DCT
3:22-cv-06179
Asetek Danmark As v. Shenzhen Apaltek Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Asetek Danmark A/S (Denmark)
- Defendant: Shenzhen Apaltek Co., Ltd. et al. (China)
- Plaintiff’s Counsel: Bracewell LLP; Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
- Case Identification: 6:21-cv-00501, W.D. Tex., 05/14/2021
- Venue Allegations: Venue is alleged to be proper on the basis that Defendants are foreign corporations not resident in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s all-in-one liquid cooling products infringe four U.S. patents related to integrated liquid cooling systems for electronic components.
- Technical Context: The technology concerns closed-loop liquid cooling systems for high-heat-generating computer components, such as CPUs, a market segment critical for high-performance computing, gaming, and data centers.
- Key Procedural History: The complaint does not detail any significant procedural events such as prior litigation between the parties or administrative challenges to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2003-11-07 | Earliest Priority Date for all Patents-in-Suit |
| 2012-08-14 | U.S. Patent No. 8,240,362 Issues |
| 2012-08-21 | U.S. Patent No. 8,245,764 Issues |
| 2018-09-18 | U.S. Patent No. 10,078,355 Issues |
| 2020-03-24 | U.S. Patent No. 10,599,196 Issues |
| 2021-05-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,240,362 - “Cooling System for a Computer System”
- Patent Identification: U.S. Patent No. 8,240,362, “Cooling System for a Computer System,” issued August 14, 2012.
The Invention Explained
- Problem Addressed: The patent describes conventional air-cooling arrangements as increasingly insufficient for modern, high-heat CPUs, while identifying existing liquid-cooling systems as complex, consisting of many separate components, and posing a risk of coolant leakage (’362 Patent, col. 1:28-47).
- The Patented Solution: The invention proposes an "integrate element" that combines the heat exchanging interface, a reservoir, and a pump into a single compact unit (’362 Patent, col. 2:7-12). This integrated design simplifies installation, reduces the number of connections, and thereby minimizes the risk of leaks, making liquid cooling more suitable for mainstream computer systems (’362 Patent, Abstract).
- Technical Importance: This integrated approach was foundational to the development of modern "All-in-One" (AIO) liquid coolers, which are factory-sealed and easy for consumers to install, thereby broadening the market for high-performance liquid cooling beyond niche enthusiasts (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts independent claim 14 (’362 Patent, col. 20:1-30; Compl. ¶16).
- Essential elements of claim 14 include:
- A reservoir configured to be coupled to a processing unit, adapted to pass cooling liquid therethrough.
- The reservoir includes an upper chamber and a lower chamber, separated by at least a horizontal wall and fluidly coupled by one or more passageways.
- A heat exchanging interface that is removably attached to the reservoir and forms a boundary wall of the lower chamber.
- A heat radiator horizontally spaced from the reservoir.
- A fan to direct air to the heat radiator.
- A pump to circulate liquid, including a motor and an impeller, where the impeller speed can be varied independent of the fan speed.
U.S. Patent No. 8,245,764 - “Cooling System for a Computer System”
- Patent Identification: U.S. Patent No. 8,245,764, “Cooling System for a Computer System,” issued August 21, 2012.
The Invention Explained
- Problem Addressed: Similar to the ’362 Patent, the invention addresses the shortcomings of complex, multi-component liquid cooling systems and the thermal limitations of air cooling (’764 Patent, col. 1:16-52).
- The Patented Solution: This patent focuses on a specific pump architecture within an integrated cooling unit. The core concept is a "double-sided chassis" where the pump's impeller (the "wet" side) is positioned on one side of the chassis within the cooling liquid, while the stator (the "dry" electrical side of the motor) is positioned on the opposite side, isolated from the liquid (’764 Patent, col. 2:40-52). The reservoir is described as having separate, vertically spaced pump and thermal exchange chambers (’764 Patent, Abstract).
- Technical Importance: By physically separating the motor's electrical components from the coolant, this design enhances the safety and reliability of the integrated pump-on-block unit, a critical factor for consumer-grade electronics (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts independent claim 1 (’764 Patent, col. 28:2-41; Compl. ¶31).
- Essential elements of claim 1 include:
- A double-sided chassis for mounting a pump, with the impeller on the underside and the stator on the upper side, isolated from the cooling liquid.
- A reservoir adapted to pass cooling liquid, which includes a pump chamber and a thermal exchange chamber that are vertically spaced apart and fluidly coupled.
- A heat-exchanging interface forming a boundary wall of the thermal exchange chamber.
- A heat radiator fluidly coupled to the reservoir.
Multi-Patent Capsule: U.S. Patent No. 10,078,355 - “Cooling System for a Computer System”
- Patent Identification: U.S. Patent No. 10,078,355, “Cooling System for a Computer System,” issued September 18, 2018.
- Technology Synopsis: The ’355 patent discloses a liquid cooling system featuring a reservoir that houses both a pump chamber and a separate thermal exchange chamber. It claims a specific arrangement where the impeller and stator are on opposite sides of a double-sided chassis, and details the fluid dynamics with an inlet positioned below the center of the impeller and an outlet positioned tangentially to its circumference (’355 Patent, Abstract; col. 27:20-28:50).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶46).
- Accused Features: The complaint accuses the integrated pump-on-block unit of the accused products, focusing on its internal division into a pump chamber and thermal exchange chamber, the double-sided chassis motor design, and the specific locations of the fluid inlet and outlet relative to the impeller (Compl. ¶¶48-54).
Multi-Patent Capsule: U.S. Patent No. 10,599,196 - “Cooling System for a Computer System”
- Patent Identification: U.S. Patent No. 10,599,196, “Cooling System for a Computer System,” issued March 24, 2020.
- Technology Synopsis: The ’196 patent claims a cooling system with a similar integrated pump-on-block architecture, including a pump chamber, thermal exchange chamber, and a double-sided chassis separating the motor's impeller and stator. A distinguishing feature of the asserted claim is the inclusion of "a set of four mounting legs configured to secure the heat-exchanging interface to a heat-generating component" (’196 Patent, Abstract; col. 30:2-10).
- Asserted Claims: Independent claim 10 is asserted (Compl. ¶62).
- Accused Features: The infringement allegations target the overall structure of the accused products' pump unit, including its internal chambers and motor design, as well as the specific four-legged mounting bracket used to attach the unit to a computer's CPU (Compl. ¶¶64-69).
III. The Accused Instrumentality
- Product Identification: The complaint names the Lian Li Galahad AIO 240 RGB, the Enermax AquaFusion 240, and the Thermaltake TH120 ARGB Sync as "Exemplary Infringing Products" (Compl. ¶7). The analysis in the complaint uses the Lian Li Galahad AIO 240 as a representative product for all accused product lines (Compl. p. 5).
- Functionality and Market Context: The accused instrumentalities are all-in-one (AIO) closed-loop liquid coolers designed for cooling computer processors (Compl. ¶17). They function by circulating a liquid coolant between a pump block mounted on the CPU and a separate radiator, where heat is dissipated into the air via fans (Compl. ¶¶21, 23). The complaint alleges that all accused products share the "same fundamental pump unit structure and configuration," which forms the basis of the infringement allegations (Compl. ¶13).
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,240,362 Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a reservoir configured to be coupled to the processing unit...the reservoir being adapted to pass a cooling liquid therethrough | The integrated pump and cold plate unit of the Galahad product, which is mounted on the CPU and circulates coolant. | ¶18 | col. 12:12-18 |
| an upper chamber and a lower chamber...separated by at least a horizontal wall and fluidly coupled together by one or more passageways | The internal structure of the Galahad pump unit, which the complaint alleges contains separate upper and lower chambers connected by passages. A teardown image shows an internal dividing wall (Compl. p. 7). | ¶19 | col. 25:31-38 |
| a heat exchanging interface configured to be placed in separable thermal contact with the processing unit, the heat exchanging interface being removably attached to the reservoir | The copper cold plate at the base of the pump unit, which contacts the CPU and is attached to the main housing with screws. | ¶20 | col. 12:4-11 |
| a heat radiator configured to be positioned at a second location horizontally spaced apart from the first location | The radiator assembly, connected to the pump unit via flexible tubing, which is mounted elsewhere in the computer case. | ¶21 | col. 10:55-58 |
| a fan adapted to direct air to the heat radiator to dissipate heat | The fans mounted on the radiator assembly. | ¶22 | col. 10:65-67 |
| a pump configured to circulate cooling liquid...wherein a speed of the impeller is configured to be varied independent of the speed of the fan | The pump integrated into the CPU block, which is powered and controlled separately from the radiator fans. | ¶23 | col. 14:46-52 |
U.S. Patent No. 8,245,764 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a double-sided chassis to mount a pump...the impeller being positioned on the underside of the chassis and the stator being positioned on the upper side of the chassis and isolated from the cooling liquid | The internal housing of the pump unit, which is alleged to separate the pump impeller (in the liquid) from the stator (kept dry). An image shows the stator on one component and the impeller on another (Compl. p. 12). | ¶33 | col. 2:40-45 |
| a reservoir adapted to pass the cooling liquid therethrough | The housing of the pump unit that contains the chambers and directs the flow of coolant. | ¶34 | col. 2:53-61 |
| a pump chamber including the impeller and formed below the chassis...a thermal exchange chamber formed below the pump chamber and vertically spaced apart from the pump chamber | The internal volume of the pump unit is alleged to be divided into these distinct, vertically arranged chambers. | ¶¶35-36 | col. 28:34-37 |
| a heat-exchanging interface...forming a boundary wall of the thermal exchange chamber, and configured to be placed in thermal contact with a surface of the heat-generating component | The copper cold plate at the base of the pump unit. | ¶37 | col. 28:20-25 |
| a heat radiator fluidly coupled to the reservoir and configured to dissipate heat from the cooling liquid | The radiator assembly connected to the pump unit by flexible tubing. | ¶38 | col. 2:58-61 |
- Identified Points of Contention:
- Scope Questions: The case may present a significant claim construction dispute over the term "reservoir." Defendants may argue that in the context of the patents, the term implies a unit with a primary function of fluid storage, whereas the accused product's pump block is primarily a pump and cold plate assembly. The complaint's use of teardown photos, such as the one on page 7 showing the pump unit's internal components (Compl. p. 7), will be central to arguments about whether this integrated structure meets the claim definition.
- Technical Questions: The complaint alleges the existence of specific internal chambers (e.g., "upper and lower," "pump and thermal exchange") based on visual inspection of disassembled products. A central technical question will be whether the fluid dynamics within the accused products actually correspond to the claimed structures. For example, what evidence demonstrates that the alleged chambers are "vertically spaced apart" and "fluidly coupled together by one or more passages" in the manner required by the claims, beyond the simple existence of an internal dividing wall?
V. Key Claim Terms for Construction
The Term: "reservoir" (asserted in claims of all four patents-in-suit)
- Context and Importance: This term is foundational, defining the main pump-on-block unit. Its construction will determine whether the accused products' integrated pump and cold plate assembly falls within the scope of the claims. Practitioners may focus on this term because its ordinary meaning (a place for storing fluid) could be argued as distinct from the multi-function integrated unit of the accused products.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specifications repeatedly describe an "integrate element comprising the heat exchanging interface, the reservoir and the pump," suggesting "reservoir" is used as a term for the housing of this entire integrated unit (’362 Patent, col. 2:7-12).
- Evidence for a Narrower Interpretation: The specification also refers to the reservoir in a more conventional sense as a "storage unit for excess liquid" and a means for "venting the system of any air entrapped" (’362 Patent, col. 10:59-63). This language could support a narrower construction requiring a primary function of fluid storage or system maintenance, which a defendant might argue its compact pump block does not possess.
The Term: "double-sided chassis" (’764 Patent, claim 1)
- Context and Importance: This term defines the key structural innovation for isolating the motor's electrical components from the coolant. The infringement analysis for the ’764, ’355, and ’196 patents depends on whether the accused products' internal partition qualifies as a "double-sided chassis."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the chassis functionally as a structure where "the impeller [is] positioned on the underside of the chassis and the stator [is] positioned on the upper side of the chassis and isolated from the cooling liquid" (’764 Patent, col. 28:5-9). This functional language may support a construction that covers any physical partition achieving this wet/dry separation.
- Evidence for a Narrower Interpretation: Figure 17 of the related ’355 patent depicts a specific embodiment with a conical housing and a central "jacket" (44) extending from a recess (40) to house the rotor. A defendant could argue the term should be limited to a structure incorporating these specific features, which may differ from the design of the accused products.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendants supply the accused products to customers and resellers (e.g., Lian Li, Thermaltake, Amazon) with knowledge and intent that they will be used in an infringing manner, and provide user manuals instructing customers on how to install and use them (Compl. ¶¶24, 39, 55, 70).
- Willful Infringement: The complaint alleges that Defendants infringed "in an egregious and willful manner and with knowledge of the" patents-in-suit, or were willfully blind to the risk of infringement (Compl. ¶¶27, 42, 58, 73). The basis for pre-suit knowledge is pleaded "upon information and belief."
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "reservoir," which the patent describes as part of an integrated pump-and-interface element, be construed to read on the accused all-in-one pump-on-block units, or will it be limited to a narrower meaning focused on fluid storage, potentially placing the accused products outside the claims?
- A key evidentiary question will be one of structural and functional correspondence: does the evidence for the accused products, which relies heavily on teardown photographs like the one depicting the disassembled pump unit (Compl. p. 14), demonstrate that their internal fluid paths and chambers operate in the specific manner required by the claims (e.g., as "vertically spaced apart" chambers coupled by "passageways"), or is there a fundamental mismatch in technical operation?