Case 2:23-cv-00285 Document 1 Filed 06/16/23 Page 1 of 13 PageID #: 1
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`COBBLESTONE WIRELESS, LLC,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Defendants.
`
`Case No.
`
` 2:23-cv-00285
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Cobblestone Wireless, LLC (“Cobblestone”) files this complaint against Samsung
`
`Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively “Defendants” or “Sam-
`
`sung”) alleging infringement of U.S. Patents No. 7,924,802 (the “’802 Patent”), 8,554,196 (the
`
`“’196 Patent”), 8,891,347 (the “’347 Patent”), 9,094,888 (the “’888 Patent”), and 10,368,361 (the
`
`“’347 Patent”) (collectively the “Patents-in-Suit”).
`
`The Parties
`
`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.
`
`On information and belief, Defendant Samsung Electronics Co., Ltd. (“SEC”) is a corpo-
`
`ration organized under the laws of South Korea, with its principal place of business at 129, Sam-
`
`sung-Ro, YeongTong-Gu, Suwon-Si, Gyonggi-Do, 443-742, South Korea.
`
`3.
`
`On information and belief, Defendant Samsung Electronics America, Inc. (“SEA”) is a
`
`United States corporation organized under the laws of the State of New York, with its principal
`
`place of business at 85 Challenger Road, Ridgefield Park, New Jersey 07660 and with an office
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`1
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`Cobblestone Wireless, LLC
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`located at 6625 Excellence Way, Plano, Texas 75023. SEA is a wholly owned subsidiary of SEC.
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`SEA distributes certain Samsung consumer electronics products, including the Accused Products,
`
`in the United States.
`
`Jurisdiction and Venue
`
`4.
`
`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).
`
`5.
`
`This Court has personal jurisdiction over Defendants in this action because Defendants
`
`have established minimum contacts with the United States as a whole, such that the exercise of
`
`jurisdiction would not offend traditional notions of fair play and substantial justice. Defendants
`
`have purposefully directed activities at the United States, in particular, directing Accused Products
`
`for sale to customers and distributors within the United States (including within this District) and
`
`engaging in sales and marketing efforts to generate and support such sales. Defendants have com-
`
`mitted and continue to commit acts of infringement in this District by, among other things, import-
`
`ing, offering to sell, and selling products that infringe the Asserted Patents. Defendants, directly
`
`and through subsidiaries, intermediaries, and third parties, have committed and continue to commit
`
`acts of infringement in this District by, among other things, making, using, offering to sell, selling,
`
`and importing products that infringe the Asserted Patents.
`
`6.
`
`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). Defendant SEC is a
`
`foreign corporation. Venue is proper as to a foreign defendant in any district. 28 U.S.C.
`
`§ 1391(c)(3). Defendant SEA has committed and continues to commit acts of infringement in this
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`District and has regular and established places of business in this District, including as set forth
`
`above.
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`2
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`Count 1 – Claim for infringement of the ’802 Patent
`
`7.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–6 above and
`
`further alleges as follows:
`
`8.
`
`Cobblestone is the owner of U.S. Patent No. 7,924,802 entitled “Wireless Communication
`
`Systems and Methods,” which issued on April 12, 2011. A copy of the ’802 Patent is attached to
`
`this complaint as Exhibit 1.
`
`9.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
`
`products (“Accused Instrumentalities”), including base station and mobile products supporting
`
`LTE and/or 5G carrier aggregation functionalities, that directly infringe, literally and/or under the
`
`doctrine of equivalents, one or more claims of the ’802 Patent.
`
`10.
`
`Defendants also knowingly and intentionally induce infringement of one or more claims of
`
`the ’802 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 ’802 Patent and the infringing nature of the
`
`Accused Instrumentalities. Despite this knowledge of the ’802 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 ’802 Patent. Furthermore, Defendants offer the Accused Instrumentalities in
`
`a form and configuration such that customers and end users will perform the claimed method au-
`
`tomatically by using the Accused Instrumentalities “out of the box” in their ordinary way. Defend-
`
`ants 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 Instru-
`
`3
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`mentalities, despite their knowledge of the ’802 Patent, thereby specifically intending for and in-
`
`ducing their customers to infringe the ’802 Patent through the customers’ normal and customary
`
`use of the Accused Instrumentalities.
`
`11.
`
`Defendants have also infringed, and continue to infringe, one or more claims of the ’802
`
`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 ’802 Patent, are especially made or adapted to infringe the ’802 Patent, and are not
`
`staple articles or commodities of commerce suitable for non-infringing use. Defendants have been,
`
`and currently are, contributorily infringing the ’802 Patent in violation of 35 U.S.C. §§ 271(c) and
`
`(f).
`
`12.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’802 Patent. A claim chart comparing independent claim 1 of the ’802 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 2 and incorporated by reference herein.
`
`13.
`
`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 ’802 Patent pursuant to 35 U.S.C. § 271.
`
`14.
`
`As a result of Defendants’ infringement of the ’802 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 ’196 P atent
`
`15.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–6 above and
`
`further alleges as follows:
`
`4
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`16.
`
`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 3.
`
`17.
`
`On information and belief, Defendants make, use, offer for sale, sell, and/or import certain
`
`products (“Accused Instrumentalities”), including cellular base stations that support providing net-
`
`work coverage using different types of beams and networks, e.g. 4G LTE and 5G NR wireless
`
`networks, that directly infringe, literally and/or under the doctrine of equivalents, one or more
`
`claims of the ’196 Patent.
`
`18.
`
`Defendants also knowingly and intentionally induce infringement of one or more claims 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 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. Furthermore, Defendants offer the Accused Instrumentalities in
`
`a form and configuration such that customers and end users will perform the claimed method au-
`
`tomatically by using the Accused Instrumentalities “out of the box” in their ordinary way. Defend-
`
`ants 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 Instru-
`
`mentalities, despite their knowledge of the ’196 Patent, thereby specifically intending for and in-
`
`ducing their customers to infringe the ’196 Patent through the customers’ normal and customary
`
`use of the Accused Instrumentalities.
`
`5
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`19.
`
`Defendants have also infringed, and continue to infringe, one or more claims of the ’196
`
`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 ’196 Patent, are especially made or adapted to infringe the ’196 Patent, and are not
`
`staple articles or commodities of commerce suitable for non-infringing use. Defendants have been,
`
`and currently are, contributorily infringing the ’196 Patent in violation of 35 U.S.C. §§ 271(c) and
`
`(f).
`
`20.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’196 Patent. A claim chart comparing independent claim 1 of the ’196 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 4 and incorporated by reference herein.
`
`21.
`
`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.
`
`22.
`
`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.
`
`Count 3 – Claim for infringement of the ’347 P atent
`
`23.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–6 above and
`
`further alleges as follows:
`
`24.
`
`Cobblestone is the owner of U.S. Patent No. 8,891,347 entitled “User-focusing technique
`
`for wireless communication systems,” which issued November 18, 214. A copy of the ’347 Patent
`
`is attached to this complaint as Exhibit 5.
`
`6
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`25.
`
`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 user equipment (UE) that supports 3GPP 5G NR beamforming,
`
`that directly infringe, literally and/or under the doctrine of equivalents, one or more claims of
`
`the ’347 Patent.
`
`26.
`
`Defendants also knowingly and intentionally induce infringement of one or more claims 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. Furthermore, Defendants offer the Accused Instrumentalities in
`
`a form and configuration such that customers and end users will perform the claimed method au-
`
`tomatically by using the Accused Instrumentalities “out of the box” in their ordinary way. Defend-
`
`ants 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 Instru-
`
`mentalities, despite their knowledge of the ’347 Patent, thereby specifically intending for and in-
`
`ducing their customers to infringe the ’347 Patent through the customers’ normal and customary
`
`use of the Accused Instrumentalities.
`
`27.
`
`Defendants have also infringed, and continue to infringe, one or more claims of the ’347
`
`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 ’347 Patent, are especially made or adapted to infringe the ’347 Patent, and are not
`
`7
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`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).
`
`28.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’347 Patent. A claim chart comparing independent claims 8, 15, and 19 of the ’347 Patent to
`
`representative Accused Instrumentalities is attached as Exhibit 6 and incorporated by reference
`
`herein.
`
`29.
`
`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.
`
`30.
`
`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 4 – Claim for infringement of the ’888 Patent
`
`31.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–6 above and
`
`further alleges as follows:
`
`32.
`
`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 7.
`
`8
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`33.
`
`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, one or more claims of the ’888 Patent.
`
`34.
`
`Defendants also knowingly and intentionally induce infringement of one or more claims 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. Furthermore, Defendants offer the Accused Instrumentalities in
`
`a form and configuration such that customers and end users will perform the claimed method au-
`
`tomatically by using the Accused Instrumentalities “out of the box” in their ordinary way. Defend-
`
`ants 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 Instru-
`
`mentalities, despite their knowledge of the ’888 Patent, thereby specifically intending for and in-
`
`ducing their customers to infringe the ’888 Patent through the customers’ normal and customary
`
`use of the Accused Instrumentalities.
`
`35.
`
`Defendants have also infringed, and continue to infringe, one or more claims of the ’888
`
`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 ’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,
`
`9
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`and currently are, contributorily infringing the ’888 Patent in violation of 35 U.S.C. §§ 271(c) and
`
`(f).
`
`36.
`
`The Accused Instrumentalities satisfy all claim limitations of one or more claims of
`
`the ’888 Patent. A claim chart comparing independent claim 20 of the ’888 Patent to representative
`
`Accused Instrumentalities is attached as Exhibit 8 and incorporated by reference herein.
`
`37.
`
`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.
`
`38.
`
`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 2 – Claim for infringement of the ’361 Patent
`
`39.
`
`Cobblestone incorporates by reference each of the allegations in paragraphs 1–6 above and
`
`further alleges as follows:
`
`40.
`
`Cobblestone is 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 9.
`
`41.
`
`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) and/or Bandwidth Adaptation function-
`
`ality, that directly infringe, literally and/or under the doctrine of equivalents, one or more claims
`
`of the ’361 Patent.
`
`10
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`42.
`
`Defendants also knowingly and intentionally induce infringement of one or more claims 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 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. Furthermore, Defendants offer the Accused Instrumentalities in
`
`a form and configuration such that customers and end users will perform the claimed method au-
`
`tomatically by using the Accused Instrumentalities “out of the box” in their ordinary way. Defend-
`
`ants 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 Instru-
`
`mentalities, despite their knowledge of the ’361 Patent, thereby specifically intending for and in-
`
`ducing their customers to infringe the ’361 Patent through the customers’ normal and customary
`
`use of the Accused Instrumentalities.
`
`43.
`
`Defendants have also infringed, and continue to infringe, one or more claims 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).
`
`11
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`44.
`
`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 10 and incorporated by reference herein.
`
`45.
`
`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.
`
`46.
`
`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.
`
`Jury Trial Demanded
`
`47.
`
`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 the ’802 Patent, the
`
`’196 Patent, the ’347 Patent, the ’888 Patent, and the ’361 Patent, and that the ’802 Patent, the
`
`’196 Patent, the ’347 Patent, the ’888 Patent, and the ’361 Patent are valid, enforceable, and patent-
`
`eligible;
`
`B.
`
`A judgment and order requiring Defendants to pay Cobblestone compensatory damages,
`
`costs, expenses, and pre- and post-judgment interest for its infringement of the asserted patents, as
`
`provided under 35 U.S.C. § 284;
`
`12
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`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 ’802
`
`Patent, the ’196 Patent, the ’347 Patent, the ’888 Patent, and the ’361 Patent;
`
`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 finding that this case is exceptional under 35 U.S.C. § 285, and an award of Cobble-
`
`stone’s reasonable attorney’s fees and costs; and
`
`F.
`
`Any and all other relief to which Cobblestone may be entitled.
`
`Dated: June 16, 2023
`
` /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
`Email: cconkle@raklaw.com
`Email: jma@raklaw.com
`
`ATTORNEYS FOR PLAINTIFF,
`COBBLESTONE WIRELESS, LLC
`
`13
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