DCT
6:25-cv-00441
GD Energy Products LLC v. Southwest Oilfield Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: GD Energy Products, LLC (Oklahoma)
- Defendant: Southwest Oilfield Products, Inc. (Delaware)
- Plaintiff’s Counsel: Sheppard, Mullin, Richter & Hampton LLP
- Case Identification: 6:25-cv-00441, W.D. Tex., 09/26/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Western District of Texas, specifically in West Odessa and Pecos.
- Core Dispute: Plaintiff alleges that Defendant’s replacement fluid end modules for high-pressure drill pumps infringe three patents related to wear plate assemblies and fluid end design.
- Technical Context: The technology concerns components for high-pressure fluid ends, which are integral to plunger pumps used in demanding environments such as oil and gas drilling operations.
- Key Procedural History: The complaint notes that U.S. Patent No. 9,732,746 was previously litigated in the same court in GD Energy Products, LLC v Premium Oilfield Technologies, LLC, Case No. 6:21-cv-00864. Prior proceedings involving this patent, such as claim construction rulings, may influence the current case.
Case Timeline
| Date | Event |
|---|---|
| 2012-09-24 | ’746 Patent Priority Date |
| 2017-03-14 | ’997 and ’709 Patents Priority Date |
| 2017-08-15 | ’746 Patent Issue Date |
| 2021-12-28 | ’997 Patent Issue Date |
| 2023-08-22 | ’709 Patent Issue Date |
| 2025-09-26 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,208,997 - "Wear Plate for a Drill Pump," issued December 28, 2021
The Invention Explained
- Problem Addressed: In high-pressure pumps, the failure of a primary seal can lead to a high-velocity jet of fluid eroding the pump’s housing. This damage can make simple seal replacement impossible, forcing a costly and time-consuming disassembly or replacement of the entire drilling module (’997 Patent, col. 4:3-20).
- The Patented Solution: The patent describes a drilling module with a wear plate assembly that incorporates a dual-seal design: a primary radial seal and a secondary axial seal (’997 Patent, col. 1:12-17; Fig. 5). If the primary seal fails, the secondary seal can be installed in the field, allowing pumping operations to resume quickly and preventing catastrophic housing damage (’997 Patent, col. 4:21-27).
- Technical Importance: This approach provides sealing redundancy and enhances the serviceability of critical pump components, which may reduce operational downtime and maintenance costs in the field (’997 Patent, col. 4:26-29).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶54).
- Claim 1 requires, in essence:
- A drilling module with a housing defining a specified fluid path and a fluid end bore.
- A piston retainer mounted externally to the fluid end bore.
- A wear plate assembly positioned within the fluid end bore and abutting the bore and retainer.
- The assembly includes an annular wear plate with a radial outer surface.
- The assembly also includes a radial seal compressed between the fluid end bore and the wear plate’s radial outer surface.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 11,732,709 - "Wear Plate for a Drill Pump," issued August 22, 2023
The Invention Explained
- Problem Addressed: As a divisional of the application leading to the ’997 Patent, this patent addresses the same general problem of providing a durable and reliable seal for a wear plate in a high-pressure drilling pump environment (’709 Patent, col. 1:17-21).
- The Patented Solution: The invention focuses on the specific geometry of the wear plate assembly itself. It claims a wear plate defined by a bore inner surface and a radial outer seal surface, featuring an "annular seal groove" on the outer surface and a "shoulder" extending radially outward at one end (’709 Patent, Abstract). These features are depicted in Figures 5 and 6 of the patent (’709 Patent, col. 2:8-12).
- Technical Importance: The claimed geometry provides a dedicated housing for the seal (the groove) and a positive mechanical stop for installation (the shoulder), which may improve the consistency of installation and the reliability of the seal in operation (’709 Patent, col. 3:26-34).
Key Claims at a Glance
- The complaint asserts claims 1 and 2 (Compl. ¶69). Claim 2 is dependent on claim 1.
- Independent claim 1 requires, in essence:
- A wear plate assembly for a drill pump.
- The assembly comprises a wear plate with a first and second axial end.
- The wear plate has an annular cross-section defined by a bore inner surface and a radial outer seal surface.
- An annular seal groove is located in the radial outer seal surface.
- A shoulder extends radially outward from the radial outer seal surface at the second axial end.
- The complaint does not explicitly reserve the right to assert other dependent claims.
U.S. Patent No. 9,732,746 - "Fluid End of a High Pressure Plunger Pump," issued August 15, 2017
Technology Synopsis
The patent addresses stress concentrations that led to systemic failures in prior art fluid end designs (Compl. ¶43). The patented solution is a fluid end casing with specially configured V-shaped grooves at the inlet bore transition area, which are designed to engage an inlet spring retainer. The retainer can be installed or removed in one orientation but, when rotated into a second orientation, engages the grooves to prevent axial movement, thereby securely retaining the inlet valve components (Compl. ¶42; ’746 Patent, col. 13:48-col. 14:10).
Asserted Claims
The complaint asserts independent claim 5 (Compl. ¶84).
Accused Features
The complaint alleges that Defendant's fluid end product infringes by having a casing with the claimed arrangement of bores, first and second V-shaped grooves with a specific angular geometry, and an inlet spring retainer with engagement portions that interact with those grooves (Compl. ¶¶85-87).
III. The Accused Instrumentality
Product Identification
The accused products are Defendant’s "OEM Style Fluid End for Gardner Denver PZ11-HD 7500PSI" and related products (Compl. ¶53).
Functionality and Market Context
The complaint alleges these products are replacement fluid end modules marketed for "seamless integration into existing pump systems," including those made by Plaintiff's predecessor (Compl. ¶50). The functionality described in the complaint, supported by technical drawings from Defendant’s data sheet, includes a housing, a piston retainer, a wear plate assembly with a radial seal, and an inlet spring retainer, which are the core components of the patented inventions (Compl. ¶¶55, 70, 85). The complaint characterizes Defendant's business model as "copying and selling replaceable portions of various manufacturers’ pump systems" (Compl. ¶50). The complaint includes a technical drawing from Defendant's product data sheet showing an annotated cross-section of the accused fluid end (Compl. ¶55, p. 13).
IV. Analysis of Infringement Allegations
’997 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing defining a fluid path having a fluid inlet, a fluid outlet, and a fluid end bore branched off therebetween | The accused product is a drilling module with a housing that contains a fluid inlet, a fluid outlet, and a fluid end bore. | ¶55 | col. 4:32-34 |
| a piston retainer mounted to the housing such that the piston retainer is external to the fluid end bore | The accused product has a piston retainer mounted on the housing, located externally to the fluid end bore. | ¶55 | col. 4:35-37 |
| a wear plate assembly positioned within the fluid end bore and abutting against the fluid end bore and the piston retainer | The accused product contains a wear plate assembly located inside the fluid end bore, where it abuts against the bore and retainer. | ¶56 | col. 4:38-41 |
| the wear plate assembly comprising: an annular wear plate having a radial outer surface | The accused wear plate assembly includes a circular wear plate with a radial outer surface. The complaint includes a photograph comparing the accused wear plate to Plaintiff's product (Compl. ¶56, p. 14). | ¶56 | col. 4:42-43 |
| and a radial seal compressed between the fluid end bore and the radial outer surface of the annular wear plate | The accused product uses a radial seal installed on the wear plate's outer surface that becomes compressed when the assembly is installed in the fluid end bore. | ¶56 | col. 4:44-46 |
- Identified Points of Contention:
- Factual Question: The primary dispute appears to be factual: does the accused product physically contain each of the claimed components arranged in the specified manner? The complaint’s use of Defendant's own technical drawings suggests a direct structural comparison will be central to the case.
- Scope Question: A potential dispute may arise over the meaning of "abutting against," questioning the required nature and extent of contact between the wear plate assembly, the fluid end bore, and the piston retainer for infringement to be found.
’709 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wear plate extending between a first axial end and a second axial end | The accused wear plate is a component with two opposing axial ends. | ¶70 | col. 3:21-23 |
| the wear plate comprising: an annular cross-section defined by a bore inner surface and a radial outer seal surface... | The accused wear plate has a circular cross-section with an inner surface defining the bore and an outer surface for sealing. | ¶70 | col. 3:23-27 |
| an annular seal groove in the radial outer seal surface at a position between the first axial end and the second axial end | The accused wear plate has a distinct groove machined into its radial outer surface to hold a seal. The complaint presents a photograph showing this feature on the accused product (Compl. ¶71, p. 18). | ¶71 | col. 3:28-31 |
| and a shoulder extending radially outward from the radial outer seal surface at the second axial end | The accused wear plate includes a flange-like feature at one end that extends radially outward, alleged to be the claimed shoulder. | ¶71 | col. 3:31-34 |
- Identified Points of Contention:
- Technical Question: The infringement analysis will likely focus on a direct comparison of the accused wear plate's geometry against the claim limitations. Evidence will be needed to confirm that the accused component's features meet the specific structural requirements of a "groove" and a "shoulder."
- Scope Question: The definition of "shoulder" may be a key point of dispute. The case may question whether the flange on the accused product constitutes a "shoulder extending radially outward...at the second axial end" as construed from the patent's specification and figures.
V. Key Claim Terms for Construction
- Term: "shoulder" (’709 Patent, Claim 1)
- Context and Importance: The existence of a "shoulder" at a specific location is a required element of claim 1 of the ’709 Patent. Whether the flange on the accused product meets this definition will be a critical issue for infringement. Practitioners may focus on this term because its construction could be case-dispositive for the ’709 patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the shoulder’s function as providing "an axial stop against a surface of the housing" (’709 Patent, col. 3:29-31). This functional description could support an argument that any structure performing this stopping function, regardless of its precise geometry, qualifies as a "shoulder."
- Evidence for a Narrower Interpretation: Figure 5 of the patent depicts element 510 as a distinct, sharply-angled structure characteristic of a mechanical shoulder. This specific embodiment could support a narrower construction requiring a similar geometric profile, potentially excluding structures like a tapered or rounded flange.
- Term: "V-shaped groove" (’746 Patent, Claim 5)
- Context and Importance: Claim 5 of the ’746 Patent requires "a first V-shaped groove" and "a second V-shaped groove" with a specific angular definition. The infringement allegation for this element is based on "information and belief" that the accused product must have these features to function (Compl. ¶86). The construction of this term will be central to determining if the accused product, once examined, infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "V-shaped" is not explicitly defined, which might permit a construction that covers any groove with converging, non-parallel sides, even if not a perfect "V."
- Evidence for a Narrower Interpretation: Claim 5 further qualifies the groove by requiring its upper and lower surfaces to define an "exterior angle between 180 degrees and 270 degrees." This specific geometric constraint suggests a narrow definition that requires more than a generic V-shape and may exclude grooves with different angular relationships.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on Defendant allegedly encouraging infringement through marketing materials, instructions, and technical support (Compl. ¶¶58, 73, 90). Contributory infringement is based on the sale of key components (e.g., wear plate assemblies, inlet spring retainers) alleged to be especially made for an infringing use with no substantial non-infringing purpose (Compl. ¶¶59, 74, 91).
- Willful Infringement: Willfulness is alleged for all asserted patents. The complaint bases this on "information and belief" that Defendant knew of the patents and Plaintiff's corresponding products, "intentionally copied" the technology, and continued to infringe with "reckless disregard" for Plaintiff's patent rights (Compl. ¶¶62, 77, 94). The complaint also asserts Defendant had constructive notice through Plaintiff's marking of its products (Compl. ¶¶61, 76, 93).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary proof versus allegation: For the ’746 patent, a key infringement allegation regarding the "V-shaped groove" is pleaded on "information and belief" that the features must be present for the accused product to work (Compl. ¶86). A central question will be whether discovery confirms the existence and precise geometry of these grooves in the accused products, or if they operate via a different, non-infringing mechanism.
- A second key question will be one of definitional scope: For the ’709 patent, the analysis will likely turn on whether the flange on Defendant's wear plate can be construed as the claimed "shoulder." The outcome of this claim construction dispute may determine infringement for that patent.
- Finally, the case presents a fundamental question of copying versus legitimate competition: The complaint repeatedly alleges that Defendant's business model is based on "copying" Plaintiff's products (Compl. ¶¶50, 62, 77, 94). The case will likely involve an examination of whether the accused products are direct copies meeting every claim limitation or are permissible, reverse-engineered replacements that avoid infringement by omitting, or designing around, specific patented features.