Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 1 of 15 PageID #: 1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`CASE NO. 6:11-cv-96
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`Jury Trial Demanded
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`TRACBEAM, L.L.C., a Colorado limited
`liability company,
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` Plaintiff,
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`vs.
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`AT&T INC., a Delaware corporation; AT&T
`MOBILITY L.L.C., a Delaware limited
`liability company; METROPCS
`COMMUNICATIONS, INC., a Delaware
`corporation; METROPCS WIRELESS, INC.,
`a Delaware corporation; TEXAS RSA 7B3,
`L.P. D/B/A PEOPLES WIRELESS
`SERVICES, a Texas corporation; SPRINT
`NEXTEL CORPORATION, a Kansas
`corporation; SPRINT SPECTRUM L.P., a
`Delaware limited partnership; NEXTEL OF
`CALIFORNIA, INC., a Delaware
`corporation; NEXTEL COMMUNICATIONS
`OF THE MID-ATLANTIC, INC., a Delaware
`corporation; NEXTEL OF NEW YORK,
`INC., a Delaware corporation; NEXTEL
`SOUTH CORP., a Georgia corporation;
`NEXTEL OF TEXAS, INC., a Texas
`corporation; NEXTEL WEST CORP., a
`Delaware corporation; and CELLCO
`PARTNERSHIP d/b/a VERIZON
`WIRELESS, a Delaware partnership.
`
` Defendants.
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`COMPLAINT FOR PATENT INFRINGEMENT
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`1
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 2 of 15 PageID #: 2
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`Plaintiff TracBeam, L.L.C., (“TracBeam”), by counsel and pursuant to Federal
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`Rule of Civil Procedure 8(a), on information and belief, alleges the following in support of its
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`Complaint for patent infringement against Defendants AT&T, Inc.; AT&T Mobility, L.L.C.;
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`MetroPCS Communications, Inc.; MetroPCS Wireless, Inc.; Texas RSA 7B3, L.P. d/b/a Peoples
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`Wireless Services; Sprint Nextel Corporation; Sprint Spectrum, L.P.; Nextel of California, Inc.;
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`Nextel Communications of the Mid-Atlantic, Inc.; Nextel of New York, Inc.; Nextel South
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`Corp.; Nextel of Texas, Inc.; Nextel West Corp., and Cellco Partnership d/b/a Verizon Wireless
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`(collectively “Defendants”):
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`
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`Introduction
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`1.
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`Plaintiff TracBeam owns the inventions described and claimed in United
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`States Patent Nos. 7,764,231 entitled “Wireless Location Using Multiple Mobile Station
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`Location Techniques” (the “„231 patent”) and 7,525,484 entitled “Gateway and Hybrid Solutions
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`for Wireless Location” (the “„484 patent”) (collectively “the Patents”). Defendants have used
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`and continue to use Plaintiff‟s patented technology in products and/or services that they make,
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`use, import, sell, and/or offer to sell. TracBeam seeks damages for patent infringement and an
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`injunction preventing Defendants from making, using, selling, or offering to sell, and from
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`contributing to and inducing others to make, use, sell, or offer to sell, the technology claimed by
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`the Patents without Plaintiff‟s permission.
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`Plaintiff TracBeam
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`2.
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`Plaintiff TracBeam is a limited liability company existing under and by
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`virtue of the laws of the State of Colorado.
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`2
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
`
`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 3 of 15 PageID #: 3
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`Defendants
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`AT&T Defendants
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`3.
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`AT&T, Inc. is a Delaware corporation with its principal place of business
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`in Dallas, Texas.
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`4.
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`AT&T Mobility, L.L.C. is a Delaware limited liability company with its
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`principal place of business in Atlanta, Georgia. (AT&T, Inc. and AT&T Mobility, L.L.C. are
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`collectively referred to as “AT&T” or the “AT&T Defendants.”)
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`MetroPCS Defendants
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`5.
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`MetroPCS Communications, Inc. is a Delaware corporation with its
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`principal place of business in Richardson, Texas.
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`6.
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`MetroPCS Wireless, Inc. is a Delaware corporation with its principal place
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`of business in Richardson, Texas. (MetroPCS Communications, Inc. and MetroPCS Wireless,
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`Inc. are collectively referred to as “MetroPCS” or the “MetroPCS Defendants.”)
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`Peoples Defendant
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`7.
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`Texas RSA 7B3, L.P. d/b/a Peoples Wireless Services (“Peoples”) is a
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`Texas corporation with its principal place of business in Quitman, Texas.
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`Sprint Nextel Defendants
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`8.
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`Sprint Nextel Corporation is a Kansas corporation with its principal place
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`of business in Overland Park, Kansas.
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`9.
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`Sprint Spectrum, L.P. is a Delaware limited partnership with its principal
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`place of business in Overland Park, Kansas.
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`10.
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`Nextel of California, Inc. is a Delaware corporation with its principal
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`place of business in Overland Park, Kansas.
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`3
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 4 of 15 PageID #: 4
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`11.
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`Nextel Communications of the Mid-Atlantic, Inc. is a Delaware
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`corporation with its principal place of business in Overland Park, Kansas.
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`12.
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`Nextel of New York, Inc. is a Delaware corporation with its principal
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`place of business in Overland Park, Kansas.
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`13.
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`Nextel South Corp. is a Georgia corporation with its principal place of
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`business in Overland Park, Kansas.
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`14.
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`Nextel of Texas, Inc. is a Texas corporation with its principal place of
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`business in Overland Park, Kansas.
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`15.
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`Nextel West Corp. is a Delaware corporation with its principal place of
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`business in Overland Park, Kansas. (Sprint Nextel Corporation; Sprint Spectrum, L.P.; Nextel of
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`California, Inc.; Nextel Communications of the Mid-Atlantic, Inc.; Nextel of New York, Inc.;
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`Nextel South Corp.; Nextel of Texas, Inc.; and Nextel West Corp are collectively reffered to as
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`“Sprint Nextel” or the “Sprint Nextel Defendants.”)
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`Verizon Defendant
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`16.
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`Cellco Partership d/b/a Verizon Wireless (“Verizon”) is a Delaware
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`partnership with its principal place of business in Basking Ridge, New Jersey.
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`The Patents
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`17.
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`The United States Patent and Trademark Office issued the „231 patent
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`(attached as exhibit A) on July 27, 2010; and the „484 patent (attached as exhibit B) on April 28,
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`2009. Through assignment, Plaintiff is the owner of all right, title, and interest in the Patents,
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`including all rights to pursue and collect damages for infringement of the Patents.
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`4
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 5 of 15 PageID #: 5
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`Jurisdiction and Venue
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`18.
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`This is an action for patent infringement arising under the patent laws of
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`the United States, 35 U.S.C. §§ 271 and 281, et seq. The Court has original jurisdiction over this
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`patent infringement action under 28 U.S.C. § 1338(a).
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`19.
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`Each of the Defendants has committed acts and continues to commit acts
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`within this judicial district giving rise to this action. Venue is proper in this district pursuant to
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`28 U.S.C. § 1391(b) and § 1400.
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`First Claim for Patent Infringement
`(Infringement of the ‘231 patent)
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`20.
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`Plaintiff incorporates by reference each of the allegations in paragraphs 1 -
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`19 above and further alleges as follows:
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`21.
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`The United States Patent and Trademark Office issued the „231 patent on
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`July 27, 2010. Plaintiff is the owner of the „231 patent with full rights to pursue recovery of
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`royalties or damages for infringement of said patent, including full rights to recover past and
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`future damages.
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`22. Without a license or permission from Plaintiff, AT&T has infringed and is
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`continuing to infringe one or more claims of the „231 patent and, unless enjoined, will continue
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`to do so, by making, using, providing, selling, offering for sale, or importing infringing products
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`and services. AT&T‟s infringing products and services include, without limitation, its products
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`and services for determining the locations of wireless mobile devices (e.g., the locations of
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`AT&T subscribers‟ cellular phones). AT&T, which has knowledge of the „231 patent, has also
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`actively and knowingly contributed to and induced, and continues to actively and knowingly
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`contribute to and induce, infringement by users of AT&T‟s products and services.
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`5
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 6 of 15 PageID #: 6
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`23.
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`AT&T‟s infringement of the „231 patent has been and continues to be
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`willful. AT&T knew of a provisional patent application that led to the „231 patent as early as
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`1996, and AT&T knew or should have known of the „231 patent upon its issuance. AT&T has
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`disregarded and continues to disregard an objectively high likelihood that its actions constitute
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`infringement of the „231 patent. This objectively-defined risk has been known or so obvious that
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`it should have been known to AT&T.
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`24.
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`As a result of AT&T‟s infringement of the „231 patent, Plaintiff has been
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`damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`determined, and will suffer an impairment of the value of its patent rights unless AT&T is
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`enjoined from continuing to infringe the „231 patent.
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`25.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`AT&T to compensate it for AT&T‟s infringement of the „231 patent.
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`26. Without a license or permission from Plaintiff, MetroPCS has infringed
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`and is continuing to infringe one or more claims of the „231 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
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`products and services. MetroPCS‟s infringing products and services include, without limitation,
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`its products and services for determining the locations of wireless mobile devices (e.g., the
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`locations of MetroPCS subscribers‟ cellular phones). MetroPCS, which has knowledge of the
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`„231 patent, has also actively and knowingly contributed to and induced, and continues to
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`actively and knowingly contribute to and induce, infringement by users of MetroPCS‟s products
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`and services.
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`27.
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`As a result of MetroPCS‟s infringement of the „231 patent, Plaintiff has
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`been damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`6
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 7 of 15 PageID #: 7
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`determined, and will suffer an impairment of the value of its patent rights unless MetroPCS is
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`enjoined from continuing to infringe the „231 patent.
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`28.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`MetroPCS to compensate it for MetroPCS‟s infringement of the „231 patent.
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`29. Without a license or permission from Plaintiff, Sprint Nextel has infringed
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`and is continuing to infringe one or more claims of the „231 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
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`products and services. Sprint Nextel‟s infringing products and services include, without
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`limitation, its products and services for determining the locations of wireless mobile devices
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`(e.g., the locations of Sprint Nextel subscribers‟ cellular phones). Sprint Nextel, which has
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`knowledge of the „231 patent, has also actively and knowingly contributed to and induced, and
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`continues to actively and knowingly contribute to and induce, infringement by users of Sprint
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`Nextel‟s products and services.
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`30.
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`Sprint Nextel‟s infringement of the „231 patent has been and continues to
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`be willful. Sprint Nextel knew of a provisional patent application that led to the „231 patent as
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`early as 1996, and Sprint Nextel knew or should have known of the „231 patent upon its
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`issuance. Sprint Nextel has disregarded and continues to disregard an objectively high likelihood
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`that its actions constitute infringement of the „231 patent. This objectively-defined risk has been
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`known or so obvious that it should have been known to Sprint Nextel.
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`31.
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`As a result of Sprint Nextel‟s infringement of the „231 patent, Plaintiff has
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`been damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`determined, and will suffer an impairment of the value of its patent rights unless Sprint Nextel is
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`enjoined from continuing to infringe the „231 patent.
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`7
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 8 of 15 PageID #: 8
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`32.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`Sprint Nextel to compensate it for Sprint Nextel‟s infringement of the „231 patent.
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`33. Without a license or permission from Plaintiff, Verizon has infringed and
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`is continuing to infringe one or more claims of the „231 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
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`products and services. Verizon‟s infringing products and services include, without limitation, its
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`products and services for determining the locations of wireless mobile devices (e.g., the locations
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`of Verizon subscribers‟ cellular phones). Verizon, which has knowledge of the „231 patent, has
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`also actively and knowingly contributed to and induced, and continues to actively and knowingly
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`contribute to and induce, infringement by users of Verizon‟s products and services.
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`34.
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`Verizon‟s infringement of the „231 patent has been and continues to be
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`willful. Verizon (or one of its predecessor corporations) knew of a provisional patent
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`application that led to the „231 patent as early as 1996, and Verizon knew or should have known
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`of the „231 patent upon its issuance. Verizon has disregarded and continues to disregard an
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`objectively high likelihood that its actions constitute infringement of the „231 patent. This
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`objectively-defined risk has been known or so obvious that it should have been known to
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`Verizon.
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`35.
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`As a result of Verizon‟s infringement of the „231 patent, Plaintiff has been
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`damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`determined, and will suffer an impairment of the value of its patent rights unless Verizon is
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`enjoined from continuing to infringe the „231 patent.
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`36.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`Verizon to compensate it for Verizon‟s infringement of the „231 patent.
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`8
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 9 of 15 PageID #: 9
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`Second Claim for Patent Infringement
`(Infringement of the ‘484 patent)
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`37.
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`Plaintiff incorporates by reference each of the allegations in paragraphs 1
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`– 19 above and further alleges as follows:
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`38.
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`The United States Patent and Trademark Office issued the „484 patent on
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`April 28, 2009. Plaintiff is the owner of the „484 patent with full rights to pursue recovery of
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`royalties or damages for infringement of said patent, including full rights to recover past and
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`future damages.
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`39. Without a license or permission from Plaintiff, AT&T has infringed and is
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`continuing to infringe one or more claims of the „484 patent and, unless enjoined, will continue
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`to do so, by making, using, providing, selling, offering for sale, or importing infringing products
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`and services. AT&T‟s infringing products and services include, without limitation, its products
`
`and services for determining the locations of wireless mobile devices (e.g., the locations of
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`AT&T subscribers‟ cellular phones). AT&T, which has knowledge of the „484 patent, has also
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`actively and knowingly contributed to and induced, and continues to actively and knowingly
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`contribute to and induce, infringement by users of AT&T‟s products and services.
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`40.
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`AT&T‟s infringement of the „484 patent has been and continues to be
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`willful. AT&T knew of a provisional patent application that led to the „484 patent as early as
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`1996, and AT&T knew or should have known of the „484 patent upon its issuance. AT&T has
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`disregarded and continues to disregard an objectively high likelihood that its actions constitute
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`infringement of the „484 patent. This objectively-defined risk has been known or so obvious that
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`it should have been known to AT&T.
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`41.
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`As a result of AT&T‟s infringement of the „484 patent, Plaintiff has been
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`damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`9
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 10 of 15 PageID #: 10
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`determined, and will suffer an impairment of the value of its patent rights unless AT&T is
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`enjoined from continuing to infringe the „484 patent.
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`42.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`AT&T to compensate it for AT&T‟s infringement of the „484 patent.
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`43. Without a license or permission from Plaintiff, MetroPCS has infringed
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`and is continuing to infringe one or more claims of the „484 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
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`products and services. MetroPCS‟s infringing products and services include, without limitation,
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`its products and services for determining the locations of wireless mobile devices (e.g., the
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`locations of MetroPCS subscribers‟ cellular phones). MetroPCS, which has knowledge of the
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`„484 patent, has also actively and knowingly contributed to and induced, and continues to
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`actively and knowingly contribute to and induce, infringement by users of MetroPCS‟s products
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`and services.
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`44.
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`As a result of MetroPCS‟s infringement of the „484 patent, Plaintiff has
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`been damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`determined, and will suffer an impairment of the value of its patent rights unless MetroPCS is
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`enjoined from continuing to infringe the „484 patent.
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`45.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`MetroPCS to compensate it for MetroPCS‟s infringement of the „484 patent.
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`46. Without a license or permission from Plaintiff, Peoples has infringed and
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`is continuing to infringe one or more claims of the „484 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
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`products and services. Peoples‟ infringing products and services include, without limitation, its
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`10
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 11 of 15 PageID #: 11
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`products and services for determining the locations of wireless mobile devices (e.g., the locations
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`of Peoples subscribers‟ cellular phones). Peoples, which has knowledge of the „484 patent, has
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`also actively and knowingly contributed to and induced, and continues to actively and knowingly
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`contribute to and induce, infringement by users of Peoples‟ products and services.
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`47.
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`As a result of Peoples‟ infringement of the „484 patent, Plaintiff has been
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`damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`determined, and will suffer an impairment of the value of its patent rights unless Peoples is
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`enjoined from continuing to infringe the „484 patent.
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`48.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`Peoples to compensate it for Peoples‟ infringement of the „484 patent.
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`49. Without a license or permission from Plaintiff, Sprint Nextel has infringed
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`and is continuing to infringe one or more claims of the „484 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
`
`products and services. Sprint Nextel‟s infringing products and services include, without
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`limitation, its products and services for determining the locations of wireless mobile devices
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`(e.g., the locations of Sprint Nextel subscribers‟ cellular phones). Sprint Nextel, which has
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`knowledge of the „484 patent, has also actively and knowingly contributed to and induced, and
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`continues to actively and knowingly contribute to and induce, infringement by users of Sprint
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`Nextel‟s products and services.
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`50.
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`Sprint Nextel‟s infringement of the „484 patent has been and continues to
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`be willful. Sprint Nextel knew of a provisional patent application that led to the „484 patent as
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`early as 1996, and Sprint Nextel knew or should have known of the „484 patent upon its
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`issuance. Sprint Nextel has disregarded and continues to disregard an objectively high likelihood
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`11
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 12 of 15 PageID #: 12
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`that its actions constitute infringement of the „484 patent. This objectively-defined risk has been
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`known or so obvious that it should have been known to Sprint Nextel.
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`51.
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`As a result of Sprint Nextel‟s infringement of the „484 patent, Plaintiff has
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`been damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
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`determined, and will suffer an impairment of the value of its patent rights unless Sprint Nextel is
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`enjoined from continuing to infringe the „484 patent.
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`52.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
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`Sprint Nextel to compensate it for Sprint Nextel‟s infringement of the „484 patent.
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`53. Without a license or permission from Plaintiff, Verizon has infringed and
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`is continuing to infringe one or more claims of the „484 patent and, unless enjoined, will
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`continue to do so, by making, using, providing, selling, offering for sale, or importing infringing
`
`products and services. Verizon‟s infringing products and services include, without limitation, its
`
`products and services for determining the locations of wireless mobile devices (e.g., the locations
`
`of Verizon subscribers‟ cellular phones). Verizon, which has knowledge of the „484 patent, has
`
`also actively and knowingly contributed to and induced, and continues to actively and knowingly
`
`contribute to and induce, infringement by users of Verizon‟s products and services.
`
`54.
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`Verizon‟s infringement of the „484 patent has been and continues to be
`
`willful. Verizon (or one of its predecessor corporations) knew of a provisional patent
`
`application that led to the „484 patent as early as 1996, and Verizon knew or should have known
`
`of the „484 patent upon its issuance. Verizon has disregarded and continues to disregard an
`
`objectively high likelihood that its actions constitute infringement of the „484 patent. This
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`objectively-defined risk has been known or so obvious that it should have been known to
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`Verizon.
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`12
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`

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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 13 of 15 PageID #: 13
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`55.
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`As a result of Verizon‟s infringement of the „484 patent, Plaintiff has been
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`damaged by and will continue to suffer additional, irreparable damage, in an amount not yet
`
`determined, and will suffer an impairment of the value of its patent rights unless Verizon is
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`enjoined from continuing to infringe the „484 patent.
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`56.
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`Pursuant to 35 U.S.C. § 281, Plaintiff is entitled to recover damages from
`
`Verizon to compensate it for Verizon‟s infringement of the „484 patent.
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`Jury Demand
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`57.
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`Plaintiff demands trial by jury of all issues relating to its claims regarding
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`the „231 and „484 patents.
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`WHEREFORE, Plaintiff prays for judgment as follows:
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`Prayer for Relief
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`A.
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`A judgment in favor of Plaintiff that (a) AT&T, MetroPCS, Sprint, and Verizon
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`have infringed the „231 patent, and (b) AT&T, MetroPCS, Peoples, Sprint, and
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`Verizon have infringed the „484 patent;
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`B.
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`A judgment and order finding that AT&T, Sprint, and Verizon have willfully
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`infringed the „231 and „484 patents;
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`C.
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`A decree preliminarily and permanently enjoining (a) AT&T, MetroPCS, Sprint,
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`and Verizon, their officers, directors, employees, agents, and all persons in active
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`concert with them, from infringing, and contributing to or inducing others to
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`infringe the „231 patent; and (b) AT&T, MetroPCS, Peoples, Sprint, and Verizon,
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`their officers, directors, employees, agents, and all persons in active concert with
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`them, from infringing, and contributing to or inducing others to infringe the „484
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`patent;
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`13
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 14 of 15 PageID #: 14
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`D.
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`A judgment and order requiring (a) AT&T, MetroPCS, Sprint, and Verizon to pay
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`Plaintiff compensatory damages, costs, expenses, and pre- and post-judgment
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`interest for Defendants‟ infringement of the „231 patent, as provided under 35
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`U.S.C. § 284; and (b) AT&T, MetroPCS, Peoples, Sprint, and Verizon to pay
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`Plaintiff compensatory damages, costs, expenses, and pre- and post-judgment
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`interest for Defendants‟ infringement of the „484 patent, as provided under 35
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`U.S.C. § 284;
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`E.
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`A judgment and order finding that this patent infringement case is exceptional
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`within the meaning of 35 U.S.C. § 285 and awarding Plaintiff its reasonable
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`attorneys‟ fees; and
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`F.
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`Any and all other relief to which Plaintiff may be entitled.
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`Respectfully submitted,
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`By: /s/ S. Calvin Capshaw
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`S. Calvin Capshaw
`State Bar No. 03783900
`Elizabeth L. DeRieux
`State Bar No. 05770585
`CAPSHAW DERIEUX, L.L.P.
`114 E. Commerce Ave.
`Gladewater, Texas 75647
`Telephone: (903) 236-9800
`Facsimile: (903) 236-8787
`Email: capshaw@capshawlaw.com
`Email: ederieux@capshawlaw.com
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`
`Gregory S. Dovel
`CA State Bar No. 135387
`Email: greg@dovellaw.com
`Richard E. Lyon
`CA State Bar No. 229288
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`14
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`Dated: February 25, 2011
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam
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`Case 6:11-cv-00096-LED Document 1 Filed 02/25/11 Page 15 of 15 PageID #: 15
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`
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`Email: rick@dovellaw.com
`DOVEL & LUNER, LLP
`201 Santa Monica Blvd., Suite 600
`Santa Monica, CA 90401
`Telephone: 310-656-7066
`Facsimile: 310-657-7069
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`Robert Christopher Bunt
`State Bar No. 00787165
`Email: cbunt@cox-internet.com
`PARKER & BUNT, P.C.
`100 East Ferguson, Ste. 1114
`Tyler, TX 75702
`Telephone: 903/531-3535
`Facsimile: 903/533-9687
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`ATTORNEYS FOR PLAINTIFF
`TRACBEAM, L.L.C.
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`T-Mobile / TCS / Ericsson EXHIBIT 1019
`T-Mobile / TCS / Ericsson v. TracBeam