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Innovative Wireless Solutions v. Ubiquiti Networks

Innovative Wireless Solutions v. Ubiquiti Networks

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01867-UNA: Innovative Wireless Solutions LLC v. Ubiquiti Networks Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l9t8 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-01867-UNA: Innovative Wireless Solutions LLC v. Ubiquiti Networks Inc. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-l9t8 for more info.

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Published by: PriorSmart on Nov 07, 2013
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11/07/2013

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE INNOVATIVE WIRELESS SOLUTIONS, § LLC, § Plaintiff, § Civil Case No. ______________ § v. §
JURY TRIAL DEMANDED
 §
 
UBIQUITI NETWORKS, INC., § § Defendant. §
COMPLAINT FOR PATENT INFRINGEMENT
 Plaintiff Innovative Wireless Solutions, LLC (“IWS” or “Plaintiff”), by way of its Complaint for Patent Infringement (“Complaint”) against Defendant Ubiquiti Networks, Inc. (“Ubiquiti Networks” or “Defendant”) alleges as follows:
NATURE OF THE ACTION
1.
 
This is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. § 1
et seq
.
PARTIES
2.
 
Plaintiff Innovative Wireless Solutions, LLC (“IWS”) is a Texas limited liability company with a place of business at 555 Republic Drive, Suite 200, Plano, Texas 75074. 3.
 
On information and belief, Defendant Ubiquiti Networks is a corporation under the laws of the State of Delaware. On information and belief Defendant has a principal place of  business at 2580 Orchard Parkway, San Jose, California 95131.
JURISDICTION AND VENUE
 4.
 
This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
 
5.
 
On information and belief, Defendant is subject to the jurisdiction of this Court by virtue of the fact that it is organized under the laws of the State of Delaware. On information and  belief, Defendant is also subject to the jurisdiction of this Court by reason of its acts of patent infringement which have been committed in this Judicial District, and by virtue of its regularly conducted and systematic business contacts in this State. As such, Defendant has purposefully availed itself of the privilege of conducting business within this Judicial District; has established sufficient minimum contacts with this Judicial District such that it should reasonably and fairly anticipate being haled into court in this Judicial District; has purposefully directed activities at residents of this State; and at least a portion of the patent infringement claims alleged herein arise out of or are related to one or more of the foregoing activities. 6.
 
Venue is proper in this Judicial District under 28 U.S.C. §§ 1391(c) and 1400(b).
THE PATENTS-IN-SUIT
 7.
 
The allegations set forth in the foregoing paragraphs 1 through 6 are hereby realleged and incorporated herein by reference. 8.
 
On June 15, 1999, U.S. Patent Number 5,912,895 (the “’895 Patent”), entitled “INFORMATION NETWORK ACCESS APPARATUS AND METHODS FOR COMMUNICATING INFORMATION PACKETS VIA TELEPHONE LINES,” was duly and legally issued by the United States Patent and Trademark Office. A true and correct copy of the ’895 Patent is attached as Exhibit A to this Complaint. 9.
 
On December 4, 2001, U.S. Patent Number 6,327,264 (the “’264 Patent”), entitled “INFORMATION NETWORK ACCESS APPARATUS AND METHODS FOR COMMUNICATING INFORMATION PACKETS VIA TELEPHONE LINES,” was duly and 2
 
legally issued by the United States Patent and Trademark Office. A true and correct copy of the ’264 Patent is attached as Exhibit B to this Complaint. 10.
 
On July 1, 2003, U.S. Patent Number 6,587,473 (the “’473 Patent”), entitled “INFORMATION NETWORK ACCESS APPARATUS AND METHODS FOR COMMUNICATING INFORMATION PACKETS VIA TELEPHONE LINES,” was duly and legally issued by the United States Patent and Trademark Office. A true and correct copy of the ’473 Patent is attached as Exhibit C to this Complaint. 11.
 
IWS is the assignee and owner of the right, title and interest in and to the ’895, ’264 and ’473 Patents (henceforth collectively the “patents-in-suit”), including the right to assert all causes of action arising under said patents and the right to any remedies for infringement.
COUNT I – INFRINGEMENT OF U.S. PATENT NO. ’895
12.
 
The allegations set forth in the foregoing paragraphs 1 through 11 are hereby realleged and incorporated herein by reference. 13.
 
IWS provided actual notice to Defendant of its infringement of the ’895 Patent in a letter dated October 18, 2013 from IWS to Defendant. In this letter, IWS informed Defendant that it was infringing the ’895 Patent by making, using, offering for sale, selling, and/or importing wireless access points and/or routers capable of connecting to an Ethernet network and an IEEE 802.11 wireless network (the “’895 Patent Accused Products”) to provide wireless Internet access. 14.
 
IWS’s letter further informed Defendant that its wireless network satisfied all of the limitations of at least claim 48 of the ’895 Patent in at least the following manner: 3

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