Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 1 of 15 PageID #: 1
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`C.A. No. 2:16-cv-0012
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`JURY TRIAL REQUESTED
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`MOBILE TELECOMMUNICATIONS
`TECHNOLOGIES, LLC,
`
`
`Plaintiff,
`
`v.
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`ARUBA NETWORKS, INC.; HEWLETT
`PACKARD ENTERPRISE COMPANY;
`and HP INC.
`
`Defendants.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff Mobile Telecommunications Technologies, LLC (“MTel”), by and through its
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`undersigned counsel, files this complaint against Defendants Aruba Networks, Inc. Hewlett-
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`Packard Enterprise Company, and HP Inc. (collectively, “Aruba,” “HP” or “Defendants”) for
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`infringement of U.S. Patent Nos. 5,590,403 (the “’403 Patent”), 5,659,891 (the “’891 Patent”),
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`and 5,915,210 (the “’210 Patent”), (collectively, the “Asserted Patents” or the “Patents-in-Suit”)
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`in accordance with 35 U.S.C. § 271 and alleges as follows:
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`PARTIES
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`1.
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`Plaintiff MTel is a Delaware limited liability company having a principal place of
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`business at 1720 Lakepointe Drive, Suite 100, Lewisville, Texas 75057.
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`2.
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`MTel is a wholly owned subsidiary of United Wireless Holdings Inc. (“United
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`Wireless”). In 2008, United Wireless, through another of its wholly owned subsidiaries,
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`Velocita Wireless LLC, purchased the SkyTel wireless network, including assets related to
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`SkyTel’s more than twenty-year history as a wireless data company. Velocita Wireless LLC,
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`continued to operate the SkyTel wireless data network after the acquisition. As a result of that
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`Petitioners, Ex. 1002, Page 1
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 2 of 15 PageID #: 2
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`transaction, United Wireless gained ownership and control over the intellectual property
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`portfolio,
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`including patents,
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`that
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`several SkyTel-related entities,
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`including Mobile
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`Telecommunication Technologies Corp. (“MTel Corp.”), Destineer Corp., and SkyTel
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`Communications, developed over the years. United Wireless subsequently assigned certain
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`patent assets, including the Patents-in-Suit, together with all rights of recovery related to those
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`patent assets, to its wholly owned subsidiary, MTel, which is the plaintiff here.
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`3.
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`In a widely publicized November, 2014 jury trial in this District, MTel was
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`awarded favorable infringement and validity verdicts against Apple, Inc. on the ’403, ’210, and
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`’891 Patents.
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`4.
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`MTel alleges, upon information and belief, that HP, Inc. is a corporation
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`organized under the laws of Delaware, with a place of business in Texas at 5400 Legacy Drive,
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`Plano, Texas 75024. HP, Inc. may be served with process through its registered agent, CT
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`Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201-3136.
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`5.
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`MTel alleges, upon information and belief, that Hewlett Packard Enterprise
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`Company is a corporation organized under the laws of Delaware, with a place of business in
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`Texas at 5400 Legacy Drive, Plano, Texas 75024. Hewlett Packard Enterprise Company may be
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`served with process through its registered agent, CT Corporation System, 1999 Bryan Street,
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`Suite 900, Dallas, Texas 75201-3136.
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`6.
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`MTel alleges, upon information and belief, that Aruba Networks, Inc. is a
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`corporation organized under the laws of Delaware. Aruba was acquired by HP in 2015, in a
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`transaction completed on May 19, 2015. Aruba is now a wholly-owned subsidiary of HP, but
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`remains separately incorporated. Aruba may be served with process through its registered agent,
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`CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201-3136.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`2
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`Petitioners, Ex. 1002, Page 2
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 3 of 15 PageID #: 3
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`7.
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`Upon information and belief, MTel alleges that Defendants made, used, sold, and
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`offered to sell, infringing wireless equipment and services, during the terms of the ’403 Patent,
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`the ’210 Patent, and the ’891 Patent (the “Relevant Period,”) within the United States, including
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`within this District.
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`8.
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`Aruba is a leader in high-performance networking technology, including wireless
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`local networks (LANs).
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`9.
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`MTel alleges that Aruba used wireless access points, WLAN controllers,
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`gateways, and associated software that supports IEEE 802.11 a, g, n or ac standards (“Wi-Fi
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`Equipment”) to deploy and manage enterprise and service provider Wi-Fi networks during the
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`Relevant Period.
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`10.
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`Aruba’s Wi-Fi Equipment includes Access Points, such as the Aruba 220 Series
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`and Instant Access RAP-100 Series, Wireless Mesh Routers, Mobility Controllers, such as the
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`Aruba 7200 Series Mobility Controllers, and associated software, such as ArubaOS and modules,
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`including Aruba’s Policy Enforcement Firewall, RFProtect, Aruba Adaptive Radio Management,
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`and ClientMatch.
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`11. MTel alleges that, in addition to its Aruba line of products and service, HP made,
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`used, sold, and offered to sell, wireless access points, WLAN controllers, gateways, and
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`associated software that supports IEEE 802.11 g, n or ac standards (“Wi-Fi Equipment”) to
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`deploy and manage Wi-Fi networks during the Relevant Period.
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`12.
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`HP’s Wi-Fi Equipment includes its HP Jetdirect 2700w Wireless Print Server
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`with HP Color LaserJet Enterprise M885 and its HP E-MSM460 Dual Radio 802.11n Access
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`Point.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`3
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`Petitioners, Ex. 1002, Page 3
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 4 of 15 PageID #: 4
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`13.
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`Defendants’ Wi-Fi Equipment supported Space Time Blocking Coding (STBC).
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`See Exhibit E for a list of Defendants’ Wi-Fi Equipment that supports STBC. This list is non-
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`limiting and will be supplemented after appropriate discovery.
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`http://community.arubanetworks.com/aruba/attachments/aruba/unified-wired-wireless-
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`access/19417/1/DS_AP130Series.pdf
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`4
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`Petitioners, Ex. 1002, Page 4
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 5 of 15 PageID #: 5
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`14.
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`During the Relevant Period, Defendants’ professional services teams designed,
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`engineered, deployed, supported, and operated Wi-Fi networks in apartment buildings, hotels,
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`sports venues, and public areas.
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`15.
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`Defendants’ deployment services teams, including Aruba’s service delivery
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`engineers, installed, configured, tested, or commissioned deployments that include Wi-Fi
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`Equipment.
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`16.
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`Defendants’ engineers developed and executed test cases to thoroughly validate
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`Wi-Fi Equipment.
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`17.
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`Defendants controlled the features and functionality of Wi-Fi Equipment by, for
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`instance, causing software (e.g. updates or firmware) to be downloaded to such equipment and
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`otherwise making configuration changes thereto.
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`18. MTel alleges that, during the Relevant Period, Defendants made, used, sold, and
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`offered to sell, wireless equipment and services, including Wi-Fi Equipment, which directly
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`infringed the claims of the ’403 Patent, the ’210 Patent, and the ’891 Patent, within the United
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`States, including within this District.
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`19. MTel alleges that Defendants made, used, sold, and offered to sell, systems and
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`products that embodied the claimed methods of the Patents-in-Suit because, for instance, such
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`systems and products employed certain subcarrier frequency structures in the IEEE 802.11
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`orthogonal frequency-division multiplexing (“OFDM”) scheme or techniques consistent with the
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`MIMO aspects of IEEE 802.11 n or ac standards (e.g., as described in “Wi-Fi CERTIFIED n:
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`Longer-Range, Faster-Throughput, Multimedia-Grade Wi-Fi Networks” at 5-6, available at
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`http://www.wi-fi.org/file/wi-fi-certified-n-longer-range-faster-throughput-multimedia-grade-wi-
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`fi-networks-2009):
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`5
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`Petitioners, Ex. 1002, Page 5
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 6 of 15 PageID #: 6
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`A MIMO system has some number of transmitters (N) and receivers (M) ... Signals from
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`each of the N transmitters can reach each of the M receivers via a different path in the
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`channel. A MIMO device with multiple antennas is capable of sending multiple spatial
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`streams – spatially distinct data streams within the same channel. A MIMO device with
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`multiple antennas is capable of receiving multiple spatial streams. Multipath helps
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`decorrelate the received signals enabling transmission of multiple data streams through
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`the same MIMO channel – a technique called spatial multiplexing. MIMO can multiply
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`data rate through a technique called spatial multiplexing - dividing a data stream into
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`several branches and sending it as multiple parallel data streams simultaneously in the
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`same channel.
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`A copy of this document is attached as Exhibit D.
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`20. MIMO can also be used to improve the robustness and range of 802.11n
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`communications through a technique called spatial diversity. When the same data stream is
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`transmitted across multiple spatial streams error rate can be reduced. An additional technique
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`improving range and reliability called Space Time Block Coding (STBC) is also incorporated
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`into Wi-Fi CERTIFIED n.
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`21.
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`On information and belief, Defendants have voluntarily and purposely placed
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`these and other products and services into the stream of commerce with the expectation that they
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`would be offered for sale and sold in Texas and in this judicial district.
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`JURISDICTION AND VENUE
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`22.
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`This is an action for patent infringement under the patent laws of the United
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`States of America, 35 U.S.C. § 1 et seq. This Court has subject matter jurisdiction over the
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`6
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`Petitioners, Ex. 1002, Page 6
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 7 of 15 PageID #: 7
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`matters pleaded in this complaint under 28 U.S.C. §§ 1331 and 1338(a). Venue is proper under
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`28 U.S.C. §§ 1391 and 1400(b).
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`23.
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`This Court has personal jurisdiction over the Defendants under the law of the
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`State of Texas, including the Texas long-arm statute, Tex. Civ. Prac. & Rem. Code § 17.042, due
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`at least to its substantial business in this forum, including: (i) at least a portion of the
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`infringements alleged herein; (ii) conducting business within this District at its office in Plano,
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`Texas; and (iii) regularly doing or soliciting business, engaging in other persistent courses of
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`conduct, and/or deriving substantial revenue from goods and services provided to individuals in
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`Texas and in this judicial district.
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`FIRST CLAIM FOR RELIEF
`(Infringement of Claims 1, 10, 11 of United States Patent No. 5,590,403)
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`24. MTel incorporates by reference the preceding paragraphs of this Complaint as if
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`set forth here in full.
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`25.
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`The United States Patent and Trademark Office (“USPTO”) duly and lawfully
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`issued the ’403 Patent, entitled “Method and System for Efficiently Providing Two Way
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`Communication between a Central Network and Mobile Unit,” on December 31, 1996. MTel is
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`the assignee of all right, title, and interest in and to the ’403 Patent and possesses the exclusive
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`right of recovery, including the exclusive right to recover for past infringement. Each and every
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`claim of the ’403 Patent is valid and enforceable and each enjoys a statutory presumption of
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`validity separate, apart, and in addition to the statutory presumption of validity enjoyed by every
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`other of its claims. 35 U.S.C. § 282. A true and correct copy of the ’403 Patent is attached as
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`Exhibit A.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`7
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`Petitioners, Ex. 1002, Page 7
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 8 of 15 PageID #: 8
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`26. MTel alleges that, during the Relevant Period, Defendants directly infringed one
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`or more claims of the ’403 Patent by making, using, selling, and offering to sell Wi-Fi
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`Equipment and associated services.
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`27. MTel alleges that Defendants’ use of Wi-Fi Equipment infringed one or more
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`claims of the ’403 Patent literally and/or under the doctrine of equivalents, by, among other
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`things, using MIMO functionality and dynamically reassigning transmitters due to changing
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`conditions within the network.
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`28.
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`Defendants implemented through their Wi-Fi networks, services, and equipment
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`the IEEE 802.11 standard versions n and ac, which employed MIMO technology in several
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`variations to significantly increase data rates and coverage relative to the previous versions of the
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`standard. The different MIMO configurations implemented by Defendants provide facilities to
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`dynamically optimize system transmission for a desired level of robustness and diversity or
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`capacity gain, depending on signal-to-noise ratio (SNR) and channel conditions.
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`29.
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`The main relevant MIMO techniques that Defendants used include (i) Spatial
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`Multiplexing (SM); (ii) Space Time Block Coding (STBC); (iii) Spatial Expansion (SE); (iv)
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`Beam Forming (BF); and (v) HT Duplicate mode (MCS 32).
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`30. MTel alleges that Defendants’ use, operation, and maintenance of Wi-Fi
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`Equipment directly infringed the ’403 Patent, at least because such equipment employed MIMO
`
`techniques described above.
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`31. MTel alleges that Defendants’ use and sale of Wi-Fi Equipment, such as the
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`Aruba 220 Series and Instant Access RAP-100 Series access points, directly infringed the ’403
`
`Patent at least because such equipment embodies the asserted method claims of the ’403 Patent.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`8
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`Petitioners, Ex. 1002, Page 8
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`

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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 9 of 15 PageID #: 9
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`32. MTel alleges that Defendants directly infringed the ’403 Patent when their service
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`professionals used, installed, tested, deployed, or validated Wi-Fi Equipment.
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`33. MTel alleges that Defendants directly infringed the ’403 Patent when, for
`
`example, their technicians tested the throughput that such Wi-Fi Equipment achieved during
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`testing in various wireless channel conditions that triggered adaptations in transmission modes.
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`34. MTel alleges that Defendants directly infringed the ’403 Patent when they used
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`Wi-Fi Equipment, including the Instant Access Series, Aruba 7200 Series Mobility Controllers,
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`Aruba Adaptive Radio Management, and ClientMatch, to dynamically reassign transmitters due
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`to changing conditions within the wireless network to enable a Wi-Fi connected device to
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`seamlessly roam between zones of the Wi-Fi network.
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`35.
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`As a result of Defendants’ unlawful infringement of the ’403 Patent, MTel has
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`suffered damage. MTel is entitled to recover from Defendants damages adequate to compensate
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`for such infringement.
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`SECOND CLAIM FOR RELIEF
`(Infringement of Claims 1, 2, 3, 4 and 5 of United States Patent No. 5,659,891)
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`36. MTel incorporates by reference the preceding paragraphs of this Complaint as if
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`set forth here in full.
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`37.
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`The USPTO duly and lawfully issued the ’891 Patent, entitled “Multicarrier
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`Techniques in Bandlimited Channels,” on August 19, 1997. MTel is the assignee of all right,
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`title, and interest in and to the ’891 Patent and possesses the exclusive right of recovery,
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`including the exclusive right to recover for past, present, and future infringement. Each and
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`every claim of the ’891 Patent is valid and enforceable and each enjoys a statutory presumption
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`of validity separate, apart, and in addition to the statutory presumption of validity enjoyed by
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`9
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`Petitioners, Ex. 1002, Page 9
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 10 of 15 PageID #: 10
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`every other of its claims. 35 U.S.C. § 282. A true and correct copy of the ’891 Patent is attached
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`as Exhibit B.
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`38. MTel alleges that, during the Relevant Period, Defendants directly infringed one
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`or more claims of the ’891 Patent by making, using, selling, and offering to sell Wi-Fi
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`Equipment, and associated services.
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`39. MTel alleges, upon information and belief, that Defendants’ Wi-Fi networks and
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`equipment directly infringed one or more claims of the ’891 Patent literally and/or under the
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`doctrine of equivalents, by among other things, using certain subcarrier frequency structures of
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`the IEEE 802.11 orthogonal frequency-division multiplexing (“OFDM”) scheme.
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`40.
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`OFDM systems contain individual subcarriers that are orthogonally spaced apart
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`in the frequency domain such that they do not interfere with each other as shown in the figure
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`below. To illustrate this concept, the power spectrum for four modulated subcarriers is shown in
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`the below figure, with solid, dotted, dash-dotted, and dashed lines, respectively. It can be seen
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`that, at the center frequency of each subcarrier, the power spectra of the other subcarriers have
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`nulls in the spectrum and thus do not produce interference.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`10
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`Petitioners, Ex. 1002, Page 10
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 11 of 15 PageID #: 11
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`41. MTel alleges, for example, that Defendants directly infringed claims of the ’891
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`Patent in regards to the 802.11 systems that its Wi-Fi Equipment implemented. For instance,
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`when such equipment was using the 20 MHz channel bandwidth option, 64 subcarriers could fit
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`into the available bandwidth of 20 MHz because 20 MHz = 64 x 312.5 kHz. In the 802.11
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`systems of interest, the orthogonal subcarrier spacing (ΔF) is 312.5 kHz. However, because of
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`spectral band limitations, several subcarriers on each side of the band are not employed to
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`minimize interference to adjacent channels and meet the transmit spectrum mask imposed by
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`regulatory requirements. Since in the 20 MHz channel there are 10 MHz on both sides of the
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`center frequency, the frequency separation from the outermost used subcarrier to the band edge
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`is 1,250 kHz which corresponds to 4x ΔF, i.e. four times the inter-subcarrier frequency
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`separation. Thus, by avoiding transmission on the outermost subcarriers, a guard-band is created
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`that allows meeting the frequency mask restriction and enables the power spectral density to drop
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`from 0 dBr at 9 MHz from the center frequency to -20 dBr at 11 MHz from the center frequency.
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`Beyond 11 MHz, we have active subcarriers on the adjacent 20 MHz channel and this guard
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`band arrangement provides reduced levels into adjacent channels. When operating using a 20
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`MHz channel for example, each subcarrier is spaced 0.3125 MHz apart. Using 52 subcarriers at
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`a frequency spacing of 0.3125 MHz occupies 16.25 MHz for data transmission. The remaining
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`3.75 MHz of the 20 MHz channel is used as a guard on the upper and lower edge of the band—
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`1.875 MHz at each edge. Therefore, the claimed frequency difference between the center
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`frequency of the outer most subcarrier and the band edge (here, 1.875 MHz) is more than half the
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`frequency difference between the center frequencies of each adjacent subcarrier (here, 0.3125
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`MHz / 2 or 0.15625 MHz).
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`11
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`Petitioners, Ex. 1002, Page 11
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 12 of 15 PageID #: 12
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`42. MTel alleges that Defendants’ use, operation, and maintenance of Wi-Fi
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`Equipment, such as their access points, including the Aruba 220 Series and Instant Access RAP-
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`100 Series, directly infringed the ’891 Patent, at least because such equipment operated
`
`according to the IEEE 802.11 OFDM scheme of channelization structure.
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`43. MTel alleges that Defendants directly infringed the ’891 Patent when their service
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`professionals installed, tested, or validated Wi-Fi Equipment or conducted studies of the physical
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`and spectral dynamics leading up to a wireless network deployment.
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`44. MTel alleges that Defendants directly infringed the ’891 Patent when, for
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`example, their professionals tested the maximum throughput that such Wi-Fi Equipment
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`achieved.
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`45.
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`As a result of Defendants’ unlawful infringement of the ’891 Patent, MTel has
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`suffered damage. MTel is entitled to recover damages from Defendants adequate to compensate
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`for such infringement.
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`THIRD CLAIM FOR RELIEF
`(Infringement of Claims 1, 7, 8, 10, 15, 16, 17, and 19 of United States Patent No. 5,915,210)
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`46. MTel incorporates by reference the preceding paragraphs of this Complaint as if
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`set forth here in full.
`
`47.
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`The USPTO duly and lawfully issued the ’210 Patent entitled, “Method and
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`System for Providing Multicarrier Simulcast Transmission,” on June 22, 1999. MTel is the
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`assignee of all right, title, and interest in and to the ’210 Patent and possesses the exclusive right
`
`of recovery, including the exclusive right to recover for past, present, and future infringement.
`
`Each and every claim of the ’210 Patent is valid and enforceable and each enjoys a statutory
`
`presumption of validity separate, apart, and in addition to the statutory presumption of validity
`
`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`12
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`Petitioners, Ex. 1002, Page 12
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 13 of 15 PageID #: 13
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`enjoyed by every other of its claims. 35 U.S.C. § 282. A true and correct copy of the ’210
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`Patent is attached as Exhibit C.
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`48. MTel alleges that, during the Relevant Period, Defendants directly infringed one
`
`or more claims of the ’210 Patent by making, using, selling, and offering to sell Wi-Fi
`
`Equipment and associated services.
`
`49. MTel alleges that Defendants’ use and operation of Wi-Fi Equipment infringed
`
`one or more claims of the ’210 Patent literally and/or under the doctrine of equivalents by,
`
`among other things, employing MIMO functionality and certain multi-carrier frequency
`
`structures, such as OFDM, as described above.
`
`50. MTel alleges that Defendants’ use and sale of Wi-Fi Equipment, such as their
`
`access points, including the Aruba 220 Series and Instant Access RAP-100 Series, directly
`
`infringed the ’210 Patent at least because such equipment embodies the asserted method claims
`
`of the ’210 Patent.
`
`51. MTel alleges that Defendants directly infringed the ’210 Patent at least because
`
`Defendants made, sold, and offered to sell Wi-Fi Equipment, which implemented the claimed
`
`system of the ’210 Patent.
`
`52. MTel alleges that Defendants directly infringed the ’210 Patent when their service
`
`professionals used, installed, tested, deployed, validated, and maintained Wi-Fi Equipment.
`
`53. MTel alleges that Defendants directly infringed the ’210 Patent when, for
`
`example, their technicians tested the throughput that such Wi-Fi Equipment achieved during
`
`testing in various wireless channel conditions that triggered adaptations in transmission modes.
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`13
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`Petitioners, Ex. 1002, Page 13
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 14 of 15 PageID #: 14
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`54.
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`As a result of Defendants’ unlawful infringement of the ’210 Patent, MTel has
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`suffered damage. MTel is entitled to recover damages from Defendants adequate to compensate
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`for such infringement.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff MTel prays for entry of judgment against Defendants as follows:
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`A.
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`B.
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`That Defendants directly infringed each of the Asserted Patents under 35 U.S.C. § 271(a);
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`That Defendants provide to MTel an accounting of all gains, profits, savings, and
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`advantages derived by Defendants’s direct infringement of the Asserted Patents, and that
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`MTel be awarded damages adequate to compensate for the wrongful infringement by
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`Defendants, in accordance with 35 U.S.C. § 284;
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`C.
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`That this case be declared an exceptional one in favor of MTel under 35 U.S.C. § 285,
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`and that MTel be awarded its reasonable attorneys’ fees and all other costs and expenses
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`incurred in connection with this civil action in accordance with 35 U.S.C. § 285 and Rule
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`54(d) of the Federal Rules of Civil Procedure;
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`D.
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`That MTel receive all other or further relief as this Court may deem just or proper.
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`DEMAND FOR JURY TRIAL
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`In accordance with Federal Rule of Civil Procedure 38(b), MTel hereby demands a trial
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`Respectfully Submitted,
`
`
`
`
`
`/s/ Daniel Scardino
`Daniel Scardino
`Texas State Bar No. 24033165
`Henning Schmidt
`Texas State Bar No. 24060569
`Drew Zerdecki
`Texas State Bar No. 24051562
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`by jury on all issues triable to a jury.
`
`Dated: January 4, 2016
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`
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`14
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`Petitioners, Ex. 1002, Page 14
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`Case 2:16-cv-00012 Document 1 Filed 01/04/16 Page 15 of 15 PageID #: 15
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`REED & SCARDINO LLP
`301 Congress Avenue, Suite 1250
`Austin, TX 78701
`Tel.: (512) 474-2449
`Fax: (512) 474-2622
`dscardino@reedscardino.com
`hschmidt@reedscardino.com
`dzerdecki@reedscardino.com
`ATTORNEYS FOR PLAINTIFF
`MOBILE TELECOMMUNICATIONS
`TECHNOLOGIES, LLC
`
`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
`767610v.1
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`
`
`15
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`Petitioners, Ex. 1002, Page 15