DCT

2:23-cv-11345

Husco Automotive LLC v. Stackpole Intl Engineered Products Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-11345, E.D. Mich., 06/06/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Michigan because Defendants conduct substantial business in the district, have committed acts of infringement in the district, and reside in the district. For the foreign-based defendants, venue is alleged to be proper in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s variable displacement oil pumps, used in Stellantis vehicle engines, infringe two patents related to dual-setpoint and pressure-regulating hydraulic valve technology.
  • Technical Context: The technology concerns hydraulic valves that use selectable pressure setpoints to regulate automotive oil pump displacement, a key method for improving overall engine efficiency and fuel economy.
  • Key Procedural History: The complaint alleges a prior business relationship where Plaintiff supplied the patented valves to Defendant for use in its pumps. It further alleges that in 2022, Defendant switched to a "knock-off" valve from another supplier after having been notified of Plaintiff’s patent rights as early as September 2013, which forms the basis for the willfulness allegations.

Case Timeline

Date Event
2007-08-27 ’576 Patent Priority Date
2011-11-15 ’576 Patent Issue Date
2013-03-14 ’008 Patent Priority Date (Filing Date)
2013-09-18 Alleged notice of patents to Stackpole via presentation
2017-02-28 ’008 Patent Issue Date
2022-XX-XX Stackpole allegedly began using "Knock-off Valve"
2023-06-06 Complaint Filing Date

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

U.S. Patent No. 8,056,576 - "Dual Setpoint Pressure Controlled Hydraulic Valve" (issued Nov. 15, 2011)

The Invention Explained

  • Problem Addressed: The patent describes a need for hydraulic valves that can operate at more than one pressure setpoint, allowing a hydraulic system to be tailored to different operating conditions of a machine (Compl. ¶55; ’576 Patent, col. 1:37-43).
  • The Patented Solution: The invention is a valve where a spool moves in response to fluid pressure balanced against spring forces. A linear actuator, when energized, engages a second spring to apply an additional biasing force to the spool. This changes the pressure required to move the spool, effectively creating two distinct, electrically selectable pressure thresholds, or "setpoints," for valve operation (Compl. ¶55; ’576 Patent, Abstract; col. 4:21-40).
  • Technical Importance: This dual-setpoint capability allows hydraulic systems, such as those in automotive engines, to operate more efficiently by matching hydraulic power to the machine's immediate needs (Compl. ¶1; ’576 Patent, col. 1:12-16).

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims" of the ’576 Patent (Compl. ¶82). Independent claim 1 is representative.
  • Claim 1 requires:
    • A valve body with a bore and an inlet port, an outlet port, and a workport.
    • A valve spool slideably received within the bore.
    • A linear actuator adjacent to the valve body.
    • A first spring biasing the valve spool.
    • A second spring "extending between and coupling" the linear actuator and the valve spool to bias it in an opposing direction.

U.S. Patent No. 9,582,008 - "Systems and Methods for Fluid Pump Outlet Pressure Regulation" (issued Feb. 28, 2017)

The Invention Explained

  • Problem Addressed: Traditional engine oil pumps are often set to a single high-pressure relief value to ensure adequate lubrication under all conditions, which consumes more energy than necessary in many operating regimes. This creates a need for a system to regulate oil pressure more dynamically to improve fuel economy (’008 Patent, col. 1:30-49).
  • The Patented Solution: The patent describes a system where a pressure control valve regulates the output of a variable displacement fluid pump. The valve features a spool, multiple ports, biasing springs, and a linear actuator. A key element is a pilot passage that communicates fluid pressure from a pump outlet to one end of the spool. By energizing the actuator, the system changes the force balance on the spool, which in turn adjusts the pressure signal sent to the pump's control port, thereby regulating the pump’s output to maintain a desired pressure level (Compl. ¶62; ’008 Patent, Abstract; col. 4:5-13).
  • Technical Importance: This system enables active, real-time control of engine oil pressure, which can increase engine efficiency and reduce energy consumption by preventing the pump from working harder than necessary (’008 Patent, col. 1:45-49).

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims" of the ’008 Patent (Compl. ¶90). Independent claim 1 is representative.
  • Claim 1 requires:
    • A valve system with a valve body, bore, and spool, along with first (pump outlet), second (reservoir), and third (pump control) ports.
    • A "pilot passage arranged externally from the bore within the valve body" to communicate fluid between the first port and an end of the valve spool.
    • A linear actuator operatively coupled to the spool.
    • First and second springs to bias the spool.
    • Wherein activation and deactivation of the actuator "changes the given threshold level" to control the fluid pressure.

III. The Accused Instrumentality

Product Identification

  • The "Accused Pump," which is identified as "Stackpole's variable displacement oil pump" that incorporates a component referred to as the "Knock-off Valve" (Compl. ¶3, ¶65).

Functionality and Market Context

  • The Accused Pump is a component supplied to the automotive manufacturer Stellantis for use in the engines of numerous vehicle models, including the Ram 1500, Dodge Durango, and Jeep Grand Cherokee (Compl. ¶4). The complaint alleges that Plaintiff previously supplied its patented valves to Defendant for these pumps, but in 2022 Defendant began sourcing the "Knock-off Valve" from a third-party manufacturer, Unick Corporation, allegedly using a design provided by Stackpole (Compl. ¶5-7). The complaint alleges these pumps are assembled into hundreds of thousands of vehicles annually (Compl. ¶67).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

’576 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a valve body with a bore and having an inlet port, an outlet port and a workport in communication with the bore; The Accused Pump contains a "Knock-off Valve" alleged to be a copy of Husco's patented valve, which has these features. ¶55, ¶82 col. 5:40-44
a valve spool slideably received within the bore of the valve body... The "Knock-off Valve" incorporates a valve spool that is slideably received within the bore. ¶55, ¶82 col. 5:51-53
a linear actuator adjacent the valve body; The Accused Pump's valve system includes an actuator to enable its dual-spring functionality. ¶55, ¶68 col. 5:50-51
a first spring biasing the valve spool...; and The Accused Pump uses a "Patented Dual Spring System," which includes a first biasing spring. ¶55, ¶68, ¶87 col. 5:58-62
a second spring extending between and coupling the linear actuator and the valve spool, and biasing the valve spool... The "Patented Dual Spring System" in the Accused Pump includes a second spring that works with the actuator to create a second setpoint. ¶55, ¶68, ¶87 col. 6:5-9
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the mechanism in the "Knock-off Valve" meets the limitation of a "second spring extending between and coupling the linear actuator and the valve spool." The definition of "coupling" could be a key point of dispute, particularly how directly the spring must connect the two elements to satisfy the claim.
    • Technical Questions: A key evidentiary question is what "design" Stackpole allegedly provided to Unick (Compl. ¶7). The degree to which that design's structure and function matches the specific dual-spring, actuator-driven mechanism taught in the ’576 Patent will be critical to the infringement analysis.

’008 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a valve, the valve having a valve body with a bore and a valve spool slideably received within the bore... the valve body including a pilot passage arranged externally from the bore... to provide fluid communication between the first port and a second end of the valve spool... The Accused Pump and its "Knock-off Valve" are alleged to be a fluid pump pressure regulation system with the claimed valve, spool, and port structure. The complaint does not specifically allege the external pilot passage. ¶62, ¶90 col. 5:46-51
the first port in fluid communication with an outlet of a fluid pump... the second port... with a fluid reservoir... the third port... with a control port of the fluid pump... The Accused Pump is part of a system with a pump outlet, reservoir, and control port, and the allegedly infringing valve connects to these components as described. ¶62, ¶90 col. 4:12-19
a linear actuator adjacent the valve body and operatively coupled to the valve spool; The valve within the Accused Pump uses a linear actuator to adjust its operation. ¶62, ¶90 col. 4:48-50
a first spring... and a second spring biasing the valve spool... The valve within the Accused Pump uses a dual spring system to bias the spool. ¶62, ¶95 col. 4:41-43; col. 5:15-19
wherein activation of and deactivation of the linear actuator changes the given threshold level to enable control of the first pressure level... The Accused Pump allegedly uses the patented system to regulate pump pressure. ¶62, ¶90 col. 2:10-13
  • Identified Points of Contention:
    • Scope Questions: Claim 1 requires a "pilot passage arranged externally from the bore within the valve body." Whether the accused valve contains a structure that meets this specific limitation will likely be a significant point of contention.
    • Technical Questions: The complaint's allegations regarding the ’008 Patent are less specific than for the ’576 Patent. A primary question for the court will be whether Plaintiff can produce evidence that the Accused Pump's valve uses an external pilot passage and that its actuator functions to create two distinct pressure thresholds to regulate pump output, as claimed.

V. Key Claim Terms for Construction

’576 Patent, Claim 1: "coupling"

  • The Term: "a second spring extending between and coupling the linear actuator and the valve spool"
  • Context and Importance: This term is central to how the patented dual-setpoint function is achieved. The infringement analysis will depend on whether the accused valve's components are "coupled" in the manner required by the claim. Practitioners may focus on this term because it defines the core inventive concept of using an actuator and a second spring to create a selectable pressure threshold.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify a type of connection. A party could argue that any arrangement where the spring transmits force from the actuator to the spool constitutes "coupling" (’576 Patent, col. 2:11-15).
    • Evidence for a Narrower Interpretation: The specification's primary embodiment shows the second spring (48) extending between a bushing (46) on the actuator's armature and the valve spool (21) (’576 Patent, col. 3:26-29, Fig. 1). A party could argue "coupling" is limited to this specific arrangement where the spring abuts these components.

’008 Patent, Claim 1: "pilot passage arranged externally from the bore"

  • The Term: "a pilot passage arranged externally from the bore within the valve body"
  • Context and Importance: This limitation defines how the valve senses the pressure it is meant to regulate. If the accused device senses pressure through a different means (e.g., an internal channel or clearances), it may not infringe. Practitioners may focus on this term because it distinguishes the claimed invention from prior art or alternative designs that might use different fluid communication paths.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that any fluid path outside the main axial bore (48) that connects the first port (50) to the pilot chamber (182) meets the "externally arranged" limitation.
    • Evidence for a Narrower Interpretation: The patent figures depict a distinct, drilled channel (180) that runs parallel to but separate from the main valve bore (’008 Patent, Fig. 2, Fig. 10). A party could argue the claim term should be construed to require such a discrete, manufactured channel, not merely fluid flow through incidental gaps.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both inducement and contributory infringement. The inducement theory is based on allegations that Defendant directs and encourages its customers (e.g., Stellantis) and end users to use the infringing pumps (Compl. ¶83, ¶91). The contributory infringement theory alleges the "Knock-off Valve" is a material component of the patented invention, is not a staple article of commerce, and that Defendant knows it is specially adapted for infringement (Compl. ¶84, ¶92).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the asserted patents. The basis for this knowledge is a prior business relationship where Defendant purchased the patented valves from Plaintiff, and a specific presentation on September 18, 2013, where Plaintiff allegedly disclosed its "Patented Dual Spring System" to Defendant (Compl. ¶5, ¶68, ¶87-88, ¶95-96).

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

  • A central issue will be one of intent and prior knowledge: Did the parties’ previous supplier relationship and the alleged 2013 presentation provide Defendant with notice of the specific patents-in-suit sufficient to establish that its alleged infringement, which began years later in 2022, was willful?
  • A key evidentiary question will be one of technical identity: Does the accused "Knock-off Valve" sourced from Unick replicate the specific mechanisms of the asserted patents—namely, the dual-spring actuator system of the ’576 patent and the externally-piloted regulation system of the ’008 patent—or are there material operational and structural differences?
  • The case may also turn on a question of definitional scope: Will the court adopt a broad or narrow construction of key claim terms such as "coupling" and "pilot passage arranged externally"? The outcome of claim construction could prove dispositive of the infringement analysis.