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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC d/b/a 

BRAZOS LICENSING AND 

DEVELOPMENT,

Plaintiff,

v.

HUAWEI TECHNOLOGIES CO., LTD.

and HUAWEI TECHNOLOGIES USA 

INC.

Defendants.

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CASE NO. 6:20-cv-537

JURY TRIAL DEMANDED

ORIGINAL COMPLAINT FOR PATENT 

INFRINGEMENT

Plaintiff WSOU Investments, LLC d/b/a Brazos Licensing and Development

(“Brazos” or “Plaintiff”), by and through its attorneys, files this Complaint for Patent 

Infringement against Defendants Huawei Technologies Co., Ltd. and Huawei Technologies 

USA Inc. (collectively “Huawei” or “Defendants”) and alleges:

NATURE OF THE ACTION

1. This is a civil action for patent infringement arising under the Patent Laws 

of the United States, 35 U.S.C. §§ 1, et seq., including §§ 271, 281, 284, and 285.
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THE PARTIES

2. Brazos is a limited liability corporation organized and existing under the laws 

of Delaware, with its principal place of business at 605 Austin Ave, Ste 6, Waco, TX 76701.

3. On information and belief, Defendant Huawei Technologies Co., Ltd. is a 

Chinese corporation that does business in Texas, directly or through intermediaries, with a 

principal place of business at Bantian, Longgang District, Shenzhen 518129, People’s 

Republic of China.

4. Upon information and belief, Defendant Huawei Technologies USA Inc. is a 

corporation organized and existing under the laws of Texas that maintains an established 

place of business at 2391 NE Interstate 410 Loop, San Antonio, TX 78217. Huawei 

Technologies USA, Inc. is authorized to do business in Texas and may be served via its 

registered agent, CT Corporation System, 1999 Bryan Street, Suite 900, Dallas, Texas 

75201-3136.

5. The Defendants operate under and identify with the trade name “Huawei.” 

Each of the Defendants may be referred to individually as a “Huawei Defendant” and, 

collectively, Defendants may be referred to below as “Huawei” or as the “Huawei 

Defendants.”

JURISDICTION AND VENUE

6. This is an action for patent infringement which arises under the Patent Laws 

of the United States, in particular, 35 U.S.C. §§271, 281, 284, and 285.

7. This Court has jurisdiction over the subject matter of this action under 28 

U.S.C. §§ 1331 and 1338(a).

8. This Court has specific and general personal jurisdiction over each Huawei

Defendant pursuant to due process and/or the Texas Long Arm Statute, because each Huawei 
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Defendant has committed acts giving rise to this action within Texas and within this judicial 

district. The Court’s exercise of jurisdiction over each Huawei Defendant would not offend 

traditional notions of fair play and substantial justice because Huawei has established 

minimum contacts with the forum. For example, on information and belief, Huawei

Defendants have committed acts of infringement in this judicial district, by among other 

things, selling and offering for sale products that infringe the asserted patent, directly or 

through intermediaries, as alleged herein.

9. Venue in the Western District of Texas is proper pursuant to 28 U.S.C. 

§§1391 and 1400(b) because Huawei Technologies USA Inc. has committed acts of 

infringement in this judicial district and has a regular and established places of business in 

this judicial district and in Texas. As non-limiting examples, on information and belief, 

Huawei Technologies USA Inc. has sold or offered to sell the Accused Products in this 

judicial district and has employees or agents that operate Huawei equipment in this judicial 

district, including at 189 CR 265, Georgetown, TX 78626, 1150 S Bell Blvd, Cedar Park, 

TX 78613, 1399 S A W Grimes Blvd, Round Rock, TX 78664, 12335 IH 35, Jarrell, TX 

76537, 1050 Rabbit Hill Rd, Unit #E, Georgetown, TX 78626, 1602 A W Grimes Blvd, 

Round Rock, TX 78664, 4120 IH 35 N, Georgetown, TX 78626, 900 CR 272, Leander, TX 

78641, 1950 Crystal Falls Pkwy, Leander, TX 78641, 1101 N Industrial Blvd, Round Rock, 

TX 78681, 506 McNeil Rd, Round Rock, TX 78681, 3210 Chisholm Trail Rd, Round Rock, 

TX 78681, 112 Roundville Ln, Round Rock, TX 78664, 202 Central Dr W, Georgetown, 

TX 78628, 3595 E Hwy 29, Georgetown, TX 78626, 1402 W Welch St, Taylor, TX 76574, 

3801 Oak Ridge Dr, Round Rock, TX 78681, 1957 Red Bud Ln #B, Round Rock, TX 

78664, 6603 S Lakewood Dr, Georgetown, TX 78633, 500 W Front, Hutto, TX 78634.
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COUNT ONE - INFRINGEMENT OF 

U.S. PATENT NO. 7,860,512

10. Brazos re-alleges and incorporates by reference the preceding paragraphs 

of this Complaint.

11. On December 28, 2010, the United States Patent and Trademark Office 

duly and legally issued U.S. Patent No. 7,860,512 (“the ’512 Patent”), entitled “Method For

Managing Radio Resources And Radiosystem.” A true and correct copy of the ’512 Patent 

is attached as Exhibit A to this Complaint.

12. Brazos is the owner of all rights, title, and interest in and to the ’512 Patent, 

including the right to assert all causes of action arising under the ’512 Patent and the right 

to any remedies for the infringement of the ’512 Patent.

13. Huawei makes, uses, sells, offers for sale, imports, and/or distributes in the 

United States, including within this judicial district, products such as, but not limited to,

Huawei eLTE Integrated access solution (collectively, the “Accused Products”). 

14. The Accused Products include Huawei eLTE Architecture, which includes 

DBS3900 Distributed Base Station and eCore9300.

15. The accused product Huawei eLTE Integrated access solution provides 

industry solutions that have scalable bandwidths and frequency band customization. The eLTE 

Architecture consists of DBS3900 Distributed Base Station and eCore9300. 
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https://e.huawei.com/us/solutions/business-needs/wireless-private-network/broadband-accessnew

16. eLTE Architecture comprises of two major components, DBS3900 and eCore 

9300. eCore product series include the MME, EPC-UGW, HSS, PCRF and another necessary 

service NEs. 

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c
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17. The accused product consists of eCore9300 (i.e., an apparatus). eCore9300 is 

a hardware platform, supporting broadband access and trunking services via a virtualization 

feature. eCore can support up to 3000 eNodeBs. 

https://e.huawei.com/en/products/wireless/elte-dsa/network-side-devices/ecore9300

18. eCore Product series are categorized in two parts which are eCore9300 & 

eCore9100. eCore9300 is majorly used in eLTE. 

19. The eCore9300 uses Huawei OSTA5.0 (3 U) as the hardware platform. The 

OSTA5.0 comprises GPUB9 Board as a service component. GPUB9 board has CPU which 

uses Intel Broadwell-EP Xeon E5-2600 v4 CPUs (i.e., processor) as service processing units. 

GPUB9 boards can work in active/standby mode. GPUB9 Board provides Memory for eCore 
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9300. The memory provides DDR3 memory channels with capacity of 128 GB. The Storage 

for the board is equivalent to two 800 GB 2.5-inch SSD disks. 

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c,

20. OSTA5.0 supports host software (i.e., computer program code) which 

provides resource management. 

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c
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21. eCore product series include the MME, EPC-UGW, HSS, PCRF and another 

necessary service NEs. 

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c

22. EPC with eNodeB is an S1-C interface. 

https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01

23. Transport resource overload control occurs at S1 Interface. 
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https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01

24. Huawei eCore9300 with EPC supports Transport resource preemption. 

Transport Resource preemption allows higher priority services to preempt lower-priority 

services. (i.e., manage transport network resources).

https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01
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https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01

25. EPC connects with base stations through S1-C interface. EPC receives 

transport resource information which is in use for transport resource preemption. See below 

(i.e., receive transport capacity information on a transport network in a radio system)

https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c
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26. The eCore9300 uses Huawei OSTA5.0 (3 U) as the hardware platform. The 

OSTA5.0 comprises GPUB9 Board as a service component. GPUB9 board has CPU which 

uses Intel Broadwell-EP Xeon E5-2600 v4 CPUs (i.e., processor) as service processing units. 

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c

27. The eLTE Architecture consists of DBS3900 Distributed Base Station which 

allows radio access on small to large eLTE wireless private network that provides services 

like video surveillance, data acquisition, etc. The Base station consists of a baseband unit and 

a remote radio unit. 
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https://e.huawei.com/en/products/wireless/elte-trunking/network-element/dbs3900

28. The baseband unit is connected with a remote unit that receives and transmits 

signals. 

https://www.scribd.com/document/203697649/Dbs3900-Lte-Product-Description, 

29. Different RRUs are used depending upon the storage and coverage area. For 

example, RRU3928 is configured with BBU3900 in DBS3900 as shown in Error! Reference 

source not found.. 
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https://www.scribd.com/doc/97584371/RRU3928-Description-V1-2

30. RRU 3928 is an outdoor remote radio unit and has a 3928 dual-transmitter 

(i.e., radio transmission) and dual-receiver structure (i.e., radio reception) which supports 

higher output power and carrier capacity. 

https://www.scribd.com/doc/97584371/RRU3928-Description-V1-2
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31. Huawei accused product architecture comprises a connection between 

eNodeB and eCore. eCore9300 comprises Host Software which provides resource 

management (i.e., a radio resource management unit configured to manage the radio resources 

between at least one base station and the user equipment). eCore in combination with Host 

Software receives the capacity associated with base stations. (i.e., configured to receive radio 

capacity information on the radio cell). 

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c

https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c161c

32. EPC in eCore Architecture provides transport resource management. (i.e., 

transport resource management unit). S1 is the interface between EPC and eNodeB. Transport 

capacity is regularly measured on the interface (i.e., transport capacity limit for a radio cell 
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based on the transport capacity information). If the transport capacity is exceeding, network 

resources are overloaded, the eNodeB releases the services that can be preempted and have 

low priorities to ensure the quality of the high priority services (i.e., signal the transport 

capacity limit to at least one base station to adjust the radio capacity information based on the 

transport capacity limit). .

https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01

https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01
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https://www.scribd.com/doc/298261608/Transport-Resource-Management-ERAN-8-1-01

33. Hence, once the capacity is changed, the newly adjusted radio resource 

capacity is sent to host software to provide resource management again for the eCore 

Architecture (i.e., to signal the adjusted radio capacity information to the radio resource 

management unit to manage radio resources of the radio network by using the signaled 

adjusted radio capacity information). 

34. In view of preceding paragraphs, each and every element of at least claim 22

of the ’512 Patent is found in the Accused Products.

35. Huawei has and continues to directly infringe at least one claim of the ’512

Patent, literally or under the doctrine of equivalents, by making, using, selling, offering for 

sale, importing, and/or distributing the Accused Products in the United States, including 

within this judicial district, without the authority of Brazos.
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36. Huawei has received notice and actual or constructive knowledge of the ’512

Patent since at least the date of service of this Complaint.

37. Since at least the date of service of this Complaint, through its actions, 

Huawei has actively induced product makers, distributors, retailers, and/or end users of the 

Accused Products to infringe the ’512 Patent throughout the United States, including within 

this judicial district, by, among other things, advertising and promoting the use of the Accused 

Products in various websites, including providing and disseminating product descriptions, 

operating manuals, and other instructions on how to implement and configure the Accused 

Products. Examples of such advertising, promoting, and/or instructing include the documents 

at:

• https://e.huawei.com/us/solutions/business-needs/wireless-privatenetwork/broadband-access-new

• https://e.huawei.com/se/material/wireless/mccs/1464e39cd04b4b29810f9575b59c

161c,

• https://www.scribd.com/doc/298261608/Transport-Resource-ManagementERAN-8-1-01,

• https://e.huawei.com/en/products/wireless/elte-trunking/network-element/dbs3900

• https://www.scribd.com/document/203697649/Dbs3900-Lte-Product-Description

• https://www.scribd.com/doc/97584371/RRU3928-Description-V1-2

38. Since at least the date of service of this Complaint, through its actions, Huawei

has contributed to the infringement of the ’512 Patent by having others sell, offer for sale, or 

use the Accused Products throughout the United States, including within this judicial district, 

with knowledge that the Accused Products infringe the ’512 Patent. The Accused Products are 

especially made or adapted for infringing the ’512 Patent and have no substantial noninfringing use. For example, in view of the preceding paragraphs, the Accused Products 

contain functionality which is material to at least one claim of the ’512 Patent.

JURY DEMAND

Brazos hereby demands a jury on all issues so triable.
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REQUEST FOR RELIEF

WHEREFORE, Brazos respectfully requests that the Court:

(A) Enter judgment that Huawei infringes one or more claims of the ’512 Patent 

literally and/or under the doctrine of equivalents;

(B) Enter judgment that Huawei has induced infringement and continues to 

induce infringement of one or more claims of the ’512 Patent;

(C) Enter judgment that Huawei has contributed to and continues to contribute 

to the infringement of one or more claims of the ’512 Patent;

(D) Award Brazos damages, to be paid by Huawei in an amount adequate to 

compensate Brazos for such damages, together with pre-judgment and post-judgment 

interest for the infringement by Huawei of the ’512 Patent through the date such judgment 

is entered in accordance with 35 U.S.C. §284, and increase such award by up to three times 

the amount found or assessed in accordance with 35 U.S.C. §284;

(E) Declare this case exceptional pursuant to 35 U.S.C. §285; and

(F) Award Brazos its costs, disbursements, attorneys’ fees, and such further and 

additional relief as is deemed appropriate by this Court.

Dated: June 17, 2020 Respectfully submitted,

/s/ James L. Etheridge

James L. Etheridge

Texas State Bar No. 24059147 

Ryan S. Loveless

Texas State Bar No. 24036997 

Travis L. Richins

Texas State Bar No. 24061296

ETHERIDGE LAW GROUP, PLLC

2600 E. Southlake Blvd., Suite 120 / 324
19

Southlake, Texas 76092

Telephone: (817) 470-7249

Facsimile: (817) 887-5950

Jim@EtheridgeLaw.com

Ryan@EtheridgeLaw.com

Travis@EtheridgeLaw.com

COUNSEL FOR PLAINTIFF