{"cached_at":"2026-10-16T09:51:45.220785+00:00","cl_docket_id":"73438267","docket":{"resource_uri":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","id":73438267,"court":"https://www.courtlistener.com/api/rest/v4/courts/txnd/","court_id":"txnd","original_court_info":null,"idb_data":null,"clusters":[],"audio_files":[],"assigned_to":"https://www.courtlistener.com/api/rest/v4/people/14421/","referred_to":null,"bankruptcy_information":null,"absolute_url":"/docket/73438267/green-revolution-cooling-inc-v-riot-platforms-inc/","date_created":"2026-06-03T19:30:58.505125-07:00","date_modified":"2026-10-06T15:10:28.091316-07:00","source":1,"appeal_from_str":"","assigned_to_str":"Ada Brown","referred_to_str":"","panel_str":"","date_last_index":null,"date_cert_granted":null,"date_cert_denied":null,"date_argued":null,"date_reargued":null,"date_reargument_denied":null,"date_filed":"2026-06-03","date_terminated":null,"date_last_filing":"2026-10-06","case_name_short":"","case_name":"Green Revolution Cooling Inc v. Riot Platforms Inc","case_name_full":"","slug":"green-revolution-cooling-inc-v-riot-platforms-inc","docket_number":"3:26-cv-01842","docket_number_core":"2601842","docket_number_raw":"3:26-cv-01842","docket_number_source":0,"federal_dn_office_code":"3","federal_dn_case_type":"cv","federal_dn_judge_initials_assigned":"E","federal_dn_judge_initials_referred":"","federal_defendant_number":null,"pacer_case_id":"420903","cause":"","nature_of_suit":"","jury_demand":"","jurisdiction_type":"","appellate_fee_status":"","appellate_case_type_information":"","mdl_status":"","filepath_ia":"","filepath_ia_json":"","ia_upload_failure_count":null,"ia_needs_upload":true,"ia_date_first_change":"2026-06-03T19:30:58.459788-07:00","date_blocked":null,"blocked":false,"appeal_from":null,"parent_docket":null,"tags":[],"panel":[]},"parties":[],"entries":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/480720318/","id":480720318,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/496433839/","id":496433839,"tags":[],"absolute_url":"/docket/73438267/21/green-revolution-cooling-inc-v-riot-platforms-inc/","date_created":"2026-10-06T15:10:28.213540-07:00","date_modified":"2026-10-06T15:10:28.231758-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"21","attachment_number":null,"pacer_doc_id":"177019041787","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order Reassigning Case","acms_document_guid":""}],"date_created":"2026-10-06T15:10:28.190152-07:00","date_modified":"2026-10-06T15:10:28.197063-07:00","date_filed":"2026-10-06","time_filed":"16:49:44","entry_number":21,"recap_sequence_number":"2026-10-06.001","pacer_sequence_number":81,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/479139344/","id":479139344,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/494782252/","id":494782252,"tags":[],"absolute_url":"/docket/73438267/20/green-revolution-cooling-inc-v-riot-platforms-inc/","date_created":"2026-09-23T13:15:30.251413-07:00","date_modified":"2026-09-23T13:15:30.264073-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"20","attachment_number":null,"pacer_doc_id":"177018996906","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order for Scheduling Order Proposal","acms_document_guid":""}],"date_created":"2026-09-23T13:15:30.216168-07:00","date_modified":"2026-09-23T13:15:30.224435-07:00","date_filed":"2026-09-23","time_filed":"14:27:55","entry_number":20,"recap_sequence_number":"2026-09-23.001","pacer_sequence_number":79,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/477217159/","id":477217159,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/492805765/","id":492805765,"tags":[],"absolute_url":"/docket/73438267/19/green-revolution-cooling-inc-v-riot-platforms-inc/","date_created":"2026-09-08T10:36:33.413256-07:00","date_modified":"2026-09-08T10:36:33.419806-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"19","attachment_number":null,"pacer_doc_id":"177018945314","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Answer to Counterclaim","acms_document_guid":""}],"date_created":"2026-09-08T10:36:33.389832-07:00","date_modified":"2026-09-08T10:36:33.396802-07:00","date_filed":"2026-09-08","time_filed":"12:09:04","entry_number":19,"recap_sequence_number":"2026-09-08.001","pacer_sequence_number":71,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/476096139/","id":476096139,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/491648593/","id":491648593,"tags":[],"absolute_url":"/docket/73438267/17/green-revolution-cooling-inc-v-riot-platforms-inc/","date_created":"2026-08-27T16:08:27.068292-07:00","date_modified":"2026-08-27T16:08:27.081061-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"17","attachment_number":null,"pacer_doc_id":"177018915402","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Answer to Complaint AND Counterclaim","acms_document_guid":""}],"date_created":"2026-08-27T16:08:27.050138-07:00","date_modified":"2026-08-27T16:08:27.053956-07:00","date_filed":"2026-08-27","time_filed":"17:11:23","entry_number":17,"recap_sequence_number":"2026-08-27.001","pacer_sequence_number":52,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/472519535/","id":472519535,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487956701/","id":487956701,"tags":[],"absolute_url":"","date_created":"2026-07-29T10:10:09.368930-07:00","date_modified":"2026-07-29T10:10:09.368945-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Motion for Extension of Time","acms_document_guid":""}],"date_created":"2026-07-29T10:10:09.360588-07:00","date_modified":"2026-07-29T10:10:09.360600-07:00","date_filed":"2026-07-29","time_filed":"11:08:52","entry_number":null,"recap_sequence_number":"2026-07-29.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466627211/","id":466627211,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/481871126/","id":481871126,"tags":[],"absolute_url":"","date_created":"2026-06-08T07:07:16.286160-07:00","date_modified":"2026-06-08T07:07:16.291245-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Application for Admission Pro Hac Vice","acms_document_guid":""}],"date_created":"2026-06-08T07:07:16.273726-07:00","date_modified":"2026-06-08T07:07:16.273741-07:00","date_filed":"2026-06-08","time_filed":"08:33:54","entry_number":null,"recap_sequence_number":"2026-06-08.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466233567/","id":466233567,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73438267/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/481467562/","id":481467562,"tags":[],"absolute_url":"/docket/73438267/1/green-revolution-cooling-inc-v-riot-platforms-inc/","date_created":"2026-06-03T20:16:19.970676-07:00","date_modified":"2026-06-04T14:08:26.568652-07:00","sha1":"5c980698bd2caf107364582d695d8ac10fdddf1c","page_count":42,"file_size":4931599,"filepath_local":"recap/gov.uscourts.txnd.420903/gov.uscourts.txnd.420903.1.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txnd.420903/gov.uscourts.txnd.420903.1.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"  Case 3:26-cv-01842-E          Document 1         Filed 06/03/26       Page 1 of 42    PageID 1\n\n\n\n                        IN THE UNITED STATES DISTRICT COURT\n                        FOR THE NORTHERN DISTRICT OF TEXAS\n                                  DALLAS DIVISION\n\n\n\nGREEN REVOLUTION COOLING, INC.,\n                                                                Civil Action No. 3:26-cv-01842\n                Plaintiff,\n\n        v.\n                                                                JURY TRIAL DEMANDED\nRIOT PLATFORMS, INC., RIOT CORSICANA,\nLLC, AND WHINSTONE US, INC.\n\n                Defendants.\n\n\n                       COMPLAINT FOR PATENT INFRINGEMENT\n\n        Plaintiff Green Revolution Cooling, Inc. (\u0093GRC\u0094 or \u0093Plaintiff\u0094) files this Complaint for\n\nPatent Infringement against Defendants Riot Platforms, Inc.; Riot Corsicana, LLC; and Whinstone\n\nUS, Inc. (collectively \u0093Riot\u0094 or \u0093Defendants\u0094) for infringement of U.S. Patent No. 12,513,853 (the\n\n\u0093 853 Patent\u0094). GRC, on personal knowledge as to its own acts, and on information and belief as\n\nto all others based on its investigation, alleges as follows:\n\n                                 SUMMARY OF THE ACTION\n\n        1.      This is a patent infringement suit relating to Riot\u0092s unauthorized and unlicensed use\n\nof the 853 Patent. GRC\u0092s patented technology supports the core of Riot\u0092s systems, including all\n\nof Riot\u0092s immersion cooling facilities in Texas.\n\n        2.      GRC was founded in 2009 with a vision to change the way data centers are\n\ndesigned, built, and operated. Even back then GRC recognized that data was the lifeblood of\n\nbusinesses big and small. However, as data processing needs increased over time, more powerful\n\n(heat generating) servers were required to process this data. It became increasingly complicated\n\nand expensive for data centers to cool these servers using traditional air cooling. Traditional air-\n\n\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E          Document 1        Filed 06/03/26        Page 2 of 42      PageID 2\n\n\n\ncooling and the conventional solutions (more space and/or more air-cooling capacity) were\n\nbecoming less cost effective, if not impossible. In fact, no matter how good the system, air cooling\n\ncould only carry away so much heat, which meant it would be extremely difficult to effectively air\n\ncool with increasingly powerful, tightly packed servers. Moreover, air cooling equipment already\n\nconsumed almost half of a data center\u0092s energy usage and formed a large portion of a data center\u0092s\n\nbuild-out cost. Creating more space was not practical for the same reasons. Traditional systems\n\nneeded a Computer Room Air Conditioner (\u0093CRAC\u0094), chiller, cooling tower, backup generator,\n\nair-flow engineering (e.g., air ducting), hot/cold aisles, raised or special flooring, and rack rails to\n\ncome online. As a result, these facilities were not easily reengineered or expanded.\n\n        3.      GRC set its sights on solving this problem. The result was groundbreaking: a single-\n\nphase immersion cooling system that works by immersing servers in a liquid coolant. Compared\n\nto air, single-phase immersion systems (when well designed) can cool servers with warm liquid\n\nversus air cooling which typically requires cooling the air down to 50 to 70 F. As a result, GRC\u0092s\n\nimmersion technologies cut lifetime cooling costs by around 85% and used around 95% less\n\ncooling power. In addition to these cost savings, GRC\u0092s innovations reduced the cost, complexity,\n\nand equipment needed to build a data center. Rooms no longer had to be designed for careful\n\nairflow. Backup generators could be 50% smaller as overall power consumption dropped. Server\n\nreliability increased by removing hotspots, allowing more time for disaster recovery, and\n\neliminating fans and related vibration. GRC\u0092s use of dielectric coolant also meant that its systems\n\nrelied on non-toxic fluids that carry 1,200 times more heat by volume than air.\n\n        4.      The industry quickly took notice. GRC was awarded grants from the Department\n\nof Defense and the National Science Foundation. In 2009 and 2010, GRC won back-to-back\n\n\u0093Disruptive Technology of the Year\u0094 awards at the Supercomputing Conference. The NSA also\n\n\n\n                                                   2\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E        Document 1       Filed 06/03/26      Page 3 of 42     PageID 3\n\n\n\npublicly praised GRC\u0092s technology in a rare report. And for over a decade, GRC\u0092s immersion\n\nsystems have supported USAF military operations. More recently, IT giants Dell, Intel, and others\n\nhave come to partner with GRC, whose technologies are currently at work in some of the world\u0092s\n\nlargest cloud, enterprise, education, government, and telecom organizations. GRC\u0092s products have\n\nbeen deployed in the United States, Canada, Costa Rica, the United Kingdom, France, Spain,\n\nSweden, the Netherlands, Austria, Romania, Serbia, Italy, Mali, Uganda, India, Singapore,\n\nVietnam, South Korea, Australia, Taiwan, and Japan. Today GRC\u0092s systems can power the data\n\ncenters behind artificial intelligence, machine learning, edge computing, blockchain, and crypto-\n\nmining with substantial advantages over the competition.\n\n        5.      With success comes copycats and others who seek to capitalize on GRC\u0092s novel\n\napproach to immersion cooling. Riot is one example. Riot is a bitcoin mining company whose\n\n\u0093vision is to be the world\u0092s leading Bitcoin-driven infrastructure platform.\u0094 Riot Platforms FY\n\n2023 Update, Feb. 27, 2024, https://s3.amazonaws.com/b2icontent.irpass.cc/2865/193123.pdf. In\n\n2021, more than a decade after GRC launched its immersion cooling systems, Riot deployed\n\ninfringing immersion cooling technology within its bitcoin mining facilities. Riot announced that\n\nafter only \u0093months of research and development,\u0094 it \u0093pioneer[ed] . . . the use of cutting-edge\n\nimmersion-cooling technology at an unprecedented scale.\u0094 Press Release, Riot Platforms, Riot\n\nAnnounces First Industrial-Scale Immersion-Cooled Bitcoin Mining Operation, Oct. 19, 2021,\n\nhttps://www.riotplatforms.com/riot-announces-first-industrial-scale-immersion-cooled-bitcoin-\n\nmining-operation/ [hereinafter October 2021 Press Release]. Riot has now launched infringing\n\nimmersion-based facilities in both Rockdale and Corsicana, Texas. GRC brings this action to put\n\nan end to Riot\u0092s unauthorized use of GRC\u0092s 853 Patent.\n\n\n\n\n                                               3\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E          Document 1       Filed 06/03/26       Page 4 of 42      PageID 4\n\n\n\n                                             PARTIES\n\n          6.    Plaintiff Green Revolution Cooling, Inc. is a Delaware corporation with its\n\nprincipal place of business at 11525 Stonehollow Drive, Suite A-135, Austin, Texas 78758.\n\n          7.    On information and belief, Defendant Riot Platforms, Inc. is a Nevada company\n\nwith its principal place of business at 3855 Ambrosia Street, Suite 301, Castle Rock, CO 80109.\n\n          8.    On information and belief, Defendant Riot Corsicana, LLC (f/k/a Project Lefty,\n\nLLC) is a Texas company with its principal place of business at 6980 FM 709 S Corsicana, Texas\n\n78759. Riot Corsicana, LLC is a subsidiary of Riot Platforms, Inc., and Riot Platforms, Inc. is the\n\nparent of Riot Corsicana, LLC.\n\n          9.    On information and belief, Defendant Whinstone US, Inc. is a Delaware company\n\nwith its principal place of business at 2721 Charles Martin Hall Rd, Rockdale, Texas 76567.\n\nWhinstone US, Inc. is a wholly-owned subsidiary of Riot Platforms, Inc.\n\n                                 JURISDICTION AND VENUE\n\n          10.   This is an action containing claims for patent infringement arising under the patent\n\nlaws of the United States, Title 35, U.S.C. \u00a7 271. This Court has exclusive subject matter\n\njurisdiction over those claims pursuant to 28 U.S.C. \u00a7\u00a7 1331, 1367, and/or 1338.\n\n          11.   This Court has personal jurisdiction over Riot because it either currently resides in\n\nthe State of Texas, has a regular and established place of business within the State of Texas, has\n\nhad minimum contacts with the State of Texas sufficient to confer the Court with general personal\n\njurisdiction, or has committed acts within the State of Texas giving rise to the claims asserted\n\nherein.\n\n          12.   Riot does extensive business in this Division, District, and State. Upon information\n\nand belief, Riot Platforms, Inc., along with its wholly-owned subsidiary, Riot Corsicana, LLC,\n\n\n\n                                                  4\nACTIVE 724210304v2\n\f     Case 3:26-cv-01842-E      Document 1       Filed 06/03/26       Page 5 of 42      PageID 5\n\n\n\nowns and operates an infringing immersion cooling facility in Navarro County, Texas (the\n\n\u0093Corsicana Facility\u0094) that currently employs immersion cooling. This facility is in Corsicana, TX,\n\nwhich is in the Dallas Division of the Northern District of Texas. Riot states that \u0093[t]he initial\n\nphase of the development of the Corsicana Facility involves the construction of 400 megawatts\n\n(\u0091MW\u0092) of immersion-cooled Bitcoin Mining and Data Center Hosting infrastructure.\u0094 See Riot\n\n2023 10-K at 5. In 2023, Riot \u0093entered into a purchase agreement with Midas for the purchase of\n\n200 MW of immersion cooling systems for its Corsicana Facility.\u0094 Id. at F-25. Delivery of these\n\nsystems \u0093began in the fourth quarter of 2023 and is expected to be completed in the first quarter\n\nof 2024.\u0094 Id. The \u0093400 MW substation [at the Corsicana Facility] is expected to be energized by\n\nthe end of March 2024, and the first 100 MW building, A1, will commence operations immediately\n\nthereafter.\u0094 See Press Release, Riot Platforms, Riot Announces January 2024 Production and\n\nOperations Updates, Feb. 5, 2024, https://www.riotplatforms.com/riot-announces-january-2024-\n\nproduction-and-operations-updates/. On April 18, 2024, Riot announced that the Corsicana\n\nFacility is operational, stating \u0093\u0091[t]wo years ago, we purchased 265 acres of land in Navarro\n\nCounty, Texas, driven by our vision to build the world's largest Bitcoin mining facility, and today,\n\nwe have achieved a new milestone in turning that vision into a reality with the energization of our\n\nCorsicana Facility,\u0092 said Jason Les, CEO of Riot. \u0091This landmark achievement highlights our\n\nteam\u0092s unwavering dedication and collaborative effort over the past two years. With the Corsicana\n\nFacility\u0092s 400-megawatt substation now operational, we remain well on track to increase our self-\n\nmining hash rate capacity to 31 EH/s by the end of 2024, which will represent a significant increase\n\nin     our   operational    capabilities.\u0092\u0094   https://www.marketscreener.com/quote/stock/RIOT-\n\nPLATFORMS-INC-38481086/news/Riot-Energizes-New-Corsicana-Facility-in-Navarro-\n\nCounty-Texas-46468926/. Riot describes the Corsicana Facility as having \u0093400 MW of\n\n\n\n                                                 5\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E          Document 1        Filed 06/03/26     Page 6 of 42      PageID 6\n\n\n\nimmersion-cooling.\u0094 https://www.riotplatforms.com/bitcoin-mining/corsicana/. The following is\n\none building full of immersion cooling units at the Corsicana Facility:\n\n\n\n\nId.\n\n         13.     Riot does further business in Texas. Upon information and belief, Riot Platforms,\n\nInc., along with its wholly-owned subsidiary Whinstone US, Inc. owns and operates an infringing\n\nimmersion cooling facility in Rockdale, Texas. Riot boasts that its \u0093Rockdale Facility\u0094 is \u0093believed\n\nto be the largest single Bitcoin mining facility in North America.\u0094 See Riot Platforms, Inc., Annual\n\nReport         (Form    10-K)      33,     Feb.       23,    2024,        https://s3.amazonaws.com/\n\nsec.irpass.cc/2865/0001558370-24-001550.pdf [hereinafter Riot 2023 10-K]. It \u0093currently\n\nprovides 700 MW in total developed capacity.\u0094 Id. To a \u0093large extent,\u0094 Riot relies on immersion\n\ncooling at the Rockdale Facility. Id. at 21. At least \u0093200 MW [MegaWatts] of capacity across two\n\n[Rockdale] buildings [are] dedicated to immersion-cooled self-mining operations.\u0094 Riot Platforms\n\nCorporate Presentation 5, Dec. 6, 2023, https://d2ghdaxqb194v2.cloudfront.net/2865/192541.pdf.\n\n\n\n                                                  6\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E         Document 1        Filed 06/03/26       Page 7 of 42       PageID 7\n\n\n\nDuring 2023, Riot \u0093paid $31.2 million in deposits and payments to Midas Green Technologies,\n\nLLC . . . for the purpose of immersion cooling systems.\u0094 Riot 2023 10-K at 41.\n\n\n\n\nSee https://www.riotplatforms.com/bitcoin-mining/rockdale/.\n\n        14.     On information and belief, Riot has used, and is using, the claimed technology of\n\nthe 853 Patent within these facilities, thereby committing acts of patent infringement in this\n\nDivision, District, and State. Riot has also derived substantial revenue from these infringing\n\nactivities within this Division, District, and State. As one example, Riot announced 2023 financial\n\nresults of \u0093all-time highs of $281 million in total revenues, 6,626 Bitcoin produced, and $71\n\nmillion in power credits earned . . .\u0094 Press Release, Riot Platforms, Riot Platforms Reports Full\n\nYear 2023 Financial Results, Current Operational and Financial Highlights, Feb. 22, 2024,\n\nhttps://www.riotplatforms.com/riot-platforms-reports-full-year-2023-financial-results-current-\n\noperational-and-financial-highlights/. Riot therefore has a regular and established place of\n\nbusiness within this Division, District, and State; Riot regularly conducts business in this Division,\n\nDistrict, and State; and Riot has committed purposeful acts within this Division, District, and State\n\nsuch that it should reasonably anticipate being haled into this Court.\n\n                                                  7\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E           Document 1      Filed 06/03/26      Page 8 of 42       PageID 8\n\n\n\n        15.     Venue is proper in the Northern District of Texas under 28 U.S.C. \u00a7 1400(b) as Riot\n\nhas a regular and established place of business in this Division and District with its Corsicana\n\nFacility. And, on information and belief, Riot has committed acts of infringement at least at this\n\nlocation and within the State.\n\n                                   FACTUAL ALLEGATIONS\n\n        A. GRC Has a Rich History of Innovation in Immersion Cooling.\n\n        16.     GRC was founded in Austin, Texas and has a long history of innovation in the\n\nimmersion cooling space, spanning nearly 15 years. Around 2009, there were 30 million computer\n\nservers worldwide that used variants of air cooling. Conventional air-cooling systems nearly\n\ndoubled data center energy consumption, required costly capital expenditures and special data\n\ncenter designs, and did not work well for high-density server hardware. This environment typically\n\nrequired chilling water to 10\u00b0C (50\u00b0F) to create an air temperature of 25\u00b0C (77\u00b0F) for use in air\n\ncooling the servers in a data center. Chilling alone added 25-33% to the power consumed by a data\n\ncenter. These facilities also needed fans to circulate the air and, because of layout considerations,\n\nair-cooling often created hotspots and/or vibration that could damage components and reduce data\n\ncenter reliability. Combined, fans and cooling equipment were responsible for roughly 50% of\n\ntotal power draw within a data center.\n\n        17.     GRC co-founder and co-inventor, Christiaan Best, discovered these inefficiencies\n\nin early 2008 while working at a MEMS start-up in the air conditioning field. He and his co-\n\ninventor immediately began brainstorming for solutions to this problem. The result was a new,\n\nimmersion-cooled system that used a safe, non-toxic, single-phase dielectric coolant in which data\n\ncenter components were immersed. GRC filed a patent application on this idea, which matured\n\ninto a patent family that includes the 853 Patent. GRC also began building these systems, and the\n\nfirst incarnation was called the \u0093CarnotJet.\u0094 It efficiently removed heat by fully submersing a data\n\n                                                 8\nACTIVE 724210304v2\n\f  Case 3:26-cv-01842-E         Document 1       Filed 06/03/26      Page 9 of 42      PageID 9\n\n\n\ncenter\u0092s computer components in a single-phase dielectric coolant, with innovative hardware\n\narchitecture, system design, and control software to optimize performance and reliability. GRC\u0092s\n\nCarnotJet system featured a horizontal rack that allowed data center technicians to easily remove\n\nor swap servers while the remainder of the system continued to function. And because the dielectric\n\ncoolant was safe for humans, the racks did not have to be sealed and no special considerations\n\nwere needed to handle or interact with submersed servers. In recognition of these achievements,\n\nGRC won \u0093Disruptive Technology of the Year\u0094 in 2009 and 2010.\n\n        18.     One of the first to implement GRC\u0092s then patent-pending technology in a live data\n\ncenter was Texas Advanced Computing Center (\u0093TACC\u0094) in April 2010. The results were\n\nastounding. GRC\u0092s systems allowed TACC to consume 40% less total energy. This demonstration\n\nalso showed that GRC\u0092s systems could perform even for top supercomputing sites, like that of\n\nTACC. Swiss National Supercomputing followed suit in December 2010. Both installations\n\nexhibited 100% uptime and consumed 95% less cooling energy compared to standard air-cooled\n\nsystems.\n\n        19.     Since that time, many customers and partners have come to see the benefits of this\n\ntechnology for themselves. Between 2012 and 2013, the U.S. Air Force, Intel, the NSA, Vienna\n\nScientific Cluster, Tokyo Institute of Technology, and other leading names in computing came on\n\nboard. In June 2013, GRC released a containerized version of its systems for the Department of\n\nDefense. In 2015, GRC installed its technologies at Port d\u0092Informacio Cientifica (\u0093PIC\u0094), which\n\nsupports data processing for CERN\u0092s Large Hadron Collider. And by 2019, GRC had entered\n\npartnerships with Hewlett Packard Enterprise, Dell, and other global partners. In short, GRC\u0092s\n\nsystems support some of the largest computing installations around the world, including those in\n\nthe United States, Canada, Costa Rica, the United Kingdom, France, Spain, Sweden, the\n\n\n\n                                                9\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26       Page 10 of 42       PageID 10\n\n\n\nNetherlands, Austria, Romania, Serbia, Italy, Mali, Uganda, India, Singapore, Vietnam, South\n\nKorea, Australia, Taiwan, and Japan.\n\n        20.     Today, GRC continues to innovate. It has over two dozen patents and applications\n\nthat protect its technologies. GRC has also unveiled several products, including the ICEraQ series.\n\nThese products include the basic principles on which GRC was founded\u0097immersion cooling with\n\nsafe coolants, along with additional features that are cost effective, scalable, resilient, and future-\n\nproof. These products can handle the extreme heat load of the newest generations of servers behind\n\nbleeding-edge technologies like artificial intelligence, machine learning, blockchain, and crypto-\n\nmining.\n\n        B. Riot Implemented, and Improperly Benefits From, GRC\u0092s Patented Technology.\n\n        21.     In May 2021, Riot acquired Whinstone, which had a 300 MW Bitcoin mining\n\ninfrastructure in Rockdale, Texas. \u0093Immediately following the acquisition, Riot announced a 400\n\nMW expansion\u0094 of the facility to be completed by Q2 2022. Press Release, Riot Platforms, Riot\n\nBlockchain Announces Investor Site Tour, Sept. 29, 2021, https://www.riotplatforms.com/riot-\n\nblockchain-announces-investor-site-tour/. About 200 MW of that expansion would be\n\n\u0093immersion-cooling technology at [] Whinstone,\u0094 which has since been renamed the Rockdale\n\nFacility. See October 2021 Press Release.\n\n        22.     Riot\u0092s plan was to \u0093leverag[e] technology, industry-leading low power costs, and\n\neconomies of scale\u0094 to drive \u0093operating and capital efficiencies for its self-mining business and its\n\ninstitutional clients.\u0094 Id. This technology would also allow Riot to observe \u0093an increase in the\n\nCompany\u0092s hash rate and productivity\u0094 without \u0093having to rely solely on purchasing additional\n\nASICs\u0094 Id. In fact, Riot expected \u0093an estimated 25% increase in hash rate\u0094 and a 50% \u0093increase\n\n[in] ASIC performance.\u0094 Id. Riot\u0092s first immersion-cooled building came online in May 2022.\n\nPress Release, Riot Platforms, Riot Blockchain Announces July 2022 Production and Operations\n\n                                                  10\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26      Page 11 of 42       PageID 11\n\n\n\nUpdates, Aug. 3, 2022, https://www.riotplatforms.com/riot-blockchain-announces-july-2022-\n\nproduction-and-operations-updates/.\n\n        23.     As part of this plan, Riot set out to expand its Texas footprint. By early 2023, Riot\n\nhad completed expansion of its Rockdale Facility, which it \u0093believed to be the largest single\n\nBitcoin mining facility in North America.\u0094 See Riot 2023 10-K at 33. At least \u0093200 MW of capacity\n\nacross two [Rockdale] buildings [are] dedicated to immersion-cooled self-mining operations.\u0094\n\nRiot Platforms Corporate Presentation at 5.\n\n        24.     And by October 2022, Riot \u0093ha[d] officially broken ground at [its] 1 gigawatt\n\n(\u0091GW\u0092) expansion project (\u0091the Corsicana Facility\u0092) in Corsicana, Navarro County, Texas.\u0094 Press\n\nRelease, Riot Platforms, Riot Announces Groundbreaking at 1 GW Data Center Facility in\n\nCorsicana, Navarro County, Texas, Oct. 19, 2022, https://www.riotplatforms.com/riot-announces-\n\ngroundbreaking-at-1-gw-data-center-facility-in-corsicana-navarro-county-texas/. \u0093The first phase\n\nof the Corsicana Facility\u0092s development is expected to consist of four 100 MW buildings utilizing\n\nimmersion cooling technology similar to what is already in place at Riot\u0092s Rockdale Facility.\u0094 Id.\n\n        25.     Since 2024, the Corsicana Facility has moved from initial development to active,\n\nlarge scale operations and continued expansion. In April 2024, Riot announced that it had\n\n\u0093successfully energized the substation\u0094 at the Corsicana Facility and that \u0093miners [were] now\n\nhashing,\u0094 with the initial 400 megawatt phase placed into operation and additional buildings\n\nscheduled to come online throughout 2024. Riot further represented on its website and through\n\npress releases that the Corsicana Facility\u0097consisting of approximately 400 MW of\n\nimmersion cooled Bitcoin mining infrastructure\u0097was completed or substantially deployed by\n\nyear end 2024, and that the site is designed to scale to approximately 1 gigawatt of total capacity.\n\nRiot has continued to describe the Corsicana Facility as a long term asset, emphasizing its role in\n\n\n\n                                                 11\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1       Filed 06/03/26        Page 12 of 42     PageID 12\n\n\n\nexpanding Riot\u0092s mining operations and supporting future growth initiatives, including additional\n\ndata center and high performance computing uses, thereby confirming the ongoing, large scale,\n\nand permanent nature of Riot\u0092s operations at the Corsicana Facility.\n\n         26.    In its 10-K for fiscal year 2025 dated March 2, 2026, Riot stated that \u0093[d]uring the\n\nyear ended December 31, 2025, we continued development activities at the Corsicana Facility and\n\ndeployed miners at all our Facilities, with the objective of increasing our operational efficiency\n\nand performance in the future. As of December 31, 2025, we had a total deployed hash rate\n\ncapacity of 38.5 EH/s, as compared to 31.5 EH/s as of December 31, 2024, an increase of 22.1%.\u0094\n\nRiot further stated that \u0093[w]e are increasingly dependent on immersion-cooling technology for our\n\nBitcoin Mining operations, to a large extent at the Rockdale Facility, and exclusively at the\n\nCorsicana Facility.\u0094 See Riot Platforms, Inc., Annual Report (Form 10-K) 27 and 46, Mar. 2, 2026,\n\nhttps://s3.amazonaws.com/ sec.irpass.cc/2865/0001558370-24-001550.pdf [hereinafter Riot 2025\n\n10-K].\n\n         27.    On information and belief, Riot has used, and is using, the claimed technology of\n\nthe 853 Patent within these facilities, thereby committing acts of patent infringement. Riot has\n\nalso derived substantial revenue from these infringing activities.\n\n         28.    For example, \u0093[f]or the year ended December 31, 2025, Bitcoin Mining revenue\n\nwas approximately $576.3 million.\u0094 See Riot 2025 10-K at 46.\n\n                     COUNT 1: INFRINGEMENT OF PATENT NO. 12,513,853\n\n         29.    GRC incorporates by reference the preceding paragraphs, as if set forth herein.\n\n         30.    GRC\u0092s immersion cooling technologies are protected by various patents including\n\nthe 853 Patent asserted here.\n\n         31.    The 853 Patent is valid and enforceable under United States Patent Laws.\n\n\n\n                                                 12\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26       Page 13 of 42       PageID 13\n\n\n\n        32.     GRC owns, by assignment, all right, title, and interest in and to the 853 Patent,\n\nincluding the right to collect for past damages.\n\n        33.     A copy of the 853 Patent is attached as Exhibit A.\n\n        A. The 853 Patent\n\n        34.     The 853 Patent is entitled \u0093Liquid Submerged, Horizontal Computer Server Rack\n\nAnd Systems And Methods Of Cooling Such A Server Rack.\u0094 It was filed on July 10, 2025, and\n\nclaims priority to: U.S. Patent Application No. 13/057,881 filed on August 10, 2009; U.S.\n\nProvisional Application No. 61/188,589 filed on August 11, 2008; U.S. Provisional Application\n\nNo. 61/163,443 filed on March 25, 2009; and U.S. Provisional Application No. 61/165,470 filed\n\non March 31, 2009. The U.S. Patent and Trademark Office issued the 853 Patent on December\n\n30, 2025, to Green Revolution Cooling, Inc., listing Christiaan Best and Mark Garnett as co-\n\ninventors.\n\n        35.     Prior to the inventions described in the 853 Patent, data centers typically relied on\n\nair cooling. Ex. A at 1:66-2:7. Air cooling uses \u0093vents that allow external air to flow\u0094 into the data\n\ncenter, and to its server components, by a fan. Id. at 2:2-8. Air in a data center \u0093usually passe[d]\n\nthrough a heat exchanger for cooling the air . . . before entering a server.\u0094 Id. at 2:16-20. \u0093In some\n\ndata centers, [a] heat exchanger [was] . . . mounted to [a] rack to provide \u0091rack-level\u0092 cooling of\n\nair before the air enter[ed] a server.\u0094 Id. at 2:20-23. In other installations, \u0093the air [was] cooled\n\nbefore entering the data center.\u0094 Id. at 2:23-24. Such designs accounted for \u0093[m]ore than one-third\n\nof data center electricity consumption . . ., which could equate to more than about 1% of all U.S.\n\nelectricity consumed by 2011.\u0094 Id. at 1:41-44. Thus, the \u0093overall cost of cooling [was] a large and\n\ngrowing part of the total cost of operating a data center.\u0094 Id. at 1:44-48.\n\n        36.     In addition, because \u0093spacing heat-dissipating components from each other (e.g.,\n\nreducing heat density) makes cooling such components less difficult,\u0094 conventional data centers\n\n                                                   13\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26       Page 14 of 42      PageID 14\n\n\n\n\u0093compensated for increased power dissipation (corresponding to increased server performance) by\n\nincreasing the spacing between adjacent servers.\u0094 Id. at 2:55-57, 2:61-64. Consequently, even\n\nsome \u0093state-of-the-art data centers are capable of cooling only about 150 Watts-per square- foot,\n\nas opposed to cooling the more than about 1,200 Watts-per-square-foot that could result from\n\narranging servers to more fully utilize available volume (e.g., closely spacing servers and racks to\n\nmore fully utilize floor-to ceiling height and floor space).\u0094 Id. at 3:18-24.\n\n        37.     The co-inventors therefore recognized the \u0093need for an effective, efficient and low-\n\ncost cooling alternative for cooling electronic components,\u0094 especially since \u0093commercially\n\navailable methods of cooling have not kept pace with increasing server and data-center\n\nperformance needs, or the corresponding growth in heat density.\u0094 Id. at 3:28-31, 4:33-35.\n\n        38.     To address this, the 853 Patent \u0093provides novel apparatus, systems, and methods\n\nfor efficiently cooling computing devices having heat-generating electronic components.\u0094 Id. at\n\n4:39-41. In one embodiment, the 853 Patent describes systems that hold and cool servers that have\n\nheat producing electronic components. See, e.g., id. at 10:6-21. These systems include \u0093a tub or\n\ntank [] containing a dielectric liquid coolant into which a plurality of servers [] may be immersed.\u0094\n\nId. at 10:24-26; see also id. at 13:16-18. An exemplary illustration of the 853 system embodiments\n\nis shown below:\n\n\n\n\n                                                 14\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26       Page 15 of 42       PageID 15\n\n\n\n\nId. at Figure 11.\n\n        39.     As the servers generate heat through their operation, the liquid coolant also\n\nbecomes heated. Id. at 10:37-42. In one embodiment, a pump \u0093may pump liquid coolant from [an]\n\nexternal heat exchanger through the piping system into the tank [] to maintain coolant fluid\n\ncirculation within the tank.\u0094 Id. at 15:17-20. In some configurations, the \u0093liquid coolant heated by\n\nthe heat generating components in the servers [] naturally rise[s] through the servers and exit[s]\n\nthrough the top or \u0091front panel\u0092 of the servers.\u0094 Id. at 15:26-28. In other embodiments the piping\n\n\u0093may be reversed such that the heated liquid coolant may exit from the installed servers through\n\nits \u0091rear panel.\u0092\u0094 Id. at 15:36-38. The liquid coolant may then be \u0093fluidly coupled through suitable\n\npiping or lines to a pump [], which pumps the heated liquid coolant through suitable piping or lines\n\nto a remotely or distally located heat exchanger.\u0094 Id. at 10:36-41; see also id. at 13:45-50. The heat\n\nexchanger \u0093rejects the heat from the incoming heated liquid coolant and fluidly couples the cooled\n\nliquid coolant through a return fluid line or piping [] back into the tank.\u0094 Id. at 10:42-46; see also\n\nid. at 13:29-46. The tank therefore may be \u0093fabricated to have an inlet pipe or line [] from a piping\n\n                                                 15\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1       Filed 06/03/26       Page 16 of 42       PageID 16\n\n\n\nsystem connected to a heat exchanger for the flow of lower temperature or cooled liquid coolant\n\ninto the tank [] and an outlet pipe or line [] connected to the collection piping for the flowing or\n\npumping of heated coolant out of the tank to the external heat exchanger . . .\u0094 Id. at 14:48-53.\n\n        B. 853 Patent Allegations\n\n        40.     Upon information and belief after reasonable investigation, the immersion-cooled\n\nportions of Riot\u0092s Rockdale and Corsicana Facilities (the \u0093Accused Products\u0094) infringe the 853\n\nPatent. As one example, Riot uses a system comprising at least one tank, a coolant inlet, a coolant\n\noutlet, a dielectric liquid coolant, a heat exchanger, a pump, and a plurality of computers according\n\nto claim 1. For example, Riot\u0092s Accused Products use immersion-cooled bitcoin mining\n\ninfrastructure where bitcoin mining ASICs are submerged in a specialized fluid to keep the ASICs\u0092\n\nintegrated circuits operating at lower temperatures. See October 2021 Press Release (explaining\n\nRiot\u0092s use of immersion cooling); see also Chad Everett Harris, Riot Blockchain\u0092s 700 MW\n\nBitcoin Mining Facility \u0096 200MW Industrial-scale Immersion System, YouTube (Jan. 18, 2022),\n\nhttps://www.youtube.com/watch?v=aQ3o_QDTYV4 [hereinafter 700 MW Bitcoin Mining\n\nFacility Video] (video showing Riot\u0092s use of immersion cooling system). The tank, coolant inlet,\n\ncoolant outlet, dielectric liquid coolant, heat exchanger, pump, and plurality of computers can be\n\nseen in Riot\u0092s videos as shown below:\n\n\n\n\n                                                 16\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E       Document 1      Filed 06/03/26    Page 17 of 42    PageID 17\n\n\n\n\nSee Jimmy is Promo, Private Tour of Riot\u0092s MASSIVE Whinstone Bitcoin Mining Facility &\n\nExclusive Interview with the CEOs, YouTube (Mar. 3, 2022), https://www.youtube.com/ watch?\n\nv=La7vMl1txCU [hereinafter Private Facility Tour Video].\n\n\n\n\n                                            17\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E     Document 1     Filed 06/03/26   Page 18 of 42    PageID 18\n\n\n\n\nSee Riot\u0092s Corsicana Video (https://www.youtube.com/watch?v=0BvJwTMsG2k&list=\n\nPLC8ND4e27bHJXv5qTGpqrnjjLJ8LR2I3V&index=3).\n\n\n\n\n                                         18\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26      Page 19 of 42       PageID 19\n\n\n\n\nSee id.\n\n          41.   Riot\u0092s Accused Products use a tank that includes at least a portion of the dielectric\n\nliquid coolant. For example, Riot\u0092s Accused Products use a tank that contains dielectric coolant,\n\nas shown below:\n\n\n\n\nSee id; see also 700 MW Bitcoin Mining Facility Video; Private Facility Tour Video.\n\n\n\n\n                                                 19\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1      Filed 06/03/26   Page 20 of 42    PageID 20\n\n\n\n\nSee       Corsicana   Phase    1   Progress      video,   YouTube    (Sept.    24,   2024),\n\nhttps://www.youtube.com/watch?v=nCn_LclP7uk [hereinafter Corsicana Phase 1 Progress\n\nVideo].\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n\n                                               20\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E         Document 1       Filed 06/03/26       Page 21 of 42      PageID 21\n\n\n\n\nSee id.\n\n          42.   Riot\u0092s Accused Products also include a plurality of computers where at least\n\nportions of the computers are completely submerged within the dielectric liquid coolant. For\n\nexample, Riot has stated that its \u0093[b]itcoin [m]ining activities require large volumes of a\n\nspecialized non-conductive fluid.\u0094 See Riot 2023 10-K at 8. According to the October 2021 Press\n\nRelease, this fluid is what is pumped into the tank. Riot also describes its \u0093[p]rocess of\n\n[i]mmersion-[c]ooling as \u0093a technique where Bitcoin mining ASICs are submerged in a specialized\n\nfluid, which is circulated to keep the ASICs\u0092 integrated circuits operating at lower temperatures.\u0094\n\nSee October 2021 Press Release. The fluid can also be seen flowing and reflecting light in Riot\u0092s\n\nvideos:\n\n\n\n\n                                                21\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1   Filed 06/03/26   Page 22 of 42   PageID 22\n\n\n\n\nSee Private Facility Tour Video.\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n\n                                            22\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E         Document 1       Filed 06/03/26     Page 23 of 42     PageID 23\n\n\n\n\nSee id.\n\n          43.   In Riot\u0092s Accused Products, the pump is configured to pump the dielectric liquid\n\ncoolant from the coolant inlet to each of the plurality of computers. For example, as shown in\n\nRiot\u0092s videos, the pump(s) move the coolant from the coolant inlet to each of the plurality of\n\ncomputers:\n\n\n\n\n                                               23\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E      Document 1        Filed 06/03/26   Page 24 of 42   PageID 24\n\n\n\n\nSee 700 MW Bitcoin Mining Facility Video.\n\n\n\n\n                                             24\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E        Document 1   Filed 06/03/26   Page 25 of 42   PageID 25\n\n\n\n\nSee Private Facility Tour Video.\n\n\n\n\nSee Corsicana Phase 1 Progress video.\n\n\n                                          25\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1   Filed 06/03/26   Page 26 of 42   PageID 26\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n\n\n\nSee id.\n\n\n                                            26\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1       Filed 06/03/26       Page 27 of 42       PageID 27\n\n\n\n\nSee id.\n\n          44.   As shown in Riot\u0092s videos above, the dielectric liquid coolant flows through the\n\nplurality of computers for absorbing at least a portion of any heat being generated by each of the\n\nplurality of computers. Additionally, these features are described in a Riot news release, explaining\n\nthat Riot uses tanks to hold \u0093a specialized fluid\u0094 that is \u0093pumped and circulated to assist in\n\ndissipating the heat\u0094 and \u0093pumped back through the immersion tank.\u0094 See October 2021 Press\n\nRelease.\n\n\n\n\n                                                 27\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1       Filed 06/03/26      Page 28 of 42      PageID 28\n\n\n\n        45.     Riot\u0092s Accused Products include at least a portion of the dielectric liquid coolant\n\nexiting the plurality of computers that flows through the coolant outlet. For example, Riot\u0092s\n\nOctober 2021 Press Release states that the fluid which the servers are submerged in is \u0093pumped\n\nand circulated\u0094 to a \u0093heat exchanger,\u0094 after which the cooled fluid is \u0093pumped back through the\n\nimmersion tank.\u0094 And as shown in the videos below, the coolant rises through the computers, exits\n\nthe computers, and flows through the coolant outlet:\n\n\n\n\nSee Private Facility Tour Video.\n\n\n\n\n                                                28\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1      Filed 06/03/26      Page 29 of 42      PageID 29\n\n\n\n\nSee Corsicana Phase 1 Progress video.\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n        46.     Riot\u0092s Accused Products also have a coolant outlet that is configured to enable\n\nheated dielectric liquid coolant to flow to the heat exchanger for heat rejection. For example, as\n\n                                               29\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1       Filed 06/03/26    Page 30 of 42      PageID 30\n\n\n\nstated in the October 2021 Press Release, Riot uses tanks to hold \u0093a specialized fluid\u0094 that is\n\n\u0093pumped and circulated to assist in dissipating the heat\u0094 and \u0093pumped back through the immersion\n\ntank.\u0094 See October 2021 Press Release. The heat is dissipated through the heat exchanger sitting\n\nbelow or to the side of the tank. The coolant outlet connecting to the heat exchanger can be seen\n\nbelow or to the side of the tank in Riot\u0092s videos:\n\n\n\n\nSee Private Facility Tour Video.\n\n\n\n\n                                                 30\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1   Filed 06/03/26   Page 31 of 42   PageID 31\n\n\n\n\nSee Corsicana Phase 1 Progress video.\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n\n\n\n                                            31\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1      Filed 06/03/26       Page 32 of 42      PageID 32\n\n\n\n        47.      In Riot\u0092s Accused Products, the heat exchanger is configured to enable cooled\n\ndielectric coolant to flow to the coolant inlet. For example, after the heat exchanger rejects heat\n\nfrom the coolant to create cooled coolant, the cooled coolant flows from the heat exchanger to the\n\ncoolant inlet as can be seen in Riot\u0092s videos above. See id. In addition, as stated in the October\n\n2021 Press Release, Riot uses tanks to hold \u0093a specialized fluid\u0094 that is \u0093pumped and circulated to\n\nassist in dissipating the heat\u0094 and \u0093pumped back through the immersion tank.\u0094 See October 2021\n\nPress Release.\n\n        48.      In Riot\u0092s Accused Products, the tanks are configured to enable a removal of a\n\ncomputer of the plurality of computers without a need to remove any other computer of the\n\nplurality of computers from the at least one tank. For example, the tanks are configured to enable\n\nthe servers to be independently movable (and thus removable) as shown in the videos below.\n\nMultiple servers are installed in each tank, and one may be removed while the others remain in\n\nplace as shown in the videos below:\n\n\n\n\nSee 700 MW Bitcoin Mining Facility Video.\n\n                                                32\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1   Filed 06/03/26   Page 33 of 42   PageID 33\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n\n\n\nSee Behind the Infrastructure Video, YouTube (Sept. 17, 2024), https://www.youtube.com/\n\nwatch?v=8ehOVCpAFlY [hereinafter Behind the Infrastructure Video].\n\n\n\n                                            33\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26       Page 34 of 42       PageID 34\n\n\n\n\nSee id.\n\n          49.   In Riot\u0092s Accused Products, the tanks comprise open tops configured to enable\n\naccess to each of the plurality of computers as described in claim 2. This can be seen in the pictures\n\nand videos already discussed in the prior paragraphs.\n\n          50.   In Riot\u0092s Accused Products, a flow of the dielectric liquid coolant between the\n\nplurality of computers is restricted, thereby enhancing the flow of the dielectric liquid coolant\n\nthrough the plurality of computers. For example, as shown in Riot\u0092s videos, the plenum through\n\nwhich the dielectric liquid coolant flows performs this action consistent with the description in\n\nclaim 3:\n\n\n\n\n                                                 34\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E         Document 1       Filed 06/03/26       Page 35 of 42    PageID 35\n\n\n\n\nSee 700 MW Bitcoin Mining Facility Video.\n\n        51.     Riot\u0092s Accused Products also include a plurality of computers that are oriented\n\nvertically as discussed in claim 10. This vertical orientation can be seen below:\n\n\n\n\n                                                35\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E       Document 1       Filed 06/03/26   Page 36 of 42   PageID 36\n\n\n\n\nSee 700 MW Bitcoin Mining Facility Video.\n\n\n\n\nSee Corsicana Phase 1 Progress Video.\n\n\n                                             36\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26       Page 37 of 42       PageID 37\n\n\n\n\nSee Riot\u0092s Corsicana Video.\n\n        52.     Riot\u0092s Accused Products also allow for heat to be transferred from the plurality of\n\ncomputers to the dielectric liquid coolant without piping going through the plurality of computers\n\nas discussed in claim 11. This can be seen in the videos and pictures discussed above.\n\n        53.     Riot\u0092s Accused Products also allow for at least a portion of the dielectric liquid\n\ncoolant to flow from a bottom of the at least one tank to the open top as discussed in claim 12.\n\nThis can be seen in the videos and pictures discussed above.\n\n        54.     Riot has infringed and is infringing, individually and/or jointly, either literally or\n\nunder the doctrine of equivalents, at least claims 1-3, 6, and 10-12 of the 853 Patent in violation\n\nof 35 U.S.C. \u00a7\u00a7 271, et seq., directly and/or indirectly, by making, using, offering for sale, selling,\n\noffering for lease, or leasing in the United States, and/or importing into the United States without\n\nauthority or license, the Accused Products as explained above. See also Riot 2023 10-K at 41 (Riot\n\n\u0093generate[s] engineering and construction services revenue from the fabrication and deployment\n\nof immersion cooling technology for Bitcoin mining customers\u0094). Riot Platforms, Inc. is also\n\n                                                  37\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1        Filed 06/03/26      Page 38 of 42       PageID 38\n\n\n\nvicariously liable for the infringing conduct of its subsidiaries Whinstone US, Inc. and Riot\n\nCorsicana, LLC (collectively the \u0093Subsidiaries\u0094) under both the alter ego and agency theories\n\nbecause, as an example and on information and belief, Riot Platforms, Inc. has the right and ability\n\nto control its Subsidiaries\u0092 infringing acts and/or use of the Accused Products; Riot Platforms, Inc.\n\ndirects its Subsidiaries to perform the infringing acts and/or use the Accused Products; Riot\n\nPlatforms, Inc.\u0092s Subsidiaries act as Riot Platforms, Inc.\u0092s agents in putting the Accused Products\n\nto use; and Riot Platforms, Inc. receives a direct financial benefit from the Subsidiaries\u0092\n\ninfringement. See CloudofChange, LLC v. NCR Corp., 123 F.4th 1333 (Fed. Cir. 2024); Centillion\n\nData Sys. LLC v. Qwest Communications Int\u0092l Inc., 631 F.3d 1279, 1284 (Fed. Cir. 2011); see also\n\nAcceleration Bay LLC v. 2K Sports, Inc., 15 F.4th 1069, 1074 (Fed. Cir. 2021).\n\n        55.     Riot has been, and currently is, an active inducer of infringement of at least claims\n\n1-3, 6, and 10-12 of the 853 Patent under 35 U.S.C. \u00a7 271(b). Direct infringement is the result of\n\nactivities performed by the Subsidiaries, third party mining companies, or suppliers of the Accused\n\nProducts as detailed above. Riot Platforms, Inc., Riot Corsicana, LLC, and Whinstone US, Inc. are\n\ntherefore jointly and severally liable for all general damages.\n\n        56.     On information and belief, Riot has and continues to induce infringement of the\n\n853 Patent by actively and knowingly inducing others (including each other) to make, have made,\n\nuse, sell, or offer for sale in the United States, or import into the United States the infringing\n\nimmersion cooling systems or components that embody or use the inventions claimed in at least\n\nclaims 1-3, 6, and 10-12 of the 853 Patent. Riot has done so at least by providing directions,\n\ndesigns, and/or instructions to the Subsidiaries and/or third-party mining companies to make or\n\nuse immersion cooling systems or components that are involved in the Accused Products. See id.\n\n(\u0093[w]e provide energized space and operating and maintenance services to third-party mining\n\n\n\n                                                 38\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E          Document 1       Filed 06/03/26      Page 39 of 42      PageID 39\n\n\n\ncompanies who locate their mining hardware at our Rockdale Facility\u0094). Riot has also done so at\n\nleast by providing directions, designs, and/or instructions to the Subsidiaries and/or suppliers to\n\nmake immersion cooling systems or components that are involved in the Accused Products. See\n\nid. Riot performed the acts that constitute induced infringement, and would induce actual\n\ninfringement, with the knowledge of the 853 Patent and with the knowledge or willful blindness\n\nthat the induced acts would constitute infringement.\n\n        57.     On information and belief, Riot has knowledge of the 853 Patent. Riot has litigated\n\nagainst GRC in a prior case where family members of the \u0092853 Patent were in dispute. During that\n\ncase and at least as early as September 8, 2025, GRC\u0092s expert discussed the applicability of the\n\nthen-pending 853 Patent to immersion cooling systems, including those owned and operated by\n\nRiot. Finally, should Riot contend that it did not have knowledge of the 853 Patent, this Complaint\n\nwill serve as notice.\n\n        58.     Allegations of Riot\u0092s knowledge of the 853 Patent and willful infringement will\n\nlikely have additional evidentiary support after a reasonable opportunity for discovery.\n\n        59.     Riot\u0092s infringement of the 853 Patent is willful and deliberate, entitling GRC to\n\nenhanced damages and attorneys\u0092 fees.\n\n        60.     Riot\u0092s infringement of the 853 Patent is exceptional and entitles GRC to attorneys\u0092\n\nfees and costs incurred in prosecuting this action under 35 U.S.C. \u00a7 285.\n\n        61.     GRC has been damaged by Riot\u0092s infringement of the 853 Patent and will continue\n\nto be damaged unless Riot is enjoined by this Court. GRC has suffered and continues to suffer\n\nirreparable injury for which there is no adequate remedy at law. The balance of hardships favors\n\nGRC, and public interest is not disserved by an injunction.\n\n\n\n\n                                                39\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E           Document 1          Filed 06/03/26     Page 40 of 42    PageID 40\n\n\n\n         62.    GRC is entitled to recover from Riot all damages that GRC has sustained as a result\n\nof Riot\u0092s infringement of the 853 Patent, including without limitation, lost profits and/or not less\n\nthan a reasonable royalty.\n\n                                          JURY DEMAND\n\n         Pursuant to Rule 38 of the Federal Rules of Civil Procedure, GRC respectfully requests a\n\ntrial by jury of any issues so triable by right.\n\n                                      PRAYER FOR RELIEF\n\n         Wherefore, GRC respectfully requests that this Court enter judgment in its favor and\n\nagainst Riot and respectfully requests the following relief:\n\n         1.     A judgment that Riot infringed and continues to infringe the 853 Patent;\n\n         2.     A judgment and order requiring Riot to pay GRC\u0092s monetary damages sufficient to\n\ncompensate GRC for Riot\u0092s infringement of the 853 Patent, but in no event less than a reasonable\n\nroyalty under 35 U.S.C. \u00a7 284;\n\n         3.     An award of enhanced damages pursuant to 35 U.S.C. \u00a7 284;\n\n         4.     An award of treble damages for willful infringement;\n\n         5.     A judgment and order requiring Riot to pay GRC\u0092s pre-judgment and post-\n\njudgment interest on the damages award, to the full extent allowed under the law, as well as its\n\ncosts;\n\n         6.     A judgment and order finding this to be an exceptional case under 35 U.S.C. \u00a7 285\n\nand requiring Riot to pay costs of this action and attorneys\u0092 fees;\n\n         7.     A permanent injunction against all Riot products found to infringe the 853 Patent;\n\n         8.     In lieu of an injunction, an award of a compulsory forward royalty;\n\n         9.     An order for an accounting of damages; and\n\n\n\n                                                    40\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E         Document 1       Filed 06/03/26     Page 41 of 42      PageID 41\n\n\n\n        10.     An award of such further relief as the Court may deem appropriate and just under\n\nthe circumstances.\n\n\n\n\n                                               41\nACTIVE 724210304v2\n\fCase 3:26-cv-01842-E   Document 1   Filed 06/03/26     Page 42 of 42     PageID 42\n\n\n\n Dated: June 3, 2026                Respectfully submitted,\n\n                                     GREENBERG TRAURIG, LLP\n\n                                     By: /s/ Ashley N. Moore\n                                     Ashley N. Moore\n                                     Texas Bar No. 24074748\n                                     Phillip M. Aurentz\n                                     Texas Bar No. 24059404\n                                     Zachary H. Ellis\n                                     Texas Bar No. 24122606\n                                     GREENBERG TRAURIG, LLP.\n                                     2200 Ross Avenue\n                                     Suite 5200\n                                     Dallas, Texas 75202\n                                     214-665-3600 \u0096 Phone\n                                     214-665-3601 \u0096 Fax\n                                     Ashley.Moore@gtlaw.com\n                                     Phillip.Aurentz@gtlaw.com\n                                     Zak.Ellis@gtlaw.com\n\n                                     Jonathan Presvelis (pro hac vice forthcoming)\n                                     presvelisj@gtlaw.com\n                                     One Vanderbilt Avenue\n                                     New York, NY 10017\n\n                                    ATTORNEYS FOR PLAINTIFF\n                                    GREEN REVOLUTION COOLING, INC.\n\n\n\n\n                                     42\nACTIVE 724210304v2\n\f","ocr_status":1,"date_upload":"2026-06-04T01:10:23.650737-07:00","document_number":"1","attachment_number":null,"pacer_doc_id":"177018668324","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Complaint","acms_document_guid":""}],"date_created":"2026-06-03T20:16:19.905060-07:00","date_modified":"2026-06-04T14:08:26.470250-07:00","date_filed":"2026-06-03","time_filed":"21:47:15","entry_number":1,"recap_sequence_number":"2026-06-03.001","pacer_sequence_number":9,"description":"","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=73438267&page_size=40"}