DCT
2:25-cv-00679
Liftwerx USA Inc v. Liftra IP ApS
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LiftWerx USA Inc. (Delaware)
- Defendant: Liftra IP ApS (Denmark)
- Plaintiff’s Counsel: Dechert, LLP
- Case Identification: 2:25-cv-00679, E.D. Va., 10/23/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation not resident in the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its up-tower wind turbine repair systems do not infringe Defendant’s patents related to main shaft fixtures used for such repairs.
- Technical Context: The technology concerns specialized fixtures that allow for major repairs on wind turbine components within the nacelle (the housing at the top of the tower), a method that avoids the significant cost of using large ground-based cranes.
- Key Procedural History: The complaint asserts that an actual controversy exists due to Defendant's litigation campaign against Plaintiff’s corporate affiliates in Europe and Canada over counterpart patents. This history allegedly gives Plaintiff a reasonable apprehension of being sued for infringement in the U.S., forming the basis for this declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2014-10-07 | Priority Date for '518 and '578 Patents |
| 2019-08-13 | U.S. Patent No. 10,378,518 Issued |
| 2024-09-20 | Defendant's Affiliate Made European Seizure Request |
| 2024-10-01 | U.S. Patent No. 12,104,578 Issued |
| 2024-11-01 | European Seizure Executed (approx. date) |
| 2025-03-21 | Defendant's Affiliate Initiated European Access Proceedings |
| 2025-05-16 | Defendant's Affiliate Filed European Infringement Complaint |
| 2025-07-18 | Defendant's Affiliate Filed Canadian Infringement Complaint |
| 2025-10-23 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,378,518 - "Main Shaft Fixture"
The Invention Explained
- Problem Addressed: The patent's background describes the difficulty and cost of servicing heavy components (like gearboxes or generators) inside a wind turbine nacelle. Prior methods required specialized fixtures that were often inflexible for different turbine shaft geometries and necessitated a prolonged, costly shutdown of the turbine for installation (Compl. ¶2; ’518 Patent, col. 1:19-51).
- The Patented Solution: The invention is a modular main shaft fixture that can be mounted on existing stable structures within the nacelle. Its key feature is a set of at least three "radially displaceable pressure mandrels" equipped with "tap shoes." These mandrels can be adjusted to securely grip main shafts of varying shapes and sizes, providing greater universality. The system is designed to be installed without first halting the turbine's rotor and can incorporate a "rotor lock" to fix the main shaft in place when required for repairs (’518 Patent, col. 2:12-30, col. 3:59-62).
- Technical Importance: This approach aims to reduce turbine downtime and eliminate the need for different custom fixtures for each type of turbine, thereby lowering operational and maintenance costs in the wind energy industry (’518 Patent, col. 2:12-16).
Key Claims at a Glance
- The complaint seeks a declaration of non-infringement for claims 1-8 (Compl. ¶59). The independent claims are 1 and 2.
- Independent Claim 1: A main shaft fixture comprising:
- at least three radially displaceable pressure mandrels with tap shoes, displaceable between a passive and an advanced lockable position;
- a rotor lock for fixation of the rotor; and
- one of a multi-part needle bearing, roller bearing, or ball bearing comprised of a multi-part inner ring and a cooperating multi-part outer ring.
- Independent Claim 2: A main shaft fixture comprising:
- at least three radially displaceable pressure mandrels with tap shoes, displaceable between a passive and an advanced lockable position; and
- a rotor lock for fixation of the rotor, wherein the rotor lock is comprised of a flange element fastened to two beam-shaped brackets.
U.S. Patent No. 12,104,578 - "Main Shaft Fixture"
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’518 Patent, the ’578 Patent addresses the same technical challenges of safely and efficiently servicing heavy wind turbine components up-tower (’578 Patent, col. 1:21-49).
- The Patented Solution: The ’578 Patent claims a similar main shaft fixture with adjustable pressure mandrels but focuses on combinations of features including "mounting facilities adapted for anchoring a crane" directly onto the fixture. This integration allows a crane, such as a self-hoisting crane with a ground-based winch, to be mounted simultaneously with the shaft-fixing apparatus, which streamlines the repair process and saves space in the constrained nacelle environment (’578 Patent, col. 2:30-33, col. 2:58-62). Figure 1 illustrates the fixture (10) supporting a lightweight crane (12) and a self-hoisting crane (14) (’578 Patent, col. 5:6-14).
- Technical Importance: Integrating crane mounting facilities directly into the shaft fixture provides an all-in-one solution for both securing the drivetrain and lifting heavy components, further reducing the complexity and cost of up-tower maintenance (’578 Patent, col. 2:62-67).
Key Claims at a Glance
- The complaint seeks a declaration of non-infringement for claims 1-17 (Compl. ¶73). The independent claims are 1, 15, and 16.
- Independent Claim 1: A main shaft fixture comprising:
- adjustable pressure mandrels with tap shoes, displaceable between a passive and an active position; and
- mounting facilities adapted for anchoring a crane on/in a nacelle of a wind turbine.
- Independent Claim 15: A main shaft fixture comprising:
- adjustable pressure mandrels with tap shoes, where the mandrels consist of threaded bolts; and
- mounting facilities adapted for anchoring a crane on/in a nacelle of a wind turbine.
- Independent Claim 16: A main shaft fixture comprising:
- adjustable pressure mandrels with tap shoes;
- mounting facilities adapted for anchoring a crane; and
- a rotor lock for fixation of a rotor of the wind turbine.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities generally as "LiftWerx USA's up-tower lifting technologies, solutions, products and services" (Compl. ¶59).
Functionality and Market Context
- The complaint does not describe the specific functionality of the accused products. Instead, as a complaint for declaratory judgment of non-infringement, it focuses on enumerating the patented features that its products and services allegedly lack (Compl. ¶¶60, 74). The complaint frames LiftWerx as a specialist in "up-tower wind turbine corrective repairs using novel lifting solutions" that lower costs by "exchanging major components without the need for large traditional cranes" (Compl. ¶2).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint makes detailed allegations of non-infringement. The following tables summarize Plaintiff's exemplary grounds for asserting that its products do not meet certain limitations of the asserted independent claims.
’518 Patent Non-Infringement Allegations
| Claim Element (from Independent Claim 1) | Plaintiff's Alleged Basis for Non-Infringement | Complaint Citation | Patent Citation |
|---|---|---|---|
| further comprising a rotor lock (24) for fixation of the rotor (8) of the wind turbine | Plaintiff alleges its products do not include this feature. | ¶60.v | col. 6:65-67 |
| further comprising one of a multi-part needle bearing, roller bearing, or ball bearing (46) comprised of a multi-part inner ring (48) fastened to the main shaft (4) | Plaintiff alleges its products do not include this feature. | ¶60.vi | col. 7:1-4 |
| a therewith cooperating multi-part outer ring (50) comprised of bowed sub-segments (52) | Plaintiff alleges its products do not include this feature. | ¶60.vii | col. 7:4-8 |
’578 Patent Non-Infringement Allegations
| Claim Element (from Independent Claim 1) | Plaintiff's Alleged Basis for Non-Infringement | Complaint Citation | Patent Citation |
|---|---|---|---|
| adjustable pressure mandrels with tap shoes | Plaintiff alleges its products do not include this feature. | ¶74.ii | col. 7:8-9 |
| mounting facilities adapted for anchoring a crane on/in a nacelle of a wind turbine | Plaintiff alleges its products do not include this feature. | ¶74.iv | col. 7:13-15 |
- Identified Points of Contention: The analysis centers on Plaintiff's negative allegations, which frame the likely points of dispute.
- Factual Questions: A primary point of contention will be factual: do the accused LiftWerx products and services, in fact, include the elements they claim to lack? For example, the case may turn on evidence demonstrating whether the accused systems contain a "rotor lock" or a "multi-part needle bearing" as recited in the ’518 Patent, or "mounting facilities adapted for anchoring a crane" as recited in the ’578 Patent.
- Scope Questions: The dispute raises the question of whether certain components of the accused systems perform the functions required by the claims, even if they are not explicitly named as such. For instance, does a braking system in the accused product meet the definition of a "rotor lock"? Does a structural hardpoint on the accused fixture meet the definition of "mounting facilities adapted for anchoring a crane"?
V. Key Claim Terms for Construction
The Term: "rotor lock" (’518 Patent, Claim 1)
Context and Importance: Plaintiff's non-infringement argument relies heavily on the assertion that its products lack a "rotor lock" (Compl. ¶60.v). The definition of this term is therefore central to the dispute. Practitioners may focus on whether this term requires a specific structure or can be met by any component that fixes the rotor.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the purpose of the rotor lock as being "for fixing the wind turbine rotor" (’518 Patent, col. 3:62). This functional language could support an interpretation that covers any mechanism capable of achieving this result.
- Evidence for a Narrower Interpretation: The patent describes a preferred embodiment in detail as being "comprised of a flange, whose bolt circle geometry corresponds to a bolt circle geometry on the rotor," which is then bolted in place (’518 Patent, col. 3:63-col. 4:10). This specific structural description could support a narrower construction limited to such a flange-based mechanism.
The Term: "mounting facilities adapted for anchoring a crane" (’578 Patent, Claim 1)
Context and Importance: Plaintiff alleges its products do not have this feature (Compl. ¶74.iv). The interpretation of "adapted for" will be critical. The dispute will likely involve whether a component must be specifically designed for anchoring a crane or if it is sufficient that a component is merely suitable or capable of being used for that purpose.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification broadly states the fixture "may comprise mounting facilities for a self-hoisting crane" (’578 Patent, col. 2:58-62). This suggests the facility is an added, but not structurally limited, capability.
- Evidence for a Narrower Interpretation: The patent shows specific "bracket facilities" (23) for a self-hoisting crane and separate "mounting facilities" (40) for a lightweight crane (’578 Patent, col. 5:33-36, col. 6:1-3). This could support an argument that "mounting facilities" refers to these specific, purpose-built structures rather than any general-purpose attachment point.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiff does not "directly or indirectly infringe" the patents-in-suit (Compl. ¶¶59, 73). As a declaratory judgment complaint filed by the accused infringer, it does not set forth the patentee's potential factual basis for such an indirect infringement claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be factual and evidentiary: Do the accused LiftWerx systems, when analyzed, actually contain the specific mechanical structures recited in the patent claims, such as a "rotor lock" and a "multi-part needle bearing," which LiftWerx's complaint explicitly denies having? The outcome will depend heavily on a direct technical comparison of the accused products to the claim language.
- The case will also turn on a question of claim scope and construction: Can terms like "rotor lock" and "mounting facilities adapted for anchoring a crane" be interpreted broadly enough to read on components of the accused systems that may serve similar functions but have different structures? The court's construction of these key terms will likely determine whether Plaintiff's design choices successfully avoid the scope of the patent claims.