DCT
7:25-cv-00266
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: 7:25-cv-00266, W.D. Tex., 06/06/2025
- 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 there, specifically an office in Odessa, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s cloud-based industrial automation system infringes a patent related to the remote control and monitoring of fluid-handling equipment.
- Technical Context: The technology relates to Supervisory Control and Data Acquisition (SCADA) systems used to manage industrial equipment, such as pumps and sensors in the oil and gas industry, from a remote location.
- Key Procedural History: The asserted patent is the result of a long chain of continuation applications, suggesting a sustained and focused patent prosecution strategy in this technology area. The complaint does not mention any prior litigation or post-grant proceedings involving the patent.
Case Timeline
| Date | Event |
|---|---|
| 2012-01-XX | Alleged Invention Date of ’184 Patent |
| 2012-12-07 | Earliest Patent Priority Date (U.S. App. No. 13/708,557) |
| 2019-02-26 | Accused System operational date suggested by screenshot |
| 2024-12-18 | Date of access for accused mobile application screenshot |
| 2025-06-03 | ’184 Patent Issue Date |
| 2025-06-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 12,321,184, “Remote control of fluid-handling devices,” issued June 3, 2025 (the “’184 Patent”).
The Invention Explained
- Problem Addressed: The patent describes challenges with prior art SCADA systems used for managing remote industrial sites like oil wells (Compl. ¶25). These systems often failed when the network connection to the central command server was lost, as complex control logic resided on that central server (’184 Patent, col. 1:67-2:4). Additionally, these systems struggled with interoperability, requiring installation of special-purpose software for each new type of field device, which hindered scalability and created operational fragility (Compl. ¶28-29; ’184 Patent, col. 2:4-10).
- The Patented Solution: The invention proposes a system architecture that pushes intelligence to the "edge"—a local "site master-controller" located at the industrial site (’184 Patent, Fig. 1, element 18). This local controller is capable of executing complex commands, translating commands from a universal protocol into various device-specific protocols, and maintaining control even if the connection to the central server is lost (Compl. ¶30, 34). It also features a "report buffer" to store site data (e.g., sensor readings, alarms) during network outages and transmit the buffered data to the central server once connectivity is restored (’184 Patent, col. 11:20-31).
- Technical Importance: This architecture aims to provide more resilient and scalable remote control, ensuring continuous operation and data integrity despite the intermittent network connectivity common in geographically dispersed industrial operations (Compl. ¶33).
Key Claims at a Glance
- The complaint asserts claims 1-31, with a detailed infringement analysis provided for independent system claim 30 (Compl. ¶40, 47).
- Independent Claim 30 recites a system with essential elements including:
- A plurality of fluid handling devices.
- A "first computing system" that stores instructions to perform a set of operations.
- The operations include:
- Receiving commands from an authorized remote user to control the fluid-handling devices.
- Determining different target states for a device over time, while being "operative to maintain control" of the devices even "in an absence of an external network connection."
- "Translating" the commands from a first protocol into different protocols for the local devices.
- "Obtaining" and "storing" site data in a "report buffer" so it is "not lost in the absence of the network connection."
- Sending the data from the report buffer to a "remote second computing system."
- The complaint reserves the right to assert other claims, which could include dependent claims that further narrow these elements (Compl. ¶40).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is TankLogix’s "Ignition-Hosted Automation System" (the "Accused System") (Compl. ¶19).
Functionality and Market Context
- The Accused System is described as a "Comprehensive Hosted SCADA" service that is "powered by Inductive Automation’s Ignition platform" (Compl. ¶20). This image from the complaint describes the Accused System's use of a third-party platform. (Compl. p. 6, ¶20).
- It provides a cloud-based infrastructure and software that allows customers to remotely connect with, collect data from, and control their "field devices" such as PLCs, pumps, and sensors (Compl. ¶20, 51). The system allows users to interact with their equipment through desktop and mobile software, enabling actions like starting or stopping pumps and monitoring tank levels remotely (Compl. ¶53, p. 21). This IIoT Architecture diagram from the complaint illustrates the alleged data flow from on-site PLCs and RTUs through a cloud network to an "Ignition Server" and remote user clients. (Compl. p. 18, ¶51).
- The complaint alleges the system is marketed for use in the oil and gas industries, offering features such as automated control, real-time data monitoring, and user-based security permissions (Compl. ¶19, 24).
IV. Analysis of Infringement Allegations
’184 Patent Infringement Allegations
| Claim Element (from Independent Claim 30) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system, comprising: a plurality of fluid handling devices; | The Accused System includes and controls devices such as "TankLogix brand sensors," pumps, flow lines, and vessels. A marketing screenshot from the complaint lists various sensors and devices. (Compl. p. 17, ¶50). | ¶50 | col. 5:60-6:2 |
| a first computing system...storing instructions that, when executed...effectuate operations comprising: | The Accused System allegedly comprises a first computing system (e.g., a PLC) communicatively coupled to the fluid handling devices. | ¶51 | col. 10:24-34 |
| receiving...a plurality of commands encoded in a first protocol to control a plurality of different fluid-handling devices... | The Accused System allegedly receives commands via a network interface (e.g., through its cloud network) to control various field devices. | ¶52 | col. 12:1-11 |
| wherein: the plurality of commands are responsive to inputs to a command interface presented on a remote user computing device, and...are received after determining that a user...is authorized... | The Accused System presents a command interface on remote devices and requires users to log in through an application, thereby authenticating them before commands can be issued. The complaint provides a screenshot of a user interface for controlling pumps and tanks. (Compl. p. 21, ¶53). | ¶53, ¶54 | col. 4:6-26 |
| determining...a plurality of different target states...wherein the first computing system is operative to maintain control of the fluid handling devices in an absence of an external network connection; | The complaint alleges the Accused System includes controllers (e.g., VFDs with PID controllers) that determine target states and can "control your field devices" even when disconnected. | ¶55 | col. 17:7-11 |
| translating...the plurality of commands into translated commands encoded in a plurality of protocols different from the first protocol... | The Accused System is allegedly configured to translate commands from a server-side protocol (e.g., TCP/IP) into various field-device protocols like Modbus, analog, and digital outputs. | ¶56 | col. 17:12-22 |
| obtaining, with the first computing system, site data and storing the site data in a report buffer...such that the site data...is not lost in the absence of the network connection... | The complaint alleges the Accused System collects and stores data from field devices in its "cloud-based infrastructure," which functions as the claimed report buffer. | ¶58 | col. 17:25-31 |
| sending, with the first computing system, the site data stored in the report buffer to a remote second computing system. | The complaint alleges that the on-site PLCs send data to the remote "Ignition Server," which functions as the claimed "remote second computing system." | ¶59 | col. 17:32-35 |
- Identified Points of Contention:
- Scope Questions: A central question may be the definition of the "first computing system." The patent's specification consistently describes an integrated, local "site master-controller" (e.g., ’184 Patent, Fig. 1), whereas the complaint alleges infringement by a distributed architecture combining on-site PLCs with a remote, cloud-based "Ignition Server." The resolution may depend on whether the claim term can be construed to cover such a distributed system.
- Technical Questions: The complaint's evidence for the system being "operative to maintain control... in an absence of an external network connection" relies on marketing statements like "control your field devices" (Compl. ¶55, p. 24). The case may turn on what level of "control" is maintained offline and whether it meets the standard contemplated by the patent, which was designed to solve the problem of complex logic failing during network outages.
- Technical Questions: What evidence demonstrates that the Accused System's data storage functions as the claimed "report buffer"—specifically, that it buffers data because of a network outage for later transmission? The court will likely need to distinguish this claimed functionality from general data logging or cloud storage.
V. Key Claim Terms for Construction
The Term: "first computing system"
Context and Importance: This term is the central component of the claimed invention. Its construction is critical because the infringement theory appears to map this term to a combination of a local PLC and a remote cloud server. Practitioners may focus on this term to determine if the patent covers modern, distributed cloud/edge architectures or is limited to the more self-contained, on-premises "site master-controller" described in the patent's detailed description.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself uses the general term "first computing system" rather than the more specific "site master-controller" used throughout the specification. This could suggest the patentee did not intend to limit the claim to the specific embodiment shown in the figures.
- Evidence for a Narrower Interpretation: The specification repeatedly describes a local "site master-controller 18" as the entity performing the key claim functions of translating protocols, maintaining control offline, and buffering data locally (’184 Patent, col. 11:20-31). The patent summary also describes a system where the processors, network interface, and memory are communicatively coupled, suggesting a more integrated unit (’184 Patent, col. 2:17-25).
The Term: "report buffer... such that the site data in the report buffer is not lost in the absence of the network connection"
Context and Importance: This term is key to the invention's claimed resilience. The infringement analysis depends on whether the accused "cloud-based infrastructure" (Compl. ¶58) performs the specific function of a buffer that retains data during a network outage for subsequent transmission.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "report buffer" is not explicitly defined and could be interpreted broadly to mean any temporary data store.
- Evidence for a Narrower Interpretation: The claim links the buffer's function directly to the "absence of the network connection." The specification explains this feature solves the problem of data loss when "network access ceases intermittently" (’184 Patent, col. 11:28-31). This suggests the term requires a specific function of caching data locally at the "edge" during an outage, not merely storing it remotely in the cloud.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that TankLogix encourages its customers to infringe by providing "product manuals and other technical information" that instruct on the use of the Accused System (Compl. ¶44). It also alleges contributory infringement on the basis that the Accused System is especially adapted for infringement and is not a staple article of commerce (Compl. ¶45).
- Willful Infringement: The complaint alleges willful infringement based on TankLogix’s knowledge of the ’184 Patent "since at least as early as the filing of this lawsuit." It also makes a more speculative allegation of pre-suit knowledge based on the possibility that "TankLogix employees have accessed the patent information on SitePro’s website" (Compl. ¶46).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "first computing system," which in the patent's embodiments refers to an integrated on-site controller, be construed to read on the accused distributed architecture combining local PLCs with a remote, cloud-based server? The viability of the infringement case may depend heavily on the court’s construction of this term.
- A key evidentiary question will be one of functional operation: does the Accused System's functionality truly match the patent's claimed solutions to prior art failures? Specifically, the case will require technical evidence to prove (1) that the system maintains complex control logic during a network outage, beyond standard PLC operation, and (2) that its data storage acts as a "report buffer" to specifically cache and forward data lost during such an outage, as required by the claims.