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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

SolutionInc Limited,

Plaintiff,

v.

Cisco Systems, Inc., 

Defendant.

Case No. 1:20-cv-145

Patent Case

Jury Trial Demanded

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff SolutionInc Limited ("SolutionInc"), through its attorneys, complains of Cisco 

Systems, Inc. ("Cisco"), and alleges the following:

PARTIES

1. Plaintiff SolutionInc Limited is a corporation organized and existing under the 

laws of Canada that maintains its principal place of business at 5692 Bloomfield StHalifax, NS 

B3K 1T2, Canada.

2. Defendant Cisco Systems, Inc. is a corporation organized and existing under the 

laws of California that maintains an established place of business at 12515-3 Research Park 

Loop, Austin, TX 78759 and 18615 Tuscany Stone, San Antonio, Texas 78258.

JURISDICTION

3. This is an action for patent infringement arising under the patent laws of the 

United States, Title 35 of the United States Code.

4. This Court has exclusive subject matter jurisdiction under 28 U.S.C. §§ 1331 and 

1338(a). 

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5. This Court has personal jurisdiction over Defendant because it has engaged in 

systematic and continuous business activities in this District. As described below, Defendant has 

committed acts of patent infringement giving rise to this action within this District. 

VENUE

6. Venue is proper in this District under 28 U.S.C. § 1400(b) because Defendant has 

committed acts of patent infringement in this District, and has an established place of business in 

this District. In addition, SolutionInc has suffered harm in this district.

PATENTS-IN-SUIT

7. SolutionInc is the assignee of all right, title and interest in United States Patent 

Nos. 7,526,538 (the "'538 Patent"); 7,007,080 (the "'80 Patent"); 7,502,841 (the "'841 Patent");

(collectively the "Patents-in-Suit"); including all rights to enforce and prosecute actions for 

infringement and to collect damages for all relevant times against infringers of the Patents-inSuit. Accordingly, SolutionInc possesses the exclusive right and standing to prosecute the 

present action for infringement of the Patents-in-Suit by Defendant.

The '538 Patent

8. The '538 Patent is entitled "System using server to provide mobile computer 

accessing to a different network without reconfiguring the mobile computer," and issued 

4/28/2009. The application leading to the '538 Patent was filed on 7/8/2005. A true and correct 

copy of the '538 Patent is attached hereto as Exhibit 1 and incorporated herein by reference.

9. The '538 Patent is valid and enforceable.

The '80 Patent

10. The '80 Patent is entitled "System for reconfiguring and registering a new IP 

address for a computer to access a different network without user intervention," and issued 

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2/28/2006. The application leading to the '80 Patent was filed on 12/22/2000. A true and correct 

copy of the '80 Patent is attached hereto as Exhibit 2 and incorporated herein by reference.

11. The '80 Patent is valid and enforceable.

The '841 Patent

12. The '841 Patent is entitled "Server, system and method for providing access to a 

public network through an internal network of a multi-system operator," and issued 3/10/2009. 

The application leading to the '841 Patent was filed on 2/2/2005. A true and correct copy of the 

'841 Patent is attached hereto as Exhibit 3 and incorporated herein by reference.

13. The '841 Patent is valid and enforceable.

COUNT 1: INFRINGEMENT OF THE '538 PATENT

14. SolutionInc incorporates the above paragraphs herein by reference. 

15. Direct Infringement. Defendant has been and continues to directly infringe one 

or more claims of the '538 Patent in at least this District by making, using, offering to sell, selling 

and/or importing, without limitation, at least the Cisco products identified in the charts

incorporated into this Count below (among the "Exemplary Cisco Products") that infringe at 

least the exemplary claims of the '538 Patent also identified in the charts incorporated into this 

Count below (the "Exemplary '538 Patent Claims") literally or by the doctrine of equivalents. On 

information and belief, numerous other devices that infringe the claims of the '538 Patent have 

been made, used, sold, imported, and offered for sale by Defendant and/or its customers.

16. Defendant also has and continues to directly infringe, literally or under the 

doctrine of equivalents, the Exemplary '538 Patent Claims, by having its employees internally 

test and use these Exemplary Products.

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17. The service of this Complaint upon Defendant constitutes actual knowledge of 

infringement as alleged here.

18. Despite such actual knowledge, Defendant continues to make, use, test, sell, offer 

for sale, market, and/or import into the United States, products that infringe the '538 Patent. On 

information and belief, Defendant has also continued to sell the Exemplary Cisco Products and 

distribute product literature and website materials inducing end users and others to use its 

products in the customary and intended manner that infringes the '538 Patent. Thus, on 

information and belief, Defendant is contributing to and/or inducing the infringement of the '538

Patent.

19. Induced Infringement. Defendant actively, knowingly, and intentionally has 

been and continues to induce infringement of the '538 Patent, literally or by the doctrine of 

equivalents, by selling Exemplary Cisco Products to their customers for use in end-user products 

in a manner that infringes one or more claims of the '538 Patent.

20. Contributory Infringement. Defendant actively, knowingly, and intentionally 

has been and continues materially contribute to their own customers' infringement of the '538

Patent, literally or by the doctrine of equivalents, by selling Exemplary Cisco Products to their 

customers for use in end-user products in a manner that infringes one or more claims of the '538

Patent. Moreover, the Exemplary Cisco Products are not a staple article of commerce suitable for 

substantial noninfringing use.

21. Exhibit 4 includes charts comparing the Exemplary '538 Patent Claims to the 

Exemplary Cisco Products. As set forth in these charts, the Exemplary Cisco Products practice

the technology claimed by the '538 Patent. Accordingly, the Exemplary Cisco Products 

incorporated in these charts satisfy all elements of the Exemplary '538 Patent Claims. 

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22. SolutionInc therefore incorporates by reference in its allegations herein the claim 

charts of Exhibit 4.

23. SolutionInc is entitled to recover damages adequate to compensate for 

Defendant's infringement.

COUNT 2: INFRINGEMENT OF THE '80 PATENT

24. SolutionInc incorporates the above paragraphs herein by reference. 

25. Direct Infringement. Defendant has been and continues to directly infringe one 

or more claims of the '80 Patent in at least this District by making, using, offering to sell, selling 

and/or importing, without limitation, at least the Cisco products identified in the charts

incorporated into this Count below (among the "Exemplary Cisco Products") that infringe at 

least the exemplary claims of the '80 Patent also identified in the charts incorporated into this 

Count below (the "Exemplary '80 Patent Claims") literally or by the doctrine of equivalents. On 

information and belief, numerous other devices that infringe the claims of the '80 Patent have 

been made, used, sold, imported, and offered for sale by Defendant and/or its customers.

26. Defendant also has and continues to directly infringe, literally or under the 

doctrine of equivalents, the Exemplary '80 Patent Claims, by having its employees internally test 

and use these Exemplary Products.

27. The service of this Complaint upon Defendant constitutes actual knowledge of 

infringement as alleged here.

28. Despite such actual knowledge, Defendant continues to make, use, test, sell, offer 

for sale, market, and/or import into the United States, products that infringe the '80 Patent. On 

information and belief, Defendant has also continued to sell the Exemplary Cisco Products and 

distribute product literature and website materials inducing end users and others to use its 

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products in the customary and intended manner that infringes the '80 Patent. Thus, on 

information and belief, Defendant is contributing to and/or inducing the infringement of the '80

Patent.

29. Induced Infringement. Defendant actively, knowingly, and intentionally has 

been and continues to induce infringement of the '80 Patent, literally or by the doctrine of 

equivalents, by selling Exemplary Cisco Products to their customers for use in end-user products 

in a manner that infringes one or more claims of the '80 Patent.

30. Contributory Infringement. Defendant actively, knowingly, and intentionally 

has been and continues materially contribute to their own customers' infringement of the '80

Patent, literally or by the doctrine of equivalents, by selling Exemplary Cisco Products to their 

customers for use in end-user products in a manner that infringes one or more claims of the '80

Patent. Moreover, the Exemplary Cisco Products are not a staple article of commerce suitable for 

substantial noninfringing use.

31. Exhibit 5 includes charts comparing the Exemplary '80 Patent Claims to the 

Exemplary Cisco Products. As set forth in these charts, the Exemplary Cisco Products practice

the technology claimed by the '80 Patent. Accordingly, the Exemplary Cisco Products 

incorporated in these charts satisfy all elements of the Exemplary '80 Patent Claims. 

32. SolutionInc therefore incorporates by reference in its allegations herein the claim 

charts of Exhibit 5.

33. SolutionInc is entitled to recover damages adequate to compensate for 

Defendant's infringement.

COUNT 3: INFRINGEMENT OF THE '841 PATENT

34. SolutionInc incorporates the above paragraphs herein by reference. 

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35. Direct Infringement. Defendant has been and continues to directly infringe one 

or more claims of the '841 Patent in at least this District by making, using, offering to sell, selling 

and/or importing, without limitation, at least the Cisco products identified in the charts

incorporated into this Count below (among the "Exemplary Cisco Products") that infringe at 

least the exemplary claims of the '841 Patent also identified in the charts incorporated into this 

Count below (the "Exemplary '841 Patent Claims") literally or by the doctrine of equivalents. On 

information and belief, numerous other devices that infringe the claims of the '841 Patent have 

been made, used, sold, imported, and offered for sale by Defendant and/or its customers.

36. Defendant also has and continues to directly infringe, literally or under the 

doctrine of equivalents, the Exemplary '841 Patent Claims, by having its employees internally 

test and use these Exemplary Products.

37. The service of this Complaint upon Defendant constitutes actual knowledge of 

infringement as alleged here.

38. Despite such actual knowledge, Defendant continues to make, use, test, sell, offer 

for sale, market, and/or import into the United States, products that infringe the '841 Patent. On 

information and belief, Defendant has also continued to sell the Exemplary Cisco Products and 

distribute product literature and website materials inducing end users and others to use its 

products in the customary and intended manner that infringes the '841 Patent. Thus, on 

information and belief, Defendant is contributing to and/or inducing the infringement of the '841

Patent.

39. Induced Infringement. Defendant actively, knowingly, and intentionally has 

been and continues to induce infringement of the '841 Patent, literally or by the doctrine of 

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equivalents, by selling Exemplary Cisco Products to their customers for use in end-user products 

in a manner that infringes one or more claims of the '841 Patent.

40. Contributory Infringement. Defendant actively, knowingly, and intentionally 

has been and continues materially contribute to their own customers' infringement of the '841

Patent, literally or by the doctrine of equivalents, by selling Exemplary Cisco Products to their 

customers for use in end-user products in a manner that infringes one or more claims of the '841

Patent. Moreover, the Exemplary Cisco Products are not a staple article of commerce suitable for 

substantial noninfringing use.

41. Exhibit 6 includes charts comparing the Exemplary '841 Patent Claims to the 

Exemplary Cisco Products. As set forth in these charts, the Exemplary Cisco Products practice

the technology claimed by the '841 Patent. Accordingly, the Exemplary Cisco Products 

incorporated in these charts satisfy all elements of the Exemplary '841 Patent Claims. 

42. SolutionInc therefore incorporates by reference in its allegations herein the claim 

charts of Exhibit 6.

43. SolutionInc is entitled to recover damages adequate to compensate for 

Defendant's infringement.

JURY DEMAND

44. Under Rule 38(b) of the Federal Rules of Civil Procedure, SolutionInc

respectfully requests a trial by jury on all issues so triable.

PRAYER FOR RELIEF

WHEREFORE, SolutionInc respectfully requests the following relief:

A. A judgment that the '538 Patent is valid and enforceable;

B. A judgment that the '80 Patent is valid and enforceable;

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C. A judgment that the '841 Patent is valid and enforceable;

D. A judgment that Defendant has infringed, contributorily infringed, and/or induced 

infringement of one or more claims of the '538 Patent;

E. A judgment that Defendant has infringed, contributorily infringed, and/or induced 

infringement of one or more claims of the '80 Patent;

F. A judgment that Defendant has infringed, contributorily infringed, and/or induced 

infringement of one or more claims of the '841 Patent;

G. An accounting of all damages not presented at trial;

H. A judgment that awards SolutionInc all appropriate damages under 35 U.S.C. § 

284 for Defendant's past infringement, and any continuing or future infringement 

of the Patents-in-Suit, up until the date such judgment is entered, including pre- or 

post-judgment interest, costs, and disbursements as justified under 35 U.S.C. § 284 

and, if necessary, to adequately compensate SolutionInc for Defendant's 

infringement, an accounting:

i. that this case be declared exceptional within the meaning of 35 U.S.C. § 285 

and that SolutionInc be awarded its reasonable attorneys' fees against 

Defendant that it incurs in prosecuting this action;

ii. that SolutionInc be awarded costs, and expenses that it incurs in prosecuting 

this action; and

iii. that SolutionInc be awarded such further relief at law or in equity as the Court 

deems just and proper.

Dated: February 7, 2020 Respectfully submitted,

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/s/ Isaac Rabicoff

Isaac Rabicoff

Rabicoff Law LLC

73 W Monroe St

Chicago, IL 60603

(773) 669-4590

isaac@rabilaw.com

Counsel for Plaintiff

SolutionInc Limited

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