Exhibit A
`U.S. Patent No. 7,490,348
`Westin Stonebriar
`Evidence
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`
`On information and belief, Westin Stonebriar’s accused instrumentalities include a first communication part defining a first
`class of service that includes a first set of permissions for access to resources including access to files on a system being
`controlled by said first communication part, and a second communication part, transmitting a separate communication stream
`from said first communication part, over substantially a same transmitting area as said first communication part, and said
`second communication part defining a second class of service which includes a second set of permissions of access to
`resources, where said second set of permissions does not include said access to said first files on said system.
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`Plaintiff requires the benefit of discovery before it can identify the accused instrumentality that meets this claim limitation. At
`the parties’ March 8, 2013 Rule 26(f) conference, the first possible day to serve such discovery, Plaintiff served Interrogatory
`No. 1 and accompanying document requests which seek information sufficient to identify all Defendants’ networks, including
`those that are hidden or encrypted, whether such networks have access to server resources, including what type of access,
`and the hardware configurations associated with such networks. While Plaintiff has requested expedited production and
`responses to this discovery, Defendants have not yet provided such information.
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`The first communication part may be met by hidden networks. On information and belief, the hotel has one or more hidden
`networks that may meet this limitation, including: networks where the network name (e.g., SSID) is not broadcast, networks
`that are broadcast in only a portion of the hotel that is not publicly accessible, or networks transmitted using a standard that
`requires specialized equipment to monitor.
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`Networks observed on the property may also belong to the hotel and meet this limitation. Those networks include: “Tammy’s
`Verizon MIFI4510L,” or “Bbrown Mifi.” Without the additional discovery mentioned above, Plaintiff cannot determine the
`relationship of this network to the hotel or the details of this network.
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`On information and belief, the hotel uses digital-radio-based networks to communicate amongst hotel staff that may meet this
`claim limitation. For example, the hotel uses digital radios that communicate based on one or more ETSI DMR standards.
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`On information and belief, the hotel used and/or uses wireless networks identified above to allow access to files on one or
`
`Claim
`Language
`Claim 1
`A wireless
`network
`comprising:
`
` a
`
` first
`communication
`part defining a
`first class of
`service that
`includes a first
`set of
`permissions for
`access to
`resources
`including
`access to files
`on a system
`being
`controlled by
`said first
`communication
`part, and a
`second
`communication
`part,
`transmitting a
`separate
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`STARWOOD Ex 1013, page 1
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`more servers. For example, the hotel used and/or uses wireless networks to connect to a ZapMail server, a hospitality server,
`a Galaxy LightSpeed server, a doorlock server, an audio server, a video server, or an Internet Access server.
`
`Alternatively, the first communication part may be met by known networks but would require unauthorized access to those
`networks to determine if they allow access to files on a system. Plaintiff could not have legally obtained this information
`outside of discovery because Plaintiff would have had to access Defendants’ networks without sufficient permission. See, e.g.,
`Tex. Penal Code Ann. § 33.02 (“[a] person commits an offense if the person knowingly accesses a computer, computer
`network, or computer system without the effective consent of the owner.”); see also the Federal Wiretap Act, 18 U.S.C.§2511
`(“[e]xcept as otherwise specifically provided in this chapter any person who… intentionally intercepts, endeavors to intercept,
`or procures any other person to intercept or endeavor to intercept, any wire, oral, or electronic communication… shall be
`punished… or shall be subject to suit… .”); see also the Pen Register and Trap and Trace Act, 18 U.S.C. §3121 (“[e]xcept as
`provided in this section, no person may install or use a pen register or a trap and trace device without first obtaining a court
`order under section 3123 of this title… .”).
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`Regarding the second communication part:
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`The second communication part comprises“WESTIN-GUEST” broadcast from a device with a MAC address of
`00:3A:99:02:1F:80. As shown in the screenshot below, a network named WESTIN-GUEST is broadcasted from a device with a
`MAC address of 00:3A:99:02:1F:80. At least eight other “WESTIN-GUEST” networks are broadcast from devices with different
`MAC addresses within the Westin Stonebriar property. All nine networks named WESTIN-GUEST are “Open,” which means
`unencrypted.
`
`
`Claim
`Language
`communication
`stream from
`said first
`communication
`part, over
`substantially a
`same
`transmitting
`area as said
`first
`communication
`part, and said
`second
`communication
`part defining a
`second class of
`service which
`includes a
`second set of
`permissions of
`access to
`resources,
`where said
`second set of
`permissions
`does not
`include said
`access to said
`first files on
`said system,
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`STARWOOD Ex 1013, page 2
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`STARWOOD Ex 1013, page 3
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`STARWOOD Ex 1013, page 4
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`STARWOOD Ex 1013, page 5
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`Evidence
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`On information and belief, the other WESTIN-GUEST devices shown above similarly meet this claim limitation.
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:02:1F:80 is associated with the name ‘WESTIN-GUEST’ and that at least eight other devices with different MAC
`addresses are also associated with the name ‘WESTIN-GUEST’” on the Westin Stonebriar property. (Legacy Stonebriar Hotel,
`Ltd. and Legacy Stonebriar Hotel II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶
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`STARWOOD Ex 1013, page 6
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`95; Def. Starwood Hotels & Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 95.)
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`The Westin Stonebriar website admits: “Plano hotel, guest room amenities: … High Speed wired and wireless internet access.”
`http://www.westinstonebriar.com/accommodations.html
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`WESTIN-GUEST broadcast from a device with a MAC address of 00:3A:99:02:1F:80 does not provide access to information on a
`Westin Stonebriar server.
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`Alternatively, the second commuication part comprises“WESTIN-MEETING” broadcast from a device with a MAC address of
`00:3A:98:E6:07:80. As shown in the screenshot below, a network named “WESTIN-MEETING” is broadcasted from a device
`with a MAC address of 00:3A:98:E6:07:80. At least ten other devices with different MAC addresses also transmit a network
`named WESTIN-MEETING within the Westin Stonebriar property. All eleven networks named WESTIN-MEETING are “Open,”
`which means unencrypted.
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`STARWOOD Ex 1013, page 7
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`STARWOOD Ex 1013, page 8
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`STARWOOD Ex 1013, page 9
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`STARWOOD Ex 1013, page 10
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`Language
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`Evidence
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`On information and belief, the other WESTIN-MEETING devices shown above similarly meet this claim limitation.
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:98:E6:07:80 is associated with the name ‘WESTIN-MEETING’ and that at least ten other devices with different MAC
`addresses are also associated with the name ‘WESTIN-MEETING’” on the Westin Stonebriar property. (Legacy Stonebriar
`Hotel, Ltd. and Legacy Stonebriar Hotel II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s
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`STARWOOD Ex 1013, page 11
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`Claim
`Language
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`said first
`communication
`part having its
`access
`controlled by
`requiring users
`of the first
`communication
`part to use a
`first key, said
`first key being
`a non-public
`key of a type
`that controls
`access, and
`automatically
`provides access
`to users that
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`Evidence
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`Complaint, at ¶ 97; Def. Starwood Hotels & Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 97.)
`
`The Westin Stonebriar website admits: “[a]ll of our meeting facilities feature high-speed wired and wireless Internet access,
`videoconferencing capabilities, satellite and T-1 line connections, and the support of our superb onsite audio/video staff.”
`http://www.westinstonebriar.com/meetings.html
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`WESTIN-MEETING broadcast from a device with a MAC address of 00:3A:98:E6:07:80 does not provide access to information
`on a Westin Stonebriar server.
`
`Lone Star WiFi presently asserts that this claim element is literally present. To the extent that this claim element is found to
`not literally meet the claim element, Lone Star WiFi contends that the instrumentality identified herein is insubstantially
`different from the claimed invention of the associated patent-in-suit and therefore would infringe under the doctrine of
`equivalents.
`
`On information and belief, Westin Stonebriar’s accused instrumentalities include said first communication part having its
`access controlled by requiring users of the first communication part to use a first key, said first key being a non-public key of a
`type that controls access, and automatically provides access to users that have said first key and does not provide access to
`users who do not have said first key, said second communication part allowing access without said first key.
`
`Regarding the non-public key, discovery is needed. Plaintiff requires the benefit of discovery before it can identify the accused
`instrumentality that meets this claim limitation. At the parties’ March 8, 2013 Rule 26(f) conference, the first possible day to
`serve such discovery, Plaintiff served Interrogatory No. 1 and accompanying document requests which seek information
`sufficient to identify all Defendants’ networks, including those that are hidden or encrypted, whether such networks have
`access to server resources, including what type of access, and the hardware configurations associated with such networks.
`While Plaintiff has requested expedited production and responses to this discovery, Defendants have not yet provided such
`information.
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`Regarding the second communication part:
`
`The second communication part comprisesWESTIN-GUEST displays the below initial webpage which requires a “Last Name”
`and “Room Number” as a key before allowing access to additional webpages on the Internet.
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`STARWOOD Ex 1013, page 12
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`Evidence
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`Claim
`Language
`have said first
`key and does
`not provide
`access to users
`who do not
`have said first
`key, said
`second
`communication
`part allowing
`access without
`said first key;
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`STARWOOD Ex 1013, page 13
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`Evidence
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`If you select “Enter an Access Code,” WESTIN-GUEST displays the below webpage that requires an “Access Code” as a key.
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`STARWOOD Ex 1013, page 14
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`Claim
`Language
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`Evidence
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:02:1F:80 is associated with the name ‘WESTIN-GUEST’ and that users at The Westin Stonebriar Hotel can obtain
`access to one or more webpages with certain active access codes or last names and room numbers.” (Legacy Stonebriar Hotel,
`Ltd. and Legacy Stonebriar Hotel II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶
`99; Def. Starwood Hotels & Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 99.)
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`STARWOOD Ex 1013, page 15
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`Evidence
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`Alternatively, the second commuication part comprisesWESTIN-MEETING displays the below initial webpage without a key.
`The webpage requires an “Access Code” before allowing access to additional webpages on the Internet. As shown below,
`WESTIN-MEETING also displays a “Terms” and a “Need Help Connecting” webpage prior to entry of a key.
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`STARWOOD Ex 1013, page 16
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`Claim
`Language
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`Evidence
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:98:E6:07:80 is associated with the name ‘WESTIN-MEETING’ and that users at The Westin Stonebriar Hotel can obtain
`access to one or more webpages with certain active access codes.” (Legacy Stonebriar Hotel, Ltd. and Legacy Stonebriar Hotel
`II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶ 103; Def. Starwood Hotels &
`Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 103.)
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`STARWOOD Ex 1013, page 17
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`Claim
`Language
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`wherein said
`second
`communication
`part allows said
`access upon
`detecting a
`second key
`which is a
`public key, and
`does not allow
`said access
`when not
`detecting said
`second key;
`a third
`communication
`part,
`transmitting a
`separate
`communication
`stream from
`said first
`communication
`part, and
`separate from
`said second
`
`Evidence
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:98:E6:07:80 is associated with the name ‘WESTIN-MEETING’ and that users at The Westin Stonebriar Hotel can obtain
`access to one or more webpages with certain active access codes.” (Legacy Stonebriar Hotel, Ltd. and Legacy Stonebriar Hotel
`II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶ 104; Def. Starwood Hotels &
`Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 104.)
`
`On information and belief, Westin Stonebriar’s accused instrumentalities include said second communication part allow[ing]
`said access upon detecting a second key which is a public key, and []not allow[ing] said access when not detecting said second
`key.
`
`As discussed above, the identified instrumentalities that comprise the second communication part require keys for access.
`Discovery is needed to determine if the second key, as identified above, is a public key. Plaintiff requires the benefit of
`discovery before it can identify the accused instrumentality that meets this claim limitation. At the parties’ March 8, 2013 Rule
`26(f) conference, the first possible day to serve such discovery, Plaintiff served Interrogatory No. 1 and accompanying
`document requests which seek information sufficient to identify all Defendants’ networks, including those that are hidden or
`encrypted, whether such networks have access to server resources, including what type of access, and the hardware
`configurations associated with such networks. While Plaintiff has requested expedited production and responses to this
`discovery, Defendants have not yet provided such information.
`
`
`On information and belief, Westin Stonebriar’s accused instrumentalities include a third communication part, transmitting a
`separate communication stream from said first communication part, and separate from said second communication part, over
`substantially a same transmitting area as said first and second communication parts, and said third communication part
`defining a third class of service which includes a third set of permissions of access to resources, where said third set of
`permissions does not include said access to said files on said system, and allows access to only specified internet sites; wherein
`said third communication part allowing access without needing any key.
`
`The third communication party comprises “WESTIN-LOBBY” is broadcast from a device with a MAC address of
`00:3A:99:05:90:50. At least two other devices with different MAC addresses also transmit a network named WESTIN-LOBBY
`within the Westin Stonebriar property. All three networks named WESTIN-LOBBY are “Open,” which means unencrypted.
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`STARWOOD Ex 1013, page 18
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`Claim
`Language
`communication
`part, over
`substantially a
`same
`transmitting
`area as said
`first and
`second
`communication
`parts, and said
`third
`communication
`part defining a
`third class of
`service which
`includes a third
`set of
`permissions of
`access to
`resources,
`where said
`third set of
`permissions
`does not
`include said
`access to said
`files on said
`system, and
`allows access
`to only
`specified
`internet sites;
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`STARWOOD Ex 1013, page 19
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`Claim
`Language
`wherein said
`third
`communication
`part allowing
`access without
`needing any
`key.
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`Evidence
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`STARWOOD Ex 1013, page 20
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`STARWOOD Ex 1013, page 21
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`Evidence
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`On information and belief, the other WESTIN-LOBBY devices shown above similarly meet this claim limitation.
`
`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:05:90:50 is associated with the name ‘WESTIN-LOBBY’ and that at least two other devices with different MAC
`addresses are also associated with the name ‘WESTIN-LOBBY’” on the Westin Stonebriar property. (Legacy Stonebriar Hotel,
`Ltd. and Legacy Stonebriar Hotel II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶
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`STARWOOD Ex 1013, page 22
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`96; Def. Starwood Hotels & Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 96.)
`The Westin Stonebriar website admits: “[w]e offer complimentary high-speed Internet access in all of our public areas to help
`you stay connected.” http://www.westinstonebriar.com/accommodations.html
`
`WESTIN-LOBBY displays the initial internet sites shown below without a key; allows access with an "Access Code"; allows
`complimentary access to "basic websites" without a key; and displays a “Terms” webpage prior to entry of a key.
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`STARWOOD Ex 1013, page 23
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`WESTIN-LOBBY does not allow access to a server.
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:05:90:50 is associated with the name ‘WESTIN-LOBBY’ and that users at The Westin Stonebriar Hotel can obtain
`access to one or more webpages with certain active access codes.” (Legacy Stonebriar Hotel, Ltd. and Legacy Stonebriar Hotel
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`STARWOOD Ex 1013, page 24
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`Claim
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`Claim 2
`A network as in
`claim 1,
`wherein said
`first class of
`service
`includes a
`greater speed
`of network
`access than
`
`Evidence
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`II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶ 101; Def. Starwood Hotels &
`Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 101.)
`
`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:05:90:50 is associated with the name ‘WESTIN-LOBBY’ and that The Westin Stonebriar Hotel provides complimentary
`Internet access in the lobby of The Westin Stonebriar Hotel.” (Legacy Stonebriar Hotel, Ltd. and Legacy Stonebriar Hotel II,
`Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶ 102; Def. Starwood Hotels &
`Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 102.)
`
`WESTIN-LOBBY broadcast from a device with a MAC address of 00:3A:99:05:90:50 and WESTIN-GUEST broadcast from a device
`with a MAC address of 00:3A:99:02:1F:80 transmit over substantially a same transmitting area because, as shown in the
`screenshots, they are accessible from the same locations.
`
`WESTIN-LOBBY broadcast from a device with a MAC address of 00:3A:99:05:90:50 and WESTIN-MEETING broadcast from a
`device with a MAC address of 00:3A:98:E6:07:80 transmit over substantially a same transmitting area because, as shown in the
`screenshots, they are accessible from the same locations.
`
`Lone Star WiFi presently asserts that this claim element is literally present. To the extent that this claim element is found to
`not literally meet the claim element, Lone Star WiFi contends that the instrumentality identified herein is insubstantially
`different from the claimed invention of the associated patent-in-suit and therefore would infringe under the doctrine of
`equivalents.
`
`
`On information and belief, Westin Stonebriar’s accused instrumentalities include wherein said first class of service includes a
`greater speed of network access than said second class of service.
`
`Plaintiff requires the benefit of discovery before it can identify the accused instrumentality that meets this claim limitation. At
`the parties’ March 8, 2013 Rule 26(f) conference, the first possible day to serve such discovery, Plaintiff served Interrogatory
`No. 1 and accompanying document requests which seek information sufficient to identify all Defendants’ networks, including
`those that are hidden or encrypted, whether such networks have access to server resources, including what type of access,
`and the hardware configurations associated with such networks. While Plaintiff has requested expedited production and
`responses to this discovery, Defendants have not yet provided such information.
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`STARWOOD Ex 1013, page 25
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`Claim
`Language
`said second
`class of service.
`
`Claim 3
`A network as in
`claim 1,
`wherein said
`wireless
`network
`includes an
`access granting
`mechanism,
`that detects a
`user’s key, and
`automatically
`grants one of
`said first and
`second levels
`of services
`based on
`detecting one
`of said first or
`second key, or
`grants said
`third level of
`service if a user
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`Evidence
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`Plaintiff could not have legally obtained this information outside of discovery because Plaintiff would have had to access
`Defendants’ networks without sufficient permission. See, e.g., Tex. Penal Code Ann. § 33.02 (“[a] person commits an offense if
`the person knowingly accesses a computer, computer network, or computer system without the effective consent of the
`owner.”); see also the Federal Wiretap Act, 18 U.S.C.§2511 (“[e]xcept as otherwise specifically provided in this chapter any
`person who… intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to
`intercept, any wire, oral, or electronic communication… shall be punished… or shall be subject to suit… .”); see also the Pen
`Register and Trap and Trace Act, 18 U.S.C. §3121 (“[e]xcept as provided in this section, no person may install or use a pen
`register or a trap and trace device without first obtaining a court order under section 3123 of this title… .”).
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`On information and belief, Westin Stonebriar’s accused instrumentalities include wherein said wireless network includes an
`access granting mechanism, that detects a user’s key, and automatically grants one of said first and second levels of services
`based on detecting one of said first or second key, or grants said third level of service if a user is detected without said first or
`second key..
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`Plaintiff requires the benefit of discovery before it can identify the accused instrumentality that meets this claim limitation. At
`the parties’ March 8, 2013 Rule 26(f) conference, the first possible day to serve such discovery, Plaintiff served Interrogatory
`No. 1 and accompanying document requests which seek information sufficient to identify all Defendants’ networks, including
`those that are hidden or encrypted, whether such networks have access to server resources, including what type of access,
`and the hardware configurations associated with such networks. While Plaintiff has requested expedited production and
`responses to this discovery, Defendants have not yet provided such information.
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`Plaintiff could not have legally obtained this information outside of discovery because Plaintiff would have had to access
`Defendants’ networks without sufficient permission. See, e.g., Tex. Penal Code Ann. § 33.02 (“[a] person commits an offense if
`the person knowingly accesses a computer, computer network, or computer system without the effective consent of the
`owner.”); see also the Federal Wiretap Act, 18 U.S.C.§2511 (“[e]xcept as otherwise specifically provided in this chapter any
`person who… intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to
`intercept, any wire, oral, or electronic communication… shall be punished… or shall be subject to suit… .”); see also the Pen
`Register and Trap and Trace Act, 18 U.S.C. §3121 (“[e]xcept as provided in this section, no person may install or use a pen
`register or a trap and trace device without first obtaining a court order under section 3123 of this title… .”).
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` 26
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`STARWOOD Ex 1013, page 26
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`On information and belief, Westin Stonebriar’s accused instrumentalities include a first wireless network portion, including a
`first network transmitter, which is accessed by users having a first key which is a non-public key of a type that controls access,
`and which allows a first specified level of access to services, and which automatically grants access to users having said first
`key but does not grant access to users who do not have said first key.
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` A
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` first wireless network portion comprises“WESTIN-GUEST” broadcast from a device with a MAC address of 00:3A:99:02:1F:80.
`As shown in the screenshot below, a network named WESTIN-GUEST is broadcasted from a device with a MAC address of
`00:3A:99:02:1F:80. At least eight other “WESTIN-GUEST” networks are broadcast from devices with different MAC addresses
`within the Westin Stonebriar property. All nine networks named WESTIN-GUEST are “Open,” which means unencrypted.
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`Claim
`Language
`is detected
`without said
`first or second
`key.
`Claim 4
`A wireless
`network
`system,
`comprising:
`A first wireless
`network
`portion,
`including a first
`network
`transmitter,
`which is
`accessed by
`users having a
`first key which
`is a non-public
`key of a type
`that controls
`access, and
`which allows a
`first specified
`level of access
`to services, and
`which
`automatically
`grants access
`to users having
`said first key
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`STARWOOD Ex 1013, page 27
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`but does not
`grant access to
`users who do
`not have said
`first key; and
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`Evidence
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`STARWOOD Ex 1013, page 28
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`STARWOOD Ex 1013, page 29
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`STARWOOD Ex 1013, page 30
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`On information and belief, the other WESTIN-GUEST devices shown above similarly meet this claim limitation.
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:02:1F:80 is associated with the name ‘WESTIN-GUEST’ and that at least eight other devices with different MAC
`addresses are also associated with the name ‘WESTIN-GUEST’” on the Westin Stonebriar property. (Legacy Stonebriar Hotel,
`Ltd. and Legacy Stonebriar Hotel II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶
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`STARWOOD Ex 1013, page 31
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`95; Def. Starwood Hotels & Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 95.)
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`The Westin Stonebriar website admits: “Plano hotel, guest room amenities: … High Speed wired and wireless internet access.”
`http://www.westinstonebriar.com/accommodations.html
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`WESTIN-GUEST displays the below initial webpage which requires a “Last Name” and “Room Number” as a key before allowing
`access to additional webpages on the Internet.
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`STARWOOD Ex 1013, page 32
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`STARWOOD Ex 1013, page 33
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`If you select “Enter an Access Code,” WESTIN-GUEST displays the below webpage that requires an “Access Code” as a key.
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`STARWOOD Ex 1013, page 34
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`The Legacy Stonebriar entities and Starwood admitted in their Answers that “a device with a MAC address of
`00:3A:99:02:1F:80 is associated with the name ‘WESTIN-GUEST’ and that users at The Westin Stonebriar Hotel can obtain
`access to one or more webpages with certain active access codes or last names and room numbers.” (Legacy Stonebriar Hotel,
`Ltd. and Legacy Stonebriar Hotel II, Ltd.’s Answer, Affirm. Defs., and Counterclaims [sic] to Pl. Lone Star WiFi’s Complaint, at ¶
`99; Def. Starwood Hotels & Resorts Worldwide, Inc.’s Answer to Pl.’s Compl. for Patent Infringement, at ¶ 99.)
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`STARWOOD Ex 1013, page 35
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`Alternatively, a first wireless network portion may comprise a hidden network or other network. Discovery is needed to
`determine if these other networks meet this limitation. Plaintiff requires the benefit of discovery before it can identify the
`accused instrumentality that meets this claim limitation. At the parties’ March 8, 2013 Rule 26(f) conference, the first possible
`day to serve such discovery, Plaintiff served Interrogatory No. 1 and accompanying document requests which seek information
`sufficient to identify all Defendants’ networks, including those that are hidden or encrypted, whether such networks have
`access to server resources, including what type of access, and the hardware configurations associated with such networks.
`While Plaintiff has requested expedited production and responses to this discovery, Defendants have not yet provided such
`information.
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`On information and belief, the hotel has one or more hidden networks