Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 1 of 23 PageID #: 189600
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. ____________
`
`JURY TRIAL DEMANDED
`
`))))))))))))
`
`DALI WIRELESS, INC. a Delaware
`corporation,
`
`Plaintiff,
`
`v.
`
`JOHN MEZZALINGUA ASSOCIATES, LLC
`d/b/a JMA WIRELESS, a Delaware limited
`liability company,
`
`Defendant.
`
`Plaintiff Dali Wireless, Inc. (“Dali”) files this Complaint against Defendant John
`
`COMPLAINT
`
`Mezzalingua Associates, LLC d/b/a JMA Wireless (“JMA Wireless”).
`
`NATURE OF THE CASE
`
`1.
`
`This is an action for infringement of two patents: (1) United States Patent No.
`
`10,334,499 (“the ’499 patent”) and (2) United States Patent No. 9,820,171 (“the ’171 patent”).
`
`The patents (“Patents-in-Suit” or “Asserted Patents”) relate to systems and products for providing
`
`in-building cellular network coverage.
`
`2.
`
`Defendant JMA Wireless has been making, using and selling enterprise solutions
`
`for in-building cellular coverage, including its TEKO® Cell Hub and XRAN® server software
`
`products, that infringe the ’499 patent and the ’171 patent. Plaintiff Dali is seeking injunctive
`
`relief as well as damages.
`
`PARTIES
`
`3.
`
`Dali is a Delaware corporation having its principal place of business in Menlo Park,
`
`California.
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 2 of 23 PageID #: 189601
`
`4.
`
`Founded in 2006, Dali began as a designer and manufacturer of power amplifiers
`
`used in radio frequency (“RF”) communications. Dali is known within the industry as an innovator
`
`in providing end-to-end software defined in-building digital radio distribution solutions that can
`
`be implemented for cellular, public safety, and other RF communications. Dali is a world-wide
`
`innovator in digital radio distribution systems and digital predistortion technology that
`
`revolutionized in-building and outdoor wireless coverage and capacity. Dali’s groundbreaking
`
`products have been consistently recognized by industry publications. For example, Dali has been
`
`recognized as a “Hot Tech Innovator” by ABI Research and was ranked No. 1 in innovation in the
`
`latest ABI Research report, “In-Building Wireless, DAS Vendor Competitive Assessment.” Dali’s
`
`systems improve upon traditional in-building mobile communications systems by allowing the
`
`dynamic allocation of wireless coverage and capacity.
`
`5.
`
`On information and belief, JMA Wireless is a limited liability company organized
`
`and existing under Delaware law and with a principal place of business at 7645 Henry Clay
`
`Boulevard, Liverpool, NY 13088.
`
`JURISDICTION AND VENUE
`
`6.
`
`This is an action for patent infringement arising under the Patent Laws of the United
`
`States, Title 35 of the United States Code.
`
`7.
`
`This Court has original subject matter jurisdiction under 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`8.
`
`On information and belief, this Court has personal jurisdiction over JMA Wireless
`
`because JMA Wireless is a company organized under the laws of the State of Delaware and
`
`because it regularly transacts business in this District.
`
`9.
`
`On information and belief, JMA Wireless has committed, and continues to commit,
`
`acts of infringement of Dali’s Patents-in-Suit in violation of the United States Patent Laws, and
`
`2
`
`

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`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 3 of 23 PageID #: 189602
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`has sold, offered for sale, marketed, and/or imported infringing products into this District. JMA
`
`Wireless’ infringement has caused substantial injury to Dali, including within this District.
`
`10.
`
`Venue is proper in this district pursuant to 28 U.S.C. §§ 1400 and 1391 because
`
`JMA Wireless is a Delaware company and therefore is deemed to reside in this judicial district.
`
`THE PATENTS-IN-SUIT
`
`11.
`
`The ’499 patent is titled “Distributed Antenna System” and was issued by the
`
`United States Patent and Trademark Office to Shawn Patrick Stapleton, Paul Lemson, Bin Lin,
`
`and Albert S. Lee on June 25, 2019, and assigned to Dali. A true and correct copy of the ’499
`
`patent is attached hereto as Exhibit A.
`
`12.
`
`Dali is the owner of all right, title, and interest in and to the ’499 patent with the
`
`full and exclusive right to bring suit to enforce the ’499 patent.
`
`13.
`
`14.
`
`The ’499 patent is valid and enforceable under the United States Patent Laws.
`
`The ’171 patent is titled “Remotely Reconfigurable Distributed Antenna System
`
`and Methods” and was issued by the United States Patent and Trademark Office to Paul Lemson,
`
`Shawn Patrick Stapleton, Sasa Trajkovic, and Albert S. Lee on November 14, 2017, and assigned
`
`to Dali. A true and correct copy of the ‘171 patent is attached hereto as Exhibit B.
`
`15.
`
`Dali is the owner of all right, title, and interest in and to the ’171 patent with the
`
`full and exclusive right to bring suit to enforce the ’171 patent.
`
`16.
`
`The ’171 patent is valid and enforceable under the United States Patent Laws.
`
`FIRST CAUSE OF ACTION
`(PATENT INFRINGEMENT UNDER 35 U.S.C. § 271 OF ’499 PATENT)
`
`17.
`
`18.
`
`Dali re-alleges and incorporates by reference all of the foregoing paragraphs.
`
`On information and belief, JMA Wireless has infringed and continues to infringe,
`
`either literally or under the doctrine of equivalents, one or more claims, including at least claim 1,
`
`3
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 4 of 23 PageID #: 189603
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`of the ’499 patent in violation of 35 U.S.C. §§ 271, et seq., directly and/or indirectly, by making,
`
`using, importing, selling, and/or offering certain equipment and systems relating to its wireless
`
`coverage systems, such as its infringing JMA Enterprise Platform, including its TEKO® Cell Hub
`
`and XRAN® Server products (collectively, “JMA Enterprise Platform”), throughout the United
`
`States without authority or license.
`
`19.
`
`On information and belief, JMA Wireless has been, and currently is, an active
`
`inducer of infringement of the ’499 patent under 35 U.S.C. § 271(b).
`
`20.
`
`According to product literature, JMA Wireless’ Enterprise Platform operates
`
`through the XRAN adaptive baseband server software, which processes the RF signals and delivers
`
`them to the TEKO® RF transmitting radios, and then to and from the mobile devices.”
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`21.
`
`Claim 1 of the ’499 patent states:
`
`[Preamble] A system
`comprising:
`
`[A] a baseband unit;
`
`for
`
`transporting wireless communications,
`
`[B] a plurality of signal sources, including at least a first signal source and
`a second signal source;
`
`[C] a plurality of remote units, including at least a first remote unit and a
`second remote unit;
`
`[D] wherein the baseband unit comprises a plurality of interfaces to
`communicatively couple the baseband unit to the plurality of signal sources;
`
`[E] wherein the baseband unit is configured to receive a plurality of radio
`resources from the first signal source and the second signal source;
`
`[F] wherein the baseband unit is configured to send a digital representation
`of a first set of radio resources to the first remote unit at a first point in time,
`the first set of radio resources for transmission at an antenna of the first
`remote unit;
`
`4
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 5 of 23 PageID #: 189604
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`[G] wherein the baseband unit is configured to send a digital representation
`of a second set of radio resources to the first remote unit at a second point
`in time, the second set of radio resources for transmission at the antenna of
`the first remote unit;
`
`[H] wherein a number of radio resources in the first set of radio resources
`is different from a number of radio resources in the second set of radio
`resources; and wherein the baseband unit is configured to receive digital
`signals from each of the plurality of remote units.
`
`22.
`
`On information and belief, based on publicly available JMA Wireless documents,
`
`the JMA Enterprise Platform satisfies each and every limitation recited in at least claim 1 of the
`
`’499 patent as below.
`
`23.
`
`On information and belief, the JMA Enterprise Platform meets the preamble of
`
`claim 1 of the ’499 patent based on publicly available documents. JMA Enterprise Platform is a
`
`system for transporting wireless communications, and it comprises a server running XRAN
`
`adaptive baseband software and TEKO Cell Hubs for providing the communications to and from
`
`mobile units such as cell phones. (https://jmawireless.com/resource/intel-solution-brief/.)
`
`According to the publicly available documents:
`
`With fiber, a single [TEKO] Cell Hub delivers multiple mobile operators’ licensed
`bands as well as the new CBRS (Citizens Broadband Radio Service) spectrum. The
`TEKO Cell Hub integrates directly with the JMA Wireless XRAN® technology,
`the only RF source in software that operates on off-the-shelf servers. Together,
`they provide a scalable, flexible and easy to deploy solution that uniquely address
`the needs of buildings
`to ensure best-in-class mobile performance.
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`5
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 6 of 23 PageID #: 189605
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`24.
`
`On information and belief, the “[TEKO] Cell Hub and XRAN can also be utilized
`
`in conjunction with the JMA Enterprise Platform as a hybrid solution, providing even further
`
`flexibility to address the unique needs of different buildings.” (https://jmawireless.com/jma-
`
`wireless-launches-teko-cell-hub-the-first-solution-to-deliver-virtualized-enterprise-multi-service-
`
`capabilities-for-in-building-needs/.)
`
`25.
`
`On information and belief, JMA Enterprise Platform meets limitation [A] of claim
`
`1 of the ’499 patent based on publicly available documents. Limitation [A] requires “a baseband
`
`unit . . . .”
`
`26.
`
`The JMA Enterprise Platform includes an XRAN, a software-enabled baseband
`
`unit as recited by limitation [A]: “The JMA Wireless solution to this challenge is XRAN, a
`
`completely virtualized baseband function that can run on servers powered by Intel® processors
`
`that combines with the company’s TEKOTM RF distribution technology to precisely address the
`
`key needs of the in-building market.” (https://jmawireless.com/resource/intel-solution-brief/ at 2).
`
`27.
`
`On information and belief, the JMA Enterprise Platform meets limitation [B] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [B] requires, “a
`
`plurality of signal sources, including at least a first signal source and a second signal source . . . .”
`
`28.
`
`The XRAN of the JMA Enterprise platform connects to multiple signal sources:
`
`“XRAN was created to deliver on the needs of both the carrier and the enterprise by offering:
`
`Support
`
`for multiple MNO network
`
`access,
`
`including public
`
`safety bands.”
`
`(https://jmawireless.com/resource/intel-solution-brief/ at 3).
`
`29.
`
`“The XRAN Adaptive Baseband software is compatible with all major wireless
`
`standards, including 3GPP* LTE, LTE category M (CAT-M), narrowband-IoT, and public safety
`
`bands and is capable of processing 3.5 GHz Citizens Broadband Radio Service (CBRS) in
`
`6
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 7 of 23 PageID #: 189606
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`software. XRAN utilizes 3GPP-defined network interfaces to be compatible with core mobile
`
`networks worldwide, and its software characteristics mean it can more easily be changed and
`
`enhanced
`
`for
`
`new
`
`spectrums,
`
`protocols,
`
`capabilities,
`
`and
`
`performance.”
`
`(https://jmawireless.com/resource/intel-solution-brief/)
`
`30.
`
`On information and belief, the JMA Enterprise Platform meets limitation [C] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [C] requires, “a
`
`plurality of remote units, including at least a first remote unit and a second remote unit . . . .”
`
`31.
`
`In the JMA Enterprise Platform, the XRAN delivers communications to and from
`
`the TEKO Cell Hubs:
`
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/ at 3).
`
`32.
`
`The JMA Enterprise Platform includes multiple Cell Hubs to provide connectivity
`
`throughout a venue: “Utilizing a common fiber infrastructure, multiple Cell Hub units can connect
`
`to the XRAN server or can be cascaded. Each Cell Hub provides MIMO (multiple input, multiple
`
`output) and is capable of covering up to 20K square feet of space . . . Cell Hub with XRAN aligns
`
`with the new Distributed Radio System (DRS) segment, but uniquely adds virtualized RQN to the
`
`solution (see graphic above).” (https://jmawireless.com/resource/teko-cell-hub-solution-brief/ at
`
`3).
`
`7
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 8 of 23 PageID #: 189607
`
`33.
`
`On information and belief, the JMA Enterprise Platform meets limitation [D] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [D] recites, “wherein
`
`the baseband unit comprises a plurality of interfaces to communicatively couple the baseband unit
`
`to the plurality of signal sources . . . .”
`
`34.
`
`XRAN includes multiple interfaces for the plurality of signal sources. Publicly
`
`available materials explain that “[t]he XRAN Adaptive Baseband software is compatible with all
`
`major wireless standards, including 3GPP* LTE, LTE category M (CAT-M), narrowband-IoT,
`
`and public safety bands and is capable of processing 3.5 GHz Citizens Broadband Radio Service
`
`(CBRS) in software. XRAN utilizes 3GPP-defined network interfaces to be compatible with core
`
`mobile networks worldwide, and its software characteristics mean it can more easily be changed
`
`and
`
`enhanced
`
`for
`
`new
`
`spectrums,
`
`protocols,
`
`capabilities,
`
`and
`
`performance.”
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`35.
`
`On information and belief, the JMA Enterprise Platform meets limitation [E] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [E] requires,
`
`“wherein the baseband unit is configured to receive a plurality of radio resources from the first
`
`signal source and the second signal source . . . .”
`
`36.
`
`As discussed above in relation to limitations [B] and [D], the JMA Enterprise
`
`Platform receives communications compatible with “3GPP LTE” among other radio standards that
`
`include a plurality of radio resources for more than one signal source.
`
`37.
`
` On information and belief, the JMA Enterprise Platform meets limitation [F] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [F] recites, “wherein
`
`the baseband unit is configured to send a digital representation of a first set of radio resources to
`
`8
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 9 of 23 PageID #: 189608
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`the first remote unit at a first point in time, the first set of radio resources for transmission at an
`
`antenna of the first remote unit . . . .”
`
`38.
`
`The XRAN of the JMA Enterprise Platform sends a digital representation of the
`
`radio resources to a first remote unit, the Cell Hub, for transmission at an antenna of the Cell Hub.
`
`According to JMA Wireless product literature, by “[u]tilizing a common fiber infrastructure,
`
`multiple Cell Hub units can connect
`
`to
`
`the XRAN server or can be cascaded.”
`
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`39.
`
`The product literature further explains that “[e]ach Cell Hub provides MIMO
`
`(multiple input, multiple output) and is capable of covering up to 20K square feet of space” and
`
`that the “Cell Hub with XRAN aligns with the new Distributed Radio System (DRS) segment, but
`
`uniquely
`
`adds
`
`virtualized RAN
`
`to
`
`the
`
`solution
`
`(see
`
`graphic
`
`above).”
`
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`40.
`
`Publicly available documents further note “Cell Hub utilizes a common fiber
`
`infrastructure, enabling multiple units to connect to the XRAN server “ and “[e]ach Cell Hub
`
`provides 2X2 MIMO (multiple input, multiple output) with one watt of power, and Cell Hubs can
`
`be cascaded (daisy chained)
`
`to easily scale up coverage and capacity as needed.”
`
`(https://jmawireless.com/jma-wireless-launches-teko-cell-hub-the-first-solution-to-deliver-
`
`virtualized-enterprise-multi-service-capabilities-for-in-building-needs/.)
`
`41.
`
`Additionally, the communications transported from the XRAN to the Cell Hub are
`
`a digital representation of the radio resources because the communications conform to the CPRI
`
`standard. See (https://jmawireless.com/resource/intel-solution-brief/ at 3).
`
`42.
`
`On information and belief, the JMA Enterprise Platform meets limitation [G] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [G] recites, “wherein
`
`9
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 10 of 23 PageID #: 189609
`
`the baseband unit is configured to send a digital representation of a second set of radio resources
`
`to the first remote unit at a second point in time, the second set of radio resources for transmission
`
`at the antenna of the first remote unit . . . .”
`
`43.
`
`As discussed above in relation to limitation [B] and [D], the XRAN communicates
`
`signals from multiple sources, e.g. MNOs. As a result, at least a first and second sets of radio
`
`resources will be received by the XRAN and translated into first and second digital representations
`
`to be transmitted to first remote unit, the Cell Hub, as discussed above.
`
`44.
`
`On information and belief, the JMA Enterprise Platform meets limitation [H] of
`
`claim 1 of the ’499 patent based on publicly available documents. Limitation [H] recites, “wherein
`
`a number of radio resources in the first set of radio resources is different from a number of radio
`
`resources in the second set of radio resources; and wherein the baseband unit is configured to
`
`receive digital signals from each of the plurality of remote units.”
`
`45.
`
` According to publicly available documents, the XRAN is compatible with various
`
`radio standards, such as LTE. (https://jmawireless.com/resource/intel-solution-brief/).
`
`46.
`
`These radio standards, such as LTE, have varying numbers of radio resources for
`
`communication with different end points. As such, the number of radio resources in a first and
`
`second set are different.
`
`47.
`
`Additionally, the number of radio resources are different depending on which radio
`
`standard is being used.
`
`48.
`
`Accordingly, on information and belief, the JMA Enterprise Platform product
`
`meets all elements of, and therefore infringes, at least claim 1 of the ’499 patent.
`
`49.
`
`As a result of JMA Wireless’ infringement of the ’499 patent, Dali has suffered,
`
`and continues to suffer, substantial injury and is entitled to recover all damages caused by JMA
`
`10
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 11 of 23 PageID #: 189610
`
`Wireless’ infringement to the fullest extent permitted by the Patent Act, together with prejudgment
`
`interests and costs for JMA Wireless’ wrongful conduct.
`
`50.
`
`Dali has no adequate remedy at law to prevent future infringement of the ’499
`
`patent. Dali suffers and continues to suffer irreparable harm as a result of JMA Wireless’ patent
`
`infringement and is, therefore, entitled to injunctive relief to enjoin JMA Wireless’ wrongful
`
`conduct.
`
`SECOND CAUSE OF ACTION
`(PATENT INFRINGEMENT UNDER 35 U.S.C. § 271 OF ’171 PATENT)
`
`51.
`
`52.
`
`Dali re-alleges and incorporates by reference all of the foregoing paragraphs.
`
`On information and belief, JMA Wireless has infringed and continues to infringe,
`
`either literally or under the doctrine of equivalents, one or more claims, including at least claim 1,
`
`of the ’171 patent in violation of 35 U.S.C. §§ 271, et seq., directly or indirectly, by making, using,
`
`importing, selling, and/or offering certain equipment and systems relating to its wireless coverage
`
`systems, such as its infringing JMA Enterprise Platform, including its TEKO® Cell Hub and
`
`XRAN® Server products, throughout the United States without authority or license.
`
`53.
`
`On information and belief, JMA Wireless has been, and currently is, an active
`
`inducer of infringement of the ’171 patent under 35 U.S.C. § 271(b).
`
`54.
`
`Claim 1 of the ’171 patent states,
`
`[Preamble] A method for routing and switching signals comprising:
`
`[A] providing a plurality of remote radio units, each remote radio unit
`configured to transmit one or more downlink signals and to receive one or
`more uplink signals;
`
`[B] providing at least one digital access unit configured to communicate
`with the plurality of remote radio units;
`
`[C] translating the uplink and downlink signals between RF and base band;
`
`11
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 12 of 23 PageID #: 189611
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`[D] packetizing the uplink and downlink base band signals, wherein the
`packetized signals correspond to a plurality of carriers, each remote radio
`unit configured to receive or transmit a respective subset of the plurality of
`carriers;
`
`[E] routing and switching the packetized signals among the plurality of
`remote radio units via the at least one digital access unit;
`
`[F] reconfiguring at least one of the plurality of remote radio units by
`increasing or decreasing the number of carriers in the respective subset of
`the plurality of carriers; and
`
`[G] thereafter routing and switching the packetized signals among the
`plurality of remote radio units via the at least one digital access unit
`according to a result of the reconfiguring.
`
`55.
`
`On information and belief, based on publicly available JMA Wireless product
`
`literature and other documents, the JMA Enterprise Platform satisfies each and every limitation
`
`recited in at least claim 1 of the ’171 patent as stated below.
`
`56.
`
`On information and belief, the JMA Enterprise Platform meets the preamble of
`
`claim 1 of the ’171 patent based on publicly available documents. The preamble of claim 1 refers
`
`to “[a] method for routing and switching signals ….”
`
`57.
`
`The JMA Enterprise Platform routes and switches RF signals. According to
`
`publicly available documents, the XRAN Adaptive Baseband “processes the RF signals and
`
`delivers them to the transmitting radios, and then to and from the mobile devices.”
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`58.
`
`These documents further explains that “XRAN Adaptive Baseband software is
`
`compatible with all major wireless standards, including 3GPP* LTE, LTE category M (CAT-M),
`
`narrowband-IoT, and public safety bands and is capable of processing 3.5 GHz Citizens Broadband
`
`Radio Service (CBRS) in software” and that “the XRAN utilizes 3GPP-defined network interfaces
`
`to be compatible with core mobile networks worldwide, and its software characteristics mean it
`
`12
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 13 of 23 PageID #: 189612
`
`can more easily be changed and enhanced for new spectrums, protocols, capabilities, and
`
`performance.”
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`59.
`
`On information and belief, the JMA Enterprise Platform meets claim limitation [A]
`
`of claim 1 of the ’171 patent based on publicly available documents. Limitation [A] requires “a
`
`plurality of remote radio units, each remote radio unit configured to transmit one or more downlink
`
`signals and to receive one or more uplink signals . . . .”
`
`60.
`
`According to publicly available documents, the TEKO Cell Hub (remote radio unit)
`
`“is multi-carrier and multi-band” and “utilizes a common fiber infrastructure, enabling multiple
`
`units to connect to the XRAN server” wherein “[e]ach Cell Hub provides 2X2 MIMO (multiple
`
`input, multiple output) with one watt of power, and Cell Hubs can be cascaded (daisy chained) to
`
`easily scale up coverage and capacity as needed.” (https://jmawireless.com/jma-wireless-
`
`launches-teko-cell-hub-the-first-solution-to-deliver-virtualized-enterprise-multi-service-
`
`capabilities-for-in-building-needs/.).”
`
`61. Moreover, the publicly available materials for the JMA Enterprise Platform provide
`
`a diagram of the system architecture showing how the TEKO RF distribution units transmit one or
`
`more downlink RF
`
`signals
`
`and
`
`receive one or more uplink RF
`
`signals.
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`13
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`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 14 of 23 PageID #: 189613
`
`62.
`
`The publicly available documents further explain that “[t]he XRAN Adaptive
`
`Baseband processes the RF signals and delivers them to the transmitting radios [e.g., TEKO Cell
`
`Hubs], and then to and from the mobile devices.” (https://jmawireless.com/resource/intel-
`
`solution-brief/.)
`
`63.
`
`On information and belief, the JMA Enterprise Platform meets claim limitation [B]
`
`of claim 1 of the ’171 patent based on publicly available documents. Limitation [B] requires “at
`
`least one digital access unit configured to communicate with the plurality of remote radio units
`
`. . . .”
`
`64.
`
`The JMA Enterprise Platform includes a baseband unit (XRAN Server) that acts as
`
`a digital access unit and communicates with one or more radio units (TEKO Cell Hub). According
`
`to JMA Wireless’ product literature, the JMA Enterprise Platform “[u]tilizes a common fiber
`
`infrastructure” wherein “multiple [TEKO] Cell Hub units can connect to the XRAN server or be
`
`cascaded.” (https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`14
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 15 of 23 PageID #: 189614
`
`65.
`
`Under this configuration “[e]ach [TEKO] Cell Hub provides MIMO (multiple
`
`input, multiple output) and is capable of covering up to 20K square feet of space.”
`
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`66.
`
`Other JMA Wireless product literature shows the relationship between the XRAN
`
`Server (DAS) and remote radio units in a JMA Enterprise Platform installation:
`
`(https://jmawireless.com/resource/intel-solution-brief/ (annotation added).)
`
`67.
`
`This literature explains that the “XRAN Adaptive Baseband processes [in the
`
`XRAN Server] processes the RF signals and delivers them to the transmitting radios, and then to
`
`and from the mobile devices.” (https://jmawireless.com/resource/intel-solution-brief/)
`
`68.
`
`On information and belief, the JMA Enterprise Platform meets claim limitation [C]
`
`of claim 1 of the ’171 patent based on publicly available documents. Limitation [C] requires
`
`“translating the uplink and downlink signals between RF and base band . . . .”
`
`69.
`
`On information and belief, the components of the JMA Enterprise Platform
`
`translate or convert uplink and downlink signals between RF and baseband as appropriate.
`
`15
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 16 of 23 PageID #: 189615
`
`70.
`
`According to publicly available information, the JMA Enterprise Platform
`
`architecture combines baseband processing and radio functions centralized in the Adaptive
`
`Baseband Server resulting in improved performance:
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`71.
`
`According to this documentation, the XRAN Adaptive Baseband [Server] in the
`
`JMA Enterprise Platform “processes the RF signals and delivers them to the transmitting radios,
`
`and then to and from the mobile devices.” (https://jmawireless.com/resource/intel-solution-brief/.)
`
`72.
`
`According to other publicly available JMA Wireless press materials “[t]he XRAN
`
`software platform integrates with the TEKO RF Distribution platform via high capacity digital
`
`fiber connectivity, eliminating costly layers of analog equipment and cabling, and significantly
`
`reducing the footprint, power and cooling requirements.” (https://info.jmawireless.com/jma-
`
`wireless-launches-xran-fully-virtualized-adaptive-baseband-software-to-radically-change-the-
`
`game-for-in-venue-wireless.)
`
`16
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 17 of 23 PageID #: 189616
`
`73.
`
`In another configuration of the JMA Enterprise Platform, the TEKO Cell Hub units
`
`connect to the XRAN server by common fiber infrastructure, permitting the TEKO Cell Hub to
`
`“utilize[ ] XRAN for its baseband processing” providing for “adaptable sectorization” and
`
`“allow[ing] each operator individual sector mapping” that enables “RF engineers to virtually
`
`eliminate the battle against SINR (signal to interference plus noise ratio) experienced with small
`
`cells while optimizing in-building performance by further segmenting the sectors by tenant.”
`
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`74.
`
`Accordingly, on information and belief, by transmitting signals within a fiber
`
`network, the baseband controller of JMA Wireless’ XRAN Server product must convert received
`
`downlink signals to baseband signals or convert baseband signals to uplink signals transmitted to
`
`a base station in the LTE network when appropriate.
`
`75.
`
`On information and belief, the JMA Enterprise Platform meets claim limitation [D]
`
`of claim 1 of the ’171 patent based on publicly available documents. Limitation [D] requires
`
`“packetizing the uplink and downlink baseband signals, wherein the packetized signals correspond
`
`to a plurality of carriers, each remote radio unit configured to receive or transmit a respective
`
`subset of the plurality of carriers . . . .”
`
`76.
`
`On information and belief, the JMA Enterprise Platform implements a CPRI or
`
`CPRI-based communication protocol that performs packetizing. The JMA Enterprise Platform
`
`supports all major wireless standards, including 3GPP* LTE, LTE category M (CAT-M).
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`77.
`
`LTE uses the evolved packet core (“EPC”), which is an evolution of the packet-
`
`switched architecture used in GPRS (2.5G technology for packet-based data services of GSM
`
`networks, i.e., 2G networks)/UMTS (3G technology using a packet-switched architecture for
`
`17
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 18 of 23 PageID #: 189617
`
`CDMA). Signals, including downlink and uplink signals, can be transmitted in LTE using multiple
`
`carriers.
`
`78.
`
`Accordingly, on information and belief, JMA Wireless’ JMA Enterprise Platform
`
`“packetize[s] the uplink and downlink baseband signals, wherein the packetized signals
`
`correspond to a plurality of carriers.”
`
`79.
`
`The JMA Enterprise Platform further comprises remote radio units (TEKO Cell
`
`Hubs or TEKO RF distribution units) that can be configured to receive or transmit a respective
`
`subset of the plurality of carriers. According to JMA Wireless product literature, the TEKO Cell
`
`Hub units connect to the XRAN server in the JMA Enterprise Platform can “utilize[ ] XRAN for
`
`its baseband processing” providing for “adaptable sectorization” and “allow[ing] each operator
`
`individual sector mapping” that enables “RF engineers to virtually eliminate the battle against
`
`SINR (signal to interference plus noise ratio) experienced with small cells while optimizing in-
`
`building
`
`performance
`
`by
`
`further
`
`segmenting
`
`the
`
`sectors
`
`by
`
`tenant.”
`
`(https://jmawireless.com/resource/teko-cell-hub-solution-brief/.)
`
`80.
`
`On information and belief, the sector segmentation capabilities of the JMA
`
`Enterprise Platform permit remote radio units (TEKO Cell Hubs or TEKO RF distribution units)
`
`to receive or transmit a respective subset of the plurality of carriers.
`
`81.
`
`On information and belief, the JMA Enterprise Platform meets claim limitation [E]
`
`of claim 1 of the ’171 patent based on publicly available documents. Limitation [E] requires
`
`“routing and switching the packetized signals among the plurality of remote radio units via the at
`
`least one digital access unit . . . .”
`
`82.
`
`Operation of the JMA Enterprise Platform involves routing and switching the
`
`packetized signals among the plurality of remote radio units (TEKO Cell Hubs or TEKO RF
`
`18
`
`

`

`Case 1:99-mc-09999 Document 2004 Filed 12/30/19 Page 19 of 23 PageID #: 189618
`
`distribution units) via the XRAN Adaptive Baseband Server. According to JMA Wireless product
`
`literature, the XRAN Adaptive Baseband [Server] “processes the RF signals and delivers them to
`
`the
`
`transmitting
`
`radios,
`
`and
`
`then
`
`to
`
`and
`
`from
`
`the mobile
`
`devices.”
`
`(https://jmawireless.com/resource/intel-solution-brief/.)
`
`83.
`
`Further, LTE uses the evolved packet core (“EPC”), which is an evolution of the
`
`packet-switched architecture used in GPRS (2