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`Case 6:15-cv-00907-RWS—KNM Document 74-1 Filed 04/18/16 Page 1 of 72 PageID #: 1674
`Case 6:15-Cv—00907-3RG-KNM Document 19 Filed 12/302’15 Page 1 of 72 PagetD #: 446
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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`
`srpco, LLC,'a.nct 1P co, LLC
`(d/b/a INTUS IQ),
`
`Plaintiffs,
`
`V.
`
`
`
`EMERSON ELECTRIC CO, EMERSON
`
`PROCESS MANAGEMENT LLLP, FISHER-
`ROSEMOUNT SYSTEMS, INC,
`ROSEMOUNT INC, BE, pie, BP
`AMERICA, iNC. and BP AMERICA
`
`PRODUCTION COMPANY,
`
`Defendants~
`
`Civil Action No. 6:15—cv—907
`
`JURY TRIAL DEMANDED
`
`FTRST AMENDED COMPLAINT FOR PATENT INFRiNGEMENT
`
`SIPCO, LLC 2111le CO, LLC (d/b/a INTUS IQ) (“Plaintiffs” or “SIPCO”), by and,
`
`through their counsel Nutter, McClennen & Fish LLP, hereby file this First Amended Complaint
`
`for Patent Infringement against Emerson Electric Co, Emerson Process Management LLLi?‘a
`
`FishernRosemont Systems, 1110., and Rosemo'unt Inc. (Collectively “Emerson”) and against 8?,
`
`pie, 8? America, 1110., and BP America Production Company (colleetiveiy “BP”), as foliows:
`
`THE PARTIES
`
`l.
`
`SIPCO, LLC is a limited liability company organized and existing under the laws of the
`
`State of Georgia, having its principal office at 8215 Roswell, Road, Building 9001 Suite 950,
`
`Atlanta, Georgia 303 50
`
`2.
`
`IF CO, LLC (dih/a INTUS IQ) is a limited liability company organized and existing
`
`under the laws of the State of Georgia, having its principai office at 8215 Roswell Road,
`
`Building 900, Suite 950, Atlanta, Georgia 30350.
`
`

`

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`Case 8:15—cv-00907-JRG-KNM Document 19 Filed 12/30/15 Page 2 of 72 PagelD #: 447
`
`3,
`
`Emerson Electric Co. (“EEC”) is a corporation organized and existing under the laws of
`
`the State of Missouri, having a place of business at 1300 East Whaley Street. Suite B, Longview,
`
`Texas 75601.
`
`4.
`
`Emerson Process Management LLLP (“Emerson Process Management”) is a wholly-
`
`owned subsidiary of Emerson Electric Co., and is an entity organized and existing under the laws
`
`of the State of Delaware, having a place of business at 1100 W. Louis Henna Blvd, Bidg. 2,
`
`Round. Rock, Texas 78681 and, upon information and belief, a place of business at 12301
`
`Research Bird, Research Park Plaza, Bldg, III, Austin, Texas 7875.9. Emerson Process
`
`Management’s branded products and services include those made, used, sold and/or offered for
`
`sale by and. through Defendant Fisher-Rosemount Systems, Inc. and Defendant Rosemount, inc.
`
`5.
`
`Fisher—Rosemount Systems, Inc. (“Fisher Roseniount”) is a wholly-owned subsidiary of
`
`Emerson Electric Co, and is a corporation incorporated under the laws of the State of Delaware,
`
`having its principal place of business at 1100 W. Louis Henna Blvd, Bldg. 1, Round Rock,
`
`Texas 78681.
`
`6.
`
`Rosemount, Inc, (“Roselnount”) is a whoiiy—owned subsidiary of Emerson Electric Co,
`
`and. is a corporation organized. and existing under the laws of the State of Minnesota, having its
`
`principai place of business at 8200 Market Rivet, Chanhassen, Minnesota 55317.
`
`7.
`
`BP America, Inc. is a corporation organized and existing under the laws of the State of
`
`Delaware, with a principal piece of business iocated at 501 'W'estlake Park Boulevard, Houston,
`
`TX 77079. B? America, Inc. does substantial business in Texas, including within this judicial
`
`district, and may be served with process through its registered. agent CT Corporation System, 350
`
`N. St. Paul St, Suite 2900, Dallas, TX 75201.
`
`8.
`
`BP America Production Company is a corporation organized and existing under the laws
`
`of the State of Delaware, having its principal piace of business at 501 Westlake Park Bouievard,
`
`

`

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`
`Houston, TX 77079. B? America Production Company does substantial business in Texas,
`
`including Within this judicial district, and may be served with process through its registered agent
`
`CT Corporation System, 350 N. St. Paul St. Suite 2900, Dallas, TX 75201.
`
`9.
`
`BP pic. is a British public iimited company with its corporate headquarters in London,
`
`England, SWIY 4PD. BP p.l..c.is the global parent company of the worldwide business
`
`operating under the “BF” logo. Defendants 13? America Inc. and BP America Production
`
`Company are Wholly-owned subsidiaries of BF pic. and are sufficiently controlled by BP plc.
`
`so as to be BF pic’s agents in Texas BP plc. does substantial business in Texas? including
`
`Within this judicial district, and maybe served with process by serving its registered agent, CT.
`
`Corporation System, at 350 N. St. Paul St, Suite 2900, Dallas. Texas 75201-4234.
`
`JURISDICTION AND VENUE
`
`10.
`
`Plaintiffs’ First Amended Complaint is for patent infringement arising under the patent
`
`statutes, 35 USC. § 101 8? sec}, in particular 35 USC. § 271.
`
`11.
`
`This Court has subject matter jurisdiction over Plaintifts’ claims under 28 U.S.C. §§ 1331
`
`and 1338(3).
`
`12.
`
`On information and belief, BP p.l.c., BP America, 1nd. and BF America Production
`
`Company are subject to this Court’s specific and general personai jurisdiction pursuant to due
`
`process and/or the Texas Long Arm Statue, due at least to their substantial business in this
`
`forum; including: (i) at least a portion of the infringements alleged herein; and (ii) regularly
`
`doing or soliciting business, engaging in other persistent courses of conduct, and/or deriving
`
`substantial revenue from goods and services provided to individuals in Texas and in this judicial
`
`district. For example. Houston is home to BP’S largest number of employees anywhere in the
`
`world and 33? America, Inc’s Texas—based activities include oil and gas exploration and
`
`production, research and, innovation, natural gas power and. trading. petrochemical production
`
`

`

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`Case 6:15-cv-00907-RWS—KNM Document 74-1 Filed 04/18/16 Page 4 of 72 PageID #: 1677
`Case 6:15~cv~00907-3RG~KNM Document 19 Filed 12/30/15 Page 4 of 72 PagetD #: 449
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`and wind power generation. BP America, Inc. has over 6000 Texas~based employees and
`
`supports over 28,000 Texas-basedjobs, In 2014 BP America, inc. paid over $160 miliion in
`
`Texas-based royalty, property, production and state and federal income taxes, and spent over $9
`
`biilion with Texas—based vendors. BF America, Inc, on its own and/or by and through BP
`
`America Production Company, owns and operates an East Texas Campus located at 886 Finkiea
`
`Road in Halisviile, Texas. The Harrison County Campus supports BP’s oil and natural gas
`
`operations in East Texas, including over 800 welis with associated compression, production and
`
`flow lines at and within Greg, Harrison, Panola, Rusk, Shelby and Upshur Comtties. The
`
`Campus also supports drilling operations at and Within the Haynesville Shale, with Texas~based
`
`operations at and within Angelina, Cass, Harrison, Marion, Nacogdoches, Panola, Rusk, Sabine,
`
`San Augustine and Shelby Counties. In addition, BP pic, BP America, Inc, and/or BP America.
`
`Production Company own, operate and/or license BP—branded service stations at and within this
`
`judicial district. BP plot, 8? America, Inc, and BF America Production Company have also
`
`pnrposefuliy availed themselves ofjurisdiction by voluntarily and purposefully committing and
`
`continuing to commit acts of infringement in Texas and in this jurisdiction, inciuding using
`
`infringing products sold by Emerson Electric, Emerson Process Management, Fisher Rosemount
`
`Systems, and/or Rosemount, including, upon information and belief, at and within the greater
`
`than 800 wells and associated compression, production and flow tines operated at and within
`
`Greg, Harrison, Panoia, Rush, Shelby and Upshur Counties.
`
`13.
`
`On information and belief, Emerson Electric, Emerson Process Management, Rosemount,
`
`and Fisher-Rosemount Systems are subject to this Court’s specific and general personai
`
`jurisdiction pursuant to due process and/or the Texas Long Arm Statue, due at least to their
`
`substantial business in this forum, including: (i) at least a portion of the infringements alleged
`
`herein; and (ii) regularly doing or soliciting business, engaging in other persistent courses of
`
`

`

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`Case 6:15—cv—00907—3RG-KNM Document 19 Filed 12/30/15 Page 5 of 72 PagelD #: 450
`
`conduct, and/or deriving substantial revenue from goods and services provided to individuals in
`
`Texas and in this judicial district. For example, Emerson Electric, Emerson Process Management
`
`LLP, Roseniount, and. Fisher—Rosemount Systems conduct substantial business in Texas and in
`
`this judicial district, and have purposefully availed themselves ofjurisdiction in this state and
`
`judicial district, including by voluntarily and purposefully committing and continuing to commit
`
`acts of infringement in this state and judicial district. In particular, Emerson Process
`
`Management has two places of business in Texas and has purposefully availed itself of the laws
`
`and benefits of doing business here by selling infringing products in Texas and in this judicial
`
`district. Rosemonnt has its principal place of business in. Texas and has purposefully availed
`
`itself of the laws and. benefits of doing business here by selling infringing products in Texas and
`
`in this judicial district. Emerson Electric maintains an office in this judicial district and thus has
`
`purposefully availed itself of the laws and benefits of doing business here, as well as by selling
`
`infringing products in Texas and in this judicial district. FishenRosemount has purposefully
`
`availed itself of the laws and benefits of doing business here by selling infringing products in
`
`Texas and in this judicial district,
`
`14.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391 and 1400(1)) at least
`
`because a substantial part of the infringing acts of each Defendant have occurred and are
`
`occurring in this judicial district.
`
`THE PATENTS-IN-S’UIT
`
`15.
`
`US. Patent No. 7,697,492 (“the ‘492 patent”) was duly and legally issued on April 13,
`
`2010.
`
`16.
`
`The ‘492 patent is entitled “Systems and Methods for Monitoring and Controlling
`
`Remote Devices.”
`
`17.
`
`SIPCO owns the “492 patent.
`
`‘Jl
`
`

`

`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 6 of 72 PageID #: 1679
`Case 6:15-cv-00907-RWS—KNM Document 74-1 Filed 04/18/16 Page 6 of 72 PageID #: 1679
`Case 6:15—cv—00907-JRG—KNM Document 19 Filed 12/30/15 Page 6 of 72 PagelD #: 451
`
`18.
`
`Emerson had knowledge of the ‘492 patent and knowledge of its infringement of the ‘492
`
`patent before the filing of the Complaint.
`
`19.
`
`U .8. Patent No. 6,437,692 (“the ‘692 patent”) was duly and legally issued on August 20,
`
`2002.
`
`20.
`
`The ‘692 patent is entitled “System and Method for Monitoring and Controlling Remote
`
`Devices.”
`
`2i.
`
`SIPCO owns- the ‘692 patent.
`
`22.
`
`Emerson had knowledge ofthe ‘692 patent and knowledge of its infringement of the ‘692
`
`patent before the filing of the Complaint.
`
`23.
`
`US. Patent No. 6,914,893 (“the ‘893 patent”) was duly and. legally issued on July 5,
`
`2005.
`
`24.
`
`The “893 patent is entitled “System and Method for Monitoring and Controlling Remote
`
`Devices”
`
`25.
`
`SIPCO owns the ‘893 patent.
`
`26.
`
`Emerson had. knowledge of the ‘893 patent and knowledge of its infringement of the ‘893
`
`patent before the filing of the Complaint.
`
`27.
`
`US. Patent No. 6,249,516 (“the ‘516 patent”) was duly and legally issued on June 19,,
`
`200 l .
`
`28.
`
`The ‘516 patent is entitled “Wireless Network Gateway and, Method for Providing
`
`Same.”
`
`29.
`
`IF C0 owns the ‘5 16 patent.
`
`30.
`
`Emerson had knowledge of the ‘51 6 patent and knowledge of its infringement of the ‘5 l 6
`
`patent before the filing of the Complaint.
`
`

`

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`Case 6:15—ev—00907-JRG-KNM Document 19 Filed 12/30/15 Page 7 of 72 PagelD #: 452
`
`31.
`
`U.8. Patent No. 7,468,661 (“the ‘661 patent”) was duly and legally issued on December
`
`23, 2008.
`
`32.
`
`The ‘661 patent is entitled “System and Method. for Monitoring and Controlling Remote
`
`Devices.”
`
`33.
`
`SIPCO owns the ‘661 patent.
`
`34.
`
`Emerson had knowledge of the ‘661 patent and knowledge of its infringement of the “661
`
`patent before the filing of the Complaint.
`
`35,
`
`US. Patent No. 8,000,314 (“the ‘3 l4 patent”) was duly and legally issued on August 16,
`
`20.11.
`
`36.
`
`The ‘3 l4 patent is entitled “Wireless Network System and Method for Providing Same.”
`
`37.
`
`11’ CO owns the ‘3 14 patent,
`
`38.
`
`Emerson had, knowledge of the ‘3 l4 yatent and knowledge of its infringement of the ‘3 l4
`
`patent before the filing of the Complaint
`
`39.
`
`US. Patent No, 8,233,47l (“the ‘471 patent”) was duly and legally issued on July 31,
`
`2012.
`
`40.
`
`The ‘471 patent is entitled “Wireless Network System and Method. for Providing Same.”
`
`41‘
`
`IF C0 owns the c471 patent.
`
`42.
`
`Emerson had knowledge of the ‘471 patent and knowledge of its infringement of the ‘471
`
`patent before the filing of the Complaint.
`
`43.
`
`US. Patent No. 8,625,496 (“the ‘496 patent”) was duly and. legally issued on January 7,
`
`2014.
`
`44.
`
`The ‘496 patent is entitled “Wireless Network System and Method for Providing Same.”
`
`45.
`
`IF C0 owns the ‘496 patent.
`
`

`

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`Case 6:15-cv-00907-RWS—KNM Document 74-1 Filed 04/18/16 Page 8 of 72 PageID #: 1681
`Case 6:15—CV-00907-3RG—KNM Document 19 Fiied 12/30/15 Page 8 of 72 Page“) #2 453
`
`46.
`
`Emerson had knowledge of the “496 patent and knowledge of its infringement of the ‘496
`
`patent before the filing of the Complaint,
`
`47.
`
`US. Patent No. 8,754,780 (“the ‘780 patent”) was dniy and legally issued on June 17,
`
`2014.
`
`48.
`
`The ‘780 patent is entitled “Systems and Methods for Monitoring and Controlling
`
`Remote Devices.”
`
`49.
`
`SIPCO owns the ‘780 patent.
`
`50.
`
`Emerson had knowledge of the ‘780 patent and knowledge of its infringement of the “780
`
`patent before the filing of the Complaint.
`
`51.
`
`US. Patent No. 83083842 (“the “842 patent”) was duiy and. legally issued on December
`
`9, 2014.
`
`52.
`
`The ‘842 patent is entitled “Main—Functional General Purpose Transceivers and.
`
`Devices.”
`
`51
`
`SIPCO owns the ‘842 patent.
`
`54.
`
`Emerson had. knowledge of the c842 patent and knowledge of its infringement of the ‘842
`
`patent before the filing of the Complaint.
`
`55.
`
`US. Patent No. 8,013,732 (“the ‘732 patent”) was duly and legally issued on September
`
`6, 2011.
`
`56.
`
`The “732 patent is entitled “Systems and Methods for Monitoring and Controlling
`
`Remote Devices.”
`
`57.
`
`SIPCO owns the ‘732 patent.
`
`538.
`
`Emerson had knowledge of the “732 patent and knowledge of its infringement of the ‘732
`
`patent before the filing of the Complaint.
`
`

`

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`Case 6:15—cv-00907-RWS—KNM Document 74-1 Filed 04/18/16 Page 9 of 72 PageID #: 1682
`Case 6:15»cv-00907~JRG-KNM Document 19 Filed 12/30/15 Page 9 of 72 Page“) #2 454
`
`SIPCO AND 1P CO
`
`59.
`
`SIPCO and 113 C0 are small research, development and technology companies based. in
`
`Atlanta, Georgia. T. David Petite is a founding member of both companies,
`
`60.
`
`In the 1990’s, through his own individual research and development efforts, Mr.
`
`Petite invented a large number of wireless control. and distribution technology applications. The
`
`inventions resulting from Mr. Petite’s efforts include but are not limited to, various ways of
`
`moving data as economically and seamlessly as possible over both wired and Wireless networks.
`
`61.
`
`Through the 1990’s and early 2000’s investors contributed tens of millions of dollars for
`
`technology development and implementation of networks. Clients included Georgia Power,
`
`Alabama Power, Newnan Utilities GA, Johnson Controls, Synovus Bank and Grand. Court
`
`Lifestyles residential living facilities.
`
`62.
`
`After proving that the technology worked in the field, several companies competed to
`
`purchase an exclusive license to Mr. Petite’s technology for the market known as “smart grid.”
`
`Landis+Gyr (http://www.landisgyrnomx’) (previously Siemens Metering) took an exclusive
`
`license to the smart grid technology in 2002 and in 2005 purchased rights to the technology for
`
`utility applications for $3030003000. Mr. Petite’s technology has been deployed in millions of
`
`meters across North America and throughout the world.
`
`63.
`
`SIPCO retained the rights to the mesh network patents, and for use of the technology
`
`outside of the utility space. It still maintains ownership of the software, firmware, hardware and
`
`patent portfolio that resulted from Mr. Petite’s research and development efforts, and SIPCO
`
`continues to develop and deploy wireless technology applications and wireless technology
`
`systems throughout the United States.
`
`64.
`
`SIPCO’S patent portfolios (which contain the patents in suit) include inventions that are
`
`widely recognized as pioneering in various fields of use. As a result, over 60 corporations
`
`

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` 1684
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` 1685
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` 1686
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` 1687
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` 1688
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 16 of 72 PageID #:
` 1689
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 17 of 72 PageID #:
` 1690
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` 1691
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` 1692
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` 1693
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 21 of 72 PageID #:
` 1694
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 22 of 72 PageID #:
` 1695
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` 1696
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` 1697
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` 1698
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 26 of 72 PageID #:
` 1699
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 27 of 72 PageID #:
` 1700
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 28 of 72 PageID #:
` 1701
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 29 of 72 PageID #:
` 1702
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` 1703
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` 1704
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` 1705
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` 1706
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 34 of 72 PageID #:
` 1707
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 35 of 72 PageID #:
` 1708
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 36 of 72 PageID #:
` 1709
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 37 of 72 PageID #:
` 1710
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 38 of 72 PageID #:
` 1711
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` 1712
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` 1713
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 41 of 72 PageID #:
` 1714
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 42 of 72 PageID #:
` 1715
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 43 of 72 PageID #:
` 1716
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 44 of 72 PageID #:
` 1717
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 45 of 72 PageID #:
` 1718
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`Case 6:15-cv-00907-RWS-KNM Document 74-1 Filed 04/18/16 Page 46 of 72 PageID #:
` 1719
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