DCT

5:25-cv-01573

R&R IP Investments LLC v. American Iron Works

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-01573, W.D. Okla., 12/30/2025
  • Venue Allegations: Venue is asserted on the basis that Defendant is an Oklahoma corporation with a regular and established place of business in the district, where it also allegedly commits acts of patent infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s pipe safety restraint systems and related services infringe six patents directed to safety apparatus for restraining high-pressure industrial pipelines.
  • Technical Context: The technology concerns safety restraints for temporary high-pressure flow lines, used in industries like oil and gas, which are designed to contain the violent movement of pipes and fittings in the event of a rupture or leak.
  • Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or licensing history between the parties.

Case Timeline

Date Event
2013-02-05 Earliest Priority Date for all Patents-in-Suit
2018-02-13 U.S. Patent No. 9,890,890 Issues
2018-03-20 U.S. Patent No. 9,920,870 Issues
2019-04-02 U.S. Patent No. 10,247,346 Issues
2019-09-17 U.S. Patent No. 10,415,736 Issues
2021-02-02 U.S. Patent No. 10,907,758 Issues
2022-12-27 U.S. Patent No. 11,536,410 Issues
2025-12-30 Complaint Filed

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

U.S. Patent No. 9,890,890 - "High Pressure Pipe and Fitting Restraint System"

The Invention Explained

  • Problem Addressed: The patent addresses the danger posed by temporary high-pressure pipelines, such as those used in the offshore oil and gas industry. If a section of pipe or a coupling fails, the pipe can move violently, "potentially causing injury or death to personnel and/or damage to equipment" (’890 Patent, col. 1:50-53).
  • The Patented Solution: The invention is a restraint system composed of multiple "assemblies" of "endless loop slings" that are connected end-to-end using hitch knots (e.g., a cow hitch) (’890 Patent, col. 1:30-40). A key feature is the periodic use of "disconnectable connections (e.g., shackles)" to join these assemblies. This modular design allows for maintenance or service on a section of the pipeline by disconnecting only the relevant shackles, "without disassembly of all of the endless loop slings" (’890 Patent, col. 1:37-40). The entire restraint is also knotted to the pipeline itself at intervals.
  • Technical Importance: This approach provides a method for safely restraining high-pressure lines while allowing for efficient, localized maintenance, which may be an improvement over monolithic restraint systems that would require complete removal to service a single component.

Key Claims at a Glance

  • The complaint asserts infringement of multiple claims without specifying them (Compl. ¶1). Independent claim 1 is representative and recites:
    • A first assembly of multiple endless loop slings connected end-to-end, with each sling secured to another via a "first assembly knot."
    • A second assembly of multiple endless loop slings, similarly constructed.
    • One or more "disconnectable fittings" that join the first assembly to the second assembly.
    • A requirement that the disconnectable fitting is not itself an endless loop sling.
    • Each assembly is attached to the temporary flowline at intervals with "attachments" that include a "sling knot" encircling the flowline.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,920,870 - "High Pressure Pipe and Fitting Restraint System"

The Invention Explained

  • Problem Addressed: The '870 Patent addresses the same technical problem as the ’890 Patent: the need to safely restrain temporary high-pressure pipelines to prevent catastrophic failure (’870 Patent, col. 1:43-53).
  • The Patented Solution: The solution is substantively similar to that of the ’890 Patent, describing a restraint system built from assemblies of endless loop slings connected with hitch knots and joined by disconnectable fittings (’870 Patent, Abstract). The specification describes the system as including "polyester round slings" or "loop slings" and notes the use of synthetic fibers (’870 Patent, col. 2:19-26).
  • Technical Importance: As with the ’890 Patent, the technical contribution appears to be a modular and serviceable pipeline restraint system.

Key Claims at a Glance

  • The complaint asserts infringement of multiple unspecified claims (Compl. ¶1). Independent claim 1 recites:
    • A first assembly of multiple endless loop slings including first, second, and third slings.
    • Each sling has end portions secured to another sling with a "cow hitch knot connection."
    • A plurality of "disconnectable fittings" to join assemblies.
    • The slings are attached to the pipe sections and fittings with "knots at spaced apart positions."
    • The knot includes a wrap of the sling around the piping system of at least 360 degrees.
  • The complaint does not explicitly reserve the right to assert dependent claims.

Multi-Patent Capsule: U.S. Patent No. 10,247,346

  • Patent Identification: U.S. Patent No. 10,247,346, "High Pressure Pipe and Fitting Restraint System," issued April 2, 2019 (’346 Patent).
  • Technology Synopsis: This patent, part of the same family, describes a restraint system for temporary flowlines using assemblies of "endless loop slings" connected end-to-end (’346 Patent, col. 2:15-19). These assemblies are joined by "disconnectable fittings" such as metallic shackles, and the entire system is attached to the pipeline with knotted connectors like half hitch knots (’346 Patent, col. 2:20-25, 63-65).
  • Asserted Claims: Independent claim 1.
  • Accused Features: Defendant's pipe safety restraint systems and services (Compl. ¶1, 25).

Multi-Patent Capsule: U.S. Patent No. 10,415,736

  • Patent Identification: U.S. Patent No. 10,415,736, "High Pressure Pipe and Fitting Restraint System," issued September 17, 2019 (’736 Patent).
  • Technology Synopsis: The patent discloses a safety restraint system for temporary high-pressure pipes, comprising multiple assemblies of endless loop slings connected with knots (’736 Patent, col. 3:51-56). The system's modularity is enabled by disconnectable fittings (e.g., shackles) that join the sling assemblies, allowing for localized disassembly without removing the entire restraint (’736 Patent, col. 4:44-51). The slings are also attached to the pipe assembly with knots at spaced intervals.
  • Asserted Claims: Independent claims 1, 11, and 16.
  • Accused Features: Defendant's pipe safety restraint systems and services (Compl. ¶1, 31).

Multi-Patent Capsule: U.S. Patent No. 10,907,758

  • Patent Identification: U.S. Patent No. 10,907,758, "High Pressure Pipe and Fitting Restraint System," issued February 2, 2021 (’758 Patent).
  • Technology Synopsis: This patent describes a restraint system for temporary flowlines using assemblies of endless loop slings made of materials like polyester (’758 Patent, col. 10:25-30, col. 5:14-17). The system is characterized by the use of hitch knots to connect slings within an assembly and disconnectable fittings (shackles) to connect separate assemblies, facilitating maintenance (’758 Patent, col. 6:38-51).
  • Asserted Claims: Independent claims 1 and 11.
  • Accused Features: Defendant's pipe safety restraint systems and services (Compl. ¶1, 37).

Multi-Patent Capsule: U.S. Patent No. 11,536,410

  • Patent Identification: U.S. Patent No. 11,536,410, "High Pressure Pipe and Fitting Restraint System," issued December 27, 2022 (’410 Patent).
  • Technology Synopsis: This patent discloses a similar restraint system using multiple "flexible restraining slings" connected end-to-end to form assemblies (’410 Patent, col. 13:52-56). The system is attached to the flowline with knots at spaced-apart positions, and different assemblies are joined by disconnectable fittings that are not themselves slings, providing a modular safety solution (’410 Patent, col. 13:57-63).
  • Asserted Claims: Independent claims 1, 10, and 15.
  • Accused Features: Defendant's pipe safety restraint systems and services (Compl. ¶1, 43).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Defendant's "pipe safety restraint systems" and associated "safety restraint services" (Compl. ¶1, 8).

Functionality and Market Context

  • The complaint alleges that Defendant makes, uses, sells, and configures these systems, which directly compete with Plaintiff's own products (Compl. ¶8, 9). The complaint includes a screenshot from Defendant’s website showing a "Video Library" with titles such as "Gang Line Pipe Restraint Testing 2023" and "Testing the HMPE Rope Type Restraint" (Compl. ¶11, p. 4). This visual evidence, provided as Exhibit 13 in the complaint, depicts videos that allegedly provide instructions on how to configure and use the accused products (Compl. ¶11). The complaint alleges lost sales and lost profits due to this direct competition (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits (Exhibits 7-12) that purportedly illustrate infringement (Compl. ¶1, 8). In the absence of these exhibits, the infringement analysis is based on the narrative allegations. Plaintiff alleges that Defendant’s pipe safety restraint systems, such as the "HMPE Rope Type Restraint" shown in its instructional videos, meet the limitations of the asserted claims (Compl. ¶11, 14, 19).

  • Identified Points of Contention:
    • Scope Questions: A central question may be whether Defendant's "HMPE Rope Type Restraint" falls within the scope of the claimed "multiple assemblies of endless loop slings connected end-to-end." The resolution may depend on whether a single, long rope configured with loops and knots is structurally and functionally equivalent to the patents' disclosure of discrete, interconnected "endless loop slings."
    • Technical Questions: What evidence demonstrates that Defendant's system uses the specific "cow hitch" or "girth hitch" knots recited in various claims to connect sling portions? Does the method of installing Defendant's product, as shown in its videos, meet the method limitations of claims requiring specific knotting steps and attachments at defined intervals?

V. Key Claim Terms for Construction

  • The Term: "endless loop sling"

  • Context and Importance: This term appears in the independent claims of all asserted patents and is foundational to the claimed structure. The complaint's visual evidence refers to Defendant's product as an "HMPE Rope Type Restraint," raising the question of whether a system based on a continuous "rope" constitutes one or more "endless loop slings." The construction of this term may be dispositive for infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patents use terms like "loop slings" and "round slings" interchangeably, suggesting the term is not narrowly limited to a specific commercial product but refers to a class of components with a looped structure (’870 Patent, col. 2:22-24). The function is to restrain the pipe, and a party could argue that any structure forming a continuous loop that performs this function should be covered.
    • Evidence for a Narrower Interpretation: The specifications refer to industry standards like ASME B30.9 and describe the slings as discrete components that are "connected end-to-end" to form an assembly (’870 Patent, col. 2:24-25; ’890 Patent, col. 1:32-33). A party could argue this implies that the "slings" must be separate, prefabricated units, not loops formed ad hoc from a continuous rope.

  • The Term: "disconnectable fitting"

  • Context and Importance: The modularity enabled by this component is a central feature of the invention, allowing for maintenance without full system disassembly. Whether Defendant's system uses a component that meets this limitation is critical.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims require the fitting to "join one assembly... to another assembly" (’890 Patent, cl. 1). A party could argue that any removable connector that serves this joining function would satisfy the claim language, regardless of its specific mechanical design.
    • Evidence for a Narrower Interpretation: The patents consistently provide "shackles" as the primary and often sole example of a "disconnectable fitting" (’890 Patent, col. 1:35; Abstract). The detailed description shows a shackle with a bow and a removable pin (’346 Patent, col. 4:16-19). This repeated emphasis on a specific type of hardware could be used to argue for a narrower construction limited to shackle-like devices.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant "posted advertisements and instructional videos on Youtube.com" with links from its website (Compl. ¶11). These videos allegedly "provide instructions on how to configure the infringing products" in a manner that infringes the patents (Compl. ¶11). Contributory infringement is also alleged (Compl. ¶1, 8).
  • Willful Infringement: Willfulness is alleged for all six patents. The complaint asserts that Defendant "has been long aware of the Patents" and "knew that Plaintiff's pipe safety restraint systems were patented," yet proceeded to infringe without payment to Plaintiff (Compl. ¶10, 16, 22). This alleges pre-suit knowledge of the patents and infringing conduct.

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

  1. A core issue will be one of definitional scope: can the term "multiple assemblies of endless loop slings," which the patents describe as discrete components joined end-to-end, be construed to cover the "HMPE Rope Type Restraint" system referenced in Defendant's marketing materials?
  2. A second central question will concern inducement: do Defendant’s instructional videos, as alleged in the complaint, actively encourage and instruct customers to assemble and use its restraint systems in a way that directly practices the specific knotting, wrapping, and attachment steps required by the asserted method and system claims?
  3. A key factual dispute will likely be one of knowledge and intent: what evidence supports the allegation that Defendant had pre-suit knowledge of the specific patents-in-suit and, despite this knowledge, willfully proceeded with its allegedly infringing activities?