DCT

4:25-cv-00781

Wrights IP Holdings LLC v. Trendsetter Engineering Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00781, S.D. Tex., 02/21/2025
  • Venue Allegations: Venue is asserted based on Defendant having a regular and established place of business in the district and having allegedly committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s subsea intervention systems infringe five patents related to systems for deepwater well stimulation and for clearing hydrate blockages in subsea pipelines.
  • Technical Context: The technology concerns specialized equipment for servicing deepwater oil and gas wells, a technically complex and high-value segment of the offshore energy industry.
  • Key Procedural History: The complaint notes that documents detailing the configuration of the accused Hydrate Remediation Unit were made public during a prior, unrelated lawsuit between Defendant and a third party regarding inventorship of a different patent.

Case Timeline

Date Event
2009-12-24 Earliest Priority Date for Hydrate Patents (’185, ’238)
2012-12-05 Earliest Priority Date for Stimulation Patents (’808, ’942, ’934)
2016-01-01 Defendant began offering the Trident Modular Intervention System (on or before this date)
2016-03-15 U.S. Patent No. 9,284,808 Issued
2016-09-06 U.S. Patent No. 9,435,185 Issued
2018-08-21 U.S. Patent No. 10,053,942 Issued
2018-12-25 U.S. Patent No. 10,161,238 Issued
2020-06-23 U.S. Patent No. 10,689,934 Issued
2025-02-21 Complaint Filed

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

U.S. Patent No. 10,053,942 - CHEMICAL DEEPWATER STIMULATION SYSTEMS AND METHODS, issued August 21, 2018

The Invention Explained

  • Problem Addressed: Conventional methods for servicing subsea wells require different, large-scale equipment for chemical stimulation (like acid injection) versus other interventions (like wireline operations). The patent states that switching between these operations causes significant downtime and requires replacing equipment on the sea floor, which is inefficient and costly (’942 Patent, col. 1:40-59).
  • The Patented Solution: The invention is a modular subsea system with a central conduit featuring two flow control devices (e.g., valves) that create a double barrier. Above and below this barrier are upper and lower connector assemblies. This configuration allows one set of operations, such as chemical stimulation, to be performed through one connector assembly while a different operation, such as preparing for wireline access through a blowout preventer, can be set up or performed through the other, either sequentially or simultaneously, without repositioning the entire system (’942 Patent, Abstract; col. 2:51-65). Figure 1 of the patent illustrates the overall assembly with its distinct upper and lower sections.
  • Technical Importance: The described system aims to reduce the operational downtime and eliminate the need for rig-based installation procedures typically associated with multi-stage subsea well interventions (’942 Patent, col. 2:5-9).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-4 and 11-12 (Compl. ¶18).
  • The essential elements of independent claim 1 include:
    • A conduit with an upper and lower section.
    • A first flow control device between the sections.
    • A second flow control device beneath the first.
    • An upper connector assembly with:
      • a first flow cross member enabling fluid flow in at least two directions;
      • a first connector for a chemical stimulation device;
      • a top connector for a blowout preventer or well intervention apparatus.
    • A final functional limitation wherein the conduit, the first passage, and the top passage can remain open at the same time to perform simultaneous or combined operations.
  • The complaint reserves the right to assert additional claims (Compl. ¶18).

U.S. Patent No. 10,161,238 - SUBSEA TECHNIQUE FOR PROMOTING FLUID FLOW, issued December 25, 2018

The Invention Explained

  • Problem Addressed: The flow of oil and gas through subsea pipelines, especially in low-temperature, high-pressure deepwater environments, can lead to the formation of solid gas hydrates, which crystallize and create blockages that impede or stop fluid flow (’238 Patent, col. 2:1-12).
  • The Patented Solution: The patent describes a subsea system for clearing these blockages. It comprises a pump, a motor, and a subsea separator. The pump is configured to decrease the pressure in the blocked pipeline, which draws the blockage and surrounding fluid into the separator. The separator then vents gas from the fluid, allowing the now-separated, denser fluid to be pumped to the surface (’238 Patent, Abstract; col. 10:9-22). The system is designed to be powered by a fluid, like seawater, that can be discharged into the ambient environment, eliminating the need for a hydraulic return line to the surface (’238 Patent, col. 3:41-51).
  • Technical Importance: This technology provides a method for remediating pipeline blockages directly on the seafloor, which can be more efficient than methods that rely on pumping large quantities of chemicals like methanol from the surface to dissolve hydrates (’238 Patent, col. 2:5-12).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶31).
  • The essential elements of independent claim 10 include:
    • A pump configured to pump fluid.
    • A separator in fluid communication with the pump via a first fluid conduit.
    • A pipeline conduit connecting the separator to a subsea fluid source (e.g., a blocked pipeline).
    • The pump is configured to decrease pressure to act on or remove the blockage.
    • The separator receives the fluid and separates or vents gas from it to form a separated fluid.
    • The pump moves the separated fluid to the surface through a second fluid conduit.
  • The complaint reserves the right to assert additional claims (Compl. ¶31).

U.S. Patent No. 9,284,808 - CHEMICAL DEEPWATER STIMULATION SYSTEMS AND METHODS

  • Patent Identification: U.S. Patent No. 9,284,808, issued March 15, 2016 (Compl. ¶6).
  • Technology Synopsis: This patent, a parent to the ’942 patent, similarly discloses a subsea system designed to minimize downtime during well interventions. It describes a conduit with at least two flow control devices and upper and lower connector assemblies, enabling different operations to be performed without reconfiguring the primary equipment (’808 Patent, Abstract).
  • Asserted Claims: Claims 1-2, 5, and 7-8 (Compl. ¶18).
  • Accused Features: The accused features are the same components of the Trident Systems as those accused of infringing the ’942 patent (Compl. ¶15, 21).

U.S. Patent No. 10,689,934 - CHEMICAL DEEPWATER STIMULATION SYSTEMS AND METHODS

  • Patent Identification: U.S. Patent No. 10,689,934, issued June 23, 2020 (Compl. ¶8).
  • Technology Synopsis: This patent, also in the same family as the ’942 patent, describes a modular subsea intervention system. It focuses on the combination of flow control devices and multiple connector assemblies (upper and lower) that permit simultaneous or independent well operations, such as chemical stimulation and wireline access (’934 Patent, Abstract).
  • Asserted Claims: Claims 1-4 and 11 (Compl. ¶18).
  • Accused Features: The accused features are the same components of the Trident Systems as those accused of infringing the ’942 patent (Compl. ¶15, 21).

U.S. Patent No. 9,435,185 - SUBSEA TECHNIQUE FOR PROMOTING FLUID FLOW

  • Patent Identification: U.S. Patent No. 9,435,185, issued September 6, 2016 (Compl. ¶10).
  • Technology Synopsis: This patent, a parent to the ’238 patent, describes a method and system for clearing subsea pipeline blockages. It discloses using a subsea prime mover (e.g., a drilling motor) coupled to a pump and separator, powered by a fluid like seawater, to depressurize a pipeline and remediate hydrate plugs (’185 Patent, Abstract).
  • Asserted Claims: Claims 4, 6-7, and 9 (Compl. ¶31).
  • Accused Features: The accused features are components of Defendant's Hydrate Remediation Unit, alleged to be part of the broader STIM system, which are accused of infringing the ’238 patent (Compl. ¶26, 30, 41).

III. The Accused Instrumentality

Product Identification

  • The complaint names two categories of accused instrumentalities:
    1. The Trident Modular Intervention System, which is marketed in three variations: the Hydraulic Intervention System, the Riserless Light Well Intervention System, and the Open-Water Intervention Riser System (collectively, "Trident Systems") (Compl. ¶19).
    2. The Hydrate Remediation Unit, which is identified as a subtype or configuration of Defendant's STIM (Subsea Tree Injection Manifold) system (Compl. ¶26, 41).

Functionality and Market Context

  • The Trident Systems are described as "subsea well intervention systems... designed from the tree interface up to provide a cost effective and operationally robust solution" for well intervention needs (Compl. ¶21, p.6).
  • The Hydrate Remediation Unit is alleged to be a system for acting on or removing blockages from subsea fluid sources using a motor, pump, and separator to depressurize pipelines (Compl. ¶23). The complaint alleges that public documents from a prior, unrelated legal dispute provide technical details on the configuration and use of this unit, including schematics and operating procedures (Compl. ¶27-28). The complaint provides an annotated diagram from a 2024 trade show advertisement showing the Trident System's key components (Compl. ¶20, p.6).

IV. Analysis of Infringement Allegations

10,053,942 Infringement Allegations

The complaint includes an annotated drawing from a trade show exhibit, which identifies components of the accused Trident System that allegedly correspond to elements of claim 1 (Compl. ¶21, p.6).

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a conduit having an upper section and a lower section; The accused system contains a central conduit with distinct upper and lower sections. ¶21, p.6 col. 4:19-21
a first flow control device positioned between the upper section and the lower section; The accused system has a first flow control device located between the conduit’s upper and lower sections. ¶21, p.6 col. 4:29-34
a second flow control device positioned beneath the first control device... The accused system has a second flow control device located below the first, also between the conduit sections. ¶21, p.6 col. 2:22-26
an upper connector assembly engaged with the upper section... The accused system has an upper connector assembly connected to the upper conduit section. ¶21, p.7 col. 4:38-44
a first flow cross member in fluid communication with the first flow control device via the conduit, wherein the first flow cross member enables fluid flow in at least two directions; The accused system's upper connector assembly includes a "crossover" valve identified as the first flow cross member, allowing multi-directional flow. ¶21, p.7 col. 4:40-42
a first connector connected to a chemical stimulation device and having a first passage into the first flow cross member; The accused system includes a side connector for connecting to a chemical stimulation device. ¶21, p.7 col. 4:45-51
a top connector connected to a blowout preventer, a well intervention apparatus, or combinations thereof... The accused system has a top connector for engaging equipment like a blowout preventer. ¶21, p.7 col. 4:42-45
wherein the conduit, the first passage and the top passage are operable to remain open at the same to time to perform simultaneous or combined operations... The complaint alleges that because the accused device is structurally equivalent, it "inherently enables the same simultaneous operational capability." ¶21, p.7 col. 2:65-col. 3:2
  • Identified Points of Contention:
    • Functional Questions: A central dispute may concern the final "wherein" clause of claim 1. The complaint’s allegation of infringement is based on an assertion that the system's structural equivalence "inherently enables" the claimed simultaneous operations. A key question for the court will be whether the accused Trident Systems are in fact used or are capable of being used to perform the claimed simultaneous or combined operations, as opposed to merely possessing a structure that might theoretically allow for it.

10,161,238 Infringement Allegations

The complaint provides an annotated schematic, which it identifies as a "Flowline Hydrate Remediation System P&ID" made public in a prior litigation, to map claim elements to the accused system (Compl. ¶27, 32, p.11).

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
a pump configured to pump fluid; The accused system includes a subsea pump. ¶32, p.11 col. 2:18-24
a separator in fluid communication with the pump, wherein the separator is connected to the pump with a first fluid conduit; The accused system includes a component identified as a separator, which is connected to the pump. ¶32, p.11 col. 3:45-51
a pipeline conduit connecting the separator with a subsea fluid source consisting of a pipeline... The accused system connects to subsea fluid sources such as pipeline end terminators. ¶32, p.11 col. 10:11-14
wherein the pump is configured to decrease pressure... to act on or remove the blockage to result in a flow or an increased flow of the fluid... The accused system is alleged to create a "low pressure environment" to recover liquid and gas from a blocked flowline. ¶32, p.12 col. 10:14-19
wherein the separator receives the fluid... and separates or vents gas from the fluid... to form a separated fluid... The accused system's separator, which allegedly contains an internal baffle, receives the fluid and separates gas. ¶32, p.12 col. 10:19-22
wherein the pump moves the separated fluid to the surface of the body of water through a second fluid conduit. The pump in the accused system moves the separated fluid toward the surface via a second conduit. ¶32, p.12 col. 10:21-22
  • Identified Points of Contention:
    • Scope Questions: The complaint alleges that a "manifold of the type described in the '785 patent and Exhibits J-L can function as a separator" (Compl. ¶29). A primary point of contention will likely be whether the accused manifold assembly constitutes a "separator" as that term is used in the patent. The defense may argue that a "separator" is a specific type of device, distinct from a manifold, and that the accused product lacks this claimed element.
    • Technical Questions: Evidence will be required to demonstrate that the accused manifold, when used for hydrate remediation, actually "separates or vents gas" to form a "separated fluid" as required by the claim, rather than simply routing a multiphase fluid mixture.

V. Key Claim Terms for Construction

For the ’942 Patent

  • The Term: "simultaneous or combined operations" (Claim 1)
  • Context and Importance: This term is central to the patent's purported solution to the problem of operational downtime. The infringement analysis will depend on whether the accused Trident Systems are found to perform operations that meet the definition of "simultaneous or combined."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a scenario where "the bottom section of the system could be used for well stimulation while the top section is used for other well operations, simultaneously or in combination therewith" (’942 Patent, col. 2:65-col. 3:2). This could support an interpretation covering any two different well-related tasks occurring at the same time using the upper and lower sections.
    • Evidence for a Narrower Interpretation: A defendant could argue that the term requires two active, independent intervention processes to be fully underway at the exact same time, as opposed to one section being used while the other is merely being prepared or standing by. The specification's examples involve specific pairings like stimulation and blowout preventer use, which might be argued to limit the scope of covered operations (’942 Patent, col. 5:11-17).

For the ’238 Patent

  • The Term: "separator" (Claim 10)
  • Context and Importance: The presence of a "separator" is a core structural element of the claimed invention. The plaintiff's case hinges on its assertion that a manifold in the accused system can function as this "separator." Practitioners may focus on this term because the accused product may not have a component explicitly named a "separator."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plaintiff may argue for a functional definition, where any component that "separates or vents gas from the fluid" meets the limitation, regardless of its name or other functions. The claims themselves define the separator by its function (’238 Patent, col. 10:19-22).
    • Evidence for a Narrower Interpretation: The patent's detailed description consistently refers to a "separator means 20" and depicts it in figures (e.g., Fig. 1, Fig. 7) as a distinct, standalone vessel with specific inlets, outlets, and internal components like baffles and a ball valve assembly (’238 Patent, col. 12:2-10). This could support a narrower construction requiring a dedicated separation vessel, not a multi-purpose manifold.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement by providing its systems to customers in Texas and elsewhere, and that the systems have no substantial non-infringing use (Compl. ¶36-37, ¶42-43). The basis for inducement for the Stimulation Patents is alleged use by customers (Compl. ¶36). For the Hydrate Patents, inducement is alleged based on offering infringing services and configurations of its STIM system (Compl. ¶41-42).
  • Willful Infringement: Willfulness is alleged for both patent families "upon information and belief" (Compl. ¶38, ¶44). The complaint does not explicitly allege pre-suit knowledge via a notice letter. However, it does allege that technical documents for the accused Hydrate Remediation Unit were made public during prior litigation involving the Defendant, which could be presented as evidence of knowledge regarding the technology at issue (Compl. ¶27).

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

This case presents two central disputes, each tied to a different family of asserted patents:

  1. A core issue for the Stimulation Patents will be one of functional performance: Does the accused Trident System actually perform, or is it used to perform, the "simultaneous or combined operations" required by the claims? The court will need to determine whether the mere structural capability for such operations is sufficient for infringement, or if evidence of actual simultaneous use is required.
  2. A key question for the Hydrate Patents will be one of definitional scope and technical identity: Can the accused system's manifold assembly be legally and technically construed as the "separator" recited in the claims? The resolution will likely depend on whether the court adopts a broad, functional definition of the term or a narrower, structural one based on the patent's specific embodiments.