Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 1 of 19 PageID #: 698
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`UNILOC USA, INC. et al
`Plaintiffs,
`
` v.
`
`PAYCHEX, INC.
`Defendant.
`
`RIOT GAMES, INC.,
`Defendant.
`
`
`
`CIVIL ACTION NO. 2:16-cv-1316-RWS
`CONSOLIDATED LEAD CASE
`
`JURY TRIAL DEMANDED
`
` CIVIL ACTION NO. 2:17-cv-284-RWS
`
`
`§
`§
`§
` §
`§
`§
`§
`§
`§
`§
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`.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`1.
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`Plaintiffs, Uniloc USA, Inc. and Uniloc Luxembourg, S.A. (together “Uniloc”), as
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`and for their complaint against defendant, Riot Games, Inc. (“Riot Games”), allege as follows:
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`
`
`THE PARTIES
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`2.
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`Uniloc USA, Inc. (“Uniloc USA”) is a Texas corporation having a principal place
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`of business at Legacy Town Center I, Suite 380, 7160 Dallas Parkway, Plano Texas 75024. Uniloc
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`also maintains a place of business at 102 N. College, Suite 603, Tyler, Texas 75702.
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`3.
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`Uniloc Luxembourg S.A. (“Uniloc Luxembourg”) is a Luxembourg public limited
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`liability company having a principal place of business at 15, Rue Edward Steichen, 4th Floor, L-
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`2540, Luxembourg (R.C.S. Luxembourg B159161). Uniloc Luxembourg owns several patents in
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`the field of application management in a computer network.
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`4.
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`Upon information and belief, Riot Games, Inc. is a Delaware corporation having a
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`place of business in 12333 W Olympic Blvd, Los Angeles CA 90064 and offering its products
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`and/or services, including those accused herein of infringement, for purchase or download to
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`1
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`

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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 2 of 19 PageID #: 699
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`customers and/or potential customers located in Texas and in the judicial Eastern District of Texas.
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`Riot Games, Inc. may be served with process through its registered agent: CT Corp 818 West
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`Seventh St. Ste 930 Los Angeles, CA 90017.
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`JURISDICTION AND VENUE
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`1.
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`Uniloc USA and Uniloc Luxembourg (collectively, “Uniloc”) bring this action
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`for patent infringement under the patent laws of the United States, 35 U.S.C. § 271 et seq. This
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`Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1338(a) and 1367.
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`2.
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`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(d) and
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`1400(b). This Court has personal jurisdiction over Riot Games, in part, because Riot Games
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`provides infringing online services to subscribers who reside in this district. Upon information
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`and belief, Riot Games is deemed to reside in this judicial district, has committed acts of
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`infringement in this judicial district, and/or has purposely transacted business involving the
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`accused products and/or services in Texas and this judicial district.
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`3.
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`Riot Games is subject to this Court’s jurisdiction pursuant to due process and/or
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`the Texas Long Arm Statute due at least to its substantial presence and business in this State and
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`judicial district, including: (A) at least part of its past infringing activities, (B) regularly doing
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`and/or soliciting business in Texas and/or (C) engaging in persistent conduct and/or deriving
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`substantial revenue from goods and services provided to customers in Texas. Riot also has
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`multiple facilities in the EDTX and NDTX.
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`4.
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`Riot’s gameplay relies on a behind-the-scenes network infrastructure designed to
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`allow critical low latency connections between players. To enable such infrastructure in the
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`central part of the U.S, Riot employs a massive network infrastructure located in the EDTX and
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`5.
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`Riot’s engineering website identifies its only central U.S. server facility in Dallas,
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`NDTX.
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`2
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`TX. This sever facility – called CyrusOne at 1649 West Frankford Road – is located in the EDTX.
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`This particular facility is the biggest of its kind in Texas.
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`Source: https://engineering.riotgames.com/news/fixing-internet-real-time-applications-
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`part-ii
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`6.
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`Riot also provide the following high- level snapshot for its architecture:
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`Source:
`https://boards.na.leagueoflegends.com/en/c/help-support/0hVNFnPH-na-server-
`roadmap-update-pops-peering-and-the-north-bridge
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`7.
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`Riot also has its servers and other network infrastructure in at least three other
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`3
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`Eastern EDTX facilities located in the DFW area.
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`8.
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`Riot additionally places its equipment inside facilities in the EDTX and NDTX in
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`a peering relationship to more quickly serve Riot game users.
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`9.
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`Riot games is also believed to other infrastructure and equipment as part of so -
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`called edge tier.
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`10.
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`11.
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`Riot also describes itself as an eSports tournament organizer.
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`Riot sponsors Riot Games tournaments, viewing parties, and other events in the
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`Eastern District of Texas (EDTX) and the Northern District of Texas (NDTX).
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`12.
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`These Riot Games events in EDTX and NDTX are contracted and registered
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`directly with Riot and displayed on Riot’s website.
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`13.
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`Riot’s interactive website seeks out EDTX residents and NDTX residents allowing
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`them to locate local EDTX and NDTX events as well as register for those events directly on Riot’s
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`website using Riot login credentials assigned to each of those EDTX or NDTX residents. EDTX
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`and NDTX residents may later return to Riot’s website, login, and continue to obtain additional
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`details of such Riot sponsored events.
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`14.
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`For these EDTX and NDTX events, Riots also provides prizes to EDTX and NDTX
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`residents.
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`15.
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`Riot contracts with partner companies and venues located within EDTX and NDTX
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`for these tournaments.
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`16.
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`As a contractual obligation of these tournaments in the EDTX and the NDTX, only
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`Riot permits only Riot’s League of Legend game to be played.
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`17.
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`Another contractual obligation of these tournaments, one may not use any element
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`of Riot’s intellectual property without Riot’s prior approval.
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`18.
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`For Riot Game tournaments in the EDTX and NDTX, Riot sets and requires EDTX
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`and NDTX users to follow Riot established protocol concerning game-play.
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`4
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 5 of 19 PageID #: 702
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`below:
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`19.
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`Riot Games also advertises its EDTX events in the EDTX venues such as shown
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`Source: http://na.leagueoflegends.com/en/tag/viewing-party
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`20.
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`One example of an Riot sponsored EDTX event on Riot’s website was a viewing
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`party at 7201 N. Central Expressway, Plano, TX on October 31, 2015 attended by 100’s of
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`attendees.
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`21.
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`Another example of a Riot event in EDTX listed on Riot’s website was a two-day
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`tournament where Riot also provided prizes on July 8, 2017 and July 9, 2017 at the Microsoft Store
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`2601 Preston Road Frisco, TX 75034.
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`22.
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`One example of aRiot Event in NDTX listed on Riot’s website was a May 1, 2016
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`tournament where Riot also provided prizes at Shadow Lan, 300 North Coit Rd., Suite 175
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`Richardson TX, 75080.
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`23. Multiple other Riot events have also occurred in the NDTX and EDTX.
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`24.
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`In addition to these tournaments, Riot markets to high-schools and colleges for
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`competitive team-play.
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`25. Multiple colleges and high schools in the EDTX and NDTX have teams that
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`specifically compete with Riot’s games.
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`26.
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`Texas A&M, which has campuses in the EDTX and other Texas districts, was one
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`of the eight final teams in Riot’s collegiate tournament.
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`27.
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`Riot maintains a list of collegiate teams on the following website:
`https://ulol.na.leagueoflegends.com/
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`28.
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`On its collegiate website, Riot lists the following EDTX teams: Texas A&M
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`5
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 6 of 19 PageID #: 703
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`University Commerce (team Lion Esports); Stephen F. Austin State University (team SFASU
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`LOL); The University of Texas at Dallas (team LOLUTD); Prairie View A&M University (team
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`Panther Gaming); and the University of North Texas (Team UNT Gaming and esports).
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`29.
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`On its collegiate website, Riot lists the following NDTX teams: Texas Christian
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`University (team TCU ESPORTS) and the University of Texas at Arlington (team 1997).
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`30. Much like collegiate football games, Riot broadcast collegiate games from its
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`website which are also broadcast to EDTX and NDYX residents:
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`http://watch.na.lolesports.com/en_US/
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`COUNT I
`(INFRINGEMENT OF U.S. PATENT NO.
`6,510,466)
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`Uniloc incorporates by reference the preceding paragraphs.
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`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,510,466 (“the
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`5.
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`6.
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`‘466 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS
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`FOR CENTRALIZED MANAGEMENT OF APPLICATION PROGRAMS ON A NETWORK
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`that issued on January 21, 2003. A true and correct copy of the ‘466 Patent is attached as Exhibit
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`A hereto.
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`7.
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`Uniloc USA is the exclusive licensee of the ‘466 Patent with ownership of all
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`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
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`sue and recover past damages for the infringement thereof.
`
`8.
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`The ‘466 Patent has been referenced by over four hundred other patent
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`applications/patents including patents applications/patents by IBM, HP, Network Associates,
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`Microsoft, Fujitsu, Alcatel, SAP, AT&T, Citrix, Sharp, Computer Associates, Oracle, Google, and
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`Intel.
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`
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`9.
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`Riot Games provides a platform called “League of Legends,” which includes client
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`6
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 7 of 19 PageID #: 704
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`software and server software that services such client software. Riot Games refers to these as “Riot
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`Services.” Riot Games system operates as a software licensing and delivery system:
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`10.
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`Upon information and belief, the following graphic illustrates, at least in part,
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`how certain aspects of a representative sample of Riot Games’ software licensing and delivery
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`system operates (unless otherwise noted, Riot Games is the source for each graphic in this
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`complaint):
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`Source: http://www.riotgames.com/our-games
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`11.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`7
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 8 of 19 PageID #: 705
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`Source: http://gameinfo.na.leagueoflegends.com/en/game-info/
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`12.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`8
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 9 of 19 PageID #: 706
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`Source: https://i.ytimg.com/vi/_xbRBbLhooA/maxresdefault.jpg
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`13.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`Source: http://riot-web-
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`9
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 10 of 19 PageID #: 707
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`static.s3.amazonaws.com/images/news/November_2013/OFA/OneForAllFlow.jpg
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`14.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`15.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`10
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 11 of 19 PageID #: 708
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`16.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`
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`Source: https://cdn.mmos.com/wp-content/gallery/league-of-legends-overview/League-of-
`Legends-main-gameplay.jpg
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`17.
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`Upon information and belief, the following graphic illustrates, at least in part, how
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`certain aspects of a representative sample of Riot Games’ software licensing and delivery system
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`operate:
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`11
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 12 of 19 PageID #: 709
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`Riot Games has directly infringed, and continues to directly infringe one or more
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`18.
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`claims of the ‘466 Patent, including at least Claim 15, in this judicial district and elsewhere in
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`Texas, literally and/or under the doctrine of equivalents, by or through making, using, importing,
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`offering for sale and/or selling its software licensing and delivery system during the pendency of
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`the ‘466 Patent which software and associated backend server architecture inter alia allow for
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`installing application programs on a server, receiving a login request, establishing a user desktop,
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`12
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 13 of 19 PageID #: 710
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`receiving a selection of one or more programs displayed in the user desktop and providing a
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`program for execution.
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`19.
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`In addition, should Riot Games’ software licensing and delivery system be found to
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`not literally infringe one or more claims of the ‘466 Patent, Riot Games’ would nevertheless
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`infringe one or more claims of the ‘466 Patent under the doctrine of equivalents. More specifically,
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`Riot Games’ system performs substantially the same function (making computer games/software
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`available for digital download/management), in substantially the same way (via a client/server
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`environment), to yield substantially the same result (providing authorized games/software to a
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`client for execution). Riot Games would thus be liable for direct infringement under the doctrine
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`of equivalents.
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`20.
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`Riot Games may have infringed the ‘466 Patent through other software utilizing the
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`same or reasonably similar functionality, including other versions of its software licensing and
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`delivery system. Uniloc reserves the right to discover and pursue all such additional infringing
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`software.
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`
`
`COUNT II
`(INFRINGEMENT OF U.S. PATENT NO.
`6,728,766)
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`21.
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`Uniloc incorporates the paragraphs above by reference.
`
`22.
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`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,728,766 (“the
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`‘766 Patent”) entitled METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS FOR
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`LICENSE USE MANAGEMENT ON A NETWORK that issued on April 27, 2004. A true and
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`correct copy of the ‘766 Patent is attached as Exhibit B hereto.
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`23.
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`Uniloc USA is the exclusive licensee of the ‘766 Patent with ownership of all
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`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
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`
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`13
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 14 of 19 PageID #: 711
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`sue and recover past damages for the infringement thereof.
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`24.
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`The ‘766 Patent has been referenced by over fifty other patent applications/patents
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`including patents applications/patents by IBM, Microsoft, Netapp, Time Warner Cable, Fujitsu,
`
`AT&T, Toshiba, and Computer Associates.
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`25.
`
`Riot Games has directly infringed, and continues to directly infringe one or more
`
`claims of the ‘766 Patent, including at least Claim 7, in this judicial district and elsewhere in Texas,
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`literally and/or under the doctrine of equivalents, by or through making, using, importing, offering
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`for sale and/or selling its software licensing and delivery system during the pendency of the ‘766
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`Patent which software and associated backend server architecture inter alia allow for maintaining
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`user policy based license management information for application programs at a server, receiving
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`a request for a license at the server, determining license availability based on the policy
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`information, and providing an indication of availability or unavailability.
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`26.
`
`In addition, should Riot Games’ software licensing and delivery system be found to
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`not literally infringe one or more claims of the ‘766 Patent, Riot Games would nevertheless infringe
`
`one or more claims of the ‘766 Patent under the doctrine of equivalents. More specifically, the
`
`accused software delivery system performs substantially the same function (making computer
`
`games/software available for digital download/management), in substantially the same way (via a
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`client/server environment), to yield substantially the same result (providing authorized
`
`games/software to a client for execution). Riot Games would thus be liable for direct infringement
`
`under the doctrine of equivalents.
`
`27.
`
`Riot Games may have infringed the ‘766 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software licensing and
`
`delivery system. Uniloc reserves the right to discover and pursue all such additional infringing
`
`
`
`14
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`

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`software.
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`COUNT III
`(INFRINGEMENT OF U.S. PATENT NO.
`6,324,578)
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`28.
`
`Uniloc incorporates the paragraphs above by reference.
`
`29.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 6,324,578 (“the
`
`’578 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS
`
`FOR MANAGEMENT OF CONFIGURABLE APPLICATION PROGRAMS ON A NETWORK
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`that issued on November 27, 2001. A true and correct copy of the ‘578 Patent is attached as Exhibit
`
`C hereto.
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`30.
`
`Uniloc USA is the exclusive licensee of the ‘578 Patent with ownership of all
`
`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
`
`sue and recover past damages for the infringement thereof.
`
`31.
`
`The ‘578 Patent has been referenced by over one-hundred forty other patent
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`applications/patents including patents applications/patents by IBM, Microsoft, Lucent, Netscape,
`
`General Electric, Hewlett Packard, Cisco, SAP, and Siemens.
`
`32.
`
`Riot Games has directly infringed, and continues to directly infringe one or more
`
`claims of the ‘578 Patent, including at least claim 1, in this judicial district and elsewhere in Texas,
`
`literally and/or under the doctrine of equivalents, by or through making, using, importing, offering
`
`for sale and/or selling its software licensing and delivery system during the pendency of the ‘578
`
`Patent which software and associated backend server architecture inter alia allows for installing
`
`application programs having a plurality of configurable preferences and authorized users on a
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`network, distributing an application launcher program to a user, the user obtaining a set of
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`configurable preferences, obtaining an administrator set of configurable preferences and executing
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`
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`15
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 16 of 19 PageID #: 713
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`the application program using the user and administrator sets of configurable preferences
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`responsive to a request from a user.
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`33.
`
`In addition, should Riot Games’ software licensing and delivery system be found to
`
`not literally infringe one or more claims of the ‘578 Patent, Riot Games products would
`
`nevertheless infringe one or more claims of the ‘578 Patent under the doctrine of equivalents. More
`
`specifically, the accused software/system performs substantially the same function (making
`
`computer games available for digital download/management), in substantially the same way (via a
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`client/server environment), to yield substantially the same result (distributing application programs
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`to a target on-demand server on a network). Riot Games would thus be liable for direct
`
`infringement under the doctrine of equivalents.
`
`34.
`
`Riot Games may have infringed the ‘578 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software licensing and
`
`delivery system. Uniloc reserves the right to discover and pursue all such additional infringing
`
`software.
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`
`
`COUNT IV
`(INFRINGEMENT OF U.S. PATENT NO.
`7,069,293)
`
`35.
`
`Uniloc incorporates the paragraphs above by reference.
`
`36.
`
`Uniloc Luxembourg is the owner, by assignment, of U.S. Patent No. 7,069,293 (“the
`
`‘293 Patent”), entitled METHODS, SYSTEMS AND COMPUTER PROGRAM PRODUCTS
`
`FOR DISTRIBUTION OF APPLICATION PROGRAMS TO A TARGET STATION ON A
`
`NETWORK that issued on June 27, 2006. A true and correct copy of the ‘293 Patent is attached as
`
`Exhibit D hereto.
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`37.
`
`Uniloc USA is the exclusive licensee of the ‘293 Patent with ownership of all
`
`
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`16
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 17 of 19 PageID #: 714
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`substantial rights therein, including the right to grant sublicenses, to exclude others, and to enforce,
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`sue and recover past damages for the infringement thereof.
`
`38.
`
`The ‘293 Patent has been referenced by over eighty other patent applications/patents
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`including patents applications/patents by Cisco, AT&T, Microsoft, AOL, SAP, and Samsung.
`
`39.
`
`Riot Games has directly infringed, and continues to directly infringe one or more
`
`claims of the ‘293 Patent, including at least Claim 1, in this judicial district and elsewhere in Texas,
`
`literally and/or under the doctrine of equivalents, by or through making, using, importing, offering
`
`for sale and/or selling its software licensing and delivery system during the pendency of the ‘293
`
`Patent which software and associated backend server architecture inter alia allow for providing an
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`application program for distribution to a network server, specifying source and target directories
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`for the program to be distributed, preparing a file packet associated with the program including a
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`segment configured to initiate registration and distributing the file packet to the target on-demand
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`server to make the program available for use by a client user.
`
`40.
`
`In addition, should Riot Games’ software licensing and delivery system be found to
`
`not literally infringe one or more claims of the ‘293 Patent, Riot Games would nevertheless infringe
`
`one or more claims of the ‘293 Patent under the doctrine of equivalents. More specifically, the
`
`accused software distribution and management system performs substantially the same function
`
`(distributing application programs to a target on-demand server on a network), in substantially the
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`same way (via a client/server environment to target on-demand users), to yield substantially the
`
`same result (making application programs available for use by target on-demand users). Riot
`
`Games would thus be liable for direct infringement under the doctrine of equivalents.
`
`41.
`
`Riot Games may have infringed the ‘293 Patent through other software utilizing the
`
`same or reasonably similar functionality, including other versions of its software licensing and
`
`
`
`17
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 18 of 19 PageID #: 715
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`delivery system. Uniloc reserves the right to discover and pursue all such additional infringing
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`software.
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`
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`PRAYER FOR RELIEF
`
`Uniloc requests that the Court enter judgment against Riot Games as follows:
`
`(A)
`
`that Riot Games has infringed the ‘466 Patent, the ‘766 Patent, the ‘578 Patent,
`
`and the ‘293 Patent;
`
`(B)
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`awarding Uniloc its damages suffered as a result of Riot Games’ infringement of
`
`the ‘466 Patent, the ‘766 Patent, the ‘578 Patent, and the ‘293 Patent pursuant to 35 U.S.C. §
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`284;
`
`(C)
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`enjoining Riot Games, its officers, directors, agents, servants, affiliates,
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`employees, divisions, branches, subsidiaries and parents, and all others acting in concert or privity
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`with it from infringing the ‘466 Patent, the ‘766 Patent, the ‘578 Patent, and the ‘293 Patent
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`pursuant to 35 U.S.C. § 283;
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`awarding Uniloc its costs, attorneys’ fees, expenses and interest, and
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`granting Uniloc such other and further relief as the Court may deem just and
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`(D)
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`(E)
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`proper.
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`38.
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`DEMAND FOR JURY
`TRIAL
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`Uniloc hereby demands trial by jury on all issues so triable pursuant to Fed. R. Civ.
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`18
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`Case 2:16-cv-01316-RWS Document 97 Filed 10/02/17 Page 19 of 19 PageID #: 716
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`Dated: October 2, 2017
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`Respectfully submitted,
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`/s/ Ryan S. Loveless
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`James L. Etheridge
`Texas State Bar No. 24059147
`Ryan S. Loveless
`Texas State Bar No. 24036997
`Brett A. Mangrum
`Texas State Bar No. 24065671
`Travis L. Richins
`Texas State Bar No. 24061296
`Jeffrey Huang
`California State Bar No. 266774
`ETHERIDGE LAW GROUP, PLLC
`2600 E. Southlake Blvd., Suite 120 / 324
`Southlake, Texas 76092
`Telephone: (817) 470-7249
`Facsimile: (817) 887-5950
`Jim@EtheridgeLaw.com
`Ryan@EtheridgeLaw.com
`Brett@EtheridgeLaw.com
`Travis@EtheridgeLaw.com
`Jeff@EtheridgeLaw.com
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`Counsel for Plaintiffs Uniloc USA, Inc. and
`Uniloc Luxembourg S.A.
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`CERTIFICATE OF SERVICE
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`I certify that on October 2, 2017 a true and correct copy of the foregoing document was
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`served upon all counsel of record via email under this Court’s Local Rules.
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`/s/ Ryan S. Loveless
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`Ryan S. Loveless
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`19
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