DCT
1:25-cv-00286
Precision Planter Solutions LLC v. Solid Rock Ag Solutions Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Precision Planter Solutions, LLC (Missouri)
- Defendant: Solid Rock AG Solutions, Inc. (Indiana)
- Plaintiff’s Counsel: Husch Blackwell LLP
- Case Identification: 1:25-cv-00286, N.D. Ind., 06/06/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is an Indiana corporation with a principal place of business and a regular and established place of business within the Northern District of Indiana.
- Core Dispute: Plaintiff alleges that Defendant’s aftermarket rebuilding services and components for agricultural planter arms infringe a patent related to a pivoting support system designed to extend equipment service life.
- Technical Context: The technology addresses mechanical wear in the pivoting parallel arms of agricultural planters, a critical component that frequently fails due to stress from traversing uneven terrain.
- Key Procedural History: The asserted patent is subject to a terminal disclaimer, which could link its enforceability and term to that of a parent patent.
Case Timeline
| Date | Event |
|---|---|
| 2018-01-26 | Earliest Priority Date ('187 Patent) |
| 2025-04-15 | U.S. Patent No. 12,274,187 Issued |
| 2025-06-06 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,274,187 - METHOD AND APPARATUS FOR EXTENDING THE SERVICE LIFE OF AN AGRICULTURAL PLANTER, Issued April 15, 2025
The Invention Explained
- Problem Addressed: The patent’s background section describes how the pivoting arms that connect agricultural planters to tractors are subject to significant wear and damage from continuous flexing over uneven ground, which leads to costly repairs and operational downtime (Compl. ¶¶ 8-9; ’187 Patent, col. 1:49-59).
- The Patented Solution: The invention is a pivoting support system designed to manage this wear. It introduces a durable metallic "collar" into the pivot point orifice of the planter arm. A separate, softer "bushing" is then placed inside this collar. This design concentrates the wear and rotational strain on the bushing, which is intended to be a smaller, cheaper, and more easily replaceable "sacrificial wear item" ('187 Patent, col. 7:51-52). This preserves the integrity of the larger, more expensive planter arm and other components ('187 Patent, col. 5:12-29).
- Technical Importance: This approach provides an economical method for refurbishing and extending the life of high-wear components in agricultural equipment, aiming to reduce maintenance costs and downtime for farmers ('187 Patent, col. 1:59-62).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert other claims (Compl. ¶¶ 14-15).
- Essential elements of independent claim 1 include:
- A pivoting support arm with a pivot location orifice.
- A collar made of a metallic material, which is disposed in the arm's orifice.
- A bushing with a uniform outside diameter that corresponds to the inside diameter of the collar.
- A connecting member (e.g., a bolt) disposed through the bushing.
- A terminal fastener (e.g., a nut) connected to the connecting member.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendant’s "systems for extending the service life of an agricultural planter," offered as a "parallel arm rebuilding / exchange" service and associated components (Compl. ¶11).
Functionality and Market Context
The complaint alleges that Defendant takes worn original equipment manufacturer (OEM) parallel arms, mills the pivot hole to a larger diameter, and presses in a "high-strength, heat-treated hardened sleeve." A "high-wear bushing" is then installed inside this sleeve (Compl. p. 6). Defendant’s marketing materials, cited in the complaint, state that this design ensures "the bushing will wear first, as it should," which aligns with the sacrificial wear concept central to the asserted patent (Compl. p. 6). The complaint includes an image from Defendant’s website illustrating the refurbishment process. This "Before and After" image depicts a worn OEM arm being repainted and fitted with a new sleeve and bushing (Compl. p. 4).
IV. Analysis of Infringement Allegations
’187 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a pivoting support arm including a pivoting support arm pivot location orifice... | The rebuilt OEM parallel arms that are part of Defendant's exchange program. | ¶11, p. 4 | col. 1:49-54 |
| (b) a collar including a tubular section... disposed in the pivoting support arm pivot location orifice, wherein the collar is made of a metallic material; | The "high-strength, heat-treated hardened sleeve" that Defendant presses into the milled-out orifice of the arm. An annotated image in the complaint identifies this component as the "Collar made of a metallic material." | ¶12, p. 5 | col. 7:40-44 |
| (c) a bushing having a uniform outside diameter that corresponds to the inside diameter of the collar... | The "high-wear bushing" that is placed inside the hardened sleeve. The same annotated image identifies this component. | ¶12, p. 5 | col. 7:45-48 |
| (d) a connecting member disposed through the bushing; | The hex screws (bolts) that are sold as part of Defendant’s "Hardware Kit for JD/White Parallel Arms." An image from Defendant's website shows these components. | ¶17, p. 9 | col. 7:49-50 |
| (e) a terminal fastener connected to the connecting member. | The "All Metal Locknut M16" components included in the same hardware kit. | ¶17, p. 9 | col. 7:51-52 |
Identified Points of Contention
- Scope Questions: The infringement analysis may focus on whether the term "collar", as used in the patent, can be construed to read on the accused product's "sleeve." The defense may argue that "collar" as described in the patent's specific embodiments (e.g., as part of a "rotation-limited intermediate member" with a "panel portion") implies a more complex structure than the accused cylindrical "sleeve."
- Technical Questions: While the complaint cites marketing materials stating the bushing is "softer than our sleeve" (Compl. p. 6), which supports the inventive concept, a factual question for the court will be whether the materials and relative hardness of the accused components, as actually sold, align with the patent's claims and description. Plaintiff will need to substantiate these marketing claims with technical evidence.
V. Key Claim Terms for Construction
The Term: "collar"
- Context and Importance: This term is central to the dispute, as the accused product is marketed as having a "sleeve." The determination of whether a "sleeve" is a "collar" under the claim's meaning will be a critical issue. Practitioners may focus on this term because the patent’s specific embodiments describe a component (1400) with features, like a "panel portion" and "peg portion," that a simple sleeve may lack ('187 Patent, col. 4:32-37).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Asserted claim 1 requires only "a collar including a tubular section" that is "disposed in the pivoting support arm pivot location orifice" ('187 Patent, col. 7:40-44). This broad, functional language may support reading the claim on any metallic, tubular insert serving this purpose, including the accused sleeve.
- Evidence for a Narrower Interpretation: The specification's detailed description of a preferred embodiment refers to the component containing the collar as a "rotation-limited intermediate member" (1400), which has a specific "teardrop" shape and a "peg portion" (1420) to prevent rotation ('187 Patent, col. 6:2-3, col. 4:35-37). A party could argue these details from the embodiment should inform and narrow the meaning of "collar."
The Term: "corresponds to"
- Context and Importance: This term defines the required relationship between the bushing’s outside diameter and the collar’s inside diameter. Its construction will determine the type of fit required between the two key components for infringement to be found.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain meaning of "corresponds to" could suggest that the nominal diameters simply need to match, allowing for a standard slip-fit or clearance-fit for ease of assembly.
- Evidence for a Narrower Interpretation: The patent’s objective of making the bushing a "sacrificial wear item" that absorbs "friction and rotational strain" might imply a more specific engineering fit (e.g., a press-fit or interference-fit) is necessary for the system to function as intended ('187 Patent, col. 5:17-20, col. 7:51-52).
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of indirect infringement (Compl. ¶12) but does not plead specific facts to support a claim for either induced or contributory infringement, such as identifying specific actions taken by Defendant with the intent to cause its customers to infringe.
- Willful Infringement: The complaint alleges that Defendant’s infringement is willful (Compl. ¶19). It does not allege pre-suit knowledge of the patent. The basis for willfulness appears to be post-suit knowledge resulting from the filing of the complaint itself.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "collar", as used in Claim 1, be construed to encompass the accused product’s "sleeve", especially when the patent’s preferred embodiments describe a more complex component with additional features not obviously present in the accused product?
- A key evidentiary question will be one of technical proof: can the plaintiff demonstrate, with evidence beyond the cited marketing materials, that the accused components as sold in the market possess the precise physical structure and relative material properties required by the asserted patent claims?