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- ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 2 of 42 PageID 2 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 2 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 3 of 42 PageID 3 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. 3 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 4 of 42 PageID 4 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, 4 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 5 of 42 PageID 5 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 5 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 6 of 42 PageID 6 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. 6 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 7 of 42 PageID 7 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. 7 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 8 of 42 PageID 8 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 8 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 9 of 42 PageID 9 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 9 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 10 of 42 PageID 10 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 10 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 11 of 42 PageID 11 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 11 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 12 of 42 PageID 12 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. 12 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 13 of 42 PageID 13 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 13 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 14 of 42 PageID 14 “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: 14 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 15 of 42 PageID 15 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 15 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 16 of 42 PageID 16 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: 16 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 17 of 42 PageID 17 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]. 17 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 18 of 42 PageID 18 See Riot’s Corsicana Video (https://www.youtube.com/watch?v=0BvJwTMsG2k&list= PLC8ND4e27bHJXv5qTGpqrnjjLJ8LR2I3V&index=3). 18 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 19 of 42 PageID 19 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. 19 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 20 of 42 PageID 20 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. 20 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 21 of 42 PageID 21 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: 21 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 22 of 42 PageID 22 See Private Facility Tour Video. See Riot’s Corsicana Video. 22 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 23 of 42 PageID 23 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: 23 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 24 of 42 PageID 24 See 700 MW Bitcoin Mining Facility Video. 24 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 25 of 42 PageID 25 See Private Facility Tour Video. See Corsicana Phase 1 Progress video. 25 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 26 of 42 PageID 26 See Riot’s Corsicana Video. See id. 26 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 27 of 42 PageID 27 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. 27 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 28 of 42 PageID 28 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. 28 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 29 of 42 PageID 29 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 29 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 30 of 42 PageID 30 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. 30 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 31 of 42 PageID 31 See Corsicana Phase 1 Progress video. See Riot’s Corsicana Video. 31 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 32 of 42 PageID 32 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. 32 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 33 of 42 PageID 33 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]. 33 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 34 of 42 PageID 34 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: 34 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 35 of 42 PageID 35 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: 35 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 36 of 42 PageID 36 See 700 MW Bitcoin Mining Facility Video. See Corsicana Phase 1 Progress Video. 36 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 37 of 42 PageID 37 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 37 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 38 of 42 PageID 38 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 38 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 39 of 42 PageID 39 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. 39 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 40 of 42 PageID 40 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 40 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 41 of 42 PageID 41 10. An award of such further relief as the Court may deem appropriate and just under the circumstances. 41 ACTIVE 724210304v2 Case 3:26-cv-01842-E Document 1 Filed 06/03/26 Page 42 of 42 PageID 42 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 Ashley.Moore@gtlaw.com Phillip.Aurentz@gtlaw.com Zak.Ellis@gtlaw.com Jonathan Presvelis (pro hac vice forthcoming) presvelisj@gtlaw.com One Vanderbilt Avenue New York, NY 10017 ATTORNEYS FOR PLAINTIFF GREEN REVOLUTION COOLING, INC. 42 ACTIVE 724210304v2