NATURE OF THE ACTION
1This is a civil action for infringement of U.S. Patent No. 10,233,704 (“the ’704 Patent”) arising under the patent laws of the United States, 35 U.S.C. § 1 et seq.
THE PARTIES
2Frank’s International, LLC is a Texas limited liability company with its principal place of business at 1311 Broadfield Blvd., Suite 400, Houston, Texas 77084.
3On information and belief, TCI Casing Specialties, LLC is a Texas limited liability company with its principal place of business located at 11216 West County Rd 72, Midland, Texas 79707.
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4This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).
5This Court has personal jurisdiction over TCI.
6This Court has general jurisdiction over TCI because its affiliations with this District are so continuous and systematic as to render it essentially at home in the Western District of Texas. TCI’s website states that their “head office” is located at 11216 West County Rd 72, Midland, Texas 79707.
7This Court has specific jurisdiction over TCI because TCI has committed and continues to commit acts of infringement in this District by, among other things, making, using, importing, offering to sell, and/or selling products that infringe the ’704 Patent.
8Venue is proper in this district under 28 U.S.C. §§ 1391 and 1400(b) because TCI resides in this District, has committed acts of infringement in this district and has a regular and established place of business in this District.
THE ’704 PATENT
9Frank’s owns by assignment all rights, title, and interest, including the right to recover damages for past, present, and future infringement, in the ’704 Patent, entitled “Integrated Tubular Handling System.” The ’704 patent was duly and legally issued by the United States Patent and Trademark Office on March 19, 2019. A true and correct copy of the ’704 Patent is attached as Exhibit A.
10The ’704 Patent arose from research and development into systems and methods to increase the safety and efficiency of tubular handling equipment, which is used on oil rigs to make up and lower casing and other tubulars into the wellbore. The inventions of the ’704 Patent
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address, among other things, significant challenges in the prior art by providing a system that reduces the need for manual manipulation of heavy machinery on the rig floor and improves the safety and efficiency of tubular running operations.
11The claims of the ’704 Patent are directed to, among other things, tubular handling systems and a method for handling tubulars. For example, a tubular handling system claimed in the ’704 Patent includes, among other things:
a. a power tong configured to engage and rotate an add-on tubular by applying a
torque thereto, the power tong defining a central opening configured to receive the add-on tubular therethrough; b. a spider disposed at a rig floor, the spider being configured to support a tubular
string and transmit a reactionary torque to the tubular string, when supporting the tubular string, the reactionary torque being generated in reaction to the torque applied by the power tong; c. a lifting assembly coupled with the power tong and configured to move the
power tong vertically with respect to the tubular string and the spider, wherein the lifting assembly transmits a reactionary torque from the power tong to the spider; and d. a torque measuring device configured to measure the reactionary torque
transmitted from the power tong to the lifting assembly and from the lifting assembly to the spider. ’704 Patent at Cl. 1.
DEFENDANT’S INFRINGING PRODUCT AND KNOWLEDGE OF THE PATENT
12TCI manufactures, markets, uses, sells, and/or offers for sale a product it calls the “Clear Floor Tubular Running System” or “CFTRS.” The CFTRS is a tubular handling system that performs the same functions as the system claimed in the ’704 Patent. The CFTRS, therefore, directly infringes the ’704 Patent.
13TCI has had actual knowledge of the ’704 Patent at least as early as March 18, 2025, when Frank’s, through its prior counsel, sent TCI a detailed cease-and-desist letter
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identifying the ’704 Patent and putting TCI on notice that the CFTRS infringes the ’704 Patent. TCI and Frank’s then engaged in extensive correspondence regarding the ’704 Patent throughout 2025. Frank’s provided TCI with a detailed claim chart for the ’704 Patent on August 6, 2025.
COUNT I: INFRINGEMENT OF THE ’704 PATENT
14Frank’s realleges and incorporates by reference each of the paragraphs above as if fully set forth herein.
15Frank’s is the owner of the ’704 Patent, which issued on March 19, 2019, and is attached hereto as Exhibit A.
16TCI has infringed and continues to infringe one or more claims of the ’704 Patent, including at least claims 1, 6, 7, and 8 under 35 U.S.C. § 271(a) by making, using, offering to sell, selling, and/or importing the CFTRS, or components thereof, within the United States. Attached as Exhibit B is a claim chart showing an example of how TCI’s CFTRS satisfies all claim limitations of claims 1, 6, 7, and 8 of the ’704 Patent.
17Although the preamble of claim 1 is non-limiting, the CFTRS is a tubular handling system, as shown in Exhibit B.
18The CFTRS satisfies claim limitation 1(a), as shown in Exhibit B.
19The CFTRS satisfies claim limitation 1(b), as shown in Exhibit B.
20The CFTRS satisfies claim limitation 1(c), as shown in Exhibit B.
21The CFTRS satisfies claim limitation 1(d), as shown in Exhibit B.
22The CFTRS satisfies the limitations of claim 6, as shown in Exhibit B.
23The CFTRS satisfies the limitations of claim 7, as shown in Exhibit B.
24The CFTRS satisfies the limitations of claim 8, as shown in Exhibit B.
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25TCI has directly infringed, and continues to infringe, literally and under the doctrine of equivalents, one or more claims of the ’704 Patent through making, using, selling, offering for sale, and/or importing the CFTRS. By making, using, offering for sale, selling and/or importing into the United States the CFTRS, TCI has injured Plaintiff and is liable for infringement of the ’704 Patent pursuant to 35 U.S.C. § 271.
26As described above, TCI obtained knowledge of the ’704 Patent and received notice that the CFTRS infringes the ’704 Patent at least as early as March 18, 2025. TCI has not ceased its infringing activities. TCI’s infringement of the ’704 Patent has been and continues to be willful and deliberate. TCI also has knowledge of the ’704 Patent by way of this complaint and, to the extent it does not cease its infringing activities, its infringement is and continues to be willful and deliberate.
27The infringement allegations provided for claims 1, 6, 7, and 8 of the ’704 Patent are exemplary and Plaintiff reserves its right to assert additional claims of the ’704 Patent.
28As a result of TCI’s direct infringement of the ’704 Patent, Frank’s is entitled to monetary damages (past, present, and future) in an amount adequate to compensate for TCI’s infringement, together with interests and costs.
29In addition, TCI’s continued infringement of the ’704 Patent has caused and will continue to cause irreparable harm to Frank’s, for which there is no adequate remedy at law, unless TCI is enjoined from infringing the ’704 Patent.
PRAYER FOR RELIEF
Plaintiff respectfully requests that this Court enter: (a) A judgment that TCI has infringed the ’704 Patent;
