UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TRAXCELL TECHNOLOGIES, LLC.,
`Plaintiff,
`
`v.
`
`VERIZON WIRELESS PERSONAL
`COMMUNICATIONS
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Civil Action No. 6:20-cv-01175-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S THIRD AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Traxcell Technologies, LLC. (“Traxcell”) files this Third Amended Complaint,1 and
`
`demand for jury trial seeking relief from patent infringement by Cellco Partnership d/b/a Verizon
`
`Wireless (“Verizon”) and Ericsson, Inc. (“Ericsson”) (collectively referred to as “Defendants”),
`
`alleging infringement of the claims of U.S. Pat. No. 10,701,517; U.S. Pat. No. 10,743,135; and,
`
`U.S. Pat. No. 10,820,147 (collectively referred to as “Patents-in-Suit”), as follows:
`
`I.
`
`THE PARTIES
`
`1. Plaintiff Traxcell is a Texas Limited Liability Company, with its principal place of
`
`business located at Traxcell Technologies LLC, 617 North 4th Street, Suite "S," Waco, TX 76701.
`
`2. Verizon Wireless is Delaware corporation with its principal place of business at One
`
`Verizon Way, Basking Ridge, New Jersey and a registered agent for service of process at CT Corp
`
`System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201-3136. On information and belief,
`
`Verizon Wireless Personal Communications, LP sells and offers to sell products and services
`
`throughout Texas, including in this judicial district, and introduces products and services that
`
`1 This Third Amended Complaint is filed solely to remove issues and is filed timely according to the scheduling
`order.
`
`1
`
`Exhibit 1020 / IPR2022-00073/ Page 1 of 48
`Apple Inc. v. Traxcell Technologies, LLC
`
`

`

`perform infringing processes into the stream of commerce knowing that they would be sold in
`
`Texas and this judicial district.
`
`3. Ericsson is a corporation, with its principal place of business located at 6300 Legacy Drive,
`
`Plano, Texas 75024 and may be served with process at its registered agent Capitol Corporate
`
`Services, Inc. 206 E. 9th Street, Suite 1300, Austin, Texas 78701. On information and belief,
`
`Ericsson sells and offers to sell products and services throughout Texas, including in this judicial
`
`district, and introduces products and services that perform infringing processes into the stream of
`
`commerce knowing that they would be sold in Texas and this judicial district.
`
`II.
`
`JURISDICTION AND VENUE
`
`4. This is an action for patent infringement arising under the patent laws of the U.S., 35 U.S.C.
`
`§§ 1 et. seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`5. This Court has personal jurisdiction over Verizon because: Verizon is present within or has
`
`minimum contacts within the State of Texas and this judicial district; Verizon has purposefully
`
`availed itself of the privileges of conducting business in the State of Texas and in this judicial
`
`district; Verizon regularly conducts business within the State of Texas and within this judicial
`
`district; and Plaintiff’s cause of action arises directly from Verizon’s business contacts and other
`
`activities in the State of Texas and in this judicial district.
`
`6. Venue is proper in this district under 28 U.S.C. § 1400(b). Verizon has committed acts of
`
`infringement and has a regular and established place of business in this District.
`
`7. This Court has personal jurisdiction over Ericsson because: Ericsson is present within or
`
`has minimum contacts within the State of Texas and this judicial district; Ericsson has purposefully
`
`availed itself of the privileges of conducting business in the State of Texas and in this judicial
`
`district; Ericsson regularly conducts business within the State of Texas and within this judicial
`
`2
`
`Exhibit 1020 / IPR2022-00073
`Page 2 of 48
`
`

`

`district; and Plaintiff’s cause of action arises directly from Ericsson’s business contacts and other
`
`activities in the State of Texas and in this judicial district.
`
`8. Venue is proper in this district under 28 U.S.C. § 1400(b). Ericsson has committed acts of
`
`infringement and has a regular and established place of business in this District, including at least
`
`1703 W 5th St, Austin, TX 78703.
`
`V.
`
`INFRINGEMENT (‘517 Patent (Attached as exhibit A))
`
`9. On June 30, 2020, U.S. Patent No. 10,701,517 (“the ‘517 patent”), attached as Exhibit C,
`
`entitled “Wireless network and method for suggesting corrective action based on
`
`performance and controlling access to location information” was duly and legally issued
`
`by the U.S. Patent and Trademark Office. Traxcell owns the ‘517 patent by assignment.
`
`10. The ‘517 Patent’s Abstract states, “A mobile device, wireless network and their method of
`
`operation provide suggestion of corrective actions of the network based on performance
`
`evaluation of communications between a connected mobile device and the communications
`
`network. The communications network tracks location of mobile devices and stores
`
`performance data of connections between the mobile devices and the network. The
`
`performance data is referenced to expected performance data to determine whether a fault
`
`exists and a corrective action is suggested when the fault exists. Access to the location
`
`information by another computer is controlled by a preference flag set in response to a
`
`communication from the mobile device.”
`
`A. Verizon
`
`11. The following preliminary exemplary chart provides notice of Traxcell’s allegations of
`
`infringement against Verizon:
`
`3
`
`Exhibit 1020 / IPR2022-00073
`Page 3 of 48
`
`

`

`Corresponding Structure in Accused Systems
`
`Plaintiff contends the Verizon wireless network has base stations adapted to transmits
`and receive radio frequency signals from one or more wireless devices.
`
`Representative
`Claim
`
`A wireless network
`including:
`
`a radio tower
`adapted to receive
`radio frequency
`signals from, and
`transmit radio
`frequency signals
`to, at least one
`wireless device;
`
`a system of
`computers
`programmed to
`perform steps of
`referencing
`performance of the
`at least one
`wireless device
`with wireless
`network known
`parameters and
`routinely storing
`performance data
`
`Radio Tower(s)
`Please note that Verizon uses three types of self-organizing network technology, that
`is, C-SON, D-SON and V-SON and uses network equipment or solutions supplied
`from vendors, for example, from Ericsson, etc. In addition to RAN vendor and third-
`party supplied SON features, Verizon has also developed its own proprietary SON
`implementation, known as V-SON.
`
`Plaintiff contends that a system of computers including Operations Support System
`(OSS or OSS-RC) of Verizon Wireless’ wireless telecommunications network,
`Ericsson’s SON solution [which includes SON Optimization Manager, SON Policy
`Manager, SON Visualization, etc. and the software programs that run them] interfaced
`or integrated with said Operations Support System (OSS or OSS-RC), and a set or
`network of computers [which include Trace Processing Server (TPS), OSS Data
`Gateway, RAN Analyzer, RAN Configuration Manager, Frequency Optimizer, Cell
`Optimizer, Network Capacity Planner and Implementation Server] operating,
`implementing and supporting the Ericsson’s SON solution in the wireless
`
`4
`
`Exhibit 1020 / IPR2022-00073
`Page 4 of 48
`
`

`

`Representative
`Claim
`
`Corresponding Structure in Accused Systems
`
`for the at least one
`wireless device,
`
`telecommunications network, constituting the “system of computers,” corresponds to
`this claim limitation.
`
`Further, Ericsson’s SON solution includes SON Optimization Manager (SON OM),
`SON Policy Manager, SON Visualization, etc. and the system of computers
`supporting the Ericsson’s SON solution include Verizon Wireless’ wireless
`telecommunications network’s Operations Support System (OSS or OSS-RC), Trace
`Processing Server (TPS), OSS Data Gateway, RAN Analyzer, RAN Configuration
`Manager, Frequency Optimizer, Cell Optimizer, Network Capacity Planner and
`Implementation Server. (Please note that Ericsson SON Optimization Manager
`together with Ericsson Network Manager and Network IQ delivers the full suite.)
`
`Plaintiff contends that the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.} is programmed to reference performance of the
`wireless device(s) with wireless network known parameters and to routinely store
`performance data for the wireless device(s). That is, the system of computers
`executing or loaded with Ericsson’s SON solution receives or collects UE-referenced
`network and device performance measurements from the MDT (Minimization of
`Drive Tests) reports, UE Measurement Reports, etc. and compares the collected (or
`received) performance data against the corresponding pre-defined standards or
`thresholds.
`
`The Ericsson’s SON solution has software code specifically designed for use by one
`or more computers. The system of computers is linked or connected to the wireless
`network consisting of the various network elements including the radio-tower(s) or
`base-station(s).
`
`Plaintiff contends that the system of computers executing or loaded with Ericsson’s
`SON solution; and operating, implementing and supporting SON solution in the
`wireless telecommunications network, corresponds to this claim limitation, as the
`system of computers executing or loaded with Ericsson’s SON solution references
`performance of the wireless device(s) with wireless network known parameters and
`routinely stores performance data for the wireless device(s).
`
`The Ericsson’s SON software codes are programmed to routinely store the
`performance data for a wireless device in a memory or cache associated with the
`system of computers because the software codes are programmed to collect
`performance measurements pertaining to qualitative and quantitative aspects of the
`
`
`
`
` 5
`
`Exhibit 1020 / IPR2022-00073
`Page 5 of 48
`
`

`

`Representative
`Claim
`
`Corresponding Structure in Accused Systems
`
`operation of wireless network. That is, the system of computers installed or
`compatible with Ericsson’s SON solution routinely references performance
`measurements pertaining to qualitative and quantitative aspects of the wireless
`device(s) (for example, expressed in terms of Key Performance Indices or KPIs,
`Performance Metrics, Performance Data, etc.) with wireless network known
`parameters and stores the performance data for one or more wireless devices.
`
`Plaintiff contends that the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.} receives the performance data and suggests one or
`more corrective actions in conformity with a comparison of the performance data and
`the wireless network known parameters.
`
`
`
`
`
`Plaintiff contends that the wireless network can include another computer(s) (for
`example, third-parties, LBS providers, subsidiaries, etc.) other than the system of
`computers and another computer(s) is coupled in communication with the system of
`computers executing or loaded with Ericsson’s SON solution {which includes SON
`Optimization Manager (SON OM), SON Policy Manager, SON Visualization, etc. }.
`
`The following exemplifies this limitation’s existence in Accused Systems:
`
`wherein the system
`of computers
`further receives
`the performance
`data and suggests
`at least one
`corrective action
`in conformity with
`a comparison of
`the performance
`data and the
`wireless network
`known parameters;
`and
`
`another one or more
`computers other
`than the system of
`computers,
`wherein at least
`one of the another
`one or more
`computers is
`coupled in
`communication
`with the system of
`computers,
`
`
`
`
` 6
`
`Exhibit 1020 / IPR2022-00073
`Page 6 of 48
`
`

`

`Representative
`Claim
`
`Corresponding Structure in Accused Systems
`
`wherein the system
`of computers is
`programmed to
`provide an
`indication of
`location of the at
`least one wireless
`device to the
`another one or
`more computer,
`
`and wherein the
`another one or
`more computers,
`responsive to a
`communication
`from the at least
`one wireless
`device, set a no
`access flag within
`
`Plaintiff contends that another computer(s) (for example, third-parties, LBS
`providers, subsidiaries, etc.) is coupled in communication with the system of
`computers executing or loaded with Ericsson’s SON solution {which includes SON
`Optimization Manager (SON OM), SON Policy Manager, SON Visualization, etc.}.
`The system of computers can provide access to an indication of location to another
`computer(s).
`
`Plaintiff contends that another computer(s) (for example, PDE, Positioning Engine,
`Location server, third-parties, LBS providers, subsidiaries, etc.) is coupled in
`communication with the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.}.
`
`The Another computer(s) being in communication with the system of computers and
`responsive to a communication from the wireless devices.
`
`7
`
`Exhibit 1020 / IPR2022-00073
`Page 7 of 48
`
`

`

`Corresponding Structure in Accused Systems
`
`Plaintiff contends that another computer(s) (for example, PDE, Positioning Engine,
`Location server, third-parties, LBS providers, subsidiaries, etc.) is coupled in
`communication with the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.}.
`
`The Another computer(s) being in communication with the system of computers and
`responsive to a communication from the wireless devices are capable of configuring
`or setting a no access flag within the memory of another computer(s).
`
`Therefore, the Another computer(s) provides access to an indication of location from
`another computer(s) if the no access flag is reset and denies access to the indication
`of location from another computer(s) if the no access flag is set.
`
`Representative
`Claim
`
`a memory of at
`least one of the
`another one or
`more computers,
`
`and wherein the
`another one or
`more computers
`provides access to
`an indication of
`location of the at
`least one wireless
`device from the
`another one or
`more computers if
`the no access flag
`is reset and denies
`access to the
`indication of
`location of the at
`least one wireless
`device from the
`another one or
`more computers if
`the no access flag
`is set.
`
`12. Verizon makes, uses, offers to sell, and/or sells within or imports into the U.S. wireless
`
`networks, wireless-network components, and related services that use performance
`
`measurements to suggest corrective actions and controlling access to location information
`
`such that Verizon infringes claims 1–29 of the ‘517 patent, literally or under the doctrine
`
`of equivalents.
`
`8
`
`Exhibit 1020 / IPR2022-00073
`Page 8 of 48
`
`

`

`13. Verizon put the inventions claimed by the ‘517 Patent into service (i.e., used them); but for
`
`Verizon’s actions, the claimed-inventions embodiments involving Verizon’s products and
`
`services would never have been put into service. Verizon’s acts complained of herein
`
`caused those claimed-invention embodiments as a whole to perform, and Verizon obtaining
`
`monetary and commercial benefit from it.
`
`14. Verizon has and continues to induce infringement. Verizon have actively encouraged or
`
`instructed others (e.g., its customers), and continues to do so, on how to use its products
`
`and services (e.g., U.S. wireless networks, wireless-network components that use
`
`performance measurements to suggest corrective actions and controlling access to location
`
`information) such to cause infringement claims 1–29 of the ‘517 patent, literally or under
`
`the doctrine of equivalents. Moreover, Verizon has known and should have known of the
`
`‘517 patent, by at least by the date of the patent’s issuance, or from the issuance of the ‘284
`
`patent, which followed the date that the patent’s underlying application was cited to
`
`Verizon by the U.S. Patent and Trademark Office during prosecution of one of Verizon’s
`
`patent applications, such that Verizon knew and should have known that it was and would
`
`be inducing infringement.
`
`15. Verizon has and continues to contributorily infringe. Verizon has actively encouraged or
`
`instructed others (e.g., its customers and/or the customers of its related companies), and
`
`continues to do so, on how to use its products and services e.g., U.S. wireless networks,
`
`wireless-network components that use performance measurements to suggest corrective
`
`actions and controlling access to location information) such as to cause infringement of
`
`one or more of claims 1–29 of the ‘517 patent, literally or under the doctrine of equivalents.
`
`Moreover, Verizon has known of the ‘517 patent and the technology underlying it from at
`
`
`
`
` 9
`
`Exhibit 1020 / IPR2022-00073
`Page 9 of 48
`
`

`

`least the date of issuance of the patent or from the issuance of the ‘284 patent, which
`
`followed the date that the patent’s underlying application was cited to Verizon by the U.S.
`
`Patent and Trademark Office during prosecution of one of Verizon’s patent applications,
`
`such that Verizon knew and should have known that it was and would be contributorily
`
`infringing.
`
`16. Verizon have caused and will continue to cause Traxcell damage by infringing the ‘517
`
`patent.
`
`B. Ericsson
`
`17. The following preliminary exemplary chart provides notice of Traxcell’s allegations of
`
`infringement against Ericsson:
`
`Representative
`Claim
`
`A wireless network
`including:
`
`
`
`Corresponding Structure in Accused Systems
`
`Plaintiff contends the Verizon wireless network has Ericsson base stations (and
`others) adapted to transmits and receive radio frequency signals from one or more
`wireless devices, including Ericsson devices.
`
`a radio tower
`adapted to receive
`radio frequency
`signals from, and
`transmit radio
`frequency signals
`to, at least one
`wireless device;
`
`
`
`
`
`
`
`
` 10
`
`Exhibit 1020 / IPR2022-00073
`Page 10 of 48
`
`

`

`Representative
`Claim
`
`Corresponding Structure in Accused Systems
`
`a system of
`computers
`programmed to
`perform steps of
`referencing
`performance of the
`at least one
`wireless device
`with wireless
`network known
`parameters and
`routinely storing
`performance data
`for the at least one
`wireless device,
`
`
`Radio Tower(s)
`Please note that Verizon uses three types of self-organizing network technology, that
`is, C-SON, D-SON and V-SON and uses network equipment or solutions supplied
`from vendors, for example, from Ericsson, etc. In addition to RAN vendor and third-
`party supplied SON features, Verizon has also developed its own proprietary SON
`implementation, known as V-SON.
`
`Plaintiff contends that a system of computers including Operations Support System
`(OSS or OSS-RC) of Verizon Wireless’ wireless telecommunications network,
`Ericsson’s SON solution [which includes SON Optimization Manager, SON Policy
`Manager, SON Visualization, etc. and the software programs that run them] interfaced
`or integrated with said Operations Support System (OSS or OSS-RC), and a set or
`network of computers [which include Trace Processing Server (TPS), OSS Data
`Gateway, RAN Analyzer, RAN Configuration Manager, Frequency Optimizer, Cell
`Optimizer, Network Capacity Planner and Implementation Server] operating,
`implementing and supporting the Ericsson’s SON solution in the wireless
`telecommunications network, constituting the “system of computers,” corresponds to
`this claim limitation.
`
`Further, Ericsson’s SON solution includes SON Optimization Manager (SON OM),
`SON Policy Manager, SON Visualization, etc. and the system of computers
`
`
`
`
` 11
`
`Exhibit 1020 / IPR2022-00073
`Page 11 of 48
`
`

`

`Representative
`Claim
`
`Corresponding Structure in Accused Systems
`
`supporting the Ericsson’s SON solution include Verizon Wireless’ wireless
`telecommunications network’s Operations Support System (OSS or OSS-RC), Trace
`Processing Server (TPS), OSS Data Gateway, RAN Analyzer, RAN Configuration
`Manager, Frequency Optimizer, Cell Optimizer, Network Capacity Planner and
`Implementation Server. (Please note that Ericsson SON Optimization Manager
`together with Ericsson Network Manager and Network IQ delivers the full suite.)
`
`Plaintiff contends that the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.} is programmed to reference performance of the
`wireless device(s) with wireless network known parameters and to routinely store
`performance data for the wireless device(s). That is, the system of computers
`executing or loaded with Ericsson’s SON solution receives or collects UE-referenced
`network and device performance measurements from the MDT (Minimization of
`Drive Tests) reports, UE Measurement Reports, etc. and compares the collected (or
`received) performance data against the corresponding pre-defined standards or
`thresholds.
`
`The Ericsson’s SON solution has software code specifically designed for use by one
`or more computers. The system of computers is linked or connected to the wireless
`network consisting of the various network elements including the radio-tower(s) or
`base-station(s).
`
`Plaintiff contends that the system of computers executing or loaded with Ericsson’s
`SON solution; and operating, implementing and supporting SON solution in the
`wireless telecommunications network, corresponds to this claim limitation, as the
`system of computers executing or loaded with Ericsson’s SON solution references
`performance of the wireless device(s) with wireless network known parameters and
`routinely stores performance data for the wireless device(s).
`
`The Ericsson’s SON software codes are programmed to routinely store the
`performance data for a wireless device in a memory or cache associated with the
`system of computers because the software codes are programmed to collect
`performance measurements pertaining to qualitative and quantitative aspects of the
`operation of wireless network. That is, the system of computers installed or
`compatible with Ericsson’s SON solution routinely references performance
`measurements pertaining to qualitative and quantitative aspects of the wireless
`device(s) (for example, expressed in terms of Key Performance Indices or KPIs,
`
`12
`
`Exhibit 1020 / IPR2022-00073
`Page 12 of 48
`
`

`

`Corresponding Structure in Accused Systems
`
`Performance Metrics, Performance Data, etc.) with wireless network known
`parameters and stores the performance data for one or more wireless devices.
`
`Plaintiff contends that the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.} receives the performance data and suggests one or
`more corrective actions in conformity with a comparison of the performance data and
`the wireless network known parameters.
`
`
`
`
`
`Plaintiff contends that the wireless network can include another computer(s) (for
`example, third-parties, LBS providers, subsidiaries, etc.) other than the system of
`computers and another computer(s) is coupled in communication with the system of
`computers executing or loaded with Ericsson’s SON solution {which includes SON
`Optimization Manager (SON OM), SON Policy Manager, SON Visualization, etc. }.
`
`The following exemplifies this limitation’s existence in Accused Systems:
`
`Representative
`Claim
`
`wherein the system
`of computers
`further receives
`the performance
`data and suggests
`at least one
`corrective action
`in conformity with
`a comparison of
`the performance
`data and the
`wireless network
`known parameters;
`and
`
`another one or more
`computers other
`than the system of
`computers,
`wherein at least
`one of the another
`one or more
`computers is
`coupled in
`communication
`with the system of
`computers,
`
`
`
`
` 13
`
`Exhibit 1020 / IPR2022-00073
`Page 13 of 48
`
`

`

`Representative
`Claim
`
`Corresponding Structure in Accused Systems
`
`wherein the system
`of computers is
`programmed to
`provide an
`indication of
`location of the at
`least one wireless
`device to the
`another one or
`more computer,
`
`and wherein the
`another one or
`more computers,
`responsive to a
`communication
`from the at least
`one wireless
`device, set a no
`access flag within
`
`
`
`
`
`Plaintiff contends that another computer(s) (for example, third-parties, LBS
`providers, subsidiaries, etc.) is coupled in communication with the system of
`computers executing or loaded with Ericsson’s SON solution {which includes SON
`Optimization Manager (SON OM), SON Policy Manager, SON Visualization, etc.}.
`The system of computers can provide access to an indication of location to another
`computer(s).
`
`
`
`
`
`Plaintiff contends that another computer(s) (for example, PDE, Positioning Engine,
`Location server, third-parties, LBS providers, subsidiaries, etc.) is coupled in
`communication with the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.}.
`
`The Another computer(s) being in communication with the system of computers and
`responsive to a communication from the wireless devices.
`
` 14
`
`Exhibit 1020 / IPR2022-00073
`Page 14 of 48
`
`

`

`Corresponding Structure in Accused Systems
`
`Plaintiff contends that another computer(s) (for example, PDE, Positioning Engine,
`Location server, third-parties, LBS providers, subsidiaries, etc.) is coupled in
`communication with the system of computers executing or loaded with Ericsson’s
`SON solution {which includes SON Optimization Manager (SON OM), SON Policy
`Manager, SON Visualization, etc.}.
`
`The Another computer(s) being in communication with the system of computers and
`responsive to a communication from the wireless devices are capable of configuring
`or setting a no access flag within the memory of another computer(s).
`
`Therefore, the Another computer(s) provides access to an indication of location from
`another computer(s) if the no access flag is reset and denies access to the indication
`of location from another computer(s) if the no access flag is set.
`
`Representative
`Claim
`
`a memory of at
`least one of the
`another one or
`more computers,
`
`and wherein the
`another one or
`more computers
`provides access to
`an indication of
`location of the at
`least one wireless
`device from the
`another one or
`more computers if
`the no access flag
`is reset and denies
`access to the
`indication of
`location of the at
`least one wireless
`device from the
`another one or
`more computers if
`the no access flag
`is set.
`
`18. Ericsson makes, uses, offers to sell, and/or sells within or imports into the U.S. wireless
`
`networks, wireless-network components, and related services that use performance
`
`measurements to suggest corrective actions and controlling access to location information
`
`such that Ericsson infringes claims 1–29 of the ‘517 patent, literally or under the doctrine
`
`of equivalents.
`
`15
`
`Exhibit 1020 / IPR2022-00073
`Page 15 of 48
`
`

`

`19. Ericsson put the inventions claimed by the ‘517 Patent into service (i.e., used them); but
`
`for Ericsson’s actions, the claimed-inventions embodiments involving Ericsson’s products
`
`and services would never have been put into service. Ericsson’s acts complained of herein
`
`caused those claimed-invention embodiments as a whole to perform, and Ericsson
`
`obtaining monetary and commercial benefit from it.
`
`20. Ericsson has and continues to induce infringement. Ericsson have actively encouraged or
`
`instructed others (e.g., its customers, such as Verizon), and continues to do so, on how to
`
`use its products and services (e.g., U.S. wireless networks, wireless-network components
`
`(including Ericsson network components) that use performance measurements to suggest
`
`corrective actions and controlling access to location information) such to cause
`
`infringement claims 1–29 of the ‘517 patent, literally or under the doctrine of equivalents.
`
`Moreover, Ericsson has known and should have known of the ‘517 patent, by at least by
`
`the date of the patent’s issuance, or from the issuance of the ‘284 patent, which followed
`
`the date that the patent’s underlying application was cited to Ericsson by the U.S. Patent
`
`and Trademark Office during prosecution of one of Ericsson’s patent applications, such
`
`that Ericsson knew and should have known that it was and would be inducing infringement.
`
`21. Ericsson has and continues to contributorily infringe. Ericsson has actively encouraged or
`
`instructed others (e.g., its customers, such as Verizon, and/or the customers of its related
`
`companies), and continues to do so, on how to use its products and services e.g., U.S.
`
`wireless networks, wireless-network components
`
`(including Ericsson network
`
`components) that use performance measurements to suggest corrective actions and
`
`controlling access to location information) such as to cause infringement of one or more of
`
`claims 1–29 of the ‘517 patent, literally or under the doctrine of equivalents. Moreover,
`
`
`
`
` 16
`
`Exhibit 1020 / IPR2022-00073
`Page 16 of 48
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`

`

`Ericsson has known of the ‘517 patent and the technology underlying it from at least the
`
`date of issuance of the patent or from the issuance of the ‘284 patent, which followed the
`
`date that the patent’s underlying application was cited to Ericsson by the U.S. Patent and
`
`Trademark Office during prosecution of one of Ericsson’s patent applications, such that
`
`Ericsson knew and should have known that it was and would be contributorily infringing.
`
`Ericsson have caused and will continue to cause Traxcell damage by infringing the ‘517
`
`patent.
`
`VI.
`
`INFRINGEMENT (‘135 Patent (Attached as exhibit B))
`
`22. On August 11, 21020, U.S. Patent No. 10,743,135 (“the ‘135 patent”), attached as Exhibit
`
`D, entitled “Wireless network and method for suggesting corrective action in response to
`
`detecting communications errors” was duly and legally issued by the U.S. Patent and
`
`Trademark Office. Traxcell owns the ‘135 patent by assignment.
`
`23. The ‘135 Patent’s Abstract states, “A mobile wireless network and a method of operation
`
`provide analysis of mobile wireless device communications and suggested corrective
`
`initiated upon detecting communications performance issues. In some embodiments, the
`
`operations include blocking access to location information pertaining to a mobile wireless
`
`device based on the state of access flag that is maintained in the network for the mobile
`
`wireless device.”
`
`A. Verizon
`
`24. The following preliminary exemplary chart provides Traxcell’s allegations of
`
`infringement.
`
`
`
`
` 17
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`Page 17 of 48
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`

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`Corresponding Structure in Accused Systems
`
`The following exemplifies this limitation’s existence in Accused Systems:
`
`Representative
`Claim
`
`A wireless network,
`comprising:
`
`at least two wireless
`devices each
`communicating via
`radio frequency
`signals;
`
`a system of
`computers
`programmed to
`perform steps of
`referencing
`performance of at
`least one of the at
`least two wireless
`devices with
`wireless network
`known parameters
`and routinely
`storing
`performance data
`
`Please note that Verizon uses three types of self-organizing network technology, that is,
`C-SON, D-SON and V-SON and uses network equipment or solutions supplied from
`vendors, for example, from Ericsson, etc. In addition to RAN vendor and third-party
`supplied SON features, Verizon has also developed its own proprietary SON
`implementation, known as V-SON.
`
`Plaintiff contends that a system of computers including Operations Support System
`(OSS or OSS-RC) of Verizon Wireless’ wireless telecommunications network,
`Ericsson’s SON solution [which includes SON Optimization Manager, SON Policy
`Manager, SON Visualization, etc. and the software programs that run them] interfaced
`or integrated with said Operations Support System (OSS or OSS-RC), and a set or
`network of computers [which include Trace Processing Server (TPS), OSS Data
`Gateway, RAN Analyzer, RAN Configuration Manager, Frequency Optimizer, Cell
`Optimizer, Network Capacity Planner and Implementation Server] operating,
`implementing and supporting
`the Ericsson’s SON solution
`in
`the wireless
`
`18
`
`Exhibit 1020 / IPR2022-00073
`Page 18 of 48
`
`

`

`Representative
`Claim
`
`for the at least one
`of the at least two
`wireless devices;
`
`a rad