DCT

2:24-cv-00361

Valtrus Innovations Ltd v. NTT Data Services LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00361, E.D. Tex., 11/15/2024
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a "regular and established place of business" at its DFW11 and DFW26 Data Centers located within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s data center operations, including their cooling, structural organization, and power management systems, infringe six patents originally developed by Hewlett Packard Enterprise.
  • Technical Context: The patents relate to technologies for improving the energy efficiency and operational management of large-scale data centers, a critical concern given the high energy consumption and heat generation of modern computing infrastructure.
  • Key Procedural History: The complaint states that the Asserted Patents were developed by inventors working for Hewlett Packard Enterprise (HPE) and that Plaintiff Valtrus is the successor-in-interest. No prior litigation or post-grant proceedings are mentioned in the complaint.

Case Timeline

Date Event
2002-04-17 U.S. Patent No. 6,718,277 Priority Date
2002-08-02 U.S. Patent No. 6,854,287 Priority Date
2002-11-26 U.S. Patent No. 6,862,179 Priority Date
2004-04-06 U.S. Patent No. 6,718,277 Issued
2004-05-28 U.S. Patent No. 7,031,870 Priority Date
2005-02-15 U.S. Patent No. 6,854,287 Issued
2005-03-01 U.S. Patent No. 6,862,179 Issued
2006-04-18 U.S. Patent No. 7,031,870 Issued
2009-06-25 U.S. Patent No. 7,939,967 Priority Date
2010-07-12 U.S. Patent No. 9,310,855 Priority Date
2011-05-10 U.S. Patent No. 7,939,967 Issued
2016-04-12 U.S. Patent No. 9,310,855 Issued
2024-11-15 Complaint Filed

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

U.S. Patent No. 6,718,277 - “Atmospheric control within a building”

The Invention Explained

  • Problem Addressed: The patent describes conventional data center cooling systems as inefficient because they typically operate at 100 percent capacity on a continuous basis, regardless of the actual, distributed cooling needs within the facility, leading to unnecessarily high operating expenses (’277 Patent, col. 2:28-42).
  • The Patented Solution: The invention proposes a method for dynamically controlling atmospheric conditions. The system uses sensors to gather atmospheric data, generates an "empirical atmospheric map" of the environment, and compares this map to a "template atmospheric map" (a model of optimal conditions). By identifying "pattern differentials" (e.g., hot spots) between the two maps, the system determines and executes corrective actions, such as varying the quantity, quality, or distribution of conditioned fluid to targeted areas (’277 Patent, Abstract; col. 4:44-59).
  • Technical Importance: This approach represented a shift from static, room-level cooling to a more dynamic, data-driven, and location-specific control strategy, intended to reduce energy consumption. (Compl. ¶6).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶29).
  • Claim 1 Elements:
    • supplying a conditioned fluid inside said building;
    • sensing at least one atmospheric parameter in a plurality of locations inside said building;
    • generating an empirical atmospheric map from the results of said sensing step;
    • comparing said empirical atmospheric map to a template atmospheric map; and
    • identifying pattern differentials between said empirical and template atmospheric maps.
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (Compl. ¶29).

U.S. Patent No. 6,854,287 - “Cooling system”

The Invention Explained

  • Problem Addressed: The patent addresses the inefficiency of conventional cooling systems that are designed for "worst-case scenario" heat loads and do not vary their output based on distributed needs, leading to wasted energy when computer systems are not at maximum utilization (’287 Patent, col. 2:10-30).
  • The Patented Solution: The invention describes a cooling system comprising multiple heat exchanger units (HEUs), for example, positioned above computer racks. The system controls cooling by sensing temperatures at various locations in the room and, in response, "individually manipulating a mass flow rate of the cooling fluid supplied to each of the plurality of heat exchanger units." This allows for granular, localized cooling that can be adjusted based on the specific heat loads of different racks (’287 Patent, Abstract; col. 13:48-54).
  • Technical Importance: This technology facilitates a zonal or even rack-specific cooling strategy, moving beyond monolithic room-level control to a more distributed and responsive system. (Compl. ¶6).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶32).
  • Claim 1 Elements:
    • A method for cooling a room configured to house a plurality of computer systems, comprising:
    • providing a plurality of heat exchanger units configured to receive air from said room and to deliver air to said room;
    • supplying said plurality of heat exchanger units with cooling fluid from an air conditioning unit;
    • cooling said received air through heat exchange with the cooling fluid...;
    • sensing temperatures at one or more locations in said room;
    • controlling at least one of the temperature of said cooling fluid and said air delivery... in response to said sensed temperatures...; and
    • wherein the step of controlling said air delivery... comprises individually manipulating a mass flow rate of the cooling fluid supplied to each of the plurality of heat exchanger units.
  • The complaint alleges infringement of "one or more claims" but does not explicitly reserve the right to assert dependent claims (Compl. ¶32).
    No probative visual evidence provided in complaint.

U.S. Patent No. 6,862,179 - “Partition for varying the supply of cooling fluid”

  • Technology Synopsis: The patent is directed to using a controllable partition to vary the supply of cooling fluid within a zone of a data center, allowing for more targeted and efficient cooling based on localized thermal conditions (’179 Patent, Abstract).
  • Asserted Claims: At least independent Claim 1 is asserted (Compl. ¶35).
  • Accused Features: The complaint accuses Digital Realty’s cooling systems that include "a partition for varying the supply of cooling fluid" as practiced in its DFW11 and DFW26 Data Centers (Compl. ¶35).

U.S. Patent No. 7,031,870 - “Data center evaluation using an air re-circulation index”

  • Technology Synopsis: The patent describes a method for evaluating data center components by calculating an "index of air re-circulation" based on detected inlet, outlet, and supplied air temperatures. This index helps assess cooling efficiency and identify suboptimal airflow patterns (’870 Patent, Abstract).
  • Asserted Claims: At least independent Claim 1 is asserted (Compl. ¶39).
  • Accused Features: The complaint accuses Digital Realty of operating its DFW11 and DFW26 Data Centers in a manner that infringes by using systems that evaluate data center components (Compl. ¶¶37, 39).

U.S. Patent No. 9,310,855 - “Flexible data center and methods for deployment”

  • Technology Synopsis: The patent describes methods for deploying flexible and modular data centers by constructing them from blocks of perimeter structures and connecting structures. This approach is intended to provide greater scalability and adaptability compared to traditional "brick and mortar" designs (’855 Patent, Abstract).
  • Asserted Claims: The complaint asserts at least Claim 1, but references a claim chart for Claim 8 (Compl. ¶44, p. 10).
  • Accused Features: The complaint accuses Digital Realty’s "flexible data centers," specifically its DFW10 Data Center, of infringement (Compl. ¶44).

U.S. Patent No. 7,939,967 - “Multiple Power Supply Control”

  • Technology Synopsis: The patent is directed to a redundant power supply system where a primary power supply, upon detecting a failure in its energy source, sends an alert signal to a secondary, standby power supply. The failing supply uses stored energy to maintain power to the load while the standby supply transitions to normal output, ensuring an uninterrupted power transfer (’967 Patent, Abstract).
  • Asserted Claims: At least independent Claim 1 is asserted (Compl. ¶49).
  • Accused Features: The complaint accuses Digital Realty’s data centers that use "multiple power supply control" of infringement (Compl. ¶49).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant Digital Realty's data centers, including their cooling systems, structural organization, and power control systems (Compl. ¶¶23, 29, 32, 35, 39, 44, 49). Specific facilities mentioned are the DFW11, DFW26, and DFW10 Data Centers located in Texas (Compl. ¶¶26, 29, 32, 35, 39, 44).

Functionality and Market Context

The complaint alleges that these data centers provide services covered by the Asserted Patents, such as atmospheric control, cooling, flexible deployment methods, and power supply control (Compl. ¶23). The complaint does not provide specific technical details about the operation of these data centers but broadly alleges they make, use, sell, or offer for sale products and services that infringe the patents (Compl. ¶23).

IV. Analysis of Infringement Allegations

The complaint references "exemplary claim chart[s]" attached as exhibits for each asserted patent but does not provide the exhibits themselves (Compl. ¶¶29, 32, 35, 39, 44, 49). The infringement theory is therefore summarized in prose based on the complaint's narrative allegations.

’277 Patent Infringement Allegations

The complaint alleges that Digital Realty’s operation of cooling systems in its data centers infringes at least Claim 1 of the ’277 Patent (Compl. ¶29). The narrative theory suggests that these systems control atmospheric conditions in a way that practices the claimed method of sensing parameters, generating and comparing atmospheric maps, and identifying differentials to guide cooling adjustments (Compl. ¶¶28-29).

’287 Patent Infringement Allegations

The complaint alleges that Digital Realty’s systems for cooling its datacenters infringe at least Claim 1 of the ’287 Patent (Compl. ¶32). The infringement theory posits that these systems utilize multiple heat exchanger units and control air delivery by "individually manipulating a mass flow rate of the cooling fluid" to each unit in response to sensed temperatures, as claimed (Compl. ¶¶31-32; ’287 Patent, claim 1).

Identified Points of Contention

Scope Questions

For the ’277 Patent, a central question will be whether Defendant’s systems generate an "empirical atmospheric map" and compare it to a "template atmospheric map." The court will need to determine if a standard sensor-based feedback loop meets these specific, structured limitations or if the patent requires a more complex mapping and modeling process. For the ’287 Patent, the dispute may focus on whether Defendant's systems perform "individually manipulating a mass flow rate of the cooling fluid supplied to each" heat exchanger unit. This raises the question of whether the claim requires fully independent control over each unit or is met by any form of zonal or non-uniform control.

Technical Questions

The complaint does not provide evidence detailing how Defendant’s cooling systems operate. A key technical question will be what facts demonstrate that the accused systems actually perform the specific steps recited in the claims, such as generating map-like data structures (’277 Patent) or employing per-unit mass flow rate manipulation (’287 Patent).

V. Key Claim Terms for Construction

For the ’277 Patent

  • The Term: "empirical atmospheric map" / "template atmospheric map"
  • Context and Importance: These terms define the core data-driven comparison at the heart of Claim 1. The outcome of the case may depend on whether Defendant's system, which likely uses sensor data, can be said to create and compare "maps" in the manner claimed. Practitioners may focus on these terms because they appear to be more than simple data points and imply a specific data structure and analytical process.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the system as using "input, one or more atmospheric parameters measured at various, discrete sensor locations" to accomplish control, which could support an argument that any system using sensor data arrays fits the definition (’277 Patent, col. 3:36-41).
    • Evidence for a Narrower Interpretation: The specification explicitly describes a "thermal map" as being "composed of temperature contours that define various isothermal regions," and notes that the template map can be generated by "Computational fluid dynamics (CFD) software tools." This language may support a narrower construction requiring a graphical or model-based representation, not just a set of sensor readings (’277 Patent, col. 5:44-46; col. 6:44-46).

For the ’287 Patent

  • The Term: "individually manipulating a mass flow rate"
  • Context and Importance: This phrase in Claim 1 defines the required level of control granularity. The infringement analysis will hinge on whether Defendant's system provides this "individual" control for each heat exchanger unit or uses a more centralized or zonal control scheme that falls outside the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism for manipulation. An argument could be made that any system capable of creating differential flow rates among the various heat exchanger units, even if through a coordinated system, meets the "individually manipulating" limitation.
    • Evidence for a Narrower Interpretation: Claim 7, which depends from Claim 1, recites "a plurality of valves positioned along respective cooling fluid lines" to "meter[] the flow of cooling fluid through each" unit. This suggests that "individually manipulating" may be construed to require a distinct, per-unit control element like a valve or variable-speed pump, as opposed to system-wide adjustments that result in different flow rates (’287 Patent, col. 13:60-66).

VI. Other Allegations

Indirect Infringement

The complaint does not plead separate counts for indirect infringement and lacks specific factual allegations, such as references to user manuals or component sales, that would typically support claims for inducement or contributory infringement.

Willful Infringement

Willfulness is alleged for the ’870, ’855, and ’967 patents (Compl. ¶¶40, 45, 50). The allegations are based on post-suit knowledge, asserting that Defendant was put on notice of its infringement by, at the latest, the filing of the complaint and "did not take any action to stop its infringement" (Compl. ¶¶38, 43, 48).

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

  • A core issue will be one of definitional scope: can patent terms rooted in specific data structures and control methods, such as "empirical atmospheric map" and "individually manipulating," be construed broadly enough to read on the potentially more generic feedback and control systems used in modern data center management?
  • A key evidentiary question will be one of technical proof: since the complaint's technical infringement details are deferred to un-provided exhibits, the case will turn on what discovery reveals about the actual, granular operation of Digital Realty's cooling, power, and data center deployment methods and whether that operation maps to the specific limitations of the asserted claims.