DCT

0:25-cv-03968

Redbook Software Inc v. Performance Livestock Analytics 20 Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:25-cv-03968, D. Minn., 10/15/2025
  • Venue Allegations: Plaintiff Redbook asserts venue is proper in the District of Minnesota because Defendant PLA has conducted business and has systematic and continuous business contacts within the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its "Redbook Cattle" software product does not infringe Defendant's U.S. Patent No. 9,924,700, and that the patent is invalid.
  • Technical Context: The dispute centers on agricultural technology for managing livestock feed, specifically systems that wirelessly capture and transmit weight data from feed mixing equipment to mobile and server-based applications.
  • Key Procedural History: The complaint states that on April 8, 2025, Defendant PLA accused Plaintiff Redbook of infringing the patent-in-suit. This was followed by correspondence between the parties and a subsequent patent infringement lawsuit filed by PLA against Redbook in the Northern District of Iowa on August 29, 2025, which Redbook is moving to dismiss for improper venue. This declaratory judgment action appears to be a responsive filing in Redbook's preferred forum.

Case Timeline

Date Event
2016-12-01 ’700 Patent Priority Date
2018-03-27 ’700 Patent Issue Date
2025-04-08 Defendant PLA sends correspondence accusing Redbook of infringement
2025-04-30 Plaintiff Redbook responds to Defendant's infringement allegations
2025-08-29 Defendant PLA files patent infringement lawsuit in N.D. Iowa
2025-10-15 Complaint for Declaratory Judgment filed in D. Minn.

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

U.S. Patent No. 9,924,700 - Asynchronous capture, processing, and adaptability of real-time feeder livestock ration weight information and transfer over wireless connection for mobile device, machine-to-machine supply chain control, and application processing

The Invention Explained

  • Problem Addressed: The patent's background section describes the process of mixing livestock feed as inefficient and prone to error, as operators manually read scales to determine the amount of each component added to a feed mixer. This can lead to "unbalanced ration[s]," resulting in "reduced weight gain and lower profit for producers" (’700 Patent, col. 1:46-53). Existing methods lacked a "real-time approach to tracking the amount of each component" and integrating that data into a broader supply chain workflow (id., col. 1:53-56).
  • The Patented Solution: The invention is a system and method that uses an electronic scale on feed mixing equipment to capture weight data. This data, along with a unique "scale identifier," is broadcast wirelessly (e.g., via a Bluetooth dongle) to both a mobile application for the equipment operator and a server-side application (’700 Patent, Abstract; col. 4:36-41). The server-side application can then use this real-time data to manage and control an "entire, integrated supply chain of livestock feed operations" (’700 Patent, col. 4:47-50). The overall data flow is depicted in Figure 1, which shows data from a scale (114) on mixing equipment (110) being transmitted wirelessly to a mobile app (140) and a server-side app (150) that manages the supply chain (160).
  • Technical Importance: The technology provides a method for digitizing and automating the feed mixing process, aiming to improve accuracy, efficiency, and the integration of on-farm activities with machine-to-machine supply chain management (’700 Patent, col. 2:52-56).

Key Claims at a Glance

  • The complaint notes that Defendant asserted independent claims 1, 9, and 17 (Compl. ¶12).
  • Independent Claim 1 (Method):
    • Initializing a collection of input data for a feed mixing operation.
    • Capturing a scale identifier from a scale interface on feed mixing equipment.
    • Capturing weight information for each component of the feed ration as it is loaded.
    • Broadcasting the scale identifier and weight information over a wireless connection to three destinations: a receiver coupled to the mixing equipment, at least one mobile application, and at least one server-side application.
    • Generating and transmitting output data representing the weight information to the server-side application.
  • Independent Claim 17 (System):
    • A data collection and initialization component configured to initialize data collection and capture a scale identifier and weight information.
    • A data transmission component configured to broadcast the scale identifier and weight information to a receiver, a mobile application, and a server-side application.
    • A plurality of data processing components configured to adapt the weight information for display on the mobile app and generate output data.
  • The complaint does not explicitly reserve the right to assert dependent claims, as it is a declaratory judgment action filed by the accused infringer.

III. The Accused Instrumentality

Product Identification

The "Redbook Cattle" software product (Compl. ¶12).

Functionality and Market Context

The complaint describes the product as "cutting-edge software utilized by custom cattle feedyards to optimize their operations, increase efficiency, and drive profitability" (Compl. ¶6). The complaint provides limited detail on the product's specific functionality, focusing instead on what it allegedly does not do. It alleges the "Redbook Cattle" product does not send a scale identifier to any "Redbook Cattle" server (Compl. ¶17) and does not "broadcast information to three components" (a receiver, a mobile application, and a server-side application) in the manner required by the claims (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint does not contain traditional infringement allegations but rather asserts non-infringement. The following table summarizes Plaintiff Redbook's central non-infringement theories for a representative claim.

U.S. Patent No. 9,924,700 Non-Infringement Allegations (based on Claim 1)

Claim Element (from Independent Claim 1) Alleged Missing Functionality Complaint Citation Patent Citation
capturing the scale identifier from a scale interface... The complaint alleges the product does not transmit a "scale identifier" to its server-side application. ¶17 col. 11:12-14
broadcasting at least the scale identifier and the weight information for each component over an asynchronous wireless radio communication connection to a receiver coupled to the feed mixing equipment... to at least one mobile application... and to at least one server-side application... Plaintiff alleges its product does not broadcast information to three distinct components as required by the claim. ¶18 col. 11:18-29

Identified Points of Contention

  • Scope Questions: A central dispute may concern the scope of "broadcasting... to" the three recited components (receiver, mobile app, server-side app). The question for the court will be whether this requires a direct, one-to-many transmission from a single source to all three destinations, or if a relayed architecture (e.g., scale transmits to mobile app, which then transmits to server) satisfies the limitation. The complaint's phrasing suggests Plaintiff may argue for the narrower, direct-broadcast interpretation (Compl. ¶18).
  • Technical Questions: A key factual question will be whether the "Redbook Cattle" system transmits a "scale identifier" to a server. Plaintiff alleges it does not (Compl. ¶17), which would present an evidentiary hurdle for the patentee to overcome. The complaint also raises a factual dispute regarding so-called "triggering conditions" required by claim 9, alleging such conditions "do not exist in the 'Redbook Cattle' product" (Compl. ¶19).

V. Key Claim Terms for Construction

Term: "broadcasting... to... a receiver..., to at least one mobile application..., and to at least one server-side application"

  • Context and Importance: This limitation appears in independent claims 1 and 17 and is at the core of Plaintiff's non-infringement argument (Compl. ¶18). The construction of this phrase—specifically whether it requires direct, simultaneous transmission to all three entities or allows for sequential or relayed communication—may be dispositive of infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's Figure 1 depicts the mobile app (140) communicating with the server-side app (150) via the "Internet," separate from the Bluetooth connection between the on-equipment device (130) and the mobile app. This could support an interpretation where "broadcasting to" the server-side application can be achieved indirectly via the mobile application's internet connection (’700 Patent, FIG. 1).
    • Evidence for a Narrower Interpretation: The claim language uses the parallel structure "to a receiver..., to at least one mobile application..., and to at least one server-side application," which could be argued to imply that the "broadcasting" action is directed from a common source to all three recipients over the "asynchronous wireless radio communication connection" recited in the claim (’700 Patent, col. 11:18-29).

Term: "specifically-configured processor"

  • Context and Importance: This term appears in the preamble of claims 1 and 9 and in the body of claim 17. Practitioners may focus on this term because Plaintiff has identified it as a basis for invalidity under 35 U.S.C. § 112 for lack of written description, lack of enablement, and indefiniteness, alleging the patent provides no disclosure or description for it (Compl. ¶20, ¶42).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A patentee would likely argue this term refers to a general-purpose processor that has been programmed with software to perform the claimed functions, a common understanding in the art. The specification mentions that the "computing environment may include one or more processors" configured to "execute program instructions or routines" (’700 Patent, col. 4:25-30).
    • Evidence for a Narrower Interpretation: The specification does not appear to provide any specific structural details for the "specifically-configured processor" beyond general statements about processors and software. Plaintiff's argument hinges on this lack of detail, suggesting that one of ordinary skill in the art would not understand the full scope of the term from the disclosure alone (Compl. ¶20).

VI. Other Allegations

Indirect Infringement

The complaint seeks a declaratory judgment of no indirect infringement but does not allege specific facts relating to inducement or contributory infringement (Compl. ¶46).

Willful Infringement

The complaint states that Defendant accused Plaintiff's alleged infringement of being "deliberate" and a "calculated effort to copy" (Compl. ¶12). This allegation by the patentee, cited in the complaint, establishes that pre-suit knowledge—a prerequisite for willfulness—is at issue in the underlying dispute.

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

  • A core issue will be one of claim scope: does the term "broadcasting... to" all three recited system components require a direct, simultaneous wireless transmission from a single source, or can the limitation be met by a relayed data flow where, for example, a mobile device receives data wirelessly and forwards it to a server over the internet?
  • A second central issue will be invalidity under § 112: does the patent provide adequate written description and enablement for the term "specifically-configured processor," or is the term indefinite for failing to inform a person of ordinary skill in the art about the scope of the invention with reasonable certainty?
  • A key evidentiary question will be one of factual operation: does the accused "Redbook Cattle" product in fact transmit a "scale identifier" to a server-side application, a fact Plaintiff expressly denies and which the patentee must prove to establish infringement of claims 1 and 17.