DCT
6:24-cv-00152
Green Revolution Cooling Inc v. Riot Platforms Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Green Revolution Cooling, Inc. (Delaware)
- Defendant: Riot Platforms, Inc. (Nevada), Riot Corsicana, LLC (Texas), and Whinstone US, Inc. (Delaware)
- Plaintiff’s Counsel: Greenberg Traurig, LLP
- Case Identification: 6:24-cv-00152, W.D. Tex., 04/16/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Riot operates a regular and established place of business, its Rockdale Facility, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s large-scale bitcoin mining facilities utilize immersion cooling systems that infringe patents related to the architecture and thermal management of servers submerged in a dielectric coolant.
- Technical Context: The technology concerns single-phase liquid immersion cooling for data centers, an alternative to traditional air cooling that offers significantly higher thermal efficiency and density, which is critical for high-heat applications like cryptocurrency mining.
- Key Procedural History: The complaint alleges that Defendant’s supplier, Midas, was aware of Plaintiff's patent portfolio due to prior patent prosecution history and separate litigation, and that Defendant had discussions with one of Plaintiff's partners prior to selecting its supplier, which may be relevant to allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2008-08-11 | Earliest Priority Date for ’914 and ’463 Patents |
| 2009-01-01 | Plaintiff GRC was founded |
| 2018-06-05 | U.S. Patent No. 9,992,914 Issues |
| 2018-11-06 | U.S. Patent No. 10,123,463 Issues |
| 2021-10-19 | Defendant Riot announces its first industrial-scale immersion-cooled operation |
| 2022-05-01 | Defendant Riot's first immersion-cooled building comes online |
| 2025-04-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,992,914 - "Commonly Submersed Servers with Velocity Augmentation and Partial Recirculation in Tank"
- Issued: June 5, 2018
The Invention Explained
- Problem Addressed: The patent describes the inefficiency and high cost of traditional air cooling in data centers, which limits the density of heat-producing servers and consumes substantial electricity (’914 Patent, col. 1:29-38, 2:46-55). Air cooling systems struggle to manage the heat from densely packed servers, which can exceed 1,200 Watts-per-square-foot, whereas conventional systems handle only about 150 Watts-per-square-foot (Compl. ¶36).
- The Patented Solution: The invention is an apparatus for cooling servers by fully immersing them in a tank of non-conductive, dielectric liquid coolant (’914 Patent, col. 9:58-62). Servers are arranged vertically in racks to minimize their footprint (Compl. ¶38). A pump and piping system circulates the liquid; coolant is pumped into the tank, flows vertically across the servers absorbing heat, and the now-heated liquid is pumped to an external heat exchanger before the cooled liquid is returned to the tank (’914 Patent, col. 10:9-31). An exemplary embodiment of this tank-and-rack system is depicted in Figure 11 of the patent (Compl. ¶38).
- Technical Importance: This liquid immersion approach allows for significantly more efficient heat transfer than air, enabling greater server density and reducing the overall power consumption and physical footprint required for data center cooling (Compl. ¶3, ¶36).
Key Claims at a Glance
- The complaint asserts infringement of claims 15-21, with claim 15 being the lead independent claim (Compl. ¶57).
- Independent Claim 15 of the ’914 Patent includes these essential elements:
- An apparatus with a tank defining an open interior volume with a coolant inlet and outlet.
- A volume of dielectric liquid coolant within the tank.
- Mounting members configured to hold multiple rack-mountable servers in a vertical orientation and a horizontally stacked relationship.
- One or more pumps to move the coolant.
- A controller configured to maintain the coolant temperature in a range of approximately 90°F to 130°F.
- A liquid-to-liquid or liquid-to-refrigerant heat exchanger located outside of the tank.
- The volume of coolant is thermally coupled to a distal location via this external heat exchanger.
- The complaint reserves the right to assert dependent claims (Compl. ¶57).
U.S. Patent No. 10,123,463 - "Liquid Submerged, Horizontal Computer Server Rack and Systems and Method of Cooling such a Server Rack"
- Issued: November 6, 2018
The Invention Explained
- Problem Addressed: As the parent patent to the ’914 Patent, the ’463 Patent addresses the same technical problem of inefficient and costly air cooling in data centers, which constrains server performance and density (’463 Patent, col. 1:29-38, 2:46-55).
- The Patented Solution: The patent describes a multi-circuit cooling apparatus where servers are mounted vertically in a tank of dielectric fluid (’463 Patent, col. 26:10-16). The solution specifies the orientation of the servers, with one of the two smallest sides facing upward and the motherboard oriented vertically, to facilitate cooling and access (’463 Patent, col. 25:65-26:3). The system is thermally coupled to a remote heat exchanger via an external fluid circuit to dissipate heat absorbed by the coolant (’463 Patent, col. 26:22-26). The complaint states this patent shares the same specification and figures as the ’914 Patent (Compl. ¶72).
- Technical Importance: By defining specific server orientations and a multi-circuit cooling architecture, the invention aims to create an efficient, scalable, and serviceable immersion cooling system for high-density computing environments (Compl. ¶3).
Key Claims at a Glance
- The complaint asserts infringement of claims 1, 2, 4-8, 10, 12-14, 18-27, and 29, with claim 1 being the lead independent claim (Compl. ¶95).
- Independent Claim 1 of the ’463 Patent includes these essential elements:
- An apparatus with at least one tank having an open or openable top sized to receive at least one row of servers.
- Each server in the row comprises a motherboard with heat-producing components.
- Mounting members that hold at least two servers in a horizontally stacked, vertical orientation, where one of the two smallest sides of the server faces upward and the motherboard is vertically oriented.
- Each of at least two servers is configured to connect to a computer network.
- A volume of dielectric coolant at least partially held in the tank.
- A multi-circuit fluid cooling apparatus.
- The complaint reserves the right to assert dependent claims (Compl. ¶95).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the immersion-cooled portions of Defendant Riot's large-scale Bitcoin mining facilities in Rockdale and Corsicana, Texas (the "Accused Products") (Compl. ¶41).
Functionality and Market Context
- The Accused Products are industrial-scale cryptocurrency mining operations that submerge specialized computer hardware (ASICs) in a "specialized non-conductive fluid" to manage the intense heat generated during mining (Compl. ¶41, ¶44). The heated fluid is "pumped and circulated to assist in dissipating the heat via a secondary heat exchanger" before being "pumped back through the immersion tank" (Compl. ¶43, ¶46). The complaint includes a photograph showing tanks with vertically mounted servers submerged in coolant, with external piping and pumps visible below the tanks (Compl. p. 16).
- Riot’s Rockdale facility is alleged to be the "largest single Bitcoin mining facility in North America," and the complaint cites hundreds of millions of dollars in revenue from Riot's Bitcoin Mining and Data Center Hosting services, suggesting significant commercial scale and market presence (Compl. ¶12, ¶26-27).
IV. Analysis of Infringement Allegations
’914 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an apparatus for holding and cooling rack-mountable servers...comprising: a tank defining an open interior volume and having a coolant inlet for receiving a dielectric liquid coolant...and a coolant outlet for allowing the coolant to flow from the open interior volume... | The Accused Products use tanks with an open interior volume, a coolant inlet for receiving coolant, and a coolant outlet for coolant to exit. A photograph shows open-topped tanks used for immersion cooling. | ¶42, ¶43 | col. 13:20-29 |
| a volume of dielectric liquid coolant in the tank | The Accused Products use a "specialized non-conductive fluid" that is circulated to cool the ASICs. A video screenshot shows fluid bubbling at the surface of a tank. | ¶44 | col. 13:14-16 |
| one or more mounting members...configured to hold a plurality of rack-mountable servers in a horizontally stacked relationship with one another, with the rack-mountable servers in a vertical orientation within the interior volume... | The Accused Products use mounting brackets that hold servers vertically in a horizontally stacked relationship within the tanks. A photograph shows a worker installing a server vertically into a tank. | ¶45 | col. 13:49-54 |
| a controller configured to maintain a temperature of the dielectric liquid coolant in the range of about 90° F. to 130° F. | A Master Purchase & Sale Agreement for servers allegedly requires Riot's data centers to include infrastructure designed to operate miners at a liquid working temperature within this specified range. | ¶47 | col. 10:55-66 |
| a liquid-to-liquid or liquid-to-refrigerant heat exchanger outside of the tank...wherein the volume of dielectric liquid coolant is thermally coupled to a distal location via the...heat exchanger | The Accused Products use a "secondary heat exchanger" outside the tank to dissipate heat from the circulated fluid, thermally coupling the in-tank coolant to a distal location. A video screenshot shows piping connecting the tanks to external equipment. | ¶48, ¶49 | col. 13:30-34 |
Identified Points of Contention:
- Scope Questions: A central question may be whether the term "rack-mountable server," as understood in the context of the patent's 2008 priority date, can be construed to read on the specialized ASIC-based hardware used in the Accused Products for cryptocurrency mining.
- Technical Questions: The complaint alleges the "controller" limitation is met by citing a purchase agreement that specifies an operating temperature range. A potential point of contention is whether this contractual requirement is sufficient to prove the existence and function of a "controller configured to maintain" that temperature, which may imply an active feedback and control system as described in the patent.
’463 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least one tank defining an open interior volume...sized to receive at least one row comprising a plurality of rack mountable servers, each of at least two...comprising a motherboard and heat producing components... | The Accused Products use open-topped tanks sized to hold rows of servers (ASICs) that contain motherboards and heat-producing components. A photograph shows several large, open-topped tanks installed in rows. | ¶74 | col. 25:46-56 |
| one or more mounting members...configured to hold each of at least two of the rack-mountable servers...in a horizontally stacked relationship...with the rack-mountable servers in a vertical orientation such that one of the two smallest sides of the rack-mountable server faces upward and the motherboard...is vertically oriented... | The Accused Products allegedly use mounting members that hold servers vertically, stacked horizontally, with one of the smallest sides facing upward. A photograph shows servers arranged vertically in a tank. | ¶76 | col. 25:60-26:3 |
| a volume of dielectric coolant at least partially held in the at least one tank | The Accused Products use a "specialized non-conductive fluid" in the tanks. A video screenshot shows the fluid surface inside an operational tank. | ¶78 | col. 26:6-7 |
| a multi-circuit fluid cooling apparatus | The Accused Products allegedly use a system where coolant is circulated from the tank to a "secondary heat exchanger," constituting a multi-circuit apparatus. | ¶79, ¶80 | col. 26:8-9 |
Identified Points of Contention:
- Scope Questions: As with the ’914 patent, the interpretation of "rack-mountable servers" to include modern ASICs will likely be a key issue.
- Technical Questions: Infringement of the claim's specific orientation requirements—"one of the two smallest sides... faces upward" and "motherboard... is vertically oriented"—will depend on detailed factual evidence regarding the physical construction and installation of the specific ASIC hardware used in Riot's facilities.
V. Key Claim Terms for Construction
The Term: "rack-mountable server"
- Context and Importance: This term is foundational to infringement for both patents. Its construction will determine whether the patents, which describe cooling systems for what appear to be conventional data center servers, apply to the highly specialized ASIC hardware used in the Accused Products for cryptocurrency mining.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines a "server" broadly as a "computing device connected to a computing network" and states that "servers may also include specialized computing devices." (’463 Patent, col. 8:30-40). This language may support a construction that includes ASICs.
- Evidence for a Narrower Interpretation: The specification also refers to "standard-sized servers, typically measured in units of 'U'" and provides an illustration in Figure 12A of a conventional blade-style server (’463 Patent, col. 18:13-16). This could support a narrower construction limited to the traditional server form factors prevalent when the application was filed.
The Term: "controller configured to maintain a temperature" (’914 Patent, cl. 15)
- Context and Importance: This term is critical for establishing infringement of the ’914 Patent. Practitioners may focus on whether "maintain" requires an active, responsive control system or if a system designed to passively operate within a thermal window meets the limitation, as the complaint's primary evidence is a contractual operating requirement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a controller that "may receive monitor signals" and "generate control signals" to "adjust the flow of the liquid coolant" and "the amount of the heat being rejected" (’914 Patent, col. 10:49-66). This suggests an active system with a feedback loop, which could support a narrower functional requirement for "maintain."
- Evidence for a Narrower Interpretation: The claim language is "configured to maintain." A party could argue that a system is "configured" for a purpose if its components are selected and arranged to achieve that outcome under expected operating conditions, without necessarily requiring real-time, sensor-driven adjustments.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Riot induces infringement by providing "directions, designs, and/or instructions" to its subsidiaries and to third-party mining companies that use its facilities to make or use the infringing immersion cooling systems (Compl. ¶59, ¶97).
- Willful Infringement: The complaint alleges pre-suit knowledge as a basis for willfulness. It asserts that Riot had discussions with a GRC partner about GRC's systems, that GRC's website advertises its patents, and that Riot's supplier (Midas) was aware of the GRC patent portfolio from its own patent prosecution history and from unrelated litigation. The complaint also explicitly states it serves as notice for any ongoing, post-suit infringement (Compl. ¶60, ¶98).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "rack-mountable server," rooted in the patent’s 2008 description of conventional data centers, be construed to cover the specialized, high-density ASIC hardware central to Defendant’s modern cryptocurrency mining operations?
- A key evidentiary question will be one of functional proof: does the complaint provide sufficient factual support that the Accused Products utilize a "controller" that actively "maintains" coolant temperature through a feedback mechanism as described in the patent, or is the system's operation within the claimed temperature range a passive result of its design?
- The analysis of willfulness may turn on the imputation of knowledge: can Plaintiff establish that knowledge of the patents-in-suit, allegedly held by Defendant's supplier and a business partner, should be imputed to Defendant to establish pre-suit knowledge of infringement?