DCT

1:25-cv-03117

Precision Planting LLC v. Kabat American Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-03117, N.D. Ill., 03/24/2025
  • Venue Allegations: Venue is alleged to be proper as Defendant is incorporated in Illinois and maintains a principal place of business within the Northern District of Illinois.
  • Core Dispute: Plaintiff alleges that Defendant’s agricultural planter components, including hydraulic and pneumatic cylinders, seed meters, and singulation brushes, infringe nine patents related to planter downforce control and seed handling technology.
  • Technical Context: The technology at issue pertains to precision agriculture equipment, specifically components for row crop planters that manage the force applied to the soil and ensure accurate seed singulation and placement.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of infringement via a letter on February 21, 2024. It further alleges that on March 7, 2024, Defendant admitted that its seed meters and singulation brushes infringed several of the patents-in-suit, but on March 19, 2024, refused to discontinue sales of its accused hydraulic, solenoid, and pneumatic cylinder products.

Case Timeline

Date Event
2004-08-16 Priority Date for ’963 and ’080 Patents
2005-08-19 Priority Date for ’606 Patent
2007-01-16 ’963 Patent Issued
2009-12-15 ’606 Patent Issued
2010-09-21 ’080 Patent Issued
2010-12-16 Priority Date for ’020 and ’438 Patents
2012-07-25 Priority Date for ’189, ’007, ’702, and ’062 Patents
2013-10-08 ’020 Patent Issued
2015-09-29 ’189 Patent Issued
2016-04-05 ’438 Patent Issued
2017-08-29 ’007 Patent Issued
2018-01-30 ’702 Patent Issued
2019-07-23 ’062 Patent Issued
2024-02-21 Plaintiff sends notice letter to Defendant
2024-03-07 Defendant allegedly admits infringement of Seed Meter and Singulation Brush Patents
2024-03-19 Defendant allegedly refuses to discontinue sales of cylinder products
2025-03-24 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,144,189 - "Integrated Implement Downforce Control Systems, Methods, and Apparatus"

  • Patent Identification: U.S. Patent No. 9,144,189, "Integrated Implement Downforce Control Systems, Methods, and Apparatus," Issued September 29, 2015.

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of maintaining proper downforce on individual row units of an agricultural planter as it moves through a field, encountering changes in terrain or obstructions like rocks, which can compromise seed planting depth and consistency (’189 Patent, col. 2:65-col. 3:2).
  • The Patented Solution: The invention is a downforce controller for a planter row unit that integrates a hydraulic actuator, a manifold mounted directly to the actuator, and a pressure control valve. This compact assembly is supported by the planter row unit and is configured to apply a controlled hydraulic force to maintain consistent ground contact. (’189 Patent, Abstract; col. 2:51-58). Figure 1A illustrates the integrated nature of the cylinder (130), manifold (110), and valve (140).
  • Technical Importance: By integrating the control components into a single unit for each planter row, the invention enables more responsive and granular control of downforce, improving planting consistency across varied field conditions (’189 Patent, col. 2:65-col. 3:2).

Key Claims at a Glance

  • The complaint asserts independent claim 22 (Compl. ¶ 33).
  • Claim 22:
    • A downforce controller for a planter row unit, comprising:
    • a hydraulic actuator configured to apply a force to the planter row unit; and
    • a manifold mounted to said hydraulic actuator;
    • a pressure control valve in fluid communication with said manifold, wherein said pressure control valve is supported by the planter row unit.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,879,702 - "Integrated Implement Downforce Control Systems, Methods, and Apparatus"

  • Patent Identification: U.S. Patent No. 9,879,702, "Integrated Implement Downforce Control Systems, Methods, and Apparatus," Issued January 30, 2018.

The Invention Explained

  • Problem Addressed: The patent background describes the difficulty in maintaining a desired downforce on planter row units, noting that too much force causes soil compaction while insufficient force leads to inconsistent planting depth. The background highlights a need for controlling downforce with "greater spatial granularity" to account for variations in soil properties across a field. (’702 Patent, col. 1:8-21).
  • The Patented Solution: The invention provides a downforce controller using a double-acting hydraulic cylinder, which has two chambers that produce counteracting forces (one for downforce, one for lift). This cylinder is coupled with a manifold and a pressure control valve that can establish a desired pressure, allowing for precise control over the net downforce applied to the row unit. (’702 Patent, Abstract; col. 2:1-4).
  • Technical Importance: The use of a double-acting cylinder with counteracting pressures allows the system to actively apply both downward and upward force, enabling fine-tuned, dynamic adjustment of net downforce to match changing field conditions (’702 Patent, Abstract).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶ 33).
  • Claim 1:
    • A downforce controller for an agricultural implement, comprising:
    • a double-acting hydraulic cylinder including a first chamber and a second chamber, said cylinder configured to be coupled to an agricultural row unit and an agricultural toolbar for transmitting a net downforce between said agricultural toolbar and said agricultural row unit, a first pressure in said first chamber and a second pressure in said second chamber having counteracting effects on said net downforce;
    • a manifold coupled to said cylinder, said manifold being in fluid communication with said first chamber; and
    • a pressure control valve supported by said manifold, said pressure control valve being in fluid communication with said manifold and with said first chamber;
    • wherein said pressure control valve comprises a supply port, a return port, and a control port, and wherein said pressure control valve is configured to establish a desired pressure at said control port; and
    • wherein said pressure control valve is supported by said manifold.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 9,746,007 and U.S. Patent No. 10,359,062 (part of the "Hydraulic Cylinder Patents").

  • Technology Synopsis: The ’007 Patent is directed to a system of multiple downforce controllers connected by an inter-row supply hose, allowing fluid to be shared between row units (’007 Patent, col. 4:35-43). The ’062 Patent is directed to a system comprising both a downforce controller and an upforce controller to manage pressure in both chambers of an actuator (’062 Patent, col. 7:10-24).

  • Asserted Claims: Claim 1 of the ’007 Patent; Claim 1 of the ’062 Patent (Compl. ¶¶ 17, 19, 35).

  • Accused Features: The Hydraulic Cylinder Product (#WMCT32X89) and the Solenoid Product (#P729600) are accused of infringing when used in multi-row planter systems (Compl. ¶¶ 35, 37).

  • Patent Identification: U.S. Patent No. 7,631,606 (the "Seed Meter Patent").

  • Technology Synopsis: The patent describes a seed belt for an agricultural planter used to convey seeds from a seed singulator to a seed tube. The belt features a plurality of flights with a "substantially concave portion" at the end to support and center the seeds, urging them toward this concave portion before release to improve placement accuracy. (’606 Patent, col. 8:60-col. 9:6).

  • Asserted Claims: Claim 7 (Compl. ¶ 21; see also ¶ 47 referencing claim 1).

  • Accused Features: Defendant’s Seed Meter Products (P343022, P343025, and P343030), which are alleged to include a delivery belt with "a plurality of flights with a concave portion" (Compl. ¶ 29).

  • Patent Identification: U.S. Patent No. 7,162,963 and U.S. Patent No. 7,798,080 (the "Singulation Brush Patents").

  • Technology Synopsis: These patents relate to ensuring that only single seeds are dispensed by a seed meter ("singulation"). The ’963 Patent claims a method of improving singulation by using a "selectively adjustable moveable brush" within a finger-type seed meter (’963 Patent, col. 5:52-col. 6:2). The ’080 Patent claims the combination of a seed meter and an adjustable singulating brush assembly where the brush block is "selectively adjustably pivotable" (’080 Patent, col. 5:54-col. 6:22).

  • Asserted Claims: Claim 1 of the ’963 Patent; Claim 1 of the ’080 Patent (Compl. ¶¶ 23, 24, 62).

  • Accused Features: The singulating brush included within Defendant's Seed Meter Products, which is alleged to be "pivotally adjustable along the path of the seed selector" (Compl. ¶ 30).

  • Patent Identification: U.S. Patent No. 8,550,020 and U.S. Patent No. 9,301,438 (the "Pressure Control Patents").

  • Technology Synopsis: These patents relate to systems for controlling downforce on agricultural implements. The ’020 Patent claims a variable pressure control system with a controller having two regulators and a user interface to select a desired pressure (’020 Patent, col. 9:8-col. 10:30). The ’438 Patent claims a downforce control system comprising a ground engaging element, a dual acting actuator with down and lift chambers, and a controller with a pressure regulating valve (’438 Patent, col. 9:1-col. 10:20).

  • Asserted Claims: Claim 1 of the ’020 Patent; Claim 1 of the ’438 Patent (Compl. ¶¶ 26, 27, 73).

  • Accused Features: Defendant’s "Air Cylinder Product" (#ACY2X2), which is described as being used on a "row cleaning/sweeping system" (Compl. ¶ 31).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies four categories of accused products:
    1. The "Hydraulic Cylinder Product" (#WMCT32X89) and "Solenoid Product" (#P729600) (Compl. ¶ 2).
    2. The "Seed Meter Products" (#P343022, #P343025, #P343030) (Compl. ¶ 2).
    3. The "Singulation Brushes" (included with the Seed Meter Products) (Compl. ¶ 2).
    4. The "Air Cylinder Product" (#ACY2X2) (Compl. ¶ 2).

Functionality and Market Context

  • The Hydraulic Cylinder and Solenoid products are alleged to provide and automate downforce for planter row units. The complaint alleges the cylinder is "Welded with manifold and cross tube mounts" and has a built-in "supply passage, a return passage, and a lift control passage" (Compl. ¶¶ 28, 35). These are marketed as replacements for Plaintiff's "DeltaForce" cylinder system (Compl. ¶ 28).
  • The Seed Meter Products include a delivery belt designed to move seeds from a singulator to a seed tube. Exhibit M of the complaint provides a picture of the parts of the Seed Meter Products, showing a circular belt with projecting flights (Compl. ¶ 29, Ex. M). These products also contain a "singulating brush that is pivotally adjustable" (Compl. ¶ 30).
  • The Air Cylinder Product is alleged to be a dual-acting air cylinder used on a "row cleaning/sweeping system" and is marketed as a replacement for Plaintiff's "CleanSweep" product (Compl. ¶ 31).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,144,189 Infringement Allegations

Claim Element (from Independent Claim 22) Alleged Infringing Functionality Complaint Citation Patent Citation
A downforce controller for a planter row unit, comprising: a hydraulic actuator configured to apply a force to the planter row unit; and The accused product is a "Hydraulic Cylinder #WMCT32X89, down force" for a planter. ¶28 col. 2:22-25
a manifold mounted to said hydraulic actuator; The accused cylinder is described as being "Welded with manifold." ¶28 col. 2:26-27
a pressure control valve in fluid communication with said manifold, wherein said pressure control valve is supported by the planter row unit. The accused "Solenoid Valve Set #P729600" is alleged to work on the hydraulic cylinder and its manifold. The entire assembly is alleged to be "sized to... fit on a planter row unit." ¶¶28, 35 col. 2:28-30
  • Identified Points of Contention:
    • Scope Questions: A potential issue may be the interpretation of "supported by the planter row unit." The complaint alleges the combined product assembly fits on the row unit, but the specific nature of the support and whether it meets the claim limitation as understood from the patent's specification will likely be a point of dispute.
    • Technical Questions: The complaint alleges the Solenoid Valve works "on" the Hydraulic Cylinder, implying the claimed fluid communication. The factual evidence demonstrating the nature and pathways of this fluid communication between the specific accused valve and manifold will be central to the infringement analysis.

U.S. Patent No. 9,879,702 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a double-acting hydraulic cylinder including a first chamber and a second chamber... a first pressure in said first chamber and a second pressure in said second chamber having counteracting effects on said net downforce; The complaint alleges the accused hydraulic cylinder has a "manifold including a... lift control passage all built in," which suggests a second chamber for providing a counteracting lift force. ¶35 col. 1:56-62
a manifold coupled to said cylinder, said manifold being in fluid communication with said first chamber; and The accused cylinder is "Welded with manifold." ¶28 col. 1:63-65
a pressure control valve supported by said manifold, said pressure control valve being in fluid communication with said manifold and with said first chamber; The accused Solenoid Valve is alleged to "work on" the cylinder with the integrated manifold. ¶28 col. 1:66-col. 2:2
wherein said pressure control valve comprises a supply port, a return port, and a control port... The complaint alleges the accused product's manifold has a "supply passage, a return passage, and a lift control passage," implying the valve that controls it has corresponding ports. ¶35 col. 2:3-6
wherein said pressure control valve is supported by said manifold. This is alleged by the description of the valve working "on" the cylinder's welded manifold. ¶28 col. 2:8-9
  • Identified Points of Contention:
    • Scope Questions: A central question will be whether the accused cylinder is "double-acting" and provides "counteracting effects" as claimed. While the complaint's allegation of a "lift control passage" may support this, it is not an explicit statement of the cylinder's internal operation.
    • Technical Questions: The complaint's allegations about the specific port structure ("supply port, a return port, and a control port") of the accused valve are based on an inference from the alleged structure of the manifold. Factual discovery will be needed to determine if the accused Solenoid Valve actually contains the precise port configuration required by the claim.

V. Key Claim Terms for Construction

  • The Term: "supported by" ("...the planter row unit" in ’189, cl. 22; "...said manifold" in ’702, cl. 1)

  • Context and Importance: This term defines the physical and structural relationship between the components of the claimed controller. The infringement analysis for both lead patents hinges on whether the accused valve is attached and supported in the manner claimed—either by the row unit as a whole or by the manifold specifically.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification discloses that the "downforce controller 100 is pivotally connected to the controller attachment bracket 214 by an upper pin," and the bracket is in turn "mounted to the front bracket 212" of the row unit (’189 Patent, col. 2:55-58). This suggests that "supported by" could encompass both direct and indirect forms of attachment.
    • Evidence for a Narrower Interpretation: The figures, particularly FIG. 2A, show a specific arrangement where the pressure control valve (140) is mounted directly to the manifold body (102), which is part of the overall controller (100) assembly attached to the row unit. A party could argue "supported by" requires this type of direct physical mounting as depicted in the preferred embodiment.

  • The Term: "double-acting hydraulic cylinder" (’702 Patent, cl. 1)

  • Context and Importance: This term is fundamental to the operation of the claimed invention in the ’702 Patent, as it enables the "counteracting effects" on net downforce. The complaint does not explicitly describe the accused hydraulic cylinder as "double-acting," making the construction of this term critical to determining infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term itself has a generally understood meaning in the art as a cylinder in which fluid pressure can be applied to move the piston in two opposite directions.
    • Evidence for a Narrower Interpretation: The patent specification describes a specific embodiment where the cylinder's interior is separated by a piston (174) "into a down chamber 136 and a lift chamber 134" (’702 Patent, col. 2:2-4). A party may argue that the term should be limited to this specific two-chamber internal structure.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all patent groups. The allegations for inducement are based on Defendant allegedly selling the products with knowledge and intent for them to be used in an infringing manner, citing Defendant's marketing of the products as replacements for Plaintiff's patented systems (e.g., "DeltaForce," "CleanSweep") (Compl. ¶¶ 35, 73). The allegations for contributory infringement are based on the assertion that the accused products are specially designed for infringing uses and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶ 37, 51, 64).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The basis is Defendant's alleged knowledge of the patents and infringement as of the February 21, 2024 notice letter, and its subsequent continued sales (Compl. ¶ 41). The allegation that Defendant admitted infringement of the Seed Meter and Singulation Brush patents on March 7, 2024, provides a particularly strong basis for willfulness regarding those specific patents (Compl. ¶ 13).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of evidentiary proof for infringement: For the Hydraulic Cylinder and Pressure Control patents, can Plaintiff produce evidence that the accused products, marketed as "replacements," meet the specific technical claim limitations, such as the "double-acting" nature of the cylinder and the precise "supply, return, and control port" configuration of the valve, which are not explicitly detailed in the complaint's product descriptions?
  • A second key issue will be the impact of alleged pre-suit admissions: The complaint alleges Defendant explicitly admitted infringement of the Seed Meter and Singulation Brush patents. A central question for the case will be how this alleged admission, if substantiated, affects the analysis of liability and willfulness for those patents, and potentially influences the broader litigation strategy and settlement posture for the remaining disputed patents.