DCT
6:25-cv-00499
GD Energy Products LLC v. Premium Oilfield Tech LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: GD Energy Products, LLC (Oklahoma)
- Defendant: Premium Oilfield Technologies, LLC (Delaware)
- Plaintiff’s Counsel: Sheppard, Mullin, Richter & Hampton LLP
- Case Identification: 6:25-cv-00499, W.D. Tex., 10/24/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains "regular and established places of business" in the district, including facilities in Midland and Bryan, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s fluid end modules and replacement wear plates for high-pressure drill pumps infringe two patents related to wear plate assembly designs that improve sealing and serviceability.
- Technical Context: The technology at issue involves components for high-pressure reciprocating pumps used in oil and gas drilling, a field where equipment reliability and minimizing operational downtime for maintenance are critical commercial concerns.
- Key Procedural History: U.S. Patent No. 11,732,709 is a divisional of U.S. Patent No. 11,208,997, and both claim priority to the same 2017 provisional application, indicating a shared technical disclosure. Plaintiff alleges it marks its commercial products with the asserted patent numbers, which may be relevant to notice and damages.
Case Timeline
| Date | Event |
|---|---|
| 2017-03-14 | Priority Date for ’997 and ’709 Patents |
| 2021-12-28 | U.S. Patent No. 11,208,997 Issued |
| 2023-08-22 | U.S. Patent No. 11,732,709 Issued |
| 2025-10-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,208,997 - Wear Plate for a Drill Pump
(Issued Dec. 28, 2021)
The Invention Explained
- Problem Addressed: In high-pressure drilling pumps, failure of a seal can create a high-velocity jet of fluid that erodes the pump housing. Such erosion damage can make it impossible to repair the pump by simply replacing the seal, potentially requiring a forced disassembly of the fluid end or replacement of the entire drilling module (’997 Patent, col. 4:5-20).
- The Patented Solution: The patent describes a drilling module with a wear plate assembly featuring a dual-seal design. This includes a primary radial seal and an optional secondary axial seal. If the primary seal fails, the secondary seal can be installed to allow pumping operations to resume quickly without a major overhaul, providing operational flexibility and redundancy (’997 Patent, col. 1:11-21, col. 4:21-26). Figure 5 of the patent illustrates the wear plate assembly with both a primary/radial seal and a secondary/axial seal (Compl. ¶19).
- Technical Importance: The invention provides a system for mitigating catastrophic pump damage from seal failure, which can reduce costly equipment downtime in drilling operations (’997 Patent, col. 4:21-26).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶42).
- Claim 1 of the ’997 Patent recites the following essential elements for a drilling module:
- A housing defining a fluid path with an inlet, an outlet, and a fluid end bore.
- A piston retainer mounted to the housing and external to the fluid end bore.
- A wear plate assembly positioned within the fluid end bore.
- The wear plate assembly comprises an annular wear plate with a radial outer surface.
- A radial seal is compressed between the fluid end bore and the radial outer surface of the wear plate.
U.S. Patent No. 11,732,709 - Wear Plate for a Drill Pump
(Issued Aug. 22, 2023)
The Invention Explained
- Problem Addressed: As a divisional of the ’997 Patent, the ’709 Patent addresses the same technical problem of preventing pump housing damage from high-pressure seal failures (’709 Patent, col. 4:19-29).
- The Patented Solution: This patent focuses on the specific geometry of the wear plate itself. The invention is a wear plate assembly defined by an annular cross-section, a seal groove located on its radial outer surface, and a shoulder that extends outward at one end (’709 Patent, Abstract). This claimed structure provides a dedicated location for the seal and a physical stop for positioning the assembly within the pump housing (’709 Patent, col. 3:35-40). Figure 6 of the patent shows a cross-section of the wear plate, identifying the seal groove (604) and other features (Compl. ¶31).
- Technical Importance: By claiming a specific, defined geometry for the wear plate, the invention provides a replicable design for a critical component that must withstand high pressures and facilitate effective sealing (’709 Patent, col. 4:12-18).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claim 2 (Compl. ¶56).
- Claim 1 of the ’709 Patent recites the following essential elements for a wear plate assembly:
- A wear plate extending between a first and second axial end.
- An annular cross-section defined by a bore inner surface and a radial outer seal surface.
- An annular seal groove located in the radial outer seal surface.
- A shoulder extending radially outward from the radial outer seal surface at the second axial end.
- Dependent claim 2 further requires a radial seal positioned within the annular seal groove (Compl. ¶32).
III. The Accused Instrumentality
Product Identification
The accused products are Defendant’s fluid end modules, such as the GX-7500 and DX-7500, and the individual wear plates (or "Wear Rings") sold for use in those modules, identified for example as "Wear Ring, HD Black (OEM), PXL7500 Fluid End, For PZ-10/11 Pump" (Compl. ¶¶39-41).
Functionality and Market Context
The complaint alleges that the accused products are replacement components manufactured to "OEM specifications and interchangeability" for pumps originally made by Gardner Denver (a related entity to Plaintiff) (Compl. ¶¶38-39). Plaintiff characterizes Defendant’s business model as one that "revolves around copying and selling replaceable components" of other manufacturers’ pump systems (Compl. ¶38). A photograph provided in the complaint shows the accused wear plate, a machined metal component with a prominent groove on its outer surface (Compl. p. 10, Ex. E).
IV. Analysis of Infringement Allegations
’997 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A drilling module of a drill pump, the drilling module comprising: a housing defining a fluid path having a fluid inlet, a fluid outlet, and a fluid end bore branched off therebetween; a piston retainer mounted to the housing such that the piston retainer is external to the fluid end bore | Defendant’s fluid end modules are alleged to contain a housing, fluid inlet/outlet, fluid end bore, and piston retainer, as shown in a cutaway model from Defendant’s website. | ¶43 | col. 2:41-48 |
| a wear plate assembly positioned within the fluid end bore and abutting against the fluid end bore and the piston retainer | Defendant’s wear plate assembly is shown positioned within the fluid end bore in the annotated model. | ¶44 | col. 2:45-48 |
| the wear plate assembly comprising: an annular wear plate having a radial outer surface | The accused "Wear Ring" is alleged to be an annular wear plate with a radial outer surface. | ¶44 | col. 3:15-17 |
| and a radial seal compressed between the fluid end bore and the radial outer surface of the annular wear plate | The complaint alleges a radial seal is installed in a groove on the wear plate's outer surface, which is then compressed against the fluid end bore upon assembly. | ¶44 | col. 3:30-34 |
Identified Points of Contention
- Scope Questions: The claim requires a "drilling module," which includes a housing and other components, while the defendant is accused of selling the module and also the "Wear Ring" component. The analysis may question whether the sale of the component alone can satisfy the limitations of this system claim.
- Technical Questions: Claim 1 requires a "radial seal compressed" between the bore and the wear plate. The complaint provides a model of an assembled product and a photo of a standalone wear plate with a groove for a seal (Compl. ¶¶43-44). A key evidentiary question will be whether the accused products, when assembled and used as intended, necessarily result in the claimed "compressed" state.
’709 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A wear plate assembly...comprising: a wear plate extending between a first axial end and a second axial end | The accused wear plate is alleged to have a body extending between two axial ends, as identified in an annotated model. | ¶57 | col. 3:21-23 |
| an annular cross-section defined by a bore inner surface and a radial outer seal surface | The accused wear plate is alleged to have the claimed annular shape, inner surface, and outer surface. | ¶57 | col. 1:31-33 |
| an annular seal groove in the radial outer seal surface at a position between the first axial end and the second axial end | A photograph of the accused product shows a machined groove on its outer cylindrical surface. | ¶58 | col. 1:33-35 |
| and a shoulder extending radially outward from the radial outer seal surface at the second axial end | A photograph of the accused product shows a flange-like shoulder at one end of the wear plate. | ¶58 | col. 1:35-37 |
Identified Points of Contention
- Scope Questions: The infringement theory for this patent appears to rely heavily on the physical geometry of the accused wear plate. A potential point of contention could be the precise definition and boundaries of the "radial outer seal surface" and whether the accused product's groove and shoulder are located "in" and extending "from" that surface, respectively, as the claim requires.
- Technical Questions: As the allegations are based on photographs of the physical product (Compl. p. 16, Ex. E), the literal presence of the claimed groove and shoulder appears to be a central part of the infringement case. The dispute may turn on whether these physical features on the accused product meet the specific structural definitions set forth in the patent's specification and claims.
V. Key Claim Terms for Construction
’997 Patent, Claim 1: "wear plate assembly"
- Context and Importance: This term is central because Defendant sells both full modules and individual components it calls a "Wear Ring" (Compl. ¶39). The definition of "assembly" will determine whether the sale of the "Wear Ring" alone, perhaps with instructions to add a seal, can directly infringe the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (requiring multiple components): The specification describes "wear plate assembly 402" as including "the wear plate 502, the primary seal 410, and the secondary seal 412" (’997 Patent, col. 2:61-63). This suggests an "assembly" is a collection of distinct parts.
- Evidence for a Narrower Interpretation (a single component designed for assembly): The claims define the assembly by its components ("comprising: an annular wear plate...and a radial seal..."). An argument could be made that a single part specially adapted to be combined with a seal meets the definition in the context of infringement, especially for contributory infringement.
’709 Patent, Claim 1: "radial outer seal surface"
- Context and Importance: The claim requires the "annular seal groove" to be located in this surface and the "shoulder" to extend from it. The precise boundaries of this "surface" are therefore critical to mapping the claim onto the accused product.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification identifies element 508 as a "radial seal surface" that is "sized to engage or fit within the fluid end bore 406 of the housing 202" (’709 Patent, col. 3:35-37). Figure 5 depicts 508 as the primary cylindrical outer face of the wear plate, suggesting a broad definition.
- Evidence for a Narrower Interpretation: A defendant could argue that the "seal surface" is limited to the specific portion of the outer diameter that makes physical contact with the seal itself, not the entire outer wall. However, the claim language places the groove "in" the surface, which may counter this argument, as a groove is a recess within a larger surface.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it cites Defendant’s marketing, instructions, and technical support as encouraging its customers to assemble and use the accused products in an infringing manner (Compl. ¶¶46, 60). For contributory infringement, it alleges the accused wear plates are specially made for this infringing use, are not a staple article of commerce, and have no substantial non-infringing use (Compl. ¶¶47, 61).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the asserted patents and of Plaintiff’s corresponding commercial products (Compl. ¶¶49, 63). The complaint alleges that Defendant "intentionally copied" Plaintiff’s 7500 HD Fluid End product and continued infringing after receiving notice via product marking and the filing of the suit (Compl. ¶¶48-49, 62-63).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of intent and evidence: the complaint alleges a business model of "copying" and "intentional" infringement. A key question for the court will be whether Plaintiff can substantiate these claims, which are critical to its request for willful infringement and enhanced damages, or whether the accused products represent independent design choices for interoperable parts in a competitive market.
- The case will also present a question of component versus system liability: the patents claim both a complete "drilling module" and the "wear plate assembly" itself. A core legal and factual question will be whether Defendant’s sale of a single replacement component (the "Wear Ring") constitutes direct infringement of the component-level claims and gives rise to indirect infringement of the broader system-level claims.