UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

LIONRA TECHNOLOGIES LTD.,

Plaintiff,

v.

FORTINET, INC., 

Defendant.

Case No. 2:23-cv-00206-JRG

 (Lead Case)

JURY TRIAL DEMANDED

LIONRA TECHNOLOGIES LTD.,

Plaintiff,

v.

CISCO SYSTEMS, INC., 

Defendant.

Case No. 2:23-cv-00207-JRG

 (Member Case)

AMENDED COMPLAINT FOR PATENT INFRINGEMENT 

AGAINST CISCO SYSTEMS, INC.

This is an action for patent infringement arising under the Patent Laws of the United States 

of America, 35 U.S.C. § 1 et seq., in which Plaintiff Lionra Technologies Limited (“Plaintiff” or 

“Lionra”) makes the following allegations against Defendant Cisco Systems, Inc. (“Defendant” or 

“Cisco”):

INTRODUCTION

1. This amended complaint arises from Cisco’s unlawful infringement of the 

following United States patent owned by Plaintiff, which relate to improvements in secure

computing systems: United States Patent No. 7,623,518 (“the ’518 Patent”) (the “Asserted 

Patent”).

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PARTIES

2. Plaintiff Lionra Technologies Limited is a private company limited by shares 

organized and existing under the laws of Ireland, with its principal place of business at The Hyde 

Building, Suite 23, The Park, Carrickmines, Dublin 18, Ireland. Lionra is the sole owner by 

assignment of all rights, title, and interest in the Asserted Patent, including the right to recover 

damages for past, present, and future infringement.

3. On information and belief, Defendant Cisco Systems, Inc. is a California 

corporation with its principal place of business at 170 West Tasman Drive, San Jose, California 

95134. Cisco is registered to do business in the State of Texas and may be served through its 

registered agent Corporation Service Company dba CSC – Lawyers Incorporating Service 

Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701. 

JURISDICTION AND VENUE

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

States Code. This Court has original subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 

1338(a).

5. This Court has personal jurisdiction over Cisco in this action because Cisco has 

committed acts within this District giving rise to this action and has established minimum contacts 

with this forum such that the exercise of jurisdiction over Cisco would not offend traditional 

notions of fair play and substantial justice. Cisco maintains several places of business within the 

State, including at 2250 East President George Bush Turnpike, Richardson, TX 75082. Cisco, 

directly and through subsidiaries or intermediaries, has committed and continues to commit acts 

of infringement in this District by, among other things, importing, offering to sell, and selling 

products that infringe the Asserted Patent. Cisco is registered to do business in the State of Texas, 

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and has appointed as their registered agent, Corporation Service Company d/b/a CSC – Lawyers 

Incorporating Service Company, 211 E. 7th Street, Suite 620, Austin, Texas 78701, for service of 

process.

6. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b). Cisco is 

registered to do business in Texas, and upon information and belief, Cisco has transacted business 

in this District and has committed acts of direct and indirect infringement in this District by, among 

other things, making, using, offering to sell, selling, and importing products that infringe the 

Asserted Patent. Cisco has regular and established places of business in this District, including at 

2250 East President George Bush Turnpike, Richardson, TX 75082.

COUNT I

INFRINGEMENT OF U.S. PATENT NO. 7,623,518

7. Plaintiff realleges and incorporates by reference the foregoing paragraphs as if fully 

set forth herein.

8. Plaintiff owns by assignment all rights, title, and interest, including the right to 

recover damages for past, present, and future infringement, in U.S. Patent No. 7,623,518, titled 

“Dynamic access control lists.” The ’518 Patent was duly and legally issued by the United States 

Patent and Trademark Office on November 24, 2009. The ’518 Patent is valid and enforceable. 

A true and correct copy of the ’518 Patent is attached hereto as Exhibit 1. 

9. Cisco makes, uses, offers for sale, sells, and/or imports certain products, including 

without limitation Cisco Secure Network Servers 3415, 3495, 3715, 3755, and 3795 running 

Identity Services Engine (ISE) and ISE Virtual appliances in combination with Cisco Catalyst 

platforms (e.g., 3650, 3850, 9300, 9500, 9800) (the “Accused Products”), that directly infringe, 

literally and/or under the doctrine of equivalents, one or more claims of the ’518 Patent. 

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Identification of the accused products will be provided in Plaintiff’s infringement contentions 

pursuant to the Court’s scheduling order.

10. The Accused Products satisfy all claim limitations of one or more claims of the ’518

Patent. A claim chart comparing exemplary independent claim 15 of the ’518 Patent to 

representative Accused Products is attached as Exhibit 2.

11. By making, using, offering for sale, selling and/or importing into the United States 

the Accused Products, Cisco has injured Plaintiff and is liable for infringement of the ’518 Patent 

pursuant to 35 U.S.C. § 271(a).

12. Cisco also knowingly and intentionally induces infringement of one or more claims 

of the ’518 Patent in violation of 35 U.S.C. § 271(b). At least as of the filing and service of the 

original complaint on May 9, 2023, Cisco has knowledge of the ’518 Patent and the infringing 

nature of the Accused Products through, for example, the ’518 Patent claim chart served therewith. 

Despite this knowledge of the ’518 Patent, Cisco continues to actively encourage and instruct its 

customers and end users (for example, through user manuals and online instruction materials on 

its website and materials cited in Exhibit 2) to use the Accused Products in ways that directly 

infringe the ’518 Patent. For example, Cisco advertises the switching capabilities of the exemplary 

SNS-3715 with Catalyst 9300: 

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See Ex. 3 (https://www.cisco.com/c/en/us/products/collateral/switches/catalyst-9300-seriesswitches/nb-06-cat9300-architecture-cte-en.html). Cisco further advertises that packets are 

forwarded based on the dynamic access link: 

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Id. In addition, Cisco provides users with instructions on how to deploy Cisco’s Identity Services 

Engine (ISE) for wired network access, for example. See Ex. 4

(https://community.cisco.com/t5/security-knowledge-base/ise-secure-wired-access-prescriptivedeployment-guide/ta-p/3641515#toc-hId-1185473819). Cisco provides these instructions, user 

manuals, and other materials knowing and intending (or with willful blindness to the fact) that its 

customers and end users will commit these infringing acts. Cisco also continues to make, use, 

offer for sale, sell, and/or import the Accused Products, despite its knowledge of the ’518 Patent, 

thereby specifically intending for and inducing its customers to infringe the ’518 Patent through 

the customers’ normal and customary use of the Accused Products.

13. Cisco has also infringed, and continues to infringe, one or more claims of the ’518

Patent by selling, offering for sale, or importing into the United States, the Accused Products, 

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knowing that the Accused Products constitute a material part of the inventions claimed in the ’518

Patent, are especially made or adapted to infringe the ’518 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use. At least as of the filing and service of 

the original complaint, Cisco has knowledge of the ’518 Patent and the infringing nature of the 

Accused Products through, for example, the ’518 Patent claim chart served therewith. Cisco has 

been, and currently is, contributorily infringing the ’518 Patent in violation of 35 U.S.C. §§ 271(c) 

and/or (f). For example, Cisco’s Cisco Secure Network Servers 3415, 3495, 3715, 3755, and 3795 

running Identity Services Engine (ISE) and ISE Virtual appliances and/or Cisco Catalyst platforms 

(e.g., 3650, 3850, 9300, 9500, 9800) constitute a material part of the inventions claimed in the ’518

Patent, are especially made or adapted to infringe the ’518 Patent, and are not staple articles or 

commodities of commerce suitable for non-infringing use, as demonstrated by the evidence in 

Exhibit 2. 

14. On information and belief, Plaintiff (including its predecessors and any licensees) 

complied with 35 U.S.C. §287 during the relevant time period because Plaintiff, its predecessors, 

and any licensees did not make, offer for sale, or sell products that practice(d) the ’518 Patent 

during the relevant time period or were not required to mark during the relevant time period. 

15. As a result of Cisco’s direct infringement of the ’518 Patent, Plaintiff is entitled to 

monetary damages (past, present, and future) in an amount adequate to compensate for Cisco’s 

infringement, but in no event less than a reasonable royalty for the use made of the invention by 

Cisco, together with interest and costs as fixed by the Court.

16. As a result of Cisco’s indirect infringement of the ’518 Patent, Plaintiff is entitled 

to monetary damages (present and future) in an amount adequate to compensate for Cisco’s 

infringement, but in no event less than a reasonable royalty for the use made of the invention by 

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Cisco, together with interest and costs as fixed by the Court, accruing as of the time Cisco obtained 

knowledge of the ’518 Patent. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter:

a. A judgment in favor of Plaintiff that Cisco has infringed, either literally and/or 

under the doctrine of equivalents, the ’518 Patent;

b. A judgment and order requiring Cisco to pay Plaintiff its damages (past, present, 

and future), costs, expenses, and pre-judgment and post-judgment interest for Cisco’s infringement 

of the ’518 Patent;

c. A judgment and order requiring Cisco to pay Plaintiff compulsory ongoing 

licensing fees, as determined by the Court in equity.

d. A judgment and order requiring Cisco to provide an accounting and to pay 

supplemental damages to Plaintiff, including without limitation, pre-judgment and post-judgment 

interest and compensation for infringing products released after the filing of this case that are not 

colorably different from the accused products;

e. A judgment and order finding that this is an exceptional case within the meaning 

of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees against Cisco; and

f. Any and all other relief as the Court may deem appropriate and just under the 

circumstances.

DEMAND FOR JURY TRIAL

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

any issues so triable by right.

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Dated: December 4, 2023 Respectfully submitted,

/s/ Brett E. Cooper

Brett E. Cooper (NY SBN 4011011)

bcooper@bc-lawgroup.com

Seth Hasenour (TX SBN 24059910)

shasenour@bc-lawgroup.com

Jonathan Yim (TX SBN 24066317)

jyim@bc-lawgroup.com

Drew B. Hollander (NY SBN 5378096)

dhollander@bc-lawgroup.com

BC LAW GROUP, P.C. 

200 Madison Avenue, 24th Floor

New York, NY 10016 

Tel.: (212) 951-0100

Fax: (646) 293-2201

Attorneys for Plaintiff Lionra Technologies 

Limited 

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing document has been 

served on all counsel of record on December 4, 2023. 

/s/ Brett Cooper

Brett Cooper

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