Cactus Wellhead, LLC v. Cameron International Corporation et al, No. 2:24-cv-01010 (E.D. Tex. Oct. 29, 2026)

2A remote greasing system for lubricating a valve of a wellhead or frac manifold comprising:

a grease supply skid, the grease supply skid including a grease reservoir and a grease pump;

a remote greasing skid, the remote greasing skid including:

a grease manifold, the grease manifold operatively coupled to the grease pump of the grease supply skid by a grease trunk line; . . . and

a control skid, the control skid including an interface, the control skid operatively coupled to the remote greasing skid by a control line, the control skid adapted to control the actuation of the grease supply valve; . . . .

’109 Pat. at 7:51–8:6. Claim 12 depends on claim 1 and further recites that “the grease supply skid

and remote greasing skid are on one skid.” (Id. at 8:54–55.)

Cameron argued that Plaintiff Cactus’s technical expert Mr. McGowen opined that the

Grease Injection Unit in the accused systems includes both a “grease supply skid” and a “remote

greasing skid” because some portion of a greasing device is a grease supply skid, and another

portion of the greasing device is a remote greasing skid. Cameron takes issue with this mapping

because in Magnolia Med. Techs., Inc. v. Kurin, Inc., 169 F.4th 1094, 1100 (Fed. Cir. 2026), for

instance, the Federal Circuit affirmed a non-infringement finding where “there is only one structure

in the [accused product] corresponding to two limitations in the asserted claims of the [] patent—

the ‘vent’ and ‘seal’ limitations.” Id. Under such precedent, Cameron’s Grease Injection Unit

allegedly cannot meet both the claimed elements of “a grease supply skid” and “a remote greasing

skid.”

Cactus argues that Cameron’s cited cases address claims requiring distinct structures, not

physically separate structures. Cactus alleges that its expert, in contrast, maps to distinct structures

to show infringement as required. Cactus also argues that claim 12 of the ’109 Patent, which

3depends on claim 1, adds the further limitation “wherein the grease supply skid and remote

greasing skid are on one skid.” According to Cactus, such language means that claim 1 can have

both the claimed grease supply skid and remote greasing skid on one skid.

The Court, in light of the Parties’ competing positions regarding skids, the accused

products, and claim 12 of the asserted patent, found that there was a genuine fact dispute as to

whether the accused products include a grease supply skid and a remote greasing skid. The Court

was persuaded that Cactus improperly reads the cited one structure precedent. That precedent does

not preclude Plaintiff in this case from showing that the accused products include the claimed skids

based on a portion of a greasing device.

The Court further found that there was a genuine fact dispute as to whether accused

products include a “grease trunk line” claim term. Cameron argues that because there is no “grease

supply skid” that is physically separate from a “remote greasing skid,” there is simply no line—

much less a “grease trunk line”—that couples these two skids together in the accused products.

However, this argument, at best, reargues Cactus’s “grease supply skid” and “remote greasing

skid” argument addressed previously. Similar to that discussed above, genuine fact disputes remain

whether the accused products include a grease supply skid and a remote greasing skid connected

by a grease trunk line as claimed, warranting denial.

2. Plaintiff Cactus’s Motion for Partial Summary Judgment of No Anticipation (Dkt.

No. 74) This Motion was DENIED.

3. Defendant Cameron’s Corrected Motion to Strike Certain Opinions of Harold

McGowen (Dkt. No. 76) This Motion was DENIED.

4. Plaintiff Cactus’s Motions in Limine (Dkt. No. 106)

4a. Cactus MIL 1: To preclude Cameron from introducing evidence, testimony, or

argument regarding the existence of, or the disputes at issue in, the case captioned: Cactus Wellhead, LLC v. Cameron Int’l Corp., No. 4:21-cv-02720 (S.D. Tex.) (the “Southern District Case”). This MIL was DENIED. The Court instructed the Parties not to mention or reference their

parallel litigation in the Southern District of Texas (Case No. 4:21-cv-02720). The Court also

instructed the Parties that Cactus MIL 1 was duplicative of Court MIL 13, warranting denial.

b. Cactus MIL 2: To preclude Cameron from introducing evidence, testimony, or

argument from any fact witness, or any expert witnesses on damages, regarding the scope of any claim term or for opinions regarding whether any particular device or system embodies any Asserted Claim. This MIL was DENIED.

c. Cactus MIL 3: To preclude Cameron from introducing evidence, testimony, or

argument regarding images of Cameron’s greasing system at Stella Maris received by Cactus from Mr. Babineaux’s brother. This MIL was GRANTED IN PART. The Parties disputed whether evidence related to an

event occurring in 2021—wherein Mr. Babineaux’s brother covertly took photos of Cameron’s

greasing system at Stella Maris—should be put before the jury. Plaintiff argued that such evidence

would serve to unfairly paint Cactus as an unethical company. Defendant asserted it would only

use such evidence to demonstrate its own lack of willfulness, avoiding any representation of Cactus

as unethical. The Court ORDERED that the Parties are precluded from making any reference to

Greg Babineaux individually as the person that took the photographs without prior leave of the

Court, but otherwise DENIED the MIL.

5. Defendant Cameron’s Motions in Limine (Dkt. No. 107)

a. Cameron MIL 1: Preclude Cactus from offering any evidence, testimony, and

argument that Cameron’s invalidity positions were rejected by the Patent Office and/or that Dr. Wooley’s invalidity opinions “contravene” the Examiner’s conclusions during prosecution.

5This MIL was GRANTED IN PART. Plaintiff must obtain leave of Court before

presenting evidence of the prosecution history of the asserted patent; Plaintiff may not reference

the fact that references used by Defendant in its invalidity case are cited on the face of the patent

without leave of Court. Among other issues, the Court will act as a gatekeeper if and when

Defendant elects to advance prior art that was considered during patent examination at trial.

b. Cameron MIL 2: To preclude Cactus from offering any evidence, testimony,

and argument regarding the doctrine of equivalents for purposes of showing that Cameron infringes any asserted claim under 35 U.S.C. § 271. This MIL is MOOT by agreement of the Parties.

c. Cameron MIL 3: To permit the parties to refer to the related Southern District

of Texas litigation between the parties [requesting leave to modify the Court’s MIL No. 13]. This MIL, which overlaps with Cactus MIL 3, was DENIED for reasons similar to those

discussed above for Cactus MIL 3.

6. Exhibits

Following a representation at the pretrial conference that the Parties resolved their exhibit

disputes, the Court ORDERED to Parties to jointly produce a list of all preadmitted exhibits and

promptly send the same to the Court via the Courtroom Deputy. A copy of the Parties’ preadmitted

exhibits, which the Parties sent as ordered, is attached hereto as Exhibit A.

So Ordered this Oct 27, 2026

EASTERN DISTRICT OF TEXAS

CACTUS WELLHEAD, LLC EXHIBIT LIST

V. Case Number: 2:24-CV-01010-JRG

CAMERON INTERNATIONAL CORPORATION

PLAINTIFF'S ATTORNEYS DEFENDANT'S ATTORNEYS

PRESIDING JUDGE RODNEY GILSTRAP

Robert H. Reckers John R. Keville COURT REPORTER COURTROOM DEPUTY

TRIAL DATE(S): December 7, 2026

Shawn McRoberts Andrea Brunson JTX PTX DTX DATE PRE

MARKED DESCRIPTION OF EXHIBITS

No. No. No. OFFERED ADMITTED

Cameron Automated Greasing Operation Manual v2.1, 02/22/2021 (CAMN_EDTX_000006-JTX 001 X

CAMN_EDTX_000046)

Case Study: Automated valve greasing save 18 h during zipper frac operations, 09/22/2023 JTX 002 X

(CAMN_EDTX_000050-CAMN_EDTX_000052)

Email from Maloney to Bulman, Subject: Re: Auto-greasing stoppage, 03/26/2026 (CAMN_EDTX_129047-JTX 003 X

CAMN_EDTX_129049)

Schlumberger, Business Case Surface Systems Frac Tree Greasing Automation (Tony Viator) JTX 004 X

(CAMN_EDTX_000142-CAMN_EDTX_000158)

Presentation: Schlumberger Automated Greasing System (PPD # 135473) Business Commercialization CDP, JTX 005 X

1/0/2021 (CAMN_EDTX_117223-CAMN_EDTX_117261)

Schlumberger, Valve Commander on Agora User Guide, 01/27/2025 (CAMN_EDTX_128823-JTX 006 X

CAMN_EDTX_129019)

JTX 007 X Brochure: Meyer Remote Grease Manifold, 03/00/2019 (MEYER_0189-MEYER_0189) JTX 008 X Meyer, Remote Grease Manifold Operation Manual (Version 3.0), 07/10/1905 (MEYER_0430-MEYER_0450) JTX 009 X Presentation: Meyer, Multi-Station Greasing Manifold System, 07/10/1905 (MEYER_0569-MEYER_0586) JTX 010 X U.S. Pat. Appl. Publ. No. 2017/0276293, Lubrication Manifold to McKim, 09/28/2017

Excel Spreadsheet: Invoice map of jobs that include Automated Grease Unit (CAMN_EDTX_000003-JTX 011 X

CAMN_EDTX_000003)

Excel Spreadsheet: Invoice map of jobs that include Automated Grease Unit (CAMN_EDTX_000004-JTX 012 X

CAMN_EDTX_000004)

Excel Spreadsheet: Invoice map of jobs that include Automated Grease Unit (CAMN_EDTX_000049-JTX 013 X

CAMN_EDTX_000049)

JTX 014 X Excel Spreadsheet: 2025 Monthly Customer Wells, 2025 (CAMN_EDTX_000171-CAMN_EDTX_000171)

Excel spreadsheet: USD Sales 2020-2021 for Chevron, Enerplus Resources, Tap Rock Operating and JTX 015 X

Oxy/Anadarko (CAMN_EDTX_001337-CAMN_EDTX_001337) Excel spreadsheet: Preliminary Business Cases & Product Specification Sheet, Project Name: FRAC DESK -JTX 016 X

Automated Greasing, 10/01/2018 (CAMN_EDTX_124124-CAMN_EDTX_124124) JTX 017 X Excel Spreadsheet: SFP NAL HQ P&L, 03/24/2026 (CAMN_EDTX_128822-CAMN_EDTX_128822) JTX 018 X Excel Spreadsheet: Auto Grease 2026 Thru Feb, 03/26/2026 (CAMN_EDTX_129021-CAMN_EDTX_129021) JTX 019 X Excel Spreadsheet: Greasing Count, 04/06/2026 (CAMN_EDTX_129051-CAMN_EDTX_129051)

Non-Exclusive Patent License Agreement between Cameron International Corporation and Scout Surface Solutions JTX 020 X

LLC (fully executed), 03/25/2021 (CAMN_CACTUS_047212-CAMN_CACTUS_047222) Non-Exclusive Patent License Agreement between Cameron International Corporation and Patriot Research Center JTX 021 X

LLC (fully executed), 07/02/2024 (CAMN_CACTUS_079665-CAMN_CACTUS_079676) Settlement Agreement and Release between Cameron International Corporation and Patriot Control (fully JTX 022 X

executed), 07/01/2024 (CAMN_CACTUS_079677-CAMN_CACTUS_079688) Non-Exclusive Patent License Agreement between Cameron International Corporation and Vault Pressure Control, JTX 023 X

LLC (fully executed), 03/28/2025 (CAMN_CACTUS_147290-CAMN_CACTUS_147300) JTX 024 X Presentation: Cactus, Inc.'s Frac Innovations (color version) (CAC(RGS)_0001373-CAC(RGS)_0001410)

Email from Babineaux to Behrendt, Subject: Remote Greasing AND Attachment: Remote Grease Sys.pptx (color JTX 025 X

version), 01/30/2019 (CAC(RGS)_0040312-CAC(RGS)_0040319) Cactus Wellhead Frac SOP Manual, Section 6 - SafeInject Greasing Procedure (Rev. A), 06/23/2022 JTX 026 X

(CAC(RGS)_0000486-CAC(RGS)_0000530)

Email from Cade to Babineaux, Subject: Fwd: Grease manifold options AND Attachments: 180174 grease manifold.docs; 180176 HIGH FLOW grease unit.docx; datasheet_GreasingManifold_v1 (1).pdf; JTX 027 X

datasheet_Highflow_grease-unit.pdf; datasheet_GreaseFlowMeter_v3.pdf; 180175 deluxe grease w remote.docx, 01/26/2018 (CAC(RGS)_0002094-CAC(RGS)_0002101)

Email from Cade to Babineaux, Subject: RE: Grease Manifold, 01/08/2018 (CAC(RGS)_0002019-JTX 028 X

CAC(RGS)_0002020)

Email from Babineaux to Cade, Subject: RE: Grease manifold options AND Attachment: grease manifold.pptx, JTX 029 X

01/29/2018 (CAC(RGS)_0006612-CAC(RGS)_0006616)

Email from Babineaux to Eric Bender, Subject: FW: XTO: Zipper Manifolds AND Attachments: Grease Manifold_PLC.PPTX; 12962_r0 (ASSY, MANIFOLD ASSY-FESTO SKID).pdf; 129616_r0 (ASSY, HMI ENCLOSURE SKID).pdf; CWOP - Permian RigLock v03.pptx, 03/06/2018 (CAC(RGS)_0040631-CAC(RGS)_0040656)