IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

INNOVATIO IP VENTURES, LLC, 

Plaintiff, 

v. 

DELTA AIR LINES, INC., 

Defendant. 

Case No. 12-cv-3858 

JURY TRIAL DEMANDED 

 

COMPLAINT FOR PATENT INFRINGEMENT

 For its original complaint for patent infringement, Plaintiff Innovatio IP Ventures, LLC 

(“Innovatio”), by and through its undersigned counsel, alleges as follows: 

THE PARTIES

1. Plaintiff Innovatio is a limited liability company organized under the laws of the 

State of Delaware with a place of business at 22 West Washington Street, Suite 1500, Chicago, 

Illinois 60602. 

2. On information and belief, Defendant Delta Air Lines, Inc. (“Delta Air”) is a 

corporation organized under the laws of the State of Delaware, has a principal place of business 

at Post Office Box 20706, Atlanta, Georgia 30320, and does substantial business within this 

District, including operating airplanes that frequently travel within this District, including 

through O’Hare and Midway airports. 

JURISDICTION AND VENUE 

3. This action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et 

seq. This Court has jurisdiction over the subject matter of this action under 28 U.S.C. §§ 1331 

and 1338(a). 

4. This Court has personal jurisdiction over Defendant. 

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5. Venue for this action is proper in this district pursuant to 28 U.S.C. §§ 1391 and 

1400(b). 

PATENTS-IN-SUIT 

6. On March 30, 2004, the United States Patent and Trademark Office (“the 

USPTO”) duly and legally issued U.S. Patent No. 6,714,559 (“the ‘559 Patent”) titled 

“Redundant Radio Frequency Network Having A Roaming Terminal Communication Protocol.” 

A copy of the ‘559 Patent is attached as Exhibit A. 

7. On June 10, 2008, the USPTO duly and legally issued U.S. Patent No. 7,386,002 

(“the ‘002 Patent”) titled “Redundant Radio Frequency Network Having A Roaming Terminal 

Communication Protocol.” A copy of the ‘002 Patent is attached as Exhibit B. 

8. On May 19, 2009, the USPTO duly and legally issued U.S. Patent No. 7,535,921 

(“the ‘921 Patent”) titled “Redundant Radio Frequency Network Having A Roaming Terminal 

Communication Protocol.” A copy of the ‘921 Patent is attached as Exhibit C. 

9. On June 16, 2009, the USPTO duly and legally issued U.S. Patent No. 7,548,553 

(“the ‘553 Patent”) titled “Redundant Radio Frequency Network Having A Roaming Terminal 

Communication Protocol.” A copy of the ‘553 Patent is attached as Exhibit D. 

10. On April 14, 1998, the USPTO duly and legally issued U.S. Patent No. 5,740,366 

(“the ‘366 Patent”) titled “Communication Network Having Plurality Of Bridging Nodes Which 

Transmit A Beacon To Terminal Nodes In Power Saving State That It Has Messages Awaiting 

Delivery.” A copy of the ‘366 Patent is attached as Exhibit E. 

11. On August 17, 1999, the USPTO duly and legally issued U.S. Patent No. 

5,940,771 (“the ‘771 Patent”) titled “Network Supporting Roaming, Sleeping Terminals.” A 

copy of the ‘771 Patent is attached as Exhibit F. 

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12. On April 16, 2002, the USPTO duly and legally issued U.S. Patent No. 6,374,311 

(“the ‘311 Patent”) titled “Communication Network Having A Plurality Of Bridging Nodes 

Which Transmit A Beacon To Terminal Nodes In Power Saving State That It Has Messages 

Awaiting Delivery.” A copy of the ‘311 Patent is attached as Exhibit G. 

13. On November 25, 2008, the USPTO duly and legally issued U.S. Patent No. 

7,457,646 (“the ‘646 Patent”) titled “Radio Frequency Local Area Network.” A copy of the ‘646 

Patent is attached as Exhibit H. 

14. On August 13, 1996, the United States Patent and Trademark Office (“USPTO”) 

duly and legally issued U.S. Patent No. 5,546,397 (“the ‘397 Patent”) titled “High Reliability 

Access Point For Wireless Local Area Network.” A copy of the ‘397 Patent is attached as 

Exhibit I. 

15. On December 1, 1998, the USPTO duly and legally issued U.S. Patent No. 

5,844,893 (“the ‘893 Patent”) titled “System For Coupling Host Computer Means With Base 

Transceiver Units On A Local Area Network.” A copy of the ‘893 Patent is attached as Exhibit J. 

16. On December 16, 2003, the USPTO duly and legally issued U.S. Patent No. 

6,665,536 (“the ‘536 Patent”) titled “Local Area Network Having Multiple Channel Wireless 

Access.” A copy of the ‘536 Patent is attached as Exhibit K. 

17. On February 24, 2004, the USPTO duly and legally issued U.S. Patent No. 

6,697,415 (“the ‘415 Patent”) titled “Spread Spectrum Transceiver Module Utilizing Multiple 

Mode Transmission.” A copy of the ‘415 Patent is attached as Exhibit L. 

18. On March 14, 2006, the USPTO duly and legally issued U.S. Patent No. 

7,013,138 (“the ‘138 Patent”) titled “Local Area Network Having Multiple Channel Wireless 

Access.” A copy of the ‘138 Patent is attached as Exhibit M. 

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19. On May 4, 2010, the USPTO duly and legally issued U.S. Patent No. 7,710,907 

(“the ‘907 Patent”) titled “Local Area Network Having Multiple Channel Wireless Access.” A 

copy of the ‘907 Patent is attached as Exhibit N. 

20. On March 29, 2011, the USPTO duly and legally issued U.S. Patent No. 

7,916,747 (“the ‘747 Patent”) titled “Redundant Radio Frequency Network Having A Roaming 

Terminal Communication Protocol.” A copy of the ‘747 Patent is attached as Exhibit O. 

21. On January 18, 2011, the USPTO duly and legally issued U.S. Patent No. 

7,873,343 (“the ‘343 Patent”) titled “Communication Network Terminal With Sleep Capability.” 

A copy of the ‘343 Patent is attached as Exhibit P. 

22. On May 19, 2009, the USPTO duly and legally issued U.S. Patent No. 7,536,167 

(“the ‘167 Patent”) titled “Network Supporting Roaming, Sleeping Terminals.” A copy of the 

‘167 Patent is attached as Exhibit Q. The seventeen patents identified in paragraphs 6-22 are 

hereinafter referred to collectively as the “WLAN Patents.” 

23. Innovatio owns all rights, title, and interest in and to, and has standing to sue for 

infringement of, the WLAN Patents, including the right to sue for and collect past damages. 

DEFENDANT’S KNOWLEDGE OF THE WLAN PATENTS

24. Defendant Delta Air has been aware and on actual notice of the WLAN Patents 

since on or about December 23, 2011, when Innovatio wrote to Delta Air and provided it with 

actual notice of its infringement of the WLAN Patents. 

COUNT ONE 

INFRINGEMENT OF THE ‘559 PATENT 

25. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

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26. Defendant has infringed and continues to infringe one or more claims of the ‘559 

Patent in violation of 35 U.S.C. § 271(a) by using throughout the United States, including in this 

judicial district, WLAN products to provide wireless network access to their customers, 

employees, and/or the public, and/or in their business operations, where such WLAN products 

practice the methods of, by way of example and not limitation, at least claims 6, 7, and 8 of the 

‘559 Patent. 

COUNT TWO 

INFRINGEMENT OF THE ‘002 PATENT 

27. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

28. Defendant has infringed and continues to infringe one or more claims of the ‘002 

Patent in violation of 35 U.S.C. § 271(a) by using throughout the United States, including in this 

judicial district, WLAN products to provide wireless network access to their customers, 

employees, and/or the public, and/or in their business operations, where such WLAN products 

practice the methods of, by way of example and not limitation, at least claims 14-16, 18, and 19 

of the ‘002 Patent. 

COUNT THREE 

INFRINGEMENT OF THE ‘921 PATENT 

29. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

30. Defendant has infringed and continues to infringe one or more claims of the ‘921 

Patent in violation of 35 U.S.C. § 271(a) by using throughout the United States, including in this 

judicial district, WLAN products to provide wireless network access to their customers, 

employees, and/or the public, and/or in their business operations, where such WLAN products 

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practice the methods of, by way of example and not limitation, at least claims 1, 2, 5, 7, and 8 of 

the ‘921 Patent. 

COUNT FOUR 

INFRINGEMENT OF THE ‘553 PATENT 

31. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

32. Defendant has infringed and continues to infringe one or more claims of the ‘553 

Patent in violation of 35 U.S.C. § 271(a) by using throughout the United States, including in this 

judicial district, WLAN products to provide wireless network access to their customers, 

employees, and/or the public, and/or in their business operations, where such WLAN products 

practice the methods of, by way of example and not limitation, at least claims 10-12, 17, 19, and 

20 of the ‘553 Patent. 

COUNT FIVE 

INFRINGEMENT OF THE ‘366 PATENT 

33. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

34. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘366 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLANs to provide wireless network access to their 

customers, employees, and/or the public, and/or in their business operations, where such WLANs 

infringe, by way of example and not limitation, at least claims 5-7, 9-17, 19-24, 26-29, and 32 of 

the ‘366 Patent. 

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35. Plaintiff further believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has, with specific knowledge of the ‘366 Patent, 

induced and contributed to the direct infringement by others of one or more claims of the ‘366 

Patent in violation of 35 U.S.C. §§ 271(b) and (c) by making available to Defendant’s customers, 

employees, and or the public throughout the United States, including in this judicial district, 

WLANs, where such customers, employees, and/or the public cause the systems of, by way of 

example and not limitation, at least claims 5-7, 9-17, 19-24, 26-29, and 32 of the ‘366 Patent as a 

whole to perform the claimed processing of such systems, and where such customers, employees, 

and/or the public obtain the benefit of, and directly infringe by, using the claimed systems. 

COUNT SIX 

INFRINGEMENT OF THE ‘771 PATENT 

36. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

37. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘771 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLANs to provide wireless network access to their 

customers, employees, and/or the public, and/or in their business operations, where such WLANs 

infringe, by way of example and not limitation, at least claims 1-7 of the ‘771 Patent. 

38. Plaintiff further believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has, with specific knowledge of the ‘771 Patent, 

induced and contributed to the direct infringement by others of one or more claims of the ‘771 

Patent in violation of 35 U.S.C. §§ 271(b) and (c) by making available to Defendant’s customers, 

employees, and or the public throughout the United States, including in this judicial district, 

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WLANs, where such customers, employees, and/or the public cause the systems of, by way of 

example and not limitation, at least claims 1-7 of the ‘771 Patent as a whole to perform the 

claimed processing of such systems, and where such customers, employees, and/or the public 

obtain the benefit of, and directly infringe by, using the claimed systems. 

COUNT SEVEN 

INFRINGEMENT OF THE ‘311 PATENT 

39. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

40. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘311 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLANs to provide wireless network access to their 

customers, employees, and/or the public, and/or in their business operations, where such WLANs 

infringe, by way of example and not limitation, at least claims 20-24, 26-30, 32-37, 39-41, 43-51, 

53-56, 60, and 64 of the ‘311 Patent. 

41. Plaintiff further believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has, with specific knowledge of the ‘311 Patent, 

induced and contributed to the direct infringement by others of one or more claims of the ‘311 

Patent in violation of 35 U.S.C. §§ 271(b) and (c) by making available to Defendant’s customers, 

employees, and or the public throughout the United States, including in this judicial district, 

WLANs, where such customers, employees, and/or the public cause the systems of, by way of 

example and not limitation, at least claims 20-24, 26-30, 32-37, 39-41, 43-51, 53-56, 60, and 64 

of the ‘311 Patent as a whole to perform the claimed processing of such systems, and where such 

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customers, employees, and/or the public obtain the benefit of, and directly infringe by, using the 

claimed systems. 

COUNT EIGHT 

INFRINGEMENT OF THE ‘646 PATENT 

42. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

43. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘646 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products practice the methods of, by way of example and not limitation, at least claims 

14-17, 19-22, 26-35, 39-40, 43-45, 47, 49-51, 53-56, 59-64, 66-69, 71-73, 79, 82-89, 91-94, 98-

104, 107, 108, 111, 112, 114-123, 125-128, 130, 135-137, 143, and 144 of the ‘646 Patent. 

COUNT NINE 

INFRINGEMENT OF THE ‘397 PATENT 

44. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

45. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘397 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

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WLAN products infringe, by way of example and not limitation, at least claims 1-5 of the ‘397 

Patent. 

COUNT TEN 

INFRINGEMENT OF THE ‘893 PATENT 

46. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

47. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘893 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLANs to provide wireless network access to their 

customers, employees, and/or the public, and/or in their business operations, where such WLANs 

infringe, by way of example and not limitation, at least claims 7-11 of the ‘893 Patent. 

48. Plaintiff further believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has, with specific knowledge of the ‘893 Patent, 

induced and contributed to the direct infringement by others of one or more claims of the ‘893 

Patent in violation of 35 U.S.C. §§ 271(b) and (c) by making available to Defendant’s customers, 

employees, and or the public throughout the United States, including in this judicial district, 

WLANs, where such customers, employees, and/or the public cause the systems of, by way of 

example and not limitation, at least claims 7-11 of the ‘893 Patent as a whole to perform the 

claimed processing of such systems, and where such customers, employees, and/or the public 

obtain the benefit of, and directly infringe by, using the claimed systems. 

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COUNT ELEVEN 

INFRINGEMENT OF THE ‘536 PATENT 

49. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

50. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘536 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products infringe, by way of example and not limitation, at least claims 1, 5, 8, 10, 11, 

13-17, 19, 20, and 49 of the ‘536 Patent. 

51. Plaintiff further believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has, with specific knowledge of the ‘536 Patent, 

induced and contributed to the direct infringement by others of one or more claims of the ‘536 

Patent in violation of 35 U.S.C. §§ 271(b) and (c) by making available to Defendant’s customers, 

employees, and or the public throughout the United States, including in this judicial district, 

WLANs, where such customers, employees, and/or the public cause the systems of, by way of 

example and not limitation, at least claims 20 and 49 of the ‘536 Patent as a whole to perform the 

claimed processing of such systems, and where such customers, employees, and/or the public 

obtain the benefit of, and directly infringe by, using the claimed systems. 

COUNT TWELVE 

INFRINGEMENT OF THE ‘415 PATENT 

52. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

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53. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘415 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products infringe, by way of example and not limitation, at least claims 11, 12, and 15 of 

the ‘415 Patent. 

COUNT THIRTEEN 

INFRINGEMENT OF THE ‘138 PATENT 

54. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

55. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘138 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products infringe, by way of example and not limitation, at least claims 1, 5, 8, 10, 11, 

13-15, 17, 18, 21, 24, 26, 28, and 36 of the ‘138 Patent. 

56. Plaintiff further believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has, with specific knowledge of the ‘138 Patent, 

induced and contributed to the direct infringement by others of one or more claims of the ‘138 

Patent in violation of 35 U.S.C. §§ 271(b) and (c) by making available to Defendant’s customers, 

employees, and or the public throughout the United States, including in this judicial district, 

WLANs, where such customers, employees, and/or the public cause the systems of, by way of 

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example and not limitation, at least claims 15, 17, 18, 21, 24, 26, 28, and 36 of the ‘138 Patent as 

a whole to perform the claimed processing of such systems, and where such customers, 

employees, and/or the public obtain the benefit of, and directly infringe by, using the claimed 

systems. 

COUNT FOURTEEN 

INFRINGEMENT OF THE ‘907 PATENT 

57. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

58. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘907 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products infringe, by way of example and not limitation, at least claims 1, 7, 10, 12, 13, 

15-17, 20, 21, 23, 24, 30, 33, 35, 36, 38, 39, 40, 43, 44, and 46-50 of the ‘907 Patent. 

COUNT FIFTEEN 

INFRINGEMENT OF THE ‘747 PATENT 

59. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

60. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘747 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

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WLAN products infringe, by way of example and not limitation, at least claims 1-3, 5-8, 11, 13, 

16, 17, and 20-25 of the ‘747 Patent. 

COUNT SIXTEEN 

INFRINGEMENT OF THE ‘343 PATENT 

61. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

62. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘343 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products infringe, by way of example and not limitation, at least claims 1-6, 8-12, 15-20, 

22, 23, 25, 28-30, 31-36, 38-42, 45-50, 52, 53, 55, and 58-60 of the ‘343 Patent. 

COUNT SEVENTEEN 

INFRINGEMENT OF THE ‘167 PATENT 

63. Innovatio repeats and realleges the allegations of the preceding paragraphs 1-24 

as if fully set forth herein. 

64. Plaintiff believes that a reasonable opportunity for further investigation or 

discovery will likely show that Defendant has infringed and continues to infringe one or more 

claims of the ‘167 Patent in violation of 35 U.S.C. § 271(a) by using throughout the United 

States, including in this judicial district, WLAN products to provide wireless network access to 

their customers, employees, and/or the public, and/or in their business operations, where such 

WLAN products practice the methods of, by way of example and not limitation, at least claims 

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73-77, 79-83, 85, 89-97, 100, 102-107, 109-113, 115, 119-127, 130, 132-134, and 203 of the 

‘167 Patent. 

PRAYER FOR RELIEF 

 WHEREFORE, Innovatio respectfully requests entry of judgment in its favor and the 

following relief, including: 

 A. That Defendant be adjudged to have infringed one or more claims of each of the 

WLAN Patents; 

B. That Defendant and all related entities and their officers, agents, employees, 

representatives, servants, successors, assigns and all persons in active concert or participation 

with any of them, directly or indirectly, be preliminarily and permanently enjoined from using, 

or contributing or inducing the use of, any WLAN product, system or network that infringes any 

WLAN Patent; 

 C. That Defendant account for damages sustained by Innovatio as a result of 

Defendant’s infringement of the WLAN Patents, including both pre- and post-judgment interest 

and costs as fixed by this Court under 35 U.S.C. § 284; 

D. That the Court award Innovatio its costs, expenses, and attorneys’ fees pursuant to 

at least 35 U.S.C. § 285; and 

 D. That the Court grant Innovatio such other and further relief as the Court may 

deem just and proper. 

JURY DEMAND

 Innovatio demands a trial by jury on all issues so triable. 

 

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Respectfully submitted, 

Dated: May 18, 2012 /s/ Matthew G. McAndrews 

Matthew G. McAndrews 

Raymond P. Niro, Jr. 

Brian E. Haan 

Gabriel I. Opatken 

NIRO, HALLER & NIRO 

181 West Madison St., Suite 4600 

Chicago, Illinois 60602 

Telephone: (312) 236-0733 

Facsimile: (312) 236-3137 

E-mail: rnirojr@nshn.com 

E-mail: mmcandrews@nshn.com

E-mail: bhaan@nshn.com 

E-mail: gopatken@nshn.com 

Attorneys for Plaintiff,

INNOVATIO IP VENTURES, LLC 

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