Case 2:20-cv-00280-JRG Document 1 Filed 08/28/20 Page 1 of 13 PageID #: 1
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`KAIFI LLC,
`
`Plaintiff,
`
`v.
`
`VERIZON COMMUNICATIONS INC.;
`CELLCO PARTNERSHIP D/B/A VERIZON
`WIRELESS; VERIZON SERVICES CORP.;
`VERIZON ENTERPRISE SOLUTIONS, LLC;
`VERIZON BUSINESS GLOBAL LLC;
`VERIZON BUSINESS NETWORK
`SERVICES, LLC; VERIZON CORPORATE
`SERVICES GROUP INC.; VERIZON DATA
`SERVICES, LLC; VERIZON MEDIA INC.;
`and VERIZON ONLINE, LLC,
`
`Defendants.
`
`
`
`Case No. 2:20-CV-280
`
`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff KAIFI LLC (“Plaintiff” or “KAIFI”) hereby alleges infringement of United
`
`States Patent No. 6,922,728 (“the ʼ728 Patent”) against Defendants Verizon Communications
`
`Inc. (“VZComms”); Cellco Partnership d/b/a Verizon Wireless (“VZWireless”); Verizon
`
`Services Corp. (“VZServices”); Verizon Enterprise Solutions, LLC (“VZEnterprise”); Verizon
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`Business Global, LLC (“VZBizGlobal”); Verizon Business Network Services, LLC
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`(VZBizNetwork); Verizon Corporate Services Group Inc. (“VZCorp”); Verizon Data Services,
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`LLC (“VZData”); Verizon Media Inc. (“VZMedia”); and Verizon Online, LLC (“VZOnline”)
`
`(collectively, “Defendants” or “Verizon”) as follows:
`
`THE PARTIES
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`1.
`
`Plaintiff KAIFI is a corporation organized and existing under the laws of the State
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`Error! Unknown document property name.
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`Case 2:20-cv-00280-JRG Document 1 Filed 08/28/20 Page 2 of 13 PageID #: 2
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`of Texas, having a principal place of business at 405 State Highway 121, Lewisville, Texas
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`75067.
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`2.
`
`Defendant VZComms is a corporation organized and existing under the laws of
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`the State of Delaware, with a principal place of business at 1095 Avenue of the Americas, New
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`York, New York 10036. Defendant VZComms may be served with process through its
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`registered agent at CT Corporation System, 350 North St. Paul Street, Dallas, Texas 75201.
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`3.
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`Defendant VZWireless is a general partnership organized and existing under the
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`laws of the State of Delaware, with a principal place of business at One Verizon Way
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`Basking Ridge, New Jersey 07920. Defendant VZWireless may be served with process through
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`its registered agent at The Corporation Trust Company, Corporation Trust Center, 1209 Orange
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`Street, Wilmington, Delaware 19801.
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`4.
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`Defendant VZServices is a corporation organized and existing under the laws of
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`the State of Delaware, with a principal place of business at 1717 Arch Street, 21st Floor,
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`Philadelphia, Pennsylvania 19103. Defendant VZServices may be served with process through
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`its registered agent at CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas
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`75201.
`
`5.
`
`Defendant VZEnterprise is a limited liability company organized and existing
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`under the laws of the State of Delaware, with a principal place of business at One Verizon Way
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`Basking Ridge, New Jersey 07920. Defendant VZEnterprise may be served with process
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`through its registered agent at The Corporation Trust Company, Corporation Trust Center, 1999
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`Bryan Street, Suite 900, Dallas, Texas 75201.
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`6.
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`Defendant VZBizGlobal is a limited liability company organized and existing
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`under the laws of the State of Delaware, with a principal place of business at One Verizon Way
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`2
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`Basking Ridge, New Jersey 07920. Defendant VZBizGlobal may be served with process
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`through its registered agent at The Corporation Trust Company, Corporation Trust Center, 1209
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`Orange Street, Wilmington, Delaware 19801.
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`7.
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`Defendant VZBizNetwork is a limited liability company organized and existing
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`under the laws of the State of Delaware, with a principal place of business at 22001 Loudoun
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`County Parkway, Ashburn, Virginia 20147. Defendant VZBizNetwork may be served with
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`process through its registered agent at CT Corporation System, 1999 Bryan Street, Suite 900,
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`Dallas, Texas 75201.
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`8.
`
`Defendant VZCorp is a corporation organized and existing under the laws of the
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`State of New York, with a principal place of business at One Verizon Way, Basking Ridge, New
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`Jersey 07920. Defendant VZCorp may be served with process through its registered agent at CT
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`Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
`
`9.
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`Defendant VZData is a limited liability company organized and existing under the
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`laws of the State of Delaware, with a principal place of business at One East Telecom Parkway,
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`B3E, Temple Terrace, Florida 33637. Defendant VZData may be served with process through
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`its registered agent at CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas
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`75201.
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`10.
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`Defendant VZMedia is a corporation organized and existing under the laws of the
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`State of Delaware, with a principal place of business at 770 Broadway, New York, New York
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`10003. Defendant VZMedia may be served with process through its registered agent at CT
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`Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`11.
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`Defendant VZOnline is a limited liability company organized and existing under
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`the laws of the State of Delaware, with a principal place of business at 22001 Loudoun County
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`3
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`Parkway, Ashburn, Virginia 20147. Defendant VZOnline may be served with process through
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`its registered agent at CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas
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`75201.
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`12.
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`Upon information and belief, Defendant VZComms is the parent corporation of
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`Defendants VZWireless, VZServices, VZEnterprise, VZBizGlobal, VZBizNetwork, VZCorp,
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`VZData, VZMedia, and VZOnline. Defendants have regular and established places of business
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`throughout Texas and the Eastern District of Texas incluidng at 1006 E End Blvd N, Marshall,
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`Texas 75670, and 500 E Loop 281, Longview, Texas 75605.
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`JURISDICTION; VENUE; JOINDER
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`13.
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`This action arises under the patent laws of the United States, Title 35 of the
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`United States Code (“U.S.C.”) § 101 et seq.
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`14.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331, 1332, and
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`1338(a).
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`15.
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`Defendants are subject to this Court’s specific and general personal jurisdiction
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`consistent with the principles of due process and/or the Texas Long Arm Statute.
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`16.
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`Defendants are registered with the Secretary of State to do business in the State of
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`Texas. Defendants sell and offer to sell products and services throughout the State of Texas,
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`including in this judicial district, and introduce infringing products and services into the stream
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`of commerce knowing that they would be sold in the State of Texas and this judicial district.
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`17.
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`Personal jurisdiction exists generally over Defendants because each Defendant
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`has sufficient minimum contacts with the forum as a result of business conducted within the
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`State of Texas and the Eastern District of Texas. Personal jurisdiction also exists over each
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`Defendant because it, directly or through subsidiaries or intermediaries, makes, uses, sells, offers
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`for sale, imports, advertises, makes available, and/or markets products within the State of Texas
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`4
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`Case 2:20-cv-00280-JRG Document 1 Filed 08/28/20 Page 5 of 13 PageID #: 5
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`and the Eastern District of Texas that infringe one or more claims of the ʼ728 Patent, as alleged
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`more particularly below.
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`18.
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`Venue in this District is proper under 28 U.S.C. §§ 1400(b) and 1391(b)–(c)
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`because each Defendant is subject to personal jurisdiction, resides and/or has a regular and
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`established place of business, and has committed acts of infringement in this District. Each
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`Defendant makes, uses, sells, offers to sell, and/or imports infringing products into and/or within
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`this District, maintains a permanent and/or continuing presence within this District, and has the
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`requisite minimum contacts with this District such that this venue is a fair and reasonable one.
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`Upon information and belief, each Defendant has transacted and, at the time of the filing of the
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`Complaint, is continuing to transact business within this District.
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`19.
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`Defendants are properly joined under 35 U.S.C. § 299(a)(1) because, as set forth
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`in greater detail below, Defendants commonly and/or jointly make, use, sell, offer to sell, and/or
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`import infringing instrumentalities, such that at least one right to relief is asserted against
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`Defendants jointly, severally, and in the alternative with respect to the same transactions,
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`occurrences, or series of transactions or occurrences relating to the making, using, selling,
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`offering to sell, and/or importing into the United States the same accused instrumentalities, as set
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`forth in greater detail herein.
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`20.
`
`Defendants are properly joined under 35 U.S.C. § 299(a)(2) because, as set forth
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`in greater detail below, Defendants make, use, sell, offer to sell in, and/or import into the United
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`States the same or similar accused instrumentalities, such that questions of fact that are common
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`to all Defendants will arise, as set forth in greater detail herein.
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`21.
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`The ’728 Patent was the subject of a prior litigation in this District, in KAIFI LLC
`
`v. AT&T Inc., et al., Case No. 2:19-cv-00138-JRG (E.D. Tex.), making this action a “related”
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`5
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`case under this District’s Local Patent Rule 2-6.
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`BACKGROUND
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`22.
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`The ʼ728 Patent, entitled “Optimal Internet Network Connecting and Roaming
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`System and Method Adapted for User Moving Outdoors or Indoors,” issued on July 26, 2005 to
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`the Korea Advanced Institute of Science & Technology (“KAIST”), one of South Korea’s
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`premier research universities. A true and correct copy of the ʼ728 Patent is attached hereto as
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`Exhibit A.
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`23.
`
`KAIST was founded in 1971 as Korea’s first research-oriented science and
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`engineering institution, has over 9,000 students and 1,100 faculty researchers, and holds more
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`than 3,300 registered patents worldwide. KAIST has ranked 1st in Korea and 21st in the world
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`for engineering and information technologies. In 2017, Thomson Reuters named KAIST as the
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`6th most innovative university in the world. The Times Higher Education ranked KAIST as the
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`3rd best university in the world under 50 years old.
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`24.
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`Plaintiff KAIFI is an intellectual property consulting company that promotes and
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`manages intellectual property directed to telecommunications technologies, which are developed
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`by Korean research institutes and universities, such as KAIST. KAIFI owns by assignment all
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`right, title, and interest in and to the ʼ728 Patent, including the right to all remedies for past and
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`ongoing infringement thereof, and thus has standing to sue for infringement.
`
`25.
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`The sole inventor of the ʼ728 Patent is Dong-Ho Cho, who is currently a professor
`
`of electrical engineering at KAIST. Prof. Cho has been the Dean of the College of Information
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`Science & Technology at KAIST, served as the director of KAIST’s Wireless Power Transfer
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`Technology Research Center, served as an advisor to the Korean Ministry of Information and
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`Communication from 2003 to 2007, and heads the LG-KAIST 6G Research Center.
`
`26.
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`Prof. Cho is the named inventor on over 70 U.S. patents and hundreds of patents
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`worldwide, and is the author of numerous technical publications. His patents and publications
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`have been cited over 8,000 times. He has conducted research into network interconnection
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`technologies and integration of packet-based voice and data terminals with cellular mobile
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`networks since the late 1980s. He has been recognized as a leading scholar on wireless
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`communications, including next-generation “5G” mobile networks.
`
`27.
`
`Prof. Cho and his research have been recognized with numerous distinctions. For
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`example, the Republic of Korea awarded Prof. Cho a Presidential Citation and the Red Stripes
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`Order of Service Merit, for his contributions to the fields of advanced mobile communications
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`and wireless technologies. The Korean Institute of Communications and Information Sciences
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`has recognized and awarded Prof. Cho for his contributions. The Korean newspaper, Dong-a
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`Ilbo, named Prof. Cho as among Korea’s 100 leading pioneers.
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`28.
`
`The ʼ728 Patent is directed to an Internet network connecting and roaming system
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`and method. The ʼ728 Patent provides significant benefits and solutions. For example, with the
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`patented invention, voice and data communications may be seamlessly transitioned to a Wi-Fi
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`network from an LTE network. This reduces load and congestion on cellular networks, reduces
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`network costs, and increases voice and data communication coverage quality and range.
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`29.
`
`In April 2019, KAIFI filed suit on the ‘728 Patent against various AT&T entities
`
`in KAIFI LLC v. AT&T Inc. et al., Case No. 2:19-cv-00138-JRG (“AT&T Case”). The Court
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`issued a claim construction order on April 17, 2020. Trial was scheduled for September 14,
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`2020. The AT&T Case was dismissed on August 8, 2020 subject to the terms of a written
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`settlement agreement.
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`VERIZON ADOPTS THE ʼ728 PATENT TECHNOLOGY
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`30.
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`Defendants provide wireless network and system instrumentalities that enable
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`seameless voice and data communication services, including Defendants’ Wi-Fi Calling, and, on
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`information and belief, other reasonably similar services from Defendants and third parties.
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`31.
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`In or around 2015, Verizon began offering Wi-Fi Calling. According to Verizon,
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`“Verizon customers with Advanced Calling . . . can make and receive calls and initiate video
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`calls over a Wi-Fi Internet connection. Verizon customers already enjoy the largest and most
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`reliable wireless network in the United States, and Advanced Calling with Wi-Fi Calling
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`provides an alternative for those who wish to use Wi-Fi in the home, office or while traveling.”
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`According to Verizon, “Once Advanced Calling is enabled, customers can activate Wi-Fi
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`Calling. When a customer uses Advanced Calling on our 4G LTE network and travels outside of
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`coverage, the call will seamlessly transfer to a known Wi-Fi hotspot when available.”
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`32.
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`According to Verizon, “Making a voice or video call over Wi-fi is the same as a
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`regular call.” According to Verizon, “Wi-Fi Calling lets you make and receive voice and video
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`calls over a Wi-Fi connection instead of using your cellular connection. If you have a Wi-Fi
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`connection and are in an area where voice service is weak or unavailable, use Wi-Fi calling to
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`continue making voice calls.” According to Verizon, “A Wi-Fi Calling icon will appear on your
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`screen during the call to confirm that it is using Wi-Fi to connect it.”
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`33.
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`Verizon’s current selection of smartphones and plans are “Wi-Fi Calling-
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`capable.” Verizon instructs customers on how to use Wi-Fi Calling. For example, the Verizon
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`web-site provides instructions for activating Wi-Fi Calling on the Verizon wireless network for
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`Android devices and the Apple iPhone.
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`34.
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`According to Verizon, “When you turn on Wi-Fi Calling you must be connected
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`to the Verizon network in the US.” “To use Wi-Fi Calling, HD Voice must be actived on your
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`device. It is activated by default on our current selection of smartphones.”
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`35.
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`According to Verizon, the Wi-Fi Calling feature is included in the monthly voice
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`plan. According to Verizon, Wi-Fi Calling uses about 1 MB/minute of data for a voice call and
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`6-8 MB of data for a 1-minute video call. Under Verizon’s subscription plans, Verizon may
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`temporarily slow data speeds after a certain amount of data has been used by subscribers.
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`THE ACCUSED INSTRUMENTALITIES
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`36.
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`The Accused Instrumentalities include systems, networks, and components and
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`services thereto used and controlled by Defendants for implementing seamless network
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`transition, including off-loading to a Wi-Fi network, such as through their Wi-Fi Calling system
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`and service, and include both native and third-party, over the top (OTT) voice and data
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`applications.
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`37.
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`38.
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`COUNT 1
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`Each Defendant infringes at least claim 1 of the ʼ728 Patent.
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`Each Defendant has committed and continues to commit acts of direct
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`infringement by making, using, selling, offering to sell, and/or importing Accused
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`Instrumentalities, including but not limited to instrumentalities comprising a wireless network
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`and system, user mobile devices, Wi-Fi Calling service, internet service provisioning, and Wi-Fi
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`access points and services, which include nationwide Wi-Fi hotspots.
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`39.
`
`Exhibit B details the manner in which the Accused Instrumentalities infringe the
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`‘728 Patent by way of a representative example that charts Defendants’ Wi-Fi Calling. On
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`information and belief, the manner of infringement by all Accused Instrumentalities is materially
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`the same as this representation.
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`40.
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`Defendants have actual notice of the ʼ728 Patent and/or their infringing activities
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`relating to the ʼ728 Patent. For example, on August 27, 2020, KAIFI provided Verizon with the
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`‘728 Patent and a claim chart, and offered to license the ‘728 Patent. Defendants have been
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`aware of the ʼ728 Patent since at least the filing date of this complaint, when they were put on
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`notice of infringement.
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`41.
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`Each Defendant has been and is indirectly infringing the ʼ728 Patent by actively
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`inducing the direct infringement by others of the ʼ728 Patent, in the United States, the State of
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`Texas, and this District.
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`42.
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`Each Defendant has induced and continues to induce through affirmative acts
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`customers and third parties, such as wireless subscribers and/or Internet service users, to directly
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`infringe the ʼ728 Patent under 35 U.S.C. § 271(b) by making, using, selling, offering for sale,
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`and/or importing into the United States the Accused Instrumentalities.
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`43.
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`Defendants infringe the ‘728 Patent by creation and control of systems utilized by
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`end users, including Defendant’s direct customers and users who contract with Mobile Virtual
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`Network Operators (MVNOs). Upon information and belief, per contractual agreements with
`
`Defendants, MVNOs market differently branded-virtual mobile network services to users, that
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`are implememented and operated on and through Defendant’s actual networks.
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`44.
`
`The mechanisms by which Defendants infringe the ‘728 Patent through MVNOs
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`is provided in more detail in Exhibit B and at least a partial list of MVNOs through which
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`Verizon infringes the ‘728 Patent is found in Exhibit C.
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`45.
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`Each Defendant specifically intended and was aware that the ordinary and
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`customary use of the Accused Instrumentalities would infringe the ʼ728 Patent.
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`46.
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`The affirmative acts of inducement by Defendants include, but are not limited to,
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`any one or a combination of encouraging and/or facilitating third party infringement through the
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`advertisement, marketing, and dissemination of the Accused Instrumentalities and their
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`components, including via Defendants’ wireless subscribers and/or internet service users; and
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`creating and publishing promotional and marketing materials, supporting materials, product
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`10
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`manuals, and/or technical support and information relating to the Accused Instrumentalities,
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`including but not limited to Wi-Fi Calling and off-loading to a Wi-Fi network, which describe,
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`train, and instruct users on the implementation of the Accused Instrumentalities and their
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`components, including but not limited to mobile devices, Wi-Fi networks, and cellular networks.
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`47.
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`Defendants knew that the induced conduct would constitute infringement, and
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`intended said infringement at the time of committing the aforementioned acts, such that those
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`acts and conduct have been and continue to be committed with the specific intent to induce
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`infringement, or to deliberately avoid learning of the infringing circumstances at the time these
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`acts were committed, so as to be willfully blind to the infringement they induced.
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`48.
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`Defendants took active steps to encourage end users to use and operate the
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`Accused Instrumentalities, including but not limited to Wi-Fi Calling and off-loading to a Wi-Fi
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`network, despite knowing of the ʼ728 Patent in the United States, in a manner they knew directly
`
`infringes each element of at least claim 1 of the ʼ728 Patent. Further, Defendants provided
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`product manuals and other technical information that cause their subscribers, customers, and
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`other third parties to use and to operate the Accused Instrumentalities for their ordinary and
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`customary use, such that Defendants’ customers and other third parties have directly infringed
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`the ʼ728 Patent, through the normal and customary use of the Accused Instrumentalities.
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`49.
`
`Therefore, each Defendant is liable for infringement of the ʼ728 Patent and that
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`infringement has been and continues to be willful in nature.
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`50.
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`51.
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`Plaintiff KAIFI has incurred and will continue to incur substantial damages.
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`Plaintiff KAIFI has been and continues to be irreparably harmed by each
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`Defendant’s infringement.
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`52.
`
`Therefore, Plaintiff KAIFI is entitled to an injunction, actual and/or compensatory
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`damages, reasonable royalties, pre- and post-judgment interest, enhanced damages, attorney fees,
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`and costs.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff KAIFI respectfully requests that this Court:
`
`A.
`
`Enter judgment in favor of Plaintiff KAIFI that the ʼ728 Patent is valid and
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`enforceable;
`
`B.
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`Enter judgment in favor of Plaintiff KAIFI that each Defendant has infringed and
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`continues to infringe the ʼ728 Patent, and find that such infringement is willful;
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`C.
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`Award Plaintiff KAIFI all monetary relief available under the laws of the United
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`States, including but not limited to 35 U.S.C. § 284;
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`D.
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`Order each Defendant to pay ongoing royalties in an amount to be determined for
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`any continued infringement after the date that judgment is entered;
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`E.
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`Declare this case exceptional and award Plaintiff KAIFI its reasonable attorney
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`fees under 35 U.S.C. § 285;
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`F.
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`Enjoin each Defendant, and its officers, subsidiaries, agents, servants, and
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`employees, and all persons in active concert with any of the foregoing, from further infringement
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`of the ʼ728 Patent; and
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`G.
`
`Grant Plaintiff KAIFI all such other relief as the Court deems just and equitable.
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`DEMAND FOR JURY TRIAL
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`Plaintiff KAIFI demands a jury trial on all issues so triable pursuant to Rule 38 of the
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`Federal Rules of Civil Procedure.
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`Case 2:20-cv-00280-JRG Document 1 Filed 08/28/20 Page 13 of 13 PageID #: 13
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`
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`Date: August 28, 2020
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`
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`
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`Respectfully submitted,
`
`/s/ Robert Christopher Bunt
`
`
`
`Robert Christopher Bunt
`Texas Bar No. 00787165
`PARKER, BUNT & AINSWORTH PC
`100 E. Ferguson St., Suite 418
`Tyler, Texas 75702
`Telephone: (903) 531-3535
`Email: rcbunt@pbatyler.com
`
`Enoch H. Liang
`Cal. Bar No. 212324 (admitted in E.D. Texas)
`Michael J. Song
`Cal. Bar No. 243675 (admitted in E.D. Texas)
`Vincent M. Pollmeier
`Cal. Bar No. 210684
`LTL ATTORNEYS LLP
`300 S. Grand Ave., 14th Fl.
`Los Angeles, California 90071
`Telephone: (213) 612-8900
`Facsimile: (213) 612-3773
`Email: enoch.liang@ltlattorneys.com
`Email: michael.song@ltlattorneys.com
`Email: vincent.pollmeier@ltlattorneys.com
`
`Attorneys for Plaintiff KAIFI LLC
`
`13
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