Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 1 of 32
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`
`
`Civil Action No. 6:21-cv-00501
`
`
`
`JURY TRIAL DEMAND
`
`
`ASETEK DANMARK A/S,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`SHENZHEN APALTEK CO., LTD., A/K/A
`SHENZHEN ANG PAI TECHNOLOGY CO.,
`LTD. AND GUANGDONG APALTEK LIQUID
`COOLING TECHNOLOGY CO., LTD., A/K/A
`GUANGDONG ANG PAI LIQUID COOLING
`TECHNOLOGY CO., LTD., OR DONGGUAN
`APALCOOL
`
`
`Defendants.
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Asetek Danmark A/S (“Asetek”), files this Complaint for Patent Infringement
`
`and Damages against Defendants Shenzhen Apaltek Co., Ltd., a/k/a Shenzhen Ang Pai
`
`Technology Co., Ltd. (“Apaltek”) and Guangdong Apaltek Liquid Cooling Technology Co.,
`
`Ltd., a/k/a Guangdong Ang Pai Liquid Cooling Technology Co., Ltd., or Dongguan Apalcool
`
`(“Apalcool”) (collectively, “Defendants”), and would respectfully show the Court as follows:
`
`NATURE OF THE ACTION
`
`1. This Complaint seeks judgment that the Defendants have infringed and continue to
`
`infringe Asetek’s U.S. Patent Nos. 8,240,362 (“the ’362 patent), 8,245,764 (“the ’764 patent),
`
`10,078,355 (“the ’355 patent”), and 10,599,196 (“the ’196 patent”) (collectively “the Patents-in-
`
`Suit”). Each of these patents relates to liquid cooling systems and methods for cooling heat
`
`generating electronic components.
`
`1
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 2 of 32
`
`PARTIES
`
`2. Asetek is a corporation organized and existing under the laws of Denmark, and has a
`
`location at Assensvej 2, DK-9220 Aalborg East, Denmark. Asetek is the owner of the Patents-in-
`
`Suit.
`
`3. On information and belief, Apaltek is a Chinese corporation with its principal place of
`
`business at B03/B04/B05, 15th Floor, Block 2, Yicheng Huanzhi Center, Intersection of Renmin
`
`Road and Bayi Road, Jinglong Community, Longhua Street, Longhua District, Shenzhen,
`
`Guangdong Province, PRC.
`
`4. On information and belief, Apalcool is a Chinese corporation with its principal place
`
`of business at No. 12, West Second Lane, Shenzhen Zai Road, Qingxi Town, Dongguan City,
`
`Guangdong Province, PRC.
`
`JURISDICTION AND VENUE
`
`5. This is an action for patent infringement arising under the United States Patent Laws,
`
`35 U.S.C. § 100 et seq. Subject matter jurisdiction is proper under 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`6. Upon information and belief, Defendants operate a website, www.apalcool.com, on
`
`which they describe themselves under their “About Us” tab as having “more than 20 years of
`
`experience in the design and production of liquid-cooled and air-cooled heat dissipation
`
`products.” Defendants describe themselves under their “About Us” tab as providers of ODM
`
`and OEM manufacturing services for the global heat dissipation industry. (“[W]e provide
`
`ODM/OEM customers with superior products and excellent services. We hope to become a loyal
`
`partner in the local and global heat dissipation industry, so that people anywhere in the world can
`
`share happiness through our products and our customers.”)
`
`2
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 3 of 32
`
`7. The following products infringe at least one claim of each of the Patents-in-Suit as
`
`explained in detail in Counts I-IV below: the Lian Li Galahad AIO 240 RGB, the Enermax
`
`AquaFusion 240, and Thermaltake TH120 ARGB Sync (collectively the “Exemplary Infringing
`
`Products”). On information and belief, the Lian Li Galahad AIO family of liquid cooling
`
`products, the Enermax AquaFusion family of liquid cooling products, and the Thermaltake TH
`
`ARGB Sync family of liquid cooling products infringe at least one claim of each of the Patents-
`
`in-Suit.
`
`8. Upon information and belief, Defendants make, offer for sale, and sell the Galahad
`
`AIO line of liquid cooling products to Lian Li, the AquaFusion line of liquid cooling products to
`
`Enermax, and the TH120 ARGB Sync line of liquid cooling products Thermaltake, knowing and
`
`intending that these customers and/or resellers (including www.amazon.com, www.newegg.com,
`
`and www.walmart.com) will and do offer for sale and sell Exemplary Infringing Products to
`
`customers throughout the United States. For example, the Galahad AIO line of liquid cooling
`
`products, the AquaFusion line of liquid cooling products, and the TH120 ARGB Sync line of
`
`liquid cooling products have been and are offered for sale and sold throughout the United States,
`
`Texas, and this district on www.amazon.com, www.newegg.com, and www.walmart.com. On
`
`information and belief, these products are purchased and used by customers in this district. This
`
`Court has personal jurisdiction over Defendants for at least the reasons set forth in this paragraph
`
`and the preceding paragraph.
`
`9. On information and belief, Defendants also likely offer for sale, sell, import, and/or
`
`ship the infringing Enermax AquaFusion line of products to Enermax USA in the United States,
`
`and the infringing Thermaltake TH ARGB Sync line of liquid cooling products to Thermaltake
`
`in the United States.
`
`3
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 4 of 32
`
`10. Venue is proper in the District in accordance with 28 U.S.C. § 1391(c)(3) because
`
`Defendants are foreign corporations not resident in the United States.
`
`FACTUAL BACKGROUND
`
`11. Asetek is a world leading provider of liquid cooling systems for heat-generating
`
`electronic components, such as CPUs and GPUs. Asetek’s business is dedicated entirely to liquid
`
`cooling, which makes up 100% of its revenue. Asetek’s solutions are used by leading original
`
`equipment manufacturers (“OEM”) servicing the datacenter, server, gaming, workstation, and
`
`high performance PC markets. Asetek is also the leading provider of liquid cooling products for
`
`the enthusiast/do-it-yourself market, which includes end-users who buy and self-install liquid
`
`cooling systems into their computers.
`
`12. Asetek’s patented combination of a pump, a dual chambered reservoir, and a cold
`
`plate into a single pump unit—which is claimed in the Patents-in-Suit—provides the benefits of
`
`improved pumping and heat removal efficiencies in a compact (narrow profile) design that
`
`enables the pump unit to be installed directly on the CPU/GPU of a computer motherboard,
`
`graphics card, or a server. In addition to improved efficiency and compactness, Asetek’s
`
`patented designs have greatly reduced and/or eliminated the risk of coolant leakage and have
`
`enabled pre-filled (factory assembled and sealed) liquid cooling products that are easy to install
`
`and use. Asetek’s patented designs have also made manufacturing of liquid cooling products
`
`simpler and less costly.
`
`13. The Exemplary Infringing Products have the same fundamental pump unit structure
`
`and configuration; any differences between the products are irrelevant to the claims of the
`
`Patents-in-Suit and to Defendants’ infringement of the same. Upon information and belief, the
`
`same is true for the Galahad AIO line of liquid cooling products, the AquaFusion line of liquid
`
`cooling products, and the TH120 ARGB Sync line of liquid cooling products. Accordingly,
`
`4
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 5 of 32
`
`Counts I-IV below refer to the Lian Li Galahad AIO 240 as a representative product for all of the
`
`Exemplary Infringing Products and their respective product lines.
`
`COUNT I
`INFRINGEMENT OF U.S. PATENT NO. 8,240,362
`
`14. Asetek incorporates by reference paragraphs 1-10 as though fully set forth herein.
`
`15. Asetek owns the entire right, title, and interest in and to the ’362 patent. A true and
`
`correct copy of the ’362 patent is attached hereto as Exhibit A.
`
`16. The Exemplary Infringing Products infringe at least claim 14 of the ’362 patent,
`
`either literally and/or under the doctrine of equivalents.
`
`17. The Exemplary Infringing Products are cooling systems for processing units
`
`positioned on a motherboard of a computer and comprise the claimed elements of at least claim
`
`14 of the ’362 patent.
`
`18. The Exemplary Infringing Products include “a reservoir configured to be coupled to
`
`the processing unit positioned on the motherboard at a first location, the reservoir being adapted
`
`to pass a cooling liquid therethrough.” For example, as the image of the representative Lian Li
`
`
`
`5
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 6 of 32
`
`Galahad product below shows, the Exemplary Infringing Products include a reservoir configured
`
`to be coupled to a processing unit positioned on the motherboard at a first position and the
`
`reservoir is adapted to pass cooling liquid therethrough.
`
`
`
`19. The reservoir of the Exemplary Infringing Products includes “an upper chamber and a
`
`lower chamber, the upper chamber and lower chamber being separate chambers containing
`
`cooling liquid that are separated by at least a horizontal wall and fluidly coupled together by one
`
`or more passageways, at least one of the one or more passageways being a substantially circular
`
`passageway positioned on the horizontal wall.” For example, as the image of the representative
`
`Lian Li Galahad product below shows, the reservoir of the Exemplary Infringing Products
`
`includes an upper chamber and a lower chamber separated by at least a horizontal wall and
`
`fluidly coupled together by one or more passageways. Further, at least one of the passageways
`
`on the horizontal wall is substantially circular and positioned on the horizontal wall.
`
`6
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 7 of 32
`
`
`
`20. The reservoir of the Exemplary Infringing Products includes “a heat exchanging
`
`interface configured to be placed in separable thermal contact with the processing unit, the heat
`
`exchanging interface being removably attached to the reservoir such that the heat exchanging
`
`interface forms a boundary wall of the lower chamber and the reservoir.” For example, as the
`
`image of the representative Lian Li Galahad product below shows, the reservoir of the
`
`Exemplary Infringing Products includes a heat exchanging interface configured to be placed in
`
`separable thermal contact with the processing unit and is removably attached (e.g., using screws,
`
`fasteners, or brackets) to the reservoir such that the heat exchanging interface forms a boundary
`
`wall of the lower chamber of the reservoir.
`
`
`
`
`
`
`
`
`
`
`21. The Exemplary Infringing Products include “a heat radiator configured to be
`
`positioned at a second location horizontally spaced apart from the first location when the
`
`7
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 8 of 32
`
`reservoir is coupled to the processing unit.” For example, as the image of the representative Lian
`
`Li Galahad product below shows, the Exemplary Infringing Products include a heat radiator
`
`configured to be positioned at a second location horizontally spaced apart from the first location
`
`when the reservoir is coupled to the processing unit.
`
`
`22. The Exemplary Infringing Products further include “a fan adapted to direct air to the
`
`heat radiator to dissipate heat from the cooling liquid to the surrounding atmosphere.” For
`
`example, as the image of the representative Lian Li Galahad product below shows, the
`
`Exemplary Infringing Products include a fan that is adapted to direct air to the heat radiator to
`
`dissipate heat from the cooling liquid to the surrounding atmosphere.
`
`8
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 9 of 32
`
`
`
`23. The Exemplary Infringing Products further include “a pump configured to circulate
`
`cooling liquid between the reservoir and the heat radiator, the pump including a motor having a
`
`rotor, a stator, and an impeller having the equivalent (under the doctrine of equivalents) of
`
`curved blades, the impeller being mechanically coupled to the rotor and at least partially
`
`submerged in the cooling liquid of the reservoir, wherein a speed of the impeller is configured to
`
`be varied independent of the speed of the fan.” For example, as the images of the representative
`
`Lian Li Galahad product below show, the Exemplary Infringing Products include a pump
`
`configured to circulate cooling liquid between the reservoir and the heat radiator, the pump
`
`having a stator and a rotor. The pump also includes an impeller with curved blades. The impeller
`
`is mechanically coupled to the rotor and is at least partially submerged in the cooling liquid in
`
`the reservoir. Because separate motors drive the fan and the pump, a speed of the impeller is
`
`configured to be varied independent of the speed of the fan.
`
`
`
`9
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 10 of 32
`
`24. Upon information and belief, Defendants have induced and continue to actively
`
`induce direct infringement of at least claim 14 of the ’362 patent by others (including Lian Li,
`
`Thermaltake, Enermax, Amazon, Newegg, Walmart, and/or end-users) in the United States and
`
`in this district under 35 U.S.C. § 271(b). Defendants knew of the ’362 patent prior to the filing of
`
`this action, and upon information and belief, Defendants have taken affirmative steps that have
`
`encouraged, aided and abetted (and continue to encourage, aid and abet) direct infringement by
`
`their customers and others (such as Lian Li, Thermaltake, Enermax, Amazon, Newegg, Walmart,
`
`and/or end-users) in the United States and in this district, and Defendants have known that their
`
`induced acts constitute infringement of the ’362 patent or have been willfully blind to the
`
`infringement. On information and belief, these acts include, but are not limited to (1)
`
`Defendants’ manufacture and supply of the Exemplary Infringing Products and their respective
`
`product lines to at least Lian Li, Thermaltake, and/or Enermax, knowing and intending that they
`
`would cause the Exemplary Infringing Products and their respective product lines to be offered
`
`for sale, sold, imported, and/or shipped to the United States, and used in the United States, and
`
`(2) Defendants’ supply of user manuals/guides/product descriptions instructing customers/end
`
`users how to install and use the Exemplary Infringing Products and their respective product lines.
`
`25. Upon information and belief, Defendants have contributed to and continue to
`
`contribute to the direct infringement of at least claim 14 of the ’362 patent by others (including
`
`Lian Li, Thermaltake, Enermax, Amazon, Newegg, Walmart, and/or end-users) in the United
`
`States and in this district under 35 U.S.C. § 271(c). Upon information and belief, Defendants,
`
`with knowledge of the patent, supply important (material) components of the Exemplary
`
`Infringing Products and their respective product lines (as well as instructions for the same) to
`
`others, including Lian Li, Thermaltake, and/or Enermax. Upon information and belief,
`
`10
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 11 of 32
`
`Defendants knew or were willfully blind that the combination for which their components were
`
`especially made was both patented and infringing, that the Exemplary Infringing Products and
`
`their respective product lines are not a staple article or commodity of commerce, and have no
`
`substantial non-infringing uses.
`
`26. Upon information and belief, Defendants likely have also directly infringed one or
`
`more claims of the ’362 patent under 35 U.S.C. §§ 271(a) by, among other things, offering for
`
`sale, selling, importing and/or distributing the Exemplary Infringing Products and their
`
`respective product lines in and into the United States.
`
`27. Upon information and belief, Defendants have infringed the ’362 patent in an
`
`egregious and willful manner and with knowledge of the ’362 patent, or were willfully blind to
`
`the risk of infringement.
`
`28. Defendants’ infringement of the ’362 patent has caused and continues to cause
`
`damages and irreparable harm to Asetek.
`
`COUNT II
`INFRINGEMENT OF U.S. PATENT NO. 8,245,764
`
`29. Asetek incorporates by reference paragraphs 1-10 as though fully set forth herein.
`
`30. Asetek owns the entire right, title, and interest in and to the ’764 patent. A true and
`
`correct copy of the ’764 patent is attached hereto as Exhibit B.
`
`31. The Exemplary Infringing Products infringe at least claim 1 of the ’764 patent, either
`
`literally and/or under the doctrine of equivalents.
`
`32. The Exemplary Infringing Products are cooling systems for heat-generating
`
`components comprising the claimed elements of at least claim 1 of the ’764 patent.
`
`11
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 12 of 32
`
`
`
`33. The Exemplary Infringing Products include “a double-sided chassis to mount a pump
`
`configured to circulate a cooling liquid, the pump comprising a stator and an impeller, the
`
`impeller being positioned on the underside of the chassis and the stator being positioned on the
`
`upper side of the chassis and isolated from the cooling liquid.” For example, as the images of the
`
`representative Lian Li Galahad product below show, the Exemplary Infringing Products include
`
`a double-sided chassis mounted with a pump that has a stator and an impeller, with the impeller
`
`positioned on the underside of the chassis and the stator positioned on the upper side of the
`
`chassis and isolated from the cooling liquid.
`
`
`
`12
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 13 of 32
`
`34. The Exemplary Infringing Products further include “a reservoir adapted to pass the
`
`cooling liquid therethrough.” For example, as the image of the representative Lian Li Galahad
`
`product below shows, the Exemplary Infringing Products include a reservoir adapted to pass
`
`cooling liquid through it.
`
`
`
`35. The reservoir of the Exemplary Infringing Products includes “a pump chamber
`
`including the impeller and formed below the chassis, the pump chamber being defined by at least
`
`an impeller cover having one or more passages for the cooling liquid to pass through.” For
`
`example, as the images of the representative Lian Li Galahad product below show, the reservoir
`
`of the Exemplary Infringing Products includes a pump chamber formed below the chassis and
`
`housing the pump impeller, the pump chamber comprising at least an impeller cover with one or
`
`more passages.
`
`13
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 14 of 32
`
`
`
`36. The Exemplary Infringing Products include a reservoir that further includes “a
`
`thermal exchange chamber formed below the pump chamber and vertically spaced apart from the
`
`pump chamber, the pump chamber and the thermal exchange chamber being separate chambers
`
`that are fluidly coupled together by one or more passages.” For example, as the images of the
`
`representative Lian Li Galahad product below show, the reservoir of the Exemplary Infringing
`
`Products includes a thermal exchange chamber that is vertically spaced apart from the pump
`
`chamber, with the thermal exchange chamber formed below the pump chamber. Both the pump
`
`chamber and thermal exchange chamber are separate chambers that are fluidly coupled together
`
`by one or more passages.
`
`
`
`14
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 15 of 32
`
`37. The thermal exchange chamber of the reservoir of the Exemplary Infringing Products
`
`further includes “a heat-exchanging interface, the heat exchanging interface forming a boundary
`
`wall of the thermal exchange chamber, and configured to be placed in thermal contact with a
`
`surface of the heat-generating component.” For example, as the image of the representative Lian
`
`Li Galahad product below shows, the Exemplary Infringing Products include a heat-exchanging
`
`interface that forms a boundary wall of the thermal exchange chamber and is configured with
`
`one side to be placed in thermal contact with a surface of the heat-generating component.
`
`
`
`38. The Exemplary Infringing Products include a “heat radiator fluidly coupled to the
`
`reservoir and configured to dissipate heat from the cooling liquid.” For example, as the image of
`
`the representative Lian Li Galahad product below shows, the Exemplary Infringing Products
`
`include a heat radiator fluidly coupled to the reservoir and configured to dissipate heat from the
`
`cooling liquid.
`
`15
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 16 of 32
`
`
`
`39. Upon information and belief, Defendants have induced and continue to actively
`
`induce direct infringement of at least claim 1 of the ’764 patent by others (including Lian Li,
`
`Thermaltake, Enermax, Amazon, Newegg, Walmart, and/or end-users) in the United States and
`
`in this district under 35 U.S.C. § 271(b). Defendants knew of the ’764 patent prior to the filing of
`
`this action, and upon information and belief, Defendants have taken affirmative steps that have
`
`encouraged, aided and abetted (and continue to encourage, aid and abet) direct infringement by
`
`their customers and others (such as Lian Li, Thermaltake, Enermax, Amazon, Newegg, Walmart,
`
`and/or end-users) in the United States and in this district, and Defendants have known that their
`
`induced acts constitute infringement of the ’764 patent or have been willfully blind to the
`
`infringement. On information and belief, these acts include, but are not limited to (1)
`
`Defendants’ manufacture and supply of the Exemplary Infringing Products and their respective
`
`product lines to at least Lian Li, Thermaltake, and/or Enermax, knowing and intending that they
`
`would cause the Exemplary Infringing Products and their respective product lines to be offered
`
`for sale, sold, imported, and/or shipped to the United States, and used in the United States, and
`
`(2) Defendants’ supply of user manuals/guides/product descriptions instructing customers/end
`
`users how to install and use the Exemplary Infringing Products and their respective product lines.
`
`16
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 17 of 32
`
`40. Upon information and belief, Defendants have contributed to and continue to
`
`contribute to the direct infringement of at least claim 1 of the ’764 patent by others (including
`
`Lian Li, Thermaltake, Enermax, Amazon, Newegg, Walmart, and/or end-users) in the United
`
`States and in this district under 35 U.S.C. § 271(c). Upon information and belief, Defendants,
`
`with knowledge of the patent, supply important (material) components of the Exemplary
`
`Infringing Products and their respective product lines (as well as instructions for the same) to
`
`others, including Lian Li, Thermaltake, and/or Enermax. Upon information and belief,
`
`Defendants knew or were willfully blind that the combination for which their components were
`
`especially made was both patented and infringing, that the Exemplary Infringing Products and
`
`their respective product lines are not a staple article or commodity of commerce, and have no
`
`substantial non-infringing uses.
`
`41. Upon information and belief, Defendants likely have also directly infringed one or
`
`more claims of the ’764 patent under 35 U.S.C. §§ 271(a) by, among other things, offering for
`
`sale, selling, importing and/or distributing the Exemplary Infringing Products and their
`
`respective product lines in and into the United States.
`
`42. Upon information and belief, Defendants have infringed the ’764 patent in an
`
`egregious and willful manner and with knowledge of the ’764 patent, or were willfully blind to
`
`the risk of infringement.
`
`43. Defendants’ infringement of the ’764 patent has caused and continues to cause
`
`damages and irreparable harm to Asetek.
`
`COUNT III
`INFRINGEMENT OF U.S. PATENT NO. 10,078,355
`
`44. Asetek incorporates by reference paragraphs 1-10 as though fully set forth herein.
`
`17
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 18 of 32
`
`45. Asetek owns the entire right, title, and interest in and to the ’355 patent. A true and
`
`correct copy of the ’355 patent is attached hereto as Exhibit C.
`
`46. The Exemplary Infringing Products infringe at least claim 1 of the ’355 patent, either
`
`literally and/or under the doctrine of equivalents.
`
`47. The Exemplary Infringing Products are liquid cooling systems for cooling a heat-
`
`generating component of a computer comprising the claimed elements of at least claim 1 of the
`
`’355 patent.
`
`
`
`48. The Exemplary Infringing Products include “a reservoir configured to circulate a
`
`cooling liquid therethrough.” For example, as the image of the representative Lian Li Galahad
`
`product below shows, the Exemplary Infringing Products include a reservoir, which is
`
`configured to be coupled to a processing unit positioned on the motherboard of a computer and
`
`the reservoir is adapted to pass cooling liquid therethrough.
`
`18
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 19 of 32
`
`
`
`49. The reservoir of the Exemplary Infringing Products includes “a pump chamber
`
`housing an impeller and defined at least in part by an impeller cover and a double-sided chassis,
`
`the impeller being positioned on one side of the chassis and a stator of the pump is positioned on
`
`an opposite side of the chassis.” For example, as the image of the representative Lian Li Galahad
`
`product below shows, the reservoir of the Exemplary Infringing Products includes a pump
`
`chamber housing an impeller and defined in part by an impeller cover and a double-sided
`
`chassis, and the impeller is positioned on one side of the chassis and a stator of the pump is on
`
`the opposite side of the chassis.
`
`
`
`19
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 20 of 32
`
`50. The reservoir of the Exemplary Infringing Products includes “a thermal exchange
`
`chamber disposed between the pump chamber and the heat-generating component when the
`
`system is installed on the heat-generating component.” For example, as the image of the
`
`representative Lian Li Galahad product below shows, the reservoir of the Exemplary Infringing
`
`Products includes a thermal exchange chamber positioned between the pump chamber and the
`
`heat generating component when the system is installed on the heat-generating component.
`
`
`
`51. The reservoir of the Exemplary Infringing Products includes “a heat-exchanging
`
`interface forming a boundary wall of the thermal exchange chamber, the heat-exchanging
`
`interface has an outer surface configured to be placed in thermal contact with a surface of the
`
`heat-generating component and an inner surface that defines a plurality of channels that direct
`
`the flow of a cooling liquid within the thermal exchange chamber.” For example, as the image of
`
`the representative Lian Li Galahad product below shows, the reservoir of the Exemplary
`
`Infringing Products has a heat-exchanging interface forming a boundary wall of the thermal
`
`exchange chamber and has an outer surface configured to be placed in thermal contact with a
`
`surface of the heat-generating component and an inner surface that defines a plurality of channels
`
`that direct the flow of a cooling liquid within the thermal exchange chamber.
`
`20
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 21 of 32
`
`
`
`52. The Exemplary Infringing Products include “a heat radiator adapted to pass the
`
`cooling liquid therethrough, the heat radiator being fluidly coupled to the reservoir via fluid
`
`conduits, the heat radiator being configured to dissipate heat from the cooling liquid.” For
`
`example, as the image of the representative Lian Li Galahad product below shows, the
`
`Exemplary Infringing Products include a radiator spaced apart from and fluidly coupled to the
`
`reservoir.
`
`
`
`53. The pump chamber of the Exemplary Infringing Products includes “an inlet defined
`
`by the impeller cover positioned below a center of the impeller configured to enable the cooling
`
`liquid to flow into the center of the pump chamber.” For example, as the image of the
`
`representative Lian Li Galahad product below shows, the pump chamber of the Exemplary
`
`21
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 22 of 32
`
`Infringing Products has an inlet defined by the impeller cover positioned below a center of the
`
`impeller configured to enable the cooling liquid to flow into the center of the pump chamber.
`
`
`
`54. The pump chamber of the Exemplary Infringing Products includes “an outlet defined
`
`by the impeller cover positioned tangentially to the circumference of the impeller.” For example,
`
`as the image of the representative Lian Li Galahad product below shows, the pump chamber of
`
`the Exemplary Infringing Products has an outlet defined by the impeller cover positioned
`
`tangentially to the circumference of the impeller.
`
`
`
`55. Upon information and belief, Defendants have induced and continue to actively
`
`induce direct infringement of at least claim 1 of the ’355 patent by others (including Lian Li,
`
`Thermaltake, Enermax, Amazon, Newegg, Walmart, and/or end-users) in the United States and
`
`in this district under 35 U.S.C. § 271(b). Defendants knew of the ’355 patent prior to the filing of
`
`22
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 23 of 32
`
`this action, and upon information and belief, Defendants have taken affirmative steps that have
`
`encouraged, aided and abetted (and continue to encourage, aid and abet) direct infringement by
`
`their customers and others (such as Lian Li, Thermaltake, Enermax, Amazon, Newegg, Walmart,
`
`and/or end-users) in the United States and in this district, and Defendants have known that their
`
`induced acts constitute infringement of the ’355 patent or have been willfully blind to the
`
`infringement. On information and belief, these acts include, but are not limited to (1)
`
`Defendants’ manufacture and supply of the Exemplary Infringing Products and their respective
`
`product lines to at least Lian Li, Thermaltake, and/or Enermax, knowing and intending that they
`
`would cause the Exemplary Infringing Products and their respective product lines to be offered
`
`for sale, sold, imported, and/or shipped to the United States, and used in the United States, and
`
`(2) Defendants’ supply of user manuals/guides/product descriptions instructing customers/end
`
`users how to install and use the Exemplary Infringing Products and their respective product lines.
`
`56. Upon information and belief, Defendants have contributed to and continue to
`
`contribute to the direct infringement of at least claim 1 of the ’355 patent by others (including
`
`Lian Li, Thermaltake, Enermax, Amazon, Newegg, Walmart, and/or end-users) in the United
`
`States and in this district under 35 U.S.C. § 271(c). Upon information and belief, Defendants,
`
`with knowledge of the patent, supply important (material) components of the Exemplary
`
`Infringing Products and their respective product lines (as well as instructions for the same) to
`
`others, including Lian Li, Thermaltake, and/or Enermax. Upon information and belief,
`
`Defendants knew or were willfully blind that the combination for which their components were
`
`especially made was both patented and infringing, that the Exemplary Infringing Products and
`
`their respective product lines are not a staple article or commodity of commerce, and have no
`
`substantial non-infringing uses.
`
`23
`
`

`

`Case 6:21-cv-00501 Document 1 Filed 05/14/21 Page 24 of 32
`
`57. Upon information and belief, Defendants likely have also directly infringed one or
`
`more claims of the ’355 patent under 35 U.S.C. § 271(a) by, among other things, offering for
`
`sale, selling, importing and/or distributing the Exemplary Infringing Products and their
`
`respective product lines in and into the United States.
`
`58. Upon information and belief, Defendants have infringed the ’355 patent in an
`
`egregious and willful manner and with knowledge of the ’355 patent, or were willfully blind to
`
`the risk of infringement.
`
`59. Defendants’ infringement of the ’355 patent has caused and continues to cause
`
`damages and irreparable harm to Asetek.
`
`COUNT IV
`INFRINGEMENT OF U.S. PATENT NO. 10,599,196
`
`60. Asetek incorporates by reference paragraphs 1-10 as though fully set forth herein.
`
`61. Asetek owns the entire right, title, and interest in and to the ’196 patent. A true and
`
`correct copy of the ’196 patent is attached hereto as Exhibit D.
`
`62. The Exemplary Infringing Products infringe at least claim 10 of the ’196 patent,
`
`either literally and/or under the doctrine of equivalents.
`
`63. The Exemplary Infringing Products are cooling systems for cooling heat-generating
`
`components compr