DCT

6:22-cv-01036

Apollo Lighting Solutions Inc v. C&M Oilfield Rentals LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-01036, W.D. Tex., 10/05/2022
  • Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant C&M has principal places of business in the district, including a "Texas Location" in Odessa and a "Texas Satellite Sales/Service Facility" in Midland, and has a regular and established place of business there.
  • Core Dispute: Plaintiffs allege that Defendant’s "Crown Jewel" lighting system, designed for oil and gas rigs, infringes a patent related to crown-mounted lighting systems.
  • Technical Context: The technology concerns lighting systems for drilling rigs, which operate 24/7 and require comprehensive, safe, and efficient illumination of the entire well site.
  • Key Procedural History: The complaint notes that Defendant C&M previously filed two lawsuits against the Plaintiffs in the same court, one of which was dismissed and one of which is pending, submitting itself to the court's jurisdiction. Plaintiffs also allege providing Defendant with notice of the patent's underlying application prior to its issuance.

Case Timeline

Date Event
2016-08-31 '121 Patent Priority Date (Provisional Application filing)
2018-01-01 Alleged launch of Accused "Crown Jewel" Lighting System (approx.)
2022-06-13 Plaintiffs allegedly notified Defendant of related patent application
2022-07-19 U.S. Patent No. 11,391,121 Issued
2022-10-05 Complaint Filed

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

  • Patent Identification: U.S. Patent No. 11,391,121, Drilling Rig With Attached Lighting System And Method, issued July 19, 2022 (the "’121 Patent").

The Invention Explained

  • Problem Addressed: Prior methods for illuminating drilling sites, such as mobile light towers, were described as inadequate, creating inconsistent lighting and shadows, and requiring separate power sources like diesel engines which increase costs, pollution, and the risk of fuel spills (Compl. ¶¶10, 12; ’121 Patent, col. 1:46-54).
  • The Patented Solution: The invention is a lighting system where multiple light fixtures are attached directly to the "crown" of a drilling rig—the rig's uppermost structural component. By mounting the lights at the highest central point and on at least two sides of the crown, the system claims to provide more even, comprehensive site lighting, reduce shadows, and eliminate the need for separate ground-based light towers (’121 Patent, Abstract; col. 2:19-28). The complaint includes a visual comparing the illumination from traditional light towers to the superior site-wide illumination from a crown-mounted system (Compl. p. 4).
  • Technical Importance: This approach sought to create a systematic, integrated lighting solution for drilling rigs, improving safety and operational efficiency during nighttime hours while reducing the environmental and logistical footprint of ancillary lighting equipment (Compl. ¶¶11-12; ’121 Patent, col. 2:25-28).

Key Claims at a Glance

  • The complaint asserts direct infringement of at least independent claims 1 (a system claim) and 14 (a method claim) (’121 Patent, col. 4:9-45; Compl. ¶49).
  • Independent Claim 1 (System):
    • A lighting system for a rig comprising: a plurality of light fixtures, and a plurality of light fixture attachments;
    • wherein one or more light fixtures are attached to each light fixture attachment;
    • each light fixture attachment is separately attached to a crown of the rig; and
    • one or more of the light fixture attachments are separately attached on each of at least two sides of the crown.
  • Independent Claim 14 (Method):
    • A method of providing lighting to a drilling site comprising: attaching at least one light fixture to a light fixture attachment; and
    • separately attaching a plurality of light fixture attachments to the crown of a rig,
    • wherein the light fixture attachments are removably attached on each of at least two sides of the crown.
  • The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims" of the ’121 Patent (Compl. ¶49).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant C&M’s "Crown Jewel" lighting system and the associated methods of installing and operating it (Compl. ¶¶17, 22).

Functionality and Market Context

  • The complaint alleges the Crown Jewel system is designed to be installed on the crown of a drilling rig to illuminate a well site (Compl. ¶¶22, 24). The system is alleged to utilize a plurality of light fixtures and corresponding attachments, which are separately attached to a rail on the rig's crown on at least two sides (Compl. ¶¶27-29). A photograph provided in the complaint depicts the accused Crown Jewel system installed atop a drilling rig, providing site-wide illumination (Compl. p. 5). The complaint positions the Crown Jewel system as a direct competitor to Plaintiffs' own HALO™ product and as C&M being Plaintiffs' "biggest competitor" in this market (Compl. ¶¶20-21).

IV. Analysis of Infringement Allegations

'121 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A lighting system for a rig comprising: a plurality of light fixtures; and a plurality of light fixture attachments; The accused Crown Jewel system allegedly utilizes a "plurality of light fixtures and a plurality of light fixture attachments." A photograph depicts multiple light fixtures mounted on a rig in a "down position" (Compl. p. 6, top photo). ¶27 col. 3:46-54
wherein one or more light fixtures are attached to each light fixture attachment; The complaint alleges that in the Crown Jewel system, "[a] light fixture is attached to each light fixture attachment." ¶27 col. 3:50-54
each light fixture attachment is separately attached to a crown of the rig; C&M's system is alleged to utilize a plurality of attachments where "each light fixture attachment is separately attached to a rail of the crown of the rig." ¶28 col. 4:17-19
and one or more of the light fixture attachments are separately attached on each of at least two sides of the crown. The complaint alleges that the light fixture attachments of the Crown Jewel systems "are separately attached to the crown on each of at least two sides." This is alleged to provide lighting for more than 180 degrees, and up to 360 degrees, around the site (Compl. ¶36-37). ¶29 col. 4:20-22

Identified Points of Contention

  • Scope Questions: A central question may be the definition of "crown of the rig." The patent illustrates the crown as the top block of the derrick (’121 Patent, Fig. 1A, element 13), while the complaint alleges the accused system attaches to a "rail of the crown" (Compl. ¶28). The parties may dispute whether this "rail" is properly considered part of the "crown" as claimed.
  • Technical Questions: The meaning of "separately attached" will likely be a focus. The complaint alleges each attachment is separately attached to the crown (Compl. ¶28). The dispute may turn on the degree of physical or structural independence required to meet this limitation, and what evidence shows that the accused system's attachments meet that standard. The photographs of the accused system in a "rig down position" show multiple distinct mounting arms, which Plaintiffs may argue satisfy this element (Compl. p. 6).

V. Key Claim Terms for Construction

  • The Term: "crown of the rig"

  • Context and Importance: This term defines the location of the entire patented system. Its scope is critical because infringement requires the accused system to be attached to this specific part of the rig. Practitioners may focus on this term to determine if the "rail" where the accused system allegedly attaches (Compl. ¶28) falls within the patent's definition of the "crown."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the crown more functionally than structurally, stating the "crown block 13 remains stationary" and provides mechanical advantage for lifting (’121 Patent, col. 3:11-16). A party might argue "crown" encompasses the entire stationary top structure of the rig.
    • Evidence for a Narrower Interpretation: Figure 1A explicitly labels element 13 as the "crown block," a specific piece of equipment at the apex of the derrick 14 (’121 Patent, Fig. 1A). A party could argue the term is limited to this specific block and does not include ancillary rails or other structures.

  • The Term: "separately attached"

  • Context and Importance: This limitation appears in both asserted independent claims and describes the relationship between the fixture attachments and the crown. Its construction will be critical to determining if the accused system's mounting configuration infringes. Practitioners may focus on whether "separately" implies distinct, non-contiguous points of contact with the crown, or merely that each attachment is a distinct component.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims require "each light fixture attachment is separately attached," which could be interpreted to mean simply that the attachments are not part of a single, monolithic mounting frame before being affixed to the rig.
    • Evidence for a Narrower Interpretation: The patent's objective is to place lights on "at least two sides of the crown" to provide wide-angle illumination (’121 Patent, col. 4:20-22). This purpose suggests "separately attached" requires sufficient physical separation on the crown's perimeter to achieve the functional goal of multi-sided lighting, rather than just using multiple fasteners on one side.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges C&M actively induces infringement by its customers (Compl. ¶52). The factual basis appears to be that C&M "offers and leases the Crown Jewel lighting system for installation and operation" (Compl. ¶17), thereby providing the means and allegedly encouraging the infringing use of the system and performance of the patented method.
  • Willful Infringement: The willfulness allegation is based on alleged knowledge of the infringing activity (Compl. ¶51). The complaint alleges that C&M had knowledge of the asserted patent claims via its parent patent application "no later than June 13, 2022," approximately one month before the '121 Patent issued, through a notice letter sent to C&M's counsel (Compl. ¶47). It further alleges C&M has "actual knowledge of the '121 Patent" itself (Compl. ¶50).

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

  • A core issue will be one of definitional scope: does the term "crown of the rig," as defined and illustrated in the patent, encompass the "rail" to which the accused Crown Jewel system is allegedly attached? The outcome of this construction could be dispositive for infringement.
  • A second key question will be structural interpretation: does the accused system's use of multiple mounting points satisfy the "separately attached" limitation of the claims, particularly the requirement for attachments on "at least two sides of the crown"? The court will need to evaluate evidence of how the accused system is physically configured on a rig.
  • Finally, for the method claim (Claim 14), a central question will be one of direct liability: do C&M's alleged actions of leasing, selling, and installing the Crown Jewel system (Compl. ¶¶17-19, 32-35) constitute its own direct infringement of the method steps, or does it only support a theory of indirect infringement based on the actions of its customers?