R421A LLC v. BMP USA: Refrigerant Patent Dispute Ends in Consent Judgment
Plaintiffs R421A, LLC and RMS of Georgia, LLC (d/b/a Choice Refrigerants) brought a patent infringement action in the Florida Middle District Court against BMP USA, Inc. and four co-defendants over two patents covering R22-replacement refrigerant blends with lubricating oil. The case resolved by consent judgment in 226 days — before trial.
R22 refrigerant patent dispute settled by court-entered consent judgment
On 27 September 2022, R421A, LLC and RMS of Georgia, LLC (d/b/a Choice Refrigerants) filed a patent infringement action in the U.S. District Court for the Middle District of Florida against BMP USA, Inc., Cool Master U.S.A., LLC, L.M. Supply, Inc., Xianbin Meng, and IGAS USA, Inc. The asserted patents — US8197706B2 and US9982179B2 — cover refrigerant blends with lubricating oil formulated as drop-in replacements for R22 refrigerant, a widely used but now phase-down-restricted compound.
The recorded basis of termination is Consent Judgment. The docket order states that the parties notified the court, pursuant to Local Rule 3.09(a), that they had reached an agreement in principle to resolve the action and were working to finalise a written agreement. The case closed on 11 May 2023. The specific terms of the resolution are not disclosed in the available public record.
The 226-day duration from filing to closure suggests the parties moved toward resolution relatively early in the litigation lifecycle, potentially before substantial discovery or claim-construction proceedings concluded. What drove the agreement — and whether it involves any licensing, commercial, or operational terms — is not disclosed in the available record.
See Complete Case & Patent Analysis →Filing to Consent Judgment in 226 days
226 days — resolved well under the typical district court trial timeline
US8197706B2 & US9982179B2 — R22-replacement refrigerant formulations
Any company importing, blending, distributing, or reselling refrigerant products marketed as R22 drop-in replacements should treat these two patents as material FTO targets. The plaintiffs have demonstrated willingness to pursue the full supply chain — importers, distributors, and individual officers — and secured a court-entered consent judgment. If your product is an HFC-based R22 alternative supplied with or compatible with lubricating oil systems, a formal FTO analysis is warranted before further commercialisation.
Official order — verbatim text
The docket notice, filed under Local Rule 3.09(a), records that all parties had reached an agreement in principle and were preparing a final written agreement. The recorded basis of termination is Consent Judgment. The notice does not disclose the substantive terms of the resolution, and those terms are not available in the public record.
Consent judgment: what the agreed resolution means for both parties
What a consent judgment means in federal patent litigation
A consent judgment is a binding, court-entered judgment on terms agreed by the parties. Unlike a voluntary dismissal, it carries the full force of a judicial order and can be enforced by the court. It formally ends the litigation on the merits as agreed — not through a unilateral procedural step. The court retains jurisdiction to enforce its terms if a party fails to comply.
Court-entered, binding and finalPlaintiffs secure a judicially enforceable resolution
For R421A, LLC and RMS of Georgia, LLC, a consent judgment represents a court-backed resolution of their infringement claims against all five defendants. The patents-in-suit — US8197706B2 and US9982179B2 — remain intact and were not adjudicated invalid through this proceeding. The specific terms of the judgment are not disclosed in the available public record.
Patents not invalidatedFive defendants bound by a single agreed court order
BMP USA, Inc., Cool Master U.S.A., LLC, L.M. Supply, Inc., IGAS USA, Inc., and Xianbin Meng are all parties to the consent judgment. Each is bound by its terms. Whether the judgment imposes injunctive relief, royalty obligations, or other conditions is not disclosed in the available public record. Breach of a consent judgment can give rise to contempt proceedings.
All defendants boundR22-replacement refrigerant market faces active IP enforcement
The R22 phase-down under the Montreal Protocol has created a competitive market for drop-in refrigerant alternatives. This case signals that R421A, LLC and RMS of Georgia are actively enforcing their portfolio across the distribution chain — targeting not just importers but distributors and individual officers. Companies supplying R22-replacement blends should assess exposure to US8197706B2 and US9982179B2.
Active enforcement across supply chainFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | R421A, LLC | Company | Refrigerant IP licensing entities — holders of US8197706B2 and US9982179B2Search in Eureka ↗ |
| Co-Plaintiff | RMS of Georgia, LLC | Company | Search in Eureka ↗ |
| Defendant | BMP USA, Inc. | Company | Distributors and suppliers of refrigerant products, including BMP USA, Cool Master U.S.A., L.M. Supply, IGAS USA, and individual defendant Xianbin MengSearch in Eureka ↗ |
| Co-Defendant | Cool Master U.S.A., LLC | Company | Search in Eureka ↗ |
| Co-Defendant | L.M. Supply, Inc. | Company | Search in Eureka ↗ |
| Co-Defendant | Xianbin Meng | Individual | Search in Eureka ↗ |
| Co-Defendant | IGAS USA, Inc. | Company | Search in Eureka ↗ |
| Plaintiff counsel | Andrea Pham Nguyen | Attorney | Counsel for R421A, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Joseph W. Staley | Attorney | Counsel for R421A, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Ryan Thomas Santurri | Attorney | Counsel for R421A, LLCSearch in Eureka ↗ |
| Plaintiff counsel | Scott P. Amy | Attorney | Counsel for R421A, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Allen, Dyer, Doppelt, & Gilchrist, PA | Law Firm | Representing R421A, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Perilla Knox & Hildebrandt LLP | Law Firm | Representing R421A, LLCSearch in Eureka ↗ |
| Plaintiff law firm | Thomas Horstemeyer LLP | Law Firm | Representing R421A, LLCSearch in Eureka ↗ |
| Defendant counsel | Buffey Elizabeth Klein | Attorney | Counsel for BMP USA, Inc.Search in Eureka ↗ |
| Defendant counsel | Eric J. Rakestraw | Attorney | Counsel for BMP USA, Inc.Search in Eureka ↗ |
| Defendant counsel | Eric William Neilsen | Attorney | Counsel for BMP USA, Inc.Search in Eureka ↗ |
| Defendant counsel | Kara R. Fussner | Attorney | Counsel for BMP USA, Inc.Search in Eureka ↗ |
| Defendant counsel | Stephen Bosco | Attorney | Counsel for BMP USA, Inc.Search in Eureka ↗ |
| Defendant law firm | Husch Blackwell LLP | Law Firm | Representing BMP USA, Inc.Search in Eureka ↗ |
| Defendant law firm | Neilsen Law Group P.A. | Law Firm | Representing BMP USA, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Florida Middle District CourtSearch in Eureka ↗ |
R&D signals in the R22-replacement refrigerant IP space
Forward-looking patent and innovation intelligence derived from the R421A LLC and RMS of Georgia enforcement action — what it reveals about the HFC refrigerant IP landscape.
R421A LLC's refrigerant patent portfolio: scope and coverage
R421A, LLC holds at least two granted U.S. patents covering R22-replacement refrigerant compositions with lubricating oil. Monitoring their application activity and any continuation filings from the US12/961045 and US13/493491 families can reveal whether claim scope is expanding into adjacent blend formulations or delivery methods — critical intelligence for any company active in the HFC replacement market.
Portfolio monitoringFiling trends in R22-replacement refrigerant formulations
The global phase-down of R22 under the Montreal Protocol has driven sustained patent filing activity in HFC and HFO-based drop-in replacements. Tracking filing trends across this segment — particularly claims covering lubricant compatibility and retrofit system performance — can identify which technology vectors are becoming crowded and where white space remains for non-infringing formulations.
HFC blend filing trendsBMP USA and co-defendants: patent position in the refrigerant supply chain
BMP USA, Cool Master U.S.A., IGAS USA, and L.M. Supply operate as importers and distributors in the refrigerant supply chain. Assessing whether any of these entities — or their affiliated entities — hold defensive IP or have filed their own refrigerant-related patents can inform competitive positioning and FTO strategy for other players in the distribution network.
Distributor IP mappingAdjacent R&D opportunities near the asserted refrigerant patents
The asserted patents focus on R22-replacement blends compatible with mineral oil lubricants used in legacy systems. Adjacent white space may exist in next-generation refrigerant formulations targeting synthetic lubricant compatibility, ultra-low-GWP HFO blends, or retrofit retrofit kits that reduce lubricant migration — areas that may fall outside the current claim scope of US8197706B2 and US9982179B2.
Low-GWP refrigerant white spaceSimilar refrigerant patent infringement cases in U.S. district courts
Browse related HFC refrigerant and R22-replacement patent enforcement actions filed in U.S. district courts, including cases involving similar supply-chain defendant strategies.
What this case signals for the refrigerant IP landscape
This consent judgment highlights the enforcement posture of R421A LLC and RMS of Georgia across the R22-replacement refrigerant supply chain.
Supply-chain defendants face coordinated infringement claims
The plaintiff group named five defendants spanning importers, distributors, and an individual officer. This multi-defendant strategy is consistent with patent holders seeking to disrupt infringing supply chains comprehensively rather than targeting a single entity. Distributors of R22-alternative refrigerants should audit their product sourcing.
Early resolution signals active licensing posture, not trial strategy
A 226-day resolution, before trial and apparently before significant claim construction, suggests the plaintiffs may prioritise licensing and enforcement outcomes over lengthy litigation. Companies operating in the R22-replacement space should assess whether their formulations overlap with the asserted patent claims before receiving a demand letter.
R421A v BMP — key questions answered
The plaintiffs asserted two patents: US8197706B2 (application no. US12/961045) and US9982179B2 (application no. US13/493491). Both cover refrigerant compositions with lubricating oil designed as drop-in replacements for R22 refrigerant.
The recorded basis of termination is Consent Judgment, a binding court-entered resolution agreed by all parties. The docket order states that the parties notified the court they had reached an agreement in principle and were preparing a final written agreement. The specific terms are not disclosed in the available public record.
The defendants were BMP USA, Inc., Cool Master U.S.A., LLC, L.M. Supply, Inc., IGAS USA, Inc., and individual defendant Xianbin Meng. The multi-defendant structure targeted entities across the R22-replacement refrigerant import and distribution supply chain.
The case was filed on 27 September 2022 and closed on 11 May 2023 — a duration of 226 days. This timeline suggests resolution occurred well before trial, and potentially before significant discovery or claim-construction proceedings were completed.
Companies distributing or importing HFC-based R22 drop-in replacement blends — particularly those compatible with mineral oil lubricants — should consider a formal FTO analysis against both patents. The plaintiffs pursued distributors and an individual officer in this case, and the patents were not invalidated through any trial or IPR ruling on the available public record.
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