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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

PLAINTIFF COBBLESTONE WIRELESS, LLC’S RESPONSE TO DEFENDANT’S

CELLCO PARTNERSHIP DB/A VERIZON WIRELESS’S COUNTERCLAIMS

Plaintiff Cobblestone Wireless, LLC (“Cobblestone” or “Plaintiff”) hereby answers the 

Counterclaims of Cellco Partnership d/b/a Verizon Wireless (“Verizon” or “Defendant”), as 

follows:

THE PARTIES

1. Admit.

COBBLESTONE WIRELESS, LLC, 

Plaintiff, 

v. 

CELLCO PARTNERSHIP d/b/a VERISON

WIRELESS

Defendant.

CASE No. 2:23-cv-00382-JRG-RSP

(LEAD CASE)

JURY TRIAL DEMANDED

COBBLESTONE WIRELESS, LLC, 

Plaintiff, 

AT&T SERVICES INC.; et al.

Defendants.

Case No. 2:23-cv-00380-JRG-RSP

(Member Case)

COBBLESTONE WIRELESS, LLC, 

Plaintiff, 

v. 

T-MOBILE USA, INC.

Defendant.

Case No. 2:23-cv-00381-JRG-RSP

(Member Case)

Case 2:23-cv-00382-JRG-RSP Document 31 Filed 11/22/23 Page 1 of 6 PageID #: 150
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2. Admit.

JURISDICTION AND VENUE

3. Admit that Defendant’s counterclaims arise under the patent laws of the United 

States and that Defendant seeks certain declaratory relief. Deny that Defendant is entitled to any 

such relief. Deny any other allegations in this paragraph.

4. Admit that Defendant’s counterclaims arise under the patent laws of the United 

States and that Defendant seeks certain declaratory relief. Deny that Defendant is entitled to any 

such relief. Deny any other allegations in this paragraph.

5. Admit.

6. Admit that venue is proper in this district. Deny any other allegations in this 

paragraph.

7. Admit that there is a case or controversy between the parties concerning alleged 

infringement of the Patents-in-Suit. Deny any other allegations in this paragraph.

8. Admit that there is a case or controversy between the parties concerning alleged 

infringement of the Patents-in-Suit. Deny any other allegations in this paragraph.

FIRST COUNTERCLAIM DECLARATION OF NON-INFRINGEMENT OF U.S. 

PATENT NO. 7,924,802

9. Plaintiff realleges Paragraphs 1-8 as though fully set forth herein.

10. Admit that Plaintiff’s allegations in its Complaint speak for themselves. Deny any 

other allegations in this paragraph.

11. Admit that Defendant denies that it infringes the ’802 Patent. Deny any other 

allegations in this paragraph.

12. Denied.

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13. Admit that Defendant denies that it infringes the ’802 Patent. Deny any other 

allegations in this paragraph.

14. Admit that there is a case or controversy between the parties concerning alleged 

infringement of the ’802 Patent. Deny any other allegations in this paragraph.

15. Denied.

16. Denied.

SECOND COUNTERCLAIM DECLARATION OF INVALIDITY OF U.S. 

PATENT NO. 7,924,802

17. Plaintiff realleges Paragraphs 1-16 as though fully set forth herein.

18. Admit that Defendant alleges that the ’802 Patent is invalid. Deny any other 

allegations in this paragraph.

19. Admit that there is a case or controversy between the parties concerning alleged 

validity of the ’802 Patent. Deny any other allegations in this paragraph.

20. Admit that there is a case or controversy between the parties concerning alleged 

validity of the ’802 Patent. Deny any other allegations in this paragraph.

PRAYER FOR RELIEF

WHEREFORE, Cobblestone prays for the following relief with respect to Defendant’s 

counterclaims:

A. A judgment in favor of Plaintiff on all counterclaims asserted by Defendants;

B. An adjudication that Defendants are not entitled to any relief on its counterclaims, 

including, without limitation, any fine or damages; and

C. A dismissal with prejudice of Defendants’ counterclaims;

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D. 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 

Defendant; 

E. Plaintiff’s costs of suit against Defendants; and

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

circumstances.

DEMAND FOR JURY TRIAL

Cobblestone demands a trial by jury on all issues so triable.

Dated: November 22, 2023 Respectfully submitted,

/s/ Reza Mirzaie

Reza Mirzaie 

CA State Bar No. 246953 

Marc A. Fenster 

CA State Bar No. 181067 

Neil A. Rubin 

CA State Bar No. 250761 

Amy E. Hayden

CA State Bar 287026

Jacob R. Buczko

CA State Bar No. 312773

Peter Tong

TX State Bar No. 2419042

Matthew D. Aichele

VA State Bar No. 77821

Christian W. Conkle 

CA State Bar No. 306374 

Jonathan Ma 

CA State Bar No. 312773

RUSS AUGUST & KABAT 

12424 Wilshire Boulevard, 12th Floor 

Los Angeles, CA 90025 

Telephone: 310-826-7474 

Email: rmirzaie@raklaw.com 

Email: mfenster@raklaw.com 

Email: nrubin@raklaw.com 

Email: ahayden@raklaw.com

Email: jbuczko@raklaw.com

Email: ptong@raklaw.com

Case 2:23-cv-00382-JRG-RSP Document 31 Filed 11/22/23 Page 4 of 6 PageID #: 153
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Email: maichele@raklaw.com

Email: cconkle@raklaw.com

Email: jma@raklaw.com

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CERTIFICATE OF SERVICE

The undersigned certifies that on November 22, 2023, all counsel of record who are 

deemed to have consented to electronic service are being served with a copy of this document via 

the Court’s CM/ECF system pursuant to Local Rule CV-5(a)(3)(A).

/s/ Reza Mirzaie_______

Reza Mirzaie

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