Magma Power LLC v. Geoalaska LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Magma Power, LLC (Florida)
  • Defendant: Geoalaska, LLC (Alaska); Ignis H2 Energy, Inc. (Texas); American Geopower, LLC (Delaware)
  • Plaintiff’s Counsel: The Strategic LegalGroup, PLLC
• Case Identification: 8:25-cv-02587, M.D. Fla., 09/24/2025
• Venue Allegations: Plaintiff alleges venue is proper because it is a Florida company that resides in the district and because a substantial part of the events giving rise to the claims, including the harm from Defendants' alleged defamatory statements and threatened patent infringement, occurred in the district.
• Core Dispute: Plaintiff alleges that Defendants' publicly announced plans to develop geothermal power projects by drilling into magma reservoirs in Alaska will necessarily infringe patents covering methods and apparatuses for extracting energy from such reservoirs.
• Technical Context: The technology at issue relates to advanced geothermal energy systems designed to overcome the limitations of conventional methods by directly tapping into the high-energy potential of underground magma reservoirs.
• Key Procedural History: The complaint alleges that prior to filing suit, Defendants engaged in a defamatory campaign against Plaintiff beginning in October 2024. Plaintiff allegedly issued a cease-and-desist letter to principals of Defendant American GeoPower on October 29, 2024. The complaint further alleges that public statements made by an owner of Defendant GeoAlaska demonstrate Defendants' knowledge of the patents-in-suit prior to the announced infringement, which may be relevant to the allegation of willfulness.

Case Timeline

Date	Event
2022-02-28	Earliest Priority Date for ’383 and ’278 Patents
2023-12-26	U.S. Patent No. 11,852,383 Issues
2024-10-01	Alleged Defamation Campaign Begins (approx.)
2024-10-29	Plaintiff Issues Cease-and-Desist Letter
2025-06-10	U.S. Patent No. 12,326,278 Issues
2025-08-04	Defendants Announce Intent to Drill in Alaska
2025-09-24	Complaint Filed

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

U.S. Patent No. 11,852,383 - "Geothermal Power from Superhot Geothermal Fluid and Magma Reservoirs," issued December 26, 2023

The Invention Explained

• Problem Addressed: The patent describes conventional geothermal systems as financially impractical due to their reliance on low-temperature resources and susceptibility to equipment failure from corrosion and scaling caused by high concentrations of total dissolved solids (TDS) in geothermal fluids (’383 Patent, col. 5:32-44, col. 6:12-34).
• The Patented Solution: The invention is a pumping apparatus designed to extract superhot geothermal fluid (SHGF) without requiring a submerged motor and pump, which are vulnerable to the harsh environment. The system uses a well screen partially submerged in the underground reservoir and a coaxially aligned "slidable casing." The slidable casing is repositioned downward to cover the screen's apertures, trapping a volume of SHGF. Pressure is then increased within the slidable casing's cavity (e.g., via compressed air), forcing the trapped fluid up a draw pipe to the surface (’383 Patent, Abstract; col. 8:31-55).
• Technical Importance: This mechanical displacement approach seeks to enable the reliable harvesting of high-temperature geothermal resources by avoiding direct, prolonged exposure of complex pumping machinery to the corrosive SHGF at depth (’383 Patent, col. 7:16-20).

Key Claims at a Glance

• The complaint asserts apparatus claims 1-10 and method claims 11-20 (Compl. ¶¶ 71, 77).
• Independent Claim 1 (apparatus) includes:
  • A well screen coupled to a casing string, at least partially submerged in an underground reservoir of SHGF, defining a volume to be filled with SHGF through apertures.
  • A slidable casing suspended in the borehole, defining a cavity, and coaxially aligned with the well screen.
  • A draw pipe extending through an end wall of the slidable casing, configured to convey SHGF to the surface in response to two conditions: (1) the slidable casing being repositioned to obstruct more of the well screen's apertures, and (2) an increase in pressure within the slidable casing's cavity.
• Independent Claim 11 (method) includes:
  • Repositioning a slidable casing from an initial position to a final position at least partially within the underground reservoir.
  • Securing the slidable casing at the final position.
  • Increasing a pressure within the cavity of the slidable casing to cause the SHGF to flow into a draw pipe.
  • Conveying the SHGF to the surface through the draw pipe.
• The complaint asserts infringement of all claims of the patent (Compl. ¶3).

U.S. Patent No. 12,326,278 - "Geothermal Power from Superhot Geothermal Fluid and Magma Reservoirs," issued June 10, 2025

The Invention Explained

• Problem Addressed: The patent addresses the same background problem as the ’383 Patent: the technological and financial impracticality of accessing high-density geothermal energy from magma reservoirs using conventional means (’278 Patent, col. 1:19-29).
• The Patented Solution: The invention is a "cased wellbore" system designed to generate superheated steam. It features a fluid pathway extending from the surface down to a magma reservoir and back to the surface. This pathway, often formed by a set of nested boiler casings, is configured to receive a working fluid (such as saturated steam), use the magma's heat to transform it into superheated steam at the wellbore's lower end, and then convey the superheated steam to the surface for power generation (’278 Patent, Abstract; col. 2:41-3:4). A wellhead at the surface includes connectors for the fluid inlet and outlet.
• Technical Importance: This system represents a closed-loop approach that uses magma as a heat exchanger rather than extracting native geothermal fluids, which may avoid issues of corrosion and TDS while enabling the generation of high-temperature, high-pressure steam (’278 Patent, col. 7:46-55).

Key Claims at a Glance

• The complaint asserts cased wellbore claims 1-11, system claims 12-19, and method claims 20-25 (Compl. ¶¶ 83, 89, 94).
• Independent Claim 1 (cased wellbore) includes:
  • A first end at a surface and a second end at an underground reservoir of magma.
  • A fluid pathway extending from an inlet at the first end to the second end, and then back to an outlet at the first end.
  • The fluid pathway is configured to receive saturated steam at the inlet and expel superheated steam from the outlet.
  • A wellhead including connectors for the inlet and outlet, an aperture for a drill stem, and a configuration where the inlet diameter is greater than the outlet diameter.
• Independent Claim 12 claims a system including the cased wellbore and a set of turbines.
• Independent Claim 20 claims a method of generating superheated steam using such a wellbore.
• The complaint asserts infringement of all claims of the patent (Compl. ¶3).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are not existing products but are Defendants' announced and planned geothermal power generation projects at Mount Augustine and Mount Spurr, Alaska (Compl. ¶4, ¶33).

Functionality and Market Context

• The complaint alleges that on August 4, 2025, Defendants GeoAlaska and Ignis issued a press release announcing their exploration for geothermal power, with an expected generation capacity of over 200+ MW at the Augustine Island prospect (Compl. ¶33). The complaint alleges these activities will necessarily involve drilling into magma reservoirs and extracting geothermal energy using methods and systems covered by the patents-in-suit (Compl. ¶34, ¶37). It further alleges that it is "technologically impossible" to extract superhot geothermal fluid from magma reservoirs without using the patented technology (Compl. ¶38, ¶86).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’383 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a well screen coupled to an end of a casing string and at least partially submerged within the underground reservoir... configured to be at least partially filled by the SHGF through a set of apertures in the well screen	Defendants' announced activities to extract geothermal fluid would necessarily require a pumping apparatus with a well screen system in magma boreholes.	¶73(a), ¶73(j)	col. 31:40-49
a slidable casing... suspended within the borehole... and aligned coaxially with the well screen	Defendants' planned pumping apparatus would necessarily employ a slidable casing to be repositioned within the magma reservoir for fluid extraction.	¶73(a), ¶73(b)	col. 31:50-58
a draw pipe... configured to convey the SHGF... in response to: the slidable casing being slidably repositioned... and an increase in pressure within the cavity of the slidable casing	The announced system would necessarily use a draw pipe and a pressurization system (e.g., using compressed air or compressors) to convey fluid to the surface.	¶73(a), ¶73(c), ¶73(d)	col. 31:59-32:11

Identified Points of Contention

• Evidentiary Question: The complaint's infringement theory rests on the allegation that it is "impossible to extract superhot geothermal fluid from the magma reservoirs without infringing" the asserted claims (’383 Patent, ¶74). A central question for the court will be a factual one: what evidence supports this claim of technological necessity? Defendants may argue that alternative, non-infringing designs for extracting geothermal fluid exist and are part of their plans.
• Technical Question: What specific features of Defendants' planned, but not yet built, apparatus will meet the claim limitation requiring SHGF conveyance to be "in response to" both the repositioning of the slidable casing and an increase in pressure? The analysis may focus on whether Defendants' planned system links these two conditions in the manner required by the claim.

’278 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a cased wellbore for generating superheated steam, the cased wellbore comprising: a first end at a surface; a second end at an underground reservoir of magma	Defendants' announced plan to drill into magma reservoirs for power generation will necessarily require the construction of a cased wellbore extending from the surface to the magma.	¶84, ¶85(a)	col. 29:2-5
a fluid pathway extending from an inlet... to the second end and then... to an outlet... configured to receive saturated steam at the inlet and expel superheated steam from the outlet	The announced activities will necessarily require a cased wellbore with fluid pathways for steam circulation, where a working fluid is heated by magma to generate superheated steam.	¶85(a), ¶85(c)	col. 29:6-15
a wellhead that includes: an aperture configured to receive a drill stem; a first connector... to a source of the saturated steam; and a second connector... to a system for generating power from superheated steam, wherein a first diameter of the inlet... is greater than a second diameter of the outlet	The planned wellbore systems would necessarily include a wellhead with appropriate apertures and connectors for steam circulation to and from the power generation facility.	¶85(a)	col. 29:16-27

Identified Points of Contention

• Scope Questions: Claim 1 requires a fluid pathway configured to "receive saturated steam." A potential point of contention is whether this limitation reads on a system that might be designed to receive liquid-phase water at the inlet, which is then converted to steam within the wellbore. The construction of "receive saturated steam" may be critical.
• Technical Questions: Does the planned 200+ MW power generation facility require the specific "cased wellbore" and "fluid pathway" structure as claimed? The complaint alleges it is "impossible" to generate superheated steam from magma without infringing these claims (Compl. ¶86), a position that raises a key technical question for expert analysis.

V. Key Claim Terms for Construction

Term from the ’383 Patent: "slidable casing" (Claim 1)

• Context and Importance: This term defines a core moving part of the claimed pumping apparatus. The infringement analysis will depend on whether this term is construed to cover any movable casing that performs the claimed function or is limited to the specific structures shown in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself describes the component functionally as a "slidable casing" that is "slidably repositioned" to "obstruct" apertures (’383 Patent, col. 32:7-9). The specification describes it as being repositioned by a "lift" which can include a "hydraulic ram or a winch" (’383 Patent, col. 9:1-4), suggesting a range of mechanisms.
  • Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific embodiment where a cylindrical casing (408) moves vertically within a stationary well screen (404) (’383 Patent, Figs. 4A-4B). A defendant may argue the term should be limited to this disclosed coaxial arrangement.

Term from the ’278 Patent: "fluid pathway" (Claim 1)

• Context and Importance: This term is fundamental to the structure of the claimed wellbore. Whether infringement is found may depend on how broadly this term is construed, particularly whether it is limited to the dual-casing embodiments described in the specification.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim defines the term functionally as "extending from an inlet at the first end to the second end and then from the second end to an outlet at the first end" (’278 Patent, col. 29:6-9), which does not explicitly require a specific structure.
  • Evidence for a Narrower Interpretation: The specification consistently describes the fluid pathway as being formed by a "set of boiler casings," such as a "first boiler casing" and a "second boiler casing" that create distinct conduits for inbound and outbound fluid (’278 Patent, col. 16:50-65). A court could be asked to limit the term to such a nested-casing structure.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement of all claims of both patents.
  • Inducement: The complaint alleges Defendants intend to actively induce contractors, equipment suppliers, and power purchasers to practice the patented methods, citing the press release announcing the projects and public solicitation for partners as evidence of inducement (Compl. ¶¶ 100-103).
  • Contributory Infringement: The complaint alleges Defendants will provide or cause to be provided specialized equipment designed for magma reservoir exploitation, such as "well screens, slidable casings, draw pipes, compressor systems, adjustable apertures," which are alleged to have no substantial non-infringing use (Compl. ¶¶ 105-106).

Willful Infringement

• Willfulness is alleged for all direct infringement counts. The complaint bases this allegation on Defendants' purported actual knowledge of the patents, evidenced by a statement from GeoAlaska's owner acknowledging the need for "patents from the McBays" to drill into magma (Compl. ¶5, ¶39). The complaint alleges Defendants announced their infringing plans despite this knowledge (Compl. ¶46, ¶75, ¶81, ¶87, ¶92, ¶98).

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

This case presents an unusual posture, as it concerns planned future conduct rather than an existing product. The resolution will likely depend on the following key questions:

• A core issue will be one of technological necessity: Can Plaintiff provide sufficient evidence to support its foundational argument that any commercially viable system for generating power from magma reservoirs must necessarily practice the specific apparatus and method steps recited in the asserted claims?
• A central dispute will be one of imminent infringement: Have Defendants' public announcements and partnership activities created a controversy of sufficient immediacy and reality to support a finding of infringement, and do the alleged public statements provide a sufficient basis for the claim of willfulness?
• A key question of definitional scope will be whether claim terms such as "slidable casing" (’383 Patent) and "fluid pathway" (’278 Patent) are construed broadly enough to cover any system Defendants might design for their announced projects, or if they will be limited to the specific embodiments disclosed in the patents, potentially allowing for a non-infringing design-around.