Case 2:22-cv-00474 Document 1 Filed 12/15/22 Page 1 of 14 PageID #: 1
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEX AS
`MARSHALL DIVISION
`
`COBBLESTONE WIRELESS, LLC,
`
`Plaintiff,
`
`v.
`
`AT&T INC.; AT&T SERVICES INC.; AT&T
`MOBILITY LLC; AND AT&T CORP.;
`
`Defendants.
`
`Case No. 2:22-cv-00474
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Cobblestone Wireless, LLC (“Cobblestone”) files this complaint against
`
`Defendants AT&T Inc., AT&T Services Inc., AT&T Mobility LLC, and AT&T Corp.
`
`(collectively, “Defendants” or “AT&T”) alleging infringement of U.S. Patent Nos. 8,891,347 (the
`
`“’347 patent”), 9,094,888 (the “’888 patent”), 10,368,361 (the “’361 patent”), and 8,554,196 (the
`
`“’196 patent”) (collectively, the “Patents-in-Suit” or “Asserted Patents”).
`
`Plaintiff Cobbleston e and th e Pa tents-in-S uit
`
`1.
`
`Plaintiff Cobblestone Wireless, LLC is a limited liability company organized under the
`
`laws of the State of Texas, with an address at 101 E. Park Blvd., Suite 600, Plano, Texas 75074.
`
`2.
`
`Cobblestone is the owner of U.S. Patent No. 8,891,347 entitled “User-Focusing Technique
`
`for Wireless Communication Systems,” which issued November 18, 2014. A copy of the ’347
`
`patent is attached to this complaint as Exhibit 1.
`
`3.
`
`Cobblestone is the owner of U.S. Patent No. 9,094,888 entitled “Wireless Device Handoff
`
`Between Wireless Networks,” which issued July 28, 2015. A copy of the ’888 patent is attached
`
`to this complaint as Exhibit 2.
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`1
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`4.
`
`Cobblestone
`
`is
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`the owner of U.S. Patent No. 10,368,361 entitled “Adaptive
`
`Communication Resource Allocation in a Wireless Network,” which issued July 30, 2019. A copy
`
`of the ’361 patent is attached to this complaint as Exhibit 3.
`
`5.
`
`Cobblestone is the owner of U.S. Patent No. 8,554,196 entitled “Network Coverage By
`
`Cycling Through Beam Shape Coverage Configurations,” which issued October 8, 2013. A copy
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`of the ’196 patent is attached to this complaint as Exhibit 4.
`
`6.
`
`On information and belief, Defendant AT&T Inc. is a corporation organized under the laws
`
`of the State of Delaware, with its principal place of business at 208 S. Akard Street, Dallas, Texas,
`
`75202. AT&T Inc. has as its registered agent for service: CT Corporation System, located at 1999
`
`Bryan Street, Suite 900, Dallas, Texas 75201.
`
`7.
`
`On information and belief, Defendant AT&T Services, Inc. is a corporation organized and
`
`existing under the laws of the State of Delaware, with a principal place of business at 208 South
`
`Akard Street, Dallas, Texas 75202. AT&T Services, Inc. has as its registered agent for service: CT
`
`Corporation System, located at 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
`
`8.
`
`On information and belief, Defendant AT&T Mobility LLC is a limited liability company
`
`organized and existing under the laws of Delaware, with its principal place of business at 1025
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`Lenox Park Boulevard NE, Atlanta, Georgia 30319. AT&T Mobility LLC has as its registered
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`agent for service: The Corporation Trust Company, located at Corporation Trust Center, 1209
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`Orange Street, Wilmington, Delaware 19801.
`
`9.
`
`On information and belief, Defendant AT&T Corp. is a corporation organized and existing
`
`under the laws of the State of New York, with a principal place of business at One AT&T Way,
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`Bedminster, New Jersey 07921-0752. AT&T Corp. has as its registered agent for service: C T
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`Corporation System, located at 28 Liberty Street, New York, New York, 10005.
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`2
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`Jurisdiction and V enue
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`10.
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`This action arises under the patent laws of the United States, Title 35 of the United States
`
`Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
`
`1338(a).
`
`11.
`
`This Court has personal jurisdiction over AT&T in this action because AT&T has
`
`committed acts of infringement within this District giving rise to this action, has a regular and
`
`established place of business in this District, and has established minimum contacts with this forum
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`such that the exercise of jurisdiction over AT&T would not offend traditional notions of fair play
`
`and substantial justice. AT&T, directly and/or through subsidiaries or intermediaries, conducts its
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`business extensively throughout Texas, by shipping, distributing, offering for sale, selling, and
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`advertising its products and/or services in the State of Texas and the Eastern District of Texas,
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`regularly does business or solicits business, engages in other persistent courses of conduct, and/or
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`derives substantial revenue from products and/or services provided to individuals in the State of
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`Texas, and commits acts of infringement of Plaintiff’s patents in this District by, among other
`
`things, making, using, importing, offering to sell, and selling products and/or services that infringe
`
`the asserted patents, including without limitation the tablets and phones accused of infringement
`
`in this case and cellular services offered by AT&T on its network.
`
`12.
`
`AT&T, directly and/or through subsidiaries or intermediaries, has purposefully and
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`voluntarily placed one or more products and/or services in the stream of commerce that practice
`
`the Asserted Patents with the intention and expectation that they will be purchased and used by
`
`consumers in the Eastern District of Texas. These products and/or services have been and continue
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`to be purchased and used in the Eastern District of Texas.
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`3
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`13.
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`Venue as to AT&T is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). On
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`information and belief, AT&T resides in this District and/or has committed acts of infringement
`
`and has a regular and established place of business in this District.
`
`14.
`
`For example, AT&T advertises its wireless networks as available in Texas, including
`
`within the Eastern District of Texas. See e.g., https://www.att.com/maps/wireless-coverage.html:
`
`15.
`
`AT&T had more than 196 million subscribers as of March 31, 2022.1
`
`16.
`
`For further example, AT&T sells mobile devices accused of infringement in Texas,
`
`including within the Eastern District of Texas.2
`
`
`
`
`1 https://investors.att.com/~/media/Files/A/ATT-IR-V2/financial-reports/quarterly-
`earnings/2022/1Q22/ATT_1Q22_8K.pdf.
`2 See, e.g., https://www.att.com/maps/wireless-coverage.html
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`4
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`
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`17.
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`On information and belief, AT&T owns and operates a foundry at 2900 West Plano
`
`Parkway, Plano, Texas 75075.3
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`Count 1 – Claim for infringement of the ’347 patent.
`
`18.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–17 above
`
`and further alleges as follows:
`
`19.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No. 8,891,347 (the
`
`“’347 Patent”), entitled “User-Focusing Technique for Wireless Communication Systems.”
`
`The ’347 Patent was duly and legally issued by the United States Patent and Trademark Office on
`
`November 18, 2014. A true and correct copy of the ’347 Patent is attached as Exhibit 1.
`
`
`3 See e.g., https://about.att.com/story/2018/plano_foundry.html.
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`5
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`20.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
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`products (“Accused Instrumentalities”), including (1) cellular base stations that support 3GPP 5G
`
`NR beamforming, and (2) cellular handsets that support 3GPP 5G NR beamforming, including
`
`without limitation the Apple iPhone 12, iPhone 12 mini, iPhone 12 Pro, iPhone 12 Pro Max, iPhone
`
`13, iPhone 13 mini, iPhone 13 Pro, iPhone 13 Pro Max, iPhone 14, iPhone 14 Plus, iPhone 14 Pro,
`
`and iPhone 14 Pro Max and Samsung Galaxy S20 FE, Galaxy S21, Galaxy S21 FE, Galaxy S21
`
`Ultra, Galaxy S22, Galaxy S22+, Galaxy S22 Ultra, Galaxy Z Flip3, Galaxy Z Flip4, Galaxy Z
`
`Fold3, Galaxy Z Fold4, Galaxy A52, Galaxy A53, that directly infringe, literally and/or under the
`
`doctrine of equivalents, at least Claim 1 of the ’347 Patent.
`
`21.
`
`Defendants also knowingly and intentionally induce infringement of at least Claim 1 of
`
`the ’347 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendants have had knowledge of the ’347 Patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’347 Patent, Defendants continue to
`
`actively encourage and instruct their customers and end users (for example, through user manuals
`
`and online instruction materials on their website) to use the Accused Instrumentalities in ways that
`
`directly infringe the ’347 Patent. Defendants do so knowing and intending that their customers and
`
`end users will commit these infringing acts. Defendants also continue to make, use, offer for sale,
`
`sell, and/or import the Accused Instrumentalities, despite their knowledge of the ’347 Patent,
`
`thereby specifically intending for and inducing their customers to infringe the ’347 Patent through
`
`the customers’ normal and customary use of the Accused Instrumentalities.
`
`22.
`
`Defendants have also infringed, and continue to infringe, at least Claim 1 of the ’347 Patent
`
`by selling, offering for sale, or importing into the United States, the Accused Instrumentalities,
`
`knowing that the Accused Instrumentalities constitute a material part of the inventions claimed in
`
`6
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`the ’347 Patent, are especially made or adapted to infringe the ’347 Patent, and are not staple
`
`articles or commodities of commerce suitable for non-infringing use. Defendants have been, and
`
`currently are, contributorily infringing the ’347 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`23.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’347 Patent. A claim chart comparing independent claim 1 of the ’347 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 5.
`
`24.
`
`By making, using, offering for sale, selling and/or importing into the United States the
`
`Accused Instrumentalities, Defendants have injured Plaintiff and are liable for infringement of
`
`the ’347 Patent pursuant to 35 U.S.C. § 271.
`
`25.
`
`As a result of Defendants’ infringement of the ’347 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Defendants’ infringement, but in no event less
`
`than a reasonable royalty for the use made of the invention by Defendants, together with interest
`
`and costs as fixed by the Court.
`
`Count 2 – Claim for infringement of the ’888 patent.
`
`26.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–25 above
`
`and further alleges as follows:
`
`27.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No. 9,094,888 (the
`
`“’888 Patent”), entitled “Wireless Device Handoff Between Wireless Networks.” The ’888 Patent
`
`was duly and legally issued by the United States Patent and Trademark Office on July 28, 2015.
`
`A true and correct copy of the ’888 Patent is attached as Exhibit 2.
`
`28.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
`
`products (“Accused Instrumentalities”), including cellular base stations that support handover
`
`7
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`between 4G LTE and 5G NR wireless networks, that directly infringe, literally and/or under the
`
`doctrine of equivalents, at least Claim 9 of the ’888 Patent.
`
`29.
`
`Defendants also knowingly and intentionally induce infringement of at least Claim 9 of
`
`the ’888 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendants have had knowledge of the ’888 Patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’888 Patent, Defendants continue to
`
`actively encourage and instruct their customers and end users (for example, through user manuals
`
`and online instruction materials on their website) to use the Accused Instrumentalities in ways that
`
`directly infringe the ’888 Patent. Defendants do so knowing and intending that their customers and
`
`end users will commit these infringing acts. Defendants also continue to make, use, offer for sale,
`
`sell, and/or import the Accused Instrumentalities, despite their knowledge of the ’888 Patent,
`
`thereby specifically intending for and inducing their customers to infringe the ’888 Patent through
`
`the customers’ normal and customary use of the Accused Instrumentalities.
`
`30.
`
`Defendants have also infringed, and continue to infringe, at least Claim 9 of the ’888 Patent
`
`by selling, offering for sale, or importing into the United States, the Accused Instrumentalities,
`
`knowing that the Accused Instrumentalities constitute a material part of the inventions claimed in
`
`the ’888 Patent, are especially made or adapted to infringe the ’888 Patent, and are not staple
`
`articles or commodities of commerce suitable for non-infringing use. Defendants have been, and
`
`currently are, contributorily infringing the ’888 Patent in violation of 35 U.S.C. §§ 271(c) and (f).
`
`31.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’888 Patent. A claim chart comparing independent claim 9 of the ’888 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 6.
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`8
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`32.
`
`By making, using, offering for sale, selling and/or importing into the United States the
`
`Accused Instrumentalities, Defendants have injured Plaintiff and are liable for infringement of
`
`the ’888 Patent pursuant to 35 U.S.C. § 271.
`
`33.
`
`As a result of Defendants’ infringement of the ’888 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Defendants’ infringement, but in no event less
`
`than a reasonable royalty for the use made of the invention by Defendants, together with interest
`
`and costs as fixed by the Court.
`
`Count 3 – Claim for infringement of the ’361 patent.
`
`34.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–33 above
`
`and further alleges as follows:
`
`35.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No. 10,368,361
`
`(the “’361 Patent”), entitled “Adaptive Communication Resource Allocation in a Wireless
`
`Network.” The ’361 Patent was duly and legally issued by the United States Patent and Trademark
`
`Office on July 30, 2019. A true and correct copy of the ’361 Patent is attached as Exhibit 3.
`
`36.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
`
`products (“Accused Instrumentalities”), including cellular base stations that support 3GPP NG-
`
`RAN supporting directional Supplementary Uplink (SUL) functionality, that directly infringe,
`
`literally and/or under the doctrine of equivalents, at least Claim 10 of the ’361 Patent.
`
`37.
`
`Defendants also knowingly and intentionally induce infringement of at least Claim 10 of
`
`the ’361 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendants have had knowledge of the ’361 Patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’361 Patent, Defendants continue to
`
`actively encourage and instruct their customers and end users (for example, through user manuals
`
`9
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`and online instruction materials on their website) to use the Accused Instrumentalities in ways that
`
`directly infringe the ’361 Patent. Defendants do so knowing and intending that their customers and
`
`end users will commit these infringing acts. Defendants also continue to make, use, offer for sale,
`
`sell, and/or import the Accused Instrumentalities, despite their knowledge of the ’361 Patent,
`
`thereby specifically intending for and inducing their customers to infringe the ’361 Patent through
`
`the customers’ normal and customary use of the Accused Instrumentalities.
`
`38.
`
`Defendants have also infringed, and continue to infringe, at least Claim 10 of the ’361
`
`Patent by selling, offering for sale, or importing into the United States, the Accused
`
`Instrumentalities, knowing that the Accused Instrumentalities constitute a material part of the
`
`inventions claimed in the ’361 Patent, are especially made or adapted to infringe the ’361 Patent,
`
`and are not staple articles or commodities of commerce suitable for non-infringing use. Defendants
`
`have been, and currently are, contributorily infringing the ’361 Patent in violation of 35 U.S.C.
`
`§§ 271(c) and (f).
`
`39.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’361 Patent. A claim chart comparing independent claim 10 of the ’361 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 7.
`
`40.
`
`By making, using, offering for sale, selling and/or importing into the United States the
`
`Accused Instrumentalities, Defendants have injured Plaintiff and are liable for infringement of
`
`the ’361 Patent pursuant to 35 U.S.C. § 271.
`
`41.
`
`As a result of Defendants’ infringement of the ’361 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Defendants’ infringement, but in no event less
`
`than a reasonable royalty for the use made of the invention by Defendants, together with interest
`
`and costs as fixed by the Court.
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`10
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`Count 4 – Claim for infringement of the ’196 patent.
`
`42.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–41 above
`
`and further alleges as follows:
`
`43.
`
`Plaintiff owns by assignment all rights, title, and interest in U.S. Patent No. 8,554,196 (the
`
`“’196 Patent”), entitled “Network Coverage By Cycling Through Beam Shape Coverage
`
`Configurations.” The ’196 Patent was duly and legally issued by the United States Patent and
`
`Trademark Office on October 8, 2013. A true and correct copy of the ’196 Patent is attached as
`
`Exhibit 4.
`
`44.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
`
`products (“Accused Instrumentalities”), including cellular handsets that support wifi-only
`
`automatic updates, including without limitation the Apple iPhone 12, iPhone 12 mini, iPhone 12
`
`Pro, iPhone 12 Pro Max, iPhone 13, iPhone 13 mini, iPhone 13 Pro, iPhone 13 Pro Max, iPhone
`
`14, iPhone 14 Plus, iPhone 14 Pro, and iPhone 14 Pro Max and Samsung Galaxy S20 FE, Galaxy
`
`S21, Galaxy S21 FE, Galaxy S21 Ultra, Galaxy S22, Galaxy S22+, Galaxy S22 Ultra, Galaxy Z
`
`Flip3, Galaxy Z Flip4, Galaxy Z Fold3, Galaxy Z Fold4, Galaxy A52, Galaxy A53, that directly
`
`infringe, literally and/or under the doctrine of equivalents, at least Claim 23 of the ’196 Patent.
`
`45.
`
`Defendants also knowingly and intentionally induce infringement of at least Claim 23 of
`
`the ’196 Patent in violation of 35 U.S.C. § 271(b). Through at least the filing and service of this
`
`Complaint, Defendants have had knowledge of the ’196 Patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’196 Patent, Defendants continue to
`
`actively encourage and instruct their customers and end users (for example, through user manuals
`
`and online instruction materials on their website) to use the Accused Instrumentalities in ways that
`
`directly infringe the ’196 Patent. Defendants do so knowing and intending that their customers and
`
`11
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`end users will commit these infringing acts. Defendants also continue to make, use, offer for sale,
`
`sell, and/or import the Accused Instrumentalities, despite their knowledge of the ’196 Patent,
`
`thereby specifically intending for and inducing their customers to infringe the ’196 Patent through
`
`the customers’ normal and customary use of the Accused Instrumentalities.
`
`46.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’196 Patent. A claim chart comparing independent claim 23 of the ’196 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 8.
`
`47.
`
`By making, using, offering for sale, selling and/or importing into the United States the
`
`Accused Instrumentalities, Defendants have injured Plaintiff and are liable for infringement of
`
`the ’196 Patent pursuant to 35 U.S.C. § 271.
`
`48.
`
`As a result of Defendants’ infringement of the ’196 Patent, Plaintiff is entitled to monetary
`
`damages in an amount adequate to compensate for Defendants’ infringement, but in no event less
`
`than a reasonable royalty for the use made of the invention by Defendants, together with interest
`
`and costs as fixed by the Court.
`
`Jury Trial D emanded
`
`49.
`
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Cobblestone requests a trial
`
`by jury of any issues so triable by right.
`
`Prayer for Relief
`
`
`
`Plaintiff Cobblestone respectfully requests the following relief from this Court:
`
`A.
`
`A judgment in favor of Cobblestone that Defendants have infringed, either literally and/or
`
`under the doctrine of equivalents, the ’347, ’888, ‘361, and ‘196 patents, and that the ’347, ’888,
`
`‘361, and ’196 patents are valid, enforceable, and patent-eligible;
`
`12
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`B.
`
`A judgment and order requiring Defendants to pay Cobblestone compensatory damages,
`
`costs, expenses, and pre-judgment and post-judgment interest for their infringement of the asserted
`
`patents, as provided under 35 U.S.C. § 284;
`
`C.
`
`Any and all injunctive and/or equitable relief to which Cobblestone may be entitled
`
`including, but not limited to, ongoing royalties with respect to Defendants’ infringement of the
`
`’347, ’888, ’361, and ‘196 patents;
`
`D.
`
`A judgment and order requiring Defendants to provide an accounting and to pay
`
`supplemental damages to Cobblestone, including, without limitation, pre-judgment and post-
`
`judgment interest;
`
`E.
`
`A judgment and order finding that this case is exceptional under 35 U.S.C. § 285, and an
`
`award of Cobblestone’s reasonable attorney’s fees and costs; and
`
`F.
`
`Any and all other relief to which Cobblestone may be entitled.
`
`
`
`Dated: December 15, 2022
`
`
`
`Respectfully submitted,
`
`/s/ Reza Mirzaie
`Reza Mirzaie
`CA State Bar No. 246953
`Marc A. Fenster
`CA State Bar No. 181067
`Neil A. Rubin
`CA State Bar No. 250761
`Christian W. Conkle
`CA State Bar No. 306374
`Jonathan Ma
`CA State Bar No. 312773
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Telephone: 310-826-7474
`Email: rmirzaie@raklaw.com
`Email: mfenster@raklaw.com
`Email: nrubin@raklaw.com
`
`13
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`Email: cconkle@raklaw.com
`Email: jma@raklaw.com
`
`ATTORNEYS FOR PLAINTIFF,
`COBBLESTONE WIRELESS, LLC
`
`
`
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`14
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