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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

CELLCO PARTNERSHIP d/b/a VERIZON 

WIRELESS

Defendant,

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

(Lead Case)

JURY TRIAL DEMANDED

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

AT&T SERVICES INC.; AT&T MOBILITY 

LLC; AT&T CORP., 

Defendants,

CASE NO. 2:23-cv-00380-JRG-RSP 

(Member Case)

JURY TRIAL DEMANDED

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

T-MOBILE USA, INC.,

Defendant,

CASE NO. 2:23-cv-00381-JRG-RSP 

(Member Case)

JURY TRIAL DEMANDED

––AND––

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

T-MOBILE USA, INC.,

CASE NO. 2:22-cv-00477-JRG-RSP 

(Lead Case)

JURY TRIAL DEMANDED

Case 2:23-cv-00382-JRG-RSP Document 86-1 Filed 01/12/24 Page 1 of 4 PageID #: 711
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Defendant, 

NOKIA OF AMERICA CORPORATION,

ERICSSON INC.

Intervenors.

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

AT&T SERVICES INC.; AT&T MOBILITY 

LLC; AT&T CORP., 

Defendants,

NOKIA OF AMERICA CORPORATION,

ERICSSON INC.

Intervenors.

CASE NO. 2:22-cv-00474 -JRG-RSP 

(Member Case)

JURY TRIAL DEMANDED

COBBLESTONE WIRELESS, LLC,

Plaintiff,

v.

CELLCO PARTNERSHIP d/b/a VERIZON 

WIRELESS

Defendant,

NOKIA OF AMERICA CORPORATION,

ERICSSON INC.

Intervenors.

CASE NO. 2:22-cv-00478 -JRG-RSP 

(Member Case)

JURY TRIAL DEMANDED

DECLARATION OF REZA MIRZAIE IN SUPPORT OF PLAINTIFF’S OPPOSITION 

TO MOTION TO CONSOLIDATE

Case 2:23-cv-00382-JRG-RSP Document 86-1 Filed 01/12/24 Page 2 of 4 PageID #: 712
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I, Reza Mirzaie, declare and state as follows:

1. I am a member of the State Bar of California, an attorney at the firm of Russ August 

& Kabat, and counsel of record for Plaintiff AlmondNet, Inc. in the above-captioned action. I 

submit this declaration in support of Plaintiff’s Opposition to Motion to Consolidate. I have 

personal knowledge of the facts set forth herein, and if called upon to testify, could and would 

testify competently thereto.

2. In Cobblestone’s infringement contentions served on March 13, 2022, the accused 

products in the Carrier 1 cases include (1) cellular base stations that support 3GPP 5G NR 

beamforming, handover between 4G and 5G NR wireless networks, or directional Supplementary 

Uplink (SUL) and/or Bandwidth Adaptation functionality, (2) cellular user equipment and Wi-Fi 

gateway devices that supports 3GPP 5G NR beamforming, and (3) cellular handsets, tablets, or 

smartwatches that support Wi-Fi-only automatic updates.

3. In Cobblestone’s infringement contentions served on December 11, 2023, the 

accused products in the Carrier 2 cases include cellular base stations, mobile products, and services 

that support 3GPP carrier aggregation. 

4. During the parties’ meet and confers, Cobblestone made clear that it was amenable 

to putting the Carrier 2 cases on the same schedule as the Carrier 1 cases (rather than delaying the 

Carrier 1 cases eight months to put them on the same schedule as the Carrier 2 cases, which is 

what Defendants propose). Defendants rejected this proposal.

5. Defendants have not agreed to be bound by any decisions in the Samsung case.

6. The Carrier 1 and Carrier 2 cases were filed eight months apart. Trial in the Carrier 

1 cases is set for September 2024. Trial in the Carrier 2 cases is set eight months later in May 2025. 

In the Carrier 1 cases, the parties have completed certain claim construction disclosures, fact 

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discovery is underway and set to close in under four months, and expert discovery is set to close 

in under five months. The Carrier 2 cases are in the pleading stage and claim construction 

disclosures are not even set to begin until July (after the close of expert discovery in the Carrier 1 

cases). 

7. Discovery has been open in the Carrier 1 cases since April 2023 and is set to close, 

in May 2024. Defendants and Intervenors Ericsson and Nokia have responded to numerous 

interrogatories and have produced hundreds of thousands of pages of documents. The parties have 

engaged in multiple rounds of discovery correspondence. Cobblestone’s source code expert has 

conducted code reviewmultiple times. Discovery has just opened in the Carrier 2 cases. 

8. The Carrier 1 cases focus on mobile devices pertaining to 5G beamforming or wifionly automatic updates, while the Carrier 2 cases, focuses on mobile devices pertaining to 4G and 

5G carrier aggregation.

9. Defendants also have not identified any technical witnesses in Carrier 2 to date.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 12, 2023, at Los Angeles, California.

/s/ Reza Mirzaie

Reza Mirzaie

Case 2:23-cv-00382-JRG-RSP Document 86-1 Filed 01/12/24 Page 4 of 4 PageID #: 714