Performance Livestock Analytics 20 Inc v. Redbook Software Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Performance Livestock Analytics 2.0, Inc. (Delaware)
  • Defendant: Redbook Software, Inc. (Delaware)
  • Plaintiff’s Counsel: Shuttleworth & Ingersoll, P.L.C.
• Case Identification: 0:26-cv-00279, N.D. Iowa, 08/29/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Iowa because a substantial portion of the events underlying its Lanham Act claim occurred in the district, and the court has personal jurisdiction over the Defendant.
• Core Dispute: Plaintiff alleges that Defendant’s "Redbook Cattle" software infringes a patent related to real-time, wireless livestock feed management systems, and further asserts claims for trade dress infringement and tortious interference based on allegations that Defendant created a "copycat" product using Plaintiff's confidential information.
• Technical Context: The technology at issue involves software and hardware integration to accurately measure and track the weight of individual ingredients being mixed into livestock feed, addressing a critical need for precision in large-scale cattle feeding operations to optimize animal health and profitability.
• Key Procedural History: The complaint describes a corporate history wherein Plaintiff's predecessor was sold to Zoetis Holdings, LLC in 2020 and subsequently repurchased by the current Plaintiff entity in 2023. Plaintiff alleges that several of its former employees, after being terminated by Zoetis, joined Defendant and used confidential information to develop the accused product. Plaintiff also alleges it sent Defendant a notice of infringement letter on April 8, 2025.

Case Timeline

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 inefficiency and inaccuracy inherent in large-scale livestock feeding, where operators loading thousands of pounds of feed components into a mixer must manually read a scale to determine when to stop loading, often resulting in "an unbalanced ration, and lower end results" for livestock health and producer profit (’700 Patent, col. 5:45-54).
• The Patented Solution: The invention provides a system where an electronic scale on the feed mixer captures weight data for each ingredient as it is loaded. This data, along with a unique identifier for the scale, is then broadcast wirelessly (e.g., via Bluetooth) to a mobile application used by the equipment operator. This provides accurate, real-time feedback during the mixing process and transmits the data to a server-side application for broader supply-chain management (’700 Patent, col. 6:20-34, Fig. 1).
• Technical Importance: This approach sought to replace manual, error-prone processes with a digitally integrated workflow, enabling greater precision in feed formulation and data collection for farm management (’700 Patent, col. 5:51-54).

Key Claims at a Glance

• The complaint asserts independent claim 9 (’700 Patent; Compl. ¶91).
• The essential elements of method claim 9 include:
  • Identifying a triggering condition to initialize data collection for a feed mixing operation.
  • Selecting a scale identifier and a subscriber identifier from a database based on the trigger.
  • Associating the trigger with scale parameters and a desired weight for a ration component.
  • Transmitting the identifiers and desired weight to a mobile application over an asynchronous wireless connection as components are loaded.
  • Transmitting the identifiers, desired weight, and collected weight information to a server-side application for use in an integrated supply chain.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's "Redbook Cattle" software product (Compl. ¶47).

Functionality and Market Context

The complaint alleges that Redbook Cattle is a "cattle management platform" that, like Plaintiff's Performance Beef product, "streamlines the feeding process by collecting data in a single interface" (Compl. ¶54). The platform is alleged to perform the same functions as Plaintiff's product and is described as a "copycat or near replica" (Compl. ¶56). The complaint alleges the accused product utilizes the same third-party "POINT® scale indicator" from Scale-Tec that Plaintiff's product uses to interface with feed mixing equipment (Compl. ¶67). A screenshot provided in the complaint depicts the user interface of the accused product, showing a grid-based layout for displaying target and loaded feed weights (Compl. ¶58).

IV. Analysis of Infringement Allegations

The complaint references a claim chart exhibit that was not provided; the following analysis is based on the complaint's narrative allegations (Compl. ¶46, ¶91).

’700 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the general act of a user starting a loading process on the Redbook Cattle app meets the specific definition of a "triggering condition" as described in the patent, which includes "a ready indication from feed ration loading equipment" (’700 Patent, col. 12:23-24).
  • Technical Questions: What evidence does the complaint provide that the accused system transmits the specific combination of data elements recited in the final limitation (subscriber ID, scale ID, desired weight, collected weight, etc.) to a "server-side application" for integration into a "supply chain of feed ration providers"? The complaint's allegations focus more on the mobile application's user-facing functionality than on the back-end data architecture.

V. Key Claim Terms for Construction

• The Term: "triggering condition"

• Context and Importance: This term defines the initiation of the claimed method. Its construction will be critical to determining the point of infringement. A broad interpretation could cover a user simply pressing a "start" button in the software, while a narrower interpretation might require a specific signal originating from the physical loading or mixing equipment itself.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language is "at least one triggering condition," which suggests flexibility. The specification is not explicitly limiting, leaving open the possibility that various events could initiate the process.
  • Evidence for a Narrower Interpretation: Claim 9 itself provides specific examples of a "triggering condition," namely "a ready indication from feed ration loading equipment...and an indication from the feed mixing equipment that the feed ration is ready for a next component" (’700 Patent, col. 12:23-27). A defendant may argue these examples limit the term's scope to signals from the hardware.

• The Term: "server-side application configured to apply the weight information...to an integrated supply chain of feed ration providers"

• Context and Importance: This limitation appears to position the invention as more than just a remote display for a scale; it claims a connection to a larger logistics and supply chain system. Infringement will depend on whether the accused Redbook Cattle product's back-end performs this supply-chain integration function.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the server-side application as enabling "control of machine-to-machine operations across an entire, integrated supply chain" (’700 Patent, col. 6:47-49). A plaintiff may argue that any server that aggregates data for inventory or reordering purposes meets this limitation.
  • Evidence for a Narrower Interpretation: The specification provides examples of server-side functions like commanding "a micro-feeder machine" to release ingredients and correlating data for "high-precision dosing" (’700 Patent, col. 7:4-12). A defendant may argue the term requires active, automated control over external supply chain machinery, not just passive data aggregation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Redbook provides its product to customers "with the intent and direction" that they use it in a way that directly infringes claim 9 (Compl. ¶99). It further alleges contributory infringement, stating the accused product is a material component "especially made or especially adapted" for infringement and is not a staple article of commerce (Compl. ¶107-108).
• Willful Infringement: The complaint alleges willfulness based on Redbook's alleged knowledge of the ’700 Patent as of "at least April 8, 2025," the date Plaintiff's counsel sent a notice of infringement letter (Compl. ¶76, ¶97).

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

• A core issue will be one of evidentiary proof: While the complaint provides visual evidence suggesting the accused mobile application's user interface is similar to Plaintiff's, what evidence will be presented to demonstrate that Redbook Cattle's back-end architecture performs every step of the claimed method, particularly the transmission of a specific data package to a "server-side application" for "integrated supply chain" purposes?
• A key question of claim scope will be the interpretation of "triggering condition." Can Plaintiff establish that the initiation of a feed loading process in the accused software meets this limitation, or will the court construe the term more narrowly to require a specific hardware-based signal from the feeding equipment itself?
• The case also presents a significant question of technical functionality: Does the accused Redbook Cattle system, which allegedly uses the same third-party scale interface as the Plaintiff, inherently practice the patented method of data capture and wireless transmission, or are there non-infringing ways to use that hardware that Defendant may employ?