Deep Fix, LLC v. Marine Well Containment Company LLC

CourtDistrict Court, S.D. Texas
DecidedAugust 12, 2019
Docket4:18-cv-00948
StatusUnknown

This text of Deep Fix, LLC v. Marine Well Containment Company LLC (Deep Fix, LLC v. Marine Well Containment Company LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Deep Fix, LLC v. Marine Well Containment Company LLC, (S.D. Tex. 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT August 12, 2019 FOR THE SOUTHERN DISTRICT OF TEXAS David J. Bradley, Clerk HOUSTON DIVISION DEEP FIX, LLC, § Plaintiff, § § v. § CIVIL ACTION NO. H-18-0948 § MARINE WELL CONTAINMENT § COMPANY LLC, § Defendant. § MEMORANDUM AND ORDER This patent case is before the Court on the “Motion for Partial Judgment on the Pleadings and to Dismiss Defendant’s Inequitable Conduct Claims Pursuant to Fed. R. Civ. P. 9(b) and 12(c)” (“Motion to Dismiss”) [Doc. # 137] filed by Plaintiff Deep Fix, LLC (“Deep Fix”). Defendant Marine Well Containment Company LLC (“MWCC”) filed an Opposition [Doc. # 148] to the Motion to Dismiss, and Deep Fix filed a Reply [Doc. # 155]. Having reviewed the record, with particular attention to the allegations in Defendant’s Fourth Amended Answer [Doc. # 60], and having applied relevant legal authorities, the Court denies the Motion to Dismiss. I. BACKGROUND

Charles Adams is the sole inventor of the cap valve covered by the ’393 Patent. Through a series of assignments, Deep Fix asserts sole ownership of all interest in the ’393 Patent.

P:\ORDERS\11-2018\0948MDAffDefense.wpd 190812.0812 MWCC is a consortium of oil and gas companies including ExxonMobil, British Petroleum (“BP”), and others. MWCC manufactures oil and gas well

containment systems used in well blowout situations. On September 3, 2010, Adams filed a provisional patent application for his cap valve invention. See Complaint [Doc. # 1], ¶ 14. On September 2, 2011, Adams filed

a non-provisional patent application and claimed priority based on the provisional patent application filed in 2010. See id. The ’393 Patent issued on September 16, 2014. See id.

Deep Fix filed this patent infringement lawsuit on March 26, 2018, alleging that three well containment systems manufactured by MWCC infringe the claims of the ’393 Patent. MWCC filed its Answer on June 18, 2018. In the Answer, MWCC asserted the affirmative defense of inequitable conduct. See Answer [Doc. # 31], p. 9.

On July 9, 2018, MWCC filed an Amended Answer again pleading the affirmative defense of inequitable conduct. See Amended Answer [Doc. # 34], pp. 17-23. On August 14, 2018, MWCC filed a Second Amended Answer, again asserting

inequitable conduct. See Second Amended Answer [Doc. # 46], pp. 17-23. On September 18, 2018, MWCC filed a Third Amended Answer asserting inequitable conduct. See Third Amended Answer [Doc. # 52], pp. 18-31. On November 16,

2018, MWCC filed its Fourth Amended Answer asserting inequitable conduct as the 2 P:\ORDERS\11-2018\0948MDAffDefense.wpd 190812.0812 fifth affirmative defense. See Fourth Amended Answer [Doc. # 60], pp. 24-61. On May 30, 2019, Deep Fix filed the pending Motion to Dismiss challenging the

inequitable conduct affirmative defense in the Fourth Amended Answer. The Motion to Dismiss has been fully briefed and is now ripe for decision. II. RULE 12(c) STANDARD

The standard for a motion for judgment on the pleadings under Rule 12(c) “is the same as that for dismissal for failure to state a claim under Rule 12(b)(6).” Johnson v. Johnson, 385 F.3d 503, 529 (5th Cir. 2004). The Court must accept the

well-pleaded facts in the affirmative defense as true and view them in the light most favorable to the defendant. See id. The Court should deny the 12(c) motion unless the defendant could not succeed on the affirmative defense “under any set of facts that he could prove” consistent with the affirmative defense. See id.

To plead inequitable conduct with the particularity required by Rule 9(b) of the Federal Rules of Civil Procedure, “the pleading must identify the specific who, what, when, where, and how of the material misrepresentation or omission committed before

the PTO.” Exergen Corp. v. Wal-Mart Stores, Inc., 575 F.3d 1312, 1328 (Fed. Cir. 2009); Sanders v. The Mosaic Co., 418 F. App’x 914, 918 (Fed. Cir. Apr. 20, 2011). At the pleading stage, however, the party asserting inequitable conduct is required to

plead only those facts that support “a reasonable inference that a specific individual 3 P:\ORDERS\11-2018\0948MDAffDefense.wpd 190812.0812 knew of the misrepresentation and had the specific intent to deceive the PTO.” Exergen, 575 F.3d at 1328-29.

III. ANALYSIS A. Legal Standards for Inequitable Conduct Defense “Inequitable conduct is an equitable defense to patent infringement that, if

proved, bars enforcement of a patent.” In re Rembrandt Techs. LP Patent Litig., 899 F.3d 1254, 1272 (Fed. Cir. 2018) (quoting Therasense, Inc. v. Becton, Dickinson & Co., 649 F.3d 1276, 1285 (Fed. Cir. 2011) (en banc)). “To prevail on the defense of

inequitable conduct, the accused infringer must prove that the applicant misrepresented or omitted material information with the specific intent to deceive the [Patent and Trademark Office (“PTO”)].” Id. (quoting Therasense, 649 F.3d at 1287). Generally, the “materiality” required for a successful inequitable conduct

defense is “but-for” materiality. See Regeneron Pharm., Inc. v. Merus N.V., 864 F.3d 1343, 1350 (Fed. Cir. 2017), cert. denied, 139 S. Ct. 122 (2018). A prior art reference is “but-for” material if the PTO “would not have allowed a claim had it been aware

of the undisclosed prior art.” Id. However, when the patentee “has engaged in affirmative acts of egregious misconduct, such as the filing of an unmistakably false affidavit, the misconduct is material” and no further showing of materiality is

required. Therasense, 649 F.3d at 1292. 4 P:\ORDERS\11-2018\0948MDAffDefense.wpd 190812.0812 The party asserting inequitable conduct must also prove “that the patentee acted with the specific intent to deceive the PTO.” See Regeneron, 864 F.3d at 1350

(quoting Therasense, 649 F.3d at 1290). “In a case involving nondisclosure of information, clear and convincing evidence must show that the applicant made a deliberate decision to withhold a known material reference.” Id. at 1351. The alleged

infringer need not present direct evidence of intent, and a court may infer intent from circumstantial evidence. Id. “An inference of intent to deceive is appropriate where the applicant engages in ‘a pattern of lack of candor,’ including where the applicant

repeatedly makes factual representations ‘contrary to the true information he had in his possession.’” Id. (quoting Apotex Inc. v. UCB, Inc., 763 F.3d 1354, 1362 (Fed. Cir. 2014)). “When a party raises inequitable conduct as a defense to patent infringement,

[t]he accused infringer must prove both elements – intent and materiality – by clear and convincing evidence.” Rembrandt Techs., 899 F.3d at 1272 (internal quotations and citation omitted). Ultimately, inequitable conduct “is an equitable issue

committed to the discretion of the trial court.” Barry v. Medtronic, Inc., 914 F.3d 1310, 1333 (Fed. Cir. 2019).

5 P:\ORDERS\11-2018\0948MDAffDefense.wpd 190812.0812 B. Allegations in Fourth Amended Answer In the Fourth Amended Answer, MWCC alleges in great detail that Adams both

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Related

Exergen Corp. v. Wal-Mart Stores, Inc.
575 F.3d 1312 (Federal Circuit, 2009)
Sanders v. The Mosaic Co.
418 F. App'x 914 (Federal Circuit, 2011)
Therasense, Inc. v. Becton, Dickinson and Co.
649 F.3d 1276 (Federal Circuit, 2011)
Apotex Inc. v. Ucb, Inc.
763 F.3d 1354 (Federal Circuit, 2014)
Regeneron Pharmaceuticals, Inc. v. Merus N.V.
864 F.3d 1343 (Federal Circuit, 2017)
Barry v. Medtronic, Inc.
914 F.3d 1310 (Federal Circuit, 2019)
Johnson v. Johnson
385 F.3d 503 (Fifth Circuit, 2004)

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Deep Fix, LLC v. Marine Well Containment Company LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deep-fix-llc-v-marine-well-containment-company-llc-txsd-2019.