DCT
2:24-cv-01010
Cactus Wellhead LLC v. Cameron Intl Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cactus Wellhead, LLC (Delaware)
- Defendant: Cameron International Corporation (Delaware); Schlumberger Technology Corporation (Texas)
- Plaintiff’s Counsel: Shook, Hardy & Bacon L.L.P.; Gillam & Smith, LLP
- Case Identification: 2:24-cv-01010, E.D. Tex., 12/09/2024
- Venue Allegations: Venue is based on Defendants maintaining regular and established places of business within the Eastern District of Texas (specifically in Longview and Frisco) and conducting business related to the accused products in the district.
- Core Dispute: Plaintiff alleges that Defendants’ Automated Valve Greasing System, used in hydraulic fracturing operations, infringes a patent related to remote-controlled lubrication systems for wellhead equipment.
- Technical Context: The technology involves systems that allow operators to remotely lubricate high-pressure valves on a wellhead, aiming to improve safety and operational efficiency by eliminating the need for personnel to enter hazardous areas.
- Key Procedural History: The complaint alleges that Defendant Cameron became aware of the patent-in-suit through party discussions in December 2021. More significantly, it alleges that Cameron cited the patent-in-suit in an Information Disclosure Statement (IDS) on February 10, 2023, during the prosecution of its own, later-issued patent. This allegation, if proven, may establish pre-suit knowledge of the patent.
Case Timeline
| Date | Event |
|---|---|
| 2019-04-19 | Patent Priority Date (Provisional Application Filing) |
| 2020-04-17 | Patent Application Filing Date |
| 2021-10-05 | U.S. Patent No. 11,137,109 Issues |
| 2021-12-01 | Alleged Knowledge via Discussions Between Parties (approx.) |
| 2023-02-10 | Alleged Knowledge via Defendant's IDS Filing |
| 2024-12-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,137,109 - "Remote Greasing System", issued October 5, 2021
The Invention Explained
- Problem Addressed: The patent's background describes the challenge of lubricating valves on wellhead equipment (a "frac tree") during hydraulic fracturing. Traditionally, this process required halting operations and sending personnel into a dangerous "hazardous zone" or "red zone," creating safety risks and costly "non-productive time." (’109 Patent, col. 1:28-42; Compl. ¶13).
- The Patented Solution: The invention is a multi-part system that separates the operator from the hazardous wellhead area. It proposes using a "grease supply skid" and a "remote greasing skid" placed within the hazardous zone, which are connected to a "control skid" positioned safely outside the zone. (’109 Patent, Abstract). An operator uses an interface on the control skid to remotely actuate specific "grease supply valves" on the remote greasing skid, which then deliver lubricant from a reservoir to the frac tree valves without interrupting operations. (’109 Patent, col. 3:20-39).
- Technical Importance: The system is designed to enable simultaneous operations ("sim ops"), where fracking continues uninterrupted during valve lubrication, thereby enhancing wellsite safety and reducing operational downtime. (Compl. ¶15).
Key Claims at a Glance
- The complaint asserts infringement of independent claim 1 and dependent claim 12. (Compl. ¶33).
- Independent Claim 1 (System Claim) requires:
- A "grease supply skid" with a grease reservoir and pump.
- A "remote greasing skid" with a grease manifold and a grease supply valve.
- A "control skid" with an interface, operatively coupled to the remote greasing skid.
- A specific spatial arrangement: the "grease supply skid" and "remote greasing skid" are positioned within a hazardous zone, while the "control skid" is positioned outside of it.
- The complaint does not explicitly reserve the right to assert other claims.
III. The Accused Instrumentality
Product Identification
- The "Automated Valve Greasing System" offered by Cameron. (Compl. ¶22).
Functionality and Market Context
- The system is marketed as a way to "eliminate red zone activities and reduce greasing time" for frac valve maintenance. (Compl. ¶23).
- The complaint alleges the system is comprised of two main components: a "grease injection unit (GIU)" and a "remote-control skid." (Compl. ¶25).
- The "remote-control skid" houses a human-machine interface (HMI) and is placed "outside the red zone." (Compl. ¶25, ¶30).
- The "grease injection unit (GIU)" is placed "in the red zone" and contains a grease tote (reservoir), a high-pressure grease pump, and a "control rack" to direct grease to selected valves via hoses. (Compl. ¶25, ¶29).
- A technician uses the HMI on the remote skid to select a valve, which signals the GIU to pump grease to that specific valve on the frac tree. (Compl. ¶26).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’109 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a grease supply skid, the grease supply skid including a grease reservoir and a grease pump | The accused system's "grease injection unit (GIU)" allegedly contains a "grease tote" (reservoir) and a "high-pressure grease pump." | ¶25 | col. 2:48-50 |
| a remote greasing skid ... including: a grease manifold ... and a grease supply valve | The GIU is alleged to include a "control rack" that functions as a manifold, and the system's remote operation implies the presence of a grease supply valve function. The complaint explicitly alleges the system comprises a remote greasing skid. | ¶25, ¶26 | col. 2:50-55 |
| a grease manifold operatively coupled to the grease pump of the grease supply skid by a grease trunk line | The GIU's grease pump allegedly "pushes grease to the control rack," establishing the operative coupling. | ¶25 | col. 3:21-23 |
| a grease supply valve ... having an output port operatively coupled to a lubrication port of the valve of the wellhead or frac manifold by a grease supply line | The system uses "greasing hoses" that are "affixed to each valve" of the frac tree, connecting the system's output to the valve lubrication ports. | ¶26 | col. 3:29-39 |
| a control skid ... including an interface, the control skid operatively coupled to the remote greasing skid by a control line | The accused system features a "remote-control skid" with a "human machine interface (HMI)," which is used to operate the GIU. | ¶27, ¶28 | col. 2:58-62 |
| the control skid adapted to control the actuation of the grease supply valve | A technician using the HMI on the control skid "select[s] the valve ... that needs greasing," thereby controlling the system's actuation. | ¶27 | col. 2:62-63 |
| wherein the grease supply skid and remote greasing skid are positioned within a threshold distance of the wellhead defining a hazardous zone | The GIU, which allegedly contains the components of both skids, is "placed in the red zone." | ¶29 | col. 2:63-65 |
| and wherein the control skid is positioned outside of the hazardous zone. | The "remote-control skid" is alleged to be positioned "outside the hazardous zone." | ¶30 | col. 3:1-2 |
- Identified Points of Contention:
- Scope Questions: Claim 1 recites a "grease supply skid" and a "remote greasing skid" as two separate limitations. The complaint alleges the accused system uses a single "grease injection unit (GIU)" inside the hazardous zone. A central dispute may be whether this single GIU can satisfy the two-skid limitation of Claim 1. The assertion of dependent Claim 12 (which adds the limitation that the two skids are "on one skid") suggests Plaintiff will argue the GIU embodies two functionally distinct skids that are merely co-located, thereby meeting Claim 12.
- Technical Questions: What evidence does the complaint provide that the accused system's "control rack" (Compl. ¶25) is the structural and functional equivalent of the "grease manifold" as described in the patent? The infringement case will depend on demonstrating that the accused components perform the functions recited in the claims in the manner disclosed in the specification.
V. Key Claim Terms for Construction
The Term: "grease supply skid" and "remote greasing skid"
- Context and Importance: The infringement analysis for Claim 1 will turn on whether these terms require two structurally separate physical platforms or can be read to cover two functionally distinct modules housed within a single unit. Practitioners may focus on this term because the accused system is alleged to use a single "Grease Injection Unit" in the hazardous zone, creating a potential mismatch with the language of Claim 1.
- Intrinsic Evidence for a Broader Interpretation (Functional): The specification describes the distinct functions of the supply skid (providing pressurized grease) and the remote greasing skid (distributing the grease). (’109 Patent, col. 3:54-65, col. 4:20-39). Plaintiff may argue that as long as these distinct sets of components and functions are present, the limitations are met, regardless of their physical housing.
- Intrinsic Evidence for a Narrower Interpretation (Structural): The patent consistently depicts the "grease supply skid (101)" and "remote greasing skid (131)" as separate physical units in the figures (e.g., Figs. 2, 4, 5) and describes them as distinct items in the text. (’109 Patent, col. 3:24-26). A defendant may argue that the doctrine of claim differentiation, based on dependent Claim 12’s explicit recitation of the two skids being "on one skid," compels an interpretation where Claim 1 requires two physically separate skids.
The Term: "hazardous zone"
- Context and Importance: The claim's positional limitations—positioning skids "within" and "outside" this zone—make its definition crucial. The geographic boundary of the "hazardous zone" will be a key factual element for determining infringement.
- Intrinsic Evidence for Interpretation: The patent provides a flexible definition, stating the zone "may be defined based on anticipated conditions" such as "high pressures and potentially flammable atmospheres." (’109 Patent, col. 1:35-37; col. 3:40-42). It offers an exemplary, non-limiting distance of "between 50 and 70 feet around frac tree 20." (’109 Patent, col. 3:43-45). This language may support a definition that is adaptable to specific wellsite conditions rather than being a fixed, predetermined area.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant intends for its customers to use the accused system in an infringing manner. (Compl. ¶32). This is supported by allegations that Defendant’s marketing materials and website instruct or encourage customers to use the system to "eliminate red zone activities," which necessitates the infringing placement of the system components. (Compl. ¶23).
- Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge of the ’109 Patent. The complaint alleges two separate instances of knowledge: first, "through discussions between the parties in December 2021" (Compl. ¶19), and second, through Defendant’s own citation of the ’109 Patent in an Information Disclosure Statement (IDS) filed with the USPTO on February 10, 2023, during prosecution of its own patent. (Compl. ¶20).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural scope: Does the accused system’s single "Grease Injection Unit" meet the requirements of Claim 1 for both a "grease supply skid" and a "remote greasing skid," or can it only be found to infringe the narrower dependent Claim 12? The resolution will likely depend on the court's construction of these key terms and the application of the doctrine of claim differentiation.
- A second key issue will be one of pre-suit knowledge and intent: Given the specific allegation that Defendant cited the patent-in-suit in its own patent prosecution filings, a central question for the willfulness analysis will be how Defendant can rebut the strong inference that it knew of the patent and the risks of infringement more than a year before the lawsuit was filed.
- A final evidentiary question will be one of technical mapping: Can the Plaintiff provide sufficient evidence to prove that the named components of the accused system (e.g., the "control rack") are structurally and functionally equivalent to the specific elements recited in the patent's claims (e.g., the "grease manifold")?