CentralSquare Tech LLC v. National Board Of Boiler Pressure Vessel Inspectors

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CentralSquare Technologies, LLC (Delaware)
  • Defendant: The National Board of Boiler and Pressure Vessel Inspectors (Ohio)
  • Plaintiff's Counsel: Finnegan, Henderson, Farabow, Garrett & Dunner LLP
• Case Identification: 2:25-cv-00774, S.D. Ohio, 04/03/2026
• Venue Allegations: Venue is alleged to be proper as Defendant is an Ohio corporation with its principal place of business located within the Southern District of Ohio.
• Core Dispute: Plaintiff alleges that Defendant's Jurisdictional Reporting System infringes a patent related to a centralized, online system for managing regulatory inspections across multiple jurisdictions.
• Technical Context: The technology concerns a web-based software platform designed to consolidate and streamline the management of legally mandated equipment inspections (e.g., for boilers and pressure vessels) that involve coordination between government jurisdictions, insurance carriers, and inspectors.
• Key Procedural History: The complaint notes that the patent-in-suit expired on October 3, 2024. This fact frames the litigation as a claim for past monetary damages exclusively, as injunctive relief is not available for an expired patent.

Case Timeline

Date	Event
2000-09-07	'304 Patent Priority Date
2000-01-01	Plaintiff's "Jurisdiction Online" product launched
2007-02-20	'304 Patent Issue Date
2018-07-04	CentralSquare acquires the "Jurisdiction Online" platform
2022-06-01	Defendant announces the Accused "JRS" Product (Summer 2022)
2023-06-01	Defendant's "JRS" product "went live"
2024-10-03	'304 Patent Expiration Date
2026-04-03	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 7,181,304, titled "System and Method for an Online Jurisdiction Manager," issued on February 20, 2007 (the "'304 Patent") Compl. ¶13

The Invention Explained

• Problem Addressed: At the time of the invention, managing required inspections of equipment like boilers and pressure vessels was highly fragmented Compl. ¶¶18-19 Data was stored on paper or in disparate, non-communicating computer systems specific to each jurisdiction or insurance company Compl. ¶18 This created significant technical challenges, including the need to navigate different interfaces, re-enter data when entities changed, and manually route forms, which was slow, error-prone, and posed safety risks '304 Patent, col. 2:20-29 Compl. ¶¶19-21
• The Patented Solution: The '304 patent describes a centralized, web-based system-a "jurisdiction online manager"-that serves as a single hub for multiple jurisdictions, inspection entities (like insurance companies), and inspectors Compl. ¶22 The system uses a central database coupled to a global computer network (e.g., the Internet) to receive, store, and distribute all relevant data, including equipment details, jurisdiction-specific inspection templates, inspection results, and review data '304 Patent, abstract The complaint references Figure 1 from the patent, which illustrates this architecture, showing the central manager (110) connecting jurisdictions (120), insurance companies (130), and inspectors (135) via a network (199) Compl. ¶24 This centralization provides a "single source for equipment information" and overcomes the "technical challenges of accessing a variety of jurisdiction-specific interfaces" Compl. ¶31 '304 Patent, col. 4:12-41
• Technical Importance: The invention's approach of using a central, network-accessible database to manage multi-entity regulatory processes was described as non-conventional for its 2000 priority date, a time when such processes relied on local storage and siloed systems Compl. ¶¶17, 32

Key Claims at a Glance

• The complaint asserts independent claim 1, along with a number of dependent claims Compl. ¶54
• Claim 1 is a method claim directed to managing required inspections using a central computer system, comprising the steps of:
  • Receiving object data for inspectable objects located in a plurality of jurisdictions via a global computer network
  • Storing the object data in at least one database
  • Determining an object controlling jurisdiction for each object
  • Displaying online inspection template information based on the jurisdiction's compliance requirements
  • Receiving object inspection result data from an inspection entity via the network
  • Storing the object inspection result data in the database
  • Providing the inspection result data online to the controlling jurisdiction
  • Receiving review result data from the jurisdiction online
  • Storing the review result data in the database
  • Providing the review result data online to the inspection entity Compl. ¶23
• The complaint does not explicitly reserve the right to assert other claims, but asserts a broad range of claims beyond claim 1 Compl. ¶54

III. The Accused Instrumentality

Product Identification

• Defendant's Jurisdictional Reporting System ("JRS") Compl. ¶52

Functionality and Market Context

• The complaint alleges the JRS is a "centralized inspection-management system" that was announced in the summer of 2022 and "went live" in June of 2023 Compl. ¶¶50, 52-53
• The system is alleged to create a "shared database to allow for the easy transfer of information and records between entities" (Compl. ¶50). The complaint includes a screenshot from Plaintiff's own "Jurisdiction Online" product, an embodiment of the '304 patent, to illustrate the concept of an online portal for accessing a shared database Compl. ¶48
• The complaint asserts that Defendant NBBI is an organization of chief boiler and pressure vessel inspectors from across North America, suggesting the JRS is targeted to the same regulatory market as Plaintiff's product Compl. ¶51

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendant's JRS product practices the method claimed in the '304 Patent Compl. ¶56 While the complaint references a claim chart in Exhibit E, that exhibit is not provided with the filing. The following chart summarizes the infringement theory for claim 1 based on the narrative allegations in the complaint Compl. ¶¶23, 30-38

• '304 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
[1] receiving object data for inspectable objects located in a plurality of jurisdictions in the central computer system via a global computer network;	The JRS system is alleged to receive and store object data from multiple entities over a network in a central system, overcoming the prior art problem of disconnected systems.	¶31	col. 8:65-9:2
[2] storing the object data in at least one database coupled to the central computer system;	The JRS is alleged to use a central database, providing a single source for equipment information.	¶31	col. 10:41-44
[3] determining an object controlling jurisdiction for each object;	The JRS is alleged to determine the relevant controlling jurisdiction to facilitate data transfer and apply correct requirements.	¶¶34, 37	col. 12:65-13:1
[4] displaying online inspection template information based upon compliance requirements of an object controlling jurisdiction;	The JRS is alleged to provide a central system that retrieves requirements for different jurisdictions and displays corresponding template information.	¶34	col. 13:1-7
[5] receiving object inspection result data...via the global computer network;	The JRS is alleged to receive inspection data in the central system over a network.	¶31	col. 13:11-16
[6] storing the object inspection result data in the at least one database;	The JRS is alleged to store inspection result data in its central database.	¶31	col. 13:31-33
[7] providing object inspection result data on-line to the object controlling jurisdiction via the global computer network;	The JRS is alleged to use the network to provide stored inspection data to the relevant controlling jurisdictions.	¶37	col. 13:33-37
[8] receiving review result data...on-line from the object controlling jurisdiction via the global computer network;	The JRS is alleged to receive review data from jurisdictions in its central system via a network.	¶31	col. 14:7-9
[9] storing the review result data in the at least one database;	The JRS is alleged to store the received review data in its central database.	¶31	col. 14:17-20
[10] providing the review result data on-line to the inspection entity via the global computer network.	The JRS is alleged to use the network to provide stored review data to the relevant inspection entities.	¶37	col. 14:20-24

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the architecture of the accused JRS qualifies as a "central computer system" within the meaning of the claims. The complaint emphasizes this centralization, illustrated with the patent's Figure 1 system diagram and Figure 3 hardware diagram, as the key inventive concept Compl. ¶¶24-25 The defense may argue its system is architecturally distinct (e.g., more distributed or federated) and does not meet this limitation.
  • Technical Questions: The analysis may focus on whether the JRS performs the specific data handling and routing steps as claimed. For instance, a question may arise as to whether the JRS provides "inspection template information based upon compliance requirements" or if it manages jurisdictional rules in a fundamentally different way that falls outside the claim's scope.

V. Key Claim Terms for Construction

• The Term: "central computer system"

• Context and Importance: This term is the core of the claimed invention, defining the system's fundamental architecture. The infringement analysis will likely depend on whether the Defendant's JRS is properly characterized as "central." Practitioners may focus on this term because the complaint repeatedly contrasts the claimed "central system" with the "separate, disconnected systems" of the prior art Compl. ¶¶22, 30

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the system functionally as a "computer system with computer programs designed to carry out the functions described herein" '304 Patent, col. 8:12-15, which may support a construction not limited to a specific hardware configuration.
  • Evidence for a Narrower Interpretation: The specification discloses a specific three-tiered hardware architecture (client, web/application, database) in Figure 3 as an embodiment of the "jurisdiction online manager" '304 Patent, col. 8:56-9:2 Compl. ¶¶25-26 A defendant may argue this embodiment limits the scope of the term.

• The Term: "inspection template information"

• Context and Importance: This term is critical because it links the central system to the varied requirements of the "plurality of different jurisdictions." The infringement question may turn on what type of information qualifies as a "template" and how it must be tied to "compliance requirements."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification refers to retrieving an "inspection format for that jurisdiction," suggesting the term could cover any data structure or set of fields needed for a given jurisdiction '304 Patent, col. 13:1-4
  • Evidence for a Narrower Interpretation: The specification also discusses a "jurisdiction's inspection form" and the ability to "print an inspection form," which could support an argument that the "template" must be a discrete, form-based document rather than just a collection of data fields '304 Patent, col. 5:3-4 '304 Patent, col. 13:8-10

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on the allegation that Defendant actively encourages its customers to use the JRS product in an infringing manner Compl. ¶57 Contributory infringement is based on allegations that the JRS product constitutes a material part of the invention, is known by the Defendant to be especially adapted for use in an infringing way, and is not a staple article of commerce suitable for substantial non-infringing use Compl. ¶¶58-59
• Willful Infringement: The complaint does not contain specific factual allegations to support pre-suit knowledge of the '304 patent or its infringement. It requests a judgment including "enhanced damages due to, for example, Defendant's willful infringement," which suggests the willfulness claim may be based on conduct occurring after the filing of the lawsuit Compl., Prayer for Relief ¶B

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

• A core issue will be one of architectural scope: does the Defendant's Jurisdictional Reporting System operate as a "central computer system" as that term is construed in light of the '304 patent's specification, or does it employ a different architecture (e.g., distributed, federated) that falls outside the claims?
• A second key question will be one of functional specificity: does the JRS method of handling jurisdiction-specific rules and data fields meet the "displaying online inspection template information" limitation, or is there a technical mismatch between how the accused system functions and what the patent requires?
• Finally, the case presents a focused damages inquiry. With the patent having expired in October 2024 and the accused product launching in June 2023, the damages window is a fixed and relatively short period of approximately 16 months. The litigation will center entirely on establishing liability and the appropriate measure of past monetary damages for that specific timeframe.