DCT
2:25-cv-00851
Valveworks USA Inc v. Bestway Oilfield Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Valveworks USA, Inc. (Louisiana)
- Defendant: Bestway Oilfield, Inc. (Texas)
- Plaintiff’s Counsel: Haynes and Boone, LLP
- Case Identification: 2:25-cv-00851, E.D. Tex., 08/22/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in Texas, has committed acts of infringement in the district, and maintains a regular and established place of business in Tyler, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s frac valves, which incorporate its "ValveShield System technology," infringe a patent related to protective sleeves for gate valves used in oil and gas operations.
- Technical Context: The dispute concerns high-pressure gate valves, critical components in hydraulic fracturing ("fracking") operations, where equipment reliability and longevity directly impact operational costs and safety.
- Key Procedural History: The complaint details pre-suit correspondence, including a June 2025 cease-and-desist letter from Plaintiff to Defendant that allegedly included a claim chart, and Defendant’s subsequent denial of infringement. This correspondence forms the basis for Plaintiff's allegations of willful infringement. The complaint also references Defendant's own patent application and a prior lawsuit where Defendant described its technology, suggesting these documents may be used as admissions.
Case Timeline
| Date | Event |
|---|---|
| 2016-01-04 | ’426 Patent Priority Date |
| 2021-08-31 | ’426 Patent Issue Date |
| 2025-03-06 | Defendant's '803 Patent Application Publication Date |
| 2025-06-24 | Plaintiff sends cease-and-desist letter to Defendant |
| 2025-06-30 | Defendant responds to Plaintiff, denying infringement |
| 2025-07-09 | Plaintiff replies, identifying specific infringing products |
| 2025-08-22 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,105,426 - "Gate Valve with Full-Bore Protective Sleeve"
- Issued: August 31, 2021
The Invention Explained
- Problem Addressed: In high-pressure oil and gas operations like hydraulic fracturing, fluidic materials flow through gate valves at high rates, which can cause structural degradation, wear-out, or blowout of components like sealing elements, potentially requiring replacement of the entire valve (’426 Patent, col. 1:21-34).
- The Patented Solution: The invention is a gate valve that incorporates a "protective sleeve" positioned between the main valve body and the valve seat element (’426 Patent, Abstract; Fig. 8A). This sleeve is designed to shield the valve’s annular seals from the abrasive, high-velocity fluid flow, protecting them from deterioration while maintaining a constant "full-bore" internal diameter to ensure unimpeded flow (’426 Patent, col. 9:1-4; col. 10:55-65).
- Technical Importance: This design aims to extend the service life and improve the reliability of gate valves used in harsh operational environments, thereby reducing equipment downtime and replacement costs (’426 Patent, col. 1:30-34).
Key Claims at a Glance
- The complaint asserts at least independent claim 6 (Compl. ¶18).
- Claim 6 of the ’426 Patent recites the following essential elements for a gate valve:
- A valve body comprising a passage, a first fluid bore, a first annular recess, a first annular shoulder, and a second annular shoulder.
- A first seat element extending within the first annular recess, comprising a second fluid bore.
- A first protective sleeve extending on opposing sides of the first annular shoulder.
- An inside circumferentially-extending surface and an outside circumferentially-extending surface on the protective sleeve.
- Limitations requiring that the full-bore inside diameters of the valve body bore, the seat element bore, and the protective sleeve are all "substantially equal."
- The complaint does not explicitly reserve the right to assert other claims, but this remains a possibility as the case proceeds.
III. The Accused Instrumentality
Product Identification
- The "Mark V SLVTM SERVICE-LESSTM FRAC VALVES" and the "Don 1TM SERVICE-LESS FRAC VALVES" (collectively, the "Accused Products") (Compl. ¶9).
Functionality and Market Context
- The Accused Products are frac valves that allegedly feature "dual purpose ValveShield System technology" (Compl. ¶9). Plaintiff cites Defendant’s own prior court filing, which described this technology as enabling "greaseless frac operations, while eliminating sand and particle intrusion" and extending the service life of the valve (Compl. ¶10). The complaint alleges that the technical details of the Accused Products are described in Defendant’s own U.S. Patent Application Publication No. US 2025/0075803 (Compl. ¶11). The complaint includes a reference to photographs of a disassembled MARK V Valve, which allegedly show components consistent with the infringing technology (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint incorporates by reference a claim chart (Exhibit 5) that was not attached to the publicly filed document. The following table summarizes the infringement theory for claim 6 based on the narrative allegations in the complaint (Compl. ¶¶9-11, 14, 19).
'426 Patent Infringement Allegations
| Claim Element (from Independent Claim 6) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a valve body comprising a passage... a first fluid bore... a first annular recess... a first annular shoulder... and a second annular shoulder | The complaint alleges the Accused Products are gate valves containing the requisite body, bore, and shoulder structures, as depicted in Defendant's '803 Publication and in photographs of a disassembled valve. | ¶¶9, 11, 14 | col. 2:27-56 |
| a first seat element extending within the first annular recess... comprising a second fluid bore | The Accused Products allegedly contain a seat element with a fluid bore that fits within the valve body. | ¶¶11, 14 | col. 3:36-49 |
| a first protective sleeve extending on opposing sides of the first annular shoulder | Defendant's "ValveShield System technology" is alleged to be, or to contain, a protective sleeve that is positioned on opposing sides of an annular shoulder within the valve. | ¶¶9, 10 | col. 4:30-49 |
| wherein the first fluid bore of the valve body has a first full-bore inside diameter, the second fluid bore... has a second full-bore inside diameter, and the first protective sleeve has a third full-bore inside diameter, the first, second, and third full-bore inside diameters being substantially equal | The "ValveShield System" allegedly maintains a constant, unimpeded fluid path through the valve, consistent with the "substantially equal" full-bore diameter requirement of the claim. | ¶10 | col. 9:5-13 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the meaning of "protective sleeve." The analysis will question whether Defendant's "ValveShield System" is the same as, or equivalent to, the specific structure claimed in the patent, or if it represents a distinct, non-infringing design.
- Technical Questions: The complaint relies heavily on Defendant's marketing statements and its patent application to establish infringement (Compl. ¶¶10-11). A key question will be whether the actual physical construction of the Accused Products, as may be revealed in discovery and expert analysis of components like those shown in the referenced photographs (Compl. ¶14), matches the specific arrangement required by the claim, particularly the limitation that the sleeve is "extending on opposing sides of the first annular shoulder."
V. Key Claim Terms for Construction
The Term: "protective sleeve"
- Context and Importance: This term describes the core inventive concept. Its construction will determine the scope of the patent's protection and will be central to the infringement analysis. Practitioners may focus on this term because the dispute hinges on whether Defendant’s "ValveShield System" falls within its definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the sleeve's function as being "adapted to protect the annular seal... from blowout, wear-out, and/or deterioration" (’426 Patent, col. 9:1-4). A party could argue that any component performing this protective function should be considered a "protective sleeve."
- Evidence for a Narrower Interpretation: The patent consistently depicts the "protective sleeve" (e.g., 65a) as a distinct, generally cylindrical tube that extends between and engages specific surfaces on both the valve body (12) and the seat element (64a) (’426 Patent, Fig. 8A; col. 4:30-49). A party could argue the term is limited to structures that match this specific configuration and relationship with other valve components.
The Term: "extending on opposing sides of the first annular shoulder"
- Context and Importance: This positional limitation defines the required location and arrangement of the "protective sleeve." Infringement will depend on whether the accused device meets this precise spatial requirement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue this language only requires that some portion of the sleeve exists on one side of the shoulder and another portion exists on the other, without requiring a specific method of support or engagement.
- Evidence for a Narrower Interpretation: The specification describes an embodiment where the protective sleeve "extends between respective portions of the valve body... and the seat element... that is, between the annular shoulder 44 and the annular shoulder 80" (’426 Patent, col. 4:35-36). This suggests the sleeve must physically span the gap between structures located on opposite sides of the shoulder, potentially limiting the claim to that specific arrangement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Defendant instructs customers on how to use the Accused Products through "product information and instruction materials" (Compl. ¶26). It alleges contributory infringement by claiming the Accused Products are "especially made and adapted for use during fracking operations" and have no substantial non-infringing use (Compl. ¶33).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’426 Patent as of at least June 24, 2025, the date Plaintiff sent a cease-and-desist letter that allegedly included a claim chart detailing the infringement (Compl. ¶¶12, 20).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "protective sleeve," as described and depicted in the ’426 Patent, be construed to read on the specific components of Defendant’s "ValveShield System technology"? The outcome will likely depend on whether the term is limited to the patent's specific structural embodiments or can encompass broader functional equivalents.
- A key evidentiary question will be one of structural identity: does the physical assembly of the Accused Products, particularly the placement of components relative to the valve body's "annular shoulder," meet the precise positional limitations of claim 6? This will turn on technical evidence regarding the products' actual construction, potentially using Defendant's own patent application and the disassembled product photographs as key pieces of evidence.