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., 05/05/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Indiana because all defendants are residents of Indiana and reside in the district, and because a substantial part of the events giving rise to the claims occurred there.
• Core Dispute: Plaintiff seeks a declaratory judgment that its "Accused Trailer Step Assembly" does not infringe five patents asserted by Defendants, which relate to retractable stair assemblies for trailers.
• Technical Context: The technology concerns retractable stair systems for vehicles with elevated floors, such as mobile restroom trailers, a significant product category in the portable sanitation industry.
• Key Procedural History: This declaratory judgment action follows a June 2025 cease-and-desist letter sent on behalf of Defendant JAG Mobile Solutions, Inc. ("JAG"), accusing Plaintiff of infringement. The complaint alleges that the individual defendants, Honer and Gibson, are the joint owners of the patents-in-suit, and that JAG has no ownership interest, raising questions about JAG's standing to assert the patents and forming the basis for Plaintiff's additional claims of false advertising and tortious interference.

Case Timeline

Date	Event
2019-02-04	Earliest Priority Date for all Patents-in-Suit
2019-12-31	U.S. Patent No. 10,518,708 (''708 Patent) Issued
2020-01-07	U.S. Patent No. 10,525,891 (''891 Patent) Issued
2020-05-12	U.S. Patent No. 10,647,261 (''261 Patent) Issued
2020-12-01	U.S. Patent No. 10,850,669 (''669 Patent) Issued
2023-08-22	U.S. Patent No. 11,731,562 (''562 Patent) Issued
2025-06-23	JAG's counsel sends patent infringement notice to Satellite
2025-06-23	Satellite's counsel responds, denying infringement
2025-08-22	Defendant Gibson allegedly accuses Satellite of infringement to a Satellite employee
2025-09-14	Defendant Gibson allegedly accuses Satellite of infringement to a customer
2025-09-17	Defendant Gibson allegedly accuses Satellite of infringement to a second customer
2025-10-01	Satellite's counsel contacts Defendant Honer regarding patent ownership
2026-05-05	Amended Complaint for Declaratory Judgment filed

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 prior art retractable stairs that are installed underneath a trailer frame, exposing them to weather elements and potential damage (e.g., from rocks or steep slopes) '669 Patent, col. 1:37-47 These under-mount systems also require complex and costly lift mechanisms to elevate the top step to the trailer's floor level, creating a potentially dangerous transition if not properly elevated '669 Patent, col. 1:48-60
• The Patented Solution: The invention proposes storing the retractable stair assembly within an "interior cavity" of the trailer frame itself, specifically in the space between the frame platform and a subfloor '669 Patent, col. 8:1-4 When deployed, the stair assembly extends out from this protected cavity through an opening in a structural beam of the trailer frame '669 Patent, col. 8:17-23 This placement protects the assembly from the elements when stowed and eliminates the need for a complex lift mechanism, as the top step platform can be substantially at floor level '669 Patent, col. 3:58-65
• Technical Importance: This design offers a method to integrate retractable stairs into the trailer's structure for protection and simplified deployment, an alternative to conventional under-mount systems.

Key Claims at a Glance

• The complaint seeks a declaration of non-infringement of all claims, but specifically references independent claim 1 '669 Patent, claim 1 Compl. ¶85
• Independent Claim 1 of the '669 Patent is a method claim with the key steps of:
  • Providing a trailer with a frame, a subfloor, and an interior cavity defined between them.
  • Providing a retractable stair assembly in a stowed position "at least partially within the interior cavity."
  • Moving the assembly 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 '669 Patent, the '261 Patent addresses the disadvantages of prior art stairs mounted underneath a trailer, which leaves them vulnerable to damage and requires complicated lifting mechanisms '261 Patent, col. 1:37-2:13
• The Patented Solution: The '261 patent claims a trailer apparatus that incorporates a retractable stair assembly within an "interior cavity" formed by the trailer frame and a subfloor '261 Patent, col. 7:40-50 The assembly is designed to move from its stowed position within this cavity to 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" '261 Patent, col. 7:50-54
• Technical Importance: This patented apparatus provides a structural solution for stowing stairs inside the trailer frame, aiming for improved durability and simpler operation compared to externally mounted systems.

Key Claims at a Glance

• The complaint references independent claim 1 as a basis for its non-infringement argument Compl. ¶92
• Independent Claim 1 of the '261 Patent claims a trailer apparatus comprising:
  • A trailer frame, a subfloor, and an interior cavity defined between them.
  • A retractable stair assembly movable between a stowed position "within the interior cavity" and a deployed position.
  • In the deployed position, the assembly "extends laterally out of a side of the trailer frame through an opening in the at least one structural beam."

Multi-Patent Capsule: U.S. Patent No. 10,518,708 ('708 Patent), issued December 31, 2019

• Technology Synopsis: The '708 patent discloses a method for moving a retractable stair assembly. It addresses the same problem as the patents above by teaching a method where the stair assembly is moved from a stowed position within an interior cavity of the trailer frame to a deployed position extending outward '708 Patent, col. 7:31-35 '708 Patent, col. 8:11-23
• Asserted Claims: The complaint references independent claim 1 Compl. ¶99
• Accused Features: Plaintiff alleges its Accused Trailer Step Assembly does not "extend[] out of the trailer frame" as recited in the claim Compl. ¶99

Multi-Patent Capsule: U.S. Patent No. 10,525,891 ('891 Patent), issued January 7, 2020

• Technology Synopsis: The '891 patent claims a trailer apparatus featuring a retractable stair assembly. The invention is distinguished by the stair assembly being stowed within an interior cavity defined by the trailer frame and subfloor, and deploying by extending laterally through a gap in a structural beam '891 Patent, abstract '891 Patent, claim 1
• Asserted Claims: The complaint references independent claim 1 and quotes it as "exemplary" of the patents-in-suit Compl. ¶77 Compl. ¶106
• Accused Features: Plaintiff alleges its Accused Trailer Step Assembly does not "extend[] laterally out of a side of the trailer frame through a gap in the at least one structural beam" Compl. ¶106

Multi-Patent Capsule: U.S. Patent No. 11,731,562 ('562 Patent), issued August 22, 2023

• Technology Synopsis: The '562 patent claims a method of moving a retractable stair assembly between a deployed position and a stowed position. The method involves moving the assembly into an "interior cavity" between the trailer's subfloor and frame platform for stowage '562 Patent, claim 1
• Asserted Claims: The complaint references independent claim 1 Compl. ¶113
• Accused Features: Plaintiff alleges its Accused Trailer Step Assembly does not practice the claimed method because it does not "extend[] out of the trailer frame" from an interior cavity Compl. ¶113

III. The Accused Instrumentality

• Product Identification: The "Accused Trailer Step Assembly," which is part of a Satellite portable restroom trailer Compl. ¶41
• Functionality and Market Context: The complaint describes the accused product as a "stair assembly" used to "facilitate consumers entering and exiting certain trailer products" Compl. ¶40 Compl. ¶41 The complaint includes a photograph of the accused product, which shows a set of stairs deployed from the side of a restroom trailer Compl. ¶41 The complaint alleges that Defendants have accused this product of infringement in communications to Plaintiff and its customers in the portable sanitation industry Compl. ¶6 Compl. ¶¶51-57 The photograph provided shows the stairs of the Accused Trailer Step Assembly deployed for use Compl. ¶41

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the plaintiff's non-infringement positions as articulated in the complaint.

• '669 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
moving the retractable stair assembly from the stowed position to a deployed position extending out of the trailer frame...	Plaintiff's theory of non-infringement is that its Accused Trailer Step Assembly does not "extend[] out of the trailer frame" in the manner claimed.	¶85	col. 8:17-23
moving the retractable stair assembly from the deployed position to a stowed position in which the retractable stair assembly is disposed at least partially within the interior cavity...	The complaint's non-infringement theory implies the accused assembly is not stowed within an "interior cavity" as defined by the patent.	¶85	col. 7:52-56

• '261 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a retractable stair assembly movable between a stowed position in which the retractable stair assembly is positioned within the interior cavity of the trailer frame...	Plaintiff's non-infringement argument suggests that its Accused Trailer Step Assembly is not positioned "within the interior cavity" when stowed.	¶92	col. 7:45-48
and a deployed position in which the retractable stair assembly extends laterally out of a side of the trailer frame through an opening in the at least one structural beam...	Plaintiff specifically alleges that its assembly does not "extend[] laterally out of a side of the trailer frame through an opening in the at least one structural beam."	¶92	col. 7:50-54

• Identified Points of Contention:
  • Structural Location: The central dispute appears to be the structural location of the stair assembly. The patents consistently claim an assembly stowed within an interior cavity of the frame and deploying through a structural beam. The complaint's denial that its product "extend[s] out of the trailer frame" in the claimed manner suggests Satellite's product may be mounted externally, such as underneath the frame, similar to the prior art the patents sought to improve upon '669 Patent, col. 1:30-36 Compl. ¶¶85, 92 Figure 6 of the patent specification, included in the complaint, depicts the claimed invention extending through a gap in a structural beam Compl. ¶78
  • Scope Questions: A primary question for the court will be whether the claims, which require the stair assembly to be positioned "within the interior cavity," can be read to cover a system that may be mounted external to that cavity. The interpretation of the specific structural limitations (e.g., "interior cavity," "through an opening in the at least one structural beam") will be determinative.

V. Key Claim Terms for Construction

• The Term: "interior cavity"

• Context and Importance: This term is the lynchpin of the patented invention, distinguishing it from prior art under-mount systems. Its definition is critical because the plaintiff's non-infringement defense appears to rest on its product not being stowed within such a cavity. Practitioners may focus on this term because the entire infringement analysis hinges on whether the accused product's storage location falls within the scope of this claimed structure.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the cavity in functional terms as a space where the assembly is "protected from outside elements" '261 Patent, col. 5:9-11 A party might argue this functional goal should inform the term's scope.
  • Evidence for a Narrower Interpretation: The claims and specification consistently provide a specific structural definition. Claim 1 of the '261 patent defines it as being "between the subfloor, the frame platform, and the at least one structural beam" '261 Patent, col. 7:42-45 The specification further clarifies this as the space "above the frame platform 128" and between structural beams 130 and 132 '261 Patent, col. 5:58-63 This explicit definition may support a narrow construction limited to that precise location.

• The Term: "extends laterally out of a side of the trailer frame through an opening in the at least one structural beam"

• Context and Importance: This phrase describes the unique deployment path of the patented invention. Plaintiff's non-infringement allegation for the '261 and '891 patents directly targets this limitation Compl. ¶92 Compl. ¶106 The dispute will likely center on whether "through an opening" requires passing through the vertical plane of the beam itself, as opposed to deploying from beside or underneath it.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that "through an opening" could be interpreted more generally as passing through any gap or space created by or adjacent to the beam to exit the side of the trailer.
  • Evidence for a Narrower Interpretation: The specification provides strong support for a narrow reading. Figure 6, which the complaint itself references, clearly depicts the stair assembly (10) passing through a cutout or "gap" (130) in the physical structure of the beam '891 Patent, Fig. 6 '891 Patent, col. 5:5-14 The text explicitly states "there is an opening 138 defined in beam 130 through which the retractable stair assembly 102 extends" '891 Patent, col. 5:5-9 This evidence suggests the phrase requires extension through the material of the beam itself.

VI. Other Allegations

• Indirect Infringement: The complaint states that Plaintiff Satellite "does not infringe by inducement, and do not contributorily infringe" any claim of the patents-in-suit Compl. ¶86 Compl. ¶93 The complaint does not provide a specific factual basis for these denials beyond its general non-infringement position.
• Willful Infringement: The complaint alleges that the pre-suit demand letter from JAG's counsel accused Satellite of "willful infringement" and asserted that Satellite's activities exposed it to "significant legal and financial liability" Compl. ¶46 This allegation of willfulness by the Defendants forms part of the basis for the Plaintiff's request for declaratory relief.

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

This case appears to be a preemptive strike by an accused infringer to resolve a patent dispute that includes significant questions of patent ownership and standing. Based on the complaint, the core patent-related issues for the court will likely be:

1. A central question of claim construction and structural location: Can the term "interior cavity," defined in the patents as the space between the subfloor and the trailer's frame platform, be construed to cover the storage location of the Plaintiff's accused stair assembly, which may be mounted externally?
2. An evidentiary question of technical operation: Does the Plaintiff's stair assembly "extend... through an opening in the at least one structural beam" as required by several key claims? The resolution will depend on evidence showing the precise interaction between the accused product and the trailer frame, compared to the specific embodiments and definitions in the patents.
3. A threshold legal question of patent standing: Does Defendant JAG Mobile Solutions, Inc. have an ownership interest sufficient to make threats or bring a suit for infringement, or do those rights reside solely with the individual inventor Defendants? The answer will determine the viability of JAG's accusations and the merits of Plaintiff's related claims for false advertising and tortious interference.