Green Revolution Cooling Inc v. Riot Platforms Inc

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: 3:26-cv-01842, N.D. Tex., 06/03/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Texas because Defendant Riot operates an accused immersion cooling facility in Corsicana, Texas, which is within the Dallas Division, and allegedly has a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendants' immersion cooling systems, used for large-scale cryptocurrency mining at facilities in Texas, infringe a patent related to liquid immersion cooling for racks of electronic components.
• Technical Context: The lawsuit concerns immersion cooling technology, an advanced method for managing the substantial heat generated by high-density computing hardware, which is critical in energy-intensive applications like cryptocurrency mining and AI.
• Key Procedural History: The complaint alleges that Defendant Riot had pre-suit knowledge of the patent-in-suit from a prior litigation between the parties involving related patents, during which the applicability of the now-issued patent to Riot's systems was allegedly discussed by Plaintiff's expert.

Case Timeline

Date	Event
2008-08-11	'853 Patent - Earliest Priority Date
2021-05-01	Riot acquires Whinstone and its Rockdale, Texas mining facility
2021-10-19	Riot announces its first industrial-scale immersion-cooled mining operation
2022-05-01	Riot's first immersion-cooled building at the Rockdale facility reportedly comes online
2022-10-19	Riot announces groundbreaking on its Corsicana, Texas facility
2024-04-18	Riot announces its Corsicana facility is operational
2025-09-08	Alleged date of expert discussion of the then-pending '853 Patent in prior litigation
2025-12-30	U.S. Patent No. 12,513,853 issues
2026-06-03	Complaint filed

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

U.S. Patent No. 12,513,853 - "Liquid Submerged, Horizontal Computer Server Rack And Systems And Methods Of Cooling Such A Server Rack"

• Patent Identification: U.S. Patent No. 12,513,853, "Liquid Submerged, Horizontal Computer Server Rack And Systems And Methods Of Cooling Such A Server Rack," issued December 30, 2025.

The Invention Explained

• Problem Addressed: The patent's background section describes the significant inefficiency, cost, and physical limitations of traditional air cooling in data centers Compl. ¶35 '853 Patent, col. 1:41-48 As servers become more powerful and densely packed, air cooling struggles to remove sufficient heat, consuming a large portion of a data center's electricity Compl. ¶35 '853 Patent, col. 3:18-24
• The Patented Solution: The invention proposes a system where servers are submerged in a tank containing a dielectric (non-conductive) liquid coolant Compl. ¶38 '853 Patent, col. 10:6-10 The heated coolant is circulated, typically by a pump, to a remote heat exchanger where the heat is rejected, and the cooled liquid is then returned to the tank Compl. ¶39 '853 Patent, abstract '853 Patent, col. 10:36-46 This method is described as being more efficient than air cooling, in part by allowing the coolant to operate at a higher "elevated temperature" Compl. ¶39 '853 Patent, col. 5:25-30
• Technical Importance: Immersion cooling enables significantly higher computing density and greater energy efficiency compared to conventional air-based methods, addressing a key bottleneck in the scaling of high-performance computing facilities Compl. ¶36 '853 Patent, col. 3:18-24

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-3, 6, and 10-12 Compl. ¶54
• Independent Claim 1 of the '853 Patent recites a system with the following essential elements:
  • At least one tank, a coolant inlet, a coolant outlet, a dielectric liquid coolant, a heat exchanger, a pump, and a plurality of computers
  • The tank contains at least a portion of the dielectric liquid coolant
  • At least portions of the computers are completely submerged within the coolant
  • A pump configured to move the coolant from the inlet to each of the computers
  • The coolant flows through the computers, absorbing heat
  • Heated coolant exits the computers and flows through the coolant outlet to the heat exchanger for heat rejection
  • The heat exchanger is configured to flow cooled coolant back to the coolant inlet
  • The tank is configured to allow removal of one computer without needing to remove any other computer

III. The Accused Instrumentality

Product Identification

The immersion-cooled portions of Defendants' bitcoin mining facilities in Rockdale and Corsicana, Texas (the "Accused Products") Compl. ¶40

Functionality and Market Context

• The Accused Products are large-scale cryptocurrency mining operations that use immersion cooling to manage heat generated by specialized mining hardware, known as Application-Specific Integrated Circuits (ASICs) Compl. ¶42
• The complaint alleges these systems function by submerging the ASICs in tanks filled with a specialized, non-conductive fluid Compl. ¶42 This fluid is circulated to a heat exchanger to dissipate the heat generated by the ASICs, allowing them to operate at lower, more efficient temperatures Compl. ¶42 Compl. ¶45 The complaint cites a press release stating this technology yields an estimated 25% increase in hash rate and a 50% increase in ASIC performance Compl. ¶22
• The complaint presents these facilities as central to Riot's business strategy and a source of substantial revenue Compl. ¶14 Compl. ¶28 The complaint includes a wide-angle photograph of one of the accused facilities, showing numerous rows of immersion cooling units in a large warehouse-style building Compl. ¶12, p. 6

IV. Analysis of Infringement Allegations

'853 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a system comprising: at least one tank, a coolant inlet, a coolant outlet, a dielectric liquid coolant, a heat exchanger, a pump, and a plurality of computers	Riot uses a system with these components for its immersion-cooled bitcoin mining infrastructure.	¶40	col. 25:51-60
wherein the at least one tank includes at least a portion of the dielectric liquid coolant	Riot's tanks contain a specialized non-conductive fluid for cooling. The complaint includes a screenshot allegedly showing the coolant bubbling on a surface inside a tank.	¶41; ¶42	col. 25:61-63
wherein at least portions of the plurality of computers are completely submerged within the dielectric liquid coolant	Riot's bitcoin mining ASICs (alleged to be computers) are submerged in the specialized fluid.	¶42	col. 25:64-66
wherein the pump is configured to pump the dielectric liquid coolant from the coolant inlet to each of the plurality of computers	Pumps are allegedly used to move the coolant to the computers. The complaint shows a photo of a pump connected via hoses to the side of a tank.	¶43; ¶44	col. 26:1-4
wherein at least a portion of the dielectric liquid coolant exiting the plurality of computers flows through the coolant outlet	The complaint alleges that after rising through the computers, the heated coolant exits through an outlet.	¶45	col. 26:8-10
wherein the coolant outlet is configured to enable heated dielectric liquid coolant to flow to the heat exchanger for heat rejection	The heated fluid is allegedly pumped to a heat exchanger to dissipate heat.	¶46	col. 26:11-14
wherein the at least one tank is configured to enable a removal of a computer...without a need to remove any other computer...	The complaint alleges the tanks are configured to allow servers to be independently movable and removable. A supporting screenshot shows a worker handling a single server module within a tank while others remain in place.	¶48	col. 26:18-23

• Identified Points of Contention:
  • Scope Questions: The patent's specification frequently refers to "servers" in a general-purpose data center context (e.g.,'853 Patent, col. 1:50-54). A potential dispute may arise over whether the term "computers" in claim 1 should be construed to encompass the highly specialized Application-Specific Integrated Circuits (ASICs) used in the accused mining facilities Compl. ¶42
  • Technical Questions: Claim 1 requires that the tank be "configured to enable a removal of a computer... without a need to remove any other computer." The complaint provides a video screenshot purporting to show a single unit being handled Compl. ¶48, p. 32 This raises the evidentiary question of whether this demonstrates that the system is truly "configured" for such independent removal without affecting the electrical or cooling operation of the remaining units, as may be required by the claim.

V. Key Claim Terms for Construction

• The Term: "computers"

  • Context and Importance: This term's scope is critical, as the accused devices are specialized Bitcoin mining ASICs, not the general-purpose "servers" frequently discussed in the patent's specification. Defendants may argue that ASICs do not fall within the patent's definition of "computers."
  • Intrinsic Evidence for a Broader Interpretation: The claim itself uses the broader term "computers," not the narrower term "servers." The specification also uses general terms like "computing devices having heat-generating electronic components" (e.g.,'853 Patent, col. 4:39-41), which could support an interpretation that includes specialized hardware.
  • Evidence for a Narrower Interpretation: The background section and numerous embodiments focus on traditional "servers" and "racks" in a "data center" or "server farm" context (e.g., '853 Patent, col. 1:50-54; '853 Patent, col. 2:9-14). This context could be used to argue for a definition limited to general-purpose computing machines.

• The Term: "configured to enable a removal of a computer ... without a need to remove any other computer"

  • Context and Importance: This limitation defines the serviceability of the system. The dispute will likely center on what level of independent operation and non-disruption is required to satisfy the "configured to enable" and "without a need to remove" language.
  • Intrinsic Evidence for a Broader Interpretation: The patent describes an open-top tank design that provides "easy installation and removal of each of the plurality of servers without removing or disturbing any other server" '853 Patent, col. 5:21-24 This language may support an interpretation where physical accessibility for individual removal is sufficient.
  • Evidence for a Narrower Interpretation: A party could argue that "configured to enable removal" implies more than just physical access, requiring that the cooling and power systems for the remaining computers continue to operate completely undisturbed during the removal of one unit. The claim language itself does not explicitly detail the required level of operational continuity.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Riot induced infringement by actively and knowingly providing "directions, designs, and/or instructions" to its subsidiaries and third-party mining companies to make and use the accused immersion cooling systems Compl. ¶56
• Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge of the '853 Patent. The complaint claims that during a prior litigation involving the parties, GRC's expert discussed the applicability of the then-pending '853 Patent to Riot's systems as early as September 8, 2025 Compl. ¶57 The complaint also states that its filing serves as notice for any ongoing infringement Compl. ¶57

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

1. A central issue will be one of definitional scope: can the term "computers," which is used in a patent specification heavily focused on general-purpose data center servers, be properly construed to cover the specialized, single-function Application-Specific Integrated Circuits (ASICs) that comprise the accused cryptocurrency mining systems?

2. A second key question will be evidentiary and functional: what technical proof is necessary to show that the accused tanks are "configured to enable" the removal of a single computer "without a need to remove any other," and does the evidence presented in the complaint, such as video stills of a worker handling a unit, suffice to plausibly allege this specific functional capability as required by claim 1?

3. The case may also turn on the issue of pre-suit knowledge: do the alleged discussions by an expert in a prior, related litigation regarding a then-pending patent application provide a sufficient factual basis to support a plausible claim for willful infringement from the date the patent issued?