DCT

2:24-cv-00534

Valtrus Innovations Ltd v. Cyrusone LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Valtrus Innovations Ltd. et al v. CyrusOne, LLC, 2:24-cv-00534, E.D. Tex., 07/12/2024
  • Venue Allegations: Venue is alleged to be proper based on Defendant operating three data centers that constitute a regular and established place of business within the Eastern District of Texas.
  • Core Dispute: Plaintiffs allege that Defendant’s data centers infringe seven patents related to data center cooling, environmental sensing, power management, and physical layout.
  • Technical Context: The patents address technologies critical to the efficiency and reliability of large-scale data centers, focusing on optimizing energy consumption for cooling and power distribution while ensuring operational uptime.
  • Key Procedural History: The complaint is related to a prior pending action between Valtrus and CyrusOne (2:24-cv-00259). This action adds Key Patent Innovations Ltd. as a co-plaintiff. Plaintiffs allege that Defendant has been on notice of at least four of the asserted patents since receiving a notice letter on April 1, 2024.

Case Timeline

Date Event
2002-04-17 ’277 Patent Priority Date
2002-08-02 ’287 Patent Priority Date
2002-11-26 ’179 Patent Priority Date
2004-04-06 ’277 Patent Issue Date
2004-05-28 ’870 Patent Priority Date
2004-06-29 ’490 Patent Priority Date
2005-02-15 ’287 Patent Issue Date
2005-03-01 ’179 Patent Issue Date
2006-04-18 ’870 Patent Issue Date
2008-03-04 ’490 Patent Issue Date
2009-06-25 ’967 Patent Priority Date
2010-07-12 ’855 Patent Priority Date
2011-05-10 ’967 Patent Issue Date
2016-04-12 ’855 Patent Issue Date
2024-04-01 Notice Letter Delivered to Defendant
2024-04-11 Defendant Responds to Notice Letter
2024-07-12 Complaint Filing Date

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

U.S. Patent No. 6,718,277 - "Atmospheric control within a building," issued April 6, 2004

The Invention Explained

  • Problem Addressed: The patent describes conventional data center cooling as inefficient because it typically operates at full capacity and applies cooling uniformly across a room, regardless of the specific, localized heat loads generated by different electronic components, resulting in unnecessarily high operating expenses (’277 Patent, col. 2:21-41).
  • The Patented Solution: The invention proposes a "smart" cooling system that uses sensors to measure atmospheric parameters at multiple locations. This data is used to generate an "empirical atmospheric map," which is then compared to a "template atmospheric map" representing optimal conditions. The system identifies differences ("pattern differentials") and determines corrective actions to adjust the quantity, quality, and distribution of conditioned fluid to target areas with higher cooling needs (’277 Patent, Abstract; col. 4:39-55).
  • Technical Importance: This approach represents a shift from brute-force, room-level cooling to an intelligent, location-specific methodology designed to reduce energy consumption by matching cooling resources to actual, distributed thermal loads (’277 Patent, col. 7:37-44).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶32).
  • Essential Elements of Claim 1:
    • supplying a conditioned fluid inside a building;
    • sensing at least one atmospheric parameter in a plurality of locations;
    • generating an empirical atmospheric map from the sensing results;
    • comparing the empirical map to a template atmospheric map; and
    • identifying pattern differentials between the two maps.
  • The complaint alleges infringement of "one or more claims" but focuses on claim 1 (Compl. ¶32).

U.S. Patent No. 6,854,287 - "Cooling system," issued February 15, 2005

The Invention Explained

  • Problem Addressed: The patent addresses the high energy cost of conventional data center cooling systems, which often operate at or near maximum compressor power even when the actual heat load is reduced, leading to inefficient energy use (’287 Patent, col. 2:10-18).
  • The Patented Solution: The invention describes a cooling system with multiple heat exchanger units (HEUs) that cool air for computer racks. The system's innovation lies in controlling the cooling process in response to sensed temperatures within the room. Specifically, it allows for control of the temperature of the cooling fluid itself and/or the rate of cooled air delivery, with the ability to "individually manipulat[e] a mass flow rate of the cooling fluid supplied to each of the plurality of heat exchanger units" (’287 Patent, Abstract; col. 13:28-34). This enables a granular, demand-based response to thermal conditions.
  • Technical Importance: This technology allows for zonal cooling control, where different racks or areas can receive different amounts of cooling based on their specific, real-time needs, thereby optimizing power consumption across the data center (’287 Patent, col. 5:1-13).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶35).

  • Essential Elements of Claim 1:

    • providing a plurality of heat exchanger units;
    • supplying the units with cooling fluid from an air conditioning unit;
    • cooling air via heat exchange in the units;
    • sensing temperatures at one or more locations in the room;
    • controlling either the cooling fluid temperature or the air delivery in response to the sensed temperatures; and
    • wherein the controlling step includes individually manipulating a mass flow rate of cooling fluid supplied to each heat exchanger unit.

  • The complaint alleges infringement of "one or more claims" but focuses on claim 1 (Compl. ¶35).

  • Multi-Patent Capsule: U.S. Patent No. 6,862,179, "Partition for varying the supply of cooling fluid," issued March 1, 2005

    • Technology Synopsis: The patent describes a system for zoning a data center's under-floor plenum using a controllable partition. By manipulating the partition, the system can vary the volume and velocity of cooling fluid delivered to different zones, allowing for dynamic allocation of cooling resources in response to localized thermal loads (’179 Patent, Abstract; col. 5:3-17).
    • Asserted Claims: Independent claim 1 is asserted (Compl. ¶38).
    • Accused Features: The complaint accuses Defendant’s "cooling systems in its data centers, including a partition for varying the supply of cooling fluid" (Compl. ¶38).

  • Multi-Patent Capsule: U.S. Patent No. 7,031,870, "Data center evaluation using an air re-circulation index," issued April 18, 2006

    • Technology Synopsis: The patent discloses a method for evaluating data center cooling performance by calculating an "air re-circulation index" (specifically, a Supply Heat Index or SHI). The index is derived from the inlet and outlet temperatures of a heat-dissipating device (like a server rack) and the temperature of the supplied cooling air. This metric allows operators to quantify and diagnose cooling inefficiencies, such as the undesirable recirculation of hot exhaust air into equipment inlets (’870 Patent, Abstract).
    • Asserted Claims: Independent claim 1 is asserted (Compl. ¶42).
    • Accused Features: The complaint accuses Defendant's operation of "cooling systems in its data centers" in a manner that infringes the patented evaluation method (Compl. ¶42).

  • Multi-Patent Capsule: U.S. Patent No. 7,339,490, "Modular sensor assembly," issued March 4, 2008

    • Technology Synopsis: The invention is a physical sensor apparatus designed for easy deployment in a data center. It consists of an elongate, flexible body containing multiple addressable sensors interconnected on a common wire. This modular design simplifies the installation of comprehensive environmental monitoring on computer racks (’490 Patent, Abstract).
    • Asserted Claims: Independent claim 1 is asserted (Compl. ¶47).
    • Accused Features: The complaint accuses Defendant’s use of "modular sensor assemblies for sensing conditions such as temperature at a computer rack in its data centers" (Compl. ¶47).

  • Multi-Patent Capsule: U.S. Patent No. 9,310,855, "Flexible data center and methods for deployment," issued April 12, 2016

    • Technology Synopsis: This patent describes a method for deploying a scalable and flexible data center using a modular, block-based architecture. A "block" consists of one or more "perimeter structures" that house server racks, connected to a central "connecting structure" that houses monitoring and support equipment. This approach allows for rapid, industrialized, and scalable construction compared to traditional brick-and-mortar designs (’855 Patent, Abstract).
    • Asserted Claims: Independent claim 8 is asserted (Compl. ¶52).
    • Accused Features: The complaint accuses Defendant's "flexible data centers," specifically identifying the "DFW1 Data Center" as an infringing instrumentality (Compl. ¶52).

  • Multi-Patent Capsule: U.S. Patent No. 7,939,967, "Multiple Power Supply Control," issued May 10, 2011

    • Technology Synopsis: The patent addresses power redundancy in systems with multiple power supplies. When one power supply detects a failure in its independent energy source, it sends an alert to another power supply, which transitions from a standby mode to a normal output mode. Critically, the failing supply uses its own stored energy (e.g., in capacitors) to power the load during this transition, ensuring an uninterrupted power delivery (’967 Patent, Abstract).
    • Asserted Claims: Independent claim 1 is asserted (Compl. ¶57).
    • Accused Features: The complaint accuses Defendant’s "redundant power systems in its U.S. data centers" of infringement (Compl. ¶57).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are Defendant CyrusOne's data centers, including their associated infrastructure such as cooling systems, power supply systems, sensor assemblies, and physical layouts (Compl. ¶32, ¶35, ¶47, ¶52, ¶57). The complaint specifically identifies the "DFW Data Centers" located in Carrollton, Lewisville, and Allen, Texas, as infringing facilities (Compl. ¶3, ¶29).
  • Functionality and Market Context: The complaint alleges that CyrusOne operates data centers that provide colocation services, which rely on the accused cooling, monitoring, power, and deployment technologies to function (Compl. ¶26, ¶29). The infringement allegations cover the core operational systems that ensure the thermal stability, environmental monitoring, power redundancy, and physical organization of these large-scale computing facilities (Compl. ¶31-58). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts attached as Exhibits 8 and 9 but does not provide these exhibits (Compl. ¶32, ¶35). The infringement theory is therefore summarized from the complaint's narrative allegations.

'277 Patent Infringement Allegations
The complaint alleges that CyrusOne directly infringes at least claim 1 of the ’277 Patent by "making, using, selling, offering for sale, and/or importing systems in its data centers for cooling, or otherwise controlling atmospheric conditions" (Compl. ¶32). The core of the alleged infringement is the operation of cooling systems that control the data center environment in a manner that practices the claimed method of sensing, mapping, comparing, and identifying differentials to manage atmospheric conditions (Compl. ¶32).

  • Identified Points of Contention:
    • Scope Questions: The dispute may center on whether Defendant's system "generat[es] an empirical atmospheric map" and compares it to a "template atmospheric map" as those terms are understood in the patent. A question for the court will be whether a system that uses a set of discrete temperature thresholds or setpoints, rather than a graphical or contoured map, meets these limitations.
    • Technical Questions: What evidence does the complaint provide that the accused systems perform the specific five-step method of Claim 1 in sequence? The analysis will question whether the accused systems merely react to sensor data or if they explicitly generate and compare distinct "maps" to identify "pattern differentials" as the claim requires.

'287 Patent Infringement Allegations
The complaint alleges that CyrusOne infringes at least claim 1 of the ’287 Patent by operating cooling systems in its data centers (Compl. ¶35). The alleged infringement centers on the use of a system with multiple heat exchanger units where control is achieved in response to sensed room temperatures by "individually manipulating a mass flow rate of the cooling fluid supplied to each" unit (Compl. ¶35; ’287 Patent, col. 13:31-34).

  • Identified Points of Contention:
    • Scope Questions: A primary point of contention will likely be the claim element requiring "individually manipulating a mass flow rate of the cooling fluid." The infringement analysis raises the question of whether Defendant's system controls the flow of the refrigerant or chilled water to each cooling unit independently (e.g., via valves or variable speed pumps per unit), or if it primarily controls the air flow (e.g., via fan speed), which may not meet the claim limitation.
    • Technical Questions: Does the complaint provide evidence that the control over each heat exchanger is truly "individual"? A system that applies a global change affecting all units, even if in response to a local temperature reading, may not satisfy this element. The court will need to examine the specific control architecture of the accused cooling systems.

V. Key Claim Terms for Construction

For the ’277 Patent:

  • The Term: "empirical atmospheric map"
  • Context and Importance: This term is the foundational data structure of the claimed method. Its construction will determine whether a wide range of modern data center environmental control systems, which rely on sensor networks, fall within the claim's scope. Practitioners may focus on this term because if it is construed narrowly to require a specific graphical or topographical data representation, it may be easier for Defendant to design around or argue non-infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that thermal mapping software "is capable of processing thousands of input data points... and outputting map-like information," which could be argued to cover any data structure that correlates location with temperature, not just a visual graphic (’277 Patent, col. 4:41-43).
    • Evidence for a Narrower Interpretation: The patent repeatedly describes the map in visual terms, as being "composed of temperature contours that define various isothermal regions, or isotherms" and can be used to "triangulate the location of the actual hot spot" (’277 Patent, col. 4:44-52). This language may support a construction requiring a more complex data model than simple sensor-value pairs.

For the ’287 Patent:

  • The Term: "individually manipulating a mass flow rate of the cooling fluid"
  • Context and Importance: This limitation defines the specific mechanism of control and is central to distinguishing the invention from more generalized or cruder cooling control methods. The case may turn on whether Defendant's control systems meet this granular, fluid-based manipulation requirement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff might argue that any control scheme that results in different cooling fluid flow to different units, even if achieved through a centralized controller making sequential adjustments, meets the "individually manipulating" requirement. The term does not explicitly require separate, dedicated hardware for each unit.
    • Evidence for a Narrower Interpretation: The patent's detailed description and figures show distinct valves and pumps for different HEUs, suggesting a system designed for independent hardware-level control of fluid flow to each unit (’287 Patent, Fig. 3; col. 6:15-20). This supports an argument that simply controlling fan speed or a central chiller does not constitute "individually manipulating a mass flow rate of the cooling fluid" to each unit.

VI. Other Allegations

  • Indirect Infringement: The complaint does not allege specific facts to support claims of indirect infringement (inducement or contributory infringement). The claims focus on direct infringement by Defendant's "making, using, selling, [and] offering for sale" the accused systems (e.g., Compl. ¶32).
  • Willful Infringement: Willfulness is alleged for the ’870, ’490, ’855, and ’967 Patents (Compl. ¶43, ¶48, ¶53, ¶58). The allegations are based on pre-suit knowledge stemming from a "Notice Letter" delivered to CyrusOne on April 1, 2024, which allegedly provided "a specific factual basis for its infringement" (Compl. ¶41, ¶46, ¶51, ¶56). The complaint further alleges that Defendant "did not take any action to stop its infringement" after being notified (Id.).

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

  1. A core issue will be one of definitional scope: For the ’277 Patent, can the term "atmospheric map" be construed to cover a system that operates based on a distributed set of numerical sensor readings and corresponding temperature thresholds, or does it require a more complex, integrated data model representing thermal contours?
  2. A second key issue will be one of technical operation: For the ’287 Patent, does Defendant’s cooling architecture perform the claimed function of "individually manipulating a mass flow rate of the cooling fluid" to each cooling unit, or does it primarily control air delivery via fan speed or make global adjustments to a central chiller, potentially placing it outside the claim's scope?
  3. An evidentiary question for willfulness will be the adequacy of notice: Did the pre-suit notice letter provide a sufficiently detailed "specific factual basis" for infringement to support a finding that any post-notice infringement was willful, or was it a more general notice that did not establish an objective risk of infringement?