Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 1 of 15
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`WSOU INVESTMENTS, LLC d/b/a
`BRAZOS LICENSING AND
`DEVELOPMENT,
`
`Plaintiff,
`
`v.
`
`MICROSOFT CORPORATION
`
`Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`CIVIL ACTION NO. 6:20-cv-465
`
`JURY TRIAL DEMANDED
`
`ORIGINAL COMPLAINT FOR PATENT
`INFRINGEMENT
`
`Plaintiff WSOU Investments, LLC d/b/a Brazos Licensing and Development (“Brazos” or
`
`“Plaintiff”), by and through its attorneys, files this Complaint for Patent Infringement against
`
`Microsoft Corporation (“Microsoft” or “Defendant”) and alleges:
`
`1.
`
`This is a civil action for patent infringement arising under the Patent Laws of the
`
`NATURE OF THE ACTION
`
`United States, 35 U.S.C. §§ 1, et seq., including §§ 271, 281, 284, and 285.
`
`2.
`
`Brazos is a limited liability corporation organized and existing under the laws of
`
`THE PARTIES
`
`Delaware, with its principal place of business at 605 Austin Avenue, Suite 6, Waco, Texas 76701.
`
`3.
`
`On information and belief, Defendant Microsoft Corporation is incorporated under
`
`the laws of Washington State with its principal place of business at 1 Microsoft Way, Redmond,
`
`Washington 98052. Microsoft may be served with process through its registered agent Corporation
`
`Service Company, 211 East 7th Street, Suite 620, Austin, Texas 78701.
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 2 of 15
`
`4.
`
`On information and belief, Microsoft has been registered to do business in the state
`
`of Texas under Texas SOS file number 0010404606 since about March 1987.
`
`5.
`
`On information and belief, Microsoft has had regular and established places of
`
`business in this judicial district since at least 2002.
`
`6.
`
`This is an action for patent infringement which arises under the Patent Laws of the
`
`JURISDICTION AND VENUE
`
`United States, in particular, 35 U.S.C. §§ 271, 281, 284, and 285.
`
`7.
`
`This Court has jurisdiction over the subject matter of this action under 28 U.S.C.
`
`§§ 1331 and 1338(a).
`
`8.
`
`This Court has specific and general personal jurisdiction over Microsoft pursuant
`
`to due process and/or the Texas Long Arm Statute, because Microsoft has committed acts giving
`
`rise to this action within Texas and within this judicial district. The Court’s exercise of jurisdiction
`
`over Microsoft would not offend traditional notions of fair play and substantial justice because
`
`Microsoft has established minimum contacts with the forum. For example, on information and
`
`belief, Microsoft has committed acts of infringement in this judicial district, by among other things,
`
`selling and offering for sale products that infringe the asserted patent, directly or through
`
`intermediaries, as alleged herein.
`
`9.
`
`Venue in the Western District of Texas is proper pursuant to 28 U.S.C. §§1391
`
`and/or 1400(b).
`
`10.
`
`This district was deemed to be a proper venue for patent cases against Microsoft in
`
`actions bearing docket numbers: 6-19-cv-00572 (Zeroclick, LLC v. Microsoft Corporation ); 6-19-
`
`cv-00687 (Exafer, Ltd. v. Microsoft Corporation.); and 6-19-cv-00399 (Neodron Ltd. v. Microsoft
`
`Corporation).
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 3 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 3 of 15
`
`11.
`
`On information and belief, Microsoft maintains a variety of regular and established
`
`business locations in the judicial district including its Corporate Sales Office Locations, Retail
`
`Store Locations, and Datacenter Locations.
`
`12.
`
`On information and belief, Microsoft operates multiple corporate sales offices in
`
`the judicial district, and these offices constitute regular and establishedplaces of business.
`
`13.
`
`On information and belief, Microsoft employs hundreds of employees within its
`
`corporate sales offices located in the judicial district.
`
`14.
`
`On information and belief, Microsoft has an established place of business in this
`
`judicial district known as “Corporate Sales Office: Austin” located at 10900 Stonelake Boulevard,
`
`Suite 225, Austin, Texas 78759 and “Microsoft Retail Store: The Domain” located at 3309
`
`Esperanza Crossing, Suite 104 Austin, Texas 78758.
`
`Microsoft U.S. office locations
`
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`1 Corporate Sales Office Austin
`10900 Szonelake Boulevard, Suite 225
`Austin, TX USA
`78759
`_
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`View directions
`
`2. Microsoft Retail Store: The Domain
`3309 Esperanza Crossing, Suite 104
`Austin. TX. USA
`78758
`
`View directions
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`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 4 of 15
`
`15.
`
`On information and belief, Microsoft’s “Corporate Sales Office: Austin” and
`
`“Microsoft Retail Store: The Domain” locations were respectively assessed by the Travis County
`
`Appraisal District in 2019 to have market values of over $2.3 million dollars and $2.7 million
`
`dollars.
`
`http://propaccess.traviscad.org/clientdb/SearchResults.aspx
`
`16.
`
`On information and belief, Microsoft has another established place of business in
`
`this judicial district known as “Corporate Sales Office: San Antonio” located at Concord Park II,
`
`401 East Sonterra Boulevard, Suite 300, San Antonio, Texas 78258.
`
`
`
`
`Source: Google Maps
`
`
`
`
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 5 of 15
`
`17.
`
`On information and belief, Microsoft owns and operates multiple datacenters in the
`
`judicial district, including without limitation data centers located at 5150 Rogers Road, San
`
`Antonio, Texas 78251; 5200 Rogers Road, San Antonio, Texas 78251; 3823 Weisman Boulevard,
`
`San Antonio, Texas 78251; and 15000 Lambda Drive, San Antonio, Texas 782245.
`
`18.
`
`On information and belief, Microsoft utilizes its datacenter locations in this judicial
`
`district as regular and established places of business. As a non-limiting example, the data centers
`
`in San Antonio are referred to within Microsoft as “US Gov Texas.”
`
`19.
`
`On information and belief, thousands of customers who rely on the infringing
`
`datacenter infrastructure that Microsoft’s engineering and operations teams have built, reside in
`
`this judicial district.
`
`
`
`COUNT ONE - INFRINGEMENT OF
`U.S. PATENT NO. 8,274,902
`
`
`20.
`
`Brazos re-alleges and incorporates by reference the preceding paragraphs of this
`
`Complaint.
`
`21.
`
`On September 25, 2012, the United States Patent and Trademark Office duly and
`
`legally issued U.S. Patent No. 8,274,902 (“the ’902 Patent”), entitled “Estimation Method for Loss
`
`Rates in a Packetized Network.” A true and correct copy of the ’902 Patent is attached as Exhibit
`
`A to this Complaint.
`
`22.
`
`Brazos is the owner of all rights, title, and interest in and to the ’902 Patent,
`
`including the right to assert all causes of action arising under the ’902 Patent and the right to any
`
`remedies for the infringement of the ’902 Patent.
`
`
`
`5
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 6 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 6 of 15
`
`23.
`
`Microsoft makes, uses, sells, offers for sale, imports, and/0r distributes in the
`
`United States, including within this judicial district, products such as, but not limited to, network
`
`monitoring products, including Network Performance Monitor (NPM) in Azure (collectively, the
`
`“Accused Products”).
`
`24.
`
`Microsoft Azure is a cloud computing service for building, testing, deploying, and
`
`managing applications and services through Microsoft-managed data centers. The Azure portal
`
`helps users to manage Azure services.
`
`What is Azure?
`
`Azure is a complete cloud platform that can host your existing applications and streamline new
`application development. Azure can even enhance on-premises applications. Azure integrates the
`cloud services that you need to develop, test, deploy, and manage your applications, all while taking
`advantage of the efficiencies of cloud computing.
`
`By hosting your applications in Azure, you can start small and easily scale your application as your
`customer demand grows. Azure also offers the reliability that’s needed for high-availability
`applications, even including failover between different regions. The wiLrtal lets you easily
`
`manage all your Azure services. You can also manage your services programmatically by using service-specific APls and templates.
`
`hflps://docs.microsofi.com/en—us/azure/gujdes/developer/azme—developer-guide
`
`25.
`
`The Accused Products offer a variety of solutions to monitor networking assets in
`
`Azure and in hybrid environments comprising Azure and on—premises equipment. The Accused
`
`Products have solutions and utilities to monitor network connectivity, the health of ExpressRoute
`
`circuits, and analyze network traffic in the cloud.
`
`Azure offers a host of solutions to monitor your networking assets. Azure has solutions and utilities
`
`the cloud.
`
`to monitor network connectivity, the health of ExpressRoute circuits, and analyze network traffic in
`
`ht_tps://docs.microsofi.com/en-us/azure/networkingznetwork-monitoring-overview
`
`h
`s://docs.microsofi.com/en-us/azure/azure-monitor/insi
`ts/network— erfonnance-monitor—fa
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 7 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 7 of 15
`
`Network Performance Monitor (NPM) is a suite of capabilities, each of which is geared towards
`
`monitoring the health of your network. network connectivity to your applications, and provides
`
`insights into the performance of your network. NPM is cloud-based and provides a hybrid network
`
`monitoring solution that monitors connectivity between:
`
`Performance Monitor. ExpressRoute Monitor, and Service Connectivity Monitor are monitoring capabilities within NPM and are described below.
`
`0 Cloud deployments and on—premises locations
`
`0 Multiple data centers and branch offices
`
`0 Mission critical multi-tier applications/micro-services
`
`0 User locations and web—based applications (HTTP/HTTPs)
`
`
`
`h s://docs.microsofi.com/en—us/azure/networkin network-monitorin -overview
`
`26.
`
`A user of the Accused Products can monitor network connectivity across cloud
`
`deployments and on-premises locations, multiple data centers, etc. and can determine the
`
`infrastructure in the path, such as intermediate branching nodes and response time ofthe service.
`
`Network Performance Monitor offers three broad capabilities:
`
`0 Performance Monitor: You can monitor network connectivity across cloud deployments and
`on-premises locations. multiple data centers, and branch offices and mission-critical multitier
`applications or microservices. With Performance Monitor. you can detect network issues before
`users complain.
`
`branch offices and Azure, over Azure ExpressRoute.
`
`My Monitor. You can monitor the connectivity from your users to the services
`you care about, determine what infrastructure is in the path, and identify where network
`bottlenecks occur. You can know about outages before your users. and see the exact location
`of the issues along your network path.
`
`This capability helps you perform tests based on HTTP, HTTPS, TCP. and ICMP to monitor in
`near real time or historically the availability and response time of your service. You also can
`monitor the contribution of the network in packet loss and latency. With a network topology
`map, you can isolate network slowdowns. You can identify problem spots that occur along the
`network path from the node to the service, with latency data on each hop. With built-in tests,
`you can monitor network connectivity to Office 365 and Dynamics CRM without any
`preconfiguration. With this capability. you can monitor network connectivity to any TCP-
`capable endpoint, such as websites, SaaS applications, PaaS applications, and SQL databases.
`
`ExpressRoute Monitor. Monitor end-to-end connectivity and performance between your
`
`monitor
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 8 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 8 of 15
`
`27.
`
`The Accused Products include Performance Monitor (PM). PM provides network
`
`monitoring for cloud, hybrid, and on—premises environments. A user can monitor network
`
`connectivity across remote branch and field offices, store locations, data centers, and clouds.
`
`Performance Monitor is part of NPM and is network monitoring for cloud. hybrid, and on-premises
`
`environments. You can monitor network connectivity across remote branch and field offices, store
`
`locations, data centers, and clouds. You can detect network issues before your users complain. The
`
`key advantages are:
`
`Monitor the health of the network. without the need for SNMP
`
`Monitor loss and latency across various subnets and set alerts
`
`Monitor all paths (including redundant paths) on the network
`
`Troubleshoot transient and point-in—time network issues, that are difficult to replicate
`
`Determine the specific segment on the network that is responsible for degraded performance
`
`
`h
`s://docs.microsoft.com/en-us/azure/networkin network-monitorin -overview
`
`28.
`
`A reference architecture of an implementation of a Hub-Spoke Network topology
`
`in Azure is shown below. Here, Virtual Machines (VMs) act as endpoints.
`
`,
`On-premises network
`
`Hub virtual network
`
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`Spoke1 virtual network
`
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`s://docs.microsofi.com/en—us/azure/architecture/reference-architectures/h brid-
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`
`networkinglhub-spoke
`
`29.
`
`The Accused Products are a cloud-based platform and thereby act as a collection
`
`point to collect the performance data to show network connectivity and report data to the user.
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 9 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 9 of 15
`
`Therefore, the network branches from the Accused Product to a plurality of downstream end nodes
`
`(here, VMs, for example).
`
`What is Cloud Computing?
`
`Cloud computing IS a platform that provrdes access to
`computing resources over (he mlemel
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`
`hflps://www.youtube.com/watch?v=3Ag521UPG4
`
`30.
`
`Users of the Accused Products can monitor the connectivity, determine what
`
`infrastructure is in the path, and identify where network bottlenecks occur. Further, service
`
`connectivity helps to monitor end—to-end connectivity to applications and determines network
`
`latency and packet loss in the network.
`
`ith Service Connectivity monitoring, you can now test reachability of applications and detect
`
`performance bottlenecks across on-premises, carrier networks and cloud/private data centers.
`
`Dynamics 365, Skype for Business and other Microsoft services
`
`Monitor end—to—end network connectivity to applications
`
`Correlate application delivery with network performance, detect precise location of
`
`degradation along the path between the user and the application
`
`Test application reachability from multiple user locations across the globe
`
`Determine network latency and packet loss for your line of business and SaaS applications
`
`Determine hot spots on the network, that may be causing poor application performance
`
`Monitor reachability to Office 365 applications, using built-in tests for Microsoft Office 365,
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 10 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 10 of 15
`
`ht_tps://docs.microsofi.com/en-us/azure/networkingznetwork-monitoring—overview
`
`h
`s://docs.microsofi.com/en-us/azure/azure—monitor/insi
`ts/network- erformance-monitor-fa
`
`31.
`
`Azure virtual machines allow pinging to a port of the machine to confum the
`
`connectivity
`
`between
`
`the
`
`collection
`
`point
`
`and
`
`the
`
`end
`
`node.
`
`See
`
`hmgs://dreamtechprojects.wordpress.com/ta gZQacket-lossL
`
`32.
`
`The Accused Products use synthetic transactions to monitor network performance
`
`between source and destination agents. A user can choose between TCP or ICMP as the protocol
`
`for monitoring the performance and service connectivity.
`
`Network Performance Monitor uses synthetic transactions to monitor network performance
`
`between source and destination agents. You can choose between TCP and ICMP as the protocol for
`
`communication between the Log Analytics agents used for monitoring on the protocol you choose.
`
`monitoring in Performance Monitor and Service Connectivity Monitor capabilities. Only TCP is
`
`available as the monitoring protocol for ExpressRoute Monitor. Make sure that the firewall allows
`
`
`h
`s://docs.microsofi.com/en-us/azure/azure—monitor/insi
`ts/network- erfonnance-monitor
`
`33.
`
`Based on the data collected (using TCP or ICMP Protocol), the Accused Products
`
`measure the parameters and compute latency and packet loss rates at various points in the network,
`
`allowing users to perform end-to—end diagnostics of the performance of the environment for the
`
`network, portions of the network, and/or nodes.
`
`10
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 11 of 15
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`
`34.
`
`For example, an administrator can monitor network perfonnance between two end
`
`nodes of a network. After selecting the nodes, one can obtain the packet loss rate (loss %) of the
`
`11
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 12 of 15
`
`test packets and latency between the selected two end nodes, which provides an estimate of packet
`
`loss for the network.
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`
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`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 13 of 15
`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 13 of 15
`
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`
`35.
`
`In view of preceding paragraphs, each and every element of at least claim 1 of the
`
`’902 Patent is found in the Accused Products.
`
`36.
`
`Microsoft has and continues to directly infringe at least one claim of the ’902
`
`Patent, literally or under the doctrine of equivalents, by making, using, selling, offering for sale,
`
`importing, and/or distributing the Accused Products in the United States, including within this
`
`judicial district, without the authority of Brazos.
`
`37.
`
`Microsoft has received notice and actual or constructive knowledge of the ’902
`
`Patent since at least the date of service of this Complaint.
`
`38.
`
`Since at least the date of service of this Complaint,
`
`through its actions,
`
`Microsoft has actively induced product makers, distributors, retailers, and/or end users of the
`
`Accused Products to infringe the ’902 Patent throughout the United States, including within this
`
`judicial district, by, among other things, advertising and promoting the use of the Accused
`
`l3
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 14 of 15
`
`Products in various websites, including providing and disseminating product descriptions,
`
`operating manuals, and other instructions on how to implement and configure the Accused
`
`Products. Examples of such advertising, promoting, and/or instructing include the documents
`
`at:
`
`• https://docs.microsoft.com/en-us/azure/guides/developer/azure-developer-guide
`
`• https://docs.microsoft.com/en-us/azure/networking/network-monitoring-
`overview
`
`• https://docs.microsoft.com/en-us/azure/azure-monitor/insights/network-
`performance-monitor
`• https://docs.microsoft.com/en-us/azure/architecture/reference-
`architectures/hybrid-networking/hub-spoke
`
`
`39.
`
`Since at least the date of service of this Complaint, through its actions,
`
`Microsoft has contributed to the infringement of the ’902 Patent by having others sell, offer for
`
`sale, or use the Accused Products throughout the United States, including within this judicial
`
`district, with knowledge that the Accused Products infringe the ’902 Patent. The Accused
`
`Products are especially made or adapted for infringing the ’902 Patent and have no substantial
`
`non-infringing use. For example, in view of the preceding paragraphs, the Accused Products
`
`contain functionality which is material to at least one claim of the ’902 Patent.
`
`Brazos hereby demands a jury on all issues so triable.
`
`JURY DEMAND
`
`
`
`REQUEST FOR RELIEF
`
`
`WHEREFORE, Brazos respectfully requests that the Court:
`
`(A)
`
`Enter judgment that Microsoft infringes one or more claims of the ’902 Patent
`
`literally and/or under the doctrine of equivalents;
`
`(B)
`
`Enter judgment that Microsoft has induced infringement and continues to induce
`
`infringement of one or more claims of the ’902 Patent;
`
`
`
`14
`
`

`

`Case 6:20-cv-00465 Document 1 Filed 06/02/20 Page 15 of 15
`
`(C)
`
`Enter judgment that Microsoft has contributed to and continues to contribute to
`
`the infringement of one or more claims of the ’902 Patent;
`
`(D)
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`Award Brazos damages, to be paid by Microsoft in an amount adequate to
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`compensate Brazos for such damages, together with pre-judgment and post-judgment interest for
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`the infringement by Microsoft of the ’902 Patent through the date such judgment is entered in
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`accordance with 35 U.S.C. § 284, and increase such award by up to three times the amount found
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`or assessed in accordance with 35 U.S.C. § 284;
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`(E)
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`(F)
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`Declare this case exceptional pursuant to 35 U.S.C. § 285; and
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`Award Brazos its costs, disbursements, attorneys’ fees, and such further and
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`additional relief as is deemed appropriate by this Court.
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`Dated: June 2, 2020
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`Respectfully submitted,
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`/s/ James L. Etheridge
`James L. Etheridge
`Texas State Bar No. 24059147
`Ryan S. Loveless
`Texas State Bar No. 24036997
`Travis L. Richins
`Texas State Bar No. 24061296
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`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
`Travis@EtheridgeLaw.com
`
`COUNSEL FOR PLAINTIFF
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`15
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