DCT
6:24-cv-00166
Midas Green Tech LLC v. Green Revolution Cooling Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Midas Green Technologies, LLC (Texas)
- Defendant: Green Revolution Cooling, Inc. (Texas)
- Plaintiff’s Counsel: K&L Gates LLP; Cherry Johnson Siegmund James, PLLC
- Case Identification: 6:24-cv-00166, W.D. Tex., 05/27/2025
- Venue Allegations: Venue is asserted based on Defendant's principal place of business being located in Austin, Texas, within the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s immersion cooling systems for data centers and cryptocurrency mining infringe a patent related to the design of such systems, specifically focusing on fluid circulation and heat management architecture.
- Technical Context: The technology addresses the critical need for efficient heat dissipation in high-density computing environments, where conventional air cooling is often insufficient.
- Key Procedural History: The complaint references prior service of infringement contentions in the same case, suggesting this is an amended complaint filed after initial disclosures. Plaintiff also includes a declaratory judgment count regarding Defendant's "HashRaQ Max" product, anticipating a potential defense that the product has only been advertised and not yet sold in an infringing configuration. The complaint notes the '457 Patent's term was extended by 680 days and a certificate of correction was issued to amend the listed inventors.
Case Timeline
| Date | Event |
|---|---|
| 2012-12-14 | '457 Patent Priority Date (US Provisional No. 61/737,200) |
| 2019-09-03 | '457 Patent Issue Date |
| 2023-06-01 | Defendant GRC issues press release for HashRaQ Max product |
| 2025-04-07 | Plaintiff serves final infringement contentions on Defendant |
| 2025-04-15 | USPTO issues certificate of correction for the '457 Patent |
| 2025-05-27 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,405,457 - "Appliance Immersion Cooling System," Issued Sep. 3, 2019
The Invention Explained
- Problem Addressed: The patent's background section identifies several problems with prior art immersion cooling systems for electronics. These include the need to drain entire systems for component servicing, inefficient or non-uniform coolant flow leading to uneven cooling across appliances, poor scalability, and a lack of "fail-soft" or redundant operation (’457 Patent, col. 2:1-46).
- The Patented Solution: The invention proposes a self-contained immersion cooling system designed for improved fluid dynamics and serviceability. A key feature is a specific fluid circulation path: a plenum at the bottom of the tank dispenses dielectric fluid "substantially uniformly" upward through slots holding electronic appliances. The heated fluid then overflows a "weir" integrated into a long wall of the tank and is collected in a "recovery reservoir" positioned vertically beneath the weir's lip. From there, it is circulated through external heat exchangers and returned to the plenum (’457 Patent, Abstract; col. 4:12-62). This architecture, including redundant circulation pumps and control facilities, is intended to provide uniform cooling and allow for continuous, fail-soft operation (’457 Patent, col. 5:16-35).
- Technical Importance: The described approach aims to improve upon prior systems by creating a more efficient, uniform, and reliable cooling environment for high-density servers, which is critical for maintaining performance and longevity in data centers (’457 Patent, col. 2:42-46).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 6, as well as dependent claims 2 and 3 (Compl. ¶46).
- Independent Claim 1 (System Claim):
- An appliance immersion cooling system comprising a tank with appliance slots.
- A weir integrated horizontally into a long wall of the tank with an overflow lip to facilitate substantially uniform recovery of the dielectric fluid.
- A dielectric fluid recovery reservoir positioned vertically beneath the overflow lip.
- A primary circulation facility with a plenum at the bottom of the tank to dispense fluid substantially uniformly upward.
- A secondary fluid circulation facility to extract heat from the dielectric fluid.
- A control facility to coordinate the primary and secondary facilities based on fluid temperature.
- Independent Claim 6 (Tank Module Claim):
- A tank module comprising a tank with appliance slots.
- A weir integrated horizontally into a long wall of the tank with an overflow lip to facilitate substantially uniform recovery of the dielectric fluid.
- A dielectric fluid recovery reservoir positioned vertically beneath the overflow lip.
- A primary circulation facility with a plenum at the bottom of the tank to dispense fluid substantially uniformly upward.
- A control facility to control the primary circulation facility based on fluid temperature.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's immersion cooling systems, specifically the "ICEraQ S10, ICEraQ SX, and ICEraQ Micro" and the "HashRaQ Max" product lines (Compl. ¶8).
Functionality and Market Context
- The complaint alleges these products are immersion cooling systems designed for use in data centers, including for high-demand applications like cryptocurrency mining (Compl. ¶2). The complaint asserts these products contain the structural and functional components of the patented system, including a tank, weir, reservoir, plenum, and circulation facilities, to cool electronic components submerged in a dielectric fluid (Compl. ¶10-16, ¶24-30). The "HashRaQ Max" is specifically identified as being designed for "blockchain applications" (Compl. ¶53).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges infringement of claims 1 and 6. The allegations for each claim are nearly identical, with claim 1 directed to a broader "system" and claim 6 to a more specific "tank module."
’457 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a tank adapted to immerse in a dielectric fluid a plurality of electrical appliances, each in a respective appliance slot distributed vertically along, and extending transverse to, a long wall of the tank | The ICEraQ and HashRaQ products comprise a tank for immersing electronic appliances in dielectric fluid in appliance slots. | ¶10, ¶24 | col. 4:42-50 |
| a weir, integrated horizontally into the long wall of the tank adjacent all appliance slots, having an overflow lip adapted to facilitate substantially uniform recovery of the dielectric fluid flowing through each appliance slot | The accused products have a weir integrated horizontally into the long wall of the tank with an overflow lip to facilitate uniform fluid recovery. | ¶11, ¶25 | col. 4:52-56 |
| a dielectric fluid recovery reservoir positioned vertically beneath the overflow lip of the weir and adapted to receive the dielectric fluid as it flows over the weir | The accused products have a dielectric fluid recovery reservoir positioned vertically beneath the overflow lip. | ¶12, ¶26 | col. 4:27-33 |
| a primary circulation facility adapted to circulate the dielectric fluid through the tank, comprising: a plenum, positioned adjacent the bottom of the tank, adapted to dispense the dielectric fluid substantially uniformly upwardly through each appliance slot | The accused products have a primary circulation facility with a plenum at the bottom of the tank to dispense fluid upward. | ¶13, ¶14, ¶27-28 | col. 4:12-26 |
| a secondary fluid circulation facility adapted to extract heat from the dielectric fluid | The accused products have a secondary fluid circulation facility to extract heat from the dielectric fluid. | ¶15, ¶29 | col. 5:1-6 |
| a control facility adapted to coordinate the operation of the primary and secondary fluid circulation facilities as a function of the temperature of the dielectric fluid in the tank | The accused products have a control facility to coordinate the operation of the circulation facilities based on fluid temperature. | ¶16, ¶30 | col. 5:16-24 |
- Identified Points of Contention:
- Doctrine of Equivalents: For every element of the asserted claims, the complaint states, "To the extent this limitation is not literally practiced, is it practiced under the doctrine of equivalence" (e.g., Compl. ¶10-16). This repeated pleading suggests Plaintiff anticipates that Defendant’s products may have structural or functional differences from the literal claim language, raising the question of whether those differences are insubstantial.
- Technical Questions: A central question will be whether the accused products’ fluid handling components—specifically their weir, reservoir, and plenum equivalents—perform in "substantially the same way" to achieve "substantially the same result" as the claimed invention. The complaint offers conclusory allegations of function but no detailed technical evidence (e.g., fluid dynamics modeling, component schematics) to substantiate these claims.
- Declaratory Judgment: The complaint preemptively seeks a declaratory judgment that the HashRaQ Max product infringes, anticipating that GRC may argue it "has only advertised, but has not yet made, used, sold, [or] offered to sell" a complete, infringing system (Compl. ¶52). This raises a procedural question of whether an "actual case and controversy" exists for this product line sufficient to confer jurisdiction.
V. Key Claim Terms for Construction
The Term: "weir, integrated horizontally into the long wall of the tank" (Claim 1)
- Context and Importance: The structural relationship between the weir and the tank wall is a specific limitation. Practitioners may focus on this term because the definition of "integrated" will be critical. If construed narrowly to mean "formed as a single, unitary piece with the wall," it may not read on systems where the weir is a distinct component that is merely attached. If construed more broadly to include permanent attachment, the scope of infringement could be wider.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "integrated" is not explicitly defined. A party might argue that in the context of mechanical arts, components that are welded, bolted, or otherwise permanently affixed to function as one unit can be considered "integrated."
- Evidence for a Narrower Interpretation: The figures, such as Figure 5, appear to depict the weir (22) as a feature formed from the material of the tank wall (14) itself, rather than as a separate part. The specification states it is integrated "into" the wall, which may suggest a unitary construction (’457 Patent, col. 4:53-54).
The Term: "substantially uniform" (referring to fluid recovery and dispensing) (Claim 1)
- Context and Importance: This term of degree is central to the patent's purported solution to the "uneven cooling" problem of the prior art (’457 Patent, col. 2:32). The infringement analysis will depend heavily on the level of variance in fluid flow permitted by the term "substantially."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a quantitative measure for "uniform," so a party could argue it should be given its plain and ordinary meaning relative to the goals of the invention—i.e., uniform enough to prevent the specific problem of uneven cooling identified in the prior art.
- Evidence for a Narrower Interpretation: The specification emphasizes that a key problem is "non-uniform flow patterns" (’457 Patent, col. 2:31-32). A party could argue that "substantially uniform" must be construed to require a high degree of uniformity, one that measurably improves upon the prior art systems discussed. The use of multiple orifices per appliance slot is described as a way to "make the flow of dielectric fluid more uniform" (’457 Patent, col. 4:25-26), providing context for what the inventor considered to be a more uniform flow.
VI. Other Allegations
- Indirect Infringement: The complaint makes general allegations of indirect infringement (Compl. ¶42). It further alleges in its declaratory judgment count that infringement would occur "once the GRC-supplied components of the HashRaQ Max system are installed and in use by a GRC customer" (Compl. ¶52) and that GRC has created "software guides for end users to operate the HashRaQ Max" (Compl. ¶54). These allegations may form the factual basis for a claim of induced infringement, although the complaint does not explicitly connect the software guides to specific acts of inducement.
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the patent, which Plaintiff claims stems from "past interaction with Plaintiff" (Prayer for Relief ¶G(i)) and continued infringement after receiving actual notice (Compl. ¶50). The complaint alleges infringement has been knowing and intentional since at least 2021 (Compl. ¶44).
VII. Analyst’s Conclusion: Key Questions for the Case
- Doctrine of Equivalents vs. Literal Infringement: A primary battleground will be factual. Given Plaintiff’s repeated pleading in the alternative, a key question is whether Defendant's products literally meet the claim limitations or, if not, whether any differences between the accused systems and the patent's specific architecture (e.g., the integrated weir, the plenum design, the reservoir location) are insubstantial enough to support infringement under the doctrine of equivalents.
- Claim Construction and Scope: The case may turn on a legal question of definitional scope. The construction of relative terms like "substantially uniform" and structural terms like "integrated" will be dispositive. The court’s interpretation will determine whether the claims are broad enough to cover Defendant's specific product designs or if they are limited to the precise embodiments shown in the patent.
- Justiciability of the "HashRaQ Max" Dispute: A threshold procedural issue is whether a sufficient "case and controversy" exists for the HashRaQ Max product. The court will need to determine if Defendant's actions—such as issuing press releases, creating detailed CAD drawings, and building promotional versions—constitute sufficient affirmative acts toward infringement to warrant a declaratory judgment, even if, as Plaintiff anticipates Defendant may argue, a commercial sale of a complete system has not yet occurred.