DCT

3:23-cv-01079

Shenzhen Apaltek Co Ltd v. Asetek Danmark As

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:23-cv-01079, N.D. Cal., 04/17/2023
  • Venue Allegations: Plaintiff alleges that Defendant has consented to venue in the Northern District of California through prior litigation involving some of the patents-in-suit and has purposefully directed enforcement activities into the district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their liquid cooling products do not infringe nine of Defendant's patents related to integrated computer cooling systems.
  • Technical Context: Liquid cooling for high-performance computer processors is a critical technology for managing thermal energy, enabling faster computation, and reducing acoustic noise compared to traditional air cooling.
  • Key Procedural History: The complaint notes extensive prior litigation by Defendant involving the patents-in-suit. Central to this action is a final summary judgment ruling in a separate case, Asetek v. CoolIT Systems, where the court construed a "reservoir" limitation common to the patents as requiring a "single receptacle." Plaintiffs base their non-infringement position on this prior ruling. The complaint also references a pending case filed by Defendant against Plaintiffs (Asetek v. Apaltek, N.D. Cal. Case No. 3:22-cv-06179), which Defendant is seeking to dismiss while maintaining that its patents are infringed, creating the alleged controversy for this declaratory judgment action. Subsequent to the filing of this complaint, inter partes review (IPR) proceedings have resulted in the cancellation of numerous claims across the patents-in-suit, including all independent claims of U.S. Patent Nos. 10,078,354 and 10,078,355.

Case Timeline

Date Event
2004-11-08 Priority Date for ’362 Patent Family (incl. ’354, ’601, ’861)
2005-05-06 Priority Date for ’764 Patent Family (incl. ’681, ’355, ’196, ’862)
2012-08-14 U.S. Patent No. 8,240,362 Issues
2012-08-21 U.S. Patent No. 8,245,764 Issues
2017-08-15 U.S. Patent No. 9,733,681 Issues
2018-09-18 U.S. Patent No. 10,078,354 Issues
2018-09-18 U.S. Patent No. 10,078,355 Issues
2020-03-24 U.S. Patent No. 10,599,196 Issues
2020-04-07 U.S. Patent No. 10,613,601 Issues
2022-03-29 U.S. Patent No. 11,287,861 Issues
2022-03-29 U.S. Patent No. 11,287,862 Issues
2023-04-17 Complaint for Declaratory Judgment Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,078,354 - "Cooling System for a Computer System"

  • Patent Identification: U.S. Patent No. 10,078,354, "Cooling System for a Computer System," issued September 18, 2018.

The Invention Explained

  • Problem Addressed: The patent describes that as computer processing units (CPUs) become faster, they generate more heat, rendering traditional air-cooling arrangements less effective (Compl. ¶17; ’354 Patent, col. 1:36-44). Existing liquid-cooling systems are described as being composed of many separate components, which increases installation time, complexity, and the risk of leakage, making them undesirable for mainstream consumer PCs (’354 Patent, col. 1:48-57).
  • The Patented Solution: The invention proposes a compact and integrated liquid-cooling solution where the heat exchanging interface, the liquid reservoir, and the pump are combined into a single "integrate element." (’354 Patent, col. 2:15-20). This integrated design is intended to be smaller, less complex, and easier to install in existing computer systems, overcoming the drawbacks of prior multi-component liquid coolers (’354 Patent, col. 1:62-col. 2:2).
  • Technical Importance: This integrated approach sought to make the superior thermal performance of liquid cooling accessible and practical for the mass-market personal computer industry, which had previously relied on simpler but less effective air cooling. (Compl. ¶17; ’354 Patent, col. 1:21-24).

Key Claims at a Glance

  • The complaint seeks a declaration of non-infringement of "any claim" of the patents-in-suit (Compl. ¶24). Independent claim 1 is representative of the patent's core inventive concept.
  • The essential elements of independent claim 1 include:
    • A reservoir configured to circulate a cooling liquid, comprising an upper and a lower chamber.
    • A first passage coupling the lower chamber to the upper chamber.
    • A second passage at the perimeter of the lower chamber.
    • A plurality of channels in the lower chamber to direct liquid flow.
    • A heat exchanging interface attached to the reservoir to form a boundary wall.
    • A pump with a motor and impeller positioned within the upper chamber.
    • A radiator spaced apart from and fluidly coupled to the reservoir.
  • The complaint reserves the right to address any claims asserted by Defendant (Compl. ¶24). As of a June 14, 2024 IPR Certificate, all independent claims (1, 8, 15) of the ’354 Patent have been canceled.

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.

The Invention Explained

  • Problem Addressed: The patent addresses the same technical challenge as the ’354 Patent: the inadequacy of air cooling for modern CPUs and the complexity and leak-proneness of conventional liquid cooling systems (’355 Patent, col. 1:21-50).
  • The Patented Solution: The invention discloses a liquid cooling system featuring an integrated design where the pump's stationary part (stator) is placed outside the liquid reservoir, while the moving part (rotor and impeller) is embedded within the cooling liquid inside the reservoir (’355 Patent, col. 2:38-46). This arrangement, shown in Figure 17, aims to create a reliable seal and a compact unit by separating the electrical motor components from the liquid without complex sealing structures (’355 Patent, col. 21:22-44).
  • Technical Importance: This design architecture provides a method for integrating an electric motor into a liquid cooling pump head while minimizing the risk of leaks, a key concern for placing liquid-filled components inside a computer case housing sensitive electronics. (Compl. ¶17; ’355 Patent, col. 1:45-50).

Key Claims at a Glance

  • The complaint seeks a declaration of non-infringement of "any claim" (Compl. ¶24). Independent claim 1 is representative.
  • The essential elements of independent claim 1 include:
    • A reservoir with a pump chamber housing an impeller, defined by an impeller cover and a double-sided chassis.
    • A stator of the pump positioned on the opposite side of the chassis from the impeller.
    • A thermal exchange chamber disposed between the pump chamber and the heat-generating component.
    • A heat-exchanging interface forming a boundary wall of the thermal exchange chamber.
    • A heat radiator fluidly coupled to the reservoir.
  • The complaint reserves the right to address any claims asserted by Defendant (Compl. ¶24). Subsequent to the complaint's filing, claims 1, 2, 5, 6, and 8 were canceled via an IPR certificate dated July 17, 2024.

Multi-Patent Capsules

  • U.S. Patent No. 8,240,362: "Cooling System for a Computer System," issued August 14, 2012. This is a parent patent to the ’354 Patent, disclosing the foundational integrated cooling unit combining a reservoir, pump, and heat exchanger to address the shortcomings of complex, multi-part liquid cooling systems (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims. The patent-in-suit is subject to a May 2, 2024 IPR certificate cancelling all claims (1-19).

  • U.S. Patent No. 8,245,764: "Cooling System for a Computer System," issued August 21, 2012. This is a parent patent to the ’355 Patent, disclosing an integrated cooling unit with a focus on the pump and reservoir design to provide a compact and reliable liquid cooling solution for CPUs (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims. The patent-in-suit is subject to a May 1, 2024 IPR certificate cancelling all claims (1-30).

  • U.S. Patent No. 9,733,681: "Cooling System for a Computer System," issued August 15, 2017. This patent is part of the ’764 patent family and further develops the integrated liquid cooling system, describing specific configurations of the pump chamber, thermal exchange chamber, and flow paths (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims. Claims 8, 11, 15 and 16 were disclaimed via an IPR certificate dated April 4, 2023.

  • U.S. Patent No. 10,599,196: "Cooling System for a Computer System," issued March 24, 2020. This patent is part of the ’764 patent family and discloses refinements to the integrated cooling system, particularly concerning the arrangement of the pump chambers, heat exchange interface, and radiator (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims.

  • U.S. Patent No. 10,613,601: "Cooling System for a Computer System," issued April 7, 2020. This patent is part of the ’362 patent family and describes further embodiments of the integrated cooling unit, focusing on control systems and specific channel configurations within the liquid reservoir (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims.

  • U.S. Patent No. 11,287,861: "Cooling System for a Computer System," issued March 29, 2022. This patent is part of the ’362 patent family and continues the development of the integrated liquid cooling system architecture (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims.

  • U.S. Patent No. 11,287,862: "Cooling System for a Computer System," issued March 29, 2022. This patent is part of the ’764 patent family and discloses further configurations of the compact liquid cooling apparatus (Compl. ¶17). Apaltek seeks DJ of non-infringement of any claims.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies "Apaltek's past and current products" as the instrumentalities for which a declaratory judgment of non-infringement is sought (Compl. ¶26, ¶29). Specific product models are not named.

Functionality and Market Context

  • The complaint provides minimal technical detail about the functionality of Apaltek's products. The core of the non-infringement allegation is structural: the products are alleged to include structures that the court in Asetek v. CoolIT "summarily ruled are non-infringing" (Compl. ¶26). This ruling concerned the interpretation of a claimed "reservoir" as requiring a "single receptacle," a feature Apaltek's products allegedly lack (Compl. ¶25, ¶28). The complaint suggests Apaltek is a significant competitor in the computer liquid cooling market, noting that Defendant has "sued most of the industry" (Compl. ¶22).

IV. Analysis of Infringement Allegations

The complaint does not allege infringement but instead seeks a declaration of non-infringement. Its central theory is that all patents-in-suit require a "reservoir" that, based on a prior court ruling, must be a "single receptacle" (Compl. ¶25, ¶28). Apaltek contends its products do not have this structure and are therefore non-infringing (Compl. ¶26). The following tables summarize this non-infringement position with respect to the representative independent claims.

No probative visual evidence provided in complaint.

’354 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Apaltek's Non-Infringement Position Complaint Citation Patent Citation
a reservoir configured to circulate a cooling liquid therethrough, the reservoir including: an upper chamber and a lower chamber... Apaltek alleges its products do not have a "reservoir" limitation requiring a "single receptacle" as previously construed by the Court. ¶25, ¶28 col. 19:22-26
a heat exchanging interface attached to the reservoir to form a boundary wall of the lower chamber... The complaint does not provide sufficient detail for analysis of this element. col. 19:35-39
a pump having a motor and an impeller, the impeller being positioned within the upper chamber of the reservoir; The complaint does not provide sufficient detail for analysis of this element. col. 19:40-42
and a radiator spaced apart from and fluidly coupled to the reservoir. The complaint does not provide sufficient detail for analysis of this element. col. 19:44-46

’355 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Apaltek's Non-Infringement Position Complaint Citation Patent Citation
a reservoir configured to circulate a cooling liquid therethrough, the reservoir including: a pump chamber housing an impeller... Apaltek alleges its products do not have a "reservoir" limitation requiring a "single receptacle" as previously construed by the Court. ¶25, ¶28 col. 27:21-23
a thermal exchange chamber disposed between the pump chamber and the heat-generating component... The complaint does not provide sufficient detail for analysis of this element. col. 27:30-33
a heat-exchanging interface forming a boundary wall of the thermal exchange chamber... The complaint does not provide sufficient detail for analysis of this element. col. 27:34-36
a heat radiator adapted to pass the cooling liquid therethrough, the heat radiator being fluidly coupled to the reservoir... The complaint does not provide sufficient detail for analysis of this element. col. 27:42-45
  • Identified Points of Contention:
    • Scope Questions: The primary dispute concerns claim scope: whether the term "reservoir" as used across the patents-in-suit is limited to a "single receptacle" structure. This question hinges on whether the reasoning from the Asetek v. CoolIT decision is applicable to all asserted patents and controlling in this case.
    • Technical Questions: A key factual question is whether Apaltek's products actually practice a design that falls outside the "single receptacle" construction. The complaint asserts this is the case but provides no technical evidence, such as product diagrams or operational descriptions, to substantiate the claim (Compl. ¶26).

V. Key Claim Terms for Construction

  • The Term: "reservoir"
  • Context and Importance: This term is central to the dispute. Its construction was the basis for a summary judgment of non-infringement in prior litigation involving Defendant, and Plaintiffs' entire declaratory judgment action is predicated on the argument that this construction applies here and absolves their products of infringement (Compl. ¶25, ¶28). Practitioners may focus on this term because its definition could be case-dispositive for the entire family of asserted patents.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a functional description, stating the reservoir "serves as a storage unit for excess liquid not capable of being contained in the remaining components" and as "a means for venting the system." (’354 Patent, col. 8:9-13). Such functional language could be argued to support a broader definition not limited to a specific structure.
    • Evidence for a Narrower Interpretation: The embodiments depicted consistently show a single, integrated housing (labeled as element 14 in Fig. 4) that contains the pump and serves as the reservoir (’354 Patent, Figs. 4-6). This consistent depiction of a unitary structure could be cited to support a narrower construction limited to a "single receptacle." The abstract also describes an "integrate element" comprising the heat exchanging interface, reservoir, and pump, which may suggest a physically unified structure (’354 Patent, Abstract).

VI. Other Allegations

  • Indirect Infringement: The complaint seeks a declaration of non-infringement "directly or indirectly" (Compl., p. 6, Prayer for Relief, ¶A). However, the body of the complaint does not allege any specific facts concerning knowledge or intent that would be relevant to induced or contributory infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

This declaratory judgment action appears to center on a preemptive legal argument rather than a detailed technical dispute. The key questions for the court will likely be:

  • A primary issue will be the impact of post-filing events: given that numerous asserted claims, including all independent claims of the lead patents analyzed, have been canceled in IPR proceedings that concluded after this complaint was filed, what is the remaining justiciable controversy, and can the case proceed on any surviving claims?
  • A core legal question is one of issue preclusion and claim scope: to what extent is the court’s prior construction of the term "reservoir" in the Asetek v. CoolIT case binding or persuasive in this matter, and does that single construction govern the scope of infringement for all nine patents-in-suit as alleged by the Plaintiff?
  • A fundamental evidentiary question will be one of technical comparison: should the case proceed, what are the specific designs of the "past and current" Apaltek products, and does the evidence show that they lack the structural elements required by a proper construction of the asserted claims?