DCT
6:24-cv-00643
SitePro Inc v. TankLogix LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SitePro, Inc. (Delaware)
- Defendant: TankLogix, LLC (Utah)
- Plaintiff’s Counsel: Perkins Coie LLP
- Case Identification: 6:24-cv-00643, W.D. Tex., 03/13/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has committed acts of infringement in the district and maintains a regular and established place of business in Odessa, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Ignition-Hosted Automation System for industrial monitoring infringes four patents related to the remote control of fluid-handling devices.
- Technical Context: The technology relates to Supervisory Control and Data Acquisition (SCADA) systems used for remote monitoring and control of equipment in the oil and gas, municipal, and agricultural industries.
- Key Procedural History: The complaint alleges that Plaintiff complies with statutory marking requirements by publicly listing the asserted patents on its corporate website.
Case Timeline
| Date | Event |
|---|---|
| 2012-12-07 | Earliest Priority Date for ’078, ’871, ’403, and ’461 Patents |
| 2016-05-17 | U.S. Patent No. 9,342,078 Issues |
| 2019-11-26 | U.S. Patent No. 10,488,871 Issues |
| 2022-04-05 | U.S. Patent No. 11,294,403 Issues |
| 2024-06-25 | U.S. Patent No. 12,019,461 Issues |
| 2025-03-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,342,078 - "Remote control of fluid-handling devices"
Issued May 17, 2016 (the "’078 Patent")
The Invention Explained
- Problem Addressed: The patent’s background section describes technical problems with prior art SCADA systems used to remotely control geographically dispersed fluid-handling equipment. These systems would often fail if their network connection to a central station was lost, and they required the installation of special-purpose software on user computers, which hindered scalability and ease of use (Compl. ¶27; ’078 Patent, col. 1:42-50). Additionally, the variety of communication protocols used by different field devices created integration challenges (Compl. ¶29).
- The Patented Solution: The invention proposes a method and system where a local "site master-controller" at a fluid-handling site receives commands from a remote server but can execute them to completion even if the network connection is lost (Compl. ¶¶30-31; ’078 Patent, col. 5:10-19). A key aspect of the solution is performing protocol translation at the edge of the network. The system receives user instructions in a "shared protocol" and the local controller translates them into various different protocols (e.g., Modbus, analog electrical signals) required by the specific fluid-handling devices at the site (Compl. ¶¶34-37; ’078 Patent, col. 8:48-9:14).
- Technical Importance: This architecture was designed to improve the reliability of industrial control systems in the event of network outages and to simplify the integration of diverse equipment from multiple vendors (Compl. ¶33).
Key Claims at a Glance
- The complaint asserts claims 1-9, 11-13, and 15-19, with a focus on independent claim 1 (Compl. ¶¶41, 48).
- Essential elements of independent claim 1, a method, include:
- Receiving, via a network interface, user-directed instructions encoded in a shared protocol to control fluid-handling devices.
- Obtaining a target state for a device, which includes determining a plurality of different target states corresponding to different times.
- For each instruction, selecting a respective protocol from a plurality of protocols that are different from the shared protocol, where the target device is responsive to the selected protocol.
- Translating the received instructions into the selected respective protocol, with the translated instructions including the determined target states.
- Sending the translated instructions to the fluid-handling device to cause it to attempt to achieve the target state.
- The complaint does not explicitly reserve the right to assert dependent claims but asserts several ranges of them (Compl. ¶41).
U.S. Patent No. 10,488,871 - "Remote control of fluid-handling devices"
Issued November 26, 2019 (the "’871 Patent")
The Invention Explained
- Problem Addressed: The common specification shared with the ’078 Patent notes the deficiencies of prior SCADA systems, including their unreliability during network outages and difficulties in scaling due to software and hardware interoperability issues (Compl. ¶¶27-29; ’871 Patent, col. 1:50-69). The solution claimed in the ’871 Patent specifically addresses the need for a multi-tenant architecture to securely manage multiple distinct customers and their respective facilities on a single, hosted platform.
- The Patented Solution: The invention describes a hosted, networked method for industrial monitoring that stores records for multiple accounts, with each account corresponding to an entity that operates one or more facilities (’871 Patent, col. 4:25-44). The system provides user interfaces for remote control and is configured to manage permissions across these accounts. The claims explicitly detail a structure of at least four account types with different permissions: two accounts authorized to control devices at two different groups of facilities, and two accounts authorized only to view data reports from those respective facility groups (Compl. ¶68; ’871 Patent, col. 17:5-34).
- Technical Importance: This invention provides a technical framework for a scalable and secure multi-tenant Software-as-a-Service (SaaS) platform for industrial control, enabling a single provider to serve numerous, distinct customer entities with role-based access control to sensitive industrial equipment (Compl. ¶13).
Key Claims at a Glance
- The complaint asserts claims 18-34, with a focus on independent claim 18 (Compl. ¶¶61, 68).
- Essential elements of independent claim 18, a method, include:
- Storing records comprising a plurality of accounts, each corresponding to an entity operating fluid-handling facilities.
- Storing addresses for industrial equipment (sensors, actuators) at those facilities.
- Obtaining data from sensors and sending commands to actuators via a "facility-interface module."
- Sending instructions to present control interfaces on user devices logged into respective accounts via a "user-interface module."
- Receiving a user command to actuate a device, identifying the facility address, and sending instructions to the facility to actuate the device.
- The method requires that the plurality of accounts include a specific four-part structure: a first account for controlling a first group of facilities; a second account for controlling a second, different group of facilities; a third account for viewing data from the first group; and a fourth account for viewing data from the second group.
- The complaint does not explicitly reserve the right to assert dependent claims but asserts a range of them (Compl. ¶61).
Multi-Patent Capsule: U.S. Patent No. 11,294,403
- Patent Identification: U.S. Patent No. 11,294,403 ("’403 Patent"), "Remote control of fluid-handling devices", Issued April 5, 2022 (Compl. ¶17).
- Technology Synopsis: The ’403 Patent claims a system comprising a first computer at a fluid-handling site and a remote server system. The server receives fluid level data from the site computer, obtains and authenticates credentials from a remote client device, and provides the client with a user interface. A key aspect is the server hosting data for other sites the user is not authorized to interact with, thereby providing a secure, multi-tenant environment (Compl. ¶¶32, 96).
- Asserted Claims: At least claims 1-30 (Compl. ¶89).
- Accused Features: The complaint alleges the Accused System’s architecture of on-site computers, a remote cloud-based server, and remote client computing devices for user access and control infringes the claimed system (Compl. ¶¶99-106).
Multi-Patent Capsule: U.S. Patent No. 12,019,461
- Patent Identification: U.S. Patent No. 12,019,461 ("’461 Patent"), "Remote control of fluid-handling devices", Issued June 25, 2024 (Compl. ¶18).
- Technology Synopsis: The ’461 Patent claims a fluid processing method that mirrors the system of the ’403 Patent. The method involves receiving fluid property information from on-site sensors, providing remote control, receiving credentials at a server, authenticating the user for a specific site while hosting data for other unauthorized sites, presenting a user interface, and causing the on-site computer to execute a command (Compl. ¶¶32, 118).
- Asserted Claims: At least claims 1-17 (Compl. ¶111).
- Accused Features: The complaint alleges the Accused System's end-to-end process—from gathering sensor data at a wellhead to authenticating users and executing remote commands—infringes the claimed method (Compl. ¶¶121-128).
III. The Accused Instrumentality
Product Identification
Defendant’s "Ignition-Hosted Automation System" (the "Accused System") (Compl. ¶22).
Functionality and Market Context
- The Accused System is described as a "Comprehensive Hosted SCADA" service powered by Inductive Automation's "Ignition platform" (Compl. ¶23). It is designed to allow customers to connect with, collect data from, and remotely control field devices such as pumps, valves, flow meters, and sensors (Compl. ¶¶51, 54). Data is hosted on a cloud-based infrastructure, and users can interact with the system via desktop and mobile software (Compl. ¶23).
- The complaint provides an "IIoT Architecture" diagram, depicting data flow from on-site controllers (PLCs/RTUs) through an Edge Gateway via MQTT protocol to a cloud-based "Ignition Server," which then serves "Web-Launched Ignition Clients" (Compl. p. 16). This diagram illustrates the system's distributed architecture for remote monitoring and control (Compl. p. 16).
- The system is marketed for "innovative, robust automation for the oil and gas industries," offering services including Oilfield Automation, Remote Monitoring, and Hosted Ignition (Compl. ¶22).
IV. Analysis of Infringement Allegations
’078 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, via a network interface, a plurality of user-directed instructions to control fluid-handling devices...the plurality of instructions being received encoded in a shared protocol | The Accused System receives user commands via web-launched clients to control field devices like pumps and valves at oil facilities. The complaint alleges these commands are sent via a shared protocol such as TCP/IP using an MQTT architecture. | ¶51 | col. 8:66-9:2 |
| obtaining a target state of at least one of the fluid-handling devices...determining a plurality of different target states...each corresponding to different times | The Accused System allegedly allows users to set target states for devices, such as controlling pumps based on time, pressure, or tank level. The complaint alleges that VFDs with PID controllers determine a plurality of target states over time. | ¶¶52-53 | col. 10:49-54 |
| for each of the plurality of instructions, selecting a respective protocol or protocols from among a plurality of protocols different from the shared protocol...wherein at least some of the selected protocols are different from one another | The complaint alleges on information and belief that the Accused System communicates with a variety of devices (valves, pumps, sensors) that are responsive to different protocols (e.g., analog, digital, Modbus) and that the system selects a protocol different from the shared TCP/IP protocol to communicate with them. | ¶54 | col. 9:3-14 |
| translating each received instructions into one or more translated instructions encoded in the selected respective protocol or protocols | On information and belief, the Accused System is configured to translate commands from the server system's protocol (e.g., TCP/IP) into commands in various field protocols, such as digital or analog outputs understood by the devices. | ¶55 | col. 8:66-9:2 |
| sending each translated instructions to at least the fluid-handling device...wherein at least some of the translated instructions are effective to cause the at least one of the fluid-handling devices to attempt to achieve the target state | The Accused System sends commands that cause fluid-handling devices to perform actions, such as starting or stopping pumps to control tank levels. A screenshot shows a user interface for remotely controlling pumps and valves at "Site Number 1" (Compl. p. 20). | ¶56 | col. 10:39-44 |
Identified Points of Contention
- Technical Questions: The complaint’s allegation of protocol "selection" and "translation" from a shared protocol (e.g., MQTT/TCP/IP) to different device-level protocols (e.g., Modbus, analog) is made "on information and belief" (Compl. ¶¶54-55). A central evidentiary question will be whether the Accused System’s Ignition platform actually performs this specific translation step at the edge, or whether it employs a different architecture, for instance, one where edge devices communicate natively in the shared protocol.
- Scope Questions: The case may raise the question of whether an industry-standard communication architecture like MQTT, as depicted in the complaint's diagram (Compl. p. 16), falls within the scope of the claimed method, particularly the steps of "selecting" a different protocol and "translating" instructions.
’871 Patent Infringement Allegations
| Claim Element (from Independent Claim 18) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing, with one or more processors, records comprising: a plurality of accounts, each account corresponding to an entity operating one or more geographically distributed fluid-handling facilities | The complaint alleges the Accused System provides access to different customer organizations (entities) to monitor their respective field devices, and that each customer can manage multiple user accounts. | ¶¶71-72 | col. 4:25-30 |
| addresses by which industrial monitoring or control equipment at the facilities is accessible...including sensors...and actuators | The complaint shows a user interface for the Accused System depicting various sensors (tank levels) and actuators (pumps, valves) at a facility, which are accessible via network connections for monitoring and control. | ¶73 | col. 5:58-6:4 |
| obtaining, with one or more processors implementing a facility-interface module...data from the sensors...and send commands to the actuators | The Accused System's IIoT architecture allegedly shows a facility-interface module (an Edge Gateway) that obtains data from and sends commands to on-site PLCs/RTUs connected to sensors and actuators. | ¶74 | col. 4:51-5:4 |
| sending, with one or more processors implementing a user-interface module...respective instructions to present respective control interfaces on respective user-computing devices logged in to respective ones of the accounts | The Accused System provides web-launched clients for user devices, which present control interfaces to users who have logged into their accounts. The complaint includes a screenshot of the system’s user interface depicting tank levels and pump controls (Compl. p. 30). | ¶75 | col. 4:5-9 |
| wherein: the plurality of accounts include a first account, a second account, a third account, and a fourth account...[with specific control/view permissions for two different groups of facilities] | The complaint alleges that the Accused System's "role based approach to security" allows for the creation of multiple user accounts with different permissions, thereby meeting the four-part structure required by the claim. A screenshot highlights the system's "Users & Security" feature (Compl. p. 29). | ¶¶79-84 | col. 17:13-34 |
Identified Points of Contention
- Scope Questions: Claim 18 recites a highly specific four-part account structure with defined control and view permissions across two distinct groups of facilities. The complaint alleges the Accused System’s flexible "role based approach to security" meets this limitation (Compl. ¶¶80-81). A primary dispute may be whether the claim requires the system to be sold or used with this exact four-account configuration, or if a system that is merely capable of being so configured meets the claim limitation.
- Technical Questions: What evidence does the complaint provide that Defendant's customers actually use the Accused System in a manner that creates the specific four-account, two-facility-group structure recited in the claim?
V. Key Claim Terms for Construction
’078 Patent: "selecting a respective protocol...different from the shared protocol"
- The Term: "selecting a respective protocol or protocols from among a plurality of protocols different from the shared protocol"
- Context and Importance: This term is central to the claimed invention, which distinguishes itself from prior art by performing protocol translation at the edge of the network. The infringement analysis will depend on whether the Accused System's use of a protocol like MQTT to communicate with an edge gateway, which in turn communicates with field devices, constitutes "selecting" a "different" protocol as required. Practitioners may focus on this term because it defines the core technical mechanism of the alleged invention.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "protocol multiplexer" as selecting among "command translators 74, each of which corresponds to a different protocol," including Modbus RTU, binary/analog signals, and Ethernet (’078 Patent, col. 9:3-14). This suggests the term covers a functional selection process that results in communication over a different physical or logical layer.
- Evidence for a Narrower Interpretation: The claim language requires "selecting...from among a plurality of protocols." A party could argue this requires an active choice between multiple available, distinct protocols for a given instruction, rather than a static, pre-configured communication path from a server protocol to a device protocol.
’871 Patent: The Four-Account Structure
- The Term: "wherein: the plurality of accounts include a first account, a second account, a third account, and a fourth account; [followed by specific control/view permissions]"
- Context and Importance: This "wherein" clause defines a specific, rigid multi-tenant permission structure. The viability of the infringement claim depends on whether the Accused System, which offers flexible, role-based security, is deemed to "include" this structure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of "include" could be argued to mean that as long as the system contains these four account types among potentially many others, the claim is met. The patent describes organizing controllers by user accounts and authorizing users to interact with specific controllers, which supports a flexible, multi-tenant system (’871 Patent, col. 4:25-40).
- Evidence for a Narrower Interpretation: A party could argue that this is a structural limitation requiring the actual presence and configuration of these four distinct account types with their specified permissions, not merely the capability to create them within a generic role-based system. The claim recites the structure in detail, suggesting its specificity is a key feature of the invention (’871 Patent, col. 17:13-34).
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement for all four asserted patents. Inducement is alleged based on Defendant providing product manuals and technical information that instruct and encourage customers to use the Accused System in an infringing manner (e.g., Compl. ¶¶43-45, 63-65).
Willful Infringement
Willfulness is alleged for all four asserted patents. The complaint bases this on Defendant's alleged knowledge of the patents "since at least the filing and service of this Complaint," and potentially earlier if Defendant's employees accessed Plaintiff's public patent marking webpage (e.g., Compl. ¶¶47, 67).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of technical operation: Does the evidence support the allegation that the Accused System's architecture performs active "selection" and "translation" from a "shared protocol" to multiple, different field-level protocols as required by the ’078 Patent, or is there a fundamental mismatch between the claimed method and the accused system's actual data handling process?
- A second core issue will be one of definitional scope: For the ’871 Patent, can the claim's recitation of a specific four-part account and permission structure be met by a system that offers flexible, role-based security that is merely capable of being configured in such a way, or must the system be shown to actually be used in that specific configuration to infringe?
- A third key question will concern multi-tenancy implementation: For the ’403 and ’461 Patents, the infringement analysis may turn on how the Accused System technically implements its multi-tenant architecture and whether its method of authenticating users and partitioning data for different customers aligns with the specific steps and system components recited in the claims.