Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 1 of 40
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TRAXCELL TECHNOLOGIES, LLC,
`Plaintiff,
`
`v.
`VERIZON WIRELESS PERSONAL
`COMMUNICATIONS, LP,
` Defendant.
`
`
`
`
`
`
`
`CASE NO. 6:20-CV-01175
`
`
`JURY DEMAND
`
`
`
`
`
`
`PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`
`
`
`
`
`Traxcell Technologies, LLC. (“Traxcell”) files this Original Complaint, and demand for
`
`jury trial seeking relief from patent infringement by Verizon Wireless Personal Communications,
`
`LP (“Defendant” or “Verizon”), alleging infringement of the claims of U.S. Pat. No. 9,918,196;
`
`U.S. Pat. No. 10,390,175; U.S. Pat. No. 10,701,517; U.S. Pat. No. 10,743,135; and, U.S. Pat. No.
`
`10,820,147 (collectively referred to as “Patents-in-Suit”), as follows:
`
`I.
`
`THE PARTIES
`
`1. Plaintiff Traxcell is a Texas Limited Liability Company, with its principal place of
`
`business located at 103 Country Club Drive. #508, Marshall, Texas 75672.
`
`2. Verizon Wireless Personal Communications, LP is Delaware corporation with its principal
`
`place of business at One Verizon Way, Basking Ridge, New Jersey and a registered agent for
`
`service of process at CT Corp System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201-3136.
`
`On information and belief, Verizon Wireless Personal Communications, LP sells and offers to sell
`
`products and services throughout Texas, including in this judicial district, and introduces products
`
`and services that perform infringing processes into the stream of commerce knowing that they
`
`would be sold in Texas and this judicial district.
`
`
`
`
`
`
` 1
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`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 2 of 40
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`II. JURISDICTION AND VENUE
`
`3. This is an action for patent infringement arising under the patent laws of the U.S., 35
`
`U.S.C. §§ 1 et. seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§
`
`1331 and 1338(a).
`
`4. This Court has personal jurisdiction over Defendants because: Defendants are present
`
`within or has minimum contacts within the State of Texas and this judicial district;
`
`Defendants have purposefully availed itself of the privileges of conducting business in the
`
`State of Texas and in this judicial district; Defendants regularly conducts business within
`
`the State of Texas and within this judicial district; and Plaintiff’s cause of action arises
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`directly from Defendants’ business contacts and other activities in the State of Texas and
`
`in this judicial district.
`
`5. Venue is proper in this district under 28 U.S.C. § 1400(b). Defendants have committed
`
`acts of infringement and have a regular and established place of business in this District.
`
`III. INFRINGEMENT (‘196 Patent (attached as Exhibit A))
`
`6. On March 13, 2018, U.S. Patent No. 9,918,196 (“the ’196 patent”), attached as Exhibit A,
`
`entitled “Internet queried directional navigation system with mobile and fixed originating
`
`location determination” was duly and legally issued by the U.S. Patent and Trademark
`
`Office. Traxcell owns the ’196 patent by assignment.
`
`7. The ’196 Patent’s Abstract states, “A mobile wireless network and a method of operation
`
`provide directional assistance in response to an Internet query. The directional assistance
`
`is provided from a location of the querying device to a destination that may be selectively
`
`prompted based on whether the destination is a nearby business, a type of business, a street
`
`address, or another mobile device or fixed telephone location. The location of the querying
`
`
`
`
` 2
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`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 3 of 40
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`device is also selectively determined depending on whether the querying device is a
`
`wireless device such as a mobile telephone, or whether the device has a presumed fixed
`
`location, such as an ordinary telephone connected to a public-switched telephone network
`
`(PSTN).
`
`8. The following preliminary exemplary chart provides notice of Traxcell’s allegations of
`
`infringement.
`
`Claim 1
`
`1. A method of
`providing
`navigation
`assistance to a user
`of a
`communications
`device, the method
`comprising:
`
`
`
`
`
`
`
`
`
`receiving, by a
`directional
`assistance service,
`an Internet query
`initiated at the
`communications
`device and
`directed via the
`Internet to initiate
`a request for
`
`
`
`
`Corresponding Structure in Accused Systems
`
`Verizon’s wireless telecommunications network that supports the Apple Maps online
`navigation service together with the Apple Maps (or other navigation/mapping service
`provider) server-side or cloud infrastructure needed to provide the service, constitute the
`“Accused System”.
`
`The term “Apple Maps” encompasses and includes all the versions and variants of the Apple
`Maps web (for PCs, laptops and other computers functioning with macOS or Mac OS X
`operating systems) and the Apple Maps app [Apple Maps app for iOS devices (iPhone, iPad,
`iPod Touch etc.,) and watchOS devices] and the applications supported by the Apple Maps
`Platform.
`
`The “method of providing navigation assistance to a user of a communications device” refers to
`the method by which Apple Maps provides online navigation assistance (directions) to a user of
`a communications device or UE (example: mobile phone, smartphone, laptop, tablet, iPhone,
`iPad, iPod Touch etc.) including the Apple Maps app or including a browser plugin enabling
`access to the Apple Maps website or having other means to access the Apple Maps website, for
`querying and receiving navigation instructions for travelling from a starting location (current
`location of the communications device or a location specified by its user as the ‘origin’) to a
`destination location (a location specified by the said user as the ‘destination’).
`Navigation using Apple Maps online navigation service (or other navigation/mapping service)
`is a well-known example of off-board navigation. To elaborate, an off-board navigation system
`is a client/server system wherein only the user interface (UI) resides on the client’s (user’s)
`communications device and all the databases (GIS and/or mapping) and infrastructure required
`for computation (of route, distance, travel time, traffic etc.) reside remotely on a server or a
`network of servers (the server-side) located on the world wide web (www). The server-side
`could also comprise virtual (instead of physical) or cloud server infrastructure. The client side
`(user interface or UI at a user’s communications device) can only communicate with the server-
`side via the Internet.
`
`
` 3
`
`

`

`Claim 1
`
`navigational
`assistance to a
`destination;
`
`responsive to
`receiving the
`Internet query,
`determining
`whether or not the
`communications
`device is a mobile
`wireless
`communications
`device;
`
`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 4 of 40
`
`Corresponding Structure in Accused Systems
`
`This claim element refers to the method and process involved in initiating a navigation query,
`using Apple Maps online navigation service, to obtain directions (navigation assistance) for
`travelling from a starting location to a destination location. The process involved in initiating
`the said navigation query includes inputting a destination location at the Apple Maps’ user
`interface (UI) at the user’s communications device, and sending the said query via Internet to
`the remote Apple Maps server (cloud server). The said remote Apple Maps server (cloud
`server) receives the said query via Internet.
`
`The term “directional assistance service” herein refers to Apple Maps online navigation service
`supported and facilitated by Verizon’s wireless telecommunications network.
`Apple Maps (or other navigation/mapping service) is is programmed to identify the “phone
`number” and the “device identifiers” of the communications device (UE) at which the said
`navigation query is initiated. In other words, Apple Maps determines whether or not the said
`communications device (UE) is a mobile wireless communications device (UE)
`
`“a mobile wireless communications device” refers to a mobile wireless communications device
`or UE (example: mobile phone, smartphone, laptop, tablet, iPhone, iPad, iPod Touch etc.),
`which includes the Apple Maps app or includes a browser plugin enabling access to the Apple
`Maps website or has other means to access the Apple Maps website for querying and receiving
`navigation instructions for travelling from a starting point (current location of the
`communication’s device or a location specified by its user as the ‘origin’) to a destination
`location (a location specified by the said user as the ‘destination’). The said mobile wireless
`communications device being a subscriber of Verizon’s wireless telecommunications network
`services. Any wireless mobile communications device, which uses Verizon’s Mobile Hotspot
`for connecting to the Internet and includes the Apple Maps app or a browser plugin enabling
`access to the Apple Maps website or has other means to access the Apple Maps website, also
`corresponds to this claim element.
`
`In Attachment 6, Apple’s Privacy Policy document, it is clearly indicated that Apple (which
`includes Apple Maps) collects information such as phone number and device identifiers
`pertaining to the communications device (UE) at which a navigation query is initiated and
`communicated to the Apple Maps server. In other words, Apple Maps has means to
`determine whether a querying communications device (UE) is a mobile wireless
`communications device (UE) or not.
`
`The following is mentioned therein –
`
`“What personal information we collect
`
`When you create an Apple ID, apply for commercial credit, purchase a product, download a
`software update, register for a class at an Apple Retail Store, connect to our services, contact us
`including by social media or participate in an online survey, we may collect a variety of
`information, including your name, mailing address, phone number, email address, contact
`
`
`
`
` 4
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 5 of 40
`
`Claim 1
`
`Corresponding Structure in Accused Systems
`
`preferences, device identifiers, IP address, location information, credit card information and
`profile information where the contact is via social media.”
`
`
`In the aforementioned, it is also mentioned that when a user connects to Apple’s services (like
`Apple Maps online navigation), Apple also collects the IP address from which the said user
`connects to Apple’s services (like Apple Maps online navigation). In other words, when a user
`connects to the Apple Maps server using the client-side UI on his/her communications device
`(UE) via Internet, the Apple Maps server collects the IP address from which the said user
`connects to the Apple Maps server.
`
`Based on the above information, it is confirmed that whenever a communications device uses
`Apple Maps, information such as mobile network information including the name of the carrier
`providing data services to the said communications device are collected by Apple (Apple
`Maps). In other words, Apple Maps can also ascertain whether the communications device
`(UE) at which the said navigation query is initiated, is connected to the Apple Maps server
`through Verizon’s wireless telecommunications network service (i.e. through RF signal-based
`communication) or through a Wi-Fi network supported by a fixed (wired or wireless)
`broadband Internet service.
`
`In summary, Apple Maps has means to determine whether a querying communications device
`(UE) is a mobile wireless communications device (UE) or not, and also whether the said
`communications device (UE) is connected to the Apple Maps server through Verizon’s wireless
`telecommunications network service (i.e. through RF signal-based communication) or through
`a Wi-Fi network supported by a fixed (wired or wireless) broadband Internet service.
`If the Apple Maps online navigation service (or other navigation/mapping service) is
`determines that the said navigation query has been initiated at a mobile wireless
`communications device (UE), and that the said query was communicated through Verizon’s
`wireless telecommunications network service (i.e. through RF signal-based communication),
`Apple Maps determines current location of the mobile wireless communications device (UE)
`and uses it as the starting point for providing navigation information (instructions or directions)
`to travel to the destination input by the user of the said communications device (UE).
`
`The “the mobile wireless communications device” or the “communications device” refers to the
`mobile wireless communications device or UE (example: mobile phone, smartphone, laptop,
`tablet, iPhone, iPad, iPod Touch etc.) at which the navigation query was initiated.
`
` user can simply input a “destination” entry and initiate a navigation query on the Apple
`Maps’ client-side user interface (UI) at the user’s mobile wireless communications device
`(Apple Maps app on an iPhone). The Apple Maps server, upon receiving the navigation query
`(including input “destination”) from the client-side via Internet, determines the “current
`location” of the user’s mobile wireless communications device, uses it as the default starting
`point, ascertains the location of the input “destination”, computes or calculates the route(s) and
`
` A
`
` 5
`
`responsive to
`determining that
`the
`communications
`device is the
`mobile wireless
`communications
`device, the
`directional
`assistance service
`determining and
`using a present
`location of the
`mobile wireless
`communications
`device as a
`location of the
`
`
`
`
`

`

`Claim 1
`
`communications
`device;
`
`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 6 of 40
`
`Corresponding Structure in Accused Systems
`
`directions, and downloads the computed or calculated route(s) and directions to the user’s
`mobile wireless communications device.
`
`As has been mentioned with reference to the previous claim element, Apple Maps, upon
`receiving a navigation query from a user’s communications device, determines whether or not
`the said communications device is a mobile wireless communications device.
`
`It is clearly indicated in Attachment 47, that a user can simply input a “destination” entry and
`initiate a navigation query on the Apple Maps’ client-side user interface (UI) at the user’s
`mobile wireless communications device (Apple Maps app on iPhone, iPad or iPod Touch). The
`Apple Maps server, upon receiving the navigation query (including input “destination”) from
`the client-side via Internet, determines the “current location” of the user’s mobile wireless
`communications device, uses it as the default starting point, ascertains the location of the input
`“destination”, computes or calculates the route(s) and directions, and downloads the computed
`or calculated route(s) and directions to the user’s mobile wireless communications device. The
`following is mentioned therein –
`
`“Get directions
`
`1. Open Maps and enter your destination in the Search bar.
`
`2. Tap Directions.
`
`3. Choose Drive, Walk, Transit, or Ride.
`
`4. Select the route that you prefer. Maps shows the fastest route first based on traffic conditions.
`
`5. When you're ready, tap “GO”. To see an overview of your route, tap "Tap for Overview" in
`the banner.
`
`6. To end navigation, tap “End”, in the bottom right corner. Then tap End Route. You can also
`ask Siri to "Stop Navigating" when you have Hands-Free turned on.”
`
`responsive to
`determining that
`the
`communications
`device is not the
`mobile wireless
`communications
`device, obtaining a
`fixed location
`
`As mentioned previously, Apple Maps (or other navigation/mapping service) is programmed to
`identify the “phone number” and the “device identifiers” of the communications device (UE)]
`at which the said navigation query is initiated, and also to ascertain the IP address from where
`the communications device (UE) at which the said navigation query is initiated connected to the
`Apple Maps server.
`
`In other words, Apple Maps has means to determine whether a querying communications
`device (UE) is a mobile wireless communications device (UE) or not, and also whether the said
`communications device (UE) is connected to the Apple Maps server through Verizon’s wireless
`telecommunications network service (i.e. through RF signal-based communication) or through
`a Wi-Fi network supported by a fixed (wired or wireless) broadband Internet service.
`
`
`
`
` 6
`
`

`

`Claim 1
`
`associated with the
`communications
`device to
`determine the
`location of the
`communications
`device; and
`
`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 7 of 40
`
`Corresponding Structure in Accused Systems
`
`
`In Attachment 6, Apple’s Privacy Policy document, it is clearly indicated that Apple (which
`includes Apple Maps) collects information such as phone number and device identifiers
`pertaining to the communications device (UE) at which a navigation query is initiated and
`communicated to the Apple Maps server. In other words, Apple Maps has means to
`determine whether a querying communications device (UE) is a mobile wireless
`communications device (UE) or not.
`
`The following is mentioned therein –
`
`“What personal information we collect
`
`When you create an Apple ID, apply for commercial credit, purchase a product, download a
`software update, register for a class at an Apple Retail Store, connect to our services, contact us
`including by social media or participate in an online survey, we may collect a variety of
`information, including your name, mailing address, phone number, email address, contact
`preferences, device identifiers, IP address, location information, credit card information and
`profile information where the contact is via social media.”
`
`
`In the aforementioned, it is also mentioned that when a user connects to Apple’s services (like
`Apple Maps online navigation), Apple also collects the IP address from which the said user
`connects to Apple’s services (like Apple Maps online navigation). In other words, when a user
`connects to the Apple Maps server using the client-side UI on his/her communications device
`(UE) via Internet, the Apple Maps server collects the IP address from which the said user
`connects to the Apple Maps server.
`
`Based on the above information, it is confirmed that whenever a communications device uses
`Apple Maps (or other navigation/mapping service), information such as mobile network
`information including the name of the carrier providing data services to the said
`communications device are collected by Apple (Apple Maps). In other words, Apple Maps can
`also ascertain whether the communications device (UE) at which the said navigation query is
`initiated, is connected to the Apple Maps server through Verizon’s wireless
`telecommunications network service (i.e. through RF signal-based communication) or through
`a Wi-Fi network supported by a fixed (wired or wireless) broadband Internet service.
`
`In summary, Apple Maps has means to determine whether a querying communications device
`(UE) is a mobile wireless communications device (UE) or not, and also whether the said
`communications device (UE) is connected to the Apple Maps server through Verizon’s wireless
`telecommunications network service (i.e. through RF signal-based communication) or through
`a Wi-Fi network supported by a fixed (wired or wireless) broadband Internet service.
`
`If Apple Maps determines that the communications device (UE) at which the said navigation
`query is initiated is not a mobile wireless communications device, or in other words, if the said
`
`
`
`
` 7
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 8 of 40
`
`Claim 1
`
`Corresponding Structure in Accused Systems
`
`communications device (UE) is determined to be a stationary or fixed communications device,
`for example – a Mobile phone, smartphone, iPhone, iPad, iPod Touch, laptop or tablet
`connected or tethered to a Wi-Fi (internet) access point, modem, router or Wi-Fi hotspot
`supported by a fixed (wired or wireless) broadband Internet Service, Apple Maps determines
`the location of the said stationary or fixed communications device by identifying the Internet
`Service Provider or Wi-Fi hotspot serving the said communications device and obtaining the
`stationary location of the said Wi-Fi (internet) access point, modem, router or hotspot from a
`Wi-Fi database, Wi-Fi location database or Wi-Fi hotspot database.
`“Additionally, some cell phones, are designed to be able to connect to the Internet via a cellular
`broadband network and/or via Wi‐Fi network (aka a local wireless Internet access point). If a
`cell phone connects via a Wi‐Fi network, that connection can also disclose more or less precise
`information about a cell phone’s location depending upon how the Internet Service Provider
`provides the wireless Internet connection. Some cell phones also keep a temporary file of
`nearby cell phone towers and Wi‐Fi hotspots (places that offer local wireless Internet access), to
`potentially make the cell phone user’s connectivity more efficient.”
`
`In response to receiving the navigation query (which includes the “destination” entry input by
`the user at the Apple Maps client-side user interface or UI residing at the user’s
`communications device) initiated at the communications device (UE) and directed via the
`Internet, Apple Maps server determines the current location of the querying (the user’s)
`communications device, considers it the default starting point, ascertains the location of the
`input “destination”, computes and provides the navigation information (directions) to the said
`communications device (UE) to travel from the current location of said communications device
`(UE) to the input destination.
`
` user can simply input a “destination” entry and initiate a navigation query on the Apple
`Maps’ client-side user interface (UI) at the user’s mobile wireless communications device
`(Apple Maps app on iPhone, iPad or iPod Touch). The Apple Maps server, upon receiving the
`navigation query (including input “destination”) from the client-side via Internet, determines
`the “current location” of the user’s mobile wireless communications device, uses it as the
`default starting point, ascertains the location of the input “destination”, computes or calculates
`the route(s) and directions, and downloads the computed or calculated route(s) and directions to
`the user’s mobile wireless communications device. In this manner, Apple Maps provides the
`navigation information (directions) to the said communications device (UE) to travel from the
`current location of said communications device (UE) to the input destination.
`
` A
`
`the directional
`assistance service
`providing
`navigation
`information to the
`communications
`device in response
`to the Internet
`query, wherein the
`navigation
`provides directions
`for proceeding
`from the location
`of the
`communications
`device to a
`location of the
`destination.
`
`The following is mentioned therein –
`
`“Get directions
`
`1. Open Maps and enter your destination in the Search bar.
`
`
`
`
` 8
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 9 of 40
`
`Claim 1
`
`Corresponding Structure in Accused Systems
`
`2. Tap Directions.
`
`3. Choose Drive, Walk, Transit, or Ride.
`
`4. Select the route that you prefer. Maps shows the fastest route first based on traffic conditions.
`
`5. When you're ready, tap “GO”. To see an overview of your route, tap "Tap for Overview" in
`the banner.
`
`6. To end navigation, tap “End”, in the bottom right corner. Then tap End Route. You can also
`ask Siri to "Stop Navigating" when you have Hands-Free turned on.”
`
`
`
`
`
`
`9. Defendant makes, uses, offers to sell, and/or sells within or imports into the U.S. wireless
`
`networks, wireless-network components, and related services that use identified locations
`
`of wireless devices to provide directional assistance such that Defendant infringes claims
`
`1–30 of the ’196 patent, literally or under the doctrine of equivalents.
`
`
`10. Defendant put the inventions claimed by the ’196 Patent into service (i.e., used them); but
`
`for Defendant’s actions, the claimed-inventions embodiments involving Defendant’s
`
`products and services would never have been put into service. Defendant’s acts
`
`complained of herein caused those claimed-invention embodiments as a whole to perform,
`
`and Defendant obtaining monetary and commercial benefit from it.
`
`11. Defendant has and continues to induce infringement. Defendants have actively encouraged
`
`or instructed others (e.g., its customers), and continues to do so, on how to use its products
`
`and services (e.g., U.S. wireless networks, wireless-network components that use identified
`
`locations of wireless devices to provide directional assistance) such to cause infringement
`
`claims 1–30 of the ’196 patent, literally or under the doctrine of equivalents. Moreover,
`
`Defendant has known and should have known of the ’196 patent, by at least by the date of
`
` 9
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 10 of 40
`
`the patent’s issuance, or from the issuance of the ‘284 patent, which followed the date that
`
`the patent’s underlying application was cited to Defendants by the U.S. Patent and
`
`Trademark Office during prosecution of one of Defendant’s patent applications, such that
`
`Defendant knew and should have known that it was and would be inducing infringement.
`
`12. Defendant has and continues to contributorily infringe. Defendant has actively encouraged
`
`or instructed others (e.g., its customers and/or the customers of its related companies), and
`
`continues to do so, on how to use its products and services e.g., U.S. wireless networks,
`
`wireless-network components that use identified locations of wireless devices to provide
`
`directional assistance) such as to cause infringement of one or more of claims 1–30 of the
`
`’196 patent, literally or under the doctrine of equivalents. Moreover, Defendant has known
`
`of the ’196 patent and the technology underlying it from at least the date of issuance of the
`
`patent or from the issuance of the ‘284 patent, which followed the date that the patent’s
`
`underlying application was cited to Defendants by the U.S. Patent and Trademark Office
`
`during prosecution of one of Defendant’s patent applications, such that Defendant knew
`
`and should have known that it was and would be contributorily infringing.
`
`13. Defendants have caused and will continue to cause Traxcell damage by infringing the ’196
`
`patent.
`
`IV. INFRINGEMENT (‘175 Patent (attached as Exhibit B))
`
`14. On August 20, 2019, U.S. Patent No. 10,390,175 (“the ‘175 patent”), attached as Exhibit
`
`B, entitled “Mobile wireless device tracking and notification system” was duly and legally
`
`issued by the U.S. Patent and Trademark Office. Traxcell owns the ’175 patent by
`
`assignment.
`
`
`
`
` 10
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 11 of 40
`
`15. The ’175 Patent’s Abstract states, “A mobile wireless network and a method of operation
`
`provide tracking of mobile devices either in a passive mode or an active mode. In the
`
`passive mode, fault detection triggers generation of a case file associated with the device
`
`experiencing the fault. In the active mode, a user of the system can specify tracking mobile
`
`devices by sector or one or more mobile devices by identifier. Notifications can be
`
`generated in response to detection of a fault, or when a device enters a predetermined
`
`geographic region.”
`
`16. The following preliminary exemplary chat provides Traxcell’s allegations of infringement.
`
`Exemplary Claim
`
`A system including:
`
`
`
`Corresponding Structure in Accused Systems
`
`
`
`at least one radio-
`frequency
`transceiver and an
`associated at least
`one antenna to
`which the at least
`one radio-
`frequency
`transceiver is
`coupled,
`
`Plaintiff contends that the Verizon network use base stations. Base stations include at
`least one radio-frequency transceiver designed and used in association with at least
`one antenna. When base-station transceivers and antennas are in communication, they
`are coupled. Further, in addition to being so coupled, the transceivers and antenna are
`also, by placement within a base station, physically coupled.
`
`The following exemplifies this limitation’s existence in Accused Systems:
`
`
`
`
`
`
`
`
`
`
` 11
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 12 of 40
`
`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`
`
`
`
`Plaintiff contends each base station has a RF transceiver whose parameters have been
`configured for RF communication with mobile wireless communications devices.
`
`
`
`Please note that Verizon uses three types of self-organizing network technology, that
`is, C-SON, D-SON and V-SON and uses network equipment or solutions supplied
`from vendors, for example, from Ericsson, etc. In addition to RAN vendor and third-
`party supplied SON features, Verizon has also developed its own proprietary SON
`implementation, known as V-SON.
`
`Plaintiff contends that a system of computers including Operations Support System
`(OSS or OSS-RC) of Verizon Wireless’ wireless telecommunications network,
`
` 12
`
`wherein the at least
`one radio-
`frequency
`transceiver is
`configured for
`radio-frequency
`communication
`with at least one
`mobile wireless
`communications
`device; and
`
`
`
`a system of
`computers coupled
`to the at least one
`radio-frequency
`transceiver
`programmed to
`locate the at least
`one mobile
`
`
`
`
`

`

`Case 6:20-cv-01175 Document 1 Filed 12/21/20 Page 13 of 40
`
`Exemplary Claim
`
`wireless
`communications
`device and acquire
`an indication of a
`location of the at
`least one mobile
`wireless
`communications
`device,
`
`
`
`
`
`
`
`Corresponding Structure in Accused Systems
`
`Ericsson’s SON solution [which includes SON Optimization Manager, SON Policy
`Manager, SON Visualization, etc. and the software programs that run them]
`interfaced or integrated with said Operations Support System (OSS or OSS-RC), and
`a set or network of computers [which include Trace Processing Server (TPS), OSS
`Data Gateway, RAN Analyzer, RAN Configuration Manager, Frequency Optimizer,
`Cell Optimizer, Network Capacity Planner and Implementation Server] operating,
`implementing and supporting the Ericsson’s SON solution in Verizon Wireless’ said
`wireless telecommunications network, constituting the “system of computers,”
`corresponds to this claim limitation, as the SON Optimization Manager ascertains the
`location information of UEs from MDT (Minimization of Drive Tests) reports, UE
`Measurement Reports, CTR (Cell Traffic Recordings), UETR (UE Traffic
`Recording), etc. received or collected in the form of PM and Trace data.
`
`Further, Ericsson’s SON solution includes SON Optimization Manager (SON OM),
`SON Policy Manager, SON Visualization, etc. Ericsson SON Suite includes the
`software programs that run the Ericsson’s SON solution. The system of computers
`supporting the Ericsson’s SON solution include Verizon Wireless’ wireless
`telecommunications network’s Operations Support System (OSS or OSS-RC), Trace
`Processing Server (TPS), OSS Data Gateway, RAN Analyzer, RAN Configuration
`Manager, Frequency Optimizer, Cell Optimizer, Network Capacity Planner and
`Implementation Server. (Please note that Ericsson SON Optimization Manager
`together with Ericsson Network Manager and Network IQ delivers the full suite.)
`
`Also, Ericsson’s SON solution is integrated/interfaced with the client wireless
`network’s (in the present case, Verizon Wireless’) Operations Support System (OSS
`or OSS-RC) and other systems in the OAM (Operations, Administration and
`Management) level of the network architecture. The client MNO’s (Verizon
`Wireless’) wireless network’s Operations Support System (OSS or OSS-RC) is
`communicatively connected to the Radio Access Network (RAN) portion of the client
`MNO’s (Verizon Wireless’) wireless network. The said Radio Access Network
`(RAN) includes base stations (NodeBs, eNodeBs, RBSetc.). Thus, Ericsson’s SON
`solution is communicatively connected to the base stations (NodeBs, eNodeBs, RBS
`etc.) in the Radio Access Network (RAN) portion of the client MNO’s (Verizon
`Wireless’) wireless network. The system is coupled to these base station(s)
`communicatively and in some Accused Systems structurally by system-architecture
`structure (e.g., wire) to locate one or more mobile wireless communications devices
`and generate or acquire an indication of locations of those device