Green Revolution Cooling Inc v. Riot Platforms Inc — Entry #1

Case 3:26-cv-01842-E          Document 1         Filed 06/03/26       Page 1 of 42    PageID 1


                        IN THE UNITED STATES DISTRICT COURT
                        FOR THE NORTHERN DISTRICT OF TEXAS
                                  DALLAS DIVISION


GREEN REVOLUTION COOLING, INC.,
                                                                Civil Action No. 3:26-cv-01842
                Plaintiff,

        v.
                                                                JURY TRIAL DEMANDED
RIOT PLATFORMS, INC., RIOT CORSICANA,
LLC, AND WHINSTONE US, INC.

                Defendants.


                       COMPLAINT FOR PATENT INFRINGEMENT

        Plaintiff Green Revolution Cooling, Inc. (“GRC” or “Plaintiff”) files this Complaint for

Patent Infringement against Defendants Riot Platforms, Inc.; Riot Corsicana, LLC; and Whinstone

US, Inc. (collectively “Riot” or “Defendants”) for infringement of U.S. Patent No. 12,513,853 (the

“ 853 Patent”). GRC, on personal knowledge as to its own acts, and on information and belief as

to all others based on its investigation, alleges as follows:

                                 SUMMARY OF THE ACTION

        1.      This is a patent infringement suit relating to Riot’s unauthorized and unlicensed use

of the 853 Patent. GRC’s patented technology supports the core of Riot’s systems, including all

of Riot’s immersion cooling facilities in Texas.

        2.      GRC was founded in 2009 with a vision to change the way data centers are

designed, built, and operated. Even back then GRC recognized that data was the lifeblood of

businesses big and small. However, as data processing needs increased over time, more powerful

(heat generating) servers were required to process this data. It became increasingly complicated

and expensive for data centers to cool these servers using traditional air cooling. Traditional air-


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cooling and the conventional solutions (more space and/or more air-cooling capacity) were

becoming less cost effective, if not impossible. In fact, no matter how good the system, air cooling

could only carry away so much heat, which meant it would be extremely difficult to effectively air

cool with increasingly powerful, tightly packed servers. Moreover, air cooling equipment already

consumed almost half of a data center’s energy usage and formed a large portion of a data center’s

build-out cost. Creating more space was not practical for the same reasons. Traditional systems

needed a Computer Room Air Conditioner (“CRAC”), chiller, cooling tower, backup generator,

air-flow engineering (e.g., air ducting), hot/cold aisles, raised or special flooring, and rack rails to

come online. As a result, these facilities were not easily reengineered or expanded.

        3.      GRC set its sights on solving this problem. The result was groundbreaking: a single-

phase immersion cooling system that works by immersing servers in a liquid coolant. Compared

to air, single-phase immersion systems (when well designed) can cool servers with warm liquid

versus air cooling which typically requires cooling the air down to 50 to 70 F. As a result, GRC’s

immersion technologies cut lifetime cooling costs by around 85% and used around 95% less

cooling power. In addition to these cost savings, GRC’s innovations reduced the cost, complexity,

and equipment needed to build a data center. Rooms no longer had to be designed for careful

airflow. Backup generators could be 50% smaller as overall power consumption dropped. Server

reliability increased by removing hotspots, allowing more time for disaster recovery, and

eliminating fans and related vibration. GRC’s use of dielectric coolant also meant that its systems

relied on non-toxic fluids that carry 1,200 times more heat by volume than air.

        4.      The industry quickly took notice. GRC was awarded grants from the Department

of Defense and the National Science Foundation. In 2009 and 2010, GRC won back-to-back

“Disruptive Technology of the Year” awards at the Supercomputing Conference. The NSA also


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publicly praised GRC’s technology in a rare report. And for over a decade, GRC’s immersion

systems have supported USAF military operations. More recently, IT giants Dell, Intel, and others

have come to partner with GRC, whose technologies are currently at work in some of the world’s

largest cloud, enterprise, education, government, and telecom organizations. GRC’s products have

been deployed in the United States, Canada, Costa Rica, the United Kingdom, France, Spain,

Sweden, the Netherlands, Austria, Romania, Serbia, Italy, Mali, Uganda, India, Singapore,

Vietnam, South Korea, Australia, Taiwan, and Japan. Today GRC’s systems can power the data

centers behind artificial intelligence, machine learning, edge computing, blockchain, and crypto-

mining with substantial advantages over the competition.

        5.      With success comes copycats and others who seek to capitalize on GRC’s novel

approach to immersion cooling. Riot is one example. Riot is a bitcoin mining company whose

“vision is to be the world’s leading Bitcoin-driven infrastructure platform.” Riot Platforms FY

2023 Update, Feb. 27, 2024, https://s3.amazonaws.com/b2icontent.irpass.cc/2865/193123.pdf. In

2021, more than a decade after GRC launched its immersion cooling systems, Riot deployed

infringing immersion cooling technology within its bitcoin mining facilities. Riot announced that

after only “months of research and development,” it “pioneer[ed] . . . the use of cutting-edge

immersion-cooling technology at an unprecedented scale.” Press Release, Riot Platforms, Riot

Announces First Industrial-Scale Immersion-Cooled Bitcoin Mining Operation, Oct. 19, 2021,

https://www.riotplatforms.com/riot-announces-first-industrial-scale-immersion-cooled-bitcoin-

mining-operation/ [hereinafter October 2021 Press Release]. Riot has now launched infringing

immersion-based facilities in both Rockdale and Corsicana, Texas. GRC brings this action to put

an end to Riot’s unauthorized use of GRC’s 853 Patent.


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                                             PARTIES

          6.    Plaintiff Green Revolution Cooling, Inc. is a Delaware corporation with its

principal place of business at 11525 Stonehollow Drive, Suite A-135, Austin, Texas 78758.

          7.    On information and belief, Defendant Riot Platforms, Inc. is a Nevada company

with its principal place of business at 3855 Ambrosia Street, Suite 301, Castle Rock, CO 80109.

          8.    On information and belief, Defendant Riot Corsicana, LLC (f/k/a Project Lefty,

LLC) is a Texas company with its principal place of business at 6980 FM 709 S Corsicana, Texas

78759. Riot Corsicana, LLC is a subsidiary of Riot Platforms, Inc., and Riot Platforms, Inc. is the

parent of Riot Corsicana, LLC.

          9.    On information and belief, Defendant Whinstone US, Inc. is a Delaware company

with its principal place of business at 2721 Charles Martin Hall Rd, Rockdale, Texas 76567.

Whinstone US, Inc. is a wholly-owned subsidiary of Riot Platforms, Inc.

                                 JURISDICTION AND VENUE

          10.   This is an action containing claims for patent infringement arising under the patent

laws of the United States, Title 35, U.S.C. § 271. This Court has exclusive subject matter

jurisdiction over those claims pursuant to 28 U.S.C. §§ 1331, 1367, and/or 1338.

          11.   This Court has personal jurisdiction over Riot because it either currently resides in

the State of Texas, has a regular and established place of business within the State of Texas, has

had minimum contacts with the State of Texas sufficient to confer the Court with general personal

jurisdiction, or has committed acts within the State of Texas giving rise to the claims asserted

herein.

          12.   Riot does extensive business in this Division, District, and State. Upon information

and belief, Riot Platforms, Inc., along with its wholly-owned subsidiary, Riot Corsicana, LLC,


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owns and operates an infringing immersion cooling facility in Navarro County, Texas (the

“Corsicana Facility”) that currently employs immersion cooling. This facility is in Corsicana, TX,

which is in the Dallas Division of the Northern District of Texas. Riot states that “[t]he initial

phase of the development of the Corsicana Facility involves the construction of 400 megawatts

(‘MW’) of immersion-cooled Bitcoin Mining and Data Center Hosting infrastructure.” See Riot

2023 10-K at 5. In 2023, Riot “entered into a purchase agreement with Midas for the purchase of

200 MW of immersion cooling systems for its Corsicana Facility.” Id. at F-25. Delivery of these

systems “began in the fourth quarter of 2023 and is expected to be completed in the first quarter

of 2024.” Id. The “400 MW substation [at the Corsicana Facility] is expected to be energized by

the end of March 2024, and the first 100 MW building, A1, will commence operations immediately

thereafter.” See Press Release, Riot Platforms, Riot Announces January 2024 Production and

Operations Updates, Feb. 5, 2024, https://www.riotplatforms.com/riot-announces-january-2024-

production-and-operations-updates/. On April 18, 2024, Riot announced that the Corsicana

Facility is operational, stating “‘[t]wo years ago, we purchased 265 acres of land in Navarro

County, Texas, driven by our vision to build the world's largest Bitcoin mining facility, and today,

we have achieved a new milestone in turning that vision into a reality with the energization of our

Corsicana Facility,’ said Jason Les, CEO of Riot. ‘This landmark achievement highlights our

team’s unwavering dedication and collaborative effort over the past two years. With the Corsicana

Facility’s 400-megawatt substation now operational, we remain well on track to increase our self-

mining hash rate capacity to 31 EH/s by the end of 2024, which will represent a significant increase

in     our   operational    capabilities.’”   https://www.marketscreener.com/quote/stock/RIOT-

PLATFORMS-INC-38481086/news/Riot-Energizes-New-Corsicana-Facility-in-Navarro-

County-Texas-46468926/. Riot describes the Corsicana Facility as having “400 MW of


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immersion-cooling.” https://www.riotplatforms.com/bitcoin-mining/corsicana/. The following is

one building full of immersion cooling units at the Corsicana Facility:


Id.

         13.     Riot does further business in Texas. Upon information and belief, Riot Platforms,

Inc., along with its wholly-owned subsidiary Whinstone US, Inc. owns and operates an infringing

immersion cooling facility in Rockdale, Texas. Riot boasts that its “Rockdale Facility” is “believed

to be the largest single Bitcoin mining facility in North America.” See Riot Platforms, Inc., Annual

Report         (Form    10-K)      33,     Feb.       23,    2024,        https://s3.amazonaws.com/

sec.irpass.cc/2865/0001558370-24-001550.pdf [hereinafter Riot 2023 10-K]. It “currently

provides 700 MW in total developed capacity.” Id. To a “large extent,” Riot relies on immersion

cooling at the Rockdale Facility. Id. at 21. At least “200 MW [MegaWatts] of capacity across two

[Rockdale] buildings [are] dedicated to immersion-cooled self-mining operations.” Riot Platforms

Corporate Presentation 5, Dec. 6, 2023, https://d2ghdaxqb194v2.cloudfront.net/2865/192541.pdf.


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During 2023, Riot “paid $31.2 million in deposits and payments to Midas Green Technologies,

LLC . . . for the purpose of immersion cooling systems.” Riot 2023 10-K at 41.


See https://www.riotplatforms.com/bitcoin-mining/rockdale/.

        14.     On information and belief, Riot has used, and is using, the claimed technology of

the 853 Patent within these facilities, thereby committing acts of patent infringement in this

Division, District, and State. Riot has also derived substantial revenue from these infringing

activities within this Division, District, and State. As one example, Riot announced 2023 financial

results of “all-time highs of $281 million in total revenues, 6,626 Bitcoin produced, and $71

million in power credits earned . . .” Press Release, Riot Platforms, Riot Platforms Reports Full

Year 2023 Financial Results, Current Operational and Financial Highlights, Feb. 22, 2024,

https://www.riotplatforms.com/riot-platforms-reports-full-year-2023-financial-results-current-

operational-and-financial-highlights/. Riot therefore has a regular and established place of

business within this Division, District, and State; Riot regularly conducts business in this Division,

District, and State; and Riot has committed purposeful acts within this Division, District, and State

such that it should reasonably anticipate being haled into this Court.

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        15.     Venue is proper in the Northern District of Texas under 28 U.S.C. § 1400(b) as Riot

has a regular and established place of business in this Division and District with its Corsicana

Facility. And, on information and belief, Riot has committed acts of infringement at least at this

location and within the State.

                                   FACTUAL ALLEGATIONS

        A. GRC Has a Rich History of Innovation in Immersion Cooling.

        16.     GRC was founded in Austin, Texas and has a long history of innovation in the

immersion cooling space, spanning nearly 15 years. Around 2009, there were 30 million computer

servers worldwide that used variants of air cooling. Conventional air-cooling systems nearly

doubled data center energy consumption, required costly capital expenditures and special data

center designs, and did not work well for high-density server hardware. This environment typically

required chilling water to 10°C (50°F) to create an air temperature of 25°C (77°F) for use in air

cooling the servers in a data center. Chilling alone added 25-33% to the power consumed by a data

center. These facilities also needed fans to circulate the air and, because of layout considerations,

air-cooling often created hotspots and/or vibration that could damage components and reduce data

center reliability. Combined, fans and cooling equipment were responsible for roughly 50% of

total power draw within a data center.

        17.     GRC co-founder and co-inventor, Christiaan Best, discovered these inefficiencies

in early 2008 while working at a MEMS start-up in the air conditioning field. He and his co-

inventor immediately began brainstorming for solutions to this problem. The result was a new,

immersion-cooled system that used a safe, non-toxic, single-phase dielectric coolant in which data

center components were immersed. GRC filed a patent application on this idea, which matured

into a patent family that includes the 853 Patent. GRC also began building these systems, and the

first incarnation was called the “CarnotJet.” It efficiently removed heat by fully submersing a data

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center’s computer components in a single-phase dielectric coolant, with innovative hardware

architecture, system design, and control software to optimize performance and reliability. GRC’s

CarnotJet system featured a horizontal rack that allowed data center technicians to easily remove

or swap servers while the remainder of the system continued to function. And because the dielectric

coolant was safe for humans, the racks did not have to be sealed and no special considerations

were needed to handle or interact with submersed servers. In recognition of these achievements,

GRC won “Disruptive Technology of the Year” in 2009 and 2010.

        18.     One of the first to implement GRC’s then patent-pending technology in a live data

center was Texas Advanced Computing Center (“TACC”) in April 2010. The results were

astounding. GRC’s systems allowed TACC to consume 40% less total energy. This demonstration

also showed that GRC’s systems could perform even for top supercomputing sites, like that of

TACC. Swiss National Supercomputing followed suit in December 2010. Both installations

exhibited 100% uptime and consumed 95% less cooling energy compared to standard air-cooled

systems.

        19.     Since that time, many customers and partners have come to see the benefits of this

technology for themselves. Between 2012 and 2013, the U.S. Air Force, Intel, the NSA, Vienna

Scientific Cluster, Tokyo Institute of Technology, and other leading names in computing came on

board. In June 2013, GRC released a containerized version of its systems for the Department of

Defense. In 2015, GRC installed its technologies at Port d’Informacio Cientifica (“PIC”), which

supports data processing for CERN’s Large Hadron Collider. And by 2019, GRC had entered

partnerships with Hewlett Packard Enterprise, Dell, and other global partners. In short, GRC’s

systems support some of the largest computing installations around the world, including those in

the United States, Canada, Costa Rica, the United Kingdom, France, Spain, Sweden, the


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Netherlands, Austria, Romania, Serbia, Italy, Mali, Uganda, India, Singapore, Vietnam, South

Korea, Australia, Taiwan, and Japan.

        20.     Today, GRC continues to innovate. It has over two dozen patents and applications

that protect its technologies. GRC has also unveiled several products, including the ICEraQ series.

These products include the basic principles on which GRC was founded—immersion cooling with

safe coolants, along with additional features that are cost effective, scalable, resilient, and future-

proof. These products can handle the extreme heat load of the newest generations of servers behind

bleeding-edge technologies like artificial intelligence, machine learning, blockchain, and crypto-

mining.

        B. Riot Implemented, and Improperly Benefits From, GRC’s Patented Technology.

        21.     In May 2021, Riot acquired Whinstone, which had a 300 MW Bitcoin mining

infrastructure in Rockdale, Texas. “Immediately following the acquisition, Riot announced a 400

MW expansion” of the facility to be completed by Q2 2022. Press Release, Riot Platforms, Riot

Blockchain Announces Investor Site Tour, Sept. 29, 2021, https://www.riotplatforms.com/riot-

blockchain-announces-investor-site-tour/. About 200 MW of that expansion would be

“immersion-cooling technology at [] Whinstone,” which has since been renamed the Rockdale

Facility. See October 2021 Press Release.

        22.     Riot’s plan was to “leverag[e] technology, industry-leading low power costs, and

economies of scale” to drive “operating and capital efficiencies for its self-mining business and its

institutional clients.” Id. This technology would also allow Riot to observe “an increase in the

Company’s hash rate and productivity” without “having to rely solely on purchasing additional

ASICs” Id. In fact, Riot expected “an estimated 25% increase in hash rate” and a 50% “increase

[in] ASIC performance.” Id. Riot’s first immersion-cooled building came online in May 2022.

Press Release, Riot Platforms, Riot Blockchain Announces July 2022 Production and Operations

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Updates, Aug. 3, 2022, https://www.riotplatforms.com/riot-blockchain-announces-july-2022-

production-and-operations-updates/.

        23.     As part of this plan, Riot set out to expand its Texas footprint. By early 2023, Riot

had completed expansion of its Rockdale Facility, which it “believed to be the largest single

Bitcoin mining facility in North America.” See Riot 2023 10-K at 33. At least “200 MW of capacity

across two [Rockdale] buildings [are] dedicated to immersion-cooled self-mining operations.”

Riot Platforms Corporate Presentation at 5.

        24.     And by October 2022, Riot “ha[d] officially broken ground at [its] 1 gigawatt

(‘GW’) expansion project (‘the Corsicana Facility’) in Corsicana, Navarro County, Texas.” Press

Release, Riot Platforms, Riot Announces Groundbreaking at 1 GW Data Center Facility in

Corsicana, Navarro County, Texas, Oct. 19, 2022, https://www.riotplatforms.com/riot-announces-

groundbreaking-at-1-gw-data-center-facility-in-corsicana-navarro-county-texas/. “The first phase

of the Corsicana Facility’s development is expected to consist of four 100 MW buildings utilizing

immersion cooling technology similar to what is already in place at Riot’s Rockdale Facility.” Id.

        25.     Since 2024, the Corsicana Facility has moved from initial development to active,

large scale operations and continued expansion. In April 2024, Riot announced that it had

“successfully energized the substation” at the Corsicana Facility and that “miners [were] now

hashing,” with the initial 400 megawatt phase placed into operation and additional buildings

scheduled to come online throughout 2024. Riot further represented on its website and through

press releases that the Corsicana Facility—consisting of approximately 400 MW of

immersion cooled Bitcoin mining infrastructure—was completed or substantially deployed by

year end 2024, and that the site is designed to scale to approximately 1 gigawatt of total capacity.

Riot has continued to describe the Corsicana Facility as a long term asset, emphasizing its role in


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expanding Riot’s mining operations and supporting future growth initiatives, including additional

data center and high performance computing uses, thereby confirming the ongoing, large scale,

and permanent nature of Riot’s operations at the Corsicana Facility.

         26.    In its 10-K for fiscal year 2025 dated March 2, 2026, Riot stated that “[d]uring the

year ended December 31, 2025, we continued development activities at the Corsicana Facility and

deployed miners at all our Facilities, with the objective of increasing our operational efficiency

and performance in the future. As of December 31, 2025, we had a total deployed hash rate

capacity of 38.5 EH/s, as compared to 31.5 EH/s as of December 31, 2024, an increase of 22.1%.”

Riot further stated that “[w]e are increasingly dependent on immersion-cooling technology for our

Bitcoin Mining operations, to a large extent at the Rockdale Facility, and exclusively at the

Corsicana Facility.” See Riot Platforms, Inc., Annual Report (Form 10-K) 27 and 46, Mar. 2, 2026,

https://s3.amazonaws.com/ sec.irpass.cc/2865/0001558370-24-001550.pdf [hereinafter Riot 2025

10-K].

         27.    On information and belief, Riot has used, and is using, the claimed technology of

the 853 Patent within these facilities, thereby committing acts of patent infringement. Riot has

also derived substantial revenue from these infringing activities.

         28.    For example, “[f]or the year ended December 31, 2025, Bitcoin Mining revenue

was approximately $576.3 million.” See Riot 2025 10-K at 46.

                     COUNT 1: INFRINGEMENT OF PATENT NO. 12,513,853

         29.    GRC incorporates by reference the preceding paragraphs, as if set forth herein.

         30.    GRC’s immersion cooling technologies are protected by various patents including

the 853 Patent asserted here.

         31.    The 853 Patent is valid and enforceable under United States Patent Laws.


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        32.     GRC owns, by assignment, all right, title, and interest in and to the 853 Patent,

including the right to collect for past damages.

        33.     A copy of the 853 Patent is attached as Exhibit A.

        A. The 853 Patent

        34.     The 853 Patent is entitled “Liquid Submerged, Horizontal Computer Server Rack

And Systems And Methods Of Cooling Such A Server Rack.” It was filed on July 10, 2025, and

claims priority to: U.S. Patent Application No. 13/057,881 filed on August 10, 2009; U.S.

Provisional Application No. 61/188,589 filed on August 11, 2008; U.S. Provisional Application

No. 61/163,443 filed on March 25, 2009; and U.S. Provisional Application No. 61/165,470 filed

on March 31, 2009. The U.S. Patent and Trademark Office issued the 853 Patent on December

30, 2025, to Green Revolution Cooling, Inc., listing Christiaan Best and Mark Garnett as co-

inventors.

        35.     Prior to the inventions described in the 853 Patent, data centers typically relied on

air cooling. Ex. A at 1:66-2:7. Air cooling uses “vents that allow external air to flow” into the data

center, and to its server components, by a fan. Id. at 2:2-8. Air in a data center “usually passe[d]

through a heat exchanger for cooling the air . . . before entering a server.” Id. at 2:16-20. “In some

data centers, [a] heat exchanger [was] . . . mounted to [a] rack to provide ‘rack-level’ cooling of

air before the air enter[ed] a server.” Id. at 2:20-23. In other installations, “the air [was] cooled

before entering the data center.” Id. at 2:23-24. Such designs accounted for “[m]ore than one-third

of data center electricity consumption . . ., which could equate to more than about 1% of all U.S.

electricity consumed by 2011.” Id. at 1:41-44. Thus, the “overall cost of cooling [was] a large and

growing part of the total cost of operating a data center.” Id. at 1:44-48.

        36.     In addition, because “spacing heat-dissipating components from each other (e.g.,

reducing heat density) makes cooling such components less difficult,” conventional data centers

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“compensated for increased power dissipation (corresponding to increased server performance) by

increasing the spacing between adjacent servers.” Id. at 2:55-57, 2:61-64. Consequently, even

some “state-of-the-art data centers are capable of cooling only about 150 Watts-per square- foot,

as opposed to cooling the more than about 1,200 Watts-per-square-foot that could result from

arranging servers to more fully utilize available volume (e.g., closely spacing servers and racks to

more fully utilize floor-to ceiling height and floor space).” Id. at 3:18-24.

        37.     The co-inventors therefore recognized the “need for an effective, efficient and low-

cost cooling alternative for cooling electronic components,” especially since “commercially

available methods of cooling have not kept pace with increasing server and data-center

performance needs, or the corresponding growth in heat density.” Id. at 3:28-31, 4:33-35.

        38.     To address this, the 853 Patent “provides novel apparatus, systems, and methods

for efficiently cooling computing devices having heat-generating electronic components.” Id. at

4:39-41. In one embodiment, the 853 Patent describes systems that hold and cool servers that have

heat producing electronic components. See, e.g., id. at 10:6-21. These systems include “a tub or

tank [] containing a dielectric liquid coolant into which a plurality of servers [] may be immersed.”

Id. at 10:24-26; see also id. at 13:16-18. An exemplary illustration of the 853 system embodiments

is shown below:


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Id. at Figure 11.

        39.     As the servers generate heat through their operation, the liquid coolant also

becomes heated. Id. at 10:37-42. In one embodiment, a pump “may pump liquid coolant from [an]

external heat exchanger through the piping system into the tank [] to maintain coolant fluid

circulation within the tank.” Id. at 15:17-20. In some configurations, the “liquid coolant heated by

the heat generating components in the servers [] naturally rise[s] through the servers and exit[s]

through the top or ‘front panel’ of the servers.” Id. at 15:26-28. In other embodiments the piping

“may be reversed such that the heated liquid coolant may exit from the installed servers through

its ‘rear panel.’” Id. at 15:36-38. The liquid coolant may then be “fluidly coupled through suitable

piping or lines to a pump [], which pumps the heated liquid coolant through suitable piping or lines

to a remotely or distally located heat exchanger.” Id. at 10:36-41; see also id. at 13:45-50. The heat

exchanger “rejects the heat from the incoming heated liquid coolant and fluidly couples the cooled

liquid coolant through a return fluid line or piping [] back into the tank.” Id. at 10:42-46; see also

id. at 13:29-46. The tank therefore may be “fabricated to have an inlet pipe or line [] from a piping

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system connected to a heat exchanger for the flow of lower temperature or cooled liquid coolant

into the tank [] and an outlet pipe or line [] connected to the collection piping for the flowing or

pumping of heated coolant out of the tank to the external heat exchanger . . .” Id. at 14:48-53.

        B. 853 Patent Allegations

        40.     Upon information and belief after reasonable investigation, the immersion-cooled

portions of Riot’s Rockdale and Corsicana Facilities (the “Accused Products”) infringe the 853

Patent. As one example, Riot uses 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 according

to claim 1. For example, Riot’s Accused Products use immersion-cooled bitcoin mining

infrastructure where bitcoin mining ASICs are submerged in a specialized fluid to keep the ASICs’

integrated circuits operating at lower temperatures. See October 2021 Press Release (explaining

Riot’s use of immersion cooling); see also Chad Everett Harris, Riot Blockchain’s 700 MW

Bitcoin Mining Facility – 200MW Industrial-scale Immersion System, YouTube (Jan. 18, 2022),

https://www.youtube.com/watch?v=aQ3o_QDTYV4 [hereinafter 700 MW Bitcoin Mining

Facility Video] (video showing Riot’s use of immersion cooling system). The tank, coolant inlet,

coolant outlet, dielectric liquid coolant, heat exchanger, pump, and plurality of computers can be

seen in Riot’s videos as shown below:


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See Jimmy is Promo, Private Tour of Riot’s MASSIVE Whinstone Bitcoin Mining Facility &

Exclusive Interview with the CEOs, YouTube (Mar. 3, 2022), https://www.youtube.com/ watch?

v=La7vMl1txCU [hereinafter Private Facility Tour Video].


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See Riot’s Corsicana Video (https://www.youtube.com/watch?v=0BvJwTMsG2k&list=

PLC8ND4e27bHJXv5qTGpqrnjjLJ8LR2I3V&index=3).


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See id.

          41.   Riot’s Accused Products use a tank that includes at least a portion of the dielectric

liquid coolant. For example, Riot’s Accused Products use a tank that contains dielectric coolant,

as shown below:


See id; see also 700 MW Bitcoin Mining Facility Video; Private Facility Tour Video.


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See       Corsicana   Phase    1   Progress      video,   YouTube    (Sept.    24,   2024),

https://www.youtube.com/watch?v=nCn_LclP7uk [hereinafter Corsicana Phase 1 Progress

Video].


See Riot’s Corsicana Video.


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See id.

          42.   Riot’s Accused Products also include a plurality of computers where at least

portions of the computers are completely submerged within the dielectric liquid coolant. For

example, Riot has stated that its “[b]itcoin [m]ining activities require large volumes of a

specialized non-conductive fluid.” See Riot 2023 10-K at 8. According to the October 2021 Press

Release, this fluid is what is pumped into the tank. Riot also describes its “[p]rocess of

[i]mmersion-[c]ooling as “a technique where Bitcoin mining ASICs are submerged in a specialized

fluid, which is circulated to keep the ASICs’ integrated circuits operating at lower temperatures.”

See October 2021 Press Release. The fluid can also be seen flowing and reflecting light in Riot’s

videos:


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See Private Facility Tour Video.


See Riot’s Corsicana Video.


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See id.

          43.   In Riot’s Accused Products, the pump is configured to pump the dielectric liquid

coolant from the coolant inlet to each of the plurality of computers. For example, as shown in

Riot’s videos, the pump(s) move the coolant from the coolant inlet to each of the plurality of

computers:


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See 700 MW Bitcoin Mining Facility Video.


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See Private Facility Tour Video.


See Corsicana Phase 1 Progress video.


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See Riot’s Corsicana Video.


See id.


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See id.

          44.   As shown in Riot’s videos above, the dielectric liquid coolant flows through the

plurality of computers for absorbing at least a portion of any heat being generated by each of the

plurality of computers. Additionally, these features are described in a Riot news release, explaining

that Riot uses tanks to hold “a specialized fluid” that is “pumped and circulated to assist in

dissipating the heat” and “pumped back through the immersion tank.” See October 2021 Press

Release.


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        45.     Riot’s Accused Products include at least a portion of the dielectric liquid coolant

exiting the plurality of computers that flows through the coolant outlet. For example, Riot’s

October 2021 Press Release states that the fluid which the servers are submerged in is “pumped

and circulated” to a “heat exchanger,” after which the cooled fluid is “pumped back through the

immersion tank.” And as shown in the videos below, the coolant rises through the computers, exits

the computers, and flows through the coolant outlet:


See Private Facility Tour Video.


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See Corsicana Phase 1 Progress video.


See Riot’s Corsicana Video.

        46.     Riot’s Accused Products also have a coolant outlet that is configured to enable

heated dielectric liquid coolant to flow to the heat exchanger for heat rejection. For example, as

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stated in the October 2021 Press Release, Riot uses tanks to hold “a specialized fluid” that is

“pumped and circulated to assist in dissipating the heat” and “pumped back through the immersion

tank.” See October 2021 Press Release. The heat is dissipated through the heat exchanger sitting

below or to the side of the tank. The coolant outlet connecting to the heat exchanger can be seen

below or to the side of the tank in Riot’s videos:


See Private Facility Tour Video.


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See Corsicana Phase 1 Progress video.


See Riot’s Corsicana Video.


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        47.      In Riot’s Accused Products, the heat exchanger is configured to enable cooled

dielectric coolant to flow to the coolant inlet. For example, after the heat exchanger rejects heat

from the coolant to create cooled coolant, the cooled coolant flows from the heat exchanger to the

coolant inlet as can be seen in Riot’s videos above. See id. In addition, as stated in the October

2021 Press Release, Riot uses tanks to hold “a specialized fluid” that is “pumped and circulated to

assist in dissipating the heat” and “pumped back through the immersion tank.” See October 2021

Press Release.

        48.      In Riot’s Accused Products, the tanks are configured to enable a removal of a

computer of the plurality of computers without a need to remove any other computer of the

plurality of computers from the at least one tank. For example, the tanks are configured to enable

the servers to be independently movable (and thus removable) as shown in the videos below.

Multiple servers are installed in each tank, and one may be removed while the others remain in

place as shown in the videos below:


See 700 MW Bitcoin Mining Facility Video.

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See Riot’s Corsicana Video.


See Behind the Infrastructure Video, YouTube (Sept. 17, 2024), https://www.youtube.com/

watch?v=8ehOVCpAFlY [hereinafter Behind the Infrastructure Video].


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See id.

          49.   In Riot’s Accused Products, the tanks comprise open tops configured to enable

access to each of the plurality of computers as described in claim 2. This can be seen in the pictures

and videos already discussed in the prior paragraphs.

          50.   In Riot’s Accused Products, a flow of the dielectric liquid coolant between the

plurality of computers is restricted, thereby enhancing the flow of the dielectric liquid coolant

through the plurality of computers. For example, as shown in Riot’s videos, the plenum through

which the dielectric liquid coolant flows performs this action consistent with the description in

claim 3:


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See 700 MW Bitcoin Mining Facility Video.

        51.     Riot’s Accused Products also include a plurality of computers that are oriented

vertically as discussed in claim 10. This vertical orientation can be seen below:


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See 700 MW Bitcoin Mining Facility Video.


See Corsicana Phase 1 Progress Video.


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See Riot’s Corsicana Video.

        52.     Riot’s Accused Products also allow for heat to be transferred from the plurality of

computers to the dielectric liquid coolant without piping going through the plurality of computers

as discussed in claim 11. This can be seen in the videos and pictures discussed above.

        53.     Riot’s Accused Products also allow for at least a portion of the dielectric liquid

coolant to flow from a bottom of the at least one tank to the open top as discussed in claim 12.

This can be seen in the videos and pictures discussed above.

        54.     Riot has infringed and is infringing, individually and/or jointly, either literally or

under the doctrine of equivalents, at least claims 1-3, 6, and 10-12 of the 853 Patent in violation

of 35 U.S.C. §§ 271, et seq., directly and/or indirectly, by making, using, offering for sale, selling,

offering for lease, or leasing in the United States, and/or importing into the United States without

authority or license, the Accused Products as explained above. See also Riot 2023 10-K at 41 (Riot

“generate[s] engineering and construction services revenue from the fabrication and deployment

of immersion cooling technology for Bitcoin mining customers”). Riot Platforms, Inc. is also

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vicariously liable for the infringing conduct of its subsidiaries Whinstone US, Inc. and Riot

Corsicana, LLC (collectively the “Subsidiaries”) under both the alter ego and agency theories

because, as an example and on information and belief, Riot Platforms, Inc. has the right and ability

to control its Subsidiaries’ infringing acts and/or use of the Accused Products; Riot Platforms, Inc.

directs its Subsidiaries to perform the infringing acts and/or use the Accused Products; Riot

Platforms, Inc.’s Subsidiaries act as Riot Platforms, Inc.’s agents in putting the Accused Products

to use; and Riot Platforms, Inc. receives a direct financial benefit from the Subsidiaries’

infringement. See CloudofChange, LLC v. NCR Corp., 123 F.4th 1333 (Fed. Cir. 2024); Centillion

Data Sys. LLC v. Qwest Communications Int’l Inc., 631 F.3d 1279, 1284 (Fed. Cir. 2011); see also

Acceleration Bay LLC v. 2K Sports, Inc., 15 F.4th 1069, 1074 (Fed. Cir. 2021).

        55.     Riot has been, and currently is, an active inducer of infringement of at least claims

1-3, 6, and 10-12 of the 853 Patent under 35 U.S.C. § 271(b). Direct infringement is the result of

activities performed by the Subsidiaries, third party mining companies, or suppliers of the Accused

Products as detailed above. Riot Platforms, Inc., Riot Corsicana, LLC, and Whinstone US, Inc. are

therefore jointly and severally liable for all general damages.

        56.     On information and belief, Riot has and continues to induce infringement of the

853 Patent by actively and knowingly inducing others (including each other) to make, have made,

use, sell, or offer for sale in the United States, or import into the United States the infringing

immersion cooling systems or components that embody or use the inventions claimed in at least

claims 1-3, 6, and 10-12 of the 853 Patent. Riot has done so at least by providing directions,

designs, and/or instructions to the Subsidiaries and/or third-party mining companies to make or

use immersion cooling systems or components that are involved in the Accused Products. See id.

(“[w]e provide energized space and operating and maintenance services to third-party mining


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companies who locate their mining hardware at our Rockdale Facility”). Riot has also done so at

least by providing directions, designs, and/or instructions to the Subsidiaries and/or suppliers to

make immersion cooling systems or components that are involved in the Accused Products. See

id. Riot performed the acts that constitute induced infringement, and would induce actual

infringement, with the knowledge of the 853 Patent and with the knowledge or willful blindness

that the induced acts would constitute infringement.

        57.     On information and belief, Riot has knowledge of the 853 Patent. Riot has litigated

against GRC in a prior case where family members of the ’853 Patent were in dispute. During that

case and at least as early as September 8, 2025, GRC’s expert discussed the applicability of the

then-pending 853 Patent to immersion cooling systems, including those owned and operated by

Riot. Finally, should Riot contend that it did not have knowledge of the 853 Patent, this Complaint

will serve as notice.

        58.     Allegations of Riot’s knowledge of the 853 Patent and willful infringement will

likely have additional evidentiary support after a reasonable opportunity for discovery.

        59.     Riot’s infringement of the 853 Patent is willful and deliberate, entitling GRC to

enhanced damages and attorneys’ fees.

        60.     Riot’s infringement of the 853 Patent is exceptional and entitles GRC to attorneys’

fees and costs incurred in prosecuting this action under 35 U.S.C. § 285.

        61.     GRC has been damaged by Riot’s infringement of the 853 Patent and will continue

to be damaged unless Riot is enjoined by this Court. GRC has suffered and continues to suffer

irreparable injury for which there is no adequate remedy at law. The balance of hardships favors

GRC, and public interest is not disserved by an injunction.


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         62.    GRC is entitled to recover from Riot all damages that GRC has sustained as a result

of Riot’s infringement of the 853 Patent, including without limitation, lost profits and/or not less

than a reasonable royalty.

                                          JURY DEMAND

         Pursuant to Rule 38 of the Federal Rules of Civil Procedure, GRC respectfully requests a

trial by jury of any issues so triable by right.

                                      PRAYER FOR RELIEF

         Wherefore, GRC respectfully requests that this Court enter judgment in its favor and

against Riot and respectfully requests the following relief:

         1.     A judgment that Riot infringed and continues to infringe the 853 Patent;

         2.     A judgment and order requiring Riot to pay GRC’s monetary damages sufficient to

compensate GRC for Riot’s infringement of the 853 Patent, but in no event less than a reasonable

royalty under 35 U.S.C. § 284;

         3.     An award of enhanced damages pursuant to 35 U.S.C. § 284;

         4.     An award of treble damages for willful infringement;

         5.     A judgment and order requiring Riot to pay GRC’s pre-judgment and post-

judgment interest on the damages award, to the full extent allowed under the law, as well as its

costs;

         6.     A judgment and order finding this to be an exceptional case under 35 U.S.C. § 285

and requiring Riot to pay costs of this action and attorneys’ fees;

         7.     A permanent injunction against all Riot products found to infringe the 853 Patent;

         8.     In lieu of an injunction, an award of a compulsory forward royalty;

         9.     An order for an accounting of damages; and


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        10.     An award of such further relief as the Court may deem appropriate and just under

the circumstances.


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 Dated: June 3, 2026                Respectfully submitted,

                                     GREENBERG TRAURIG, LLP

                                     By: /s/ Ashley N. Moore
                                     Ashley N. Moore
                                     Texas Bar No. 24074748
                                     Phillip M. Aurentz
                                     Texas Bar No. 24059404
                                     Zachary H. Ellis
                                     Texas Bar No. 24122606
                                     GREENBERG TRAURIG, LLP.
                                     2200 Ross Avenue
                                     Suite 5200
                                     Dallas, Texas 75202
                                     214-665-3600 – Phone
                                     214-665-3601 – Fax
                                     [email protected]
                                     [email protected]
                                     [email protected]

                                     Jonathan Presvelis (pro hac vice forthcoming)
                                     [email protected]
                                     One Vanderbilt Avenue
                                     New York, NY 10017

                                    ATTORNEYS FOR PLAINTIFF
                                    GREEN REVOLUTION COOLING, INC.


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