UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

TERRESTRIAL COMMS LLC, 

 Plaintiff 

 v. 

PERIXX COMPUTER GMBH, 

 Defendants 

Case No. 6:20-cv-00105 

JURY TRIAL DEMANDED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Terrestrial Comms LLC (“Plaintiff” or “Terrestrial”) hereby asserts the 

following claims for patent infringement against Defendant Perixx Computer GmbH 

(“Defendant” or “Perixx”), and alleges, on information and belief, as follows: 

THE PARTIES 

1. Terrestrial is a limited liability company organized and existing under the laws of 

the Texas with its principal place of business at 17330 Preston Road, Suite 200D, Dallas, 

Texas 75252. 

2. On information and belief, Defendant Perixx Computer GmbH is a Gesellschaft 

mit beschränkter Haftung (a form of limited liability company) organized under the laws 

of Germany. It has a principal place of business at Heerdter Landstrasse 189e, 40549 

Dusseldorf, Germany. Perixx Computer GmbH can be served at this principal place of 

business. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 1 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 2 

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 subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a). 

4. Defendant has committed acts of infringement in this judicial district. 

5. On information and belief, the Court has personal jurisdiction over Defendant 

because Defendant has committed, and continues to commit, acts of infringement in the 

state of Texas, has conducted business in the state of Texas, and/or has engaged in 

continuous and systematic activities in the state of Texas. 

6. On information and belief, Defendant’s instrumentalities that are alleged herein 

to infringe were and continue to be used, imported, offered for sale, and/or sold in the 

Western District of Texas. 

7. Venue is proper in the Western District of Texas pursuant to 28 U.S.C. § 1400(b). 

ACUSED PRODUCTS 

8. Upon information and belief, Defendant makes, uses, imports, sells, and/or offers 

for sale the Perixx Wireless Ergonomic Split Keyboard and Vertical Mouse Combo, 

(collectively the “Accused Products”). 

9. Upon information and belief, Defendant Perixx encourages and supports the use 

of the Accused Products through its online support, advertising, and licensing 

relationships with resellers. 

THE PATENTS-IN_SUIT 

10. On August 12, 2008, United States Patent No. 7,411,552 (the “’552 patent”), 

entitled “Grounded Antenna for a Wireless Communication Device and Method,” was 

duly and lawfully issued by the U.S. Patent and Trademark Office. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 2 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 3 

11. Terrestrial is the assignee and owner of the right, title and interest in and to the 

’552 patent, including the right to assert all causes of action arising under said patents 

and the right to any remedies for infringement of them. 

12. On December 6, 2005, United States Patent No. 6,973,133 (the “’133 patent”), 

entitled “Integrated Radio Frequency Interface,” was duly and lawfully issued by the U.S. 

Patent and Trademark Office. 

13. Terrestrial is the assignee and owner of the right, title and interest in and to the 

’133 patent, including the right to assert all causes of action arising under said patents 

and the right to any remedies for infringement of them. 

14. On February 11, 2003, United States Patent No. 6,519,290 (the “’290 patent”), 

entitled “Integrated Radio Frequency Interface,” was duly and lawfully issued by the U.S. 

Patent and Trademark Office. 

15. Terrestrial is the assignee and owner of the right, title and interest in and to the 

’290 patent, including the right to assert all causes of action arising under said patents 

and the right to any remedies for infringement of them. 

COUNT I – INFRINGEMENT OF U.S. PATENT NO. 7,411,552 

16. Terrestrial repeats and realleges the allegations of paragraphs 1 through 15 as if 

fully set forth herein. 

17. Claim 1 of the ’552 Patent recites: 

1. A wireless communication device, comprising: 

a substrate; 

a ground plane positioned on one side of the substrate; 

a wireless communication chip electrically connected to said ground plane 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 3 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 4 

and proximate thereto; 

an antenna having a first end and a second end, said first end electrically 

connected to said ground plane; and 

said second end comprising an open circuit. 

18. Without license or authorization and in violation of 35 U.S.C. § 271(a), Defendant 

has infringed and continues to infringe the ’552 Patent by making, using, importing, 

offering for sale, and/or selling the Accused Products. 

19. As exemplified below, the Accused Products are a wireless communication device 

that communicates via Bluetooth and Wi-Fi. 

A wireless communication device, comprising: 

The Accused Products communicate via Wireless USB radio and Bluetooth. 

https://perixx.com/lt_furniture_3/perixx-periduo-605-wireless-ergonomic-split-keyboardand-vertical-mouse-combo-adjustable-palm-rest-and-membrane-low-profile-keys.html

a substrate; a ground plane positioned on one side of the substrate; 

The chipset within the Accused Products comprise a substrate and a ground plane 

positioned on one side of that substrate: 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 4 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 5 

https://fccid.io/Z2G-PERIDUO-605/Internal-Photos/internal-photos-4428830

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 5 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 6 

a wireless communication chip electrically connected to said ground plane 

and proximate thereto; 

The Keyboard features a wireless communication chip that, through a wiring 

pattern, connects to said ground plane. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 6 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 7 

an antenna having a first end and a second end, said first end electrically 

connected to said ground plane; and 

The Accussed Instrument comprises an antenna having two ends, one electrically 

connected to said ground plane and another comprising an open circuit: 

said second end comprising an open circuit. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 7 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 8 

20. Terrestrial is entitled to recover from Defendant the damages sustained by 

Terrestrial as a result of Defendant's infringement of the ’552 Patent in an amount 

subject to proof at trial, which, by law, cannot be less than a reasonable royalty, together 

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

COUNT II – INFRINGEMENT OF U.S. PATENT NO. 6,973,133 

21. Terrestrial repeats and realleges the allegations of paragraphs 1 through 15 as if 

fully set forth herein. 

22. Claim 1 of the ’133 Patent recites: 

1. An apparatus comprising: 

a circuit configured to (i) communicate one or more Universal Serial Bus 

(USB) data signals via a wireless radio signal comprising a single 

frequency hopping sequence configured to support one or more USB 

devices and (ii) enumerate said one or more USB devices. 

23. Without license or authorization and in violation of 35 U.S.C. § 271(a), Defendant 

has infringed and continues to infringe the ’133 Patent by making, using, importing, 

offering for sale, and/or selling the Accused Products. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 8 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 9 

24. As exemplified below, the Accused Products are an apparatus comprising a circuit 

configured to communicate USB data signals over a wireless frequency. 

An apparatus comprising: 

The Accused Products are an apparatus comprising a circuit configured to 

communicate USB data signals over a wireless frequency to one or more USB devices 

(e.g. keyboard and mouse) and to enumerate the USB devices. 

https://perixx.com/lt_furniture_3/perixx-periduo-605-wireless-ergonomic-split-keyboardand-vertical-mouse-combo-adjustable-palm-rest-and-membrane-low-profile-keys.html

a circuit configured to (i) communicate one or more Universal Serial Bus 

(USB) data signals via a wireless radio signal comprising a single frequency 

hopping sequence configured to support one or more USB devices and 

The Accused Products include a circuit configured to communicated one or more 

USB data signals to support one more USB devices. 

The Accused Products include a USB Transceiver unit. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 9 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 10 

https://fccid.io/2AGLG-TM070G/Users-Manual/15-TM070G-UserMan-3393682

The circuit is a device configured to communicate via wireless radio frequency. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 10 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 11 

https://fccid.io/2AGLG-TM070G/Internal-Photos/09-TM070G-IntPho-3393676

The circuit is operable to communicate with one or more USB devices. 

The host device (e.g. computer) communicates data through the circuit (e.g. USB 

dongle) to a USB device (e.g. keyboard) via wireless radio signal. 

As an example of this communication, after a user presses the “Caps Lock” key on 

a computer which hosts the circuit, then, when the user presses a key on the wireless 

keyboard the “Caps Lock” indicator on the wirelessly connected keyboard lights up. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 11 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 12 

The circuit operates on a frequency hopping sequence (e.g. Gaussian frequencyshift keying). 

https://fccid.io/2AGLG-TM070G/Test-Report/14-TM070G-TestRpt-3393681

The circuit operates between 2408 and 2474 MHz. 

The frequency hopping sequence supports one or more USB devices (e.g. mouse 

and keyboard). 

(ii) enumerate said one or more USB devices. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 12 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 13 

The Accused Products are operable to enumerate the USB devices. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 13 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 14 

“A hardware ID is a vendor-defined string that Windows uses to match a device to an 

INF file.” 

https://docs.microsoft.com/en-us/windows-hardware/drivers/install/hardware-ids 

25. Terrestrial is entitled to recover from Defendant the damages sustained by 

Terrestrial as a result of Defendant's infringement of the ’133 Patent in an amount 

subject to proof at trial, which, by law, cannot be less than a reasonable royalty, together 

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

COUNT III – INFRINGEMENT OF U.S. PATENT NO. 6,519,290 

26. Terrestrial repeats and realleges the allegations of paragraphs 1 through 15 as if 

fully set forth herein. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 14 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 15 

27. Claim 1 of the ’290 Patent recites: 

1. An apparatus comprising: 

a circuit configured to generate a wireless radio signal in response to one 

or more first Universal Serial Bus (USB) data signals, 

wherein said wireless radio signal comprises a single frequency hopping 

sequence configured to support one or more USB peripheral wireless 

network devices, and 

said circuit is configured to (i) generate said one or more first USB data 

signals in response to said wireless radio signal and 

(ii) enumerate said one or more USB devices. 

28. Without license or authorization and in violation of 35 U.S.C. § 271(a), Defendant 

has infringed and continues to infringe the ’290 Patent by making, using, importing, 

offering for sale, and/or selling the Accused Products. 

29. As exemplified below, the Accused Products are a circuit configured to 

communicate USB data signals over a wireless frequency. 

An apparatus comprising: 

The Accused Products are an apparatus comprising a circuit configured to 

communicate USB data signals over a wireless frequency to one or more USB devices 

(e.g. keyboard and mouse) and to enumerate the USB devices. 

https://perixx.com/lt_furniture_3/perixx-periduo-605-wireless-ergonomic-split-keyboardand-vertical-mouse-combo-adjustable-palm-rest-and-membrane-low-profile-keys.html

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 15 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 16 

a circuit configured to generate a wireless radio signal in response to one or 

more first Universal Serial Bus (USB) data signals, 

The Accused Products include a circuit configured to generate a wireless radio 

signal in response to one or more first Universal Serial Bus (USB) data signals. 

The first data signal below is communicated between the host device and the USB 

interface. 

To set up the USB interface, the client drivers (provided by the host) communicate 

with the receiver to establish the protocol as described below: 

The service shown above is the USB generic parent driver. 

https://docs.microsoft.com/en-us/windows-hardware/drivers/usbcon/usb-common-classgeneric-parent-driver

In response to said first data transaction the device is then registered to the 

computer and begins transmitting a wireless frequency device to connect to peripheral 

devices (a mouse and keyboard). 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 16 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 17 

Then once the peripheral device is turned on, the USB Transceiver registers and 

communicates with said device. 

wherein said wireless radio signal comprises a single frequency hopping 

sequence configured to support one or more USB peripheral wireless network 

devices, and 

The radio signal generated comprises a frequency hopping sequence to support 

one or more peripheral devices. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 17 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 18 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 18 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 19 

https://fccid.io/2AGLG-TM070G/Users-Manual/15-TM070G-UserMan-3393682

The circuit is a device configured to communicate via wireless radio frequency. 

https://fccid.io/2AGLG-TM070G/Internal-Photos/09-TM070G-IntPho-3393676

The circuit is operable to communicate with one or more USB devices. 

The circuit operates on a frequency hopping sequence (e.g. Gaussian frequencyshift keying). 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 19 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 20 

https://fccid.io/2AGLG-TM070G/Test-Report/14-TM070G-TestRpt-3393681

The circuit operates between 2408 and 2474 MHz. 

The frequency hopping sequence supports one or more USB peripheral devices 

(e.g. mouse and keyboard).

said circuit is configured to (i) generate said one or more first USB data 

signals in response to said wireless radio signal and 

The device generates a USB data signal in response to said wireless radio signal. 

The circuit is a device configured to communicate via wireless radio frequency (e.g. 

2.4 GHz wireless radio). 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 20 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 21 

The circuit is operable to communicate with one or more USB devices (e.g. Mouse 

and Keyboard). 

 The keyboard communicates via a wireless frequency: 

https://fccid.io/Z2G-PERIDUO-605/Test-Report/test-report-4428835

The transmitter in the wireless keyboard sends a data signal via a radio frequency 

to the USB device which receives the radio signals and converts that data into a USB 

data signal which is then communicated to the host device. 

https://fccid.io/Z2G-PERIDUO-605

https://fccid.io/Z2G-PERIDUO-605/Internal-Photos/internal-photos-4428830 

When the caps lock light when pressed on the wireless keyboard turns on the caps 

lock light on the host computers keyboard. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 21 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 22 

(ii) enumerate said one or more USB devices.

The Accused Products are operable to enumerate the USB devices. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 22 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 23 

“A hardware ID is a vendor-defined string that Windows uses to match a device to an 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 23 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 24 

INF file.” 

https://docs.microsoft.com/en-us/windows-hardware/drivers/install/hardware-ids 

30. Terrestrial is entitled to recover from Defendant the damages sustained by 

Terrestrial as a result of Defendant's infringement of the ’290 Patent in an amount 

subject to proof at trial, which, by law, cannot be less than a reasonable royalty, together 

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

PRAYER FOR RELIEF 

WHEREFORE, Terrestrial requests that this Court enter judgment against 

Defendant as follows: 

A. An adjudication that Defendant has infringed the ’552 Patent, the ’133 

Patent, and the ’290 Patent; 

B. An award of damages to be paid by Defendant adequate to compensate 

Terrestrial for Defendant's past infringement of the ’552 Patent, the ’133 Patent, and the 

’290 Patent, and any continuing or future infringement through the date such judgment 

is entered, including interest, costs, expenses and an accounting of all infringing acts 

including, but not limited to, those acts not presented at trial; 

C. A declaration that this case is exceptional under 35 U.S.C. § 285, and an 

award of Terrestrial's reasonable attorneys' fees; and 

D. An award to Terrestrial of such further relief at law or in equity as the 

Court deems just and proper. 

JURY DEMAND 

Plaintiff demands trial by jury, Under Fed. R. Civ. P. 38. 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 24 of 25
COMPLAINT FOR PATENT INFRINGEMENT PAGE | 25 

Dated: February 11, 2020 Respectfully Submitted 

/s/ Raymond W. Mort, III 

Raymond W. Mort, III 

Texas State Bar No. 00791308 

raymort@austinlaw.com 

THE MORT LAW FIRM, PLLC 

100 Congress Ave, Suite 2200 

Austin, Texas 78701 

Tel/Fax: (512) 865-7950 

ATTORNEYS FOR PLAINTIFF 

Case 6:20-cv-00105-ADA Document 1 Filed 02/11/20 Page 25 of 25