SitePro Inc v. TankLogix LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SitePro, Inc. (Delaware)
  • Defendant: TankLogix, LLC (Utah)
  • Plaintiff's Counsel: Perkins Coie LLP
• Case Identification: 7:25-cv-00266, W.D. Tex., 04/15/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the Western District of Texas and maintains a regular and established place of business in the district, specifically an office in Odessa, Texas.
• Core Dispute: Plaintiff alleges that Defendant's remote fluid monitoring and control systems infringe a patent related to systems for remotely managing fluid-handling devices, particularly in environments with unreliable network connectivity.
• Technical Context: The technology relates to Supervisory Control and Data Acquisition (SCADA) systems used in the oil and gas industry to monitor and control equipment at remote facilities like saltwater disposal sites.
• Key Procedural History: This First Amended Complaint follows an original complaint, and Plaintiff alleges Defendant has had knowledge of the asserted patent and infringement since at least the filing and service of that original complaint.

Case Timeline

Date	Event
2012-01-01	Alleged conception date for the '184 Patent
2012-12-07	Earliest priority date for the '184 Patent family
2025-06-03	U.S. Patent No. 12,321,184 issues
2026-04-15	Plaintiff files First Amended Complaint for Patent Infringement

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

U.S. Patent No. 12,321,184 - "Remote control of fluid-handling devices,"

• Issued: June 3, 2025.

The Invention Explained

• Problem Addressed: The patent's background section describes two primary problems with prior art SCADA systems used for remote fluid-handling. First, these systems often fail when a network connection is lost, as the remote logic controlling the site ceases to function '184 Patent, col. 1:67-2:4 Second, these systems often require the installation of special-purpose software on a central computer to control new or different types of field devices, which makes scaling systems and adding new equipment burdensome and complex '184 Patent, col. 2:4-10 Compl. ¶¶26-27
• The Patented Solution: The invention proposes a "site master-controller" co-located with the fluid-handling equipment '184 Patent, Fig. 1 This controller is designed to solve the stated problems in two ways. First, it can receive a command from a remote server and execute it to completion locally, even if the network connection to the remote server is subsequently lost '184 Patent, col. 11:20-25 It can also buffer site data (like sensor readings and alarms) locally and transmit it to the remote server when the network connection is restored, preventing data loss '184 Patent, col. 11:25-31 Second, the site master-controller includes a "protocol multiplexer" that translates commands from a universal format into various device-specific protocols, shielding the central server from the complexity of managing diverse field equipment '184 Patent, col. 9:16-33
• Technical Importance: This approach allows for more resilient and scalable remote control systems that can continue to operate and collect data during network outages, while simplifying the integration of diverse hardware from multiple vendors Compl. ¶31 Compl. ¶32

Key Claims at a Glance

• The complaint asserts direct and indirect infringement of claims 1-31, with a detailed analysis provided for independent system claim 30 Compl. ¶38 Compl. ¶45
• Essential elements of independent claim 30 include:
  • A first computing system coupled to a plurality of fluid handling devices.
  • Receiving commands to control the devices, where the commands originate from an authorized user at a remote computing device.
  • Determining different target states for a device over time, wherein the first computing system is operative to maintain control in the absence of an external network connection.
  • Translating the commands into different protocols suitable for the various fluid-handling devices.
  • Sending the translated commands to local controllers.
  • Obtaining site data and storing it in a report buffer such that the data is not lost during a network outage.
  • Sending the stored site data to a remote second computing system.
• The complaint reserves the right to assert additional claims Compl. ¶38

III. The Accused Instrumentality

Product Identification

The "Accused Systems" are identified as any TankLogix system for remote automation, monitoring, or control of fluid-handling equipment Compl. ¶20 The complaint specifically highlights systems built on the "Ignition" industrial automation software platform by Inductive Automation, for which TankLogix is a "Registered Integrator" Compl. ¶21 These systems include TankLogix's SCADA system, mobile applications, and associated hardware like programmable logic controllers (PLCs) Compl. ¶20

Functionality and Market Context

The complaint alleges the Accused Systems provide "Comprehensive Hosted SCADA" services, allowing customers to connect with, collect data from, and control field devices over a network, with data hosted on a cloud-based infrastructure Compl. ¶21 These systems are marketed for use in the oil and gas industries for applications such as tank monitoring and controlling pumps and valves Compl. ¶19 Compl. ¶48 The complaint includes an "IIoT Architecture" diagram, depicting a system where on-site PLCs/RTUs communicate with an "Ignition Server" in the cloud, which in turn interfaces with web-launched clients Compl. ¶49 This diagram, sourced from Inductive Automation's documentation, illustrates the flow of commands and data between the field and the cloud Compl. ¶49

IV. Analysis of Infringement Allegations

The complaint provides an exemplary infringement analysis for Claim 30 of the '184 Patent.

Claim Element (from Independent Claim 30)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A system, comprising: a plurality of fluid handling devices; and a first computing system communicatively coupled to the plurality of fluid handing devices...	The Accused Systems are comprised of a "first computing system (e.g., a PLC)" coupled to fluid handling devices such as pumps and tanks at a customer site Compl. ¶48 The complaint presents an "IIoT Architecture" diagram showing PLCs/RTUs as the on-site computing system connected to field devices Compl. ¶49	¶49	col. 10:29-34
receiving, with a first computing system, via a network interface, a plurality of commands encoded in a first protocol to control a plurality of different fluid-handling devices... wherein the plurality of commands are responsive to inputs to a command interface presented on a remote user computing device...	The Accused Systems receive commands from a remote user via a command interface. The complaint provides a screenshot of a graphical user interface showing controls for oil tanks, water tanks, and pumps, which allows users to remotely manage site operations (Compl. ¶51).	¶51	col. 4:15-19
...the plurality of commands are received after determining that a user of the remote user computing device is authorized to issue commands to the first computing system based on a user account...	The Accused Systems authenticate users before allowing them to issue commands. The complaint includes a screenshot of the TankLogix mobile application login screen, requiring a username and password for access (Compl. ¶52).	¶52	col. 4:40-55
for at least some of the plurality of commands, determining... a plurality of different target states... wherein the first computing system is operative to maintain control of the fluid handling devices in an absence of an external network connection...	The complaint alleges the on-site PLC is operative to maintain control even if the network connection is lost, thereby solving the problem of prior art systems that fail during network outages Compl. ¶53 This is supported by allegations that the system includes VFDs with PID controllers that determine a plurality of target states over time Compl. ¶26	¶53	col. 11:20-25
translating, with the first computing system, the plurality of commands into translated commands encoded in a plurality of protocols different from the first protocol...	The Accused Systems allegedly translate commands received in a primary protocol (e.g., TCP/IP) into various other protocols (e.g., Modbus, analog) understood by the different on-site fluid-handling devices (Compl. ¶54). This translation is allegedly performed by the on-site PLC (Compl. ¶54).	¶54	col. 9:16-33
sending, with the first computing system, the translated commands to the local controllers...	The on-site PLC allegedly sends the translated commands to local controllers, such as a VFD controlling a pump, to effectuate the desired change of state (Compl. ¶55).	¶55	col. 2:35-36
obtaining, with the first computing system, site data and storing the site data in a report buffer of the first computing system such that the site data... is not lost in the absence of the network connection...	The Accused Systems allegedly obtain and store site data locally (e.g., in a PLC) so that it is not lost if the connection to the cloud server is interrupted Compl. ¶56 This is presented as a key feature of the "Comprehensive Hosted SCADA" service Compl. ¶31	¶56	col. 11:25-31
sending, with the first computing system, the site data stored in the report buffer to a remote second computing system.	The on-site PLC allegedly sends the locally stored data to the remote "Ignition Server" (the second computing system) when network connectivity is available Compl. ¶57 The IIoT architecture diagram shows data flowing from the on-site system to the cloud network and Ignition Server Compl. ¶57	¶57	col. 11:28-31

Identified Points of Contention

• Architectural Mapping: A central question may be whether the distributed architecture of the Accused System, which relies on a third-party "Ignition" platform with cloud and edge components, can be mapped onto the elements of Claim 30. The claim recites a "first computing system" that performs multiple functions, including receiving commands, maintaining offline control, translating protocols, and buffering data. The complaint appears to equate this "first computing system" with the on-site PLC Compl. ¶49, and the "remote second computing system" with the cloud-based Ignition Server Compl. ¶57 The court may need to determine if this mapping is consistent with the patent's description of a more integrated "site master-controller" '184 Patent, Fig. 1
• Evidentiary Questions: The complaint's allegations regarding offline operation and local data buffering Compl. ¶53 Compl. ¶56 are based on the purported functionality of the Accused Systems. A key technical question will be what evidence demonstrates that the on-site PLCs are actually programmed and configured to perform these specific functions (maintaining control and persistently buffering data during a network outage) as required by the claim, rather than simply acting as a pass-through for commands when online.

V. Key Claim Terms for Construction

The Term: "first computing system"

• Context and Importance: The definition of this term is critical for determining where the claimed functions must be performed. The infringement theory depends on this term covering the on-site component of the Accused System (e.g., the PLC/RTU). Practitioners may focus on this term because its scope will determine whether the accused distributed architecture falls within the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent uses general language, defining a computer system as potentially including one or more processors, memory, and interfaces, which could be read to cover a distributed set of components working in concert '184 Patent, col. 13:1-12
  • Evidence for a Narrower Interpretation: The patent consistently depicts the "site master-controller" (which embodies the "first computing system") as a distinct, co-located unit at the fluid-handling site, separate from the remote "command-center server" '184 Patent, Fig. 1 '184 Patent, col. 5:26-28 This suggests the "first computing system" is intended to be the local, on-site device.

The Term: "report buffer"

• Context and Importance: This term's construction is tied to the "first computing system". Claim 30 requires the "report buffer" to be part of the "first computing system" and to store data such that it "is not lost in the absence of the network connection." This strongly implies a persistent, local storage capability. The dispute will likely center on whether the accused PLCs possess such a buffer that performs this specific function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that any form of memory on the local device that temporarily holds data before transmission qualifies.
  • Evidence for a Narrower Interpretation: The patent specification explicitly describes the "report buffer" as a component of the "site master-controller" used to buffer data "before the data is periodically returned to the command-center server 14, such that buffered data is not lost if network access ceases intermittently" '184 Patent, col. 11:25-31 This language suggests a specific function tied to surviving network outages, not just transient data handling.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that TankLogix provides "product manuals and other technical information that cause their subscribers, customers, and other third parties to use and to operate the Accused Systems" in an infringing manner Compl. ¶42

Willful Infringement

The complaint alleges willful infringement based on Defendant's knowledge of the '184 Patent since "at least as early as the filing of this lawsuit" and the original complaint Compl. ¶40 Compl. ¶44 It also alleges knowledge from Defendant's employees having potentially accessed SitePro's public patent marking website Compl. ¶44

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

The resolution of this case may depend on the answers to two central questions:

1. A question of architectural mapping: Can Plaintiff demonstrate that Defendant's allegedly infringing system, which is based on a third-party platform (Ignition) and distributed between on-site PLCs and a cloud server, meets the specific architecture of the "first computing system" as claimed? This will likely require the court to construe the location and functional boundaries of elements like the "first computing system" and its "report buffer."

2. An evidentiary question of functionality: Beyond marketing materials and high-level diagrams, what technical evidence will show that the accused on-site PLCs are actually configured to perform the specific functions of maintaining control and persistently buffering data "in an absence of an external network connection," as required by the claims? Proving this specific operational capability during a network failure will be a critical hurdle.