Valtrus Innovations Ltd v. Equinix Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Valtrus Innovations Ltd. and Key Patent Innovations Ltd. (Ireland)
  • Defendant: Equinix Inc. (Delaware)
  • Plaintiff’s Counsel: Reichman Jorgensen Lehman & Feldberg LLP; Findlay Craft
• Case Identification: 2:25-cv-00016, E.D. Tex., 04/10/2025
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant Equinix conducts business in the district and maintains a regular and established place of business, specifically its DA7 Data Center in Plano, Texas.
• Core Dispute: Plaintiffs allege that Defendant’s data center cooling systems and multiple power supply control systems infringe four patents originally developed by Hewlett Packard Enterprise.
• Technical Context: The case concerns foundational technologies for operating large-scale data centers, focusing on energy efficiency in cooling and high-reliability power redundancy, which are critical for the commercial viability and performance of cloud computing and co-location services.
• Key Procedural History: The patents-in-suit originated from development at Hewlett Packard Enterprise. The current filing is an Amended Complaint. Plaintiffs allege that the filing of an earlier Original Complaint placed Defendant on notice of U.S. Patent 7,939,967, which may be relevant to the allegation of willful infringement for that patent.

Case Timeline

Date	Event
2002-10-03	Priority Date for ’284 Patent and ’683 Patent
2003-01-16	Priority Date for ’682 Patent
2005-02-15	Issue Date for U.S. Patent 6,854,284
2005-03-22	Issue Date for U.S. Patent 6,868,682
2005-03-22	Issue Date for U.S. Patent 6,868,683
2009-06-25	Priority Date for ’967 Patent
2011-05-10	Issue Date for U.S. Patent 7,939,967
2025-04-10	Amended Complaint Filing Date

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

U.S. Patent 6,854,284, "Cooling of data centers", Issued February 15, 2005

The Invention Explained

• Problem Addressed: The patent describes conventional data center cooling systems as inefficient because they often operate at maximum capacity regardless of the actual, distributed heat load within the facility and remove air indiscriminately, wasting energy (col. 1:45-54; col. 2:1-14).
• The Patented Solution: The invention proposes a more intelligent cooling system that uses a plenum with multiple, dynamically controllable "returns" to remove heated air from the data center. These returns can vary the characteristics of air removal (e.g., volume, velocity) based on localized conditions, allowing the system to target hot spots and reduce energy consumption by matching cooling effort to the actual heat load (Abstract; col. 2:16-25). The system is designed to vary its overall intake of cooling fluid in response to pressure changes within the plenum, which correspond to the collective operation of the returns (col. 12:45-50).
• Technical Importance: This approach represented a shift from brute-force, homogenous cooling toward granular, demand-based environmental control, a key step in managing the rapidly escalating power consumption and heat density of modern data centers (col. 1:26-44).

Key Claims at a Glance

• The complaint asserts at least independent claim 10 (Compl. ¶24).
• Claim 10 (Method):
  • Activating a cooling system and opening a plurality of returns configured to remove cooling fluid from various locations in a data center, with the returns in fluid communication with a plenum.
  • Sensing a pressure of the cooling fluid in the plenum.
  • Determining whether the sensed pressure is within a predetermined pressure range.
  • Varying an intake of the cooling system through the returns in response to the sensed pressure falling outside the predetermined range.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent 6,868,682, "Agent based control method and system for energy management", Issued March 22, 2005

The Invention Explained

• Problem Addressed: Traditional data center cooling systems are described as inefficient because they do not vary their output based on the distributed needs of the equipment and typically measure temperature only at the main air conditioning unit, not at the racks where heat is generated (col. 2:11-29).
• The Patented Solution: The patent discloses a distributed control system using a "hierarchy of agents" — software entities operating at different levels (e.g., rack, row, and main cooling unit) ('682 Patent, Fig. 4). A lower-level agent (e.g., a "rack agent") monitors local temperatures and attempts to resolve thermal issues autonomously (e.g., by adjusting a local vent). If it cannot, it requests assistance from a higher-level agent (e.g., a "row agent" or "CRAC agent"), which can coordinate resources on a broader scale (Abstract; col. 3:1-14).
• Technical Importance: This hierarchical, agent-based architecture enables a scalable and more sophisticated level of automated control, allowing the cooling system to react to localized "hot spots" and optimize energy use across an entire facility in a way that centralized, monolithic control systems could not (col. 4:10-24).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶27).
• Claim 1 (Method):
  • Receiving sensory data corresponding to a temperature from a subsystem in a data center.
  • Processing the sensory data by a first agent in a hierarchy of agents to determine if the subsystem is operating within a predetermined temperature range.
  • Adjusting a delivery rate for a cooling fluid using the first agent to keep the subsystem within the range.
  • Requesting a second agent from the hierarchy to process the sensory data when the first agent cannot maintain the temperature unless the second agent redistributes the cooling fluid.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent 6,868,683, "Cooling of data centers", Issued March 22, 2005

• Technology Synopsis: This patent, like the '284 patent, addresses inefficient data center cooling by moving away from a "worst-case scenario" design ('683 Patent, col. 2:1-2). It describes a system that uses dynamically controllable vents and returns, governed by local temperature sensors, to provide individualized and localized amounts of cooling fluid according to the specific heat loads of different racks, thereby reducing overall energy consumption ('683 Patent, col. 5:15-22).
• Asserted Claims: At least independent claim 10 (Compl. ¶30).
• Accused Features: The complaint alleges that Equinix's cooling systems in its data centers infringe ('683 Patent, Compl. ¶30).

U.S. Patent 7,939,967, "Multiple power supply control", Issued May 10, 2011

• Technology Synopsis: This patent addresses the need for high-reliability redundant power systems that are also energy efficient. Instead of a balanced load-sharing approach where multiple power supplies run at suboptimal efficiency, this invention describes a system where one power supply handles the load while another remains in a low-power standby mode ('967 Patent, col. 1:6-12). If the active supply detects a failure of its input source, it issues an "alert signal" to the standby supply, which then transitions to full output. The failing supply uses its internal energy storage (e.g., capacitors) to power the load during this brief transition, ensuring uninterrupted operation ('967 Patent, Abstract; col. 3:36-46).
• Asserted Claims: At least independent claim 1 (Compl. ¶34).
• Accused Features: The complaint alleges that Equinix's redundant power systems used in its U.S. data centers infringe ('967 Patent, Compl. ¶34).

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are Defendant Equinix's data centers, including their associated cooling systems and multiple power supply control systems (Compl. ¶¶ 18, 24, 27, 30, 34). The DA7 Data Center in Plano, Texas, is specifically identified as an established place of business where infringing acts have allegedly occurred (Compl. ¶21).
• Functionality and Market Context: The complaint alleges that Equinix operates cooling systems in its data centers to cool the facilities (Compl. ¶24, 27, 30). It further alleges that Equinix's U.S. data centers use redundant power systems for multiple power supply control (Compl. ¶34). Equinix is a major global provider of data center and co-location services, and the efficient and reliable operation of its cooling and power infrastructure is fundamental to its business.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits 5, 6, 7, and 8, which were not provided with the complaint document. The following analysis is based on the narrative infringement allegations in the complaint body. No probative visual evidence provided in complaint.

'284 Patent Infringement Allegations

• The complaint alleges that Equinix's operation of cooling systems in its data centers infringes at least claim 10 of the ’284 Patent (Compl. ¶24). The infringement theory suggests that these systems cool data centers in a manner that practices the claimed method, which involves sensing pressure in a plenum and varying cooling fluid intake in response (Compl. ¶24; ’284 Patent, cl. 10).
• Identified Points of Contention:
  • Technical Question: A central question will be whether Equinix's cooling systems perform the specific step of "sensing a pressure of said cooling fluid in the plenum" as required by claim 10. The complaint does not provide detail on how the accused systems perform this step, raising the question of whether they use direct pressure sensors or infer pressure from other data, and whether either method falls within the claim's scope.
  • Functional Question: The analysis will also turn on whether any variation in the accused systems' cooling intake is performed "in response to said sensed pressure falling outside of said predetermined pressure range." Evidence will be required to link a specific pressure measurement to a specific control action for the cooling intake.

'682 Patent Infringement Allegations

• The complaint alleges that Equinix infringes at least claim 1 of the ’682 Patent by operating systems for controlling temperature in its data centers based on sensory data (Compl. ¶26-27). The core of this allegation is that the accused systems function according to the claimed method, which requires a specific "hierarchy of agents" to process sensor data and control cooling (Compl. ¶27; ’682 Patent, cl. 1).
• Identified Points of Contention:
  • Scope Question: A primary point of contention will be the interpretation of the term "hierarchy of agents." The infringement analysis will depend on whether Equinix's control architecture can be characterized as having distinct first and second agents in a hierarchy that interact as the claim requires—specifically, with the first agent escalating to the second when it cannot resolve a thermal issue autonomously.
  • Evidentiary Question: The complaint does not specify the architecture of Equinix's control systems. Plaintiffs will need to produce evidence demonstrating that the accused systems embody not just distributed control, but the particular hierarchical request-and-response structure recited in claim 1.

V. Key Claim Terms for Construction

For the ’284 Patent

• The Term: "sensing a pressure of said cooling fluid in the plenum" (from claim 10).
• Context and Importance: This term is critical because it defines the specific trigger for the claimed control method. The case may turn on whether Equinix's systems perform this exact sensing step, or a different, non-infringing control logic. Practitioners may focus on this term to determine if infringement requires a direct measurement from a dedicated pressure sensor or if it can be satisfied by an indirect calculation or correlation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests that flow rates can be "measured (e.g., either directly or by measuring pressure drop and using a suitable correlation)" ('284 Patent, col. 6:50-53), which may support an argument that "sensing a pressure" is not limited to direct measurement by a pressure transducer.
  • Evidence for a Narrower Interpretation: Claim 1 of the patent explicitly recites "a pressure sensor situated within said plenum to measure the pressure," which is absent from method claim 10. A defendant may argue this distinction implies that "sensing a pressure" in claim 10 requires an actual act of pressure measurement, even if not by a specific component, rather than mere calculation or inference.

For the ’682 Patent

• The Term: "hierarchy of agents" (from claim 1).
• Context and Importance: This term is the central inventive concept. Infringement of claim 1 hinges on whether Equinix’s control system possesses such a structure. Practitioners will recognize that the patentability of the claim likely rested on this specific limitation, making its construction pivotal.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the agents as "software 'agent[s]' configured to interact and negotiate with the other agents to accomplish a collective goal" ('682 Patent, col. 17:2-4), which could be argued to encompass any distributed, cooperative control system.
  • Evidence for a Narrower Interpretation: The specification and figures provide a specific, three-tiered example of "rack agents," "row agents," and "CRAC agents," where lower-level agents report to and request assistance from higher-level agents ('682 Patent, Fig. 4; col. 13:42-53). This detailed embodiment may be used to argue that "hierarchy" requires this specific tiered structure of escalating authority, not just peer-to-peer communication.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Equinix's infringement has been willful (Compl. ¶35; Prayer for Relief ¶B). The specific basis for willfulness regarding the ’967 Patent is alleged pre-suit notice based on the filing of Plaintiffs' Original Complaint (Compl. ¶33). For all asserted patents, the filing of the current Amended Complaint provides post-suit notice of the infringement allegations.

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

1. Definitional Scope: A core issue for the '682 patent will be one of definitional scope: can the term "hierarchy of agents," which the patent illustrates as a specific, multi-tiered command structure of rack, row, and cooling unit agents, be construed to read on the architecture of Equinix's actual data center management software?
2. Evidentiary Proof of Function: A key evidentiary question for the '284 and '683 patents will be one of functional proof: what evidence can be produced to show that Equinix's cooling systems perform the specific method steps required by the claims—particularly "sensing a pressure" ('284) or varying airflow based on discrete, localized temperature data ('683)—as opposed to employing a more generalized, non-infringing environmental control logic?
3. Operational Equivalence: For the '967 patent, the case may turn on a question of operational equivalence: does Equinix's redundant power system operate in the specific manner claimed, where a failing supply uses its own stored energy to power the load while a standby supply transitions to full output, or does it use a different, non-infringing failover mechanism?