Loeb & Loeb
A Limited Liability PartnershipIncluding ProfessionalCorporations
Seaboard International, Inc. (“Seaboard”), for its complaint against CameronInternational Corporation (“Cameron”), alleges as follows:
JURISDICTION AND VENUE
This action arises under the patent laws of the United States, Title 35,United States Code. The Court has subject matter jurisdiction over this action pursuant to28 U.S.C. §§ 1331 and § 1338(a).2.
Venue is proper pursuant to 28 U.S.C. §§ 1391(b) and 1400(b).3.
This district has a strong interest in the resolution of this suit. Theinvention claimed in the asserted patent—which is used during hydraulic fracturing or“fracing” operations—was conceived, reduced to practice, and commercialized in thisdistrict. The named inventors also reside in this district. According to published data onfracing after January 1, 2011, there are at least 700 fracing sites in California; the vastmajority are located in this district.
Seaboard International, Inc. is a Texas corporation with a place of businessat 3912 Gilmore Avenue, Bakersfield, California.5.
Cameron International Corporation is a Delaware corporation with aprincipal place of business at 1333 West Loop South, in Houston, Texas.
Seaboard manufacturers wellhead and pressure control equipment. In 2007,Seaboard acquired Duhn Oil Tool, Inc., a family-owned, California company based inBakersfield, California since 1975. Duhn designed and manufactured wellhead devicesprotected by a dozen patents, including several patents protecting a tool used to protectwellhead equipment during fracing operations when abrasive material is introduced atextremely high pressure to create new pathways for hydrocarbon extraction.7.
Cameron is a global supplier of flow equipment products, systems, andservices to oil, gas, and process industries. Among other products, Cameron sells andinstalls products used in fracing operations.