Cactus Wellhead, LLC v. Cameron International Corp. — Court Denies Summary Judgment of Non-Infringement, Finding Fact Disputes Over Whether Accused Greasing System Contains Claimed Skids and Trunk Line

Background

Cactus Wellhead, LLC sued Cameron International Corp. in the Eastern District of Texas, Marshall Division, asserting claims 1 and 5–14 of U.S. Patent No. 11,137,109, which covers a remote greasing system for lubricating valves of wellheads or frac manifolds. Claim 1 recites a system comprising three skids: a grease supply skid with a grease reservoir and pump, a remote greasing skid with a grease manifold coupled to the pump by a grease trunk line, and a control skid with an interface coupled to the remote greasing skid by a control line. Claim 12 depends on claim 1 and adds the limitation that the grease supply skid and remote greasing skid are on one skid.

The Court held a pretrial conference on October 19, 2026, regarding pending pretrial motions, motions in limine, and disputed exhibits. This Order memorializes the Court's rulings as announced from the bench, including Cameron's Motion for Summary Judgment of Non-Infringement (Dkt. No. 72), Cactus's Motion for Partial Summary Judgment of No Anticipation (Dkt. No. 74), Cameron's Corrected Motion to Strike Certain Opinions of Harold McGowen (Dkt. No. 76), and the parties' respective motions in limine (Dkt. Nos. 106, 107).

The Court’s Holding

The Court denied Cameron's Motion for Summary Judgment of Non-Infringement. Cameron argued that under Magnolia Med. Techs., Inc. v. Kurin, Inc., 169 F.4th 1094, 1100 (Fed. Cir. 2026), its Grease Injection Unit could not meet both the claimed 'grease supply skid' and 'remote greasing skid' limitations because there is only one structure corresponding to two claim limitations. The Court found that Cactus improperly reads this one-structure precedent, which does not preclude showing that the accused products include the claimed skids based on a portion of a greasing device. The Court found a genuine fact dispute as to whether the accused products include a grease supply skid and a remote greasing skid.

The Court also found a genuine fact dispute as to whether the accused products include a 'grease trunk line.' Cameron argued that because there is no physically separate grease supply skid and remote greasing skid, there is no line coupling them. The Court held this argument merely reargues the skid issue and that genuine fact disputes remain whether the accused products include the claimed skids connected by a grease trunk line, warranting denial.

The Court denied Cactus's Motion for Partial Summary Judgment of No Anticipation and Cameron's Corrected Motion to Strike Certain Opinions of Harold McGowen. Regarding motions in limine, the Court granted in part Cactus MIL 3, precluding reference to Greg Babineaux individually as the person who took photographs without prior leave, and granted in part Cameron MIL 1, requiring Cactus to obtain leave before presenting evidence of the prosecution history or referencing that Defendant's invalidity references are cited on the face of the patent. The Court denied the remaining motions in limine or found them moot.

Key Takeaways

• A single physical structure in an accused product can satisfy multiple claim limitations if the claim language does not require physically separate structures, distinguishing precedent that requires distinct structures.
• Dependent claim language specifying that two elements are 'on one skid' can support the inference that the independent claim does not require those elements to be on separate skids.
• Genuine fact disputes regarding claim element mapping—such as whether portions of a device constitute claimed skids and connecting lines—preclude summary judgment of non-infringement.
• Courts may act as gatekeepers regarding prosecution history evidence, requiring leave before a party references the examiner's consideration of prior art during trial.
• Parties may be precluded from identifying individuals who engaged in covert evidence gathering to avoid unfairly painting a party as unethical, while still allowing the evidence for other purposes such as demonstrating lack of willfulness.

Why It Matters

This order clarifies the application of Federal Circuit precedent regarding single-structure infringement theories, emphasizing that claims requiring 'distinct structures' differ from those requiring 'physically separate structures.' The ruling allows patentees to pursue infringement theories based on functional mapping of portions of a unified device to multiple claim elements, provided the claim language and dependent claims support such a construction.

The decision also demonstrates the court's role in managing trial evidence through motions in limine, particularly regarding the presentation of prosecution history and potentially prejudicial evidence about a party's investigative conduct, while preserving the defendant's ability to use such evidence for limited purposes like rebutting willfulness.