`
`Western District of Texas
`Waco Division
`
`§ § § § § § § § § § § § §
`
`No. 6:21-cv-816
`Patent Case
`Jury Trial Demanded
`
`United States District Court
` WAG ACQUISITION, L.L.C.,
`
`Plaintiff,
`
`– against –
` GOOGLE LLC and
`YOUTUBE, INC.,
`
`Defendants.
`
`
`
`Plaintiff WAG Acquisition, L.L.C., for its complaint against Defendants,
`alleges as follows:
`1.
`Plaintiff’s predecessor, known as SurferNETWORK, developed
`technology to improve the process of delivering streaming media over the
`Internet, reflected in a family of United States patents including without
`limitation U.S. Patent Nos. 9,742,824; 9,729,594; and 9,762,636 (the “patents-
`in-suit”).
`Page 1 of 19
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`INTRODUCTION
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0001
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 2 of 19
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`Defendants have used the technology taught and claimed in the
`2.
`patents-in-suit to their substantial financial benefit, to achieve responsive and
`stable delivery of media, including without limitation video-on-demand and
`live streaming programming, which Defendants provide via the Internet in the
`United States and worldwide, for pre-recorded and live programming,
`delivered to desktop, tablet, smartphone, smart TV, streaming stick, and other
`streaming device and media player platforms, by way of their streaming
`services (the “YouTube Streaming Services”).
`3.
`Plaintiff alleges that Defendants’ Internet delivery of streaming
`video via the YouTube Streaming Services have infringed the patents-in-suit, as
`more particularly specified herein.
`4. WAG Acquisition, L.L.C. is a New Jersey limited liability company
`with its principal place of business at 275 Route 10 East, Suite 220-313,
`Succasunna, New Jersey 07876.
`5.
`Defendant Google LLC (“Google”) is a Delaware limited liability
`company with its principal place of business at 1600 Amphitheatre Parkway,
`Mountain View, California 94043, and an address in this District at 500 West
`2nd Street, Austin, Texas 78701. On information and belief, based upon
`Page 2 of 19
`
`THE PARTIES
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0002
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 3 of 19
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`YouTube’s published terms of service, in recent years, Google has taken over
`the operation of the YouTube website.
`6.
`Defendant YouTube, Inc. (“YouTube”) is a Delaware corporation
`with its principal place of business at 901 Cherry Avenue, San Bruno, California
`94066, and an address in this District at 500 West 2nd Street, Austin, Texas
`78701. On information and belief, YouTube has been responsible for the
`operation of the YouTube website for some portion of the term of the patents-
`in-suit.
`7.
`The Court has subject matter jurisdiction pursuant to 28 U.S.C.
`§§ 1331 and 1338(a), in that this action arises under the patent laws of the
`United States, 35 U.S.C. §§ 1 et seq.
`8.
`This Court has personal jurisdiction over Defendants because they
`have engaged in systematic and continuous business activities in this District,
`including acts of patent infringement within this District giving rise to the
`claims asserted herein.
`9.
`Defendants have established minimum contacts with this forum
`such that the exercise of jurisdiction over Defendants would not offend
`traditional notions of fair play and substantial justice. Defendants offer
`products and services in this District. Defendant Google LLC is registered to do
`Page 3 of 19
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`JURISDICTION AND VENUE
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0003
`
`
`
`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 4 of 19
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`business in the State of Texas. Defendants have a substantial number of
`technical employees at their facilities in Austin, Texas. On information and
`belief, a substantial portion of those employees in this District are engineers
`who work on streaming media development and related technology. On
`information and belief, Defendants’ technical employees within this District
`have committed acts of infringement on behalf of Defendants in this District, by
`conduct including configuring and managing YouTube servers and software for
`media player devices, and testing and/or using media player devices, to infringe
`the patents-in-suit as hereinafter alleged.
`10. Further as part of said activities, on information and belief,
`Defendants operate in this District, at locations including Midland, El Paso,
`Austin, and San Antonio, “edge” distribution servers known as Google Global
`Cache (“GGC”) servers, which are operated by Defendants’ employees and
`stream YouTube videos in a manner alleged to be infringing hereunder, and use
`and distribute media player software on computer-readable media also in a
`manner alleged to be infringing.
`11. Venue is proper in this District pursuant to 28 U.S.C. § 1400(b)
`because Defendants have regular and established places of business in this
`District and have committed acts of infringement in this District by reason, inter
`alia, of having acted in this District to configure and manage YouTube servers
`Page 4 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0004
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 5 of 19
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`for distributing streaming video, and software for media player devices, and to
`test and/or use media player devices, in a manner that infringes the patents-in-
`suit as hereinafter alleged. Defendants have further committed acts of
`infringement in this District by reason on their making and using GGC servers
`situated in this District.
`12. The patents-in-suit comprise the following United States patents,
`which were duly and legally issued on the dates indicated:
` U.S. Patent No. 9,742,824 (the “’824 patent”), Issue Date: August 22, 2017,
`Title: Streaming Media Delivery System. A copy of the ’824 patent is
`attached hereto as Exhibit A and incorporated herein by reference.
` U.S. Patent No. 9,729,594 (the “’594 patent”), Issue Date: August 8, 2017,
`Title: Streaming Media Delivery System. A copy of the ’594 patent is
`attached hereto as Exhibit B and incorporated herein by reference.
` U.S. Patent No. 9,762,636 (the “’636 patent”), Issue Date: September 12,
`2017, Title: Streaming Media Delivery System. A copy of the ’636 patent
`is attached hereto as Exhibit C and incorporated herein by reference.
` 13. The patents-in-suit were developed in the course of Surfer-
`NETWORK’s business and were assigned by Harold Price (the inventor) to
`SurferNETWORK. Plaintiff now owns all rights to the patents-in-suit, including
`without limitation all rights to recover for infringement of the patents-in-suit.
`Page 5 of 19
`
`THE PATENTS‐IN‐SUIT
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0005
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 6 of 19
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`14. Plaintiff has complied with the marking provisions of 35 U.S.C.
`§ 287(a), and also required those persons authorized to operate for or under
`Plaintiff to comply therewith.
`15. The patents-in-suit concern technological solutions to two
`problems that SurferNETWORK perceived in the early streaming media
`implementations that characterized the prior art. First, the beginning of
`playback, when a user clicked on a program, would entail a significant period
`of “buffering,” during which the user would typically only see an hourglass.
`16. During this period, the user would have to wait until the player
`accumulated sufficient content over its Internet connection for the program to
`start. Second, even after having been started, if the program stream became
`interrupted, a repeat of the long and frustrating “buffering”/hourglass
`sequence would be necessary, and this uneven stuttering behavior could occur
`repeatedly. These problems resulted in a poor user experience and greatly
`disadvantaged Internet streaming media as compared competitively against
`other forms of audio and/or video media, such as radio and TV.
`17. SurferNETWORK sought a solution that would jump start Internet
`media playback to achieve the perception of “Instant On,” so as to provide a user
`experience akin to what ordinarily happened when turning on a transistor
`radio. The patents-in-suit address the identified shortcomings in the prior art
`Page 6 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0006
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 7 of 19
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`by changing the manner of use of computer facilities and the sequence of
`operations by which streaming media is delivered over an Internet connection,
`to provide an Internet streaming user experience that would then be
`comparable to the immediacy and continuity that the user enjoyed with
`ordinary radio and television.
`18. The advances that the patents-in-suit assert improve over the prior
`art include achieving the twin and simultaneous objects of (1) fast streaming
`startup after a user requests a stream, and (2) avoiding interruptions once the
`streaming starts, for the duration of the streamed program. The claims of the
`patents-in-suit spell out not only these functional twin objectives, but also
`recite how to implement a process that achieves both objectives—i.e., making
`the data constituting the program stream available as discrete chunks
`identified by serial ID, responding to client requests made for the chunks by
`their serial IDs, and sending each requested chunk comprising the entire
`stream at a higher-than-playback transmission rate. By doing these things, the
`patented mechanism ensures that each chunk can be transferred to the client
`before it is needed for playback, so the streaming client will have the latitude it
`needs to control the timing of its chunk requests so as to maintain its input
`buffer at a desired level for the entire transmission of the stream, thereby
`achieving the desired advance over the prior art. The claims are thus directed
`Page 7 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0007
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 8 of 19
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`at specific technological measures that improve the speed and reliability of how
`the client and server computers communicate. They utilize the computer
`components in each such computer to function in a different way than those
`components were used in prior approaches, thereby improving how computers
`communicate.
`19.
`Inventive concepts in the patents-in-suit lie in the ability to satisfy
`the requirements for fast streaming startup and uninterrupted delivery by
`switching to a “pull” model, where the flow is regulated by the pace of client
`requests, rather than trying to have the server pace its own delivery, and in
`making the pull mechanism workable, by (i) pre-collecting quantities of the
`program in time-sequenced chunks, (ii) using serial identifiers to ensure
`proper ordering of the chunks (even if some chunks are sent more quickly than
`others), (iii) making the server responsive to requests for chunks by their serial
`identifiers, and (iv) ensuring that the server will send each chunk faster than
`the playback rate.
`20. With regard to the claims concerning receiving the streams (as in
`the ’594 patent), further inventive concepts lie in the client’s ability to monitor
`the state of its buffer and rate of consumption of media to determine when to
`request chunks, and how many to request. The claims at issue make clear that
`not only the startup but the entire duration of the program is streamed in this
`Page 8 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0008
`
`
`
`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 9 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`COUNT I: INFRINGEMENT OF THE ’824 PATENT
`
`manner, and using this combination of steps for sustained media streaming was
`not conventional at the time of the invention.
`21. Defendants’ accused systems avoid the delays and stuttering that
`characterized the prior art by using the technology claimed in Plaintiff’s
`patents.
`22. Plaintiff repeats and realleges the averments of paragraphs 1-21
`above as if fully set forth at length herein.
`23. Defendants have each infringed the ’824 patent under 35 U.S.C.
`§ 271(a) by making and using server systems in accordance with one or more
`claims thereof, without authorization and in the United States, by conduct as
`hereinafter more particularly alleged.
`24.
`In particular, the YouTube Streaming Services have taken
`advantage of Plaintiff’s improved technology as claimed in the ’824 patent, from
`and before the date that patent issued through the remainder of its term.
`25. With regard to claim 1, the YouTube Streaming Services distribute
`(and for a long time prior hereto and, during the term of the ’824 patent, have
`distributed) pre-recorded video programs that are digitally stored in and read
`from its server systems, located in, or controlled from, the United States. Media
`data elements representing a program as distributed by the YouTube
`Page 9 of 19
`
`Petitioners' Exhibit 1057
`Page 0009
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 10 of 19
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`Streaming Services each comprise a digitally encoded portion of the program,
`for example, in video/mp4 or audio/webm encoding at a playback rate
`corresponding to the encoding. The media data elements are serially identified,
`for example by “rn” identifiers, which indicate a time sequence of the media
`data elements:
`
`
`YouTube streaming request/response, showing serial ID
`The above shows a request captured in mid-stream for a video segment having
`the rn identifier 102 specified in the client request. The next following
`requests/responses are identical, except that the rn numbers are incremented
`for each request, with audio segments for the stream interleaved with video
`segments, in a repetitive pattern that continues until the end of the program.
`26. The media data elements are stored in a data structure under the
`control of the server system. The server system receives “GET” requests (as
`Page 10 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0010
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 11 of 19
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`shown in the figure above) from user systems via data connections over the
`Internet, for media data elements identified by an rn number. Responsive to
`those requests, the server system sends to the requesting user system the
`media data elements having those serial identifiers corresponding to the
`request. The data connection of the server to the user system, used for so
`responding, has a data rate more rapid than the playback rate of the media data
`elements that are being sent via that connection, and each sending is at a
`transmission rate that is as fast as that data connection will allow. The media
`data elements being sent are selected without depending on the server system
`maintaining a record of the last media data element that had been sent to the
`requesting user system. All of the media data elements that are so sent by the
`server system to the one or more user systems are sent in response to the user
`system requests, and all of the media data elements that are sent by the server
`system to the requesting user systems are sent from the data structure under
`the control of the server system as the media data elements were first stored
`therein. 27. Furthermore, with regard to the dependent claims, as reflected in
`the above example, the aforementioned identifiers, in addition to being serial,
`may also be sequential, and the sending is via a reliable transmission protocol,
`which in many cases is TCP.
`Page 11 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0011
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 12 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`28. Defendants also make and use systems that incorporate and
`execute instructions that carry out the foregoing streaming media distribution,
`as well as computer-readable media (computer program products) that
`incorporate such
`instructions.
`29. Defendants, by performing the above-described processes, and
`making and using the above-described systems and computer program
`products, have each thereby infringed one or more claims of the ’824 patent
`during its term, in the United States.
`30. The foregoing allegations encompass all servers used for
`distributing YouTube Streaming Services in, or controlled from, the United
`States (regardless of where the users were located).
`31. Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to not less than a
`reasonable royalty for the use made by the Defendants under the ’824 patent,
`in an amount subject to proof at trial, together with interest and costs as fixed
`by the Court.
`32. Plaintiff repeats and realleges the averments of paragraphs 1-31
`above as if fully set forth at length herein.
`Page 12 of 19
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`COUNT II: INFRINGEMENT OF THE ’594 PATENT
`
`Petitioners' Exhibit 1057
`Page 0012
`
`
`
`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 13 of 19
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`33. Defendants have each infringed the ’594 patent under 35 U.S.C. §
`271(a) by making and using computer recorded media for a streaming media
`player in accordance with one or more claims thereof, without authorization
`and in the United States, by conduct as hereinafter more particularly alleged.
`34.
`In particular, the YouTube Streaming Services have taken
`advantage of Plaintiff’s improved technology as claimed in the ’594 patent, from
`and before the date that patent issued through the remainder of its term.
`35. With regard to claim 1, the YouTube Streaming Services utilize
`software provided by Defendants and put into the hands of the user, which
`causes the user’s media consuming device (e.g., computer, smartphone, tablet,
`smart TV, streaming stick, or other streaming devices, referred to as the “media
`player”) to make requests for streaming media data elements that are handled
`by YouTube servers as described above in connection with the ’824 patent. This
`software is embodied in JavaScript files, which Defendants create and maintain
`on computer-readable media on their server systems, and which they use (and
`have used for a long time prior hereto and during the term of the ’594 patent),
`through servers located in and/or controlled from, the United States, by
`accessing such media to send users electronic copies of said software, so that
`said software may then be operated on the user’s media player device to make
`Page 13 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0013
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 14 of 19
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`the above-described requests to the servers deployed by the YouTube
`Streaming Services and work correctly with those servers.
`36. The JavaScript software instructions are executable to cause the
`media player (via its processor) to send requests (HTTP GET requests) via an
`Internet connection for a media data element that is part of a desired
`audio/video stream, identified by a serial identifier. The requested media data
`elements have a playback rate. The instructions also cause the media player to
`receive the requested media data elements over a data connection having a data
`rate more rapid than the playback rate, receiving the requested media data
`elements as fast as the data connection allows. The instructions further cause
`the media player to store the received media data elements in its memory, and
`play the received media data elements back in series from the memory. The
`instructions are further executable to cause the media player, as the received
`media data elements are played, to automatically send additional requests for
`subsequent media data elements for storage in the memory of the media player,
`as required to maintain about a predetermined number of media data elements
`in the memory of the media
`player during playing.
`37. Furthermore, with regard to the dependent claims, the instructions
`cause the media player to maintain in its memory a record identifying the last
`Page 14 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0014
`
`
`
`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 15 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`media data element received and stored by the media player. As reflected in the
`above example, the serial identifiers, in addition to being serial, may also be
`sequential. The media data elements are received via a reliable transmission
`protocol, which in many cases is TCP. In addition, as noted above, the JavaScript
`software is provided as a software application for the media player.
`38. Defendants, by making and using the systems and computer
`program products described above, have each thereby infringed one or more
`claims of the ’594 patent, during its term, in the United States.
`39. The foregoing allegations encompass all servers used for
`distributing YouTube Streaming Services in, or controlled from, the United
`States (regardless of where the users were located).
`40. Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to not less than a
`reasonable royalty for the use made by the Defendants under the ’594 patent,
`in an amount subject to proof at trial, together with interest and costs as fixed
`by the Court.
`41. Plaintiff repeats and realleges the averments of paragraphs 1-40
`above as if fully set forth at length herein.
`42. Defendants have each infringed the ’636 patent under 35 U.S.C.
`§ 271(a) by making and using server systems in accordance with one or more
`Page 15 of 19
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`COUNT III: INFRINGEMENT OF THE ’636 PATENT
`
`Petitioners' Exhibit 1057
`Page 0015
`
`
`
`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 16 of 19
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`claims thereof, without authorization and in the United States, by conduct as
`hereinafter more particularly alleged.
`43.
`In particular, the YouTube Streaming Services have taken
`advantage of Plaintiff’s improved technology as claimed in the ’636 patent, from
`and before the date that patent issued through the remainder of its term.
`44. With regard to claim 1, the YouTube Streaming Services distribute
`(and for a long time prior hereto and during the term of the ’636 patent have
`distributed) live video programs over the Internet, where each live program is
`transmitted to a plurality of user systems. To do this, Defendants receive at
`their server systems a continuous digitally encoded stream for the audio or
`video program, via a data connection from a live source, in real time. Upon
`receipt of the stream, the server supplies media data elements representing the
`program, in which each comprises a digitally encoded portion of the program,
`for example, in video/mp4 or audio/webm encoding, at a playback rate
`corresponding to the encoding. The media data elements are serially identified,
`for example by “sq” identifiers, which indicate a time sequence of the media
`data elements. The media data elements are stored in a data structure under
`the control of the server system. The server system receives “GET” requests
`from user systems via data connections over the Internet, for media data
`elements identified by an sq number. Responsive to those requests, the server
`Page 16 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0016
`
`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 17 of 19
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`system sends to the requesting user systems the media data elements having
`those serial identifiers corresponding to the requests. In observed streaming
`sessions, the data connection of the server to the user system, used for so
`responding, has consistently had a data rate more rapid than the playback rate
`of the media data elements that are being sent via that connection, and each
`sending is at a transmission rate as fast as that data connection will allow. The
`media data elements being sent are selected without depending on the server
`system maintaining a record of the last media data element that had been sent
`to the requesting user system. Such observations also reflect that all of the
`media data elements that are so sent by the server system to the one or more
`user systems are sent in response to the user system requests, and all of the
`media data elements that are sent by the server system to the requesting user
`systems are sent from the data structure under the control of the server system
`as the media data elements were first stored therein.
`45. Furthermore, with regard to the dependent claims, as reflected in
`the above example, the aforementioned serial identifiers, in addition to being
`serial, may also be sequential, and the sending is via a reliable transmission
`protocol, which in many cases is TCP.
`46. Defendants also make and use systems that incorporate and
`execute instructions that carry out the foregoing streaming media distribution,
`Page 17 of 19
`
`Original Complaint for Patent Infringement (Google)
`
`Petitioners' Exhibit 1057
`Page 0017
`
`
`
`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 18 of 19
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`as well as computer-readable media (computer program products) that
`incorporate such instructions.
`47. Defendants, by performing the above-described processes, and
`making and using the above-described systems and computer program
`products, have each thereby infringed one or more claims of the ’636 patent
`during its term, in the United States.
`48. The foregoing allegations encompass all servers used for
`distributing live video in, or controlled from, the United States (regardless of
`where the users were located).
`49. Pursuant to 35 U.S.C. § 284, Plaintiff is entitled to not less than a
`reasonable royalty for the use made by the Defendants under the ’636 patent,
`in an amount subject to proof at trial, together with interest and costs as fixed
`by the Court.
`Plaintiff demands trial by jury on all issues.
`WHEREFORE, Plaintiff WAG ACQUISITION, L.L.C. requests an entry of
`judgment in its favor and against Defendants as follows:
`i. Declaring that each Defendant has infringed one of more claims of United
`States Patent Nos. 9,742,824; 9,729,594; and 9,762,636;
`Page 18 of 19
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`Original Complaint for Patent Infringement (Google)
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`DEMAND FOR JURY TRIAL
`
`PRAYER FOR RELIEF
`
`Petitioners' Exhibit 1057
`Page 0018
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`
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`Case 6:21-cv-00816-ADA Document 1 Filed 08/06/21 Page 19 of 19
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`HALEY & OLSON, P.C.
`
`ii. Awarding to Plaintiff the damages arising out of said infringement of
`United States Patent Nos. 9,742,824; 9,729,594; and 9,762,636;
`iii. Awarding attorneys’ fees, costs, or other damages pursuant to 35 U.S.C.
`§§ 284 or 285 or as otherwise permitted by law, jointly and severally
`against the Defendants;
`iv. Awarding costs in this action to Plaintiff; and
`v. For such other and further relief as the Court may deem just and proper.
` Dated:
`August 6, 2021
`100 North Ritchie Road, Suite 200
`Waco, Texas 76712
`Tel: (254) 776-3336
`Fax: (254) 776-6823
`By: /s/ Brandon R. Oates
`Brandon R. Oates (State Bar No. 24032921)
`Email: boates@haleyolson.com
`
`Attorneys for Plaintiff WAG Acquisition, L.L.C.
`
`LISTON ABRAMSON LLP
`
` OF COUNSEL:
`The Chrysler Building
`405 Lexington Ave, 46th Floor
`New York, New York 10174
`Tel: (212) 257-1630
`Ronald Abramson
`David G. Liston
`Ari J. Jaffess
`Alex G. Patchen
`M. Michael Lewis
`Gina K. Kim
`Email: docket@listonabramson.com
`
`Original Complaint for Patent Infringement (Google)
`
`Page 19 of 19
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`Petitioners' Exhibit 1057
`Page 0019
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`