SitePro Inc v. Plow Tech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SitePro, Inc. (Delaware)
  • Defendant: Plow Technologies LLC, et al. (Oklahoma, Texas, Delaware)
  • Plaintiff’s Counsel: Perkins Coie LLP
• Case Identification: 3:25-cv-01446, N.D. Tex., 06/06/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendants have committed acts of infringement in the district and maintain regular and established places of business there, including an office in Abilene. The complaint also asserts venue based on agency and alter ego theories among the various defendant entities, and a venue clause in an Asset Purchase Agreement between certain parties.
• Core Dispute: Plaintiff alleges that Defendants’ OnPing system, a cloud-based SCADA platform for remote industrial control, infringes a patent related to the remote control of fluid-handling devices, particularly systems that can maintain local control and translate communication protocols at the edge of the network.
• Technical Context: The technology at issue involves Supervisory Control and Data Acquisition (SCADA) systems used for remote monitoring and control in industries like oil and gas, where equipment is often located in areas with unreliable network connectivity.
• Key Procedural History: The complaint alleges that Defendant PakScada acquired assets from Defendant Plow related to the accused OnPing system via an Asset Purchase Agreement. Plaintiff also states it has complied with patent marking requirements by displaying its patents on its website.

Case Timeline

Date	Event
2012-01-01	Alleged invention date for the '184 Patent
2012-12-07	Earliest priority date for U.S. Patent No. 12,321,184
2025-06-03	U.S. Patent No. 12,321,184 issues
2025-06-06	Complaint filed

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

U.S. Patent No. 12,321,184, "Remote control of fluid-handling devices," issued June 3, 2025

The Invention Explained

• Problem Addressed: The patent describes shortcomings of prior art SCADA systems used for monitoring remote fluid-handling sites (e.g., oil wells). These systems were often rendered inoperable by network failures, as complex control logic resided on a central server that required a constant connection to the field equipment (Compl. ¶37; ’184 Patent, col. 1:67-2:4). Additionally, these systems struggled with interoperability, as they required the central server to be updated with special-purpose software to communicate with the wide variety of devices in the field, each potentially using a different communication protocol (Compl. ¶¶38-39).
• The Patented Solution: The invention proposes a system architecture that "pushes program logic to the edge of the network" by using a local computing system, or "site master-controller," at the fluid-handling site (Compl. ¶40). This local system can receive high-level commands from a remote server but then manage the execution locally, translating the commands into device-specific protocols and continuing to operate and buffer data even if the connection to the central server is lost (’184 Patent, col. 11:20-31, Fig. 1). This approach aims to improve reliability and scalability by offloading protocol translation and control execution from the central server to the edge device (’184 Patent, col. 9:16-33).
• Technical Importance: This "edge computing" approach provides a technical solution for robust control and monitoring of industrial equipment in remote locations with unreliable network infrastructure, a common challenge in the oil and gas industry (Compl. ¶37).

Key Claims at a Glance

• The complaint asserts claims 1-31 (Compl. ¶50). It specifically recites independent system claim 30.
• Independent Claim 30 (System Claim) Essential Elements:
  • A system comprising a plurality of fluid handling devices and a first computing system.
  • The first computing system is communicatively coupled to the devices and stores instructions to perform a series of operations.
  • Receiving a plurality of commands, encoded in a first protocol, to control different fluid-handling devices, where the commands are responsive to user input on a remote device and are received after user authorization.
  • Determining a plurality of different target states for a device over time, wherein the first computing system is operative to maintain control of the devices in the absence of an external network connection.
  • Translating the commands into translated commands encoded in a plurality of different protocols, where the translated commands cause a local controller to drive the device to the target states.
  • Sending the translated commands to the local controllers.
  • Obtaining and storing site data in a report buffer such that the data is not lost during a network outage.
  • Sending the stored site data to a remote second computing system.
• The complaint does not explicitly reserve the right to assert dependent claims, but the general assertion of claims 1-31 encompasses them.

III. The Accused Instrumentality

Product Identification

• The "OnPing system," which is described as a "cloud SCADA platform" (Compl. ¶33). A key component of the system is the "OnPing Lumberjack," an "edge computer" or "micro server on site" (Compl. ¶¶64-65).

Functionality and Market Context

• The OnPing system is alleged to provide remote management and control of oil and gas production sites (Compl. ¶66). The system includes the Lumberjack device, which is installed at the operational site. This device allegedly polls "all field devices on a local network, archiving, and storing all the results and passing them to our remote servers" (Compl. ¶64). A network architecture diagram provided in the complaint depicts on-site equipment communicating with a Lumberjack device, which in turn connects to "OnPing Cloud Services" via a cell tower (Compl. ¶65, p. 23). The complaint alleges the system allows users to remotely control equipment, set alarms, and visualize data via a Human-Machine Interface (HMI) (Compl. ¶66).
• The complaint alleges the system is commercially significant, describing Defendants as "a leader in oil and gas production well site automation" (Compl. ¶31).

IV. Analysis of Infringement Allegations

’184 Patent Infringement Allegations

Claim Element (from Independent Claim 30)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first computing system communicatively coupled to the plurality of fluid handing devices...	The Accused System includes the OnPing Lumberjack, a "micro server on site" that polls "all field devices on a local network." A diagram shows the Lumberjack communicating with on-site equipment.	¶64, ¶65	col. 14:46-51
receiving... a plurality of commands... responsive to inputs to a command interface presented on a remote user computing device...	The OnPing system allows users to "make changes to operating set-points" and create commands like "start, stop, enable, and disable" from an HMI. A screenshot shows an HMI for controlling tank levels.	¶66, ¶67	col. 16:51-64
the plurality of commands are received after determining that a user of the remote user computing device is authorized to issue commands to the first computing system based on a user account...	The OnPing system provides a portal for users to log in and includes functionality for creating new user accounts. A screenshot from the defendant's support documentation shows a "Creating a New User" interface.	¶68	col. 17:1-5
for at least some of the plurality of commands, determining... a plurality of different target states of a given one of the fluid-handling devices over time, wherein the first computing system is operative to maintain control of the fluid handling devices in an absence of an external network connection...	The Lumberjack device allegedly runs a "batch control function" and can execute scripts at the edge. It is alleged to proceed "even in the temporary absence of a network connection," picking up where it left off when the connection is re-established.	¶69, ¶72	col. 20:64-21:3
translating... the plurality of commands into translated commands encoded in a plurality of protocols different from the first protocol...	The Lumberjack device is advertised as supporting a "Wide Range of Available Protocols" and is shown in a diagram communicating with equipment from "various manufacturers," which allegedly requires translating commands into the necessary protocols (e.g., Modbus).	¶70	col. 17:12-22
sending, with the first computing system, the translated commands to the local controllers;	The Lumberjack device is alleged to communicate with on-site equipment from various manufacturers, which "necessarily involves sending translated commands to the local controllers (e.g., VFDs) of the various equipment."	¶71	col. 17:23-24
obtaining, with the first computing system, site data and storing the site data in a report buffer... such that the site data in the report buffer is not lost in the absence of the network connection...	The Lumberjack device is alleged to sit on-site, "polling all field devices on a local network, archiving, and storing all the results." This allegedly occurs "even in the temporary absence of a network connection."	¶72	col. 17:25-32
sending, with the first computing system, the site data stored in the report buffer to a remote second computing system.	The Lumberjack device is alleged to pass its archived and stored results "to our remote servers" after a network connection is re-established. The "remote second computing system" is identified as the "OnPing Cloud Services."	¶73	col. 17:33-35

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the accused "OnPing Lumberjack" and its associated software constitute the "first computing system" as claimed. Defendants could argue that the patent's detailed description of a "site master-controller" with specific modules (e.g., "protocol multiplexer", "command translator") limits the scope of this term in a way the accused product does not meet.
  • Technical Questions: The complaint's allegations for the "translating" and "maintain control" limitations rely heavily on marketing statements and high-level diagrams. A key technical question will be what evidentiary proof demonstrates that the Lumberjack device actually performs multi-protocol translation and autonomous control during network outages in the specific manner required by the claim language, rather than through some other technical means. For example, does the accused system's alleged offline capability meet the specific requirements of obtaining and storing data in a "report buffer" that is later sent to a remote server, as claimed?

V. Key Claim Terms for Construction

• The Term: "first computing system"

• Context and Importance: This term defines the "edge" device that is the cornerstone of the invention's architecture. The infringement analysis depends on whether the accused OnPing Lumberjack falls within the scope of this term. Practitioners may focus on this term because its construction will determine whether the patent reads on a general-purpose edge computer or is limited to a more specific architecture disclosed in the embodiments.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim itself uses the general term "first computing system" without importing the more specific terms used in the detailed description. Plaintiff may argue this indicates a broader scope covering any on-site computing device that performs the recited functions.
  • Evidence for a Narrower Interpretation: The specification repeatedly and consistently refers to this component as a "site master-controller" (e.g., ’184 Patent, col. 4:29-30) and describes its structure in detail, including a "site management module 70," a "protocol multiplexer 72," and "command translators 74" (’184 Patent, Fig. 1, col. 7:51-8:13). A defendant may argue these details define the "first computing system" and limit its scope.

• The Term: "translating... the plurality of commands into translated commands encoded in a plurality of protocols different from the first protocol"

• Context and Importance: This limitation addresses the problem of interoperability and is a key inventive concept. The dispute will likely center on the degree and nature of "translation" required. Proving that the accused system performs this specific function is critical to the infringement case.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim uses the functional word "translating" without specifying the mechanism. Plaintiff may argue that any process that takes a command in a single, standardized format and converts it into multiple, different device-specific formats meets this limitation.
  • Evidence for a Narrower Interpretation: The specification provides specific examples of translation, such as converting a generic command into the "modbus RTU protocol," a "binary or analog voltage or current signal," or the "Ethernet protocol" (’184 Patent, col. 9:40-49). A defendant may argue that "translating" requires a substantive conversion between distinct, named protocols, not merely reformatting data packets.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating Defendants took active steps to encourage infringement by providing "product manuals and other technical information that cause their subscribers, customers, and other third parties to use and to operate the Accused System" in an infringing manner (Compl. ¶55).
• Willful Infringement: The complaint alleges Defendants have had knowledge of the ’184 Patent and its infringement since "at least as early as the filing of this lawsuit" and potentially earlier, if Defendants' employees accessed the patent information on Plaintiff's public-facing patent marking website (Compl. ¶¶ 60, 75). This allegation forms the basis for seeking enhanced damages.

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

1. A central issue will be one of claim construction and scope: can the term "first computing system", which is described in the patent specification as a highly structured "site master-controller," be construed broadly enough to read on the architecture of the accused "OnPing Lumberjack" edge computer?
2. A key evidentiary challenge will be one of functional proof: beyond high-level marketing materials, what technical evidence will Plaintiff provide to demonstrate that the accused OnPing system actually performs the specific functions of (a) "translating" commands into multiple, distinct protocols and (b) "maintaining control" and buffering data during a network outage, as strictly required by the language of the asserted claims?