Oil States Energy Services, LLC v. Worldwide Oilfield Machine, Inc.

CourtDistrict Court, S.D. Texas
DecidedFebruary 27, 2024
Docket4:23-cv-00557
StatusUnknown

This text of Oil States Energy Services, LLC v. Worldwide Oilfield Machine, Inc. (Oil States Energy Services, LLC v. Worldwide Oilfield Machine, Inc.) 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
Oil States Energy Services, LLC v. Worldwide Oilfield Machine, Inc., (S.D. Tex. 2024).

Opinion

February 28, 2024 UNITED STATES DISTRICT COURT Nathan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

OIL STATES ENERGY SERVICES, LLC, § § Plaintiff, § § VS. § CIVIL ACTION NO. 4:23-CV-0557 § WORLDWIDE OILFIELD MACHINE, § INC., § § Defendant. § §

MEMORANDUM & ORDER Before the Court are the claim construction briefs in this patent infringement suit. On February 23, 2024, the Court held a hearing, in accordance with Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996), during which the parties presented arguments in support of their proposed constructions. After considering the arguments of counsel, the evidence, and the applicable law, the Court finds that the disputed claims of the patents-in-suit should be construed as set forth herein. I. BACKGROUND Plaintiff Oil States Energy Services, LLC (“Oil States”) brought this case alleging infringement of U.S. Patent Nos. 10,969,023 (the “’023 Patent”) and 11,028,929 (the “’929 Patent”) (collectively, “Asserted Patents”) against Defendant Worldwide Oilfield Machine, Inc. (“WOM”).

1 A. Technological Background The Asserted Patents relate to sealing technology for valves that are most commonly (but not exclusively) used in oil and gas production. Valves typically contain an interior bore through which fluid can pass, as well as a means of sealing the bore to stop the flow of fluid, as shown in the figure below. ’023 Patent col. 1 1. 16-18, ECF No. 40-1. ' The parties agree that the type of flow barrier used is irrelevant to the Asserted Patents and instant dispute. 100 , : FI. 3- Ht (3) it) ‘ts pe ag 7S \) Las © 4 \. ZAK of =f — — + fg i a Ap; (7 : St | “i ue i ff y i ee ff as, fd ft Af ! ; an rx } TSS dal pe 2) oJ J # 7

Ae □□ of _ -” on f/f 4 ft < / Tl : Bos ff fe if Sf A i Lf f/f fi Sf Y CP : (A 3 gf FIG, 2

Pl.’s Br. 6, ECF No. 48 (annotation of ’023 Patent at fig. 2). Traditional valve designs only seal on one side of the valve—generally, the downstream side. ’023 Patent col. 1 1. 61-67. Further, in traditional designs, the “seat” of the valve—that is, the part of the valve that exerts pressure against the bore to seal it—only contacts the plug when the valve is closed. /d. For instance, in the above figure, the sealing surface—where the blue and green parts of the figure

! The Asserted Patents share a common specification and figures, and differ only in claim language. Therefore, any citation to the specifications and figures of one patent is effectively a citation to both Asserted Patents.

meet—would typically not be engaged because the valve is open. Such designs are susceptible to various problems affecting the functionality and longevity of the valve. For example, chemicals and particulates can make their way into the gap between the sealing surface and the bore when the seal is not engaged (i.e., when the valve is open), which can degrade sealing surfaces and/or physically interfere with the formation of a seal. Jd. at col. 1 1. 67—col. 2 |. 12. Further, traditional valves are typically made up of rubber or elastomer, which have an increased risk of degradation. Id. at col. 1 1. 51-60. The Asserted Patents purport to solve these performance and longevity problems by utilizing asymmetric pressure acting on the radial surfaces of the seat such that the seat is maintained in sealing contact with the plug body regardless of whether the valve is in the open or closed position, id. at col. 2 1. 62-64, as demonstrated in the below figure. err ae a gee if Yo OL) I I | Seat bustin r// !

i vest | 1 .Pae—"t / 1 pe I l ea — 1 A‘. 700~ 5

a a eee ed Def.’s Resp. Br. 7, ECF No. 49 (annotation of ’023 Patent fig. 8). The Asserted Patents’ common specification explains that “[w]Jhen the valve is in the open condition, the fluid in the interior bore exerts pressure on both surface areas of the seat but, due to a differential in the two surface areas,” that is, the pink surface area being smaller than the red surface area, “a net

positive force tends to urge the seat into sealing engagement with the flow barrier.” ’023 Patent col. 3 l. 4–8. And, when the valve is in the closed position, the force differential leads to a double seal. Id. at col. 3 l. 17–20. The constant double seal avoids the above-described problems caused by chemicals and particulates getting between the sealing surface and the flow barrier. Another advantage of the technology is that it allows for a metal-to-metal seal, rather than the more easily degraded but more common rubber or elastomeric seals. Id. at col. 2 l. 61–col. 3 l. 2, col. 3 l. 21– 27. II. APPICABLE LAW

A. Claim Construction Claim construction is a matter of law, and the task of determining the proper construction of disputed terms therefore lies with the Court. Markman, 517 U.S. at 384. The goal of a Markman hearing is to arrive at the ordinary and customary meaning of claim terms in the eyes of a person of ordinary skill in the art (“POSITA”). Phillips v. AWH Corp., 415 F.3d 1303, 1313 (Fed. Cir. 2005) (en banc). 1. Ordinary Meaning In some instances, this inquiry is quite straightforward. That is, where ordinary meaning is “readily apparent even to lay judges,” district courts merely apply “the widely accepted meaning” of the terms, perhaps with the aid of “general purpose dictionaries.” Phillips, 415 F.3d at 1313;

see also Mentor H/S, Inc. v. Med. Device Alliance, Inc., 244 F.3d 1365, 1380 (Fed. Cir. 2001) (finding no error in the lower court’s refusal to construe “irrigating” and “frictional heat”); Biotec Biologische Naturverpackungen GmbH & Co. KG v. Biocorp, Inc., 249 F.3d 1341, 1349 (Fed. Cir. 2001) (finding no error in non-construction of “melting”). Indeed, “[a] district court is not 4 obligated to construe terms with ordinary meanings, lest trial courts be inundated with requests to parse the meaning of every word in the asserted claims.” Shell Glob. Sols. (US) Inc. v. RMS Eng’g, Inc., 782 F. Supp. 2d 317, 334 (S.D. Tex. 2011) (Ellison, J.). 2. Intrinsic Evidence In most cases, though, claim terms have a particular meaning in the field that may not be readily apparent. See Phillips, 415 F.3d at 1341. In such a scenario, courts look first to intrinsic evidence to decide if it clearly and unambiguously defines the disputed terms of the claim. Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1585 (Fed. Cir. 1996). “Such intrinsic

evidence is the most significant source of the legally operative meaning of disputed claim language.” Id. at 1582; Personalized Media Commc’ns, LLC v. Apple Inc., 952 F.3d 1336, 1340 (Fed. Cir. 2020) (“When construing claim terms, we first look to, and primarily rely on, the intrinsic evidence . . . which is usually dispositive.” (quoting Sunovion Pharms., Inc. v. Teva Pharms. USA, Inc., 731 F.3d 1271, 1276 (Fed. Cir. 2013))). The intrinsic evidence includes the claims themselves, the specification, and the prosecution history. Phillips, 415 F.3d at 1314. i. Claim Language An examination of the intrinsic evidence begins with the claim language. Immunex Corp. v. Sanofi-Aventis U.S. LLC, 977 F.3d 1212, 1218 (Fed. Cir. 2020). The claims themselves can provide substantial guidance as to the meaning of terms. Phillips, 415 F.3d at 1314. The context

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Oil States Energy Services, LLC v. Worldwide Oilfield Machine, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/oil-states-energy-services-llc-v-worldwide-oilfield-machine-inc-txsd-2024.