evidence for a Narrower Interpretation: The specification discloses a particular method for creating such a valve, stating it "can be made by using a standard regulator and reversing certain components" ('551 Patent, col. 4:26-29). It further describes modifying a "high-pressure slam shut to low pressure slam shut by flipping the orifice plat and flipping rotator valve plate and peanut valve" ('551 Patent, col. 5:9-13). A party may argue these descriptions limit the claim scope to the disclosed embodiments or structures equivalent to them.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Nacelle "has actively and knowingly induced one or more of its customers to use the GOALIE system to provide fuel to their hydraulic fracturing fleets" (Compl. ¶43).
Willful Infringement
Willfulness is alleged based on pre-suit knowledge. The complaint asserts that Nacelle learned of the "Patented Comanche Systems" and their "patent pending" status while working at a mutual customer site, hired former Comanche employees with knowledge of the system, and developed the allegedly infringing GOALIE system only after this exposure (Compl. ¶22, ¶23, ¶25, ¶29). It further alleges that Nacelle's employees have seen the ’551 patent number marked on Plaintiff's systems since the patent issued (Compl. ¶34).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and technical operation: does the accused GOALIE system’s "remote-controlled emergency shut-off valve" meet the specific functional requirements of the claimed "low-pressure slam shut valve," which must automatically "sense a decrease in a pressure" and close below a threshold, or is there a fundamental difference in how the two safety systems operate?
- The case presents a strong narrative of copying, making a key question one of evidentiary proof and intent: can the Plaintiff substantiate its detailed allegations that the Defendant developed its product only after observing the "patent pending" system and hiring former employees, and will this evidence be sufficient to support a finding of willful infringement?