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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

TRANQUILITY IP LLC,

Plaintiff,

v.

TELLABS BROADBAND LLC,

Defendant.

C.A. No. 3:22-cv-1925

JURY TRIAL DEMANDED

PATENT CASE

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Tranquility IP LLC files this Original Complaint for Patent Infringement against 

Tellabs Broadband LLC and would respectfully show the Court as follows:

I. THE PARTIES

1. Plaintiff Tranquility IP LLC (“Tranquility” or “Plaintiff”) is a Texas limited 

liability company having an address at 7548 Preston Rd, Suite 141 PMB 1114, Frisco, TX 75034.

2. On information and belief, Defendant Tellabs Broadband LLC (“Defendant”) is a 

limited liability company with its principal place of business at 4240 International Parkway, Suite 

105, Carrollton, TX 75007. Defendant has a registered agent at National Registered Agents, Inc., 

1999 Bryan St., Suite 900, Dallas, TX 75201.

II. JURISDICTION AND VENUE

3. This action arises under the patent laws of the United States, Title 35 of the United 

States Code. This Court has subject matter jurisdiction of such action under 28 U.S.C. §§ 1331 

and 1338(a). 

4. On information and belief, Defendant is subject to this Court’s specific and general 

personal jurisdiction, pursuant to due process and the Texas Long-Arm Statute, due at least to its

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business in this forum, including at least a portion of the infringements alleged herein at 4240 

International Parkway, Suite 105, Carrollton, TX 75007.

5. Without limitation, on information and belief, within this state, Defendant has used 

the patented inventions thereby committing, and continuing to commit, acts of patent infringement 

alleged herein. In addition, on information and belief, Defendant has derived revenues from its 

infringing acts occurring within Texas. Further, on information and belief, Defendant is subject 

to the Court’s general jurisdiction, including from regularly doing or soliciting business, engaging 

in other persistent courses of conduct, and deriving substantial revenue from goods and services 

provided to persons or entities in Texas. Further, on information and belief, Defendant is subject 

to the Court’s personal jurisdiction at least due to its sale of products and/or services within Texas. 

Defendant has committed such purposeful acts and/or transactions in Texas such that it reasonably 

should know and expect that it could be haled into this Court as a consequence of such activity.

6. Venue is proper in this district under 28 U.S.C. § 1400(b). On information and 

belief, Defendant maintains its principal place of business in Texas at 4240 International Parkway, 

Suite 105, Carrollton, TX 75007. On information and belief, from and within this District 

Defendant has committed at least a portion of the infringements at issue in this case.

7. For these reasons, personal jurisdiction exists and venue is proper in this Court 

under 28 U.S.C. § 1400(b).

III. COUNT I

(PATENT INFRINGEMENT OF UNITED STATES PATENT NO. 8,272,037)

8. Plaintiff incorporates the above paragraphs herein by reference.

9. On September 18, 2012, United States Patent No. 8,272,037 (“the ‘037 Patent”) 

was duly and legally issued by the United States Patent and Trademark Office. The ‘037 Patent is 

titled “Flexible WLAN Access Point Architecture Capable of Accommodating Different User 

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Devices.” A true and correct copy of the ‘037 Patent is attached hereto as Exhibit A and 

incorporated herein by reference. 

10. Plaintiff is the assignee of all right, title and interest in the ‘037 patent, including 

all rights to enforce and prosecute actions for infringement and to collect damages for all relevant 

times against infringers of the ‘037 Patent. Accordingly, Plaintiff possesses the exclusive right 

and standing to prosecute the present action for infringement of the ‘037 Patent by Defendant.

11. The invention in the ‘037 Patent relates to the field of controlling access by a mobile 

terminal to a WLAN by accommodating for the particular capabilities of each mobile terminal and 

selecting accordingly the optimum available authentication mechanism. (Id. at col. 1:17-23). 

12. The context of the patented invention in the ‘037 Patent is wireless local area 

networks (“WLAN”) employing the IEEE 802.1X architecture with an access point that provides 

access for mobile devices to other networks, such as hardwired local area and global networks

such as the Internet. (Id. at col. 1:27-31). Because a public WLAN is relatively easy and low cost 

to implement and operate, it is an ideal access mechanism through which mobile wireless 

communication devices can exchange packet with an external entity. (Id. at col. 1:38-43). WLAN 

technology has resulted in publicly available hotspots (such as at cafes, restaurants, and libraries)

where a mobile device (such as your mobile phone or laptop computer) can access the Internet 

through an access point associated with a WLAN. (Id. at col. 1:32-38). However, such a public 

deployment can compromise security unless there are adequate means for identification and 

authentication of connected devices. (Id. at col. 1:43-46). 

13. When a mobile device incorporating an IEEE 802.1X protocol (“IEEE 802.1X 

client”) attempts to access a public WLAN or hotspot, the IEEE 802.1X client would begin the 

authentication process according to its current machine configurations. (Id. at col. 1:47-51). After 

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authentication occurs, the public WLAN opens a secure data channel to a mobile communications 

device to protect the privacy of data passing between the WLAN and the device. (Id. at col. 1:51-

54). Although many manufacturers of WLAN equipment have adopted the IEEE 802.1X protocol 

for deployed equipment, other devices using WLAN may use other protocols such as may be 

provided by wired electronic privacy (“WEP”). (Id. at col. 1:54-58). Unfortunately, the IEEE 

802.1X protocol was designed with a private LAN access as its usage model so the protocol does 

not provide certain features necessary for a public WLAN environment. (Id. at col. 1:60-64). For 

example, the IEEE 802.1X protocol does not have a sophisticated mechanism for interacting with 

users. (Id. at col. 1:65-col. 2:1). The access point can only send simple messages to the client 

using electronic access point notification. (Id. at col. 2:1-3). This may be sufficient for an 

enterprise setting but would be insufficient for a public hotspot. (Id. at col. 2:3-5). A public 

hotspot should therefore be able to accommodate different client and operator capabilities, based 

on which the WLAN should have the ability to select different authentication mechanism. (Id. at 

col. 2:25-28). The prior art does not sufficiently address how the systems would provide such 

capabilities. (Id. at col. 2:28-31). The invention in the ‘037 patent seeks to address the variation 

in authentication mechanisms by providing a method for controlling the access of a terminal device 

in a WLAN environment by determining whether a terminal device uses an IEEE 802.1X protocol. 

(Id. at col. 2:43-46).

14. Direct Infringement. Upon information and belief, Defendant has been directly 

infringing at least claims 9, 10, and 11 of the ‘037 patent in Texas, and elsewhere in the United 

States, by performing actions comprising at least performing the claimed method of controlling 

access by a user terminal in a wireless local area network by determining whether the user terminal 

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uses an IEEE 802.1X protocol using at least the Tellabs Flexsym Optical Network Terminal 205

(“Accused Instrumentality”) (e.g., https://www.tellabs.com/product/ont205). 

15. The Accused Instrumentality discloses a method for controlling access by a user 

terminal (e.g., user equipment) in a wireless local area network by determining whether the user 

terminal utilizes an IEEE 802.1x protocol. IEEE 802.1X is an IEEE Standard for port-based 

Network Access Control (PNAC). It provides an authentication mechanism to devices wishing to 

attach to a LAN or WLAN. The Accused Instrumentality determines whether the UE supports the 

IEEE 802.1x protocol by sending an EAP request and waits for response from the UE. If UE 

responds by authenticating itself using credentials before time out, then it is 802.1x compliant 

otherwise not.

(E.g., https://www.tellabs.com/product/ont205).

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(E.g., https://www.tellabs.com/product/ont205).

(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010428-

configuring-policy-via-radius-authenticationv4).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010428-

configuring-policy-via-radius-authenticationv4).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

(E.g., https://www.kareemccie.com/2017/01/mac-authentication-bypass.html).

16. Upon information and belief, the Accused Instrumentality is used in a method 

performing the step of an access point (e.g., authenticator) communicating to the user terminal 

(e.g., user equipment) a request (e.g., EAPoL request) to identify (e.g., to identify whether UE is 

a supplicant or not), and if the user terminal utilizes an IEEE 802.1x protocol, acknowledging the 

request to identify (e.g., when UE supports 802.1x, it authenticates itself using credentials), 

otherwise the access point determining that the user terminal is not IEEE 802.1x compliant and 

selecting an authentication mechanism (e.g., Mac Authentication Bypass or MAB) compatible 

with the user terminal.

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(E.g., https://www.tellabs.com/product/ont205).

(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010428-

configuring-policy-via-radius-authenticationv4).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

(E.g., https://www.kareemccie.com/2017/01/mac-authentication-bypass.html).

17. Upon information and belief, the access point determines that the user terminal is 

not IEEE 802.1x compliant when it does not receive an extensible authentication protocol identity 

(e.g., response to the EAPoL request) response packet after a timeout value.

(E.g., https://www.tellabs.com/product/ont205).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010428-

configuring-policy-via-radius-authenticationv4). 

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

(E.g., https://www.kareemccie.com/2017/01/mac-authentication-bypass.html).

18. Upon information and belief, the Accused Instrumentality is used in a method 

performing the step of the access point detects if the user terminal is not IEEE 802.1x compliant, 

then configuring an internet protocol packet filter (e.g., switch drops all the frames except the first 

frame to learn the MAC address) and redirecting a user request to a local server (e.g., 

authentication server).

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(e.g., https://networklessons.com/cisco/ccie-routing-switching-written/mac-authenticationbypassmab#:~:text=Once%20the%20switch%20has%20learned,you%20can%20with%20802.1X.). 

(E.g., https://www.tellabs.com/product/ont205).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010428-

configuring-policy-via-radius-authenticationv4).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

(E.g., https://www.kareemccie.com/2017/01/mac-authentication-bypass.html).

19. Upon information and belief, the Accused Instrumentality is used in a method 

performing the step of the access point transitions (e.g., from normal 802.1x authentication 

protocol after time out) to a state corresponding to browser based authentication (e.g., 

authentication using RADIUS protocol via MAB) protocol if the user terminal is not IEEE 802.1x 

compliant.

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(E.g., https://www.tellabs.com/product/ont205),

(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010428-

configuring-policy-via-radius-authenticationv4).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

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(E.g., https://docs.tellabs.com/articles/#!optical-lan-application-notes-publication/eng-010469-

mac-authentication-bypass).

(E.g., https://www.kareemccie.com/2017/01/mac-authentication-bypass.html).

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(e.g., https://networklessons.com/cisco/ccie-routing-switching-written/mac-authenticationbypassmab#:~:text=Once%20the%20switch%20has%20learned,you%20can%20with%20802.1X.). 

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(E.g., https://mikeguy.co.uk/posts/2018/06/understanding-nac-802.1x-and-mab/).

(E.g., https://www.cisco.com/c/en/us/support/docs/security-vpn/remote-authentication-dial-userservice-radius/12433-32.html).

(E.g., https://www.geeksforgeeks.org/radius-protocol/).

20. Defendant’s customers also infringe claims 9, 10, and 11 of the ‘037 patent by using 

or performing the claimed method using the Accused Instrumentality as described above. 

Furthermore, Defendant advertises, markets, and offers for sale the Accused Instrumentality to its 

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customers for use in a system in a manner that, as described above, infringes claims 9, 10, and 11

of the ‘037 patent. Exemplary materials are cited above.

21. Plaintiff has been damaged as a result of Defendant’s infringing conduct. 

Defendant is thus liable to Plaintiff for damages in an amount that adequately compensates 

Plaintiff for such Defendant’s infringement of the ‘037 patent, i.e., in an amount that by law cannot 

be less than would constitute a reasonable royalty for the use of the patented technology, together 

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

22. The asserted claims of the ‘037 Patent are method claims to which the marking 

requirements are not applicable. To the extent required, Plaintiff has therefore complied with the 

marking statute.

IV. JURY DEMAND

Plaintiff, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of 

any issues so triable by right.

V. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court find in its favor and against 

Defendant, and that the Court grant Plaintiff the following relief:

a. Judgment that one or more claims of United States Patent No. 8,272,037 have been 

infringed, either literally and/or under the doctrine of equivalents, by Defendant;

b. Judgment that Defendant account for and pay to Plaintiff all damages to and costs 

incurred by Plaintiff because of Defendant’s infringing activities and other conduct 

complained of herein;

c. That Plaintiff be granted pre-judgment and post-judgment interest on the damages 

caused by Defendant’s infringing activities and other conduct complained of 

herein;

d. That Plaintiff be granted such other and further relief as the Court may deem just 

and proper under the circumstances.

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August 31, 2022

OF COUNSEL:

David R. Bennett

Direction IP Law

P.O. Box 14184

Chicago, IL 60614-0184

(312) 291-1667

dbennett@directionip.com

NI, WANG & MASSAND, PLLC

/s/ Hao Ni

Hao Ni

8140 Walnut Hill Lane, Suite 500

Dallas, TX 75231

Telephone: (972) 331-4600

Email: hni@nilawfirm.com

Attorneys for Plaintiff Tranquility IP LLC

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