Case 2:22-cv-00478 Document 1 Filed 12/16/22 Page 1 of 13 PageID #: 1
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`COBBLESTONE WIRELESS, LLC,
`
`Plaintiff,
`
`Case No.
`
`2:22-cv-478
`
`v.
`
`VERIZON COMMUNICATIONS, INC., CELLCO
`PARTNERSHIP D/B/A VERIZON WIRELESS.
`
`Defendants.
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Cobblestone Wireless, LLC (“Cobblestone”) files this complaint against Defend-
`
`ants Verizon Communications, Inc., Cellco Partnership d/b/a Verizon Wireless (collectively, “De-
`
`fendants” or “Verizon”) 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 Cobblestone and the Patents -in- Suit
`
`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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`Cobblestone Wireless, LLC
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`4.
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`Cobblestone is the owner of U.S. Patent No. 10,368,361 entitled “Adaptive Communica-
`
`tion 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
`
`of the ’196 patent is attached to this complaint as Exhibit 4.
`
`6.
`
`On information and belief, Defendant Verizon Communications, Inc. (“VCI”) is a corpo-
`
`ration organized under the laws of the State of Delaware, with its principal place of business at
`
`1095 Avenue of the Americas, New York, New York 10036. VCI has as its registered agent for
`
`service: The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wil-
`
`mington, Delaware 19801.
`
`7.
`
`On information and belief, Cellco Partnership d/b/a Verizon Wireless (“Verizon Wireless”)
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`is a partnership organized and existing under the laws of the State of Delaware, with a principal
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`place of business at One Verizon Way, Basking Ridge, New Jersey 07920. Verizon Wireless has
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`as its registered agent for service: The Corporation Trust Company, Corporation Trust Center,
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`1209 Orange Street, Wilmington, Delaware 19801.
`
`8.
`
`Upon information and belief, Defendant VCI is the ultimate parent corporation, either di-
`
`rectly or indirectly, of each of Defendant Verizon Wireless. Defendants collectively provide com-
`
`munications, technology, and information products and services to consumers, businesses, and
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`government entities throughout the State of Texas, including the Eastern District of Texas.
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`2
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`Jurisdiction and Venue
`
`9.
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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).
`
`10.
`
`This Court has personal jurisdiction over Verizon in this action because Verizon has com-
`
`mitted acts of infringement within this District giving rise to this action, has a regular and estab-
`
`lished 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 Verizon would not offend traditional notions of fair play
`
`and substantial justice. Verizon, directly and/or through subsidiaries or intermediaries, conducts
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`its 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 Verizon on its network.
`
`11.
`
`Verizon, directly and/or through subsidiaries or intermediaries, has purposefully and vol-
`
`untarily placed one or more products and/or services in the stream of commerce that practice the
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`Asserted Patents with the intention and expectation that they will be purchased and used by con-
`
`sumers in the Eastern District of Texas. These products and/or services have been and continue to
`
`be purchased and used in the Eastern District of Texas.
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`3
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`12.
`
`Venue as to Verizon is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). On
`
`information and belief, Verizon resides in this District and/or has committed acts of infringement
`
`and has a regular and established place of business in this District.
`
`13.
`
`For example, Defendants have regular and established places of business in the Eastern
`
`District of Texas, including at 1111 E Grand Ave., Marshall, TX 75670; 500 E Loop 281,
`
`Longview, TX 75605; 2400 S Jefferson Ave., Mount Pleasant, TX 75455; 1006 East End Boule-
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`vard N., Suite A, Marshall, Texas 75670; 741 N Central Expressway, Plano, Texas 75075; 2330
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`Preston Road, Suite 500, Frisco, Texas 75034; 3220 East Hebron Parkway, Suite 114, Carrollton,
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`Texas 75010; 5020 State Highway 121, The Colony, Texas 75056; and 204 Central Expressway
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`S, Suite 40, Allen, Texas 75013.
`
`14.
`
`For example, Verizon maintains or has authorized retail locations in this District, including
`
`at the addresses listed above in Paragraph 13, where cellular handsets, and other infringing devices
`
`have been sold.
`
`15.
`
`For example, Verizon also owns, leases, maintains and/or operates cellular base stations in
`
`this District that provide 5G data services to Verizon customers in this District, including numer-
`
`ous cell tower locations in Tyler, Texas and Longview, Texas.
`
`16.
`
`For example, Verizon offers 5G data coverage to customers in this District. Furthermore,
`
`according to its website, Verizon also offers and /or provides 4G and 5G services and equipment
`
`to customers in this District.
`
`Count 1 – Claim for infringement of the ’347 patent.
`
`17.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–16 above
`
`and further alleges as follows:
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`4
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`18.
`
`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.
`
`19.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
`
`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 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 FE, Galaxy S22, Galaxy S22+, Galaxy S22 Ultra, Galaxy
`
`Z Flip3, Galaxy Z Flip4, Galaxy Z Fold3, Galaxy Z Fold4, and Galaxy A53, that directly infringe,
`
`literally and/or under the doctrine of equivalents, at least Claim 1 of the ’347 Patent.
`
`20.
`
`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 ac-
`
`tively 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.
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`5
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`21.
`
`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
`
`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).
`
`22.
`
`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.
`
`23.
`
`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.
`
`24.
`
`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.
`
`25.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–24 above
`
`and further alleges as follows:
`
`26.
`
`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.
`
`6
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`27.
`
`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 be-
`
`tween 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.
`
`28.
`
`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 ac-
`
`tively 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.
`
`29.
`
`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).
`
`7
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`30.
`
`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.
`
`31.
`
`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.
`
`32.
`
`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.
`
`33.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–32 above
`
`and further alleges as follows:
`
`34.
`
`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 Net-
`
`work.” 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.
`
`35.
`
`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, lit-
`
`erally and/or under the doctrine of equivalents, at least Claim 10 of the ’361 Patent.
`
`36.
`
`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
`
`8
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`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 ac-
`
`tively 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 ’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.
`
`37.
`
`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 Instrumental-
`
`ities, 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).
`
`38.
`
`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.
`
`39.
`
`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.
`
`9
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`40.
`
`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.
`
`Count 4 – Claim for infringement of the ’196 patent.
`
`41.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–40 above
`
`and further alleges as follows:
`
`42.
`
`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 Config-
`
`urations.” 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.
`
`43.
`
`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 auto-
`
`matic updates, including without limitation the Apple iPhone 12, iPhone 12 mini, iPhone 13, iPh-
`
`one 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 FE, Galaxy S22, Galaxy S22+,
`
`Galaxy S22 Ultra, Galaxy Z Flip3, Galaxy Z Flip4, Galaxy Z Fold3, Galaxy Z Fold4, and Galaxy
`
`A53, that directly infringe, literally and/or under the doctrine of equivalents, at least Claim 23 of
`
`the ’196 Patent.
`
`44.
`
`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
`
`10
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`Accused Instrumentalities. Despite this knowledge of the ’196 Patent, Defendants continue to ac-
`
`tively 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
`
`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.
`
`45.
`
`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.
`
`46.
`
`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.
`
`47.
`
`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 Demanded
`
`48.
`
`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:
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`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;
`
`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 includ-
`
`ing, 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 supple-
`
`mental 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
`
`Any and all other relief to which Cobblestone may be entitled.
`
`F.
`
`
`
`Dated: December 16, 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
`
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`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
`Email: cconkle@raklaw.com
`Email: jma@raklaw.com
`
`ATTORNEYS FOR PLAINTIFF,
`COBBLESTONE WIRELESS, LLC
`
`
`
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