Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 1 of 42 PageID #: 1
`
`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.
`
`COMMSCOPE TECHNOLOGIES LLC, a
`Delaware company, and COMMSCOPE
`HOLDING COMPANY, INC., a Delaware
`corporation,
`
`Defendants.
`
`COMPLAINT
`
`Plaintiff Dali Wireless, Inc. (“Dali”) files this Complaint against Defendants CommScope
`
`Technologies LLC
`
`(“CommScope Tech”) and CommScope Holding Company,
`
`Inc.
`
`(“CommScope Holding”) (collectively, “CommScope”).
`
`NATURE OF THE CASE
`
`1.
`
`This is an action for infringement of four patents: (1) United Sates Patent No.
`
`10,045,314 (“the ’314 patent”), (2) United States Patent No. 10,080,178 (“the ’178 patent”), (3)
`
`United States Patent No. 8,682,338 (“the ’338 patent”), and (4) United States Patent No. 9,847,816
`
`(“the ’816 patent”). These patents (“Patents-in-Suit” or “Asserted Patents”) relate to digital
`
`distributed antenna systems (“DAS”).
`
`2.
`
`Defendant CommScope has been selling a OneCell digital DAS that infringes the
`
`’178 patent, the ’338 patent, and the ’816 patent as well as the ION-E and Era digital DAS systems
`
`that infringes the ’314 patent. Plaintiff Dali is seeking injunctive relief as well as damages.
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 2 of 42 PageID #: 2
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`3.
`
`Dali is a Delaware corporation having its principal place of business in Menlo Park,
`
`PARTIES
`
`California.
`
`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 digital radio distribution solutions that can be
`
`implemented in DAS used 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 DAS by allowing the dynamic allocation of wireless coverage
`
`and capacity.
`
`5.
`
`On information and belief, CommScope Tech is a limited liability company
`
`organized and existing under Delaware law and with a place of business at 1100 CommScope
`
`Place SE, Hickory, North Carolina, 28602.
`
`6.
`
`On information and belief, CommScope Holding is a corporation organized and
`
`existing under Delaware law and headquartered at 1100 CommScope Place, SE, Hickory, North
`
`Carolina 28602.
`
`7.
`
`On information and belief, CommScope Tech is a fully owned subsidiary of
`
`CommScope Holding.
`
`2
`
`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 3 of 42 PageID #: 3
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`JURISDICTION AND VENUE
`
`8.
`
`This is an action for patent infringement arising under the Patent Laws of the United
`
`States, Title 35 of the United States Code.
`
`9.
`
`This Court has original subject matter jurisdiction under 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`10.
`
`On information and belief, this Court has personal jurisdiction over CommScope
`
`because CommScope is a company organized under the laws of the State of Delaware and because
`
`it regularly transacts business in this District.
`
`11.
`
`On information and belief, CommScope has committed, and continues to commit,
`
`acts of infringement of Dali’s Patents-in-Suit in violation of the United States Patent Laws, and
`
`have sold, offered for sale, marketed, and/or imported infringing products into this District.
`
`CommScope’s infringement has caused substantial injury to Dali, including within this District.
`
`12.
`
`Venue is proper in this district pursuant to 28 U.S.C. §§ 1400 and 1391 because
`
`CommScope is a Delaware company and therefore is deemed to reside in this judicial district.
`
`THE PATENTS-IN-SUIT
`
`13.
`
`The ’314 patent is titled “Time Synchronized Routing In A Distributed Antenna
`
`System” and was issued by the United States Patent and Trademark Office to Shawn Patrick
`
`Stapleton and Qianqi Zhuang on August 7, 2018, and assigned to Dali. A true and correct copy of
`
`the ’314 patent is attached hereto as Exhibit A.
`
`14.
`
`Dali is the owner of all right, title, and interest in and to the ’314 patent with the
`
`full and exclusive right to bring suit to enforce the ’314 patent.
`
`15.
`
`16.
`
`The ’314 patent is valid and enforceable under the United States Patent Laws.
`
`The ’178 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,
`
`3
`
`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 4 of 42 PageID #: 4
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`and Albert S. Lee on September 18, 2018, and assigned to Dali. A true and correct copy of the
`
`‘178 patent is attached hereto as Exhibit B.
`
`17.
`
`Dali is the owner of all right, title, and interest in and to the ’178 patent with the
`
`full and exclusive right to bring suit to enforce the ’178 patent.
`
`18.
`
`19.
`
`The ’178 patent is valid and enforceable under the United States Patent Laws.
`
`The ’338 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 March 25, 2014, and assigned to
`
`Dali. A true and correct copy of the ‘338 patent is attached hereto as Exhibit C.
`
`20.
`
`Dali is the owner of all right, title, and interest in and to the ’338 patent with the
`
`full and exclusive right to bring suit to enforce the ’338 patent.
`
`21.
`
`22.
`
`The ’338 patent is valid and enforceable under the United States Patent Laws.
`
`The ’816 patent is titled “Digital Transport of Data Over Distributed Antenna
`
`Network” and was issued by the United States Patent and Trademark Office to Qianqi Zhuang and
`
`Shawn Patrick Stapleton on December 19, 2017, and assigned to Dali. A true and correct copy of
`
`the ‘816 patent is attached hereto as Exhibit D.
`
`23.
`
`Dali is the owner of all right, title, and interest in and to the ’816 patent with the
`
`full and exclusive right to bring suit to enforce the ’816 patent.
`
`24.
`
`The ’816 patent is valid and enforceable under the United States Patent Laws.
`
`FIRST CAUSE OF ACTION
`(PATENT INFRINGEMENT UNDER 35 U.S.C. §271 of ’314 PATENT)
`
`25.
`
`26.
`
`Dali re-alleges and incorporates by reference all of the foregoing paragraphs.
`
`On information and belief, CommScope has infringed and continues to infringe,
`
`either literally or under the doctrine of equivalents, one or more claims, including at least claim 1,
`
`4
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 5 of 42 PageID #: 5
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`of the ’314 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 Cloud-RAN
`
`(Radio Access Network) small cell systems, such as its infringing OneCell product, throughout
`
`the United States without authority or license.
`
`27.
`
`On information and belief, OneCell was first announced by Airvana Inc.
`
`(“Airvana”) in 2014. Airvana is a mobile networks technology provider that was the original
`
`designer and developer for OneCell. CommScope acquired Airvana in October 2015.
`
`28.
`
`On information and belief, CommScope has been, and currently is, an active
`
`inducer of infringement of the ’314 patent under 35 U.S.C. § 271(b).
`
`29.
`
`According to the “OneCell Cloud-RAN small cell system” product brochure, “the
`
`OneCell baseband controller and multiple radio points for a virtualized ‘super cell’ that covers the
`
`entire area” which eliminates handovers and boundary interference, resulting in “consistent,
`
`superior LT performance throughout enterprises and public venues at a dramatically lower cost of
`
`deployment than available alternatives.”1
`
`30.
`
`On information and belief, OneCell is made, used, offered for sale, and sold as a
`
`digital DAS system.
`
`31.
`
`Claim 1 of the ’314 patent states, “[preamble] A system for transporting wireless
`
`communications, comprising: [A] at least one Digital Access Unit (DAU); [B] wherein the at least
`
`one DAU comprises at least one signal source interface to communicatively couple the at least one
`
`DAU to at least one signal source; and [C] wherein the at least one DAU is configured to receive
`
`a plurality of downlink signals from the at least one signal source; and [D] a plurality of remote
`
`1 OneCell Cloud-RAN Small Cell System, available at,
`https://www.anixter.com/content/dam/Suppliers/CommScope/Documents/OneCell_Cloud_RAN
`_Brochure_BR-110160-EN.pdf (“OneCell Brochure”), last accessed February 19, 2019.
`
`5
`
`

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`units; [E] wherein the at least one DAU further comprises at least one remote interface configured
`
`to communicatively couple the at least one DAU to the plurality of remote units; [F] wherein the
`
`at least one DAU is configured to receive a plurality of uplink signals from the plurality of remote
`
`units; and [G] one or more delay compensation merge units configured to delay signals transmitted
`
`from or received by each of the plurality of remote units.”
`
`32.
`
`On information and belief, based on publicly available CommScope documents,
`
`OneCell satisfies each and every limitation recited in at least claim 1 of the ’314 patent as below.
`
`33.
`
`On information and belief, OneCell meets the preamble of claim 1 of the ’314
`
`patent based on publicly available documents.
`
`34.
`
`OneCell comprises a system for transporting wireless communications. For
`
`example, according to the Weitzen Article, “‘OneCell’ is a new smallcell technology combining
`
`many of the advantages of conventional DAS (Distributed Antenna Systems) technology and
`
`modern ‘Cloud-RAN’ based smallcell technology.”2 In addition, the user manual for OneCell
`
`states3:
`
`35.
`
`On information and belief, OneCell meets the claim element 1[A] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`2 Measuring and Mapping Multi-user Cell-Virtualization Performance in a Cloud-RAN Small
`Cell Network, Weitzen et al., 2017 IEEE International Conference on Microwaves, Antennas,
`Communications and Electronic Systems (COMCAS) (“Weitzen Article”), available at
`https://ieeexplore.ieee.org/document/8244711/, last accessed February 15, 2019.
`3 OneCell Installation and Commissioning, Release 1.0, April, 2015 (“OneCell User Manual”) at
`1-2, available at https://www.cleancss.com/user-manuals/QHY/RP-A2014, last accessed
`February 15, 2019.
`
`6
`
`

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`36.
`
`OneCell comprises a baseband control unit that corresponds to a DAU. For
`
`example, the user manual for OneCell states that its hardware consists of a baseband controller
`
`and radio points.4 DAUs function as the interface between the base stations and the digital remote
`
`units. See ’314 patent at 5:53-56. The baseband controller is the hardware component that
`
`corresponds to the claimed DAU. The specification for OneCell’s baseband controller unit shows
`
`how that unit interfaces between a base station and the digital remote units, or radio points5:
`
`37.
`
`On information and belief, OneCell meets the claim element 1[B] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`4 OneCell User Manual at 1-3.
`5 BC-W2001 Specification, available at
`https://www.commscope.com/catalog/networking_systems/pdf/part/64249/BC-W2001.pdf, last
`accessed May 20, 2019.
`
`7
`
`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 8 of 42 PageID #: 8
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`38.
`
`OneCell comprises a baseband control unit that is capable of connecting to signal
`
`sources either alone, or as a part of a network with radio points. For example, according to the
`
`Weitzen Article:
`
`In the “OneCell” architecture, the LTE eNodeB functionality is
`split between a centralized baseband controller (BC) and a
`distributed network of smallcell radio points (RP’s). The radio
`points are connected and communicate via cat-5 Ethernet, using
`standard IP protocols, in a star configuration to the controller...6
`
`The user manual for OneCell also shows the controller ports of the DAU that act as an interface to
`
`communicatively couple the DAU to a signal source base station:7
`
`6 Weitzen Article at 1.
`7 OneCell User Manual at 1-4.
`
`8
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`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 9 of 42 PageID #: 9
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`39.
`
`On information and belief, OneCell meets the claim element 1[C] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`40.
`
`OneCell comprises a baseband controller that is configured to receive a plurality of
`
`downlink signals from the at least one signal source. For example, the figure from the specification
`
`for OneCell’s baseband controller, depicted above, shows multiple ports for interfacing with a
`
`signal source, and the baseband controller allows for pooled baseband processing with a
`
`centralized scheduler, indicating that it can receive a plurality of downlink signals from at least
`
`one signal source.
`
`41.
`
`On information and belief, OneCell meets the claim element 1[D] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`42.
`
`OneCell comprises a plurality of radio points that correspond to the claimed remote
`
`units. According to the Weitzen Article, OneCell discloses an architecture that comprises a
`
`baseband controller that is networked to multiple remote units.8 OneCell uses at least two different
`
`remote units, the OneCell Radio Point 20009 and the OneCell Ruggedized Radio Point 2000.10
`
`43.
`
`On information and belief, OneCell meets the claim element 1[E] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`44.
`
`OneCell comprises a Device Management System (“DMS”) that is a remote
`
`interface configured to communicatively couple at least one baseband controller to the plurality of
`
`8 Weitzen Article at 1.
`9 RP-A2014 Specification, available at,
`https://www.commscope.com/catalog/networking_systems/pdf/part/64257/RP-A2014.pdf, last
`accessed on May 20, 2019.
`10 RP-A2114 Specification, available at,
`https://www.commscope.com/catalog/networking_systems/pdf/part/64259/RP-A2114.pdf, last
`accessed on May 20, 2019.
`
`9
`
`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 10 of 42 PageID #: 10
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`radio points. For example, the specification for the DMS is the application that allows the baseband
`
`controller to communicatively interface with multiple radio points11:
`
`Figures depicting the various components of OneCell hardware also show that the baseband
`
`controller interfaces with a plurality of radio points12:
`
`11 DMS Specification, available at,
`https://www.commscope.com/catalog/networking_systems/pdf/part/64262/DMS.pdf, last
`accessed on February 19, 2019. See also, Plug and Play with OneCell and DMS video at 0:30-
`0:40 (https://www.youtube.com/watch?v=RcWop6ZfgIc, last accessed on February 15, 2019)
`(providing a description of how the DMS is used as an interface between the baseband controller
`and the radio points).
`12 White Paper: DAS and small cells: A view from the leading edge, 2017, available at
`http://www.commscope.com/Docs/DAS_SmallCells_View_Leading_Edge_WP-111425-EN.pdf
`at 6, last accessed on February 19, 2019.
`
`10
`
`

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`
`45.
`
`On information and belief, OneCell meets the claim element 1[F] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`46.
`
`OneCell comprises a baseband controller configured to receive uplink signals from
`
`radio points. For example, a OneCell document states “multiple OneCell RPs can jointly receive
`
`uplink transmissions from a single UE, which are then combined at the controller.”13 Further, a
`
`OneCell brochure explains, “multiple users in a single physical cell can share the same
`
`frequencies—effectively multiplying system capacity without creating interference.”14 Each signal
`
`sent by a user would be transmitted to radio points and then to the baseband controller as an uplink
`
`signal.
`
`47.
`
`On information and belief, OneCell meets the claim element 1[G] of claim 1 of the
`
`’314 patent based on publicly available documents.
`
`48.
`
`OneCell implements a cell virtualization technique that requires scheduling of
`
`signals between at least one baseband controller (DAU) and a plurality of radio points (remote
`
`units), and OneCell is capable of joint uplink downlink transmissions between the baseband
`
`controller and radio points, which requires the use of one or more delay compensation units
`
`residing in the baseband controller, radio point, or both. For example, a video released by
`
`CommScope contains the following image and makes the statement below15:
`
`13 How does OneCell differ from traditional C-RAN systems (“OneCell and C-RAN”), available
`at, http://4.imimg.com/data4/TT/QY/MY-3485178/airvana-onecell-c-ran-small-cell-system.pdf,
`last accessed February 19, 2019 at 4.
`14 OneCell Brochure.
`15 Cell Virtualization with OneCell video at 0:25-1:02
`(https://www.youtube.com/watch?v=vEsHetvkOVA, last accessed on May 20, 2019).
`
`11
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 12 of 42 PageID #: 12
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`OneCell consists of a baseband controller connected to multiple
`points over an Ethernet LAN. The controller performs the
`baseband scheduling centrally to form a single cell without
`handovers or border interference in LTE capacity as allocated
`among users by dividing the spectrum into physical resource
`blocks...Cell virtualization multiplies the capacity of a single cell
`by reusing PRBS for different users at the same time.
`
`This is further supported by additional OneCell documentation16:
`
`Rather than create border interference and subsequently attempt to
`mitigate it, OneCell creates a single cell that eliminates cell borders
`altogether. It accomplishes this by centralizing the scheduling of
`users across the access points. Unlike a service controller,
`OneCell’s BC performs LTE resource block scheduling centrally
`across all the RP’s and all the users.
`
`A third party article also shows this capability17:
`
`OneCell centralises most of the baseband functions of a base
`station in a controller node, which serves many radio nodes
`distributed across a building. These Radio Points form a single
`large cell radiating the same cell identifiers in a synchronised
`
`16 OneCell and C-Ran at 2.
`17 CommScope create virtual small cells out of thin air, David Chambers, April 2016, available
`at, https://www.thinksmallcell.com/Enterprise/commscope-create-virtual-small-cells-out-of-thin-
`air.html, last accessed on February 15, 2019.
`
`12
`
`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 13 of 42 PageID #: 13
`
`the radio
`tightly coordinate
`manner. The controller can
`transmissions and receptions of every radio node. The controller
`also oversees the detailed interactions with the smartphones that
`are in the coverage area and tracks their RF signatures as seen by
`the radio nodes. This allows the controller to serve different users
`on the same frequency at the same time even though these users
`belong to the same physical cell.
`
`49.
`
`Accordingly, on information and belief, CommScope’s OneCell product meets all
`
`elements of, and therefore infringes, at least claim 1 of the ’314 patent.
`
`50.
`
`As a result of CommScope’s infringement of the ’314 patent, Dali has suffered and
`
`continues to suffer substantial injury and is entitled to recover all damages caused by
`
`CommScope’s infringement to the fullest extent permitted by the Patent Act, together with
`
`prejudgment interests and costs for CommScope’s wrongful conduct.
`
`51.
`
`Dali has no adequate remedy at law to prevent future infringement of the ’314
`
`patent. Dali suffers and continues to suffer irreparable harm as a result of CommScope’s patent
`
`infringement and is, therefore, entitled to injunctive relief to enjoin CommScope’s wrongful
`
`conduct.
`
`SECOND CAUSE OF ACTION
`(PATENT INFRINGEMENT UNDER 35 U.S.C. §271 of ’178 PATENT)
`
`52.
`
`53.
`
`Dali re-alleges and incorporates by reference all of the foregoing paragraphs.
`
`On information and belief, CommScope 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 ’178 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 indoor
`
`wireless coverage systems, such as its infringing ION-E and Era products, throughout the United
`
`States without authority or license.
`
`13
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 14 of 42 PageID #: 14
`
`54.
`
`On information and belief, CommScope has been, and currently is, an active
`
`inducer of infringement of the ’178 patent under 35 U.S.C. § 271(b).
`
`55.
`
`According to a CommScope webpage discussing DAS, ION-E18 “is an all-digital
`
`system” that “dynamically transports capacity wherever needed via software—without remote
`
`reconfigurations or patch changes.”
`
`56.
`
`On information and belief, ION-E is made, used, offered for sale, and sold as a
`
`digital DAS system.
`
`57.
`
`Claim 1 of the ’178 patent states: “[preamble] A host unit for use in the transport
`
`of wireless communications, comprising: [A] at least one interface to communicatively couple the
`
`host unit to at least one signal source; [B] at least one interface to communicatively couple the host
`
`unit to a plurality of remote units, including at least a first remote unit; [C] wherein the host unit
`
`is configured to receive a plurality of downlink channel signals from the at least one signal source;
`
`[D] wherein the host unit is configured to send digital representations of the plurality of downlink
`
`channel signals to the plurality of remote units; [E] wherein the host unit is configurable to send
`
`digital representations of a first set of downlink channel signals to the first remote unit at a first
`
`point in time, the first set of downlink channel signals for transmission at an antenna of the first
`
`remote unit; [F] wherein the host unit is configurable to send digital representations of a second
`
`set of downlink channel signals to the first remote unit at a second point in time, the second set of
`
`downlink channel signals for transmission at the antenna of the first remote unit; and [G] wherein
`
`a number of downlink channel signals in the first set of downlink channel signals is different from
`
`a number of downlink channel signals in the second set of downlink channel signals.”
`
`18 See https://www.commscope.com/solutions/distributed-antenna-systems-(das)/, last accessed
`on February 15, 2019.
`
`14
`
`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 15 of 42 PageID #: 15
`
`58.
`
`On information and belief, based on publicly available CommScope documents,
`
`ION-E satisfies each and every limitation recited in at least claim 1 of the ’178 patent as below.
`
`59.
`
`On information and belief, ION-E meets the preamble of claim 1 of the ’178 patent
`
`based on publicly available documents.
`
`60.
`
`ION-E is a DAS for transporting wireless communications, and it comprises a
`
`central area node (“CAN”) that corresponds to the claimed host unit. According to the ION-E
`
`Brochure19:
`
`ION®-E supports multiple technologies and networks, including 4G/LTE
`and legacy 3G and 2G networks, connecting to the macro network through
`an operator-approved radio frequency (RF) source. ION-E’s UAP
`supports frequencies from 380 MHz to 2.7 GHz to cover virtually every
`possible operator service band. Frequencies are software-defined; they can
`be changed in the field without changing the hardware.
`
`The ION-E Brochure also provides a figure showing a CAN acting as the host unit of ION-E20:
`
`19 ION-E Brochure, available at, https://www.commscope.com/Docs/ION-E_Brochure_BR-
`111353-EN.pdf at 3, last accessed on May 20, 2019.
`20 Id. at 6.
`
`15
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`

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`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 16 of 42 PageID #: 16
`
`61.
`
`On information and belief, ION-E meets claim element 1[A] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`62.
`
`ION-E comprises a CAN (host unit) that has at least one interface (RF Donor cards)
`
`that communicatively couples to an ION-E point of interface (e-POI) which connects to a base
`
`station (eNode B)21:
`
`In addition, public training materials provided by CommScope display ION-E’s system
`
`architecture and show how the host unit of ION-E connects to the signal source22:
`
`21 ION-E Solutions Guide, available at,
`https://www.anixter.com/content/dam/Suppliers/CommScope/Documents/ION-
`E_SolutionGuide_BR-107010%2013-EN%20GB_20150924_II.pdf at 3, last accessed on May
`20, 2019.
`22 Slides from https://www.commscopetraining.com/courses/webinars/wr9633/ion-esystem-
`architecture-hardware-overview/, last accessed before January 13, 2017 (“Training Materials”).
`
`16
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 17 of 42 PageID #: 17
`
`They also show the RF Donor card (“RFD”) which provides the host unit with an “[i]nterface to
`
`signal source”23:
`
`23 Id.
`
`17
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 18 of 42 PageID #: 18
`
`63.
`
`On information and belief, ION-E meets claim element 1[B] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`64.
`
`ION-E comprises a host unit (CAN) that has at least one interface (such as the CAT
`
`card or the OPT card) that communicatively couples to a plurality of remote units (Universal
`
`Access Points (“UAPs”)), including a first remote unit24:
`
`In addition, the Training Materials for ION-E provide a diagram of the system architecture
`
`showing how the CAN directly communicatively couples with the UAPs25:
`
`24 2015 ION-E Presentation by Marc Nulens, available at, https://www.btg.org/wp-
`content/uploads/2016/04/CommScope-Marc-Nulens-ION-E-BTG-Overview-20160421.pdf
`(“Nulens Presentation”) at 8, last accessed February 19, 2019.
`25 Training Material.
`
`18
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 19 of 42 PageID #: 19
`
`The CAN can also communicatively couple to the UAPs indirectly through a Transport Expansion
`
`Node (“TEN”)26:
`
`The CAN - where the RF signals are coming from the base station,
`received at the RF donor card, and then we manage the distribution
`of those signals to the UAPs, or to the TENs and to their UAPs in
`software domain. … CAN is the base station interface and that is
`where we manage the central signal distribution. We send any of
`the incoming signals to any of the UAPs.
`
`65.
`
`On information and belief, ION-E meets claim element 1[C] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`66.
`
`ION-E comprises a host unit (CAN) that is configured to receive downlink channels
`
`from at least one base station—i.e., eNode B through e-POI:
`
`26 Webinar Introduction to ION-E, Telecom Knowledge Share, Published July 22, 2016,
`available at https://www.youtube.com/watch?v=Kmw2qMlgLrU (“Webinar Introduction to ION-
`E”) at 13:45-14:25, last accessed February 19, 2019.
`
`19
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 20 of 42 PageID #: 20
`
`“So this is the typical installation of the ION-E system. Everything starts with the central area
`
`node, which receives signals from the base station. We can connect UAPs directly to the central
`
`area node here.”27 A CommScope webinar explains that28:
`
`The CAN - where the RF signals are coming from the base station,
`received at the RF donor card, and then we manage the distribution
`of those signals to the UAPs, or to the TENs and to their UAPs in
`software domain. … CAN is the base station interface and that is
`where we manage the central signal distribution. We send any of
`the incoming signals to any of the UAPs.
`
`67.
`
`On information and belief, ION-E meets claim element 1[D] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`68.
`
`The ION-E distributes digital representations of downlink signals to remote units
`
`(UAP) from the host unit (CAN):29
`
`27 Webinar Introduction to ION-E at 8:25-9:35.
`28 Id. at 13:45-14:25.
`29 See
`https://www.commscope.com/Docs/ION-E_Brochure_BR-111353-EN.pdf at 6, last visited on
`May 22, 2019.
`
`20
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 21 of 42 PageID #: 21
`
`69.
`
`According to CommScope, “ION-E is an all-digital system that runs on economical
`
`Category 6A and fiber-optic cables. It dynamically transports capacity wherever needed via
`
`software—without remote reconfigurations or patch changes. Add new operators, bands or
`
`technologies without adding hardware. ION-E’s simplicity and IT-friendly deployment model
`
`make it ideal for enterprise buildings.”30 See also:31
`
`30 See https://www.commscope.com/solutions/distributed-antenna-systems-(das)/, last visited on
`May 22, 2019.
`31 Nulens Presentation at 13.
`
`21
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 22 of 42 PageID #: 22
`
`70.
`
`The ION-E’s UAPs include antennas for transmitting downlink channel signals:32
`
`32 Training Materials at 7.
`
`22
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 23 of 42 PageID #: 23
`
`71.
`
`On information and belief, ION-E meets claim element 1[E] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`72.
`
`ION-E comprises a host unit (CAN) that can send digital representations of a first
`
`set of downlink channel signals to a first remote unit (UAP) at a first point in time, including
`
`through the TEN, and a first remote unit (UAP) is capable of receiving a set of downlink channel
`
`signals at a first point in time33:
`
`In addition, ION-E comprises software that allows for the creation of signal sets that are
`
`customized sets of downlink channel signals. Multiple signal sets from different base stations can
`
`be created and assigned to either a remote unit (UAP) or a TEN34:
`
`33 Nulens Presentation at 13.
`34 Id. at 15-16.
`
`23
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 24 of 42 PageID #: 24
`
`The UAPs (remote units) include antennas for transmitting downlink channel signals35:
`
`35 Training Materials at 7.
`
`24
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 25 of 42 PageID #: 25
`
`73.
`
`On information and belief, ION-E meets claim element 1[F] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`74.
`
`ION-E comprises a host unit (CAN) that can send digital representations of a
`
`second set of downlink channel signals to the first remote unit (UAP) at a second point in time for
`
`transmission through the antenna of the remote unit. ION-E allows for the creation of different
`
`signal sets from base stations that comprise different downlink channel signals. A second set of
`
`downlink channel signals may be sent to a first remote unit (UAP) at a different point in time from
`
`the first set. According to a CommScope webinar, “[w]e have a full control over each channel, we
`
`can turn channels on and off…and we can distribute the channels to any UAP with extreme
`
`flexibility, so any signal can go to any UAP… We create signal sets and then those signal sets can
`
`25
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 26 of 42 PageID #: 26
`
`be sent via software or software command to them, to any UAP.”36 In addition, multiple signal
`
`sets from different base stations can be created and assigned to remote units37:
`
`Moreover, the UAPs (remote units) include antennas for transmitting downlink channel signals38:
`
`36 Webinar Introduction to ION-E at 22:21-22:48.
`37 ION-E Series User’s Manual, available at, https://fccid.io/BCR-IONEUAP/User-Manual/user-
`manaul-2552804 (“ION-E User Manual”) at 14, last accessed February 19, 2019.
`38 Training Materials at 7.
`
`26
`
`

`

`Case 1:19-cv-00952-UNA Document 1 Filed 05/22/19 Page 27 of 42 PageID #: 27
`
`75.
`
`On information and belief, ION-E meets claim element 1[G] of claim 1 of the ’178
`
`patent based on publicly available documents.
`
`76.
`
`ION-E comprises a host unit that all