DCT
0:25-cv-04093
Satellite Industries Inc v. Jag Mobile Solutions Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Satellite Industries, Inc. (Minnesota)
- Defendant: JAG Mobile Solutions, Inc. (Indiana)
- Plaintiff’s Counsel: Carlson, Caspers, Vandenburgh & Lindquist, P.A.
- Case Identification: 0:25-cv-04093, D. Minn., 10/23/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Minnesota because Defendant is subject to personal jurisdiction in the district and a substantial part of the events giving rise to the claim occurred there, including Defendant sending an infringement notice letter to Plaintiff's Minnesota headquarters and making infringement-related statements to Minnesota-based customers and industry members.
- Core Dispute: Plaintiff seeks a declaratory judgment that its trailer step assembly products do not infringe five patents owned by Defendant related to retractable trailer step assemblies.
- Technical Context: The dispute concerns retractable stairs for trailers, a technology domain significant for providing safe and convenient access to vehicles with elevated floor levels, such as portable restroom trailers.
- Key Procedural History: This action for declaratory judgment was filed by Satellite Industries in response to alleged threats of litigation from JAG Mobile Solutions. The complaint states that JAG sent a formal notice letter alleging infringement of the five Patents-in-Suit and subsequently made statements to Satellite's customers and industry partners asserting that Satellite was infringing and that a lawsuit was imminent. This history establishes the "actual controversy" required for the court to have jurisdiction over a declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2019-02-04 | Earliest Priority Date for all Patents-in-Suit |
| 2019-12-31 | U.S. Patent No. 10,518,708 Issued |
| 2020-01-07 | U.S. Patent No. 10,525,891 Issued |
| 2020-05-12 | U.S. Patent No. 10,647,261 Issued |
| 2020-12-01 | U.S. Patent No. 10,850,669 Issued |
| 2023-08-22 | U.S. Patent No. 11,731,562 Issued |
| 2025-06-23 | Defendant’s counsel sends letter to Plaintiff alleging infringement |
| 2025-08-22 | Defendant’s President allegedly accuses Plaintiff of infringement to industry member |
| 2025-09-14 | Defendant’s President allegedly warns Plaintiff's customer of impending lawsuit |
| 2025-09-17 | Defendant’s President allegedly makes similar statements to another of Plaintiff's customers |
| 2025-10-23 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,850,669, "Trailer Step Assembly," Issued December 1, 2020
The Invention Explained
- Problem Addressed: The patent's background describes prior art retractable stairs that are installed underneath a trailer's frame structure. This positioning exposes the assembly to rain, snow, road salt, and debris, making it vulnerable to damage and corrosion. Furthermore, this under-mounted position often requires a complex lift mechanism to elevate the top step to the trailer's floor level, which adds cost and can create a potentially dangerous transition for the user. (’669 Patent, col. 1:36-2:15).
- The Patented Solution: The invention repositions the retractable stair assembly into an "interior cavity" defined within the trailer frame itself, typically between the main frame platform and a subfloor. In this protected position, the assembly is shielded from the elements. The assembly is designed to slide out from this cavity through an opening in a structural beam of the frame, allowing the top step to align with the trailer floor without needing a separate lift mechanism. (’669 Patent, col. 2:19-30; col. 3:32-48).
- Technical Importance: This design approach aims to increase the durability and longevity of trailer stairs by protecting them when stowed, while also simplifying the deployment mechanism and potentially improving user safety. (’669 Patent, col. 2:12-15).
Key Claims at a Glance
- The complaint’s first claim for relief targets the ’669 Patent, with the non-infringement argument focused on language from independent claim 1. (Compl. ¶¶ 46-52).
- Independent Claim 1 (Method) includes the essential elements of:
- Providing a trailer with a specific frame structure including a frame platform, a subfloor, and at least one structural beam defining an interior cavity.
- Providing a retractable stair assembly stowed at least partially within that interior cavity.
- Moving the retractable stair assembly from the stowed position to a deployed position where it extends out of the trailer frame.
U.S. Patent No. 10,647,261, "Trailer Step Assembly," Issued May 12, 2020
The Invention Explained
- Problem Addressed: Similar to the ’669 Patent, this patent addresses the disadvantages of conventional retractable stairs that are stowed underneath a trailer, where they are exposed to damage from road hazards and weather. (’261 Patent, col. 1:36-40).
- The Patented Solution: The patent describes a trailer apparatus incorporating the improved stair assembly. The key components are a trailer frame that defines an interior cavity and a retractable stair assembly housed within that cavity for protection. Upon deployment, the assembly moves "laterally out of a side of the trailer frame through an opening in the at least one structural beam." (’261 Patent, col. 2:20-30; Claim 1).
- Technical Importance: By integrating the stair assembly within the trailer's main frame, the invention seeks to create a more robust and reliable product that avoids the clearance and exposure issues of under-mounted systems. (’261 Patent, col. 3:45-49).
Key Claims at a Glance
- The complaint’s second claim for relief targets the ’261 Patent, with the non-infringement argument focused on language from independent claim 1. (Compl. ¶¶ 53-59).
- Independent Claim 1 (Apparatus) includes the essential elements of:
- A trailer frame with a frame platform and at least one structural beam.
- A subfloor spaced from the frame platform, defining an interior cavity between them.
- A retractable stair assembly movable from a stowed position within the interior cavity to a deployed position.
- In the deployed position, the stair assembly extends "laterally out of a side of the trailer frame through an opening in the at least one structural beam."
U.S. Patent No. 10,518,708, "Trailer Step Assembly," Issued December 31, 2019
- Technology Synopsis: This patent, from the same family, also discloses a trailer step assembly designed to be stowed within an interior cavity of the trailer frame to protect it from the elements. The invention focuses on the method of moving the assembly from its protected stowed position to a deployed position where it extends out of the frame to provide steps to an egress surface. (’708 Patent, Abstract).
- Asserted Claims: The complaint seeks a declaration of non-infringement of the ’708 Patent, referencing independent claim 1. (Compl. ¶¶ 60-66).
- Accused Features: The non-infringement allegation centers on the claim limitation requiring the assembly to "extend[] out of the trailer frame." (Compl. ¶63).
U.S. Patent No. 10,525,891, "Trailer Step Assembly," Issued January 7, 2020
- Technology Synopsis: This patent claims a trailer apparatus that incorporates the retractable stair assembly. The claims define the structural relationship between the trailer frame, a subfloor, an "interior cavity" created between them, and the stair assembly which is stored in the cavity and deploys "through a gap in the at least one structural beam." (’891 Patent, Abstract; Claim 1). The complaint uses Claim 1 of this patent as an exemplary claim for the entire patent family. (Compl. ¶42).
- Asserted Claims: The complaint seeks a declaration of non-infringement of the ’891 Patent, referencing independent claim 1. (Compl. ¶¶ 67-73).
- Accused Features: The non-infringement allegation focuses on the claim limitation requiring the assembly to "extend[] laterally out of a side of the trailer frame through a gap in the at least one structural beam." (Compl. ¶70).
U.S. Patent No. 11,731,562, "Trailer Step Assembly," Issued August 22, 2023
- Technology Synopsis: This patent claims a method of moving a retractable stair assembly. The method involves moving the assembly from a deployed position, where it provides egress, to a stowed position where it is "disposed at least partially within the interior cavity between the subfloor and the frame platform not exposed to weather elements." (’562 Patent, Claim 1).
- Asserted Claims: The complaint seeks a declaration of non-infringement of the ’562 Patent, referencing independent claim 1. (Compl. ¶¶ 74-80).
- Accused Features: The non-infringement allegation centers on the claim limitation that implies deployment "out of the trailer frame." (Compl. ¶77).
III. The Accused Instrumentality
Product Identification
The "Accused Step Assembly" is a set of stairs used on certain portable restroom trailers sold or offered for sale by Plaintiff Satellite Industries. (Compl. ¶¶ 24-26).
Functionality and Market Context
The complaint describes the Accused Step Assembly as a feature that facilitates consumer entry and exit from its trailer products. (Compl. ¶24). The complaint includes a photograph of a Satellite trailer with the Accused Step Assembly in a deployed state. (Compl. ¶25). This photograph depicts a multi-step stair assembly extending from the side of the trailer to the ground. (Compl. ¶25). The core of Satellite's non-infringement position is that this assembly's mounting and operation method is fundamentally different from that claimed in the Patents-in-Suit. (Compl. ¶¶ 49, 56). Plaintiff is described as the world's largest supplier of products to the portable sanitation industry, suggesting the accused products have significant commercial presence. (Compl. ¶23).
IV. Analysis of Infringement Allegations
This is a declaratory judgment action for non-infringement. The following tables summarize Plaintiff's central non-infringement arguments as presented in the complaint.
'669 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| moving the retractable stair assembly from the stowed position to a deployed position extending out of the trailer frame | Plaintiff alleges its Accused Trailer Step Assembly does not "extend[] out of the trailer frame" as recited in the claim. | ¶49 | col. 8:20-23 |
'261 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a retractable stair assembly... [that in a] deployed position... extends laterally out of a side of the trailer frame through an opening in the at least one structural beam | Plaintiff alleges its Accused Trailer Step Assembly does not "extend[] laterally out of a side of the trailer frame through an opening in the at least one structural beam" as recited in the claim. | ¶56 | col. 8:43-47 |
Identified Points of Contention
- Scope Questions: A central dispute will be the proper construction of key claim phrases defining the location and movement of the stair assembly. The case may turn on whether terms like "within the interior cavity of the trailer frame" and "extending out of the trailer frame" can be interpreted to read on a stair assembly that Plaintiff implies is mounted and operates external to the main frame structure. The complaint includes a representative figure from the patents showing the stairs extending through a gap in a structural beam (130), which Plaintiff appears to contrast with its own design. (Compl. ¶43).
- Technical Questions: The primary technical question is one of physical location and operation. Does the Accused Step Assembly, when stowed, reside in a protected cavity within the vertical bounds of the trailer's frame and subfloor, or is it mounted underneath the frame? Similarly, during deployment, does it pass through a structural beam of the frame, or does it deploy from a position entirely below those beams? The complaint does not provide technical drawings of the accused product, making a detailed comparison difficult at this stage.
V. Key Claim Terms for Construction
The Term: "interior cavity ... defined between the subfloor, the frame platform, and the at least one structural beam"
- Context and Importance: This term is critical because it defines the required stowed location for the patented invention. If Plaintiff's assembly is not positioned within such a cavity, a core element of the asserted claims may not be met. Practitioners may focus on this term because the patents repeatedly contrast this protected "interior" location with the exposed, under-mounted location of prior art designs.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any space generally contained within the outer boundaries of the trailer's structural components constitutes an "interior cavity."
- Evidence for a Narrower Interpretation: The specification provides language suggesting a more limited scope, describing the cavity as being "above the frame platform" and noting that in this position, the assembly is "protected from outside elements." (’261 Patent, col. 3:36-38; col. 5:6-10). Figure 5 in the patents, depicting the assembly (102) within the cavity (134) between the platform (128) and subfloor (137), reinforces this narrower interpretation.
The Term: "extends laterally out of a side of the trailer frame through a gap [or opening] in the at least one structural beam"
- Context and Importance: This phrase defines the patented path of deployment. Plaintiff's non-infringement defense for multiple patents hinges on its product not meeting this limitation. (Compl. ¶¶ 56, 70).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could contend that deploying from a position adjacent to a beam, or through a space created by the beam's end, could satisfy the "through a gap" limitation.
- Evidence for a Narrower Interpretation: The specification explicitly contrasts the invention with prior art mounted "underneath the trailer frame structure." (’261 Patent, col. 2:61-62). The specification further states that the inventive assembly "extends through the beam" and provides Figure 6, which is reproduced in the complaint, to illustrate the assembly passing through an opening (138) in the beam (130). (Compl. ¶43; ’261 Patent, col. 5:12-14). This suggests the claim requires penetration of the beam itself, not merely moving adjacent to it.
VI. Other Allegations
Indirect Infringement
The complaint makes a blanket denial that its activities constitute inducement or contributory infringement of any claim of the Patents-in-Suit. (Compl. ¶¶ 50, 57, 64, 71, 78).
Willful Infringement
The complaint notes that Defendant's June 23, 2025 notice letter alleged "willful infringement." (Compl. ¶31). It further alleges that Defendant's president told one of Plaintiff's customers that Plaintiff's product "was willfully infringing." (Compl. ¶40). These allegations form part of the basis for the controversy giving rise to the declaratory judgment action.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural location: Is the plaintiff's "Accused Step Assembly" stowed within a protected "interior cavity" formed by the trailer's primary frame elements, as required by the claims, or is it mounted underneath the frame in a manner analogous to the prior art the patents distinguish themselves from?
- A related and dispositive question will be one of deployment mechanics: Does the accused assembly, in operation, "extend... through a gap" in a main structural beam of the trailer frame? The resolution of these questions will likely depend on the court's construction of these key claim terms and a factual comparison to the design and operation of the accused product.