DCT

6:24-cv-00642

SitePro Inc v. TankLogix LLC

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:24-cv-00642, W.D. Tex., 03/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in Odessa, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s industrial automation system for oil and gas facilities infringes four patents related to the remote control and monitoring of fluid-handling equipment.
  • Technical Context: The technology addresses limitations in traditional Supervisory Control and Data Acquisition (SCADA) systems by enabling resilient local control during network outages and performing protocol translation at the network edge.
  • Key Procedural History: The complaint notes that Plaintiff SitePro, Inc. was founded as AmpliSine Labs, LLC in November 2009 and underwent subsequent name changes. It also alleges that the inventor conceived of the patented subject matter as early as January 2012. No prior litigation or post-grant proceedings are mentioned in the complaint.

Case Timeline

Date Event
2009-11-XX AmpliSine Labs, LLC (Plaintiff's predecessor) founded
2012-01-XX Alleged conception date of patented inventions
2012-12-07 Earliest Priority Date for '909, '014, '680, and '504 Patents
2014-02-11 U.S. Patent No. 8,649,909 Issued
2018-02-20 U.S. Patent No. 9,898,014 Issued
2018-07-XX Plaintiff's predecessor changes name to SitePro, LLC
2019-01-01 Plaintiff's name becomes SitePro, Inc.
2021-11-16 U.S. Patent No. 11,175,680 Issued
2023-08-15 U.S. Patent No. 11,726,504 Issued
2025-03-13 Complaint Filed

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

U.S. Patent No. 8,649,909 - Remote Control of Fluid-Handling Devices

Issued February 11, 2014

The Invention Explained

  • Problem Addressed: The patent’s background section describes technical problems with prior art SCADA systems used for remote fluid-handling facilities, noting that many such systems fail when a network connection is lost and that some require installation of special-purpose software on each computer used for remote control, deterring users (Compl. ¶27; '909 Patent, col. 1:33-42).
  • The Patented Solution: The invention proposes a control system architecture comprising a central "command-center server" that communicates with multiple "geographically distributed site master controllers" located at fluid-handling sites (Compl. ¶48; '909 Patent, col. 15:5-16:51). These on-site controllers are designed to receive commands from the central server, translate them into various device-specific protocols, and implement the commands locally, allowing them to "maintain control of the fluid handling devices in the absence of a network connection to the command-center server" ('909 Patent, col. 16:6-9). The site master-controller can also buffer sensor data and alarms for later transmission to the central server when network connectivity is restored (Compl. ¶31; '909 Patent, col. 10:39-50).
  • Technical Importance: This distributed architecture is presented as a solution to improve the resiliency and scalability of remote industrial control systems, particularly in locations with unreliable network infrastructure (Compl. ¶¶30, 33).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 (Compl. ¶41, ¶48).
  • Essential Elements of Independent Claim 1:
    • A system for remotely controlling fluid-handling devices at facilities such as oil wells.
    • A "command-center server" with a data store for multiple user accounts, where each account corresponds to a set of facilities operated by a different entity.
    • A plurality of "geographically distributed site master controllers," each corresponding to a facility.
    • Each site master controller comprises a communication module, network interface, memory, and processors configured to perform steps.
    • The steps include: receiving commands in a "first protocol" from the server; for some commands, determining different target states over time while being operative to maintain control without a network connection; "translating" the commands into a "plurality of protocols different from the first protocol" suitable for the specific fluid-handling device; and sending the translated commands to local controllers of the devices.
  • The complaint reserves the right to assert claims 2-21 (Compl. ¶41).

U.S. Patent No. 9,898,014 - Remote Control of Fluid-Handling Devices

Issued February 20, 2018

The Invention Explained

  • Problem Addressed: Stemming from the same patent family as the '909 Patent, this patent addresses the same background problems of SCADA systems failing during network outages and lacking native interoperability, which complicates scaling (Compl. ¶¶27-29; '014 Patent, col. 1:44-53).
  • The Patented Solution: The invention is a "hosted, web-based, remote industrial monitoring and control system" that stores data for a "plurality of accounts," where each account corresponds to a different entity operating different facilities ('014 Patent, col. 15:37-46). The system uses facility-interface modules to communicate with sensors and actuators via cellular networks and a web-interface module to present control interfaces to users in web browsers ('014 Patent, col. 15:47-57). The system is configured to manage user permissions, granting distinct rights for remote control and data viewing to different user accounts associated with different groups of facilities ('014 Patent, col. 16:1-32).
  • Technical Importance: This invention provides a framework for a multi-tenant Software-as-a-Service (SaaS) platform for industrial control, allowing a single hosted system to securely serve multiple, distinct customer organizations with segregated access to their respective field assets (Compl. ¶13).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 (Compl. ¶65, ¶72).
  • Essential Elements of Independent Claim 1:
    • A hosted, web-based remote industrial monitoring and control system.
    • A computer-implemented datastore storing a plurality of accounts for different entities and network addresses for equipment accessible via "cellular network connections."
    • A computer-implemented "facility-interface module" to get data from sensors and send commands to actuators.
    • A computer-implemented "web-interface module" to present control interfaces in users' web browsers.
    • The system is configured to receive a user command, identify the corresponding facility's network address, and send instructions to actuate the device.
    • The plurality of accounts includes at least a first, second, third, and fourth account with specific permissions: the first account is authorized to control a first group of facilities; the second to control a different, second group; the third to view reports from the first group; and the fourth to view reports from the second group.
  • The complaint reserves the right to assert claims 2-23 (Compl. ¶65).

U.S. Patent No. 11,175,680 - Remote Control of Fluid-Handling Devices

Issued November 16, 2021

  • Technology Synopsis: This patent, from the same family, claims a non-transitory, machine-readable medium with instructions for a server and a remote controller to interact. The server receives a command associated with a record, determines a network address for a controller from that record, and sends a target value; the controller then receives sensor measurements, determines if the target is satisfied, and controls an actuator based on a set point derived from the command (Compl. ¶97; '680 Patent, col. 16:1-57).
  • Asserted Claims: Claims 1-20 (Compl. ¶90).
  • Accused Features: The complaint alleges infringement by the Accused System's cloud-based infrastructure, which hosts the Ignition platform (the non-transitory medium) that executes instructions for the server to receive commands from clients and for on-site controllers (PLCs) to control field devices based on those commands (Compl. ¶¶100-108).

U.S. Patent No. 11,726,504 - Remote Control of Fluid-Handling Devices

Issued August 15, 2023

  • Technology Synopsis: This patent claims a fluid processing system comprising a "first computer system" at a fluid handling site and a remote "server system." The on-site system provides remote control capabilities. The server system receives fluid property data from the on-site system, obtains credentials from a client computing device, and determines if the user is authorized to interact with that specific site while hosting data for other sites the user is not authorized to access (Compl. ¶120; '504 Patent, col. 16:52-17:28).
  • Asserted Claims: Claims 1-20 (Compl. ¶113).
  • Accused Features: The complaint alleges the Accused System infringes with its on-site PLCs (the "first computer system") and its hosted Ignition server (the "server system"), which manages access for different customer organizations to their respective, segregated field sites (Compl. ¶¶123, 126, 129).

III. The Accused Instrumentality

Product Identification

The "Ignition-Hosted Automation System" ("the Accused System") offered by Defendant TankLogix (Compl. ¶22).

Functionality and Market Context

The complaint alleges the Accused System is a "Comprehensive Hosted SCADA" service powered by Inductive Automation's "Ignition platform" (Compl. ¶23). It is described as a cloud-based system that allows customers to connect with, collect data from, and control field devices over a secure network (Compl. ¶¶23, 51). The system allegedly comprises a central command center server and "geographically distributed site master controllers," which the complaint identifies as on-site PLCs (Programmable Logic Controllers) or RTUs (Remote Terminal Units) (Compl. ¶53). These on-site controllers are alleged to communicate with a plurality of fluid-handling devices, such as tanks and VFDs (Variable Frequency Drives) (Compl. ¶¶54, 60). The system provides access to multiple customer organizations (different entities) who can manage multiple user accounts with role-based security (Compl. ¶¶52, 81). The complaint includes an architectural diagram from the Ignition platform's user manual that depicts an "Ignition Server" communicating over a network with edge devices like PLCs/RTUs, which in turn connect to field equipment (Compl. ¶53, p. 19).

IV. Analysis of Infringement Allegations

8,649,909 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a command-center server having a data store storing multiple user accounts, each user account corresponding to a set of one or more oil wells...each set being operated by a different entity... The Accused System's "Hosted Ignition products comprise a command center server" that provides access to different customer organizations (entities) to monitor their respective field devices. ¶51-52 col. 3:13-14
a plurality of geographically distributed site master controllers... The Accused System utilizes on-site PLCs or RTUs, which are identified as the "geographically distributed site master controller[s]." ¶53 col. 3:15-16
[the site master controller] receiving...from the command-center server, a plurality of commands encoded in a first protocol... The system creates displays and controls, allowing a user to "manage your entire system from one place," which implies commands are sent from the server to the on-site controllers. ¶58 col. 10:27-30
...wherein the respective site-master controller is operative to maintain control of the fluid handling devices in the absence of a network connection to the command-center server... The complaint alleges on information and belief that the system's PID controllers and VFDs determine target states, implying local control is maintained. ¶59 col. 5:10-15
translating the plurality of commands into translated commands encoded in a plurality of protocols different from the first protocol... On information and belief, the Accused System is configured to translate commands from the server (e.g., in TCP/IP) into a variety of protocols (e.g., digital or analog outputs) understood by the fluid-handling devices. ¶60 col. 8:57-9:7
sending the translated commands to respective local controllers of the respective fluid-handling devices... The PLCs receive commands and send them "to the fluid-handling devices to which the respective commands are directed via the appropriate protocol." ¶60 col. 10:39-41

Identified Points of Contention

  • Scope Questions: A central question may be whether a third-party PLC/RTU running generally available software (Ignition) meets the definition of the claimed "site master controller," which the patent specification describes with specific internal structures like a "protocol multiplexer" and "command translators" ('909 Patent, Fig. 1). The analysis may turn on whether these detailed structures are read into the claim as limitations.
  • Technical Questions: The complaint alleges the Accused System maintains control during network outages (Compl. ¶59), a key feature of the claim. The basis for this allegation appears to be "information and belief" regarding the functionality of certain components. A key factual question will be what evidence demonstrates that the accused PLCs are, in fact, configured to and do operate autonomously to complete command sequences after losing connection to the central server.

9,898,014 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A hosted, web-based, remote industrial monitoring and control system... The Accused System is described as a "Comprehensive Hosted SCADA" service that is "hosted on our cloud-based infrastructure" and provides remote control. ¶74, ¶51 col. 15:37-39
a computer-implemented datastore storing: a plurality of accounts, each account corresponding to an entity operating one or more...oil or gas facilities... TankLogix's Hosted Ignition products allegedly provide access to different customer organizations (entities) to monitor their facilities, and each can manage multiple user accounts. ¶76, ¶81 col. 15:40-43
network addresses by which industrial monitoring or control equipment at the facilities is accessible via cellular network connections... Defendant's marketing materials state that its system uses "Cellular and satellite communication for even the most remote locations." ¶77 col. 15:47-49
a computer-implemented web-interface module or modules configured to send instructions to present control interfaces in web browsers... The Accused System allegedly uses "Web-Launched Ignition Clients" and web technologies to present control interfaces to users. ¶79, ¶31 col. 15:53-57
the plurality of accounts include a first account, a second account, a third account, and a fourth account... The Accused System is alleged to provide access to different customer organizations, each with the ability to manage multiple user accounts via unlimited clients, which includes the specified accounts. ¶81 col. 16:1-3
the first account...authorized to send commands to remotely control...a first group...; the second account...to remotely control...a second group... The Accused System offers "Remote control" functionality to its users, who are organized into different entities corresponding to different groups of facilities. ¶82-83 col. 16:4-14
the third account...authorized to view reports...at the first group...; the fourth account...to view reports...at the second group... The Accused System provides "Realtime & historical data views" and allows users to choose what data reports contain, which are available to users associated with distinct groups of facilities. ¶84-85 col. 16:15-24

Identified Points of Contention

  • Scope Questions: Claim 1 requires a specific, four-part account structure (control/group1, control/group2, view/group1, view/group2). The complaint points to general "Users & Security" and "Reports" features in the Accused System (Compl. ¶81, p. 41). A point of contention may be whether the Accused System’s "role based approach to security" necessarily implements this specific four-part permission structure across different customer entities, or if its functionality is more generic and does not meet this precise claim limitation.
  • Technical Questions: The claim explicitly recites accessibility via "cellular network connections." The infringement allegation relies on marketing materials advertising this capability (Compl. ¶77). The factual analysis will question whether the accused system as sold and operated actually uses cellular connections for the specific data and command pathways recited in the claim, or if other network types are used.

V. Key Claim Terms for Construction

Term: "site master controller" ('909 Patent, Claim 1)

  • Context and Importance: This term is the lynchpin of the '909 Patent's distributed architecture. The infringement case hinges on whether Defendant's on-site PLCs/RTUs (Compl. ¶53) fall within the scope of this term. Practitioners may focus on this term because Defendant is likely to argue its third-party hardware does not meet the definition of the specialized controller described in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself defines the "site master controller" functionally, as comprising a "communication module," "network interface," "memory," and "one or more processors" that execute a series of steps (receiving, determining, translating, sending) ('909 Patent, col. 15:41-16:51). Plaintiff may argue that any device performing these functions infringes.
    • Evidence for a Narrower Interpretation: The specification describes the "site master-controller" with a specific combination of internal components, including a "site management module 70," a "protocol multiplexer 72," and distinct "command translators 74" ('909 Patent, col. 7:14-19 and Fig. 1). A defendant may argue that these detailed structures are essential to the invention and limit the claim's scope.

Term: "translating" ('909 Patent, Claim 1)

  • Context and Importance: This term captures the "protocol translation at the edge" concept, which Plaintiff identifies as a key invention (Compl. ¶34). The dispute will likely involve whether the Accused System's PLCs perform an operation that qualifies as "translating" commands from a server-side protocol into multiple, different field-side protocols.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires translating commands from a "first protocol" into a "plurality of protocols different from the first protocol" ('909 Patent, col. 16:10-17). Plaintiff may argue this covers any conversion from a single network protocol (like TCP/IP) into the various protocols used by field devices (like Modbus, analog signals, etc.).
    • Evidence for a Narrower Interpretation: The specification describes the "protocol multiplexer 72" selecting among specific "command translators 74" which correspond to different protocols for different control buses ('909 Patent, col. 8:57-9:23). A defendant could argue that "translating" requires this specific multiplexer-and-translator architecture, not just a generic protocol gateway function.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement by providing "product manuals and other technical information" that instruct and encourage customers to use the Accused System in an infringing manner (Compl. ¶¶45, 69, 94, 117). The complaint also alleges contributory infringement, stating the Accused System is especially made or adapted for infringement and is not a staple article of commerce (Compl. ¶¶46, 70, 95, 118).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's knowledge of the patents since at least the filing and service of the complaint. It also raises the possibility of pre-suit knowledge based on the allegation that Defendant's employees may have accessed the patent information on Plaintiff's public-facing website (Compl. ¶¶47, 71, 96, 119).

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

  • A core issue will be one of definitional scope: Will the term "site master controller," which is described in the patent specification with a detailed internal architecture, be construed broadly enough to encompass the accused system's alleged use of third-party Programmable Logic Controllers (PLCs) running general-purpose industrial software?
  • A key evidentiary question will be one of operational reality vs. marketing claims: The complaint relies significantly on high-level architectural diagrams and marketing materials from Defendant and its software provider. The case may turn on whether discovery produces evidence that the Accused System, as actually configured and used by customers, performs the specific functions required by the claims, such as maintaining local control during a network outage and performing the multi-protocol translation from a single server-side protocol.
  • A third central question will be one of structural correspondence: Does the accused system’s "role based approach to security" for managing different clients implement the specific, four-part permission structure (separating control and viewing rights for two distinct groups of facilities) as explicitly required by claim 1 of the '014 patent, or is there a fundamental mismatch in its security architecture?