Case 2:20-cv-00281-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.
`
`T-MOBILE US, INC.; LAYER3 TV, INC.;
`L3TV DALLAS CABLE SYSTEM, LLC;
`METROPCS TEXAS, LLC; T-MOBILE
`LICENSE LLC; T-MOBILE USA, INC.; T-
`MOBILE WEST LLC; T-MOBILE WEST
`TOWER LLC; IBSV LLC; THEORY
`MOBILE, INC.; T-MOBILE PCS HOLDINGS
`LLC; T-MOBILE RESOURCES
`CORPORATION; and T-MOBILE
`SUBSIDIARY IV CORPORATION
`
`Defendants.
`
`
`
`Case No. 2:20-CV-281
`
`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 T-Mobile US, Inc. (“T-
`
`Mobile US”); Layer3 TV, Inc. ("Layer 3 TV"); L3TV Dallas Cable System, LLC ("L3TV
`
`Dallas"); MetroPCS Texas, LLC ("MetroPCS Texas"); T-Mobile License LLC ("T-Mobile
`
`License"); T-Mobile USA, Inc. ("T-Mobile USA"); T-Mobile West LLC ("T-Mobile West");
`
`T-Mobile West Tower LLC ("T-Mobile Tower"); IBSV LLC ("IBSV"); Theory Mobile, Inc.
`
`("Theory"); T-Mobile PCS Holdings LLC ("T-Mobile PCS"); T-Mobile Resources Corporation
`
`("T-Mobile Resources"); and T-Mobile Subsidiary IV Corporation ("Subsidiary IV");
`
`(collectively, “Defendants” or “T-Mobile”) as follows:
`
`
`32942659
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`

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`Case 2:20-cv-00281-JRG Document 1 Filed 08/28/20 Page 2 of 13 PageID #: 2
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`THE PARTIES
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`1.
`
`Plaintiff KAIFI is a corporation organized and existing under the laws of the State
`
`of Texas, having a principal place of business at 405 State Highway 121, Lewisville, Texas
`
`75067.
`
`2.
`
`Defendant T-Mobile US is a corporation organized and existing under the laws of
`
`the State of Delaware, with a principal place of business at 12920 SE 38th Street, Bellevue, WA
`
`98006. Defendant T-Mobile US may be served with process through its registered agent at
`
`Corporation Service Company, 251 Little Falls Drive, Wilmington DE 19808.
`
`3.
`
`Defendant Layer 3 TV is a corporation organized and existing under the laws of the
`
`State of Delaware, with a principle place of business at 1660 Wynkoop Street, Suite 800 Denver,
`
`CO 80202. Defendant Layer 3 TV may be served with process through it registered agent at
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`Corporation Service Company., 251 Little Falls Drive, Wilmington, Delaware 19808.
`
`4.
`
`Defendant L3TV Dallas is a limited liability company organized and existing under
`
`the laws of the State of Delaware, with a principle place of business at 1660 Wynkoop Street, Suite
`
`800 Denver, CO 80202. Defendant L3TV Dallas may be served with process through it registered
`
`agent at Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
`
`5.
`
`Defendant MetroPCS Texas is a limited liability company organized and existing
`
`under the laws of the State of Delaware, with a principle place of business at 8144 Walnut Hill
`
`Ln., Suite 800, Dallas, TX 75231. Defendant MetroPCS Texas may be served with process through
`
`it registered agent at Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas
`
`78701.
`
`6.
`
`Defendant T-Mobile License is a limited liability company organized and existing
`
`under the laws of the State of Delaware, with a principle place of business at 12920 SE 38th Street,
`
`Bellevue, WA 98006. Defendant T-Mobile License may be served with process through it
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`2
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`registered agent at Corporation Service Company, 251 Little Falls Drive, Wilmington, Delaware
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`19808.
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`7.
`
`Defendant T-Mobile USA is a corporation organized and existing under the laws
`
`of the State of Delaware, with a principle place of business at 12920 SE 38th Street, Bellevue, WA
`
`98006. Defendant T-Mobile USA may be served with process through it registered agent at
`
`Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
`
`8.
`
`Defendant T-Mobile West is a limited liability company organized and existing
`
`under the laws of the State of Delaware, with a principle place of business at 12920 SE 38th Street,
`
`Bellevue, WA 98006. Defendant T-Mobile West may be served with process through it registered
`
`agent at Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
`
`9.
`
`Defendant T-Mobile Tower is a corporation organized and existing under the laws
`
`of the State of Delaware, with a principle place of business at 12920 SE 38th Street, Bellevue, WA
`
`98006. Defendant T-Mobile Tower may be served with process through it registered agent at
`
`Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
`
`10.
`
`Defendant IBSV is a corporation organized and existing under the laws of the State
`
`of Delaware, with a principle place of business at 12920 SE 38th Street, Bellevue, WA 98006.
`
`Defendant IBSV may be served with process through it registered agent at Corporation Service
`
`Company, 251 Little Falls Drive, Wilmington Delaware 19808.
`
`11.
`
`Defendant Theory is a corporation organized and existing under the laws of the
`
`State of Delaware, with a principle place of business at 12920 SE 38th Street, Bellevue, WA 98006.
`
`Defendant Theory may be served with process through it registered agent at Corporation Service
`
`Company, 251 Little Falls Drive, Wilmington Delaware 19808.
`
`12.
`
`Defendant T-Mobile PCS is a limited liability company organized and existing
`
`
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`3
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`under the laws of the State of Delaware, with a principle place of business at 12920 SE 38th Street,
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`Bellevue, WA 98006. Defendant T-Mobile PCS may be served with process through it registered
`
`agent at Corporation Service Co., 251 Little Falls Drive, Wilmington, Delaware 19808.
`
`13.
`
`Defendant T-Mobile Resources is a corporation organized and existing under the
`
`laws of the State of Delaware, with a principle place of business at 12920 SE 38th Street, Bellevue,
`
`WA 98006. Defendant T-Mobile Resources may be served with process through it registered agent
`
`at Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701.
`
`14.
`
`Defendant Subsidiary IV is a corporation organized and existing under the laws of
`
`the State of Delaware, with a principle place of business at 12920 SE 38th Street, Bellevue, WA
`
`98006. Defendant Subsidiary IV may be served with process through it registered agent at
`
`Corporation Service Company, 251 Little Falls Drive, Wilmington, Delaware 19808.
`
`15.
`
`Upon information and belief, Defendant T-Mobile US is the parent corporation of
`
`Defendants Layer 3 TV, L3TV Dallas, MetroPCS Texas, T-Mobile License, T-Mobile USA, T-
`
`Mobile West, T-Mobile Tower, IBSV, Theory, T-Mobile PCS, T-Mobile Resources, and
`
`Subsidiary IV. Defendants have regular and established places of business throughout Texas and
`
`the Eastern District of Texas, including at 516 E. Front Street, Tyler, TX 75702; 222 E End
`
`Boulevard S., Suite C, Marshall, TX 75670; 302 S Mobberly Avenue, Longview, TX 75602; and
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`107 N Timberland Drive, Lufkin, TX 75901.
`
`JURISDICTION; VENUE; JOINDER
`
`16.
`
`This action arises under the patent laws of the United States, Title 35 of the
`
`United States Code (“U.S.C.”) § 101 et seq.
`
`17.
`
`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331, 1332, and
`
`1338(a).
`
`18.
`
`Defendants are subject to this Court’s specific and general personal jurisdiction
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`4
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`consistent with the principles of due process and/or the Texas Long Arm Statute.
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`19.
`
`Defendants are registered with the Secretary of State to do business in the State of
`
`Texas. Defendants sell and offer to sell products and services throughout the State of Texas,
`
`including in this judicial district, and introduce infringing products and services into the stream
`
`of commerce knowing that they would be sold in the State of Texas and this judicial district.
`
`20.
`
`Personal jurisdiction exists generally over Defendants because each Defendant
`
`has sufficient minimum contacts with the forum as a result of business conducted within the
`
`State of Texas and the Eastern District of Texas. Personal jurisdiction also exists over each
`
`Defendant because it, directly or through subsidiaries or intermediaries, makes, uses, sells, offers
`
`for sale, imports, advertises, makes available, and/or markets products within the State of Texas
`
`and the Eastern District of Texas that infringe one or more claims of the ʼ728 Patent, as alleged
`
`more particularly below.
`
`21.
`
`Venue in this District is proper under 28 U.S.C. §§ 1400(b) and 1391(b)–(c)
`
`because each Defendant is subject to personal jurisdiction, resides and/or has a regular and
`
`established place of business, and has committed acts of infringement in this District. Each
`
`Defendant makes, uses, sells, offers to sell, and/or imports infringing products into and/or within
`
`this District, maintains a permanent and/or continuing presence within this District, and has the
`
`requisite minimum contacts with this District such that this venue is a fair and reasonable one.
`
`Upon information and belief, each Defendant has transacted and, at the time of the filing of the
`
`Complaint, is continuing to transact business within this District.
`
`22.
`
`Defendants are properly joined under 35 U.S.C. § 299(a)(1) because, as set forth
`
`in greater detail below, Defendants commonly and/or jointly make, use, sell, offer to sell, and/or
`
`import infringing instrumentalities, such that at least one right to relief is asserted against
`
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`5
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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,
`
`offering to sell, and/or importing into the United States the same accused instrumentalities, as set
`
`forth in greater detail herein.
`
`23.
`
`Defendants are properly joined under 35 U.S.C. § 299(a)(2) because, as set forth
`
`in greater detail below, Defendants make, use, sell, offer to sell in, and/or import into the United
`
`States the same or similar accused instrumentalities, such that questions of fact that are common
`
`to all Defendants will arise, as set forth in greater detail herein.
`
`24.
`
`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”
`
`case under this District’s Local Patent Rule 2-6.
`
`BACKGROUND
`
`25.
`
`The ʼ728 Patent, entitled “Optimal Internet Network Connecting and Roaming
`
`System and Method Adapted for User Moving Outdoors or Indoors,” issued on July 26, 2005 to
`
`the Korea Advanced Institute of Science & Technology (“KAIST”), one of South Korea’s
`
`premier research universities. A true and correct copy of the ʼ728 Patent is attached hereto as
`
`Exhibit A.
`
`26.
`
`KAIST was founded in 1971 as Korea’s first research-oriented science and
`
`engineering institution, has over 9,000 students and 1,100 faculty researchers, and holds more
`
`than 3,300 registered patents worldwide. KAIST has ranked 1st in Korea and 21st in the world
`
`for engineering and information technologies. In 2017, Thomson Reuters named KAIST as the
`
`6th most innovative university in the world. The Times Higher Education ranked KAIST as the
`
`3rd best university in the world under 50 years old.
`
`27.
`
`Plaintiff KAIFI is an intellectual property consulting company that promotes and
`
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`6
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`manages intellectual property directed to telecommunications technologies, which are developed
`
`by Korean research institutes and universities, such as KAIST. KAIFI owns by assignment all
`
`right, title, and interest in and to the ʼ728 Patent, including the right to all remedies for past and
`
`ongoing infringement thereof, and thus has standing to sue for infringement.
`
`28.
`
`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
`
`Science & Technology at KAIST, served as the director of KAIST’s Wireless Power Transfer
`
`Technology Research Center, served as an advisor to the Korean Ministry of Information and
`
`Communication from 2003 to 2007, and heads the LG-KAIST 6G Research Center.
`
`29.
`
`Prof. Cho is the named inventor on over 70 U.S. patents and hundreds of patents
`
`worldwide, and is the author of numerous technical publications. His patents and publications
`
`have been cited over 8,000 times. He has conducted research into network interconnection
`
`technologies and integration of packet-based voice and data terminals with cellular mobile
`
`networks since the late 1980s. He has been recognized as a leading scholar on wireless
`
`communications, including next-generation “5G” mobile networks.
`
`30.
`
`Prof. Cho and his research have been recognized with numerous distinctions. For
`
`example, the Republic of Korea awarded Prof. Cho a Presidential Citation and the Red Stripes
`
`Order of Service Merit, for his contributions to the fields of advanced mobile communications
`
`and wireless technologies. The Korean Institute of Communications and Information Sciences
`
`has recognized and awarded Prof. Cho for his contributions. The Korean newspaper, Dong-a
`
`Ilbo, named Prof. Cho as among Korea’s 100 leading pioneers.
`
`31.
`
`The ʼ728 Patent is directed to an Internet network connecting and roaming system
`
`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
`
`network costs, and increases voice and data communication coverage quality and range.
`
`32.
`
`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
`
`issued a claim construction order on April 17, 2020. Trial was scheduled for September 14,
`
`2020. The AT&T Case was dismissed on August 8, 2020 subject to the terms of a written
`
`settlement agreement.
`
`T-MOBILE ADOPTS THE ʼ728 PATENT TECHNOLOGY
`
`33.
`
`Defendants provide wireless network and system instrumentalities that enable
`
`seameless voice and data communication services, including Defendants’ Wi-Fi Calling, and, on
`
`information and belief, other reasonably similar services from Defendants and third parties.
`
`34.
`
`T-Mobile first introduced Wi-Fi Calling in or around 2007. According to T-
`
`Mobile, “T-Mobile is pioneering a seamless handover between our LTE network and any available
`
`Wi-Fi connection so calls don’t drop between the two.” T-Mobile also states that “Wi-Fi Calling
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`allows customers to make and receive calls and texts (SMS & MMS) over a Wi-Fi connection.
`
`Using Wi-Fi Calling is easy–customers won’t even know they’re making a Wi-Fi call. Simply
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`connect to an available Wi-Fi network with a Wi-Fi calling-enabled smartphone and continue to
`
`make a call or send a text as you would over a cellular connection. No separate app or log-in or
`
`number is needed.” According to T-Mobile, its customers benefit from Wi-Fi Calling through:
`
`•
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` Integrated out-of-the-box experience on T-Mobile capable devices – no extra app
`
`necessary;
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`• Uses your existing phone number – no additional logins necessary;
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`8
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`• Call or message virtually anyone from anywhere you have a Wi-Fi connection;
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`• Extends coverage in areas where no cellular network reaches;
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`• Receive and make Wi-Fi calls back to the United States from anywhere in the world at
`
`no additional cost; and
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`• Available at no additional charge”
`
`35. Wi-Fi Calling is included on most T-Mobile devices and T-Mobile provides
`
`instructions to customers on how to use Wi-Fi Calling. For example, the T-Mobile web-site
`
`provides instructions on how to enable and use Wi-Fi Calling.
`
`THE ACCUSED INSTRUMENTALITIES
`
`36.
`
`The Accused Instrumentalities include systems, networks, and components and
`
`services thereto used and controlled by Defendants for implementing seamless network
`
`transition, including off-loading to a Wi-Fi network, such as through their Wi-Fi Calling system
`
`and service, and include both native and third-party, over the top (OTT) voice and data
`
`applications.
`
`37.
`
`38.
`
`COUNT 1
`
`Each Defendant infringes at least claim 1 of the ʼ728 Patent.
`
`Each Defendant has committed and continues to commit acts of direct
`
`infringement by making, using, selling, offering to sell, and/or importing Accused
`
`Instrumentalities, including but not limited to instrumentalities comprising a wireless network
`
`and system, user mobile devices, Wi-Fi Calling service, internet service provisioning, and Wi-Fi
`
`access points and services, which include nationwide Wi-Fi hotspots.
`
`39.
`
`Exhibit B details the manner in which the Accused Instrumentalities infringe the
`
`‘728 Patent by way of a representative example that charts Defendants’ Wi-Fi Calling. On
`
`
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`9
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`information and belief, the manner of infringement by all Accused Instrumentalities is materially
`
`the same as this representation.
`
`40.
`
`Each Defendant has been and is indirectly infringing the ʼ728 Patent by actively
`
`inducing the direct infringement by others of the ʼ728 Patent, in the United States, the State of
`
`Texas, and this District.
`
`41.
`
`Each Defendant has induced and continues to induce through affirmative acts
`
`customers and third parties, such as wireless subscribers and/or Internet service users, to directly
`
`infringe the ʼ728 Patent under 35 U.S.C. § 271(b) by making, using, selling, offering for sale,
`
`and/or importing into the United States the Accused Instrumentalities.
`
`42.
`
`Defendants infringe the ‘728 Patent by the creation and control of systems utilized
`
`by end users, including Defendant’s direct customers and users who contract with Mobile Virtual
`
`Network Operators (MVNOs). Upon information and belief, per contractual agreements with
`
`Defendants, MVNOs market differently branded-virtual mobile network services to users, that
`
`are implememented and operated on and through Defendant’s actual networks.
`
`43.
`
`The mechanisms by which Defendants infringe the ‘728 Patent through MVNOs
`
`is provided in more detail in Exhibit B and at least a partial list of MVNOs through which T-
`
`Mobile infringes the ‘728 Patent is found in Exhibit C.
`
`44.
`
`Defendants have actual notice of the ʼ728 Patent and/or their infringing activities
`
`relating to the ʼ728 Patent. On August 27, 2020, KAIFI provided T-Mobile with the ‘728 Patent
`
`and claim chart and offered to license the ‘728 Patent. T-Mobile MVNO, Google Fi has actual
`
`notice of the ʼ728 Patent and/or their infringing activities relating to the ʼ728 Patent. For
`
`example, Google Fi has been aware of the ʼ728 Patent since at least September 3, 2015 when
`
`they were put on notice of infringement and/or offered a license to the ʼ728 Patent.. Defendants
`
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`10
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`have been aware of the ʼ728 Patent since at least the filing date of this complaint, when they
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`were put on notice of infringement.
`
`45.
`
`Each Defendant specifically intended and was aware that the ordinary and
`
`customary use of the Accused Instrumentalities would infringe the ʼ728 Patent.
`
`46.
`
`The affirmative acts of inducement by Defendants include, but are not limited to,
`
`any one or a combination of encouraging and/or facilitating third party infringement through the
`
`advertisement, marketing, and dissemination of the Accused Instrumentalities and their
`
`components, including via Defendants’ wireless subscribers and/or internet service users; and
`
`creating and publishing promotional and marketing materials, supporting materials, product
`
`manuals, and/or technical support and information relating to the Accused Instrumentalities,
`
`including but not limited to Wi-Fi Calling and off-loading to a Wi-Fi network, which describe,
`
`train, and instruct users on the implementation of the Accused Instrumentalities and their
`
`components, including but not limited to mobile devices, Wi-Fi networks, and cellular networks.
`
`47.
`
`Defendants knew that the induced conduct would constitute infringement, and
`
`intended said infringement at the time of committing the aforementioned acts, such that those
`
`acts and conduct have been and continue to be committed with the specific intent to induce
`
`infringement, or to deliberately avoid learning of the infringing circumstances at the time these
`
`acts were committed, so as to be willfully blind to the infringement they induced.
`
`48.
`
`Defendants took active steps to encourage end users to use and operate the
`
`Accused Instrumentalities, including but not limited to Wi-Fi Calling and off-loading to a Wi-Fi
`
`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
`
`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
`
`customary use, such that Defendants’ customers and other third parties have directly infringed
`
`the ʼ728 Patent, through the normal and customary use of the Accused Instrumentalities.
`
`49.
`
`Therefore, each Defendant is liable for infringement of the ʼ728 Patent and that
`
`infringement has been and continues to be willful in nature.
`
`50.
`
`51.
`
`Plaintiff KAIFI has incurred and will continue to incur substantial damages.
`
`Plaintiff KAIFI has been and continues to be irreparably harmed by each
`
`Defendant’s infringement.
`
`52.
`
`Therefore, Plaintiff KAIFI is entitled to an injunction, actual and/or compensatory
`
`damages, reasonable royalties, pre- and post-judgment interest, enhanced damages, attorney fees,
`
`and costs.
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`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff KAIFI respectfully requests that this Court:
`
`A.
`
`Enter judgment in favor of Plaintiff KAIFI that the ʼ728 Patent is valid and
`
`enforceable;
`
`B.
`
`Enter judgment in favor of Plaintiff KAIFI that each Defendant has infringed and
`
`continues to infringe the ʼ728 Patent, and find that such infringement is willful;
`
`C.
`
`Award Plaintiff KAIFI all monetary relief available under the laws of the United
`
`States, including but not limited to 35 U.S.C. § 284;
`
`D.
`
`Order each Defendant to pay ongoing royalties in an amount to be determined for
`
`any continued infringement after the date that judgment is entered;
`
`E.
`
`Declare this case exceptional and award Plaintiff KAIFI its reasonable attorney
`
`fees under 35 U.S.C. § 285;
`
`F.
`
`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
`
`G.
`
`Grant Plaintiff KAIFI all such other relief as the Court deems just and equitable.
`
`DEMAND FOR JURY TRIAL
`
`Plaintiff KAIFI demands a jury trial on all issues so triable pursuant to Rule 38 of the
`
`Federal Rules of Civil Procedure.
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`
`
`Date: August 28, 2020
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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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