DCT
4:26-cv-03004
John Anderson Construction Inc v. Encompass Pipeline LLC
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: John Anderson Construction, Inc. (Pennsylvania)
- Defendant: EnCompass Pipeline, LLC (Minnesota)
- Plaintiff’s Counsel: Buchanan Ingersoll & Rooney PC
- Case Identification: 4:26-cv-03004, M.D. Pa., 10/08/2026
- Venue Allegations: Venue is asserted based on the defendant, EnCompass, having a regular and established place of business within the district—specifically a field office in Troy, Pennsylvania—and having committed the alleged acts of patent infringement within the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s manufacture and use of a "pig loader device" for pipeline maintenance infringes two patents related to that technology.
- Technical Context: The technology concerns devices for safely loading "pigs"—plugs used to clean or inspect pipelines—which is a common but potentially hazardous procedure in the oil and gas industry.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patents-in-suit via a letter dated June 24, 2026. It further alleges that in a response dated August 3, 2026, Defendant refused to cease its allegedly infringing activities and admitted that its device infringes the ’145 Patent. The ’145 Patent is a continuation of the ’186 Patent.
Case Timeline
| Date | Event |
|---|---|
| 2015-05-26 | Priority Date for ’186 and ’145 Patents |
| 2018-06-05 | U.S. Patent No. 9,989,186 Issued |
| 2023-05-09 | U.S. Patent No. 11,644,145 Issued |
| 2026-06-24 | Plaintiff sends notice letter to Defendant |
| 2026-08-03 | Defendant responds to Plaintiff's notice letter |
| 2026-10-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,989,186 - “Pig Loader Device”
The Invention Explained
- Problem Addressed: The patent’s background section describes traditional methods for inserting a pig into a pipeline as dangerous. These methods often require operators to manually hold the pig in place while it is forced into the pipe with heavy equipment, exposing them to high pressures, pinch points, and the risk of objects becoming projectiles ’186 Patent, col. 1:32-48
- The Patented Solution: The invention is a mechanical device that creates a "contained work area" to solve this safety problem ’186 Patent, col. 2:21-25 It features a "breech" to load the pig, a "ramrod" to push it, and a "neck" to connect to the pipeline. An operator can load a pig into the breech and then use the ramrod to safely push the pig into the pipe, obviating the need for manual handling during the dangerous seating process ’186 Patent, abstract ’186 Patent, col. 2:10-22
- Technical Importance: The invention provides a safer and more efficient method for conducting a fundamental step in pipeline maintenance, directly addressing the physical risks faced by operators ’186 Patent, col. 2:19-25
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (’Compl. ¶32).
- The essential elements of Claim 1 include:
- A body with a bore, an aperture forming a breech, a ramrod compartment, a chamber body, and a neck to connect to a pipe.
- A "breech shield" configured to selectively cover the breech.
- A ramrod that, when moved, forces a pig from the chamber body, through the neck, and into the ancillary pipe.
- The complaint’s use of the phrase "at the very least" suggests the potential to assert other claims as the case proceeds (’Compl. ¶32).
U.S. Patent No. 11,644,145 - “Pig Loader Device”
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’186 Patent, the ’145 Patent addresses the same problem of operator danger during manual pig loading operations ’145 Patent, col. 1:40-51
- The Patented Solution: The invention described is functionally identical to that of the ’186 Patent: a breech-loading apparatus that uses a ramrod to safely insert a pig into a pipeline. The claims, however, focus on slightly different structural combinations of the core components, such as the "breech plate" on the ramrod ’145 Patent, abstract ’145 Patent, col. 2:25-36
- Technical Importance: The technology enhances the safety and efficiency of pipeline pigging operations by creating a contained and mechanically-assisted loading process ’145 Patent, col. 2:25-29
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claims 1, 8, and 18 (’Compl. ¶32).
- The essential elements of Independent Claim 1 include a body, breech, ramrod compartment, chamber body, and neck, along with a "breech plate" on the ramrod that contacts and forces the pig.
- The essential elements of Independent Claim 8 describe a "breech assembly" comprising a chamber body, ramrod compartment, breech, and neck, with a ramrod having a "breech plate" that slideably traverses the assembly to force the pig into the pipe.
- The essential elements of Independent Claim 18 describe a body with a ramrod compartment, a breech for ingress/egress of a pig, a chamber body to receive the pig, and a ramrod configured to advance the pig from the breech.
- The complaint reserves the right to assert other claims (’Compl. ¶32).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is identified as a "pig loader device" that Defendant EnCompass makes and uses in its pipeline construction and maintenance services (’Compl. ¶¶30-31).
Functionality and Market Context
The complaint alleges the device is used in connection with EnCompass's pigging services and is promoted as offering "enhanced safety" (’Compl. ¶28; Compl. ¶31). The complaint states that EnCompass is a direct competitor to Plaintiff JAC and that they bid on the same service projects (’Compl. ¶31). The complaint does not provide specific technical details on the operation of the accused device, instead referencing an unprovided exhibit for such information (’Compl. ¶33).
IV. Analysis of Infringement Allegations
The complaint alleges that the accused pig loader device meets all the limitations of the asserted claims but provides no element-by-element analysis in the body of the complaint itself. Instead, it states that attached claim charts in "Exhibit C" demonstrate infringement in detail and include pictures of the accused device (’Compl. ¶33; Compl. ¶34). As Exhibit C was not provided with the complaint, the specific factual basis for the infringement allegations is not detailed in the available document. No probative visual evidence provided in complaint.
The tables below summarize the structure of the allegations for the lead independent claim of each patent, noting where the complaint's allegations are general rather than specific.
’186 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a body having a first distal end and a second distal end... wherein a bore extends from the first distal end to the second distal end | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:36-40 |
| an aperture formed in a surface of the body generating a breech | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:41-42 |
| a ramrod compartment configured to facilitate slideable motion of a ramrod along the longitudinal axis | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:43-45 |
| a chamber body adjacent the ramrod compartment, the chamber body configured to receive a pig | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:46-48 |
| a neck adjacent the chamber body, the neck configured to facilitate connection of the pig loader device to an ancillary pipe | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:49-51 |
| a breech shield configured to selectively cover the breech | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:55-56 |
| wherein when the pig is within the chamber body and the ramrod is motioned... the ramrod forces the pig through the neck and into the ancillary pipe | The complaint alleges the accused device operates in this manner, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 9:57-62 |
’145 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a body having a first distal end and a second distal end... wherein a bore extends from the first distal end to the second distal end | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:30-34 |
| an aperture formed in a surface of the body generating a breech | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:35-37 |
| a ramrod compartment configured to facilitate slideable motion of a ramrod along the longitudinal axis | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:38-40 |
| a chamber body adjacent the ramrod compartment, the chamber body configured to receive a pig | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:41-43 |
| a neck adjacent the chamber body, the neck configured to facilitate connection of the pig loader device to an ancillary pipe | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:44-46 |
| a breech plate disposed on a distal end of the ramrod | The complaint alleges the accused device includes this feature, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:47-48 |
| wherein when the pig is within the chamber body and the ramrod is motioned... the breech plate on the ramrod contacts and forces the pig through the neck and into the ancillary pipe | The complaint alleges the accused device operates in this manner, referencing an unprovided exhibit for details. | ¶32; ¶33 | col. 11:49-54 |
Identified Points of Contention
- Evidentiary Question: The primary point of contention will be evidentiary. Since the complaint relies entirely on an unprovided exhibit for its infringement theory, a key question is what evidence Plaintiff will produce to demonstrate that the accused device contains each element of the asserted claims.
- Scope Questions: The case may raise questions about the scope of key structural terms. For the ’186 Patent, a dispute could arise over whether a structure on the accused device qualifies as a "breech shield." For the ’145 Patent, a similar question may arise regarding the "breech plate."
V. Key Claim Terms for Construction
The Term: "breech shield" ’186 Patent, Claim 1
Context and Importance
This term is a key limitation in Claim 1 of the ’186 Patent and a distinguishing feature from some claims in the later ’145 Patent. Its construction will be critical to determining infringement of the ’186 Patent, as the presence and functionality of a corresponding structure on the accused device will be a central factual dispute.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification introduces the element by stating, "Some embodiments may include a breech shield configured to selectively cover the breech" ’186 Patent, col. 2:1-2 This permissive and functional language may support an argument for a broader definition that covers any component capable of selectively covering the breech opening.
- Evidence for a Narrower Interpretation: The detailed description describes an embodiment where the shield is a "solid, rigid member" secured by "securement means," such as "locking bolts" that engage "keyed plates" ’186 Patent, col. 6:56-65 ’186 Patent, col. 7:7-14 This more detailed description may support a narrower construction requiring a robust, securable plate rather than a simple cover.
The Term: "breech plate" ’145 Patent, Claims 1 and 8
Context and Importance
This element is the part of the ramrod that directly contacts and pushes the pig. Practitioners may focus on this term because the infringement analysis will depend on identifying a corresponding structure on the accused device's ramrod and showing it performs the claimed function.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The term is not explicitly defined in the specification, and Claim 1 merely requires it to be "disposed on a distal end of the ramrod" ’145 Patent, claim 1 This could support a reading that encompasses any end surface of the ramrod that pushes the pig.
- Evidence for a Narrower Interpretation: The figures consistently depict the breech plate (30) as a distinct, disc-like component attached to the end of the rod (26), separate from the rod itself ’145 Patent, Fig. 2 The specification also describes the ramrod as including "a rod 26 having... a breech plate 30 at its second distal end" ’145 Patent, col. 4:65-col. 5:1, suggesting it is a specific component of the ramrod assembly, not just the end of the rod.
VI. Other Allegations
Indirect Infringement
The complaint makes a passing reference to inducement, contribution, aiding, and abetting (’Compl. ¶8). However, it does not plead specific facts to support the requisite elements of knowledge and intent for a standalone claim of indirect infringement.
Willful Infringement
The complaint alleges willful infringement based on pre-suit knowledge of the patents and the infringing nature of the accused device (’Compl. ¶¶46, 52, 58). This allegation is primarily supported by a notice letter sent on June 24, 2026, and Defendant’s alleged continued infringement thereafter (’Compl. ¶36; Compl. ¶43). The willfulness claim is further bolstered by the allegation that Defendant admitted infringement of the ’145 Patent in an August 3, 2026 letter but refused to stop its conduct (’Compl. ¶39; Compl. ¶47).
VII. Analyst’s Conclusion: Key Questions for the Case
- An Evidentiary Question of Infringement: With the complaint’s infringement theory contained entirely within an unprovided exhibit, a threshold question is one of proof: what evidence will Plaintiff JAC offer to substantiate its conclusory allegations and demonstrate, on an element-by-element basis, that EnCompass’s device actually practices the patented technology?
- A Legal Question of Claim Scope: The case will likely involve a dispute over the definition of key structural terms. A core issue will be one of definitional scope: can the term "breech shield" ’186 Patent, which is described with specific locking mechanisms in one embodiment, be construed broadly enough to read on any form of cover over the breech, or will it be limited to a more robust, securable plate?
- A Factual Question of Willfulness: The pre-suit correspondence will be a focal point. A key question for damages will be the interpretation of EnCompass’s August 3, 2026 letter: does the letter's content, which allegedly discusses modifying its device, constitute an admission of infringement, thereby substantially strengthening JAC's case for willful infringement and potential enhanced damages?
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