UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

JENAM TECH, LLC, 

 Plaintiff 

v. 

GOOGLE LLC, 

 Defendant. 

Civil Action No.: 6:20-cv-00453 

JURY TRIAL DEMANDED 

PATENT CASE 

PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Jenam Tech, LLC (“Jenam Tech” or “Plaintiff”), files this Complaint against 

Google, LLC ( “Google” or “Defendant") seeking damages and other relief for patent 

infringement, and alleges with knowledge to its own acts, and on information and belief as to other 

matters, as follows: 

PARTIES 

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

State of Texas, having its principal place of business at 211 West Tyler Street, Suite C, Longview, 

Texas, 75601. 

2. Defendant Google is a Delaware corporation with a physical address at 500 West 

2nd Street, Austin, Texas 78701. Google may be served with process through its registered agent, 

the Corporation Service Company, at 211 East 7th Street, Suite 620, Austin, Texas 78701. Google 

is registered to do business in the State of Texas and has been since at least November 17, 2006. 

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3. This Court has personal jurisdiction over Google at least because Google regularly 

conducts and transacts business, including infringing acts described herein, in this District. 

4. Defendant conducts business in Texas, directly or through intermediaries and offer 

products or services, including those accused herein of infringement, to customers, and potential 

customers located in Texas, including in the Western District of Texas. 

JURISDICTION AND VENUE 

5. This action arises under the patent laws of the United States, 35 U.S.C. §101, et 

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

6. As to Google, venue is proper in this judicial district pursuant to 28 U.S.C. 

§1400(b). Google maintains an established place of business in the state of Texas and the Western 

District of Texas, specifically, including an office at 500 West 2nd Street, Austin, Texas 78701. 

7. Defendants are subject to this Court’s specific and general personal jurisdiction 

pursuant to due process or the Texas Long Arm Statute, because Defendants conduct substantial 

business in this forum, including: (i) making, using, selling, importing, and/or offering for sale one 

or more websites or web addresses including, but not limited to www.google.com, stored and/or 

hosted on one or more servers owned or under the control of Google (“Accused 

Instrumentalities”); (ii) making, using, selling, importing, and/or offering for sale software for 

smartphones and tablets as well as other computing devices (e.g., laptops, desktops, Chromebooks, 

etc.) (“Accused Software”); or (iii) regularly doing or soliciting business, engaging in other 

persistent courses of conduct, or deriving substantial revenue from goods and services provided to 

citizens and residents in Texas and in this District. 

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THE PATENTS-IN-SUIT 

8. On March 7, 2018, Robert Paul Morris filed United States Patent Application No. 

15/915,053 (“the ʼ053 Application”). The ʼ053 Application was duly examined and issued as 

United States Patent No. 10,069,945 (“the ʼ945 patent”) (entitled “Methods, Systems, and 

Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on 

September 4, 2018. 

9. Jenam Tech is the owner of the ʼ945 patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendants’ infringement of 

the ʼ945 patent. 

10. The ʼ945 patent is valid and enforceable. A true and correct copy of the ʼ945 patent 

is attached hereto as Exhibit A. 

11. On March 7, 2018, Robert Paul Morris filed United States Patent Application No. 

15/915,047 (“the ʼ047 Application”). The ʼ047 Application was duly examined and issued as 

United States Patent No. 10,075,564 (“the ʼ564 patent”) (entitled “Methods, Systems, and 

Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on 

September 11, 2018. 

12. Jenam Tech is the owner of the ʼ564 patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendants’ infringement of 

the ʼ564 patent. 

13. The ʼ564 patent is valid and enforceable. A true and correct copy of the ʼ564 patent 

is attached hereto as Exhibit B. 

14. On March 7, 2018, Robert Paul Morris filed United States patent Application No. 

15/915,052 (“the ʼ052 Application”). The ʼ052 Application was duly examined and issued as 

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United States Patent No. 10,075,565 (“the ʼ565 patent”) (entitled “Methods, Systems, and 

Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on 

September 11, 2018. 

15. Jenam Tech is the owner of the ʼ565 patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendants’ infringement of 

the ʼ565 patent. 

16. The ʼ565 patent is valid and enforceable. A true and correct copy of the ʼ565 patent 

is attached hereto as Exhibit C. 

17. On July 19, 2018, Robert Paul Morris filed United States Patent Application No. 

16/040,522 (“the ʼ522 Application”). The ʼ522 Application was duly examined and issued as 

United States Patent No. 10,375,215 (“the ʼ215 patent”) (entitled “Methods, Systems, and 

Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on 

August 6, 2019. 

18. Jenam Tech is the owner of the ʼ215 patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendants’ infringement of 

the ʼ215 patent. 

19. The ʼ215 patent is valid and enforceable. A true and correct copy of the ʼ215 patent 

is attached hereto as Exhibit D. 

20. On July 19, 2018, Robert Paul Morris filed United States Patent Application No. 

16/040,517 (“the ʼ517 Application”). The ʼ517 Application was duly examined and issued as 

United States Patent No. 10,306,026 (“the ʼ026 patent”) (entitled “Methods, Systems, and 

Computer Program Products for Sharing Information for Detecting an Idle TCP Connection”), on 

May 28, 2019. 

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21. Jenam Tech is the owner of the ʼ026 patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendants’ infringement of 

the ʼ026 patent. 

22. The ʼ026 patent is valid and enforceable. A true and correct copy of the ʼ026 patent 

is attached hereto as Exhibit E. 

23. On September 3, 2017, Robert Paul Morris filed United States Patent Application 

No. 15/694,802 (“the ‘802 Application”). The ‘802 Application was duly examined and issued as 

United States Patent No. 9,923,995 (“the ‘995 Patent”) (entitled “Methods, Systems, and Computer 

Program Products for Sharing Information for Detecting an Idle TCP Connection”), on March 20, 

2018. 

24. Jenam Tech is the owner of the ‘995 Patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendant’s infringement of 

the ‘995 Patent. 

25. The ʼ995 Patent is valid and enforceable. A true and correct copy of the ʼ995 Patent 

is attached hereto as Exhibit F. 

26. On September 3, 2017, Robert Paul Morris filed United States Patent Application 

No. 15/694,803 (“the ‘803 Application”). The ‘803 Application was duly examined and issued as 

United States Patent No. 9,923,996 (“the ʼ996 Patent”) (entitled “Methods, Systems, and Computer 

Program Products for Sharing Information for Detecting an Idle TCP Connection”), on March 20, 

2018. 

27. Jenam Tech is the owner of the ʼ996 Patent and has the full and exclusive right to 

bring actions and recover past, present, and future damages for the Defendant’s infringement of 

the ʼ996 Patent. 

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28. The ʼ996 Patent is valid and enforceable. A true and correct copy of the ʼ996 Patent 

is attached hereto as Exhibit G. 

29. The ʼ945, ʼ564, ʼ565, ʼ215, ʼ026, ʼ995 and ʼ996 patents are collectively referred to 

herein as the “patents” or the “patents in suit.” 

30. Jenam Tech has not practiced any claimed invention of the patents in suit. 

31. Defendants infringe the patents at least through making, using, selling, importing, 

and/or offering to sell the Accused Instrumentalities and Accused Software. 

COUNT I: INFRINGEMENT OF THE ʼ945 PATENT 

32. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

33. The ʼ945 patent includes 144 claims. ʼ945 patent, Ex. A at 24:8-36:65. 

34. Defendants directly infringe one or more claims of the ʼ945 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities. See Claim 

Chart for the ʼ945 patent, attached hereto as Exhibit H. 

35. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 104 of the ʼ945 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See

Claim Chart for the ʼ945 patent, attached hereto as Exhibit H. As demonstrated by the attached 

claim chart, each and every element of Claim 104 of the ʼ945 patent is found in the Accused 

Instrumentalities. 

36. Defendants have had actual knowledge of the ʼ945 patent at least as early as the 

date of service of this Complaint. 

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37. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

COUNT II: INFRINGEMENT OF THE ʼ564 PATENT 

38. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

39. The ʼ564 patent includes 30 claims. ʼ564 patent, Ex. B at 23:5–27:28. 

40. Defendants directly infringe one or more claims of the ʼ564 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities. See Claim 

Chart for the ʼ564 patent, attached hereto as Exhibit I. 

41. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 1 of the ʼ564 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See

Claim Chart for the ʼ564 patent, attached hereto as Exhibit I. As demonstrated by the attached 

claim chart, each and every element of Claim 1 of the ʼ564 patent is found in the Accused 

Instrumentalities. 

42. Defendants have had actual knowledge of the ʼ564 patent at least as early as the 

date of service of this Complaint. 

43. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

COUNT III: INFRINGEMENT OF THE ʼ565 PATENT 

44. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

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45. The ʼ565 patent includes 30 claims. ʼ565 patent, Ex. C at 23:48–28:65. 

46. Defendants directly infringe one or more claims of the ʼ565 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities. See Claim 

Chart for the ʼ565 patent, attached hereto as Exhibit J. 

47. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 1 of the ʼ565 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See

Claim Chart for the ʼ565 patent, attached hereto as Exhibit J. As demonstrated by the attached 

claim chart, each and every element of Claim 1 of the ʼ565 patent is found in the Accused 

Instrumentalities. 

48. Defendants have had actual knowledge of the ʼ565 patent at least as early as the 

date of service of this Complaint. 

49. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

COUNT IV: INFRINGEMENT OF THE ʼ215 PATENT 

50. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

51. The ʼ215 patent includes 39 claims. ʼ215 patent, Ex. D at 24:15–30:23. 

52. Defendants directly infringe one or more claims of the ʼ215 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities. See Claim 

Chart for the ʼ215 patent, attached hereto as Exhibit K. 

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53. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 1 of the ʼ215 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See

Claim Chart for the ʼ215 patent, attached hereto as Exhibit K. As demonstrated by the attached 

claim chart, each and every element of Claim 1 of the ʼ215 patent is found in the Accused 

Instrumentalities. 

54. Defendants have had actual knowledge of the ʼ215 patent at least as early as the 

date of service of this Complaint. 

55. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

COUNT V: INFRINGEMENT OF THE ʼ026 PATENT 

56. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

57. The ʼ026 patent includes 98 claims. ʼ026 patent, Ex. E at 24:16–34:30. 

58. Defendants directly infringe one or more claims of the ʼ026 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities and the 

Accused Software. See Claim Chart for the ʼ026 patent, attached hereto as Exhibit L. 

59. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 1 of the ʼ026 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities and the 

Accused Software. See Claim Chart for the ʼ026 patent, attached hereto as Exhibit L. As 

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demonstrated by the attached claim chart, each and every element of Claim 1 of the ʼ026 patent is 

found in the Accused Instrumentalities and the Accused Software. 

60. Defendants have had actual knowledge of the ʼ026 patent at least as early as the 

date of service of this Complaint. 

61. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

COUNT VI: INFRINGEMENT OF THE ‘995 PATENT 

62. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

63. The ʼ995 patent includes 30 claims. ʼ995 patent, Ex. F at 23:4-28:16. 

64. Defendants directly infringe one or more claims of the ʼ995 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities and the 

Accused Software. See Claim Chart for the ʼ995 patent, attached hereto as Exhibit M. 

65. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 29 of the ʼ995 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities and the 

Accused Software. See Claim Chart for the ʼ995 patent, attached hereto as Exhibit M. As 

demonstrated by the attached claim chart, each and every element of Claim 29 of the ‘995 patent 

is found in the Accused Instrumentalities and the Accused Software. 

66. Defendants have had actual knowledge of the ʼ995 patent at least as early as the 

date of service of this Complaint. 

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67. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

COUNT VII: INFRINGEMENT OF THE ‘996 PATENT 

68. Jenam Tech repeats and re-alleges the allegations of the above paragraphs as if fully 

set forth herein. 

69. The ‘996 patent includes 30 claims. ‘996 patent, Ex. G at 23:27-28:42. 

70. Defendants directly infringe one or more claims of the ʼ996 patent without authority 

by making, using (including without limitation testing), selling, importing, and/or offering to sell 

products and systems, including by way of example, the Accused Instrumentalities. See Claim 

Chart for the ʼ996 patent, attached hereto as Exhibit N. 

71. Defendants have been and are directly infringing, either literally or under the 

doctrine of equivalents, at least Claim 1 of the ʼ996 patent by making, using (including without 

limitation testing), selling, importing, and/or offering to sell the Accused Instrumentalities. See

Claim Chart for the ‘996 patent, attached hereto as Exhibit N. As demonstrated by the attached 

claim chart, each and every element of Claim 1 of the ʼ996 patent is found in the Accused 

Instrumentalities. 

72. Defendants have had actual knowledge of the ʼ996 patent at least as early as the 

date of service of this Complaint. 

73. Defendants’ acts of infringement have occurred within this District and elsewhere 

throughout the United States. 

RELIEF REQUESTED 

WHEREFORE, Plaintiff respectfully requests that the Court: 

A. Declaring that Defendants have infringed the patents in suit; 

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B. Awarding damages in an amount to be proven at trial, but in no event less than a 

reasonable royalty for Defendants’ infringement including pre-judgment and postjudgment interest at the maximum rate permitted by law; 

C. Ordering an award of reasonable attorneys’ fees and enhanced damages as 

appropriate against Defendant to Jenam Tech as provided by 35 U.S.C. § 285; 

D. Awarding expenses, costs, and disbursements in this action against Defendants, 

including prejudgment interest; and 

E. All other relief necessary or appropriate. 

JURY DEMAND 

Pursuant to Federal Rule of Civil Procedure 38(b), Plaintiff hereby demands a trial by jury 

on all issues so triable. 

Dated: June 1, 2020 /s/ James M. Lennon 

James M. Lennon (Bar No. 4570) 

Timothy Devlin (Bar No. 4241) 

Derek Dahlgren (Bar No. 983624) 

Cory Edwards (Bar No. 6329639) 

DEVLIN LAW FIRM LLC 

1526 Gilpin Avenue 

Wilmington, DE 19806 

Telephone: (302) 449-9010 

Facsimile: (302) 353-4251 

jlennon@devlinlawfirm.com 

tdevlin@devlinlawfirm.com 

ddahlgren@devlinlawfirm.com 

cedwards@devlinlawfirm.com 

Attorneys for Plaintiff, 

Jenam Tech, LLC

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