Satellite Industries Inc v. Jag Mobile Solutions Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Satellite Industries, Inc. (Minnesota)
  • Defendant: JAG Mobile Solutions, Inc. (Indiana); Kurt J. Honer (Indiana); William L. Gibson (Indiana)
  • Plaintiff’s Counsel: Dentons Bingham Greenebaum LLP; Carlson, Caspers, Vandenburgh & Lindquist, P.A.
• Case Identification: 1:26-cv-00080, N.D. Ind., 02/16/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Indiana because all defendants are residents of the State of Indiana and reside within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its trailer step assemblies do not infringe five patents, owned by the individual defendants, related to retractable stair assemblies for mobile trailers.
• Technical Context: The dispute centers on retractable stair assemblies for vehicles like restroom trailers, a key feature for providing safe access from an elevated trailer floor to the ground.
• Key Procedural History: This action follows a cease and desist letter sent on behalf of Defendant JAG Mobile Solutions on June 23, 2025, which accused the Plaintiff of infringement and demanded cessation of sales. The complaint also alleges that Defendant Gibson subsequently made statements to Plaintiff's customers asserting that a lawsuit was forthcoming. The complaint notes that after a prior declaratory judgment action was filed in Minnesota, counsel for JAG informed Plaintiff that JAG itself had no legal interest in the patents-in-suit.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,850,669 - "Trailer Step Assembly"

Issued December 1, 2020

The Invention Explained

• Problem Addressed: The patent describes conventional retractable trailer stairs as being typically installed underneath the trailer frame (ʼ669 Patent, col. 1:35-37). This position exposes the assembly to rain, road salt, and debris, making it vulnerable to damage and corrosion ʼ669 Patent, col. 1:37-40 Furthermore, this under-slung position requires a "lift mechanism" to elevate the top step to be level with the trailer floor, which adds complexity, cost, and potential danger ʼ669 Patent, col. 1:47-54
• The Patented Solution: The invention proposes a retractable stair assembly that is housed within an "interior cavity" of the trailer frame itself, for example, between the main frame platform and a subfloor ʼ669 Patent, col. 2:19-23 ʼ669 Patent, Fig. 5 When deployed, the assembly extends laterally out from the side of the frame, rather than from underneath it ʼ669 Patent, col. 2:23-26 This placement protects the assembly from the elements when stowed and allows the top platform of the stairs to be substantially level with the trailer floor without needing a complex lifting mechanism ʼ669 Patent, col. 3:35-40
• Technical Importance: This design purports to increase the durability and simplify the mechanics of retractable stairs for trailers by integrating the storage of the assembly within the protective structure of the trailer's main frame.

Key Claims at a Glance

• The complaint focuses on independent claim 1, a method claim Compl. ¶59
• Essential elements of Claim 1:
  • Providing a trailer with a specific frame structure (a frame platform, at least one structural beam, and a subfloor defining an interior cavity).
  • Providing a retractable stair assembly in a stowed position at least partially within that interior cavity.
  • Moving the retractable stair assembly from the stowed position to a deployed position extending out of the trailer frame.

U.S. Patent No. 10,647,261 - "Trailer Step Assembly"

Issued May 12, 2020

The Invention Explained

• Problem Addressed: As with the related ʼ669 Patent, the ʼ261 Patent addresses the disadvantages of conventional retractable stairs that are stowed underneath a trailer, including exposure to the elements and the need for a lift mechanism ʼ261 Patent, col. 1:35-54
• The Patented Solution: The patent claims a trailer apparatus incorporating the improved retractable stair assembly. The solution is a trailer constructed with an "interior cavity" within its frame, defined by a frame platform, a subfloor, and at least one structural beam ʼ261 Patent, col. 7:1-12 The retractable stair assembly is designed to be movable between a stowed position inside this protective cavity and a deployed position where it "extends laterally out of a side of the trailer frame through an opening in the at least one structural beam" ʼ261 Patent, col. 7:45-53
• Technical Importance: This patented apparatus provides a structural solution for integrating a retractable stair assembly into a trailer's frame, aiming for improved durability, weather resistance, and mechanical simplicity compared to prior art designs.

Key Claims at a Glance

• The complaint focuses on independent claim 1, an apparatus claim Compl. ¶66
• Essential elements of Claim 1:
  • A trailer frame including a frame platform and at least one structural beam.
  • A subfloor spaced from the frame platform, defining an interior cavity.
  • A retractable stair assembly movable between a stowed position (within the interior cavity) and a deployed position.
  • In the deployed position, the stair assembly extends laterally out of a side of the trailer frame through an opening in the at least one structural beam.

U.S. Patent No. 10,518,708 - "Trailer Step Assembly"

Issued December 31, 2019

• Patent Identification: U.S. Patent No. 10,518,708, "Trailer Step Assembly," issued December 31, 2019.
• Technology Synopsis: The ʼ708 Patent claims a method of moving a retractable stair assembly between a stowed position within an interior cavity of a trailer frame and a deployed position extending out from the frame. The technology is substantially similar to that described for the ʼ669 Patent.
• Asserted Claims: The complaint asserts non-infringement of the claims, citing independent claim 1 as an example Compl. ¶73
• Accused Features: The "Accused Step Assembly" on Plaintiff's portable restroom trailers is accused of infringing this patent (Compl. ¶¶26; 72).

U.S. Patent No. 10,525,891 - "Trailer Step Assembly"

Issued January 7, 2020

• Patent Identification: U.S. Patent No. 10,525,891, "Trailer Step Assembly," issued January 7, 2020.
• Technology Synopsis: The ʼ891 Patent claims a trailer apparatus that includes a retractable stair assembly. The technology, which involves stowing the assembly within an interior frame cavity and deploying it through a gap in a structural beam, is substantially similar to that described for the ʼ261 Patent.
• Asserted Claims: The complaint asserts non-infringement of the claims, citing independent claim 1 as an example (Compl. ¶¶51; 80).
• Accused Features: The "Accused Step Assembly" on Plaintiff's portable restroom trailers is accused of infringing this patent (Compl. ¶¶26; 79).

U.S. Patent No. 11,731,562 - "Trailer Step Assembly"

Issued August 22, 2023

• Patent Identification: U.S. Patent No. 11,731,562, "Trailer Step Assembly," issued August 22, 2023.
• Technology Synopsis: The ʼ562 Patent claims a method of moving a retractable stair assembly. The disclosed technology of stowing the assembly within and deploying it from an interior frame cavity is substantially similar to that described for the ʼ669 Patent.
• Asserted Claims: The complaint asserts non-infringement of the claims, citing independent claim 1 as an example Compl. ¶87
• Accused Features: The "Accused Step Assembly" on Plaintiff's portable restroom trailers is accused of infringing this patent (Compl. ¶¶26; 86).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the "Accused Step Assembly" used on certain of Plaintiff Satellite's portable restroom trailers Compl. ¶26

Functionality and Market Context

The complaint describes the accused product as a "trailer step assembly" that facilitates consumers entering and exiting trailer products (Compl. ¶¶4; 25). A photo shows the accused step assembly deployed from the side of a Satellite portable restroom trailer Compl. ¶26 The complaint alleges that Plaintiff has sold or offered for sale in the United States trailers incorporating this assembly Compl. ¶27 The complaint does not provide a detailed technical description of the Accused Step Assembly's structure or operation, focusing instead on what it allegedly does not do in relation to the patent claims.

IV. Analysis of Infringement Allegations

The complaint is for declaratory judgment of non-infringement. It does not provide a detailed element-by-element analysis but instead advances a specific, targeted argument for non-infringement that is consistent across all five patents-in-suit. The core of this argument is that Plaintiff's product does not "extend[] out of the trailer frame" or "through a gap in the at least one structural beam" as required by the claims (Compl. ¶¶59; 66; 73; 80; 87). A patent figure depicts the claimed stair assembly extending through a gap in a structural beam Compl. ¶52

’261 Patent Infringement Allegations

The complaint makes a similar non-infringement argument for the method claims of the ʼ669 Patent, stating the Accused Trailer Step Assembly does not "extend[] out of the trailer frame" Compl. ¶59

Identified Points of Contention

• Scope Questions: The central dispute appears to hinge on the definition of "trailer frame" and "structural beam." The case may depend on whether the structure from which the accused assembly deploys is considered part of the "trailer frame" as that term is used in the patents.
• Technical Questions: A key factual question will be the precise mechanical and structural relationship between the Accused Step Assembly and the chassis of the Satellite trailer. Discovery will likely focus on engineering diagrams and the physical operation of the accused product to determine if it extends "laterally out of a side of the trailer frame" and "through an opening" in a component that meets the claim definition of a "structural beam."

V. Key Claim Terms for Construction

The Term: "trailer frame"

• Context and Importance: Plaintiff's entire non-infringement theory is premised on its product not extending "out of the trailer frame" (Compl. ¶¶59, 73, 87). The definition of this term is therefore dispositive. Practitioners may focus on this term because its scope will determine whether the location from which the accused product deploys falls within the claimed structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims do not appear to limit the "trailer frame" to any particular configuration beyond including a platform and at least one beam. One could argue it should be given its plain and ordinary meaning, encompassing the overall chassis or understructure of the trailer.
  • Evidence for a Narrower Interpretation: The specification consistently describes the "trailer frame" in the context of a specific structure that defines an "interior cavity" (e.g., ʼ261 Patent, col. 2:21-22). The figures show the "trailer frame 126" as comprising a "frame platform 128" and "structural beams 130, 132" that work together to create this cavity ('261 Patent, col. 4:51-59). This may support an argument that "trailer frame" should be construed as this specific cavity-defining assembly, not just any part of the trailer's chassis.

The Term: "structural beam"

• Context and Importance: The claims require the stair assembly to extend "through a gap" or "an opening" in this beam ʼ261 Patent, cl. 1 Plaintiff's non-infringement argument relies on this limitation (Compl. ¶¶66, 80). The case will turn on whether the accused product passes through a component that qualifies as the claimed "structural beam."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is common, and an argument could be made that it refers to any major load-bearing component of the trailer's chassis.
  • Evidence for a Narrower Interpretation: The specification depicts the "structural beam" (130, 132) as a specific longitudinal member that forms the side of the "interior cavity" where the stairs are stowed (ʼ261 Patent, Fig. 5; ʼ261 Patent, col. 4:55-59). The patent contrasts its invention, which goes through this beam, with prior art that is stowed below the frame structure ʼ261 Patent, col. 5:7-13 This context may support a narrower construction tied to a beam that defines the side of the storage cavity.

VI. Other Allegations

The complaint, being an action for declaratory judgment of non-infringement, does not allege indirect or willful infringement by the Defendants. However, it does provide context regarding the Defendants' pre-suit allegations against the Plaintiff.

• Indirect Infringement: The complaint does not contain allegations of indirect infringement.
• Willful Infringement: The complaint alleges that the June 23, 2025 letter sent on behalf of Defendant JAG accused Satellite of "willful infringement" Compl. ¶31 It also alleges Defendant Gibson told one of Satellite's customers that the Accused Step Assembly was "willfully infringing" Compl. ¶41 These allegations are noted as part of the basis for the existence of a justiciable controversy.

VII. Analyst’s Conclusion: Key Questions for the Case

This declaratory judgment action appears poised to center on a focused, structural non-infringement dispute, alongside a threshold question of patent ownership.

• A core issue will be one of claim construction: how will the court define the term "trailer frame"? Can it be broadly interpreted to mean the general undercarriage of the trailer, or will it be narrowly construed to mean the specific multi-part structure that defines the "interior cavity" as detailed in the patent specification?
• A key evidentiary question will be one of structural fact: what is the precise physical arrangement of the Accused Step Assembly relative to the chassis of the Satellite trailer? The outcome will depend on whether evidence shows the assembly extending "out of" the construed "trailer frame" and "through" a component that meets the definition of the claimed "structural beam".
• A potential threshold issue concerns patent standing and ownership: the complaint alleges that Defendant JAG Mobile Solutions, Inc. has no legal interest in the patents-in-suit, and that they are owned solely by the individual inventor defendants (Compl. ¶¶49-50). This raises a question of which parties have the right to allege infringement and are proper defendants for this declaratory judgment action.